diff --git a/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.md b/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.md
new file mode 100644
index 0000000000000000000000000000000000000000..cf8dbd3c270b06f1ac757dba20bf2bb45a75673f
--- /dev/null
+++ b/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.md
@@ -0,0 +1,50 @@
+Case 9:09-cv-80469-KAM Document 81 Entered on FLSD Docket 07/02/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE I|
+Plaintiff,
+CASE NO.: 09-80469-CIV-MARRA
+VS.
+JEFFREY EPSTEIN
+and
+Defendants.
+/
+PLAINTIFF'S COUNSEL'S RESPONSE TO COURT'S ORDER TO SHOW CAUSE
+Plaintiff's counsel responds to the Court's Order to Show Cause, and states:
+Plaintiff's counsel apologizes to the Court for a failure to finalize a Joint
+Scheduling Conference Report and Order and to file same with the Court in accordance
+with the Court's Order.
+The parties did exchange a number of drafts of the Joint Scheduling Report
+and proposed Order but despite efforts to finalize it did not do so. There was some delay
+in effecting service on Defendant
+who is believed to have been avoiding
+service, and this accounts for part of the delay in filing the Report and Proposed Order,
+although it certainly does not excuse it.
+The parties have been involved in settlement discussions for some time, and
+reached a resolution of the claims in this and the State court companion case this week,
+and all claims have been resolved. Defendant has filed a Joint Stipulation and proposed
+Order indicating the resolution of this case.
+
+
+Case 9:09-cv-80469-KAM Document 81 Entered on FLSD Docket 07/02/2010 Page 2 of 2
+Respectfully submitted,
+BY: s/ Isidro M.
+ISIDRO M.
+Florida Bar No. 437883
+LAW FIRM, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+Telephone: (561) 832-7732
+Telecopier: (561) 832-7137
+e-mail: isidrogarcia@bellsouth.net
+CERTIFICATE OF SERVICE
+¡ HEREBY CERTIFY that a true and correct copy of the foregoing was furnished VIA
+ECM TRANSMISSION to: Robert D. Critton, Esq. and Michael Pike, Esq., BURMAN
+CRITTON LUTTIER & COLEMAN, Counsel for Defendant EPSTEIN, 515 N. Drive, Suite
+400, West Palm Beach, Florida 33401 and to Bruce Reinhart, Esq., BRUCE REINHART,
+P.A., Counsel for Defendant
+_. 250 S. Australian Avenue, Suite 1400, West Palm
+Beach, Florida 33401 this 2nd day of July. 2010.
+BY:s/ Isidro M.
+ISIDRO M.
+2
diff --git a/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.receipt.json b/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1281dcef784541bb075b57c8e905aa1182cbd3ce
--- /dev/null
+++ b/vision-fixhub/court-01/d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "d9cb822212f3da16707a3693beec4ee05dc1b2ef8eef1ddae3b3fd29bd19e69f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fa206f08ab591dadf9ed5246fb76705bed6ac113d2d7f7cc56e7346aa697c2d0",
+  "output_sha256": "e18565350f1869573333f33ed21bbfce4e51c6b24ce28ee0a8152f8dad6c5c2a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.md b/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.md
new file mode 100644
index 0000000000000000000000000000000000000000..3f0d1d75b97ecf3ac51c43d87b0f1edfd0221ee1
--- /dev/null
+++ b/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.md
@@ -0,0 +1,151 @@
+503$818088-CV-80419aK Memesument 469-1 Entered on FLSD Docket 02/17/2010 Page 1 of 4
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documests in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+Jane Doe No. 2
+Plaintiff
+V.
+Civil Action No. 08-CV-80119-MARRA/JOHNSO
+Jeffrey Epstein
+Defendant
+(If the action is pending in another district, state where:
+R TO PRODUCE DOCUMENTS IN A CIV
+To: Alfredo Rodriguez
+11349 SW 86 Lane, Miami, FL
+c, and plade set f07 / 25/08 5:24pm
+below to testify at a
+eposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designang
+ne or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf /
+about the following matters, or those set forth in an attachment:
+Place: Kress Court Reporting
+1031 Ives Dairy Road, Suite 228, Bldg. 4
+North Miami, EL 33179.
+Date and Time:
+07/29/2009 11:00 am
+The deposition will be recorded by this method: Court Reporter and Videographer
+• Production: You, or your representatives, must also bring with you to the deposition the following documents,
+electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
+material:
+Any and all journals, notes, diaries, writings or other documents referring or relating to Jeffrey Epstein or events or
+incidents occurring at his residence located at 358 El Brillo Way, Palm Beach, Florida, including without limitation, the
+joumal you described to Palm Beach Police that contains names of girls who visited the residence.
+he provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Ru
+i (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, a
+attached.
+Date:
+07/24/2009
+CLERK OF COURT
+OR
+Signature of Clerk or Deputy Clerk
+The name, address, e-mail, and telephone number of the attorney representing (name of party)
+Mermelstein & Horowitz, P.A. - Adam D. Horowitz, Esq.
+18205 Biscayne Blvd., Suite 2218, Miami, FL 33160
+Tel: 305-931-2200 - email: ahorowitz@sexabuseattorney.com
+forney's signatu
+Jane Doe No. 2
+., who issues or requests this subpoena, are:
+
+A
+
+
+505258928008-CV-8QHerhantaAMhels@Aqument 469-1 Entered on FLSD Dpck 02/17/281209 Page 2 9f4
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
+Civil Action No. 08-CV-80119-MARRA/JOHNSO
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Cir. P. 45.)
+This subpoena for (name of individual and title, if any)
+was received by me on (dare)
+• 1 personally served the subpoena on the individual at (place)
+on (date)
+; or
+• I left the subpoena at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (dale)
+, and mailed a copy to the individual's last known address; or
+• I served the subpoena on (name of individual)
+, who is
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+• I returned the subpoena unexecuted because
+• Other (specify):
+_;or
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
+tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
+$
+My fees are S
+for travel and S
+for services, for a total of $
+I declare under penalty of perjury that this information is true.
+0.00
+Date:
+Server's signature
+Prinied name and title
+Server's address
+Additional information regarding attempted service, etc:
+
+
+508.3e12108-CV-80HekfanKsAM/melDacument 469-1
+Entered on FLSD Dacked 0.7!1742-07-9o0gPage 3 2f,4
+MERMELSTEIN & HOROWITZ PA
+ATTORNEYS AT LAW
+stuart S. Mermelstel
+Tel 305.931.2200
+Fax 305.931.0871
+ssm@sexabuseattorney.com
+18205 Biscayne Bivo
+Suite 221€
+Miami, Florida 33160
+www.sexabuseattorney.com
+July 24, 2009
+Via Process Server
+Alfredo Rodriguez
+11349 SW 86th Lane
+Miami, FL 33173
+Re: Jane Does v. Jeffrey Epstein
+Dear Mr. Rodriguez:
+As you are aware, your deposition has been rescheduled to July 29, 2009 at 11:00 a.m. dueto
+your car problems on the previously scheduled date of July 23, 2009. We will provide car service to
+ransport you to and from the deposition. The car will pick you up at 9:45 a.m. on Wednesday,
+July 29, 2009. Please review the witness and document subpoena you are being provided by the
+process server.
+Thank you for your attention to this matter.
+Very truly yours,
+Stuart S. Mermelstein
+SSM/Ir
+
+
+Case 9:08-cv-80119-KAM Document 469-1 Entered on FLSD Docket 02/17/2010 Page 4 of 4
+RETURN OF SERVICE
+UNITED STATES DISTRICT COURT
+MIAMI-DADE District of Florida
+Case Number: 08-CV-80119-MARRA/JOHNSO
+Plaintiff:
+JANE DOE NO. 2
+VS.
+Defendant:
+JEFFREY EPSTEIN
+For.
+Adam D Horowitz
+MERMELSTEIN & HOROWITZ P.A
+18205 Biscayne Bolevard
+Suite 2218
+Miami, FL 33160
+Received by MIAMI-DADE PROCESS, INC. on the 24th day of July, 2009 at 4:00 pm to be served on ALFREDO
+RODRIGUEZ, 11349 SW 86 LANE, MIAMI, FL
+I, RAFAEL (BUDA)
+do hereby affirm that on the 25th day of July, 2009 at 5:24 pm, I:
+Individually Served the within named person with a true copy of this SUBPEONA TO TESTIFY AT DEPOSITION
+OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION with the date and hour endorsed thereon by me, pursuant
+to State Statutes.
+I certify that I am over the age of 18, have no interest in the above action, and am a Process Server, in good
+standing, in the judicial circuit in which the process was served and have proper authority in the jurisdiction in which
+this service was made.. Under penalties of perjury, I declare that I have read the foregoing document and that the
+facts stated in it are true F.S. 92.525 Verification of documents.
+MIAMI-DADE PROCESS, INC.
+247 S.W. 8 Street # 293
+Miami, FL 33130-3513
+(786) 486-2832
+Our Job Serial Number: 2009001154
+Copyright © 1992-2006 Database Services, Inc. - Process Server's Toolbox VE.2w
diff --git a/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.receipt.json b/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fb0334c32b82c3c2b9d7cf366f93e41d70a12d84
--- /dev/null
+++ b/vision-fixhub/court-01/d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "d9cf963ec5a9b3326d8145d4ce8be22892837e950ffd0d83a4826f578fa28130",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "19d0b789cc9c0774e46636ea760b3c283d35f79b3ac8156e869d587b23f1d476",
+  "output_sha256": "115385966dcd2707386a39d5a21dcd9ffa8743abe522263e521137465231deeb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.md b/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.md
new file mode 100644
index 0000000000000000000000000000000000000000..3a4f1413640ab786c4f40c4e1a79afea905d7e21
--- /dev/null
+++ b/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.md
@@ -0,0 +1,23 @@
+Case 9:08-cv-80736-KAM Document 258 Entered on FLSD Docket 09/22/2014 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+SEP 22 2014
+STEVEN M. LARIMORE
+CLERK U. S. DIST. CT.
+S. D. of FLA. - W.P.B..
+ORDER
+THIS CAUSE is before the Court upon Petitioners' Motion to Seal their Response in
+Opposition to Epstein's Motion for a Protective Confidentiality Order (DE 250).
+It is hereby ORDERED and ADJUDGED that the Motion to Seal (DE 250) is DENIED.
+The Clerk of Court shall unseal DE 251. This Order shall not be sealed.
+DONE AND ORDERED in
+sat West Palm Beach, Palm Beach County, Florida,
+this 21" day of September, 2014.
+KENNETH A. MARRA
+United States District Court
diff --git a/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.receipt.json b/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..644b8250a46779cd76ffe144f28b3c4b3eb9a098
--- /dev/null
+++ b/vision-fixhub/court-01/d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
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+  "doc_id": "d9cfb773ab43486e65074e9a3b0db52f8780c2bc34ff16c777c941a63a0885cd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "35cb4e3550bd8577a65b50b30044f171604116ee10d4ab59eadd307df0a031f3",
+  "output_sha256": "f78562d61ff00d934c9bf8433a2f490bb2050255c0babd1999c03449bc788f40",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.md b/vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.md
new file mode 100644
index 0000000000000000000000000000000000000000..b53b8ff4411b3e2a7bc0b6b71b0765867d16281d
--- /dev/null
+++ b/vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.md
@@ -0,0 +1,89 @@
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 1 of 3
+•.
+•.
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+I, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A.,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+3.
+I represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida. (The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 2 of 3
+5.
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+6.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+7.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+Case 9:08-cv-80119-KAM Document 63-1 Entered on FLSD Docket 03/25/2009 Page 3 of 3
+The NPA expires in late 2010.
+FURTHER THE AFFIANT SAYETH NAUGHT,
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer oaths
+acknowledgments, personally
+appeared
+Jack A. Goldberger, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+executed the same, that ! relied upon the following form of identification of the
+above named person: Awon Personally
+_, and that an oath was/was
+not taken.
+this 4 day or han an fal 20 he county and Sal as adoreat.
+tary Public State of Flork
+LE Ros
+(SEAW EVER TOMBSO
+Petri
+NAME:
+KIn E RiSIN
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11|13/2009
+Page - 3 -
diff --git a/vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.receipt.json b/vision-fixhub/court-01/d9f8d9fb8e6bf9b3a3e2a554d18facbaa224b6e4aad7032eadd0b448bfc88587.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9bc3a1eb53f8bd2cfbf6990896296af5d5286dda
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "e230f59f16f2b6f7821ad3ce2e2b1d07e21412e34e7bb144e6182afc30dbe1ec",
+  "output_sha256": "acd41c2a55ecef668291daf438a547185e7138fb3e1e5e7bee75e914a3e710ab",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.md b/vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.md
new file mode 100644
index 0000000000000000000000000000000000000000..f1c4dbeb621bbaca96a202e84b2edfb65193a4bc
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@@ -0,0 +1,29 @@
+Case 1:19-cv-10577-LJL-DCF Document 50 Filed 05/08/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff,
+V.
+DARREN I. INDYKE and RICHARD D. KAHN
+in their capacities as the executors of the ESTATE
+OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+CASE NO. 1:19-CV-10577-LJL-DCF
+NOTICE OF APPEARANCE
+PLEASE TAKE NOTICE that the undersigned attorney hereby appears as counsel for
+defendants Darren |. Indyke and Richard D. Kahn, in their capacities as the Executors of the
+Estate of Jeffrey E. Epstein, in the captioned action. I certify that I am admitted to practice in
+this Court. All notices given or required to be given in this case shall be served upon the
+undersigned.
+Dated: New York, New York.
+May 8, 2020
+By:_Is/Valerie Sirota
+Valerie Sirota
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, NY 10022
+212.704.6000
+Valerie.Sirota@troutman.com
+Attorneys for Defendants
+To: All Counsel of Record (via ECF)
diff --git a/vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.receipt.json b/vision-fixhub/court-01/da3bd204d5f17284a17d61e9c58c702e8ad7b9a7d9f17b1886f26dd5c2243d74.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..66995611df7048ae44f4e955f5cc9688b360955b
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.md b/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.md
new file mode 100644
index 0000000000000000000000000000000000000000..2009e56825a0f62d34054246950ded4386afa72e
--- /dev/null
+++ b/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.md
@@ -0,0 +1,217 @@
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFF JANE DOE NO. 4'S MOTION FOR PROTECTIVE
+ORDER AGAINST SECOND DAY OF DEPOSITION OF PLAINTIFF
+EXTENDING PAST SEVEN HOURS IN THE AGGREGATE,
+AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 4, by and through undersigned counsel, hereby files this Motion
+for Protective Order Against Second Day of Deposition of Plaintiff Extending Past Seven Hours
+in the Aggregate, and Incorporated Memorandum of Law, as follows:
+Introduction
+Plaintiff Jane Doe filed a similar Motion for Protective Order on October 29, 2009
+seeking relief from Defendant taking her deposition for a second day. (DE 378). Plaintiff Jane
+Doe No. 4 seeks essentially the same relief limiting her deposition to seven hours, and,
+accordingly, Jane Doe No. 4 joins in Jane Doe's Motion for Protective Order. As discussed
+below, a deposition of Jane Doe No. 4 longer than seven hours in the aggregate would be
+contrary to Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K), and this Court's Consolidation Order.
+(DE 98).
+1
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 2 of 7
+Background
+2.
+Pursuant to Court Order, Plaintiff Jane Doe No. 4's deposition was taken on
+October 27, 2009.
+The deposition lasted from approximately 11:00 a.m. until 6:04 p.m.
+Defendant's counsel stopped his questioning at that time, stating that he had another
+appointment.
+3.
+Defendant has subsequently demanded that Jane Doe No. 4 appear for a second
+day of deposition. The parties have tentatively agreed that this second day of deposition will
+take place on November 17, 2009.
+4.
+Plaintiffs' counsel has calculated the aggregate time Jane Doe No. 4 has spent in
+deposition thus far, deducting time spent in breaks, and has determined that Plaintiff Jane Doe
+No. 4 has spent five hours and thirty five minutes in deposition. This calculation has been
+provided to Defendant's counsel, and has not been disputed.
+5.
+For the reasons set forth below, Jane Doe No. 4 should not be required to
+complete her deposition for a period longer than one hour and twenty five minutes. This will
+provide Defendant with an aggregate total of seven hours deposition time of Jane Doe No. 4.
+Discussion
+Rule 30(d)(1), Fed.R.Civ.P., provides a limit on the time that may be taken for a
+6.
+deposition:
+Unless otherwise stipulated or ordered by the court, a deposition is
+limited to one day of seven hours.
+The Court must allow
+additional time consistent with Rule 26(d)(2) if needed to fairly
+examine the deponent ...
+Consistent with Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K) provides that "lu]nless otherwise
+authorized by the Court or stipulated by the parties, a deposition is limited, under Fed.R.Civ.P.
+30(d) to one day of seven hours."
+2
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 3 of 7
+7.
+This one day, seven hour limit was waived under the Court's Consolidation Order
+for circumstances that are not present in the deposition of Jane Doe No. 4. Specifically, the
+Court's Order consolidating cases dated May 14, 2009 (DE 98) waives the seven hour limit so
+that the multiple Plaintiffs' attorneys in these cases may have an adequate opportunity to
+question witnesses with regard to each particular Plaintiff:
+For depositions, Local Rule 26.1K (limiting deposition time to one
+day of seven hours) is waived so as to allow each party an
+adequate opportunity to develop fully the record as it may relate to
+that party. However, this waiver shall not be construed as
+authority for any party to take unnecessarily long depositions, or
+abuse the process. Any abuses of this waiver shall result in the
+imposition of appropriate sanctions against the offending party.
+(Order, p. 4, 9l 8) (emphasis supplied).
+8.
+This waiver does not apply to the deposition of a Plaintiff taken by the Defendant.
+Defendant's counsel is the only attorney asking questions at this deposition. There are two other
+Plaintiffs' attorneys attending the deposition, one of which has appeared by telephone. It is
+unlikely that either of these Plaintiffs' attorneys will ask questions of Jane Doe No. 4 because
+nothing in the testimony indicates that their clients had any contact with Jane Doe No. 4.
+Plaintiffs' counsel may have some questions of Jane Doe No. 4 in the nature of clarification of
+testimony, but Jane Doe No. 4's counsel does not seek to use any part of Defendant's seven hour
+aggregate for purposes of those questions, which will be brief and be made at the end of the
+deposition.
+Separate and apart from the time limit for depositions under the federal and local
+rules, the questioning of Jane Doe No. 4 thus far has been argumentative, hostile, badgering and
+abusive.
+Substantial portions of the questioning have not related to any legitimate discovery
+purpose. For example, the first exhibit marked by Defendant's attorney at the deposition was the
+3
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 4 of 7
+Proposal for Settlement that Defendant's counsel served earlier in the case. Defendant's attorney
+badgered Jane Doe No. 4 regarding this Proposal for Settlement, questioning whether she
+received and understood Defendant's settlement proposal. Such a line of questioning is highly
+improper and plainly not designed to lead to admissible testimony or the discovery of admissible
+evidence. As another example, Jane Doe No. 4 testified early in her deposition that the first three
+massages approximately she gave to Jeffrey Epstein were not sexual and she did not remove any
+clothes. Beginning with approximately the fourth massage, during her junior year of high school
+when she was 16 years old, she was asked progressively to remove more clothes and engage in
+more activities of a sexual nature. Over approximately a two-year period, she would engage in
+massages in which she was naked and sexual activity occurred approximately twice a week
+during periods in which Epstein was in Palm Beach. She made it clear early in her testimony
+that she did not recall the exact dates in which these massages occurred. Despite this,
+Defendant's counsel engaged in flurries of identical questions demanding exact dates, berating
+and badgering the witness, on repeated occasions throughout the course of the deposition. As
+demonstrated by these examples, a substantial portion of the deposition thus far has consisted of
+abusive questioning and not legitimate discovery.'
+' There are other instances of abuse by Defendant's counsel at Jane Doe No. 4's deposition.
+S.D.Fla.L.R. 30.1(A)(5) defines abusive deposition conduct to include the following:
+Questioning that unfairly embarrasses, humiliates, intimidates, or
+harasses the deponent, or invades his or her privacy absent a clea
+tatement on the record explaining how the answers to suc
+questions will constitute, or lead to, competent evidence admissible
+at trial.
+At the present time, Plaintiff's attorneys have not yet received the copy of the transcript of Jane
+Doe No. 4's deposition taken on October 27, 2009. Upon receipt, Plaintiff's attorney will file the
+transcript to demonstrate the abusive practices engaged in by Defendant's attorney.
+4
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 5 of 7
+10. This is not a commercial case, in which the questioning must necessarily be
+focused on numerous complex commercial documents. In Dunkin Donuts, Inc. v. Mary's
+Donuts, Inc., 206 F.R.D. 518 (S.D.Fla. 2002), the Court allowed the Plaintiff to depose the
+Defendant's accountant and corporate representative for an additional seven hours because it was
+a complex commercial case involving seven years of commercial activity and 10,000 pages of
+documents. Id. at 522. See also Pace v. City of Palmetto, 2007 WL 470477 (S.D.Fla. 2007)
+(granting a party one hour additional deposition time because the deponent had not read
+documents in advance, and was taking an inordinate amount of time during the deposition to read
+documents). The nature of this case, for damages arising from sexual misconduct, does not
+warrant a deposition in excess of seven hours.
+11.
+Under Fed.R.Civ.P. 30(d)(1), S.D.Fla.L.R. 26.1(K) and the Court's Consolidation
+Order (DE 98), it is the Defendant's burden to demonstrate why more than seven hours of
+deposition time is necessary for a particular Plaintiff. Not only can Defendants not make such a
+demonstration, the deposition of Jane Doe No. 4 emphatically demonstrates that more than seven
+hours of deposition time would only provide Defendant with a license for abuse, which is plainly
+part and parcel of Defendant's strategy to intimidate and harass the Plaintiffs in these cases.
+12.
+Plaintiff Jane Doe No. 4 is willing to sit for a second day of deposition for a
+period of no longer than one hour and twenty five minutes, giving Epstein an aggregate of seven
+hours of deposition time. Under the circumstances, any more deposition questioning will clearly
+be abusive. This additional one hour twenty five minutes of deposition time is more than enough
+time for Defendant to complete any remaining legitimate questions of Jane Doe No. 4.
+WHEREFORE, Plaintiff respectfully requests a protective order consistent with
+Fed.R.Civ.P. 30(d)(I) and S.D.Fla.L.R. 26.1(K), as well as this Court's Consolidation Order,
+5
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 6 of 7
+providing Defendant with no more than an additional one hour and twenty five minutes of
+deposition time of Jane Doe No. 4, and for such other and further relief as this Court deems just
+and proper.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: November 3, 2009.
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on November 3, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Stuart S. Mermelstein
+6
+
+
+Case 9:08-cv-80119-KAM Document 392 Entered on FLSD Docket 11/03/2009 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+7
diff --git a/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.receipt.json b/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c6385a2335f93d0bf9b552f21dd4f72df67f308e
--- /dev/null
+++ b/vision-fixhub/court-01/da56a64d9ec3df7b9881afb88a082f304756a5ba96dca6829716599c16b75077.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "390f2a4683bb3d2b4f5a6f0c8e828a4f458e9f6844ccc40320668593a695598b",
+  "output_sha256": "d85b38ca6176121d0a0be3950c79d1cc22c30a804f55c04e88175152ee6cf996",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.md b/vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.md
new file mode 100644
index 0000000000000000000000000000000000000000..72ae393a38ba0f81b63d61607a2e731e1529a4f7
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+++ b/vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.md
@@ -0,0 +1,236 @@
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+VS.
+Defendant.
+JANE DOE NO. S,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/JOHNSON
+VS.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 2 of 9
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRAJ
+VS.
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+VS.
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 3 of 9
+VS.
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRAJ
+VS.
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+Defendant.
+MOTION TO RESCHEDULE HEARING
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 4 of 9
+COMES NOW Robert C. Josefsberg, as co-counsel for Jane Doe 101 and 102, and
+respectfully requests either a rescheduling of this Court's hearing (just rescheduled for June, 12,
+2009) or in the alternative, permission to appear by telephone at said hearing, on the following
+grounds:
+1) On Wednesday, June 10, 2009, undersigned counsel, his wife and two granddaughters
+will be traveling to Hanover, New Hampshire for counsel's 50* College Reunion, and an
+opportunity for his two high school granddaughters to visit colleges in the Northeast. Counsel is
+scheduled to return to South Florida on Tuesday, June 16".
+2) Counsel is very appreciative and supportive of the Court's scheduling a hearing on the
+Defendants' Motion to Stay. That hearing was scheduled (within the last 3 hours) for Friday,
+June 12" at 10:00 a.m., right in the middle of Robert Josefsberg's reunion visit.
+3) If Robert Josefsberg cannot attend, Jane Doe 101 and 102 will be well represented by
+co-counsel who can and will appear in person at said hearing on June 12, 2009. However,
+Robert Josefsberg is lead counsel and would prefer to be present during said hearing.
+4) In the event that this hearing cannot be rescheduled for June 4, 5, 8 or 9", or June 17",
+18"' or 19", Robert Josefsberg requests permission to appear at said June 12th hearing by
+telephone.
+WHEREFORE, Robert Josefsberg requests the relief requested above.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 5 of 9
+Dated May 29, 2009.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/ Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 6 of 9
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this _
+_ day of May, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 7 of 9
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+isx @searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 8 of 9
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+1, Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+
+
+Case 9:09-cv-80469-KAM Document 28 Entered on FLSD Docket 05/29/2009 Page 9 of 9
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
\ No newline at end of file
diff --git a/vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.receipt.json b/vision-fixhub/court-01/da64e9d43afe3e8d7b681d8da073314bb2def5909df3d1edebb687ad936c87c4.receipt.json
new file mode 100644
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
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+}
diff --git a/vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.md b/vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.md
new file mode 100644
index 0000000000000000000000000000000000000000..d0fe6caf23b28b0549e36b0d4cc156f0c547e3dd
--- /dev/null
+++ b/vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.md
@@ -0,0 +1,34 @@
+Case 9:08-CV-80381-KAM Document 9-1 Entered on FLSD Docket 06/13/2008 Page 1 of 2
+
+
+
+Case 9:08-cv-80381-KAM Document 9-1 Entered on FLSD Docket 06/13/2008 Page 2 of 2
+AFFIDAVIT OF RICHARD BARNETT
+I, Richard Barnett, being duly sworn, do depose and state as follows:
+2.
+I am over the age of 18, am otherwise competent to testify and
+base the following on my personal knowledge.
+On May 7, 2008, I received copies of the summons and complaint
+in four lawsuits:
+a. Jane Doe #2 v. Jeffrey Epstein, Case No. 08-CV-80119,
+b. Jane Doe #3 v. Jeffrey Epstein, Case No. 08-CV-80232,
+c. Jane Doe #4 v. Jeffrey Epstein, Case No. 08-CV-80380, and
+d. Jane Doe #5 v. Jeffrey Epstein, Case No. 08-CV-80381.
+I do not now, nor have I ever resided at 9 East 71st Street, New
+York, New York.
+FURTHER AFFIANT SAYETH NAUGHT.
+RICHARD BARNETT
+Sworn and subscribed before me
+this 12" day of June 2008 by
+Richard Barnett, who
+is personally known to me. f-or did provide
+s identificatior.
+intries
+NOTARY PUBL
+STATE OF NEWYOR!
+MY COMMISSION EXPIRES:
+LAUREN J. KWINTNER
+Notary Public, State of New York
+No. 02KW6016686
+Qualified in New York County
+Commission Expires November 30, 20 1°
diff --git a/vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.receipt.json b/vision-fixhub/court-01/da761627de879bbaf20c7825dd760042a1a5f791477bb0714f4646c627d2e224.receipt.json
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diff --git a/vision-fixhub/court-01/da8403b39be323f810f41cd1d35aa98d8219ba1fdb1f27a63ebc5a3c5af1c487.md b/vision-fixhub/court-01/da8403b39be323f810f41cd1d35aa98d8219ba1fdb1f27a63ebc5a3c5af1c487.md
new file mode 100644
index 0000000000000000000000000000000000000000..bb3e4ddc90e85f582839f8c34d1541d443a6890d
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@@ -0,0 +1,55 @@
+Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs
+V.
+UNITED STATES OF AMERICA,
+Defendant
+INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL
+PROTECTIVE ORDER
+Now comes Intervenor, Jeffrey Epstein, who moves that this Honorable Court
+issue a supplemental Protective Order that would expand the limited Protective Order
+allowed in its decision Granting in Part and Denying in Part the Intervenors' Motion for a
+Protective Confidentiality Order. [D.E. 255 at 4]. The purpose of the proposed
+supplement to the previously ordered Protective Order is to require that any party would
+be required to file under seal any portion of the plea negotiation correspondence between
+the Government and Epstein's counsel, whether offered as an exhibit or quoted from in
+the content of a pleading or motion. Such a redacted filing would in all other respects be
+filed as a public filing unless subject to other orders of the Court, and each party would
+reserve the right to move to unseal any redacted pleading or sealed exhibit. After
+consultation with their counsel, both the Plaintiffs and the Government do not oppose the
+allowing of this Motion.
+1
+
+
+Case 9:08-cv-80736-KAM Document 261 Entered on FLSD Docket 10/08/2014 Page 2 of 2
+Respectfully submitted,
+JEFFREY EPSTEIN
+By His Attorneys,
+Is/Roy Black
+Roy Black
+Jackie Perczek
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 So. Biscayne Blvd., Suite 1300
+Miami, Florida 33131
+Tele: (305) 371-6421
+Fax: (305) 358-2006
+rblack@royblack.com
+jperczek@royblack.com
+/sl
+G. Weinberg
+G. Weinberg
+20 Park Plaza, Suite 1000
+Boston, Massachusetts 02116
+Tele: (617) 227-3700
+Fax: (617) 338-9538
+owlmgw@att.net
+CERTIFICATE OF SERVICE
+I HERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this
+8** day of October, 2014.
+Is/Roy Black
+Roy Black
+2
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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diff --git a/vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.md b/vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.md
new file mode 100644
index 0000000000000000000000000000000000000000..cd16c984bbbca112158517dc4b98e683795961cb
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+++ b/vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.md
@@ -0,0 +1,173 @@
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+AND MEMORANDUM IN SUPPORT THEREOF
+(AS TO CMA v. EPSTEIN AND |
+- 08-CIV-80811)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order allowing him to attend mediation in the above-styled
+matter and as grounds set forth would state:
+The Court entered a no contact order which may apply to Carolyn
+Andriano, [DE 238].
+Plaintiff's counsel and plaintiff,
+have no objection to Mr.
+Epstein attending deposition, mediation and obviously trial.
+3.
+Therefore, Defendant, Jeffrey Epstein, in an abundance of caution,
+requests that the court enter the attached proposed Agreed Order which shall not
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 2 of 4
+Page 2
+preclude him from attending Plaintiff
+trial of this case.
+deposition, mediation, or the
+Rule 7.1 Certification
+Defense counsel has spoken with Plaintiff's counsel and he has no objection to
+the entry of the proposed agreed order.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 20 day of _November_ 2009
+Respectfully submitted,
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 3 of 4
+Page 3
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos.
+08-80069, 08- Paul G. Cassell, Esq.
+80119, 08-80232,
+08-80380, 08-80381, Pro Hac Vice
+08-80993, 08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A
+801-585-6833 Fax
+2290 10* Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+, Esa.
+Counsel for Plaintiff in Related Case No.
+Searcy
+Denney
+Scarola Barnhart & 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+
+
+Case 9:08-cv-80381-KAM Document 134 Entered on FLSD Docket 11/20/2009 Page 4 of 4
+Page 4
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.receipt.json b/vision-fixhub/court-01/dab5cc39d15579828fe99ff7ba599bc2ee4ef8d960e8f4fd4827662521a77117.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/dae6f98bcf59efa220b28c69ab3413e2699907b672e449bfe9ee6ebf91e0824f.md b/vision-fixhub/court-01/dae6f98bcf59efa220b28c69ab3413e2699907b672e449bfe9ee6ebf91e0824f.md
new file mode 100644
index 0000000000000000000000000000000000000000..54a1856e26c2f0daeb980b9cfe6aa7940875d29d
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@@ -0,0 +1,197 @@
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpsuchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans de Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents another
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
+shame and retraumatization.
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintiffs do not hold their heads high with pride for having been sexually
+controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
+typical adolescent, into late adolescence and early adult years in the best of
+circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+1
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintiffs as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a defensive means to manage overwhelming affects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+(C7) in their social, educational, vocational, relational plans. They are hypervigilant
+(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
+Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims'
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
+residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 4 of 5
+plaintiffs" identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80469-KAM Document 34-1 Entered on FLSD Docket 06/08/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely,
+Babel Kina 1D
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN <
+Сомм.# 1791115
+NOTARY PUBLIC-CALIFORNIA
+ÔTY & COUNTY OF SAR FRANCISCO
+Mr Covu. Exp. FEB. 27, 2012
+State of California, City & County of San Francisco
+Subscribed and sworn to (or affirmed) before me on this
+do more, by Gilbert Kinceeu
+proved to me on the basis of sailsfactory evidence
+i do no need a lockde .
+5
diff --git a/vision-fixhub/court-01/dae6f98bcf59efa220b28c69ab3413e2699907b672e449bfe9ee6ebf91e0824f.receipt.json b/vision-fixhub/court-01/dae6f98bcf59efa220b28c69ab3413e2699907b672e449bfe9ee6ebf91e0824f.receipt.json
new file mode 100644
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+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "020a24894ce3a18250037fe418ebdd63d8bd5e80a7082fa040bd26bc59cbaf17",
+  "output_sha256": "cbac05011a6d5bb634b9ea937c7d306aa3dcfa88cdbe111a6d323240198867b1",
+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.md b/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.md
new file mode 100644
index 0000000000000000000000000000000000000000..3deec9642d4d8508627ef116c7d350fe203285d6
--- /dev/null
+++ b/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.md
@@ -0,0 +1,115 @@
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/C_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRAJ_
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:09-cv-80469-KAM Document 23 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A
+A.
+Villafaña
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-
diff --git a/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.receipt.json b/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..17352ca1df84829e95af2994ca10ddaa9f00eee6
--- /dev/null
+++ b/vision-fixhub/court-01/daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "daf5bf48cefd41a366de5cbaec568d064fd462893595143702eaa202e8979493",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ccc48fbafb8a9783e2f7973eb0b2bcd39693362c658fbb3fc3c3ba132c6ccada",
+  "output_sha256": "680d02f6c41f4bb7a7b6159746104878ffd57fd25697b46d521907cd4cdf1b4c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.md b/vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.md
new file mode 100644
index 0000000000000000000000000000000000000000..b04e9906fda0d90de3d584c7b291eb1a73fc7da4
--- /dev/null
+++ b/vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.md
@@ -0,0 +1,227 @@
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 1 of 4
+Page 308
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+Plaintiff,
+-VS-
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811,
+08-80893,
+09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+VOLUME III OF III
+/
+VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
+JANE DOE NO.
+4
+Tuesday, October 27, 2009
+11:11 - 6:05 p.m.
+250 Australian Avenue South
+Suite
+115
+West Palm Beach, Florida 33401
+Reported By:
+Cynthia I
+1, RPR, FPR
+Notary Public, State of Florida
+Prose Court Reporting
+(561) 832-7500
+cc1ec48b-651e-487e-Bbb1-b2f478ed0edd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 2 of 4
+Page 311
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+(561) 832-7500
+*****
+CONTINUED DIRECT EXAMINATION
+THE VIDEOGRAPHER: It is the beginning of
+Tape Number 3. We're back on the record at
+4:19.
+BY MR. LUTTIER:
+l. All right. When did you have your first
+abortion?
+A.
+Sixteen.
+l. Which would have been -- what year was
+that?
+A. I think it was, I don't remember, but I
+think it was when I was 16.
+l. Let's see, you were a senior --
+A.
+A sophomore.
+e.
+-- you were 17 when you were a senior,
+right?
+A.
+It might have been my sophomore or junior
+year. I don't remember.
+e.
+Sophomore or junior year in high school?
+A.
+Yeah.
+e. And where did you have that abortion?
+A. I don't remember what the place was
+called, The Pres -- Pres --
+l. Presidential Women's Clinic?
+PROSE COURT REPORTING AGENCY, INC.
+1(601-051-976-2934)
+cc1ec48b-651e-487e-Bbb1-b2t478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 3 of 4
+Page 312
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A.
+e.
+A.
+Yeah, I think so.
+Over on Congress Avenue?
+Yeah.
+And did you register under your real name?
+A.
+Yeah.
+e.
+Did anybody go with you?
+A. Yeah.
+Who?
+A.
+And who was the daddy of that baby?
+A.
+e.
+A.
+And who paid for it?
+A.
+Do you know what it cost?
+$300, I think.
+Was that the first time you were pregnant?
+A. Yeah.
+l. And would you agree with me, that age 16
+to have to go have an abortion was traumatic to you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+e.
+When was your second abortion?
+A.
+In my senior year in high school.
+That was when you were 17?
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+ce1ec48b-651e-487e-8bb1-b2f478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 443-1 Entered on FLSD Docket 12/29/2009 Page 4 of 4
+Page 313
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+was.
+(561) 832-7500
+A.
+e.
+A.
+Yes.
+And where did you get that one?
+Same place.
+You registered under your real name?
+A.
+Yes.
+l. Did anybody go with you?
+A.
+Yes.
+Who?
+A.
+Who was the daddy?
+A.
+e.
+A.
+Who paid for it?
+Now, I, I assume at some point in your
+life somebody explained to you what birth control
+A. Yeah.
+l. After you aborted one child, didn't you
+use birth control to keep from getting pregnant?
+A. Yeah, I did. I was using birth control.
+e. And so, obviously, if you had the baby,
+your first baby if you were pregnant at 16 --
+A. I wasn't using birth control then.
+MR. MERMELSTEIN: How about letting him
+finish. Let him finish.
+PROSE COURT REPORTING AGENCY, INC.
+ce1ec48b-651e-487e-Bbb1-b21478edOedd
\ No newline at end of file
diff --git a/vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.receipt.json b/vision-fixhub/court-01/db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e7b94463c5762d4b5be07139ee64a50c006a65fa
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@@ -0,0 +1,14 @@
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+  "byte_delta": -284,
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+  "doc_id": "db0a74843145c8e4d7e6fa7d0fe9fc342a95a8ece35e67239a3c7aafc2f35a21",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "42399591216ce44f753ed194cf3d47933ba27a10c554197917d001d415aa1fc9",
+  "output_sha256": "3746affe663f17a9c69e61be80f9811c8bf3783ad8494863be2c76348f451838",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.md b/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.md
new file mode 100644
index 0000000000000000000000000000000000000000..1f3332f4cfa1285c1bdae490186a547b0060db96
--- /dev/null
+++ b/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.md
@@ -0,0 +1,104 @@
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff.
+V.
+DARREN K INDYKE and RICHARD D. KAHN, in
+their capacities as executors of THE ESTATE OF
+JEFFERY E. EPSTEIN,
+Defendants.
+Case No. 1:20-cv-02365-LJL-DCF
+CO-EXECUTORS' STATEMENT ON PLAINTIFF'S
+APPLICATION TO PROCEED ANONYMOUSLY
+TROUTMAN PEPPER
+SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Tel: 212-704-6000
+Fax: 212-704-6288
+Attorneys for Defendants Darren K. Indyke and Richard D. Kahn,
+Co-Executors of the Estate of Jeffrey E. Epstein
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 2 of 5
+Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein (the "Co-Executors")', respectfully submit this Statement On Plaintiff Jane Doe's
+("Plaintiff") Application to Proceed Anonymously (ECF No. 31) (the "Application").
+I. The Co-Executors Have Never Opposed The Right Of Alleged Victims To Maintain
+Anonymity And Do Not Do So Here.
+The Co-Executors have never sought to prevent any alleged victim of Mr. Epstein from
+proceeding anonymously; they do not do so here. To the contrary, after Mr. Epstein's death, the
+Co-Executors established and funded in its entirety the independently administered Epstein
+Victims' Compensation Program, which gave Mr. Epstein's alleged victims the opportunity to
+resolve their claims in complete confidence if they so desired.? The Program ultimately awarded
+nearly $125 million to approximately 150 eligible claimants.?
+Nevertheless,
+in this unique situation, the Co-Executors have determined that it is
+appropriate to bring to the Court's attention material facts not contained in Plaintiff's Application,
+so that the Court can rule on it with the benefit of all relevant information, as follows: (1) Plaintiff
+(2) Plaintiff has,
+and (3) Plaintiff has
+' The captions in Plaintiff's Notice of Motion to Proceed Anonymously (ECF No. 29), Memorandum of Law in
+Support of Plaintiff's Application to Proceed Anonymously (ECF No. 31), and the Declaration of Daniel J. Kaiser
+(ECF No. 30) list more than two dozen defendants who are not parties to this action. Plaintiff's Complaint (ECF No.
+1), which has not been amended, was brought only against Darren K. Indyke and Richard D. Kahn, in their capacities
+as executors of the Estate of Jeffrey E. Epstein. Accordingly, this Statement is filed on behalf of the Co-Executors
+only.
+2 No claimant who participated in the Program is bound by any rules of confidentiality—to the contrary, they are free
+to tell their stories publicly.
+' See https://www.epsteinvep.com/documents/67.(The Declaration of Bennet J. Moskowitz, filed contemporaneously
+herewith, provides true and correct copies of all
+- 2-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 3 of 5
+Il.
+Plaintiff's
+As Plaintiff explains in her Application, when determining whether to permit a party to
+proceed under a pseudonym, the Second Circuit considers at least ten non-exhaustive factors
+pursuant to Sealed Plaintiff. Doe v. Zinsou, 2019 U.S. Dist. LEXIS 131520, at *7-8 (S.D.N.Y.
+Aug. 6, 2019) (Ramos, J.) (citing Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 188-89 (2d
+Cir. 2008)). Relevant to this discussion are the factors related to Plaintiff's identity.
+Plaintiff is
+and has
+In fact, Plaintiff's
+, as follows:
+This
+- 3-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35 Filed 08/13/21 Page 4 of 5
+Plaintiff also volunteered
+Plaintiff has also
+Plaintiff was also
+Accordingly, it is subject to judicial notice. See, e.g., Sharette v. Credit Suisse Int'l, 127 F.
+(ellipsis in original)).
+- 4-
+
+
+
+Case 1:20-cv-02365-LJL-DCF Document 35
+Filed 08/13/21
+
+Plaintiff
+III. Conclusion
+While the Co-Executors take no position on Plaintiff's Application to Proceed
+Anonymously, they believe the Court should decide it with the benefit of all relevant information.
+Dated: New York, New York
+August 13, 2021
+Respectfully submitted,
+TROUTMAN PEPPER |
+SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+By: _Is/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+- 5-
+
diff --git a/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.receipt.json b/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..80732d9c7e9d06674342ddbe8a8dcc0334abcf66
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+++ b/vision-fixhub/court-01/db28e5a6be31a5165704787d8b78e44475bbbbb9892b955596dd9ca8f3063034.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "997cd8ddfdd9430ba98388ed1bda77dcb17d38954abe1da427214be5ce4e3801",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/db467d68d53553387a1fca33ad1798b9c25350b20dac4e90bbf5adf3c0b834ba.md b/vision-fixhub/court-01/db467d68d53553387a1fca33ad1798b9c25350b20dac4e90bbf5adf3c0b834ba.md
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@@ -0,0 +1,547 @@
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+CASE NO: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 2 of 16
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+2
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 3 of 16
+CASE NO: 08-CV-80811-MARRA/
+C.M.A.,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/_
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/
+Plaintiff
+VS.
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 4 of 16
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/|
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST
+REQUEST FOR PRODUCTION
+Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant,
+Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove
+that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests
+production of a privilege log.
+Jane Doe has propounded 16 requests for production, including such
+straightforward requests as requests for production of:
+4
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 5 of 16
+Request No. 1: Copies of all telephone records;
+Request No. 2: Photos of the inside of your home located at 358 El Brillo Way,
+Palm Beach, Florida, that depict the rooms) where massages took place (including
+massage table).
+Request No. 10: Correspondence between Epstein and federal prosecutors;
+Request No. 12: Personal tax returns;
+Request No. 13: Photocopies of Epstein's passport;
+Request No. 14: A statement of net worth; and
+Request No. 16: Medical records.
+In response to each and every one of these requests, Epstein has given the
+following response (with only minor variations here and there):
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+This Court should order Epstein to provide all of the requested information or, in
+the alternative, prove that his Fifth Amendment invocations are valid. It is for the court,
+not the claimant, to determine whether the hazard of incrimination is justified. United
+States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a
+particularized inquiry, deciding, in connection with each specific area that the
+5
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 6 of 16
+questioning party wishes to explore, whether or not the privilege is well-founded." Id.
+Typically this is done in an in camera proceeding wherein the person asserting the
+privilege is given the opportunity "to substantiate his claims of the privilege and the
+district court is able to consider the questions asked and the documents requested by
+the summons." Id.
+Here Epstein has made boilerplate invocation of the Fifth Amendment to each
+and every request propounded by Jane Doe, including for example the request for
+correspondence with federal prosecutors and for production of federal tax returns. This
+obviously is not a request with Fifth Amendment implications, as the information has
+already been fully disclosed to the Government.
+For all these reasons, the Court should compel Epstein to answer the requests or
+provide a particularized justification for his Fifth Amendment invocation with regard to
+each request.
+Epstein's "cut and paste" response to the request for production also blatantly
+disregards the requirements for invoking privilege under the Court's local rules. Local
+rule 26.1.G very specifically requires the preparation of a privilege log with respect to all
+documents and oral communications (among other things) that are withheld on the
+basis of privilege. Epstein has failed to prepare such a log, making it impossible for
+Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few
+requests, Epstein has stated: "Further, the request may include information subject to
+work product or an attorney-client privilege." Of course, the whole purpose of forcing a
+defendant to prepare a privilege log is to force the defendant to decide whether or not
+6
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 7 of 16
+information is privileged. An assertion that something "may" be privileged is obviously
+woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a
+minimum) promptly required to produce a privilege log.
+For all these reasons, the Court should compel Epstein to provide a privilege log
+and to answer the interrogatories or provide a particularized justification for his Fifth
+Amendment invocation with regard to each request.
+It should be noted that (with minor exceptions) the only grounds on which Epstein
+can refuse to answer the request for production is proof of a valid Fifth Amendment
+privilege. This the only objection Epstein has asserted (with minor exceptions). As a
+result, any other objections to production are deemed waived. See Local Rule
+26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within the time
+provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be
+waived.").
+SPECIFIC REQUESTS FOR PRODUCTION
+For the convenience of the court - and in compliance with Local Rule 26.1 H
+(party filing motion to compel shall list specific requests in succession) - Jane Doe's
+requests for production and Epstein's objections are as follows:
+Request No. 1: Copies of all telephone records in your or your attorney's possession
+from 2002 through 2005 that in any way relate to you (including all phone lines owned
+by you or that were used to contact girls for the purposes of scheduling massages for
+you.)
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+7
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 8 of 16
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+: Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 2: All massage appointment books, diaries, computer calendars or
+scheduling entities, scheduling books or any other writing or correspondence that
+contains the names of any of the girls that were called, contacted, scheduled or who
+otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the
+purpose of giving you a massage.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 3: Any and all documentation in your possession that contains Plaintiff's
+name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message
+pads, diaries, appointment books, computer print outs).
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Filth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 4: Any and all photos, videos, downloaded digital prints or any other visual
+depiction of Plaintiff, or of any other known or suspected minor females introduced to
+you, directly or indirectly, by Plaintiff.
+8
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 9 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm
+Beach, Florida, that depict the rooms) where the massages too place (including
+massage table).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 6: Any and all documentation of cancelled checks or evidence of payment
+to Plaintiff of any kind and for any reason whatsoever.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+9
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 10 of 16
+Request No. 7: All discovery information obtained by you or your attorneys as a result
+of the exchange of discovery in the State criminal case against you or the Federal
+investigation against you.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse
+inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible to the terms of the deferred prosecution agreement, Federal
+Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.'
+Further, the
+request may including information subject to work product or an attorneyclient privilege.
+Request No. 8: All financial documents evidencing asset transfers from 2005 to present
+for you personally or any company or corporation owned by you.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+"Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this
+10
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 11 of 16
+Request No. 9: Any documents or other evidentiary materials provided to local, state,
+or federal law enforcement investigators or local, state or federal prosecutors
+investigating your sexual activities with minors.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 2
+Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 10: All correspondence between you and your attorneys and state or
+federal law enforcement or prosecutors (includes, but not limited to, letters to and from
+the States Attorney's office or any agents thereof).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing
+an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information
+sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+* Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of plea discussions, but rather for other purposes.
+These materials are also likely to lead to the
+discovery of other admissible evidence.
+To the extent that Epstein relies on the non-prosecution
+agreement, nothing in that agreement bars discovery of information relevant to this lawsuit.
+11
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 12 of 16
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 11: Any and all documents reflecting your current net worth.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 12: Personal tax returns for all years from 2002 through the present.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 13: A photocopy of your passport, including any supplemental pages
+reflecting travel to locations outside the 50 United States between 2002 and 2008,
+including any documents or records regarding plane tickets, hotel receipts, or
+transportation arrangements.
+" Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of correspondence in connection with plea discussions, but rather for other purposes. These
+naterials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein
+relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant
+to this lawsuit.
+12
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 13 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, 1 assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution. In addition to and without waiving his constitutional
+protections and privileges, the scope of information is so overbroad that it
+seeks information that is neither relevant nor reasonably calculated to lead
+to the discovery of admissible evidence; compiling such information over a
+six year period would be unduly burdensome and time consuming.*
+Request No. 14: A sworn statement of your net worth (including a detailed financial
+statement depicting all current assets and liabilities).
+Defendant is asserting his U.S. constitutional privileges. I intend to respond to all
+relevant questions regarding this lawsuit, however, my attorneys have counseled me
+that at the present time I cannot select authenticate, and produce documents relevant to
+this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution.
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution.
+Request No. 15: All financial statements or affidavits produced by you for any reason,
+to any person, company, entity or corporation since 2005.
+Defendant is asserting his U.S. constitutional privileges. 1 intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+* Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual
+purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is
+hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent
+or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from
+such intermediaries.
+13
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 14 of 16
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+CONCLUSION
+For all these reasons, the Court should compel Epstein to answer the request for
+production, or provide a particularized justification for his Fifth Amendment invocation
+with regard to each request. Epstein should also be required to provide a privilege log.
+Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this
+motion, and no resolution was possible.
+DATED July 10, 2009
+Respectfully Submitted,
+J.l
+J.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 54207:
+E-mail: bedwards@rra-law.com
+14
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 15 of 16
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 10, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+S/
+J.
+J.
+15
+
+
+Case 9:09-cv-80656-KAM Document 38 Entered on FLSD Docket 07/10/2009 Page 16 of 16
+SERVICE LIST
+Jane Doe V. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+16
\ No newline at end of file
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+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 1 of 32
+1
+.. D.C.
+THE UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA (FILED by_
+CASE NO. 08-80736-CIV-MARRA
+JUL 1 7 2008
+STEVEN M. LARIMORE
+CLERK US. DIST CT
+S. D. of FLA. - MIAMI
+IN RE: JANE DOE,
+Plaintiff,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORIGINAL
+JUL 1 8/2008
+STEVEN M. LARIMORE
+CLERK U.S. DIST. CT
+S.D. of FLA. - MIAMI
+./
+Federal Courthouse
+West Palm Beach, Florida
+July 11, 2008
+10:15 a.m.
+The above entitled matter came on for
+Emergency Petitioner for Enforcement of Crime Victim
+Rights before the Honorable Kenneth A. Marra,
+pursuant to Notice, taken before Victoria Aiello,
+Court Reporter, pages 1-32.
+For the Plaintiff:
+Esquire
+For the Defendant: Dexter Lee, AUSA
+Maria Villafana, AUSA
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 2 of 32
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+(Call to Order of the Court).
+THE COURT: Good morning. Please be seated.
+This is the case of In Re: Jane Doe, Case
+4
+Number 08-80736-Civ-Marra. May I have counsel state
+5
+their appearances, please?
+6
+MR. LEE: Good morning, Your Honor. May it
+7
+please the Court, for the United States of America,
+8
+9
+we have Maria Villafana, Assistant United States
+Attorney and Dexter Lee, Assistant United States
+10
+Attorney. And we have seated in the front row FBI
+11
+Special Agent Becker Kendall and Jason Richards.
+12
+13
+14
+15
+16
+Thank you, Your Honor.
+MR.
+: Good morning, Your Honor. Brad
+on behalf of the petitioners. Petitioners
+are also in the courtroom today. This petition is
+styled on her behalf.
+17
+18
+THE COURT: Good morning. All right. We're
+here on the petitioner's motion to enforce her
+19
+20
+21
+22
+rights as a victim under 18 USC 3771. I have
+received the petition, the government's response and
+the victim's reply, which was filed, I guess, this
+morning. So, You want to proceed, counsel?.
+23
+24
+MR.
+at the podium?
+: Yes, Your Honor. You prefer me
+25
+THE COURT: It is easier for us to hear you.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 3 of 32
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+MR.
+: Your Honor, as a factual
+background, Mr. Epstein is a billionaire that
+sexually abused and molested dozens and dozens of
+4
+girls between the ages of 13 and 17 years old. And
+5
+6
+through cooperating victims, that evidence can be
+proven. Because of his deviant appetite for young
+7
+8
+girls, combined with his extraordinary wealth and
+power, he may just be the most dangerous
+sexual
+9
+predator in U.S. history. This petitioner is one of
+10
+the victims and she is in attendance today. Another
+11
+one of Mr. Epstein's victims is also in attendance
+12
+13
+today. She would be able to provide evidence that
+she provided-- that Mr. Epstein paid her to provide
+14
+him over 50 girls for the purposes of him to
+15
+sexually abuse. Therefore, the undercurrents of the
+16
+petition are clear. The plea bargain that was
+17
+worked out for Mr. Epstein in light of the offenses
+18 that he committed is clearly unfair to the point
+19
+that if anybody looks at the information, it is
+20
+unconscionable.
+21
+THE COURT: Well, I mean, is that for me?
+22
+That's not my role. That's the prosecutor's role to
+23
+apply, would it not? I can't force them to bring
+24
+criminal charges. What do I have to do with that.
+25
+MR.
+: Okay.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 4 of 32
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+THE COURT: That may be your opinion, that
+may be your client's opinion, but I presume that the
+government is aware that that's your client's
+opinion. How does that change anything?
+MR.
+: That's my problem. I'm not
+sure that the government is aware that is
+petitioner's opinion and that's why we're here
+today, just to enforce the victim's rights under 18
+USC 3771, Crime Victims Rights Act, and all we are
+asking is to order that the plea agreement that has
+been negotiated in this case--
+THE COURT: How do you know there is a plea
+agreement? The plea agreement is with the State of
+Florida, wasn't it?
+MR.
+: There was a state charge with
+one victim that I'm aware of. And the plea
+agreement as to that one victim was 18 months in the
+county jail. But along with that, the Palm Beach
+County Sheriff investigating this case was getting
+no action out of the local authorities and sent this
+to the FBI.
+THE COURT: It was actually the Palm Beach--
+Town of Palm Beach Police, not the Sheriff's Office.
+MR.
+: I'm sorry, Judge. And that's
+why the FBI got involved because Michael Feeter
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 5 of 32
+5
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+wrote a scathing letter to the State Attorney about
+2
+Mr. Epstein receiving preferencial treatment by
+3
+local authorities.
+4
+Before the FBI took the case, they went
+5 behind the victim's back, and this is our motion,
+6
+without the victim's input and allowing her the
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+right to meaningfully confer with the government,
+which is a right that she can assert at this time.
+They worked out a plea deal where if Mr. Epstein
+would plead to this other charge regarding another
+victim in the state court case, they would agree to
+not prosecute him for all of the federal charges of
+what they were aware of in federal court..
+THE COURT: So that's already apparently
+taken place, correct?
+MR.
+: I don't know if it has taken
+place. I'm not sure exactly what stage it is in. I
+know it is supposed to be attached at some point in
+time to a state court plea.
+THE COURT: Hasn't he already plead guilty,
+though?
+25
+MR.
+: If he did plead guilty, it is
+my understanding and belief that the agreement with
+the federal government and with the U.S. Attorney's
+Office wasn't signed on that day. So it is still my
+
+
+Case 9:08-cV-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 6 of 32
+6
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+belief, I could be wrong, but that that agreement
+2
+hasn't been completed as of this time.
+3
+THE COURT: So let's assume it hasn't been
+4
+completed.
+5
+MR.
+: Okay. Then petitioner would
+6
+like the right to confer with--
+7
+THE COURT: You can go in the conference
+8
+room. We've got the FBI agents, you've got the
+9 assigned prosecuting attorney. You have got a
+10 conference room. You've got your client. Go and
+11
+talk. Confer. And then it is up government to
+12
+decide what to do, correct?
+13
+MR.
+: In a way, Your Honor, that's
+14
+very similar to what happened in In Re: |
+and PB
+15
+case where there is a plea agreement negotiated and
+16
+then the victim gets the right to confer.
+17
+THE COURT: It's already negotiated. What
+18
+am I supposed to do?
+19
+MR.
+: Order that the agreement that
+20
+was negotiated is invalid and it is illegal as it
+21
+did not pertain to the rights of the victim.
+22
+THE COURT: I can order you into the
+23
+conference room. Then the government can do what it
+24
+chooses. It can agree to prosecute or it can agree
+25
+to going forward with the agreement it had already
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 7 of 32
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+reached and after consulting your client and in
+taking into consideration your client's views,
+decide to go forward anyway. I can't make them
+prosecute him. I can't-- All I can do is, at best,
+say confer with the victim, consider the victim's
+input before you make a decision or reconsider the
+decision you already made in view of the victim's
+input, if it is possible for you to do that.
+So if
+I invalidate the agreement, what's the best you can
+get? The right to confer?
+MR.
+: Exactly. That is all we can.
+THE COURT: So why can't you go into the
+conference room now, take as much time as you feel
+you need and confer?
+MR.
+: Judge, at this time I'd like to
+move ore tenus to add the victim that's in the
+courtroom to this conference with the U.S.
+Attorney's Office.
+THE COURT: So is that Jane Doe 2 for
+purposes of this?
+MR.
+: Exactly, Your Honor.
+THE COURT: All right. Let me hear from the
+government then.
+MR. LEE:. Good morning, Your Honor. May it
+please the Court.
+
+
+Case 9:08-cV-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 8 of 32
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+Let me update the Court on the status of
+various matters.
+The agreement to defer prosecution
+to the State of Florida was signed and completed by
+December of 2007. Mr. Epstein's attorneys saught a
+higher review within the Department of Justice and
+it took a number of months for that to come to
+fruition. When it came to fruition, he ended up
+pleading guilty on June 30, 2008 to two charges in
+state court, and he was sentenced to a term of
+incarceration of 18 months, with another 12 months
+of community control after the completion of his
+sentence, and he is currently incarcerated as we
+speak.
+We have two arguments, Your Honor. First,
+insofar as the right that they claim under
+3771 (a) (5), their right to confer in the case, we
+respectfully submit that there was no case in
+federal court and, indeed, none was contemplated if
+the plea agreement was to be successfully completed,
+since it contemplated the State of Florida sentence
+on the criminal charges. So as long as certain
+conditions were met and certain federal interests
+were vindicated, the federal government was
+satisfied that this was an appropriate disposition.
+Insofar as the best effort, Your Honor, we
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 9 of 32
+9
+1
+have cited the Attorney General's guidelines.
+The
+2
+guidelines do say that you should normally advise
+3
+victims of plea negotiations and the terms of the
+4
+plea, but they recognize that there are times when
+5
+they may not be appropriate or could cause some harm
+6
+or prejudice, and they set out six factors which are
+7
+to be considered, non-exhaustive factors.
+8
+we have advised, in the declaration of AUSA
+9 Villafana that when the subject of having Mr.
+10
+Epstein concede that he would be convicted of an
+11
+enumerated offense for purposes of a cause of action
+12
+13
+under 18 USC 2255, there was a rather strenuous
+objection from Mr. Epstein's counsel that the
+14
+15
+federal government was inducing some effort to
+either fabricate claims, enhance claims or embellish
+16
+claims and if this agreement ultimately could not be
+17
+18
+consumated, then we'd have a federal prosecution on
+our hands, and we did not want to be in a positin of
+19
+creating additional impeachment material.
+20
+I can't say that the stand by Mr.
+21
+that the arguments of inducement in a subsequent
+22 civil action can be made by any criminal victim,
+23
+that is true. It is another thing for that
+24
+inducement to have come before the prosecution
+25
+arguing about the credibility and veracity of the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 10 of 32
+10
+1
+individual. That was a considerably strong point, in
+2
+essence,
+in not discussing those terms with the
+3
+victims as might ordinarily be done if those
+4
+considerations did not exist.
+5
+So, first, Your Honor, we believe that
+6
+3771 (a) (5) does not apply.
+7
+THE COURT:
+Well, what about the language in
+8
+the statute that suggests that a victim can bring a
+9 claim or seek enforcement of his or her rights under
+10 the statute before a case is filed? What does that
+11 refer to?
+12
+MR. LEE: Your Honor, we believe that's a
+13
+venue provision essentially telling an individual if
+14
+there is no exigent case, there is no case of United
+15
+States versus So And So, then you seek to enforce
+16
+your rights, then you can go in and do so in the did
+17
+18
+court where the offense occurred. This is not
+saying, necessarily, that rights exist, but if you
+19
+20
+believe they exist, here is the place where you're
+going to have to lodge it, and the Court will have
+21
+to decide.
+22
+Now, there are certain of the eight rights
+23
+accorded in 3771(a) that could come up before any
+24
+25
+charge is filed. For instance, let's say somebody
+believes that the perpetrator of the crime is going
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 11 of 32
+11
+to try to harm them or threatened them or
+intimidated them into not testifying or cooperating
+3 with the government and, of course, no indictment
+4
+has been returned. If an individual went to the
+5
+government and believed that the individual had not
+6
+7
+8
+acted appropriately, they can go to the district
+court and say I need to have my rights under
+3771 (a) (1) enforced because those people are
+9 threatening me, and the government hasn't done
+10 enough. That would be a situation.
+11
+But we're talking really here about (a) (5),
+12
+which is the right to consult in the case and we
+13
+respectfully submit that there is not case until a
+14
+charge has been filed.
+15
+16
+17
+18
+19
+20
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+THE COURT: So, what about the circuit case
+that was actually pending case had to do with a plea
+agreement in a pending case?
+MR. LEE: Yes. The distinction between the
+case and the instant case, Your Honor, is
+this. In
+, they had negotiated with BP
+Petroleum for a plea and it was always contemplated
+22
+23
+24
+25
+that there was going to be a federal prosecution.
+The distinction in this case was that there was
+already a pending state prosecution and the
+objective for both sides was to keep it in state
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 12 of 32
+12
+1
+court and the federal government's objective was to
+2
+ensure that there were sufficient safeguards in the
+3
+state court proceedings and concessions made by Mr.
+4
+Epstein so that federal interests, particularly a
+5
+cause of action for damages for the victims of the
+6
+sexual exploitation could be preserved. So that's
+7
+the key distinction because there was no federal
+8
+case, there was no federal criminal charge
+9
+contemplate so long as the agreement could be
+10 reached.
+11
+THE COURT: All right. So they want me to
+12
+invalidate your non-prosecution agreement.
+13
+MR. LEE: Your Honor, we respectfully submit
+14
+that 3771 does not grant authority of this Court to
+15
+do so. In the
+case, for instance, Your Honor,
+16
+there was a plea agreement that was entered into and
+17
+18
+district court, of course, entertained a plea
+agreement and exercised its judicial discretion in
+19
+terms of whether to accept it or not. The victims
+20
+were encouraged to go to district court and say, you
+21
+know, we didn't hear about this. We should have,
+22
+and we object to it for the following reasons. The
+23
+district court take that into account. There is no
+24
+plea agreement before this Court. There will be no
+25
+plea proceedings in this court. That was all done
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 13 of 32
+13
+1
+in state court several weeks ago. So that's another
+2
+basis for distinguishing
+3
+THE COURT: All right. So is there any
+4
+point in conferring with these victims?
+5
+MR. LEE: Your Honor, I will always confer,
+6
+7
+sit down with Jane Doe 1 and 2, with the two agents
+and Ms. Villafana. We'll be happy to sit down with
+8
+them.
+9
+THE COURT: But it wouldn't make any
+10 difference in terms of the outcome. Would maybe
+11
+give them the benefit of your explanation of why you
+12
+did what you did and why you came to the conclusion
+13 you did, but it is not going to change your decision
+14 in any way.
+15
+MR. LEE: If it is going to change, it would
+16
+have to be done at a level higher than mine, your
+17 Honor.
+18
+THE COURT: What was-- I didn't understand
+19
+your statement earlier that Mr. Epstein wanted some
+20 kind of review of higher authority within the
+21
+Department in terms of whether or not the federal
+22
+23
+24
+25
+government was going to insist on preserving any
+civil claims.
+MR. LEE: Your Honor, of the agreement was
+consumated by the parties in December of 2007. Mr.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 14 of 32
+14
+1
+Epstein's attorneys wanted a further review of the
+2
+agreement higher up within the Department of Justice
+3
+and they exercised their ability to do that.
+4
+THE COURT:
+Meaning? Again, I'm trying to
+5
+understand. He wasn't happy with the agreement that
+he had signed?
+7
+MR. LEE: Basically, yes. And was trying to
+8
+maintain that the agreement should be set aside or
+9
+more favorable terms.
+10
+THE COURT: Now, in terms of -- You don't
+11 dispute that Jane Doe 1 and 2-- First of all, do you
+12
+have an objection to Jane Doe 2 being added as a
+13
+petitioner in this case?
+14
+MR. LEE: No, I don't.
+15
+THE COURT: I'll grant that request.
+16
+You don't dispute that they're victims
+17
+within the meaning of the Act.
+18
+MR. LEE: It depends to which -- There is one
+19
+20
+Jane Doe-- Well, there is one individual who is one
+of Mr.
+' clients who we do not believe to
+21
+been a victim. If these are SN and CW, then we have
+22
+no objection and I can discuss-- If I may have a
+23
+moment, Your Honor.
+24
+Your Honor, thank you. I have been
+25
+corrected. We have no objection.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 15 of 32
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+THE COURT: |
+Okay.
+MR. LEE: We agree they're victims.
+THE COURT: Now, what is your position,
+then, regarding the right of a victim of a crime
+that is potentially subject to federal prosecution
+to be, to have input with the prosecutor, your
+office, before a resolution or decision not to
+prosecute is made? Do you say that there is no
+right to confer under those circumstances because
+there is no "case pending" so any decision not to
+prosecute, there is no right to confer but that
+right to confer only is triggered once there is an
+indictment or an information filed?
+MR. LEE: That is correct, Your Honor. The
+Attorney General guidelines which were published in
+May of 2005 provide that the rights in 3771(a) (1
+through 8) accrue when a charge is filed in federal
+18
+court. Now, that my change after the I
+19
+decision. It is under consideration. But that's
+20 the government's position.
+21
+THE COURT: Al1 right. And so -- Are you
+22 saying all of the rights--
+23
+24
+25
+MR. LEE: Your Honor, some of the rights
+clearly will only pertain after a charge has been
+filed. The one that pertains to notice of public
+
+
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+hearing, public proceedings, though, can't apply
+until there are public proceedings to be had.
+Of course, these guidelines are a floor and
+not a ceiling. They're to be applied with common
+sense.
+If somebody-- If charges of assault were
+being investigated and somebody would come in and
+say the perpetrator whom you're investigating is
+getting ready to indict has been threatening me,
+following me, and I need help because he or she is
+going to do something bad to me and try to take care
+of me before I can testify in the grand jury, this
+person would not be turned away because a charge
+hasn't been filed yet. Those guidelines would be
+applied with common sense.
+But specifically insofar as a (a) (5), which
+is the right to consult with the attorney for the
+government in the case, that would not accrue until
+there is a days. And, in our view, a case doesn't
+come into being until charges are filed.
+THE COURT: And are there any reported
+decisions that you are aware of where any court has
+found a right to confer before charges are filed?
+MR. LEE: I'm not aware of any, Your Honor.
+THE COURT: All right. Thank you.
+MR. LEE: Thank you, Your Honor.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 17 of 32
+17
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+THE COURT:
+Counsel?
+2
+MR.
+: I would just like to address
+3
+that
+decision. They're asking you that you
+4
+just simply ignore it because the decision clearly
+5
+was a decision made because as it is a direct result
+6
+of a plea deal being worked out prior to the victims
+7
+being able to speak.
+8
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+THE COURT: But there was a pending case,
+though, correct?
+MR.
+: As I understand the decision--
+THE COURT: As I understand the plea deal, it
+was negotiated prior to charges being filed. Then
+there was a filed case and then the court had the
+ability to accept the plea or not. And at that
+point, you would have the ability to entertain or
+assert an objection because you weren't consulted
+about the plea.
+So there was a proceeding or case in which
+you can assert a right to confer. How do you do
+that before a case is filed? How do you enforce the
+government or force the government to consult about
+not filing a case? Every case they have to consult
+with the victim before they decide not to prosecute?
+MR.
+: No, there are limitations. I
+think in my reply I refer to the case of U.S. V.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 18 of 32
+18
+1
+Rubin where they discussed that very scenario
+2
+stating there at least has to be criminal charges
+3
+contemplate by the government before these rights
+4
+kick in.
+The rights under (d) (3) and (a) (5), the
+5
+right to confer and the
+case clearly states
+6
+7
+clearly rights under the CBRA apply before
+prosecution is under way. Logically, this includes
+8
+the CBRA establishments of a victim's reasonable
+9 right to confer with the attorney for the
+10
+government. And, that's read in the plain reading
+11 of the statutes as well.
+12
+This first case in interpreting it, I think
+13
+14
+it's pretty clear the distinction they're making
+between BP and this case. Is it a distinction
+15
+16
+withoug a real difference in that the court is
+saying you have this right before the case is filed
+17
+which is exactly what we are saying. And the result
+18 in that case was they filed the case, later let him
+19
+plea out to some sweet deal. And in this case, what
+20
+we have is they avoid that by deciding not to file.
+21
+Either way, you deprive the victim of their right
+22
+before making that decision.
+23
+And the main problem that the court had in
+24
+, as it states, the victims do have rights when
+25
+there is an impact and the eventual sent is
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 19 of 32
+19
+1
+substantially less. Whereas here, their input is
+2
+received after the parties have reached a tentative
+3
+deal. Well, the government just stated the deal was
+4
+reached back in October of 2007. However, attached
+5
+to their response is a letter to my client
+6
+petitioner, dated January 10, 2008, after the time
+7
+then counsel just put on the record that the deal
+8
+was already finalized and it starts, the opening
+9 paragraph talks about whether they wanted the
+10 victims to have the right to confer. It says, this
+11
+case is currently under investigation. This is
+12
+January 2008. This case has been a lengthy process
+13
+and we request your continued patience while we
+14
+conduct a thorough investigation. Sounds like the
+15
+exact opposite of, we want you to come in and confer
+16
+and let us know what you really feel about this.
+17
+That is our biggest problem with what has
+18 happened here, is that she just wasn't given a voice
+19
+and if somebody would have heard her, we believe
+20
+there would have been a different outcome. To go
+21
+back into a room right now and talk, after there has
+22
+already been a plea negotiated without Your Honor
+23
+ordering that in this case the plea deal needs to be
+24
+25
+vacated, it is illegal and give her her rights.
+THE COURT: Well, would you agree or not
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 20 of 32
+20
+2
+3
+that Mr. Epstein plead guilty to the state charges
+probably at least, in part, in reliance upon the
+fact that he had an agreement with the federal
+4
+government they weren't going to prosecute? would
+5
+you concede that or would would present evidence to
+6
+that effect?
+7
+MR.
+: Of course we would. Yes, of
+8
+course. Sure.
+9
+THE COURT: So you agree that Mr. Epstein is
+10 now sitting in the Palm Beach County Jail a
+11
+12
+13
+convicted felon serving 18 months of imprisonment,
+at least in material part, because he relied upon
+the government's non-prosecution agreement?
+14
+MR.
+: Yes. I agree that he is sitting
+15
+there because he is guilty and maybe he took the
+16
+plea rather than going to trial and being found
+17
+18
+19
+20
+21
+22
+23
+24
+guilty later in part because of this non-prosecution
+agreement that was worked out behind the other
+victims' backs. I would agree with that.
+THE COURT: So he accepted the State's deal
+in part because he knew he had an agreement from the
+federal government that they weren't going to
+prosecute.
+MR.
+: I presume. I speculate that is
+25
+true.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 21 of 32
+21
+1
+THE COURT:
+So you want me now, then, to set
+2
+aside the government's agreement with him because
+3
+4
+there was no conferring, yet he has already accepted
+a plea agreement and is sitting in custody, in part,
+in reliance on that agreement. I mean, I can undo
+6
+the agreement in your theory, but how do I-- Mr.
+7
+Epstein, in a sense, would then be adversely
+8
+affected by my actions when he acted in reliance
+9 upon the agreement. How does that work?
+10
+11
+MR.
+: Certainly, we're only asking
+you to vacate the agreement. I understand and your
+12
+point is well taken. And I believe that at that
+13
+point in time his rights may kick in and say, wait,
+14 I was relying on this other deal so I wouldn't be
+15
+prosecuted for these hundreds of other girls that I
+16
+molested; that I plead guilty over here to the one
+17
+18
+19
+20
+21
+22
+23
+girl that I will admit to molesting. So maybe I can
+get to withdraw my plea. But the last thing he wants
+to do because if he ends up going to trial, I'll be
+in prison for the rest of his life like any other
+person who ever did this crime would be. He could
+have that argument, I guess, but still wouldn't
+really work well for him.
+24
+25
+THE COURT: All right. So you still think I
+should set aside the agreement, require the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 22 of 32
+22
+1
+government to confer?
+2
+3
+MR.
+: Work out a plea negotiation
+commensorate with the crimes that he committed and
+4
+that are favorable after they confer with the
+5
+victims. And it is within their discretion. Of
+6
+course, they can decide on their own that, hey, I
+7
+think that the agreement was fair after they have
+8
+talked with the victims.
+That could happen. I
+9
+don't know if a reasonable person that would do
+10 that, but it could happen.
+11
+12
+THE COURT: Apparently, you are not
+suggesting that that these person are not
+13
+reasonable.
+14
+15
+16
+MR.
+: I'm suggesting they haven't
+conferred with the victims and that if they took
+into consideration what these two in the courtroom
+17
+18
+19
+20
+21
+22
+23
+24
+25
+have to say, I don't think that we'd be in this same
+position right now.
+THE COURT: They have never spoken to your
+client about what happened to them?
+MR.
+: They have spoken to them about
+what happened. Maybe not about what the girls
+wanted to happen as a result of this case, which is
+part of conferring to decide that these girls wanted
+money on their own, which is basically what this--
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 23 of 32
+23
+1
+this non-prosecution agreement entails that has
+2
+language that he'll agree to liability in a civil
+3
+case. That's not what these girls-- They want
+4
+justice.
+They want him in prison now more than
+5
+ever. The reason they stated they kept this
+6
+agreement from the girls and they basically conceded
+7
+8
+we didn't tell the girls about this agreement, well,
+the reason is because they would have objected and
+9 they wouldn't have been able to sign off on this and
+10 the victims would have had a voice, and we'd still
+11
+been going through litigation. The exact problem
+12
+13
+14
+they tried to prevent, at least in their terms which
+was the impeachment of these girls at a later trial,
+is still available to anybody once the civil suits
+15
+are filed anyway.
+16
+They have three arguments. One, we didn't
+17
+have to talk to them. Iwo, we did talk to them sort
+18
+of. And if you don't buy that, the reason we didn't
+19
+talk to them, we were trying to prevent them from
+20 being impeached later. None of them trump the
+21 victims' rights to confer prior to plea
+22
+23
+24
+25
+negotiations.
+That's why, Your Honor, we would ask
+this Court to enter an order vacating that previous
+plea agreement as illegal, ask them to confer with
+the victims once again or for the first time and
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 24 of 32
+24
+1
+work out a negotiated plea to that accord.
+2
+3
+THE COURT: well, all you can ask them to do
+is confer. I can't ask them to do anything beyond
+4
+that. I mean, it is up to them to negotiate.
+5
+MR.
+: I wouldn't quarrel with that.
+6
+7
+THE COURT: Now, having learned today, I
+guess, that the agreement was signed when, in
+8
+October?
+9
+10
+11
+12
+13
+14
+15
+16
+MR.
+: October 2007, I heard.
+THE COURT: About eight or nine months ago,
+is there any need to rush to a decision in this
+matter? The decision has already been made. You
+filed this, I think, on the presumption that the
+agreement was about to take place and you wanted to
+be able to confer beforehand and you weren't sure
+what was going on.
+17
+MR.
+: Precisely, Your Honor. And I'm
+18 holding the letters that are exhibits that they were
+19
+writing to my client during the year of 2008 telling
+20
+her how lengthy of a process this was going to be
+21
+and be patient. So, right, I was completely in the
+22
+dark about when this agreement was signed.
+23
+THE COURT: In view of the fact that this
+24
+25
+agreement has already been consumated, and you want
+me to set it aside, as opposed to something that's
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 25 of 32
+25
+1
+2
+3
+4
+5
+6
+7
+B
+4: 17
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+about to occur, would you agree that-- and I have
+done this very quickly because of the petition and
+your allegation that something was about to happen.
+I'm not blaming you.
+MR.
+: I was mistaken.
+THE COURT: I'm not blaming you for doing
+that. In view of what you know now, is there any
+need to treat this as an emergency that has to be
+decided by tomorrow?
+MR.
+: I can't think of any reason in
+light of what we just heard.
+THE COURT: Mr. Lee, do you have anything
+else you wanted to add? Does either side think I
+need to take evidence about anything? If I do,
+since this is not an emergency anymore, I can
+probably find a more convenient time to do that. I
+don't have the time today to take evidence. But if
+you do believe that I should take evidence on this
+issue.
+MR.
+: It may be best if I conferred
+with the U.S. Attorney's Office on that and we can
+make a decision whether it is necessary or whether
+Your Honor deemed it was necessary for you to make a
+decision.
+THE COURT: I want to know what your
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 26 of 32
+26
+1
+2
+3
+respective positions are because it may be something
+in terms of having a complete record, and this is
+going to be an issue that's it going to go to the
+4
+Eleventh Circuit, may be better to have a complete
+5
+record as to what your position is and the
+6
+government's is as to what actions were taken. And
+7
+I don't know if I have enough information, based on
+8
+9
+Ms. Villafana's affidavit or I need additional
+information. And because it is not an emergency, I
+10 don't have to do something quickly, we can play it
+11 be ear and make this into a more complete record for
+12
+the court of appeals.
+13
+MR.
+: If there is a time where it is
+14
+15
+16
+17
+necessary to take evidence, Your Honor is correct in
+stating that it is not an emergency and it doesn't
+need to happen today. And, I will confer with the
+government on this and if evidence needs to be
+18
+19
+20
+21
+22
+23
+24
+25
+taken, it be taken at a later date. It doesn't seem
+like there will be any prejudice to any party.
+THE COURT: Mr. Lee, do you have any
+thoughts? You want to consult with Mr.
+?
+MR. LEE: There may be a couple of factual
+matters that I need to chat with petitioner's
+counsel on. If we can reach agreement on those as
+to what was communicated to CW and what time, if
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 27 of 32
+27
+1
+they don't dispute that, then we don't think it will
+be necessary to have an evidentiary hearing. But if
+3
+we can agree, fine or maybe we can't. We'll talk
+4
+about it.
+THE COURT: All right. So why don't you let
+6
+me know if you think an evidentiary hearing is
+7
+necessary. If there are additional stipulations you
+8
+want to enter into or supplement what has already
+9 been presented, you can do that.
+10
+Now, the other issue I want to take up,
+11
+though, is the government filed its response to the
+12
+petition under seal. And so I want to know why.
+13
+What is in there that at this point needs to be
+14
+under seal? Is there anything in there that's
+15
+16
+confidential, privileged, anything that's different
+from what you hve said here in open court that
+17
+requires that to be sealed?
+18
+MR. LEE: Well, Your Honor, on our motion to
+19
+seal was based on two reasons. One that dealt with
+20
+individuals or minors at the time that the offense
+21
+occurred. So we were attempting to protect the
+22
+privacy of those individuals. And also it dealt
+23
+with negotiations with Mr. Epstein which were in the
+24
+nature of plea negotiations, which we treat as
+25
+confidential. Normally, they're not aired out in
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 28 of 32
+28
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+open court. So those were our two reasons.
+THE COURT: All right. But I guess the
+letters you attached only related to Mr.
+client.
+MR. LEE: Three of them, yes, Your Honor.
+THE COURT: Are you prepared, Mr.
+to waive any issues regarding the release of those
+documents that relate to your clients?
+MR.
+: Judge, I think it would be
+appropriate to redact the names of the clients as
+they have done.
+THE COURT: I don't think the names are in
+there.
+MR.
+: I think they're redacted.
+They're blacked out. I have no problem with
+releasing those documents. I'm not sure that's part
+of the deal. But if it is--
+MR. LEE: It is.
+MR.
+: Okay. I'll waive.
+THE COURT: You really don't have any
+objection to those letters that were sent to them
+being released to the public?
+MR.
+: Of course not, Judge.
+THE COURT: Then what is there about the
+plea agreement or the negotiations that is in the
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 29 of 32
+29
+1
+response that we really haven't already kind of--
+2
+3
+MR. LEE: Your Honor, there was a
+confidentiality agreement in the deferral of
+4
+prosecution to the State of Florida.
+so we were
+5
+trying
+to maintain the confidentiality of the
+6
+negotiations that occurred since we had discussions
+7
+during those negotiations as one of the reasons why
+8
+we decided not to tell all of the individuals what
+9
+10
+11
+was going on.
+THE COURT: But is that still necessary,
+that confidentiality or is that kind of moot at this
+12
+point?
+13
+14
+15
+MR. LEE: Well, we would like it sealed.
+Admittedly, what happened today in open court has
+probably weakened our argument. I don't dispute
+16
+that.
+17
+THE COURT: In your opinion, anything in
+18 particular, any paragraph in the response or in Ms.
+19
+Villafana's affidavit that you think is particularly
+20
+troublesome that should remain under seal?
+21
+22
+MR. LEE: May I have a moment, Your Honor?
+THE COURT: Yes.
+23
+MR. LEE: Thank you. Your Honor, one aspect
+24
+of this in the notification letters that were
+25
+dispatched to individuals which were attached to Ms.
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 30 of 32
+30
+1
+Villafana's declaration, there is a citation to a
+2
+clause in the agreement that was reached regarding
+3
+the damages remedy under 18 USC 2255 that was
+4
+subject to the constitutionality agreement, we
+5
+believe that should still remain confidential.
+6
+THE COURT: But hasn't the fact that this
+7
+provision was part of the agreement again been
+8
+aired? Is there any secret to it anymore?
+9
+MR. LEE: The actual text of it has not been
+10 aired. The existence of it has been heard but the
+11 actual text has not and we believe it should still
+12
+remain confidential.
+13
+THE COURT: Okay. Any other argument on
+14
+that issue?
+15
+MR. LEE: No, Your Honor. Thank you.
+16
+THE COURT: Ms. Villafana wants to speak to
+17
+you.
+18
+MR. LEE: Your Honor, one item that I'd like
+19
+to bring to the court's attention. We had advised
+20 Mr. Epstein and his attorneys that if we were to
+21
+dislose some of the agreement, we would give them
+22
+advance notice and ability to lodge an objection. We
+23
+would like an opportunity to do that.
+24
+THE COURT: All right. But you're not
+25
+disclosing. It would be by my order that it would
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 31 of 32
+31
+1
+be disclosed.
+2
+3
+MR. LEE: Yes, Your Honor. And we just would
+like to register that we believe it should remain
+4
+confidential.
+5
+THE COURT: All right.
+6
+MR.
+: Your Honor, I don't see any
+7
+authority for keeping that under seal.
+8
+THE COURT: I agree.
+The fact that there is
+9 this preserved right on behalf of the victims to
+10
+pursue a civil action is already a matter of public
+11
+record; the exact text of the clause-- I don't see
+12
+that disclosing the text of the clause when the fact
+13
+that the clause exists is already a matter of public
+14
+record. It is not harmful in any way to Mr. Epstein
+15
+or the government and the letters to the victim that
+16
+the victim can disclose those letters, they're not
+17
+under any confidentiality obligation or restriction
+18
+and they're free to disclose it themselves if they
+19
+choose to. So I don't see that there is any real
+20
+public necessity to keep the response sealed in view
+21
+of what we discussed already on the record and the
+22 victim's ability to disclose those provisions of
+23
+their own choosing, if they wish. So, in view of
+24
+the public policy that matters filed in court
+25
+proceedings should be open to the public and sealing
+
+
+Case 9:08-cv-80736-KAM Document 15 Entered on FLSD Docket 07/18/2008 Page 32 of 32
+32
+1
+should only occur in circumstances that justife the
+2
+need to restrict public access, I'm going to deny
+3 the motion to seal the response and allow that to be
+4
+viewed.
+5
+All right. So I'll let both of you confer
+6 about whether there is a need for any additional
+7
+evidence to be presented. Let me know one way or
+the other. If there is, we'll schedule a hearing.
+If there isn't and you want to submit some
+additional stipulated information, do that, and then
+I'll take care of this in due course.
+MR.
+: Thank you, Your Honor.
+THE COURT: All right.
+MR. LEE: Thank you, Your Honor.
+MS. VILLAFANA: Thank you, Your Honor.
+THE COURT: You're welcome.
+(Proceedings concluded.)
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+I hereby certify that the foregoing is true
+and correct to the best of my ability.
+Victoria Aiello, Court Reporter
\ No newline at end of file
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@@ -0,0 +1,38 @@
+Case 9:08-cv-80119-KAM Document 286 Entered on FLSD Docket 09/02/2009__ Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+pion fata
+SEP 0 2 2009
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S, Motion
+For Extension of Time in which to Respond to Plaintiff, Jane Doe's Motions to Compel
+Responses to Request to Produce, Answers to Request for Admissions, and Answers to
+(DE# 280)
+Interrogatories. Having considered Defendant's motion and Plaintiff's counsel being in
+agreement with the requested extension, it is HEREBY ORDERED and ADJUDGED
+that:
+Defendant's motion is GRANTED. Defendant shall Respond to Plaintiff's
+Motions to Compel Responses to Request to Produce, Answers to Request for
+Admissions, and Answers to Interrogatories.
+on or before September 7, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 286 Entered on FLSD Docket 09/02/2009 Page 2 of 2
+DONE and ORDERED the 2 day or Sept:.
+→ 2009.
+-forman
+Kennet A Mam LINNEAR. JonsaD
+United States Distriet Judge
+MAGIATDATE
+Courtesy Copies:
+Counsel of Record
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+}
diff --git a/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.md b/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c2d4b86a8949e3389254b5a2963fd116d74b038
--- /dev/null
+++ b/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.md
@@ -0,0 +1,34 @@
+Case 1:20-cv-00484-JGK-DCF Document 100 Filed 03/12/21 Page 1 of 1
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+Sanders LLP
+troutman"
+pepper
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+March 12, 2021
+VIA ECF
+The Honorable John G. Koeltl
+United States District Court
+Southern District of New York
+Daniel
+Moynihan Courthouse
+500 Pearl Street
+New York, NY 10007
+Re:
+Jane Doe v. Darren I. Indyke and Richard D. Kahn, in their capacities as
+executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell
+No. 1:20-cv-00484-JGK-DCF
+Dear Judge Koeltl:
+We represent Defendants Darren _. Indyke and Richard D. Kahn, as Co-Executors
+of the Estate of Jefferey E. Epstein (the "Co-Executors"), in the above-referenced action.
+Pursuant to the Court's Memorandum Opinion and Order dated March 8, 2021, we write
+to confirm that the stipulation and the additional conditions specified therein are
+acceptable to the Co-Executors.
+Very truly yours,
+/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Cc:
+All counsel of record (via ECF)
diff --git a/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.receipt.json b/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a89d4f753a2f38012202092599ae50826838a4dd
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+++ b/vision-fixhub/court-01/db660bd71022bb2a72bfba1de3c8b27f51314d7f4d358bac06bb75e98aa912cf.receipt.json
@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.md b/vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.md
new file mode 100644
index 0000000000000000000000000000000000000000..d989111f06fd869abb89b20be1bc85086360e179
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+++ b/vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.md
@@ -0,0 +1,204 @@
+Case 9:08-CV-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 1 of 8
+Case 9:08-CV-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 1 of 8
+Jane Doe #5
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.| M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+C.W.1
+M.D., who, being by me first duly sworn under oath deposes and says:
+1.
+My name is Richard C.W.
+M.D. I am over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+since 1996.
+I have maintained a private practice in psychiatry and forensic psychiatry
+3.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns
+University and
+1
+D
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 2 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10. The amended complaint filed by Jane Doe #5 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 3 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #5 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe
+and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12. She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13.
+Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #5.
+14. Plaintiff reports she went to three different schools in the eighth grade. (Page
+3, GK Contemp note)
+15. Plaintiff reports "I have had girls be mean to me and even rumor that they
+would slice my throat when I was younger." (Page 4, GK Contemp note)
+16. Plaintiff noted that she had caught her mother and stepfather having sex.
+(Page 7, GK Contemp note)
+3
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 4 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 4 of 8
+17.
+"I got kicked out when I was 18 (by both parents). (Page7, GK Contemp note)
+18.
+Plaintiff noted that her mother suffers from depression/stress. (Page 7, GK
+Contemp note)
+19.
+Plaintiff noted that during her sophomore and junior years of high school she
+drank every weekend and started trying drugs. (Page 7, GK Contemp note)
+20.
+"Her problems began during adolescence." (Page 7, GK Contemp note)
+21. Family psychiatric history includes: a history of a blood relative having been
+sexually abused, plaintiff's mother was physically abused by sisters, and plaintiff's father
+"was very irresponsible as a father figure when I was growing up" and used drugs. (Pages
+7 and 8, GK Contemp note)
+22.
+Plaintiff noted "My stepfather hit me on a few occasions. But on one
+occasion, I lost hearing in my ear for two weeks." (Page 8, GK Contemp note)
+23. Plaintiff reported that she has been sexually active since age 13 and had 8-10
+partners. (Page 8, GK Contemp note)
+24.
+Plaintiff reported that she had been raised by her father between ages 12 to 18
+and that she found her childhood hard to remember, unhappy and painful. (Page 8, GK
+Contemp note)
+25. Plaintiff reports that her drug use has included marijuana and pain pills
+without prescription and that on several occasions she has drunk too much alcohol. (Page
+!
+4
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 5 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 5 of 8
+9, GK Contemp note)
+26.
+Plaintiff reported that her mother's sisters had paid a male to rape her (the
+mother) in a closet at school. She had been raped three times, twice in childhood and once
+on a date. Also, an uncle raped the mother. (Page 1, GK Follow-up note)
+27. Plaintiff reported having suicidal thoughts in the 9i or 10th grade. (Page 4,
+GK Follow-up note) (Pre-Epstein)
+28.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation priot to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+29. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+in the case.
+5
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 6 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 6 of 8
+30.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning.
+which our input is requested." We request the same.
+31. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+6
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 7 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 7 of 8
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+33. Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+34.
+It is, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+and conduct. We would concur and request of the court that the same and such other
+7
+
+
+Case 9:08-cv-80119-KAM Document 362-4 Entered on FLSD Docket 10/21/2009 Page 8 of 8
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 8 of 8
+similar information be made available to us to conduct our examination.
+Respectfully submitted,
+ichard C. W
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
diff --git a/vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.receipt.json b/vision-fixhub/court-01/db91455612be238080bd87982eeea17964868332835f2b16f5e1431398b4c0da.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1f5f37d18e2cba74f1f6dee95c75ed3ad75e10c0
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/dbb558a7c23a4cbcec4ed857ee63ef39017779ff58e8927ef6a2f30733d3798c.md b/vision-fixhub/court-01/dbb558a7c23a4cbcec4ed857ee63ef39017779ff58e8927ef6a2f30733d3798c.md
new file mode 100644
index 0000000000000000000000000000000000000000..89abddce9c2f8f220dbbba83370dc30eaae263ad
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@@ -0,0 +1,55 @@
+Case 9:09-cv-80591-KAM Document 25-1 Entered on FLSD Docket 05/21/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:09-CV-80591-KAM
+Jane Doe 101,
+Plaintiff,
+VS.
+Jeffrey Epstein,
+Defendant.
+CERTIFICATION OF JAY P. LEFKOWITZ
+Jay P. Lefkowitz, P.C., Esquire, pursuant to Rule 4B of the Special Rules Governing the
+Admission and Practice of Attorneys, hereby certifies that (1) I have studied the Local Rules of'
+the United States District Court for the Southern District of Florida; and (2) I am a member in
+good standing of the bars of the State of New York and District of Columbia, and am admitted to
+practice before the United States Supreme Court, the United States Courts of Appeals for the
+District of Columbia Circuit, Second Circuit, Fourth Circuit, Fifth Circuit, Eighth Circuit, Ninth
+Circuit, and Eleventh Circuit, the United States District Courts for the District of Columbia,
+Southern District of New York, Eastern District of Michigan, Eastern District of Wisconsin, and
+District of Colorado, and the United States Tax Court.
+
+
+Case 9:09-cv-80591-KAM Document 25-1 Entered on FLSD Docket 05/21/2009 Page 2 of 2
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing Motion for Limited
+Appearance, Consent to Designation and Request to Electronically Receive Notices of Electronic
+Filings was electronically filed with the Clerk of the Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all counsel of record identified on the following
+Service List in the manner specified by CM/ECF on this _ day of May, 2009
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully subminod,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar #617296
+npike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/dbb558a7c23a4cbcec4ed857ee63ef39017779ff58e8927ef6a2f30733d3798c.receipt.json b/vision-fixhub/court-01/dbb558a7c23a4cbcec4ed857ee63ef39017779ff58e8927ef6a2f30733d3798c.receipt.json
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.md b/vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.md
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@@ -0,0 +1,316 @@
+Case 9:08-cV-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 1 of 7
+Case 9:08-CV-80119-KAM Document 333-1
+Entered on FLSD Docket 09/30/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-I
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO
+PLAINTIFF'S REQUEST FOR PRODUCTION OF NET WORTH
+DOCUMENTS DATED JUNE 29, 2009
+Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorneys, serves his Responses and Objections to the Request for Production of
+Net Worth Documents and states:
+Request No. 1: All Federal and State income tax returns, including all
+W-2 forms, 1099 forms and schedules, for tax years 2003-2008.
+Response and Objections to Request Number 1: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production
+on advice from my counsel that | cannot provide
+answers/responses to questions relating to my financial history and conditior
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 2 of 7
+Case 9:08-cv-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 2 of 7
+Page 2
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. The specific
+intormation requested as to tax returns also seeks information that is confidential
+and protected by federal law, 26 USC 6103. Further, Plaintiff's Complaint alleges
+a time period of "in or about 2004-2005." Plaintiff's request seeks information for
+a time period from 2003-2008.
+To the extent this court rules that some or all of the requested information
+be produced, it should not be produced without limitations (including
+confidentiality, and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 2:
+All documents relating to the assets, liabilities,
+income, expenses and net worth of Defendant, including without limitation, the
+following for each of the past five (5) years.
+a.
+b.
+C.
+annual financial reports;
+balance sheets;
+income statements;
+cash flow statements;
+e.
+f.
+quarterly financial reports;
+budget reports; and
+financial analysis
+Response and Objections to Request Number 2: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based on
+advice from my counsel that I cannot provide
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 3 of 7
+• Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 3 of 7
+Page 3
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of the past five (5) years.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 3:
+All documentation which refer or relate to financing or
+loans requested or applied for by the Defendant, including loan applications,
+appraisals, financial spreadsheets, etc.
+Response and Objections to Request Number 3: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based on advice from my counsel that I cannot provide
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+ny Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 4 of 7
+Case 9:08-cv-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 4 of 7
+Page 4
+as guaranteed by the United States Constitution. Drawing an adverse inference
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide a
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable, overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiffs
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it should not be produced without limitations (including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 4:
+Any and all appraisals indicating fair market value of
+real estate or other property of Defendant.
+Response and Objections to Request Number 4: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, 1 assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 5 of 7
+Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 5 of 7
+Page 5
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+a
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable,
+overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Request No. 5:
+Any and all documents referring or relating to
+investment or savings accounts, including without limitation, account statements
+and summaries.
+Response and Objections to Request Number 5: Defendant is
+asserting specific legal objections including but not limited to relying on certain
+U.S. constitutional privileges in declining at present to respond to this request for
+production based
+on
+advice
+from my counsel that | cannot provide
+answers/responses to questions relating to my financial history and condition
+without waiving my Fifth Amendment and I must accept this advice or risk losing
+my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments
+as guaranteed by the United States Constitution. Drawing an adverse inference
+
+
+Case 9:08-cv-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 6 of 7
+Case 9:08-CV-80119-KAM Document 333-1 Entered on FLSD Docket 09/30/2009 Page 6 of 7
+Page 6
+under these circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable and would therefore violate the
+Constitution.
+Responding to the above financial request would require Epstein to
+identify information regarding the offenses that were the prior subject of a federal
+investigation as set forth in more detail in a supplementary response available to
+be provided to the court in camera and ex parte to the extent the good faith
+assertion of the privilege is in question. The Fifth Amendment is a safe harbor for
+all citizens, including those who are innocent of any underlying offense, however
+responding to this and other relating inquiries have the potential to provide
+link in a chain of information that would be protected. More specifically, the act of
+producing the above information may implicitly communicate statements of fact in
+that they would implicitly authenticate the requested information, require Epstein
+to admit that the requested information exists and admit that same were in his
+possession, custody and control. The very act of production itself may therefore
+provide a link in the chain of evidence adverse to Epstein, see generally United
+States v Hubbell 520 US 27, 36 (2000)
+In addition to and without waiving his constitutional privileges, Defendant
+also objects as the request for production as unreasonable,
+overbroad,
+confidential, proprietary in nature and seeks information that is neither relevant to
+the subject matter of the pending action nor does it appear to be reasonably
+calculated to lead to the discovery of admissible evidence. Further, Plaintiff's
+Complaint alleges a time period of "in or about 2004-2005." Plaintiff's request
+seeks information for a time period of January 1, 2002 to present.
+To the extent this court rules that some or all of the requested information
+be produced, it
+should not be produced without limitations including
+confidentiality), and should only be produced at the very end of litigation but
+before trial in order for Plaintiff to establish her burden making it apparent that
+punitive damages can be awarded.
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sen
+U.S. Mail, and facsimile to the following addressees this A day o
+2009.
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq
+18205 Biscayne Boulevaro
+Suite 2218
+Miami, FL 33160
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+
+
+Case 9:08-CV-80119-KAM Document 545-2 Entered on FLSD Docket 05/12/2010 Page 7 of 7
+•- Case 9:08-CV-80119-KAM Document 333-1
+Entered on FLSD Docket 09/30/2009 Page 7 of 7
+Page 7
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+iherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey
+Epstein
+ROBERT D. CRITÓN, JR., ESQ.
+Florida Bar No. 224162
+[crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+Fax: 561-515-3148
+(Co-counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.receipt.json b/vision-fixhub/court-01/dbbfee4674e02acccd0b35dccfbfab9b8a4e3bddde5ab417fed6d5d9f3120d6e.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-01/dbde43e82948f05e552228f48bf7b1f941597cdc374274b328357484bcc44ede.md b/vision-fixhub/court-01/dbde43e82948f05e552228f48bf7b1f941597cdc374274b328357484bcc44ede.md
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@@ -0,0 +1,23 @@
+Case 9:08-cv-80736-KAM Document 66 Entered on FLSD Docket 04/14/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+v.
+UNITED STATES
+[PROPOSED| ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+MOTION TWO WEEK EXTENSION OF TIME AND FOR PERMISSION TO FILE AN
+OVERLENGTH REPLY TO GOVERNMENT RESPONSES TO THEIR MOTIONS
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Two Week Extension of Time and for Permission to File an Overlength Reply to
+Government Responses to Their Motions, filed April 13, 2011.
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims may file
+replies to responses to the Government's pending motions (DE #58, 59, 60, and 62) on or before
+May 2, 2011. They may also file a reply in support of their Motion for Finding of Violations of
+the Crime Victims' Rights Act not to exceed 27 pages in length.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this 13" day of April, 2011.
+K
+KENNETH A. MARRA
+United States District Judge
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.md b/vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.md
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@@ -0,0 +1,191 @@
+Case 9:09-cV-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 9411:
+Phone (415)292-7119 Fax (415) 749-2802
+www.experichildposchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. 1, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz., to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents anothe
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintifts do not hold their heads high with pride tor having been sexually
+absorption and self-doubt and self-blame about sexual acts.
+
+A
+1
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+_, 1985).
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted, Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintifts as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:09-cV-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a detensive means to manage overwhelming attects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+auntills. Scientifie literature shows that the prognostic consequences of PTSD an
+esidual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abus
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 4 of 5
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80591-KAM Document 66-1 Entered on FLSD Docket 07/29/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will f
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN
+Соми. # 1791115
+NOTARY PUBLIC-CALIFORMA
+DITY & COUNTY OF SAN FRANCISO
+ty Cow. Exp. FEe: 27, 2012 H
+State of California, City & County of San Francisco
+subscibed and sworn to (or affimed) before me on the
+yay of undory by Gilbert Klinkeen
+proved me petrol shopped peter me
+5
diff --git a/vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.receipt.json b/vision-fixhub/court-01/dbe413725260b8f8bd376aad778adacb911074232c1de0944526ca76d2cdbb61.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8da628ce1853cca6e3b9fe85aa8867ce8157333b
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diff --git a/vision-fixhub/court-01/dc1ad867615bd26d17fe03df953d6db7f2f2c68d5fab5288452788b90ffd9f4c.md b/vision-fixhub/court-01/dc1ad867615bd26d17fe03df953d6db7f2f2c68d5fab5288452788b90ffd9f4c.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a4a33aa05c991fa98a24f9167e973225ee6ebc3
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@@ -0,0 +1,145 @@
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 1 of 4
+BOIES
+| SCHILLER
+FLEXNER
+Telephone: (212) 446-2300
+Email: jischiller@bsfllp.com
+January 31, 2020
+VIA ECE
+The Honorable Lora G. Schofield
+District Court Judge
+United States District Court
+Southern District of New York
+40 Foley Square
+New York, NY 10007
+Re: Jane Doe 1000 v. Indyke et al., Case No. 19-cv-10577
+Dear Judge Schofield,
+Pursuant to Individual Rules III.A. 1 and III.C.2, Plaintiff Jane Doe 1000 hereby responds
+to Defendants' request for a pre-motion conference in connection with their anticipated motion to
+dismiss. Dkt. 24. Plaintiff's claims are timely under New York's statutes of limitation and the
+doctrine of equitable estoppel, and Defendants' proposed motion "to dismiss" Plaintiff's request
+for punitive damages is procedurally improper. For the following reasons, the Court should deny
+Defendants" anticipated motion in its entirety.'
+I. Plaintiff's Claims Are Timely Under New York Law.
+Plaintiff's claims are timely under New York's CPLR § 215(8)(a), which provides:
+"Whenever it is shown that a criminal action against the same defendant has been commenced
+with respect to the event or occurrence from which a claim governed by this section arises, the
+plaintiff shall have at least one year from the termination of the criminal action ... to commence
+the civil action." (Emphasis added). Here, Epstein's criminal action in this District terminated on
+August 29, 2019. Compl. 9| 36. Because Plaintiff filed the Complaint less than three months later,
+the action is timely under CPLR 215(8)(a). Defendants' arguments against CPLR § 215(8)(a)'s
+application to these facts are meritless.
+First, Defendants' argument that CPLR § 215(8)(a) does not apply because Plaintiff was
+not named as a victim in Epstein's indictment is incorrect. New York courts have held that CPLR
+§ 215(8)(a) is "plain, clear and unambiguous" that it does not require that the plaintiff be "the
+victim or the specific person upon whom the crime had been committed." Clemens v. Nealon, 202
+A.D.2d 747, 749 (N.Y. App. Div. 1994).
+Second, Defendants' narrow construction of § 215(8)(a)'s "event or occurrence" language
+is improper, especially in light of the breadth of Epstein's indictment. The charges were not limited
+to crimes committed against specific victims. For example, the overt acts alleged for the sex
+trafficking conspiracy charge were enticing and recruiting multiple victims, "including minor
+" To the extent the Court allows Defendants to file a motion to dismiss, Plaintiff requests 30 days from the
+date of Defendants' motion to file an opposition, with Defendants' reply brief due 10 days thereafter.
+BOIES SCHILLER FLEXNER LLP
+55 Hudson Yards, New York, NY 10001 | (t) 212.446.2300 | () 212.446.2350 | www.bsfllp.com
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 2 of 4
+victims identified herein." Compl., Ex. A (S.D.N.Y Indictment) I| 22(a) (emphasis added). As
+another example, the Indictment's sex trafficking count charged Epstein with the sex trafficking
+of "numerous individuals ... including but not limited to Minor Victim-l." Id. Il 24. Nor did the
+Indictment describe the sex trafficking conspiracy as exclusively targeting minor victims—it
+explicitly acknowledged that some victims were not underage at the time of the sexual abuse. Id.
+• 11 ("[Epstein] knew that many of his New York victims were underage."). The Indictment was
+targeted at Epstein's sex-trafficking scheme as a whole, and that scheme is the event or occurrence
+from which Plaintiff's civil claims arose. See Kashef v. BNP Paribas S.A., 925 F.3d 53, 56-57,
+62 (2d Cir. 2019) (guilty plea conceding "knowledge of the atrocities being committed in Sudan"
+allowed victims of the atrocities in Sudan use 215(8)(a) because causes of action arose out of
+defendant's general conspiracy with Sudan to violate U.S. sanctions put in place to stop atrocities).
+Because Plaintiff's claims arise out of this common scheme, they fall within CPLR § 215(8)(a).
+The cases Defendants cite are inapposite because the criminal charges in those cases were
+much narrower than Epstein's, and related to events that occurred on specified dates. See
+Christodoulou v. Terdeman, 262 A.D.2d 595, 596 (N.Y. App. Div. 1999) (prosecution commenced
+only in connection with events on two dates); Gallina v. Thatcher, No. 2017-52980, 2018 N.Y.
+Misc. LEXIS 8435, at *3 (Sup. Ct. Oct. 23, 2018) (indictment "charged [the defendant] for
+incidents occurring on three (3) specific dates"). Epstein's Indictment was much broader, covering
+sexual abuse that occurred "over the course of many years" "from at least in or about 2002, up to
+and including at least in or about 2005." S.D.N.Y. Indictment 99| 1-2, 8, 20, 24 (emphases added).
+Plaintiff's claims are therefore timely under CPLR § 215(8)(a) because the scheme the S.D.N.Y.
+Indictment targeted is the event or occurrence from which Plaintiff's civil claims arise.
+Plaintiff's claims are also timely under CPLR § 213-c, which provides for a twenty year
+limitations period for "all civil claims or causes of action brought by any person for physical,
+psychological or other injury or condition suffered by such person as a result of conduct which
+would constitute rape" or other enumerated sex crimes. The Complaint alleges that Epstein
+sexually assaulted Plaintiff by forcible compulsion multiple times within the past twenty years.
+See Compl. 9| 50, 51. Plaintiff's claims fall squarely within CPLR § 213-c's coverage. Defendants'
+assertion that CPR § 213-c does not apply because "the 20-year SOL does not apply
+retroactively" is meritless. CPLR § 213-c's text contains no such limitation, and was revised last
+year (increasing the limitations period from 5 to 20 years) specifically to allow claims such as
+Plaintiff's to proceed. See June 17, 2019, New York Committee Report, 2019 NY S.B. 6574 (NS)
+(noting that "victims who have suffered in silence for decades have bravely spoken about their
+abuse, and have also laid bare the state's limited ability to prosecute their abusers due to the
+passage of time" and that "this bill would increase the time period in which the victim could bring
+a civil suit for these offenses to twenty years").
+Defendants also assert that Plaintiff's claims are untimely under New York's borrowing
+statute, CPLR § 202. This argument fails for two reasons. First, CPLR § 202 only applies to nonresidents who are injured outside of New York, and the controlling date for determining a
+plaintiff's residence is the date on which the cause of action accrued, not the date on which the
+action was commenced. See, e.g., DeMartino v.
+cenuthe date on which the
+1. 148 A.D.2d 568, 570 (N.Y. App. Div.
+1989). Under the borrowing statute, the phrases "resident" and "domicile" are not synonymous.
+"Rather, the determination of whether a plaintiff is a New York resident, for purposes of CPLR
+202, turns on whether [she] has a significant connection with some locality in the State as the result
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 3 of 4
+of living there for some length of time during the course of a year." Antone v. Gen. Motors Corp.,
+473 N.E.2d 742, 746 (N.Y. 1984). The fact that Plaintiff currently lives in New Jersey is irrelevant.
+At the time of her repeated sexual assaults, Plaintiff was a resident of New York—she lived in
+Epstein's apartment building on 66" Street in Manhattan, where he housed other victims. Compl.
+9140. When Plaintiff escaped Epstein, she stayed in New York and moved into a Salvation Army
+apartment. Compl. I| 46. Because Plaintiff had a significant connection with New York at the
+time her cause of action accrued, she was a resident of New York, and CPLR § 202 does not apply.
+Second, even if New York's borrowing statute did apply and Plaintiff's claims were
+otherwise untimely, they would still not be barred because CPLR § 215(8)(a) provides for civil
+actions to commence within one year from the termination of the criminal
+action ... notwithstanding that the time in which to commence such action has already expired."
+II. Plaintiff Has Sufficiently Pled Facts Supporting Equitable Estoppel and Tolling.
+Even if Plaintiff's claims were otherwise time-barred under New York's statutes of
+limitation (they are not), they would still be timely under the doctrine of equitable estoppel.
+Defendants assert that Plaintiff "fails to meet her burden to allege extraordinary circumstances
+sufficient to justify tolling or equitable estoppel." Dkt. 24 at 2. But the Complaint alleges in detail
+the methods of intimidation and control that Jeffrey Epstein and his co-conspirators used to deter
+their victims from seeking justice. Equitable estoppel applies "where it would be unjust to allow
+a defendant to assert a statute of limitations defense," Zumpano v. Quinn, 849 N.E.2d 926, 929
+(N.Y. 2006), due to "deception, concealment, threats, or other misconduct," Zoe G. v. Frederick
+F.G., 208 A.D.2d 675, 675 (N.Y. App. Div. 1994). The Complaint alleges that Epstein and his
+co-conspirators manipulated victims using "financial power, promises, and threats;" that Plaintiff
+was "terrified of Epstein, who repeatedly threatened her and made representations about his
+wealth, power, and connections;" and that Epstein forced Plaintiff to meet with a prominent lawyer
+who gathered information about Plaintiff's family's financial situation that Epstein later used "to
+intimidate her and to keep her compliant in his sex-trafficking scheme." Compl. 99l 27, 40, 43.
+The allegations concerning Epstein's purposeful silencing of his victims (and Plaintiff specifically)
+easily provide the requisite "extraordinary circumstances" for equitable tolling.
+Because equitable estoppel and equitable tolling are fact-specific doctrines, Defendants'
+attempt to resolve the issue with a motion to dismiss is inappropriate, and any motion challenging
+whether or not those doctrines apply should be reserved until after discovery. See, e.g., Carelock
+v. United States, 2015 WL 5000816, at *8 (S.D.N.Y. Aug. 20, 2015).
+I. The Court Should Address Punitive Damages After Discovery
+Federal Rule 12(b)(6) allows a defendant to file a motion to dismiss for "failure to state a
+claim upon which relief can be granted." Defendants' request for the Court to dismiss Plaintiff's
+claim for punitive damages does not relate to either of Plaintiff's clams (battery and intentional
+infliction of emotion distress) and does not relate to the sufficiency of the allegations in the
+Complaint. The issue of what type of damages to which Plaintiff is entitled should therefore be
+dealt with at a later stage of this litigation. See, e.g., Okyere v. Palisades Collection, LLC, 961 F.
+Supp. 2d 522, 536 (S.D.N.Y. 2013) (denying "motion to "dismiss' plaintiff's request for punitive
+damages as procedurally premature").
+
+
+Case 1:19-cv-10577-LJL-DCF Document 25 Filed 01/31/20 Page 4 of 4
+Respectfully submitted,
+Is/ Joshua I. Schiller
+David Boies, Esq.
+Joshua I. Schiller, Esq.
+Sigrid S. McCawley, Esq.
+cc: Counsel of Record (via ECF)
\ No newline at end of file
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new file mode 100644
index 0000000000000000000000000000000000000000..cb494d4c1bf87f1da68d2501252e9411598d0b7c
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diff --git a/vision-fixhub/court-01/dc1df20190709f67bba971b8ca2f8931fc8a6b3f8ef3397cb5146101a71b5e2f.md b/vision-fixhub/court-01/dc1df20190709f67bba971b8ca2f8931fc8a6b3f8ef3397cb5146101a71b5e2f.md
new file mode 100644
index 0000000000000000000000000000000000000000..652b0ac1f0751d5bfda9884668f78d000194256e
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@@ -0,0 +1,202 @@
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/I
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+EPSTEIN'S REPLY TO PLAINTIFES' RESPONSE TO MOTION TO COMPEL
+PRESIDENTIAL WOMEN'S CENTER TO COMPLY WITH SUBPOENA DUCES TECUM
+AND INCORPORATED MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO
+COMPLY WITH SUBPOENA DUCES TECUM REGARDING JANE DOE NO. 4
+Defendant, Jeffrey Epstein ("Epstein"), submits this reply to Plaintiffs', Jane Doe Nos. 2,
+3 and 5-8 ("Plaintiffs"), Response to Epstein's Motion to Compel Presidential Women's Center
+to Comply with Subpoena Duces Tecum (DE #442) and also moves to compel Presidential
+Women's Center to Comply with Subpoena Duces Tecum Regarding Jane Doe No. 4, and states:
+On December 2, 2009, Epstein filed a Motion to Compel Presidential Women's
+Center to Comply with Subpoena Duces Tecum ("Motion to Compel") (DE #431).
+2.
+Since the filing of the Motion to Compel (DE #431), Presidential Women's
+Center notified undersigned counsel that it does not have any records for Jane Doe Nos 2, 3, 5, 6
+and 8!
+'Epstein did not serve a subpoena on Presidential Women's Center for Jane Doe No. 7.
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 2 of 5
+Thus, unless circumstances change in the future, the issues in Epstein's Motion to
+Compel and the subpoenas to Presidential Women's Center regarding Jane Doe Nos. 2, 3, 5, 6
+and 8 are moot at the current time.
+MOTION TO COME PRESIDE ON TED COMPLY WITH
+4.
+In her deposition, Jane Doe No. 4 testified that she had three abortions, at least
+two of which was performed at Presidential Women's Center. See 10/27/09 Deposition of Jane
+Doe No. 4 at 311-313, excerpt attached as Exhibit A.
+5.
+On November 13, 2009, Epstein issued a subpoena (attached as Exhibit B) to
+Presidential Women's Center for records relating to Jane Doe No. 4.
+6.
+Jane Doe No. 4 did not object to said subpoena.
+7.
+Presidential Women's Center represented they will not produce records without a
+court order or a signed HIPAA release from the patient.
+8.
+On December 18, 2009, counsel for Epstein requested Jane Doe No. 4 provide an
+executed release for Presidential Women's Center. To date, no release has been received.
+Accordingly, Epstein requests the Court enter an order compelling Presidential
+Women's Center to comply with the November 13, 2009 subpoena duces tecum within five (5)
+days of the Court's order.
+10.
+This discovery is obviously relevant and discoverable and, again, Jane Doe No. 4
+(also represented by counsel for Jane Doe Nos. 2, 3 and 5-8) did not object to the subpoena. As
+the Court stated in its September 4, 2009 Order (DE #289), "lu]nder these circumstances, where
+Plaintiff is seeking to recover expenses associated with these complex medical issues, full
+knowledge of Plaintiff's past and present medical, psychological, familial and social histories is
+essential." See DE #289 at 4; see also DE #377 at 10 ("As a global matter, Plaintiffs clearly and
+2
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 3 of 5
+unequivocally place their sexual history in issue by their allegations that Epstein's actions in this
+case has negatively affected their relationships.... To deny Epstein this discovery [regarding
+past sexual history], would be tantamount to barring him from mounting a defense.").
+WHEREFORE, Epstein respectfully requests the Court enter an order compelling
+Presidential Women's Center to produce documents responsive to the subpoena duces tecum
+regarding Jane Doe No. 4 and attached to this Motion as Exhibit A within five (5) days of the
+Court's order and grant any additional relief the Court deems just and proper.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+Respectfully submitted,
+_s/ Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+1 Esq.
+Brad Daffe, Weasing,
+Lehrman, PL
+424 N. Andrews Avenue, Suite #2
+, Fistos &
+3
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 4 of 5
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+305-931-2200
+Phone: 954-524-2820
+Fax: 954-524-2833
+Fax: 305-931-0877
+brad@pathtojustice.com
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+. 08-80380, 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+2290 10* Avenue North
+801-585-5202
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No. 08-
+80811
+reelrhw@hotmail.com
+Isidro M.
+1, Esq.
+a Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+1, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+Sounsel for Plaintif in Related Case No. 08-
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases Nos.
+Bruce E. Reinhart, P.A.
+09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+4
+
+
+Case 9:08-cv-80119-KAM Document 443 Entered on FLSD Docket 12/29/2009 Page 5 of 5
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No. 08-
+08804
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+5
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.md b/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.md
new file mode 100644
index 0000000000000000000000000000000000000000..5ef69051ed2a6c53938242c5782e48c482b219a4
--- /dev/null
+++ b/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.md
@@ -0,0 +1,192 @@
+Case 9:08-cv-89330-508 R8038nt A5 af: Ente792008 098 A $7/1299 Page 1 of 3
+LRJ
+U.S. District Court
+Southern District of Florida (West Palm Beach)
+CIVIL DOCKET FOR CASE #: 9:08-cv-80380-KAM
+Internal Use Only
+Doe No. 4 v. Epstein
+Assigned to: Judge Kenneth A. Marra
+Referred to: Magistrate Judge Linnea R.
+Cause: 28:1332 Diversity
+Plaintiff
+Jane Doe No. 4
+Date Filed: 04/14/2008
+Jury Demand: Plaintiff
+Nature of Suit: 360 P.I.: Other
+Jurisdiction: Diversity
+represented by Adam D. Horowitz
+Herman &Mermelstein, P.A.
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+Email: ahorowitz@hermanlaw.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Jeffrey Mare Herman
+Herman &Mermelstein
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 931-0877
+Email: jherman@hermanlaw.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+Stuart S. Mermelstein
+Herman &Mermelstein
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 931-0877
+Email: Irivera@hermanlaw.com
+LEAD ATTORNEY
+ATTORNEY TO BE NOTICED
+V.
+Defendant
+Jeffrey Epstein
+represented by Ease to Stret.
+New York, NY 10021
+PRO SE
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 835-8691
+Email: jagesq@bellsouth.net
+ATTORNEY TO BE NOTICED
+
+
+Case 9:08-cv-8033-508 De038 ent A5 af: Enter008 098 A 07/1@299 Page 2 of3
+Michael
+Tein
+Tein
+3059 Grand Avenue
+Suite 340
+Coconut Grove, FL 33133
+305-442-1101
+Fax: 442-6744
+Email: tein@lewistein.com
+ATTORNEY TO BE NOTICED
+Date Filed
+04/14/2008
+04/14/2008
+04/17/2008
+#
+1
+2
+3
+Docket Text
+COMPLAINT against Jeffrey Epstein Filing fee $ 350. Receipt#: 542769, filed
+by Jane Doe No. 4.(di) (Entered: 04/14/2008)
+Summons Issued as to Jeffrey Epstein. (di) (Entered: 04/14/2008)
+04/18/2008
+04/21/2008
+04/23/2008
+05/22/2008
+05/29/2008
+06/02/2008
+06/05/2008
+06/13/2008
+06/13/2008
+06/19/2008
+ORDER REFERRING CASE to Magistrate Judge Linnea R.
+Magistrate Judge James M.
+case.Signed by Magistrate Judge James M.
+on 4/18/08.(Iw) Modified on
+4/23/2008 (Iw). (Entered: 04/18/2008
+Order Reming. Mara on 430. Entered: S421 20% Report Signed by
+(Court only) ***Set/Clear Flags (lw) (Entered: 04/23/2008)
+6
+AFFIDAVIT of Service for Summons and Complaint served on Jeffrey Epstein
+on May 7, 2008, filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered:
+05/22/2008)
+Plaintiff's MOTION for Entry of Default by Clerk Against Defendant by Jane
+Doe No. 4. (Attachments: # 1 Exhibit A and B, # 2 Text of Proposed Order
+Default Order)(Horowitz, Adam) (Entered: 05/29/2008)
+8
+| Clerks Entry of Default as to Jeffrey Epstein terminated 2 Motion for Entry of
+Default by Clerk (ail) (Entered: 06/02/2008)
+2
+Plaintiff's MOTION for Judgment Upon Default and Order Setting Hearing on
+Damagers by Jane Doe No. 4. (Attachments: #1 Text of Proposer
+Order) (Horowitz, Adam) (Entered: 06/05/2008
+10 NOTICE of Attorney Appearance by Jack Alan Goldberger on behalf of Jeffrey
+Epstein (Goldberger, Jack) (Entered: 06/13/2008)
+MOTION to Set Aside Default by Jeffrey Epstein. (Attachments: #1 Affidavit c
+lichard Barnett) (Goldberger, Jack) (Entered: 06/13/2008
+06/20/2008
+06/20/2008
+06/25/2008
+13
+Donderger, Mack) N tered: 0620200y Epstein. Responses due by 7/10/20008
+14
+Defendant's MOTION for Extension of Time to File Answer or Otherwise
+R620120 Tr Complain by Jeffrey Epstein. (Goldberger, Jack) (Entered:
+15
+MEMORANDUM in Support re 1 Plaintiff's MOTION for Entry of Default by
+Clerk Against Defendant filed by Jane Doe No. 4. (Herman, Jeffrey) (Entered
+06/25/2008)
+
+
+Case 9:08-cv-80330-508 D8038 nt A5 af: Enter008 098 A 97/1299 Page 3 of 3
+06/25/2008
+16
+RESPONSE to Motion re 11 MOTION to Set Aside Default filed by Jane Doc
+No. 4. Replies due by 7/7/2008. (Herman, Jeffrey) (Entered: 06/25/2008)
+07/01/2008
+NOTICE by Jeffrey Epstein Concerning Motion To Stay (DE 13] (Attachments:
+# 1 Exhibit "A" Final Disposition Sheets)(Goldberger, Jack) (Entered:
+07/01/2008)
+07/07/2008
+18 NOTICE of Attorney Appearance by Michael
+Tein on behalf of Jeffrey
+Epstein (Tein, Michael) (Entered: 07/07/2008)
+07/07/2008
+19
+MOTION Epstein's Reply in Support of Motion [DEI|] to Set Aside Clerk's
+Default by Jeffrey Epstein. (Tein, Michael) (Entered: 07/07/2008)
+07/08/2008
+20
+RESPONSE in Support re 11 MOTION to Set Aside Default filed by Jeffrey
+Epstein. (Goldberger, Jack) (Entered: 07/08/2008)
+07/08/2008
+21
+NOTICE by Jeffrey Epstein re 20 Response in Support of Motion /DE 11] To
+Set Aside Clerk's Default. (Goldberger, Jack) (Entered: 07/08/2008)
+07/08/2008
+NOTICE of Instruction to Filer: re 19 MOTION Epstein's Reply in Support of
+Motion [DE11] to Set Aside Clerk's Default filed by Jeffrey Epstein Error:
+Wrong Event Selected; Instruction to Filer: Counsel is instructed to re-file
+document using the correct event REPLY TO RESPONSE TO MOTION; In the
+future please select the proper event. (dg) (Entered: 07/08/2008)
+07/08/2008
+(Court only) Pursuant to DE#22***Motions terminated: 19 MOTION Epstein's
+Reply in Support of Motion [DEI]] to Set Aside Clerk's Default filed by Jetfrey
+Epstein. (dg) (Entered: 07/08/2008)
+07/08/2008
+23 REPLY to Response to Motion re I MOTION to Set Aside Default, 19
+MOTION Epstein's Reply in Support of Motion [DE11] to Set Aside Clerk's
+Default filed by Setey EpStein. ten Michael Entered: 0408/20ter s
+07/10/2008
+24
+Plaintiff's MOTION for Extension of Time to File Response as to 13 Defendant's
+MOTION to Stay by Jane Doe No. 4. (Attachments: # 1 Text of Proposed
+Order)(Horowitz, Adam) (Entered: 07/10/2008)
+07/10/2008
+07/10/2008
+07/16/2008
+25
+Sealed Document. (yc) (Entered: 07/10/2008)
+26
+Sealed Document. (yc) (Entered: 07/10/2008)
+27
+ORDER denying motion to file Ex Parte and Under Seal. The clerk shall unseal
+DE 25 and 26 and make them available for public inspection through CM/ECF at
+the earliest possible time. Signed by Judge Kenneth A. Marra on 7/16/08. (ir)
+(Entered: 07/16/2008)
+07/16/2008
+ORDER denying without prejudice 11 Motion to Set Aside Default. The
+Defendant has ten days to file a second motion to vacate the default. Signed by
+udge Kenneth A. Marra on 7/16/08. (ir) (Entered: 07/16/2002
diff --git a/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.receipt.json b/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fdda8f0abc2f492f61382a1529a46f8caf6caf73
--- /dev/null
+++ b/vision-fixhub/court-01/dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "dc2b0dd46d8d810911c963270f0c0a5d58d19968c7fa98f6f75b9cbc65c28092",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4102fbf1ea1f9ef888995cd37054d1dc086745f0d7643802fa104a05eb2b0fa5",
+  "output_sha256": "219a2d842bf2f65107a654e0cd9ea4c4414188b2bfb3cf4cfd49873d432c5005",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.md b/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.md
new file mode 100644
index 0000000000000000000000000000000000000000..752042f5d02f2b37fd0e60dd5a2023e197846e45
--- /dev/null
+++ b/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.md
@@ -0,0 +1,166 @@
+Case 9:08-cv-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 2 of 6
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRAJ m
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cV-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 3 of 6
+DOE II,
+CASE NO.: 09-CV-80469-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRA/]
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S REPLY TO DEFENDANT. JEFFREY EPSTEIN'S RESPONSE IN
+OPPOSITION TO PLAINTIFF,
+MOTION
+FOR PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM
+PARENT-CHILD CENTER, INC., DR. SERGE THYS, RECORDS OF
+DOMINIQUE HYPPOLITE/SCHOOL DISTRICT OF PALM BEACH COUNTY,
+GOOD SAMARITAN HOSPITAL, ST. MARY'S HOSPITAL, FLORIDA ATLANTIC
+UNIVERSITY AND GLORIA C. HAKKARAINEN, M.D., WITH INCORPORTATED
+MEMO OF LAW (DE 207)
+The Plaintiff,
+by and through undersigned
+counsel, files this Reply to D.E. 216, Defendant, Jeffrey Epstein's Response in
+
+
+Case 9:08-cv-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 4 of 6
+Opposition to Plaintiff,
+Motion for Protective Order
+Regarding Treatment Records From Parent-Child Center, Inc. Dr. Serge Thys, Records
+of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan
+Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkareinen,
+M.D., With Incorporated Memorandum of Law (DE 207), and further states as follows:
+Plaintiff withdraws her previously filed Motion For Protective Order (DE 207).
+The records identified above will be produced to the Defendant upon prepayment of
+the costs associated with copying same.
+Respectfully submitted,
+Is/Jack P.
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+(561) 383-9456
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 5 of 6
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on August 7, 2009, I electronically filed the foregoing
+document with the Clerk of Court using CM/ECF. I also certify that the foregoing
+document is being served this day on
+all counsel of record identified above via
+transmission of Notices of Electronic Filing generated by CM/ECF.
+Is/Jack P.|
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+(561) 383-9456
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 255 Entered on FLSD Docket 08/07/2009 Page 6 of 6
+COUNSEL LIST
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Phone:
+(561) 842-2820
+(561) 844-6929
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S.
+West Palm Beach, FL 33401
+Phone:
+(561) 863-9100
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+Phone:
+(561) 582-7600
+(561) 588-8819
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Phone:
+(561)-202-6360
+(561)-828-0983
\ No newline at end of file
diff --git a/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.receipt.json b/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..61d0ff7c7282b478926188adf09ce5984ee67fb4
--- /dev/null
+++ b/vision-fixhub/court-01/dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -98,
+  "dataset": "marble-joined",
+  "doc_id": "dc78372746545adc9e27ba90c3020ecc75b62c0c1b6f5c75bcdcddd9dee6129d",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "1e738d8ea0c0f6d13ef7afc20cfabd92ee86afdf5e0a863123abd100402c70be",
+  "output_sha256": "b6a2ee9bf0961175d5edbc8f3922c34adffc4e97d85ff394431d9450442e90b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.md b/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.md
new file mode 100644
index 0000000000000000000000000000000000000000..2b43c10461f59270e4a50dc1d12bbcf84720d32c
--- /dev/null
+++ b/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.md
@@ -0,0 +1,38 @@
+Filing # 108646390 E-Filed 06/10/2020 10:58:16 AM
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO: 2019CA014681XXXXMB AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+VS.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R. BOCK,
+as Clerk & Comptroller, Palm Beach County,
+Florida,
+Defendants.
+DEFENDANT, CLERK & COMPTROLLER, PALM BEACH COUNTY'S
+COPY
+NOTICE OF CHANGE OF ATTORNEY OF RECORD AND DIRECTIONS TO CLERK
+TO UPDATE ATTORNEY INFORMATION
+PLEASE BE ADVISED that pursuant to Administrative Order 2.311-2/13(5) of the
+Fifteenth Judicial Circuit, the Defendant, Clerk & Comptroller, Palm Beach County, hereby gives
+notice that is it changing the attorney of record in this matter to Cynthia M. Guerra. Attorney
+Nicole Fingerhut should be removed as attorney of record.
+Therefore, the Clerk hereby gives notice that any and all further pleadings, court filings and
+correspondence in this action are to be served upon the Clerk & Comptroller by directing them to
+Cynthia M. Guerra, Esq. at the address listed below.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true copy of the foregoing has been emailed in compliance
+with the Florida Rules of Judicial Administration 2.516, on this 10th day of June, 2020, to: Stephen
+A. Mendefsohn, Esq., Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca Raton, FL.
+33486, email: mendelsohns@gtlaw.com and Douglas A. Wyler, Esq., 961687 Gateway Blvd., Suite
+201-1, Fernandina Beach, FL 32034, email: jacobsscholzlaw@comcast.net.
+Cynthia M. Guerra, Esq.
+For Sharon R. Bock, Clerk & Comptroller
+Post Office Box 229
+West Palm Beach, FL 33401
+Telephone: (561) 355-2983
+E-service: Clerk_E-service@mypalmbeachclerk.com
+BY: s/Cynthia M. Guerra
+Florida Bar No. 886610
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 06/10/2020 10:58:16 AM
diff --git a/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.receipt.json b/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d972d464eb63f4f75d1306d428d6c599f2e262a1
--- /dev/null
+++ b/vision-fixhub/court-01/dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "dc88acce98c9d0c1fc3c76fc994c9c82effeea02ec1ea713ddf875ad10419758",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6086fad43a821d60c1007c5693357aae88205d2c6456c643f3337d5c143d9d6f",
+  "output_sha256": "757f0649d31f003c5513abc6a85d9ce26d575eb8bffb2f112338eff3cf4e69ce",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.md b/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.md
new file mode 100644
index 0000000000000000000000000000000000000000..5499a98377c5a1aeb47d87f683bfe78f1c108d49
--- /dev/null
+++ b/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.md
@@ -0,0 +1,158 @@
+Case 9:08-cv-80119-KAM Document 352 Entered on FLSD Docket 10/16/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+JOINT NOTICE OF AGREEMENT AND PLAINTIFF, JANE DOE'S (#08-80893)
+MOTION TO WITHDRAW PLAINTIFF, JANE DOE'S, MOTION FOR ORDER
+PERMITTING LEGAL COUNSEL TO ATTEND INDEPENDENT MEDICAL
+EXAMINATION AND INCORPORATED MEMORANDUM OF LAW (DE 346)
+PURSUANT TO THE AGREEMENT HERETO
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Joint Notice of Agreement and Plaintiff, Jane
+Doe's, Motion to Withdraw Plaintiff, Jane Doe's, Motion for Leave to Appear/Attend
+Independent Medical Examination:
+1.
+On September 15, 2009, Defendant filed his Motion for Independent
+Medical Examination as to Jane Doe (DE 302)
+On October 13, 2009, Plaintiff, Jane Doe (#08-80893), filed her Motion
+for Order Permitting Legal Counsel to Attend Independent Medical Examination and
+Incorporated Memorandum of Law (DE 346)
+
+
+Case 9:08-cv-80119-KAM Document 352 Entered on FLSD Docket 10/16/2009 Page 2 of 4
+Plaintiff, Jane Doe's, Independent Medical Examination is currently
+scheduled for November 10, 2009.
+4.
+The parties have reached an agreement related to Jane Doe's Independent
+Medical Examination subject to the State Court Order attached hereto as Exhibit A.
+Therefore, Plaintiff, Jane Doe's, Motion for Order Permitting Legal
+Counsel to Attend Independent Medical Examination and Incorporated Memorandum of
+Law (DE 346) is hereby moot.
+Moreover, Defendant's Rule 35 Motion to Compel Independent Medical
+Examination (DE 302) is moot as it specifically pertains to Jane Doe.
+ISTAN J. PIKE, ESO.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CM/ECF on this 16 day of October, 2009
+Respectfully submitted,
+ROBERT D. CRUTON, JR., ESQ.
+lorida Bar No. 22416
+crit@bclctaw.con
+MICHAEL J. PIKE, ESQ
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+
+
+Case 9:08-cV-80119-KAM Document 352 Entered on FLSD Docket 10/16/2009 Page 3 of 4
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/J
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+08-80994
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Brad
+Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Co-808d or Plaint in Related Case No.
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+_Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+
+
+Case 9:08-cv-80119-KAM Document 352 Entered on FLSD Docket 10/16/2009 Page 4 of 4
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.receipt.json b/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d120fb0778beb5819fb11315d2fdb0ae40bcb0c5
--- /dev/null
+++ b/vision-fixhub/court-01/dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "dccc5b5d4a0cbe4a56a946f4fee56dec1309f7b93f7b610bc1b9710074c03e8b",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8ba2b9aca38cd3f3942c30102b7390bb23346fd216c938dcc6f6ee300cc2535d",
+  "output_sha256": "afd48c2a6c420e66495366666d693e612ad7e15087438a0fbe8d03b1cd8bf3f4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.md b/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.md
new file mode 100644
index 0000000000000000000000000000000000000000..91c873030c9190a7a11642ff820209fb49bf10aa
--- /dev/null
+++ b/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.md
@@ -0,0 +1,267 @@
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFF,
+L, RESPONSE TO THIRD PARTY WITNESS,
+IGOR ZINOVIEW'S, MOTION FOR PROTECTIVE ORDER AND INCORPORATED
+MEMORANDUM OF LAW
+Plaintiff,
+_, by and through her undersigned counsel, hereby
+files her Response Third Party Witness, Igor Zinoview's, Motion For Protective Order
+and Incorporated Memorandum of Law (D.E. 402), and in support thereof states as
+follows:
+Third party witness, Igor Zinoview, seeks to have this Court enter an order
+preventing his deposition from going forward at all, or, in the alternative, limiting the
+scope of permissible questioning during same. Mr. Zinoview's deposition is presently
+scheduled to be taken on December 18, 2009.
+Mr. Zinoview has been employed by Defendant, Jeffrey Epstein, as his
+"driver, bodyguard, and trainer" since November of 2005. See Affidavit of Igor Zinoview
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 2 of 8
+(D.E. 402) dated November 9, 2009. Mr. Zinoview argues that his deposition should not
+go forward as scheduled because Defendant Epstein has never discussed nor
+attempted to discuss with him "any facts or information related to any legal matters in
+which he [Jeffrey Epstein] is involved." Id. From Mr. Zinoview's vague assertion springs
+the bold yet erroneous argument that "Mr. Zinoview cannot possibly have any
+knowledge or information that is presently germane to this action."
+3.
+It should initially be noted that a "complete prohibition of a deposition is an
+extraordinary measure which should be resorted to only in rare occasions." Jennings v.
+Family Management, 201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co.,
+593 F.2d 649, 651 (5" Circ. 1979)(It is very unusual for trial court to prohibit the taking
+of a deposition altogether, and absent extraordinary circumstances, such order would
+likely be in error.); Inv. Properties Intern., Ltd. v. IOS, Ltd., 459 F.2d. 705, 708 (2d Circ.
+1972)("an order to vacate a notice of taking deposition is generally regarded as both
+unusual and unfavorable ... "). Neither Mr. Zinoview's conclusory affidavit nor his
+Motion provide anything even approaching the "extraordinary circumstances" necessary
+to justify the entry of order precluding his deposition from going forward at all.
+4.
+Additionally, Mr. Zinoview's vague assertion that he and Defendant
+Epstein have never discussed any facts or information related to any legal matters that
+Mr. Epstein is involved in does not give rise to requisite "extraordinary circumstances"
+either. Detweiler Bros, Inc. v John Graham and Company, 412 F.Supp. 416 (E.D. Wash,
+1976)(Plaintiff could not properly seek to prohibit defendant from deposing plaintiff's
+employee via a protective order on grounds that employee had no knowledge of matters
+at issue.) See also, 8 Fed. Prac. & Proc. Civ. §2037,
+and
+("A witness
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 3 of 8
+ordinarily cannot escape examination by denying knowledge of any relevant facts, since
+the party seeking to take the deposition is entitled to test the witness's lack of
+knowledge.")
+5.
+The undersigned, as well as counsel for all of the other victims of Jeffrey
+Epstein, are entitled to question and challenge Mr. Zinoview on his purported lack of
+knowledge. Mr. Zinoview and plaintiffs' counsel very well might have a difference of
+opinion on what constitutes "facts and information related to any legal matters" in which
+Defendant Epstein is involved. The victims of Jeffrey Epstein ought not to be forced to
+accept Mr. Zinoview's opinion as to what constitutes "facts and information related to
+any legal matters" involving Jeffrey Epstein. Instead, plaintiffs should be able to explore
+these relevant matters directly with Mr. Zinoview, rather than being forced to rely on his
+twenty seven (27) word claim of lacking any knowledge.
+6.
+Additionally, Mr. Zinoview worked for Defendant Epstein during portions of
+the Palm Beach Police Department's months' long investigation which spanned from
+March 15, 2005 through February 2006 into the illegal sexual contact committed by
+Defendant Epstein against these minor plaintiffs. Accordingly, Mr. Zinoview certainly
+might have direct knowledge about what was going on in and around the Epstein
+residence during the time period in which he was employed by Defendant Epstein as his
+"driver, bodyguard, and trainer" while his employer was being investigated by law
+enforcement. Given the Defendant's voracious invocation of his Fifth Amendment
+privilege, the plaintiffs have consistently been denied the opportunity to seek any
+relevant information directly from Defendant Epstein himself. Rather, plaintiffs have
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 4 of 8
+been forced to build their cases against Mr. Epstein by other discovery methods,
+including deposing his employees who may have relevant information.
+7. Third party witness Igor Zinoview has failed to meet his very high burden
+of establishing "extraordinary circumstances." Mr. Zinoview has failed to demonstrate
+the "good cause" required by Rule 26(c) to protect a person from "annoyance,
+embarrassment, oppression, or undue burden or expense" to overcome the liberal
+scope of permissible discovery. The above proposed lines of inquiry of Mr. Zinoview
+are certainly reasonably calculated to lead to the discovery of admissible evidence.
+Accordingly, to the extent that it seeks to preclude his deposition from going forward at
+all, Mr. Zinoview's Motion should be denied
+Next, Mr. Zinoview also seeks to prevent questions being posed to him
+wherein he is first asked to "assume certain facts about which he has no knowledge,"
+and then be asked about his "opinions about certain facts." First, it remains to be seen
+exactly what facts about which Mr. Zinoview has no knowledge. Second, Mr. Zinoview's
+opinions and beliefs about the factual matters surrounding plaintiffs' claims are relevant
+to exploring any potential bias and prejudice in favor of his employer and against
+Defendant Epstein's victims. For example, if Mr. Zinoview believes that these plaintiffs
+are simply inventing their claims against his employer that they were sexually victimized
+by Defendant Epstein while they were minor children, it very well might impact his
+impartiality as a witness. Third, the undersigned has no present intention of engaging in
+this line of questioning unless the proverbial "door" has been opened by Mr. Zinoview
+first. Lastly, counsel for Mr. Zinoview is certainly free to invoke the privileges afforded to
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 5 of 8
+him by the applicable procedural rules should he feel that his client is being asked
+inappropriate questions during the deposition.
+9.
+In conclusion and for the reasons cited above, Mr. Zinoview's Motion For
+Protective Order should be denied in its entirety.
+WHEREFORE, Plaintiff,
+respectfully requests that
+this Court deny Third Party Igor Zinoview's Motion For Protective Order.
+Respectfully submitted,
+Is/Jack P.
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9456
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 6 of 8
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on November 28'h
+, 2009, I electronically filed the
+foregoing document with the Clerk of Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all counsel of record identified below via
+transmission of Notices of Electronic Filing generated by CM/ECF.
+Ls/Jack P.
+Jack Scarola
+Florida Bar No.: 169440
+Jack P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9424
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 7 of 8
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Brad
+, Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Co related Cases Nos. 08-80069, 08-30119, Paul O. Casell, Bs.
+08-80232, 08-80380, 08-80381, 08-80993,
+Pro Hac Vice
+08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A.
+801-585-6833 Fax
+2290 104 Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A.
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+_, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barhart & Shipley,
+P.A.
+08-80469
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+isx@searcylaw.com
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+jph(@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+
+
+Case 9:08-cv-80119-KAM Document 428 Entered on FLSD Docket 11/28/2009 Page 8 of 8
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer I. Kuvin, Esq.
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Ayenue South
+Suite 1400
+West Palm Beach, PL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesg@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.receipt.json b/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..24159a86c8f2b4c9e7e218cf5013fe3167042a4d
--- /dev/null
+++ b/vision-fixhub/court-01/dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "dce2b7c17c5903a397fc72bc8ab961ab2dca77f13e726f49a66a27bd85fe434c",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "41c655a80171e8fcbcfd431e7016b156424647ed250caf2785818548ab5efa15",
+  "output_sha256": "335a9e6541a59d4c07ac5c4e40fc44fe6c59f3e4230cc7ef250cf32111b4f208",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.md b/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.md
new file mode 100644
index 0000000000000000000000000000000000000000..e46f33f7a619cbf127d5909f7da282f8ab13dbb3
--- /dev/null
+++ b/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.md
@@ -0,0 +1,1170 @@
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 1 of 36
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA|
+JANE DOE NO. 3,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION TO
+COMPEL ANSWERS TO INTERROGATORIES, and RESPONSES TO
+1s and 2nd PRODUCTION OF DOCUMENTS, AND INCORPORATED
+MEMORANDUM OF LAW
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves
+his response and supporting memorandum of law to Plaintiffs Motion to Compel
+Answers to Interrogatories and Production of Documents, and Incorporated
+Memorandum of Law In Support, dated March 2, 2009. In support of Defendant's
+assertion of constitutional privileges and objections to discovery and in response to
+Plaintiff's motion to compel, Defendant states:
+Introduction
+As discussed more fully herein, Defendant has asserted constitutional based
+protections to the discovery requests propounded by Plaintiff. In addition and in
+alternative to the constitutional protections afforded under the Fifth, Fourteenth and
+Sixth Amendments, Defendant also asserted other factual/legal objections and
+privileges. However, as will be evident in reviewing Plaintiff's discovery requests and
+Defendant's response, the constitutional assertions are required to be determined first
+so that Defendant does not risk rendering these protections meaningless in attempting
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 2 of 36
+Page 2
+to assert and argue the factual basis for the additional objections and privileges. See
+part II.A. herein.
+I. Defendant EPSTEIN has properly asserted his constitutional claims of
+privilege and effective assistance of counsel, as guaranteed under the Fifth,
+Sixth, and Fourteenth Amendments of the United States Constitution, to each of
+the specified interrogatories and production requests.
+In accordance with applicable law, EPSTEIN has properly asserted his
+claims of privilege and effective assistance of counsel as guaranteed by the Fifth, Sixth,
+and Fourteenth Amendments of the United States Constitution to each of the
+interrogatories propounded by Plaintiff in her first set of Interrogatories and first
+production request. See Exhibit A to Plaintiff's Motion to Compel for Defendant's
+Response and Objections to Plaintiff's Amended Interrogatories, and Exhibit B to
+Plaintiff's motion for production requests and Defendant's responses thereto. Contrary
+to Plaintiff's assertion that Defendant made an improper "blanket objection," Defendant
+examined and responded to each of the discovery requests and raised constitutional
+privileges, along with other alternative objections applicable to the specific interrogatory
+or production request. See Exhibit A and B to Plaintiff's motion. (Although Defendant
+sets forth each of the interrogatories and requests below, because Plaintiff has attached
+the responses as Exhibits to her motion, Defendant does not retype the responses in
+their entirety herein).
+The circumstances of this case (and the others) are such that not only does
+Defendant EPSTEIN face allegations of sexual misconduct with and abuse, exploitation,
+and sexual battery of alleged minors in this and other civil actions, but he also faces
+criminal prosecution based on the same factual allegations. The Plaintiff's attorney
+represents Jane Doe Nos. 2, 3, 4, 5, 6, and 7, in civil actions against EPSTEIN filed in
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 3 of 36
+Page 3
+this Court. (There are additional state and federal civil actions against EPSTEIN). In
+this and the other civil actions, the Plaintiffs reference federal and state criminal statutes
+in an attempt to allege claims ranging from sexual battery to intentional infliction of
+emotional distress, to a violation of 18 U.S.C. 2422, entitled "Coercion and enticement,
+contained in Title 18, "Crimes and Criminal Procedure," Part | - "Crimes,' Chapter 117 -
+"Transportation for Illegal Sexual Activity and Related Crimes', " to a cause of action
+pursuant to 18 U.S.C. §2255 - which creates a civil remedy for personal injuries where
+a plaintiff can show a violation of specified statutory criminal statues. Plaintiff is
+attempting to allege a violation of 18 U.S.C. §2422. See endnote 1 for current text of 18
+U.S.C. §2422, along with pre-2006 amended text. See Exhibit B hereto - copy of
+Plaintiff's Second Amended Complaint.
+Plaintiff alleges that
+, a Palm Beach Community College student,"
+was an "integral player in Epstein's Florida scheme;" "she recruited girls ostensibly to
+give a wealthy man a massage for monetary compensation ...." 2d Am. Complaint, 110.
+(In civil actions by Jane Doe No. 2 and Jane Doe No. 5, also before this court, the
+Plaintiffs therein allege that
+Epstein's assistant" was a part of "Epstein's
+plan and scheme (which) reflected a particular pattern and method" in the alleged
+recruiting of girl's to come to EPSTEIN's Palm Beach mansion and give him "massages"
+in exchange for money. Jane Doe No.2 and Jane Doe No. 5 - 21° Am. Complaint, 911-
+12.)
+According to the complaint allegations - "Upon information and belief Epstein
+has a sexual preference and obsession for underage minor girls." 18. Once at Epstein's
+Palm Beach mansion, the "victim" would be "led up a flight of stairs to a bedroom that
+contained a massage table
+...." The girl would be alone with EPSTEIN. EPSTEIN
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 4 of 36
+Page 4
+would be "wearing only a towel to cover his private area." Epstein "then would lay down
+on the massage table and perform one or more lewd, lascivious and sexual acts,
+including masturbation and touching the girl sexually." 2^° Am. Complaint, 111, Exhibit
+B. Plaintiff alleges that "in 2004-2005," she, "then approximately 16 years old, fell into
+Epstein's trap and became one of his victims." 18.
+Jane Doe No. 3 further alleges that|
+brought her to Epstein's Palm
+Beach mansion, where she was led up a flight of stairs a room with a massage table.
+"She was alone in the room when Epstein arrived wearing a towel to cover his private
+parts." Plaintiff alleges that Epstein "sexually assaulted" her and "masturbated" "during
+the massage" 2d Am. Complaint, 112. Plaintiff also alleges that EPSTEIN "maintains
+his principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach, FL." Id, 17. "Upon information and belief, Jeffrey Epstein carried out
+his scheme and assaulted girls in Florida, New York and on his private island, known as
+Little St. James, in St.
+" Id, 19. The nature of the allegations is (obviously)
+serious.
+The threat of criminal prosecution is real and present as EPSTEIN remains under
+the scrutiny of the United States Attorney's Office (USAO) which, as explained more
+fully herein, possesses the power to move forward with its criminal prosecution against
+EPSTEIN. EPSTEIN entered into a Non-Prosecution Agreement ("NPA") with United
+States Attorney General's Office for the Federal Southern District of Florida. The terms
+and conditions of the NPA also entailed EPSTEIN entering into a Plea Agreement with
+the State Attorney's Office, Palm Beach County, State of Florida. By its terms, the NPA
+took effect on June 30, 2008. As well, pursuant to the NPA, any criminal prosecution
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 5 of 36
+Page 5
+against EPSTEIN is deferred as long as the terms and conditions of the NPA are
+fulfilled by EPSTEIN. Criminal matters against EPSTEIN remain ongoing until the NPA
+expires by its terms in late 2010 and as long as the USAO determines that EPSTEIN
+has complied with those terms and conditions. The threat of criminal prosecution
+against EPSTEIN by the USAO continues presently and through late 2010. The USAO
+possesses the right to declare that the agreement has been breached, give EPSTEIN's
+counsel notice, and attempt to move forward with the prosecution. In other words, the
+fact that there exists a NPA does not mean that EPSTEIN is free from future criminal
+prosecution. In fact, the threat of prosecution is real, substantial, and present. See
+attached Exhibit "A", Affidavit of Jack A. Goldberger, a board certified criminal defense
+attorney who has in the past and is currently representing EPSTEIN.
+A.
+Memorandum of Law Supporting Application of Constitutional Privileges
+The Fifth Amendment provides in relevant part that "No person ... shall be
+compelled in any Criminal Case to be a witness against himself." Hoffman v. United
+States, 341 U.S. 479, 486, 71 S.Ct. 814 (1951), citing
+v. United States, 1944,
+322 U.S. 487, 489, 64 S.Ct. 1082, 1083, 88 L.Ed. 1408." The Fifth Amendment's
+privilege against self-incrimination is "accorded liberal construction in favor of the right it
+was intended to secure." "The immediate and potential evils of compulsory selfdisclosure transcend any difficulties that the exercise of the privilege may impose on
+society in the detection and prosecution of a crime." Id, at 490; and In re
+Financial Svcs. of Fla., Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege not only
+extends to answers that would in themselves support a conviction under a criminal
+statute but likewise embraces those which would furnish a link in the chain of evidence
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 6 of 36
+Page 6
+needed to prosecute the claimant for a crime. Id, citing Blau v. United States, 1950, 340
+U.S. 159, 71 S.Ct. 223. The Fifth Amendment privilege against self-incrimination
+"permits a person not to answer official questions put to him in any other proceeding,
+civil or criminal, formal or informal, where the answers might incriminate him in future
+criminal proceedings." Edwin v. Price, 778 F.2d 668, 669 (11" Cir. 1985), citing
+Letkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). See also Ohio v. Reiner,
+532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth Amendment privilege is also available
+to those who claim innocence. One of the Fifth Amendment's "basic functions... is to
+protect innocent men ... 'who otherwise might be ensnared by ambiguous
+circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's
+Self-Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "'ilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); Kastigar v.
+U.S., 406 U.S. 441, 444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can
+be asserted in any proceeding, civil or criminal, administrative or judicial, investigatory
+or adjudicatory; and it protects against any disclosures which the witness reasonably
+believes could be used in a criminal prosecution or could lead to other evidence that
+might be so used. This Court has been zealous to safeguard the values which underlie
+the privilege." (Emphasis added)).
+As EPSTEIN is here, "the claimant must be 'confronted by substantial and 'real,'
+and not merely trifling or imaginary, hazards of incrimination." See generally, United
+States v. Apfelbaum, 445 U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)).
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 7 of 36
+Page 7
+See also, United States v. Neff, 615 F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S.
+925, 100 S.Ct. 3018, 65 L.Ed.2d 1117 (1980)(Information is protected by the privilege
+not only if it would support a criminal conviction, but even if "the responses would
+merely 'provide a lead or clue' to evidence having a tendency to incriminate.").
+The United States Supreme Court has made clear that the scope of the Fifth
+Amendment Privilege also encompasses the circumstance where "the act of producing
+documents in response to a subpoena (or production request) has a compelled
+testimonial aspect." United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043
+(2000); see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence,
+Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6" Ed.). In explaining
+the application of the privilege, the Supreme Court stated:
+We have held that "the act of production" itself may implicitly communicate
+"statements of fact."
+By "producing documents in compliance with a
+subpoena, the witness would admit that the papers existed, were in his
+possession or control, and were authentic. "EN19 Moreover, as was true in this
+case, when the custodian of documents responds to a subpoena, he may be
+compelled to take the witness stand and answer questions designed to
+determine whether he has produced everything demanded by the subpoena.
+FN20
+The answers to those questions, as well as the act of production itself,
+may certainly communicate information about the existence, custody, and
+authenticity of the documents. Whether the constitutional privilege protects
+the answers to such questions, or protects the act of production itself, is a
+question that is distinct from the question whether the unprotected contents of
+the documents themselves are incriminating.
+FN19. "The issue presented in those cases was whether the act of
+producing subpoenaed documents, not itself the making of a statement,
+might nonetheless have some protected testimonial aspects. The Court
+concluded that the act of production could constitute protected testimonial
+communication because it might entail implicit statements of fact: by
+producing documents in compliance with a subpoena, the witness would
+admit that the papers existed, were in his possession or control, and were
+authentic. United States v. Doe, 465 U.S., at 613, and n. 11, 104 S.Ct.
+1237; Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id., at 428, 432, 96
+S.Ct. 1569 (concurring opinions). See Braswell v. United States, [487
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 8 of 36
+Page 8
+U.S..| at 104, 108 S.Ct. 2284: Lid.,] at 122, 108 S.Ct. 2284 (dissenting
+opinion). Thus, the Court made clear that the Fifth Amendment privilege
+against self-incrimination applies to acts that imply assertions of fact."...
+An examination of the Court's application of these principles in other cases
+indicates the Court's recognition that, in order to be testimonial, an
+accused's communication must itself, explicitly or implicitly, relate a factual
+assertion or disclose information. Only then is a person compelled to be a
+'witness' against himself." Doe v. United States, 487 U.S., at 209-210, 108
+S.Ct. 2341 (footnote omitted).
+FN20. See App. 62-70. Thus, for example, after respondent had been duly
+sworn by the grand jury
+1, the prosecutor called his attention to
+paragraph A of the Subpoena Rider (reproduced in the Appendix, infra, at
+2048-2049) and asked whether he had produced "all those documents."
+App. 65.
+Finally, the phrase "in any criminal case" in the text of the Fifth Amendment
+might have been read to limit its coverage to compelled testimony that is used
+against the detendant in the trial itself. It has, however, long been settled that
+its protection encompasses compelled statements that lead to the discovery of
+incriminating evidence even though the statements themselves are not
+incriminating and are not introduced into evidence. Thus, a half century ago
+we held that a trial judge had erroneously rejected a defendant's claim of
+privilege on the ground that his answer to the pending question would not itself
+constitute evidence of the charged offense. As we explained:
+"The privilege afforded not only extends to answers that would in
+themselves support a conviction under a federal criminal statute but likewise
+embraces those which would furnish a link in the chain of evidence needed to
+prosecute the claimant for a federal crime." Hoffman v. United States, 341
+U.S. 479, 486, 71 S.Ct. 814, 95 L.Ed. 1118 (1951).
+Compelled testimony that communicates information that may "lead to
+incriminating evidence" is privileged even if the information itself is not
+inculpatory. Doe v. United States, 487 U.S. 201, 208, n. 6, 108 S.Ct. 2341,
+101 L.Ed.2d 184 (1988).
+It's the Fifth Amendment's protection against the
+prosecutor's use of incriminating information derived directly or indirectly fron
+the compelled testimony of the respondent that is of primary relevance in this
+case.
+In summarizing
+its holding regarding the application of the Fifth Amendment
+Privilege to a production request, the Hubbell Court left "no doubt that the constitutional
+privilege against
+self incrimination protects" not only "the target of a grand jury
+investigation from being compelled to answer questions designed to elicit information
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 9 of 36
+Page 9
+about the existence of sources of potentially incriminating evidence," but the privilege
+also "has the same application to the testimonial aspect of a response to a subpoena
+seeking discovery of those sources." At 43, and 2047.
+The privilege against self-incrimination may be asserted during discovery when a
+litigant has "reasonable grounds to believe that the response would furnish a link in the
+chain of evidence needed to prove a crime against a litigant." A witness, including a
+civil defendant, is entitled to invoke the Fifth Amendment privilege whenever there is a
+realistic possibility that the answer to a question could be used in anyway to convict the
+witness of a crime or could aid in the development of other incriminating evidence that
+can be used at trial. Id; Pillsbury Company v. Conboy, 495 U.S. 248, 103 S.Ct. 608
+(1983). See also, Hubbell, supra, quoted above as to what is encompassed by the
+phrase "in any criminal case" contained in the Fifth Amendment.
+As noted, the Fifth Amendment privilege against self-incrimination is broad.
+Hoffman; In re
+Financial Svcs., supra. To deny a witness the right to invoke the
+privilege, the judge must be perfectly clear, from a careful consideration of all the
+circumstances in the case, that the witness is mistaken, and that the answers cannot
+possibly have such tendency to incriminate. Id, at 488, 399. Recognizing the breadth
+and magnitude of this constitutional privilege, the United States Supreme Court in
+discussing how a court is to analyze the application of the privilege stated -
+... It is for the court to say whether his silence is justified, Rogers v. United
+states, 1951, 340 U.S. 361, /1 S.Ct. 438, and to require him to answer it it
+clearly appears to the court that he is mistaken Temple v. Commonwealth,
+1880, 75 Va. 892, 899. However, if the witness, upon interposing his claim,
+were required to prove the hazard in the sense in which a claim is usually
+required to be established in court, he would be compelled to surrender the
+very protection which the privilege is designed to guarantee. To sustain the
+privilege, it need only be evident from the implications of the question, in the
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 10 of 36
+Page 10
+setting in which it is asked, that a responsive answer to the question or an
+explanation of why it cannot be answered might be dangerous because
+injurious disclosure could result. The trial judge in appraising the claim 'must
+be governed as much by his personal perception of the peculiarities of the
+case as by the facts actually in evidence.'
+Hoffman, supra at 486-487.
+Hoffman and its progeny establish that "in view of the liberal construction of the
+provision [protecting against self-incrimination], after a witness has asserted the
+privilege, he should be compelled to provide the requested information only if it "clearly
+appears" to the court that the witness was mistaken in his invocation of the privilege."
+(Emphasis added). In re
+Financial Svcs., Supra at 399, citing Hoffman, at 486.
+Finally, in order to preserve the privilege against self-incrimination, as EPSTEIN
+has properly done is response to each discovery request, the privilege must be asserted
+or one risks the loss or waiver of this liberty ensuring protection. See generally, U.S. v.
+1, 846 F.2d 678, 690 (11* Cir. 1988)("First, it ignores the settled principle which
+requires a witness to assert his Fifth Amendment rights. A witness who testifies at any
+proceeding, instead of asserting his Fifth Amendment rights, loses the privilege.... A
+civil deponent cannot choose to answer questions with the expectation of later asserting
+the Fifth Amendment.").
+In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable
+cause to apprehend danger from a direct answer." The risk of incrimination resulting
+from answering each of the interrogatories and requests for production is "substantial
+and real" and "not trifling or imaginary haphazards of communication." See generally,
+In re
+Financial Svcs., supra at 400. Based on the nature of Plaintiff's claims,
+along with the ongoing scrutiny of the USAO in the criminal matters, EPSTEIN has
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 11 of 36
+Page 11
+"reasonable grounds to believe that his responses to the discovery would furnish a link
+in the chain of evidence needed to prove a crime against him. The very nature of the
+claims brought and the discovery being sought by Plaintiff in order to attempt to prove
+those claims establish a realistic possibility that the answer to an interrogatory or
+production request could be used in a type of way to convict EPSTEIN of a crime or aid
+in the development of other incriminating evidence that can be used at a criminal trial.
+Under the circumstances of this case, the threat of criminal prosecution is not
+imaginary. See Exhibits A and B to Plaintiff's Motion to Compel. This Court is well
+aware of the "peculiarities" of this action as it has before it other civil actions against
+EPSTEIN, all alleging similar underlying facts of sexual misconduct involving minors.
+The allegations of this action and others entail EPSTEIN allegedly "recruiting" Plaintiff
+and other minors to come to his home in Palm Beach to give him massages which
+allegedly became sexually inappropriate in nature, and EPSTEIN in turn would pay the
+minors. See Chapter 110 of Title 18, United States Code Annotated; and "predicate
+acts" specified in 18 U.S.C. §2255.
+Also applicable in upholding the assertion of Defendant's Fifth Amendment
+privilege is the guarantee of effective assistance of counsel by the Sixth Amendment of
+the U.S. Constitution. See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d
+1 (2003)(Sixth Amendment guarantees criminal defendants effective assistance of
+counsel.), on remand 381 F.3d 1219. The United States Constitutional guarantees are
+applicable to the states through the Fourteenth Amendment. Obviously, EPSTEIN's
+assertion of his constitutional privileges and protections is on the advice of counsel.
+EPSTEIN continues to face criminal prosecution by the USAO until the expiration of the
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 12 of 36
+Page 12
+NPA; under the constitutional guarantee of effective assistance of counsel, he is entitled
+to follow the recommended advice of his criminal defense attorney. See Exhibit A
+hereto. A review of the complaint allegations and the circumstances of this case -
+including multiple civil actions attempting to allege claims based upon sexual abuse and
+exploitation of minors, parallel criminal matter under which EPSTEIN continues to face
+prosecution for crimes based on the same allegations until the terms of the NPA have
+expired and been fulfilled as determined by the USAO - establish that EPSTEIN's
+invocation of his constitutional protections of the Fifth, Sixth and Fourteenth
+Amendments be upheld; otherwise such constitutional protections would be rendered
+meaningless.
+Circuit Court, State of Florida, recently entered order upholding assertion of Fifth
+Amendment and constitutional based protections in response to discovery.
+Further requiring the sustaining of Defendant's assertions of his
+constitutional protections, the 15" Judicial Circuit Court in and for Palm Beach County,
+State of Florida, recently entered an order sustaining Defendant's assertion of his 5, 6th
+and 14'" Amendment privileges and protections in response to Plaintiff A. C.'s request
+for production in A.C. v. Epstein, Case No. 502008CA025129XXXXMB Al. The Order,
+dated February 23, 2009, and the production requests and Defendant's responses are
+attached hereto as Composite Exhibit C. (Compare Requests for Production Nos. 1,
+2, 3, and 4 in the instant case with the production request no. 1 in Composite Exhibit C
+hereto; compare requests nos. 20 and 21 in this case with nos. 2 and 3 in Comp. Ex. C;
+and compare information sought in interrogatories nos. 3, 4, 5, 6, and 15 in this case
+with information sought in request nos. 2 and 3 in Comp. Ex. C).
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 13 of 36
+Page 13
+B. Even if the Court were to agree with Plaintiff's assertion that Defendant has
+asserted a "blank privilege" under the Fifth Amendment, under the facts and
+circumstances of this case, such assertion would be proper.
+Plaintiff claims that Defendant has improperly asserted a "blanket privilege" to the
+discovery. As stated above, Defendant disagrees. Defendant evaluated each and
+every discovery request in asserting applicable constitutional privileges and other
+objections. The facts and circumstances of this case are such that in evaluating each of
+the interrogatories and production requests on an individual basis, the constitutional
+protections asserted by Defendant apply to each. The Court will note that the additional
+objections raised are also tailored to each interrogatory and production request. Even
+the Court's analysis of the discovery will be on an individualized basis. However, simply
+for the sake of argument, as to Plaintiff's assertion that Defendant has made a "blanket
+assertion," under the facts and circumstances of this case, such an assertion is proper.
+In allowing a blanket assertion, Courts have recognized a narrow exception to the
+rule that the assertion of the privilege must be to each specific question. The Courts,
+including this Circuit, acknowledged "an exception ... (where,) based on its knowledge
+of the case and of the testimony expected from the witness, (the trial court) can
+conclude that the witness could 'legitimately refuse to answer essentially all relevant
+questions." United States v. Goodwin, 625 F.2d 693, 701 (5th Cir. Fla. 1980)); United
+States v. Tsui, 646 F.2d 365, 367-68 (9th Cir. 1981). This exception is narrow and is
+applicable where the trial judge has "some special or extensive knowledge of the case
+that allows evaluation of the claimed Fifth Amendment privilege even in the absence of
+specific questions to the witness." Id. See also U.S. v.
+1, 157 Fed.Appx. 215,
+218 (11* Cir. Ga. 2005)("A district court must make a particularized inquiry, evaluating
+whether the privilege applies with respect to each specific area that the questioning
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 14 of 36
+Page 14
+party wishes to explore. Melchor Moreno, 536 F.2d at 1049. The witness may be totally
+excused from testifying only if the court finds that he could legitimately refuse to answer
+essentially all relevant questions. United States v. Goodwin, 625 F.2d 693, 701 (5th
+Cir.1980).").
+See also State of Washington v. DelGado, 18 P.3d 1141 (Wa. Ct. of App. Div. 2
+2001) ("There is a narrow exception allowing a blanket privilege where "based on its
+knowledge of the case and of the testimony expected of the witness, [the trial court] can
+conclude that the witness could legitimately refuse to answer essentially all relevant
+questions. ... For the exception to apply, the trial judge must have 'some special or
+extensive knowledge of the case that allows evaluation of the claimed ... privilege even
+in absence of specific questions to the witness."').
+C. Plaintiff's statement of the law in section IV, (pp. 6-7), of her motion is
+incorrect under the circumstances. Contrary to Plaintiff's assertion, an adverse
+inference from invocation of the Fifth Amendment in a civil case is not always
+permitted.
+In section IV, (pp. 6-7), of Plaintiff's motion to compel, Plaintiff's general claim
+that an adverse interest based on a defendant's invocation of the Fifth Amendment in a
+civil case may be made is improper under the facts and circumstances of this case.
+Plaintiff is correct as to the general rule that "adverse inferences may be drawn in the
+civil context when Defendants invoke the privilege in refusing to testify in response to
+probative evidence offered against them." E.T.C. v. Transnet Wireless Corp., 506
+F.Supp.2d 1247, 1252, fn. 4 (S.D.Fla.,2007), citing Mitchell v. United States, 526 U.S.
+314, 328, 119 S.Ct. 1307, 143 L.Ed.2d 424 (1999). However, there exists a well
+recognized exception to the general rule - "Courts may not draw adverse inferences,
+however, if it is the sole basis for Plaintiff's prima facie case, or will cause the "automatic
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 15 of 36
+Page 15
+entry of summary judgment." See generally, F.T.C., supra, at fn.4, citing United States
+v. Premises Located at Route 13, 946 F.2d 749, 756 (11th Cir.1991) (citing Pervis v.
+State Farm and Cas. Co., 901 F.2d 944, 948 (11th Cir.1990)). See also S.E.C. v. Keith
+Group of Companies, Inc., 1998 WL 1670405 (S.D. Fla. 1998)("When a party is a
+defendant in both a civil and criminal case and is forced to choose between waiving his
+Fifth Amendment privilege ... or losing the civil case on summary judgment, an
+exception to the general rule ... applies. In such a situation, the Court may not make an
+adverse inference about the party's refusal to testify.") Accordingly, Defendant's
+assertion that an adverse interest "under the circumstances would unconstitutionally
+burden my exercise of my constitutional rights, would be unreasonable, and would
+therefore violate the constitution," is both proper and required to be upheld at this time.
+D. Plaintiff's Amended First Set of Interrogatories to Defendant
+Listed below is each of the interrogatories propounded by Plaintiff. As noted
+above, Defendant responded to each interrogatory separately in raising his
+constitutional privileges and guarantees, and, in the alternative, raising specific other
+applicable objections to each. See Exhibit A to Plaintiff's motion to compel.
+No. 1. Identify all employees who performed work of services inside the Palm Beach
+Residence.
+No. 2. Identify all Employees not identified in response to interrogatory no. 1 who at any time
+came to Defendant's Palm Beach Residence.
+No. 3. Identify all persons who came to the Palm Beach Residence and who gave a massage
+or were asked to give a massage to Defendant.
+No. 4. Identify all persons who came to the New York Residence and who gave a massage or
+were asked to give a massage to Defendant.
+No. 5. Identify all persons who came to the New Mexico Residence and who gave a massage
+or were asked to give a massage to Defendant.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 16 of 36
+Page 16
+No. 6. Identify all persons who came to the St._
+were asked to give a massage to Defendant.
+Residence and who gave a massage or
+No. 7. List all the time periods during which Jeffrey Epstein was present in the State of Florida,
+including for each the date he arrive and the date he departed.
+No. 8. Identify all of Jeffrey Epstein health care providers in the past (10) ten years, including
+without limitation, psychologists, psychiatrists, mental health counselors, physicians, hospitals
+and treatment facilities.
+No. 9. (Not at issue.)' List all items in Jeffrey Epstein's possession in Palm Beach, Florida, at
+any time during the period of these interrogatories, which were used or intended to be used as
+sexual aids, sex toys, massage aids, and/or vibrators, and for each, list the manufacturer, model
+number (if applicable), and its present location.
+Identify all persons who provide transportation services to Jeffrey Epstein,
+whether as employees or independent contractors, including without limitation, chauffeurs and
+aircraft crew.
+No. 11.
+Identify all telephone numbers used by Epstein, including cellular phones and
+land lines in any of his residences, by stating the complete telephone number and the name of
+the service provider.
+No. 12.
+Identify all telephone numbers of employees of Epstein, used in the course or
+scope of their employment, including cellular phones and land lines in any of his residences, by
+stating the complete telephone number and the name of the service provider.
+No. 13.
+List the names and addresses of all persons who are believed or known by you,
+your agents, or your attorneys to have any knowledge concerning any of the issues in this
+lawsuit; and specify the subject matter about which the witness has knowledge.
+State the name and address of every person known to you, your agents, or your
+attorneys who has knowiedge about, possession, or custody, or control of, any model, plat,
+map, drawing, motion picture, videotape or photograph pertaining to any fact or issue involved
+in this controversy; and describe as to each, what item such person has, the name and address
+of the person who took or prepared it, and the date it was taken or prepared.
+No. 15.
+Identify all persons who have made a claim, complaint, demand or threat against
+you relating to alleged sexual abuse or misconduct on a minor, and for each provide the
+following information:
+a. The person's full name, last known address and telephone number;
+b. The person's attorney, if represented;
+The date of the alleged incidents);
+d. If a civil case has been filed by or on behalf of the person, the case number and
+identifying information.
+' Fn. 4 of Plaintiff's motion states - "Plaintiff does not challenge at this time Defendant's Fifth
+Amendment privilege in response to interrogatory no. 9, which seeks information of Defendant's
+sexual aids."
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 17 of 36
+Page 17
+No. 16.
+State the facts upon which you intend to rely for each denial of a pleading
+allegation and for each affirmative defense you intend to make in these cases.
+No. 17.
+Identify all witnesses from whom you have obtained or requested a written,
+transcribed or recorded statement relating to any issue in these cases, and for each, in addition
+to the witness's identifying information, state the date of the statement and identify the person
+taking the statement.
+(Emphasis added).
+Defendant will address interrogatories nos. 3, 4, 5, 6, 13, 14, 15, 16, and 17,
+above, as the analysis as to the application of the constitutional privileges and
+protections is straightforward. Nos. 3 through 6 ask Defendant to identify anyone who
+gave "massages" or were asked to give "massages" to him. Clearly, any answer to
+these interrogatories, involve compelled statements that would furnish a link in the chain
+of evidence needed to prosecute the Defendant in future criminal proceedings or even
+support a criminal conviction. These interrogatories seek the precise information that
+the USAO investigated and continues to scrutinize. See Exhibit A hereto.
+Any answer to no. 15, which seeks information "relating to alleged sexual abuse
+or misconduct on a minor," on its face would also lead to incriminating evidence
+protected under the Fifth Amendment privilege. The same is true for no. 16 - which
+seeks "facts upon which you intend to rely for each denial of a pleading allegation and
+for each affirmative defense," and Nos. 13, 14, and 17 which seek to compel EPSTEIN
+to list any persons or witnesses in 13 "having any knowledge concerning any of the
+issues in this lawsuit," in 14 having "knowledge about, possession, or custody, or control
+of, any model, plat, map, drawing, motion picture, videotape or photograph pertaining to
+any fact or issue involved in this controversy," and in 17 "whom you have obtained or
+requested a written, transcribed or recorded statement relating to any issue in these
+cases." In answering no. 16, Defendant would be compelled to testify as to his version
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 18 of 36
+Page 18
+of the facts, and, in asserting affirmative defenses, he would further be compelled to
+admit Plaintiff's version of the facts. In listing such person or witness, the Defendant is
+further compelled to describe the subject matter, nature of the items and or statements
+of such witness or person. Again, the allegations of this action are such that in
+answering these interrogatories, Defendant is being compelled to incriminate himself in
+crimes. By answering the specified interrogatories Defendant is being compelled to
+testify as to the issues and facts not only asserted in Plaintiff's complaint, but also to
+facts which present a real and substantial danger of self-incrimination. Again, the
+information sought all relate to claims of sexual abuse and exploitation of a minor. (See
+Chapter 110 of Title 18, United States Code Annotated; and "predicate acts" specified in
+18 U.S.C. §2255, and 18 U.S.C. §2422).
+Any answer to nos. 1 and 2 would also be compelled testimony that "tends to
+show that the witness himself (EPSTEIN) committed a crime" based on the nature of the
+allegations. As noted above,
+Plaintiff alleges that at least one of EPSTEIN's
+employees,
+was part of the scheme or plan of sexual misconduct,
+exploitation and abuse of the "girls." No. 1 is asking for any employee who performed
+work or services, and no. 2 is asking EPSTEIN to testify as to anyone who came to his
+Palm Beach mansion.
+Such compelled testimony is protected under the Fifth
+Amendment as the answers "would furnish a link in the chain of evidence needed to
+prosecute the claimant for a crime." Answering the questions as to who came and went
+from his Palm Beach mansion would provide a "lead or clue' to evidence having a
+tendency to incriminate." See also 18 U.S.C. 2422, Coercion and Enticement. This
+analysis also applies to interrogatory nos. 7 and 9 which seek, respectively, "all the time
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 19 of 36
+Page 19
+periods during which Jeffrey Epstein was present in the State of Florida, including for
+each the date he arrive and the date he departed," and "all persons who provide
+transportation services to Jeffrey Epstein, whether as employees or independent
+contractors, including without limitation, chauffeurs and aircraft crew." Plaintiff alleges a
+time period of 2004-05 as to when the alleged to when the sexual misconduct, including
+sexual assault, of a minor took place in Palm Beach, Florida. Plaintiff also alleges that
+EPSTEIN engaged in the same "scheme and plan" against minor girls at his other
+places of residence. Again, EPSTEIN's answer as to his travels to and from Florida,
+and within Florida, would be a link in the chain of evidence needed to convict him of a
+crime.
+The privilege against self-incrimination also applies to Nos. 11 and 12 which
+seek, respectively, "all telephone numbers used by Epstein, including cellular phones
+and land lines in any of his residences, by stating the complete telephone number and
+the name of the service provider," and "all telephone numbers of employees of Epstein,
+used in the course or scope of their employment, including cellular phones and land
+lines in any of his residences, by stating the complete telephone number and the name
+of the service provider." Again, such compelled testimony would self-incriminate
+EPSTEIN based on the elements required to establish a violation of the criminal statute
+18 U.S.C. §2422. Such information would be a link in the chain of evidence needed to
+prosecute EPSTEIN for a crime.
+Finally, the compelled testimony sought in no. 8 - "all of Jeffrey Epstein health
+care providers in the past (10) ten years, including without limitation, psychologists,
+psychiatrists, mental health counselors, physicians, hospitals and treatment facilities,"
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 20 of 36
+Page 20
+could also lead to a link in the chain of evidence to convict EPSTEIN based on the
+allegations which are criminal in nature - sexual misconduct with minors, and a plan
+and scheme to "recruit" such minors to fulfill Epstein's "sexual preference and
+obsession." See 118 of complaint - "Upon information and belief Epstein has a sexual
+preference and obsession for underage minor girls."
+As explained in Hoffman, EPSTEIN is not required to "prove the hazard in the
+sense in which a claim is usually required to be established in court." The United States
+Supreme Court recognized placing such a requirement on a person asserting his
+constitutional privilege is in effect tantamount compelling him "to surrender the very
+protection which the privilege is designed to guarantee." Under the facts and
+circumstances of this case, it is evident from the implications of each of the
+interrogatories or an explanation of why they can't be answered "might be dangerous
+because injurious disclosure might result." Id.
+Accordingly, under applicable law and the facts of this case, Defendant's
+assertion of the constitutional privilege and guarantee under the 5", 6" and 14*
+Amendments of the United States Constitution are required to be upheld.
+E. Plaintiff's First Production Request To Defendant
+The constitutional protections are equally applicable to the request for production
+propounded on Defendant by Plaintiff. See Exhibit B to Plaintiff's motion to compel.
+The requests are as follows -
+Request No. 1.
+The list provided to you by the U.S. Attorney of individuals whom the U.S.
+Attorney was
+prepared to name in an Indictment as victims of an offense by Mr. Epstein
+enumerated in 18 U.S.C. §2255.
+Request No. 2.
+All documents referring or relating to the United States' agreement with
+Defendant to defer federal prosecution subject to certain conditions, including without limitation,
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 21 of 36
+Page 21
+the operative agreement between Defendant and the United States and all amendments,
+revisions and supplements thereto.
+Request No. 3.
+All documents referring or relating to Defendant's agreement with the
+State of Florida on his plea of guilty to violations of Florida Criminal Statutes, including without
+limitation, the operative plea agreement and any amendments, revisions and supplements
+thereto.
+Request No.4.
+All documents obtained in discovery or investigation relating to either the
+Florida Criminal Case or the Federal Criminal Case, including without limitation, documents
+obtained from any federal, state, or local law enforcement agency, the State Attorney's office
+and the United States Attorney's office.
+Request No. 5. All telephone records and other documents reflecting telephone calls made by
+or to Defendant, including without limitation, telephone logs and message pads.
+Request No. 6. All telephone records and other documents reflecting telephone calls made by
+or to Defendant, including without limitation, telephone logs and message pads, reflecting
+telephone calls made by or to employees.
+Request No. 7. All surveillance videos, slides, film, videotape, digital recording or other audio
+or video depiction or image of the Palm Beach Residence.
+Request No. 8. All documents referring or relating to Plaintiff Jane Doe No. 2, including without
+limitation, web pages, social networking site pages, correspondence, videotapes and
+audiotapes.
+Request No. 9. (Not at issue).? All statements taken, transcribed or recorded from any person
+referring or relating to Defendant's sexual conduct, massages given to Defendant or any issue
+in these cases.
+Request No. 10. All documents referring to or relating to air travel and aircraft used by
+Defendant, including without limitation, flight logs and flight manifests.
+Request No. 11. Any and all documents referring to or relating to modeling agencies, including
+but not limited to documents relating to or reflecting communications with female models.
+Request No. 12. (Not at issue). All photographs, videotapes, digital images and other
+documents depicting or showing females who, at the time thereof, were under the age of 21,
+which were taken or created by or for Defendant and not intended for sale commercially to the
+public.
+Request No. 13. (Not at issue.) All photographs and painting of females which were displayed
+in any of Defendant's homes or residences in the time frame of these requests, including
+without limitation, photographs in standing or sitting frames or wall frames.
+2 "Plaintiff concedes that the act of producing items in response to request no. 9, concerning
+witness statements, and requests nos. 12-13, concerning photographs or images of females,
+nay implicate the Fifth Amendment." Plaintiff's motion, p. 5, fn. 6
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 22 of 36
+Page 22
+Request No. 14. Any and all documents consisting of, referring or relating to communications
+between Jeffrey Epstein and
+• including, but not limited to, letters, notes, text
+messages, messages on social networking sites, and e-mails.
+Request No. 15. Any and all documents consisting of, referring or relating to communications
+between Jeffrey Epstein and
+including, but not limited to, letters, notes, text
+messages, messages on social networking sites, and e-mails.
+Request No. 16. Any and all documents consisting of, referring or relating to communications
+between Jeffrey Epstein and
+, including, but not limited to, letters, notes, text
+messages, messages on social networking sites, and e-mails.
+Request No. 17. Any and all documents consisting of, referring or relating to communications
+between Jeffrey Epstein and Ghislaine Maxwell, including, but not limited to, letters, notes, text
+messages, messages on social networking sites, and e-mails.
+Request No. 18. Any and all documents and photographs placed by Defendant at any time in
+the period of these requests on a social networking website, including without limitation,
+Facebook.com and MySpace.com.
+Request No. 19. Any and all documents reflecting or consisting of communications between
+Jeffrey Epstein and MC2 Models or Jean-Luc Brunel, relating or referring to females coming into
+the United States from other countries to pursue a career in modeling, including, but not limited
+to, letters, notes and e-mails.
+Request No. 20. Any and all documents referring or relating to gifts or loans to females under
+the age of 21, including, but not limited to, notes, receipts and car rental agreements.
+Request No. 21. Any and all personal calendars or schedules of or for Jeffrey Epstein from
+January 1, 2003 to the present.
+Request No. 22. All documents written by Jeffrey Epstein consisting of personal thoughts,
+feelings or descriptions of events, incidents or occurrences in Defendant's life, including without
+limitation, any diaries of Jeffrey Epstein.
+Request No. 23. All documents referring to or relating to Jeffrey Epstein's purchase or
+consumption of prescription medicine.
+As discussed in the supporting memorandum law herein, it is well settled that the
+Fifth Amendment privilege against self-incrimination also encompasses situations as
+here where the act of production itself involves a testimonial compulsion. Hubbell,
+supra. In responding to each request, EPSTEIN would be compelled admit that such
+documents existed, admit that the documents were in his possession or control, and
+were authentic. In other words, the very act of production of the category of documents
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 23 of 36
+Page 23
+requested would implicitly communicate "statements of fact." Hubbell, supra; Hoffman,
+supra. The act of production might not only provide evidence to support a conviction,
+but also a link in the chain of evidence for prosecution. Such compulsion to produce is
+the same as being compelled to testify. The acts of EPSTEIN in being required to
+produce the requested documents imply assertions of fact - admitting the documents
+exist, admitting the documents are in his possession or control, and admitting the
+documents are authentic. Again, in reading each of the production requests in Nos. 1,
+2, 3, 4, 5, 6, 7, 8, 10, 11, 14, 15, 16, 17, 18, 19, 20, 21, 22, and 23, (like the
+interrogatories), it is clear that the very act of production of such documents could
+implicate EPSTEIN in a crime.
+As noted above, EPSTEIN is constitutionally entitled to follow the advice of
+counsel in asserting the applicable Fifth Amendment privilege under the guarantee of
+effective assistance of counsel. Accordingly, based on the facts and circumstances of
+this case, and under applicable law, Defendant's assertion of the protections afforded
+under the 5"'
+, and 14" Amendments of the United States Constitution are required
+to be upheld.
+II. Defendant's objections made in addition to the constitutional based
+protections are required to be upheld.
+A. Constitutional issues are required to be addressed first.
+Obviously, the constitutional issues raised in Defendant's response permeate not
+only discovery, but the entire action itself. Defendant would suggest to the Court that
+the constitutional issues be decided before the additional objections are addressed. " In
+fact, in arguing certain of the additional objections, Defendant's constitutional rights
+3 Should this Court overrule Defendant's constitutional based privileges and guarantees,
+Defendant will likely take an immediate appeal of such ruling.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 24 of 36
+Page 24
+under the 5th
+", 6* and 14* Amendments are clearly implicated. In setting forth factual
+reasons to support the additional objections, Defendant is being compelled to testify in
+response to a specific discovery request, thus, impeding his privilege against selfincrimination and guarantee of effective assistance of counsel. The same is true if
+Defendant is required to prepare privilege logs. (In section IV of her motion, Plaintiff
+recognized, in addressing Defendant's assertion that an adverse inference would be
+improper, that "It is first necessary to determine whether the Fifth Amendment privilege
+is validly asserted in response to particular questions."). Thus, Defendant also requests
+that should this Court rule that the Fifth Amendment does not apply to certain of the
+discovery requests, that Defendant be given an additional 20 days from the date of the
+order thereon in which to assert other objections and privileges.
+*
+In alternative and addition to the applicable constitutional based protections,
+Defendant also raised objections to each of the interrogatories and requests for
+production. (See sections V, VI, and VII, pp. 7-12, of Plaintiff's motion to compel).
+Defendant will address Plaintiff's arguments pertaining to the additional objections in the
+order presented in Plaintiff's motion.
+B. Interrogatory No. 8, Production Request No. 23
+Section V. A. of plaintiff's motion pertains to interrogatory no. 8 -
+Identify all of Jeffrey Epstein health care providers in the past (10) ten years, including
+without limitation, psychologists, psychiatrists, mental health counselors, physicians,
+hospitals and treatment facilities.
+In addition to the constitutional protections, Defendant also stated -
+... In addition to and without waiving his constitutional privileges, Defendant also objects
+as the interrogatory is overbroad and seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 25 of 36
+Page 25
+the discovery of admissible evidence. In addition, such information is privileged pursuant
+to Rule 501, Fed. Evid., and §90.503, Fla.Evid. Code. In addition, such information is
+protected by the provisions of the Health Insurance Portability and Accountability Act
+(HIPAA).
+Federal Rule of Evidence 401 provides that - '''Relevant evidence'" means
+evidence having any tendency to make the existence of any fact that is of consequence
+to the determination of the action more probable or less probable than it would be
+without the evidence." Pursuant to Rule 26(b)(1), the scope of discovery is as follows -
+Unless otherwise limited by court order, the scope of discovery is as follows: Parties
+may obtain discovery regarding any nonprivileged matter that is relevant to any party's
+claim or defense--including the existence, description, nature, custody, condition, and
+location of any documents or other tangible things and the identity and location of
+persons who know of any discoverable matter. For good cause, the court may order
+discovery of any matter relevant to the subject matter involved in the action. Relevant
+information need not be admissible at the trial if the discovery appears reasonably
+calculated to lead to the discovery of admissible evidence. All discovery is subject to
+the limitations imposed by Rule 26(b)(2)(C).
+Plaintiff's complaint alleges a time period of 2004-05 as to when the alleged
+sexual misconduct of Defendant occurred. Plaintiff's request seeks to have EPSTEIN
+list "all health care providers" and "hospitals and treatment facilities" over a "ten year
+period." On its face, the interrogatory is overbroad as it seeks information over a 10
+year period that is neither relevant nor does it "appear reasonably calculated to lead to
+the discovery of admissible evidence." EPSTEIN's physical health is not in issue in this
+matter. Whether or not he was treated for the flu over the past ten years is not relevant
+to any party's claim or defense in this matter. The same is true for whether or not
+Defendant received treatment for a physical ailment at a hospital or facility over a 10
+year period. Plaintiff fails to tailor her question such that it can be determined what type
+of information she is seeking regarding "health care providers" and "hospitals and
+treatment facilities."
+The 10 year period is overbroad as it seeks information
+approximately 5 years prior to and four years after the alleged incident.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 26 of 36
+Page 26
+As to "psychologists, psychiatrists, mental health counselors," and the "hospitals
+and treatment facilities" where Defendant may or may not have received treatment from
+such professionals, such information would be protected under Fed. Evid. Rule 501 and
+§90.503, Fla.R.Evid. Rule 501 provides -
+Except as otherwise required by the Constitution of the United States or provided by
+Act of Congress or in rules prescribed by the Supreme Court pursuant to statutory
+authority, the privilege of a witness, person, government, State, or political subdivision
+thereof shall be governed by the principles of the common law as they may be
+interpreted by the courts of the United States in the light of reason and experience.
+However, in civil actions and proceedings, with respect to an element of a claim or
+defense as to which State law supplies the rule of decision, the privilege of a witness,
+person, government, State, or political subdivision thereof shall be determined in
+accordance with State law.
+(Emphasis added).
+Plaintiff alleges diversity jurisdiction, and thus, state law of Florida controls
+application of the privilege. 2d Am. Complaint, 15. The elements of Plaintiffs alleged
+claims in Counts I - Sexual Battery and Counts II - Intentional Infliction of Emotional
+Distress are also controlled by state law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938).
+Accordingly, the privileges recognized under state law apply to this action under Rule
+501. See, for example, 1550 Brickell Associates v. Q.B.E. Ins. Co., 253 F.R.D. 697,
+699 (S.D. Fla. 2008)("Attorney-client privilege is governed by state law in diversity
+actions.").
+§90.503(2), Fla. Stat., provides -
+(2) A patient has a privilege to refuse to disclose, and to prevent any other person from
+disclosing, confidential communications or records made for the purpose of diagnosis
+or treatment of the patient's mental or emotional condition, including alcoholism and
+ther drug addiction, between the patient and the psychotherapist, or persons who ar
+articipating in the diagnosis or treatment under the direction of the psychotherapis
+This privilege includes any diagnosis made, and advice given, by the psychotherapist
+in the course of that relationship.
+As summarized in C.L. V. Judd, 993 So.2d 991, 995 (2d DCA Fla. 2007):
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 27 of 36
+Page 27
+Under the psychotherapist-patient privilege, a patient has a privilege to refuse
+to disclose confidential information or records made for the purpose of
+diagnosis or treatment of mental conditions, including any diagnoses made by
+the psychotherapist. § 90.503(2), Fla. Stat. (2005); see Pauker v. Olson, 834
+So.2d 198, 200 (Fla. 2d DCA 2002). The psychotherapist-patient privilege does
+not apply: (1) during involuntary commitment proceedings, (2) when there is a
+court-ordered mental examination, or (3) when the patient raises and relies on
+the issue of his or her mental condition in litigation as part of any claim or
+defense. § 90.503(4); Roberson, 884 So.2d at 980; State v. Famiglietti, 817
+So.2d 901, 903 (Fla. 3d DCA 2002). The privilege does not allow the invasion of
+a patient's privileged communications with his or her psychotherapist.
+Roberson, 884 So.2d at 979.
+None of the three situations listed as exceptions to the privilege above exist in the
+present case to make the privilege inapplicable.
+Plaintiff's position is that the protection afforded under §90.503, Fla. Stat., does not
+apply "in a case of child abuse under Florida Statute §39.204." See endnote 2 for full
+text of $39.204, Fla. Stat.? (T's Motion, p. 8-9). See Carson v.
+466 So.2d
+1188, 1192 (Fla. 4" DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4"
+DCA 2007). A reading of these cases establishes that §39.204 does not provide
+Plaintiff with a carte blanche access to Defendant's medical history. The Court is
+required to hold an in camera inspection to determine if the information sought by
+Plaintiff relates to "communications involving known or expected child abuse." Id.
+As stated above, on its face the interrogatory is overbroad and encompasses
+information that has no relevance to the claims or defenses nor is it reasonably
+calculated to lead to the discovery of admissible evidence. Compelling Defendant to
+identify each and every health care provider, including psychologists, psychiatrists,
+mental health counselors, and hospital or treatment facility over the past ten year
+period, is not proper at this time. Plaintiff should be required to limit the information
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 28 of 36
+Page 28
+sought, as well as the time period, in her interrogatory, thus allowing the Defendant and
+Court to determine whether such information is relevant and discoverable.
+As to Defendant's HIPAA (Health Insurance Portability and Accountability Act)
+objection, as noted in the case cited in Plaintiff's motion,
+v. Woodford, 2007 WL
+309485 (E.D. Cal. 2007), (p. 9), HIPPA institutes procedural safeguards to protect the
+privacy of an individual's medical information and history. In the context of HIPAA,
+Courts have recognized three methods of health care discovery (assuming it's relevant)
+in civil litigation: (1) Obtaining a patient authorization that complies with the
+requirements and criteria, tailored to the specific case, of HIPAA as set forth in 45
+C.F.R. §164.508; (2) Court Order, which also complies with the requirements of HIPAA
+ensuring that the privacy and confidentiality of the information is protected; and (3)
+Subpoena or discovery request, which again comply with the strictures of HIPAA,
+including that the person whose records are being sought has been given proper notice.
+See Handbook of Federal Civil Discovery And Disclosure (2d Edition), Chap. 18, Sect.
+A - Health Insurance Portability and Accountability Act (HIPAA), §18.3 - Discovery of
+health care information in civil litigation; and Graham v. Dacheikh, 991 So.2d 932, at fn.
+3 (2d DCA Fla. 2008) ("Even under HIPAA, .... if the records are produced during normal
+discovery they are typically produced in a manner that restricts the persons who may
+access the documents and requires their return at the end of the litigation. See 45
+C.F.R. §164.512(e).").
+In production request no. 23, Plaintiff seeks - "All documents referring to or relating
+to Jeffrey Epstein's purchase or consumption of prescription medicine." On its face, this
+production request is over broad and seeks non-relevant information. For example,
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 29 of 36
+Page 29
+whether or not EPSTEIN takes prescription medicine for (purely as an example and for
+argument) blood pressure or cholesterol control has absolutely no relevance to this
+action.
+Accordingly, EPSTEIN's objections to interrogatory no. 8 and production request
+no. 23 are required to be upheld. Plaintiff is not entitled to carte blanche discovery of
+Defendant's medical information.
+C. Overbroad, relevance objections to discovery.
+As to Plaintiff's argument regarding Defendant's objections based on relevancy
+and the over-breadth of Plaintiff's discovery requests, (Part VI. A, pp. 10-11, of T's
+Motion To Compel), in her motion Plaintiff represents that she is seeking the discovery
+for a time period beginning January 1, 2003 to the present. As to interrogatory nos. 1,
+2, 3, 4, 5, 6, 7, 8, 10, 11, and 12, Defendant disagrees that time period proposed by
+Plaintiff is reasonable. Plaintiff's complaint alleges that the conduct involving her took
+place in 2004-05. The scope and breadth of these interrogatories evidences that
+information sought has absolutely no relevance and is not reasonably calculated to lead
+to the discovery of admissible evidence. The same is true for production request nos.
+5, 6, 7, 10, 11, 18, 20, 21, 22, and 23. As discussed more fully below, the length of the
+time period, along with the scope and breadth of the information and items sought,
+makes such requests improper under the rules governing discovery.
+Without waiving any of the other alternative and additional objections asserted,
+Defendant does not disagree with the time period of January 1, 2003 to present as to
+interrogatory nos. 13, 14, 15, 16, and 17; and production request nos. 1, 2, 3, 4, 14,
+15, 16, and 17. Defendant addresses the additional alternative objections below.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 30 of 36
+Page 30
+Plaintiff's motion to compel fails to address each of the discovery requests on an
+individual basis with respect to the objections asserted. A reading of each of the
+discovery requests, set forth above herein, establishes that each of the interrogatories
+and production requests is overbroad on its face and, thus, seeks non-relevant
+information. All of the interrogatories and production requests are phrased such that
+they encompass "all persons," "all Employees," "all telephone numbers," "all
+documents," "any and all," and so on. Contrary to Plaintiff's assertion, the definition of
+"employee" is on its face over broad and encompasses non-relevant information. (pp.
+11-12 of Plaintiff's motion). Plaintiff should be required to restrict the information that is
+sought to the issues relevant to this action and the claims asserted by her and defenses
+to those claims.
+D. Work Product; Attorney Client Privilege
+Plaintiff asserts that Defendant failed to provide a privilege log in asserting his
+objections based on attorney-client and work product privileges to interrogatories nos.
+13, 14, and 17, and production requests nos. 4 - 8 and 10 - 23. First, a reading of the
+particular discovery requests reveals that the encompass attorney-client and work
+product privileged material. Secondly, as set forth above herein, in being compelled to
+create a
+privileged log is in
+essence compelled testimony to which Defendant's
+constitutional protections would apply. Again, as stated previously, it makes judicial
+sense to decide the constitutional issues first, before deciding the additional objections
+to the discovery requests.
+E. Rules 408 and 410, Fed. Evid. Code; §90.410, Fla. Stat. - Production
+requests nos. 1 - 5.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 31 of 36
+Page 31
+Production requests nos. 1 - 5 set forth above herein, all pertain to the
+negotiation and eventual entering into of a Non-Prosecution Agreement (NPA) with the
+United States Attorney's Office (USAO) for the Southern District of Florida. See part I
+above herein. Again, the constitutional issues raised in Defendant's response permeate
+these discovery requests. The full text of Federal Evidence Rules 408 and 410, and
+Florida Statute §90.410, are set forth in endnote 3. Under the protections afforded by
+these evidentiary rules such documents are not subject to discovery.
+F. Third Party Privacy Rights
+In production requests nos. 1, 2, 3, 4, 5, 6, 7, 11, 14, 15, 16, 17, 18, 19, 20, 21,
+and 22, Defendant has raised the additional objection that the privacy rights of third
+parties are implicated. See specified requests. As noted by the United States Supreme
+Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972):
+In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated: (A)Iso
+fundamental is the right to be free, except in very limited circumstances, from
+unwanted governmental intrusions into one's privacy." The makers of our
+Constitution undertook to
+secure conditions favorable to the pursuit of
+happiness. They recognized the significance of man's spiritual nature, of his
+feelings and of his intellect. They knew that only a part of the pain, pleasure and
+satisfactions of life are to be found in material things. They sought to protect
+Americans in their beliefs, their thoughts, their emotions, and their sensations.
+They conferred, as against the Government, the right to be let alone-the most
+comprehensive of rights and the right most valued by civilized man! [Citations
+omitted].
+The fundamental right of privacy is not only guaranteed under by the Fourteenth
+Amendment of the United States Constitution, but also under the Constitution of the
+State of Florida, Art. I, Sect. 23. As summarized by the Florida Supreme Court in
+Shaktman v. State, 553 So.2d 148, 150-51 (Fla. 1989):
+The right of privacy, assured to Florida's citizens, demands that individuals be
+free from uninvited observation of or interference in those aspects of their lives
+which fall within the ambit of this zone of privacy unless the intrusion is
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 32 of 36
+Page 32
+warranted by the necessity of a compelling state interest. In an opinion which
+predated the adoption of section 23, the First District aptly characterized the
+nature of this right.
+A fundamental aspect of personhood's integrity is the power to control
+what we shall reveal about our intimate selves, to whom, and for what
+purpose.
+Bryon, Harless, Schaffer, Reid & Assocs., Inc. v. State ex rel, Schellenberg,
+360 So.2d 83, 92 (Fla. 1st DCA 1978), quashed and remanded on other
+grounds, 379 So.2d 633 (Fla. 1980). Because this power is exercised in varying
+degrees by differing individuals, the parameters of an individual's privacy can be
+dictated only by that individual. The central concern is the inviolability of one's
+own thought, person, and personal action. The inviolability of that right assures
+its preeminence over "majoritarian sentiment" and thus cannot be universally
+defined by consensus.
+(Emphasis added).
+Clearly, the nature of the questions and production requests identified would
+require EPSTEIN to identify third parties and necessarily thwart such individuals' rights
+to assert their constitutional right of privacy as guaranteed under the United States and
+Florida Constitutions. See generally Eisenstadt v. Baird, supra at 454-455 (The right
+encompasses privacy in one's sexual matters and is not limited to the marital
+relationship.).
+Ill. Conclusion
+Under applicable law and the facts and circumstances of this case, Defendant's
+assertions of his constitutional privileges and guarantees are required to be upheld. To
+rule otherwise would render EPSTEIN's constitutional protections meaningless. Also,
+the constitution issues so permeate this action that this Court should first decide those
+issues before deciding the merits of any additional objections raised by EPSTEIN.
+EPSTEIN is between the proverbial "rock and a hard place" in asserting is constitutional
+guarantees and then being compelled to make factual arguments regarding the
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 33 of 36
+Page 33
+application of his additional objections. EPSTEIN's additional objections as discussed
+herein are also required to be upheld.
+WHEREFORE Defendant requests that this Court deny Plaintiff's motion to
+compel and uphold EPSTEIN's assertion of his constitutional protections and, in the
+alternative or in addition to, uphold his additional objections
+to Plaintiff's discovery
+requests.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 25" day of March, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #3
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+ROBERT D. CRITTON, JR. ESO.
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 34 of 36
+Page 34
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+' Title 18. Crimes and Criminal Procedure
+Part I. Crimes
+Chapter 117. Transportation for Illegal Sexual Activity and Related Crimes
+§ 2422. Coercion and enticement
+(a) Whoever knowingly persuades, induces, entices, or coerces any individual to travel in
+Interstate or foreign commerce, or in any Territory or Possession of the United States, to
+engage in prostitution, or in any sexual activity for which any person can be charged with a
+criminal offense, or attempts to do so, shall be fined under this title or imprisoned not more than
+20 years, or both.
+(b) Whoever, using the mail or any facility or means of interstate or foreign commerce, or within
+ne special maritime and territorial jurisdiction of the United States knowingly persuades
+induces, entices, or coerces any individual who has not attained the age of 18 years, to engage
+in prostitution or any sexual activity for which any person can be charged with a criminal
+offense, or attempts to do so, shall be fined under this title and imprisoned not less than 10
+years or for life.
+2006 Amendments. Subsec. (b). Pub.L. 109-248, § 203, struck out "not less than 5 years and
+not more than 30 years" and inserted "not less than 10 years or for life".
+2003 Amendments. Subsec. (a). Pub.L. 108-21, § 103(a)(2)(A), struck out "10" and inserted
+"20".
+Subsec. (b). Pub.L. 108-21, § 103(a)(2)(B), struck out "15" and inserted "30".
+Pub.L. 108-21, § 103(b)(2)(A)(i), struck out ", imprisoned" and inserted "and imprisoned not less
+than 5 years and".
+Pub.L. 108-21, § 103(b)(2)(A)(ii), struck out", or both" at end of subsec. (b).
+= 39.204. Abrogation of privileged communications in cases involving child abuse,
+abandonment, or neglect
+The privileged quality of communication between husband and wife and between any
+protessional person and his or her patient or client, and any other privileged communication
+except that between attorney and client or the privilege provided in s. 90.505, as such
+communication relates both to the competency of the witness and to the exclusion of
+confidential communications, shall not apply to any communication involving the
+perpetrator or alleged perpetrator in any situation involving known or suspected child
+abuse, abandonment, or neglect and shall not constitute grounds for failure to report as
+required by s. 39.201 regardless of the source of the information requiring the report, failure to
+cooperate with law enforcement or the department in its activities pursuant to this chapter, or
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 35 of 36
+Page 35
+failure to give evidence in any judicial proceeding relating to child abuse, abandonment, or
+neglect.
+(Emphasis added).
+3 Relevancy and Its Limits
+Rule 408. Compromise and Offers to Compromise
+(a) Prohibited uses.-Evidence of the following is not admissible on behalf of any party, when
+offered to prove liability for, invalidity of, or amount of a claim that was disputed as to validity or
+amount, or to impeach through a prior inconsistent statement or contradiction:
+(1) Turnishing or offering or promising to furnish-or accepting or offering or promising to accept-
+a valuable consideration in compromising or attempting to compromise the claim; and
+(2) conduct or statements made in compromise negotiations regarding the claim, except when
+offered in a criminal case and the negotiations related to a claim by a public office or agency in
+the exercise of regulatory, investigative, or enforcement authority.
+(D) Permitted uses.-This rule does not require exclusion if the evidence is offered for purposes
+not prohibited by subdivision (a). Examples of permissible purposes include proving a witness's
+bias or prejudice; negating a contention of undue delay; and proving an effort to obstruct a
+criminal investigation or prosecution.
+CREDIT(S)
+(Pub.L. 93-595, § 1, Jan. 2, 1975, 88 Stat. 1933; Apr. 12, 2006, eff. Dec. 1, 2006).
+Rule 410. Inadmissibility of Pleas, Plea Discussions, and Related Statements
+Except as otherwise provided in this rule, evidence of the following is not, in any civil or criminal
+proceeding, admissible against the defendant who made the plea or was a participant in the
+plea discussions:
+(1) a plea of guilty which was later withdrawn;
+(2) a plea of nolo contendere;
+(3) any statement made in the course of any proceedings under Rule 11 of the Federal Rules of
+Criminal Procedure or comparable state procedure regarding either of the foregoing pleas; or
+(4) any statement made in the course of plea discussions with an attorney for the prosecuting
+authority which do not result in a plea of guilty or which result in a plea of guilty later withdrawn.
+However, such a statement is admissible (i) in any proceeding wherein another statement made
+in the course of the same plea or plea discussions has been introduced and the statement
+ought in fairness be considered contemporaneously with it, or (ii) in a criminal proceeding for
+perjury or false statement if the statement was made by the defendant under oath, on the record
+and in the presence of counsel.
+
+
+Case 9:08-cv-80232-KAM Document 56 Entered on FLSD Docket 03/25/2009 Page 36 of 36
+Page 36
+CREDIT (S)
+(Pub.L. 93-595, § 1, Jan. 2, 1975, 88 Stat. 1933; Pub.L. 94-149, § 1(9), Dec. 12, 1975, 89 Stat.
+805; Apr. 30, 1979, eff. Dec. 1, 1980.)
+Florida Evidence Code
+90.410. Offer to plead guilty; nolo contendere; withdrawn pleas of guilty
+Evidence of a plea of guilty, later withdrawn; a plea of nolo contendere; or an offer to plead
+guilty or nolo contendere to the crime charged or any other crime is inadmissible in any civil or
+criminal proceeding. Evidence of statements made in connection with any of the pleas or offers
+is inadmissible, except when such statements are offered in a prosecution under chapter 837.
+CREDIT(S)
+Laws 1976, c. 76-237, § 1; Laws 1978, c. 78-361, § 8.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.receipt.json b/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e212f41be05b56c52bf51aaa9c9ddafcf1d1dba4
--- /dev/null
+++ b/vision-fixhub/court-01/dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4.receipt.json
@@ -0,0 +1,14 @@
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+  "byte_delta": -1347,
+  "dataset": "marble-joined",
+  "doc_id": "dcebdab9a2ddd1fb8f591e7c5894dbfabe7ccccb7287292c9aa6403d78117ac4",
+  "engine": "marble-apple-vision",
+  "event_count": 39,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "a95e829288808346d309bd594845532722c617ab711163d69865fb88517e6f8a",
+  "output_sha256": "2edff3a0a70d9f3e0c9eba9d07ccf47fda695c3bcebaa4a7edbfdfaf684e858d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dcff14c24824b53c8c60df9bf64f4dfeacdddb238b3312e5ee4227ebd99402f2.md b/vision-fixhub/court-01/dcff14c24824b53c8c60df9bf64f4dfeacdddb238b3312e5ee4227ebd99402f2.md
new file mode 100644
index 0000000000000000000000000000000000000000..a051dc894958f265329d60aee824a430f7167763
--- /dev/null
+++ b/vision-fixhub/court-01/dcff14c24824b53c8c60df9bf64f4dfeacdddb238b3312e5ee4227ebd99402f2.md
@@ -0,0 +1,248 @@
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 2 of 10
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+CASE NO.: 08- 80993-CIV-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO
+COMPEL RESPONSE TO FIRST REQUEST TO PRODUCE, OVERRULE
+OBJECTIONS AND FOR AN AWARD OF REASONABLE EXPENSES
+Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this
+Memorandum in Opposition to Epstein's Motion to Compel Response to First Request to
+Produce, Overrule Objections, and for an Award of Reasonable Expenses, and state as follows:
+I.
+Introduction
+Defendant Epstein served a Request for Production, which includes (Request #s 10, 11,
+17 and 18) requests that seek to unearth all recordings and depictions of every instance of sexual
+conduct and activity which each Jane Doe might have engaged and documents evidencing the
+names and contact information of each sexual partner over the past nine years.
+Plaintiffs
+properly objected to these Requests, in that discovery on the sexual history of a childhood abuse
+victim is substantially limited in federal court; "courts should presumptively issue protective
+2
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 3 of 10
+orders barring discovery unless the party seeking discovery makes a showing that the evidence
+sought to be discovered would be relevant under the facts and theories of the particular case and
+cannot be obtained except through discovery." See Fed. R. Evid. 412, Advisory Committee
+Notes to 1994 Amendments, subdivision (c). Defendant has made no such showing in his
+Motion to Compel to overcome this presumption. Accordingly, Defendant's Motion to Compel
+must be denied in its entirety.
+Defendant also seeks in Request #1 "all tax returns and supporting documentation" dating
+back to 2002. Plaintiffs properly objected to this harassing and burdensome request, which is not
+reasonably calculated to lead to admissible evidence in the present sexual abuse case, particularly
+since Plaintiffs are not making a lost wages or lost income claim. Plaintiffs have already
+disclosed their entire employment history and the request at issue is far broader than necessary to
+determine Plaintiffs' employment or earnings history.
+Il.
+Argument
+Initially, it must be brought to the Court's attention that Epstein's request for depictions
+or recordings of the plaintiff engaged in sexual or simulated sexual activity since the year 2000
+includes materials which are unlawful for anyone to possess, particularly a registered sex
+offender such as Epstein. The notion that a registered sex offender is seeking child pornography
+should disturb this Court as much as it irks the Plaintiffs.
+Epstein incorrectly argues that Fed.R.Evid 412 is strictly an evidentiary rule and that
+Rule 26(b) must be read exclusively to determine whether information about an abuse victim's
+sexual history is discoverable. The Rule 412 Advisory Committee Notes, however, instruct that
+Rule 412 affects not only the admissibility of evidence at trial, but must also "inform the
+discovery process." Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The
+3
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 4 of 10
+Committee Notes state, in relevant part, as follows:
+Courts should presumptively issue protective orders barring
+discovery unless the party seeking discovery makes a showing that
+the evidence sought to be discovered would be relevant under the
+facts and theories of the particular case and cannot be obtained
+except through discovery.
+Nowhere in Defendant's Motion is it explained how or why this presumption should be
+overcome. It is well established under Fed.R.Evid. 412 that a victim's past sexual behavior is
+wholly irrelevant to the credibility of her testimony, and that her prior and subsequent sexual
+activity with third parties has no bearing on the issue of whether she consented to or complied
+with the sexual acts charged. See United States v.
+472 F.2d 909, 919 (5th Cir. 1973);
+Virgin Islands v.
+634 F.Supp. 933, 936-37 (D. V.I. 1986) (policy of rule disallowing
+evidence to show character of assault victim; Dept. of Professional Regulation v. Wise, 575
+So.2d 713 (Fla. Ist DCA 1991) (holding that evidence of sexual relations with a person other
+than an accused is not relevant). One commentator has noted that once the identity of persons
+and similarity of circumstances are removed, "probative value all but disappears." See Ordover,
+Admissibility of Patterns of Similar Sexual Conduct: The Unlamented Death of Character for
+Chastity, 63 Cornell L. Rev. 96, 106 (1977). The discovery at issue is not limited to sexual
+contact involving similar circumstances, and is therefore lacking in probative value. Defendant
+fails in his Motion to demonstrate otherwise.
+Defendant's argument that Rule 412 is merely an evidentiary rule that should be
+disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v.
+City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order
+pursuant to Rule 412 to prevent a sexual battery and harassment victim from having to disclose
+off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern
+4
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 5 of 10
+Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999
+WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. Herchenroeder v. John |
+| Univ. Applied
+Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving
+discovery motion);
+v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that
+"[a]lthough the present motion arises in the context of discovery under Rule 26, the Court must
+remain mindful of Rule 412 and its implications); Stalnaker v. Kmart Corp., 1996 WL 397563
+(D. Kan. 1996) (noting that Rule 412 "is applicable and has significance in deciding certain
+discovery motions*).
+As the above-referenced cases make abundantly clear, childhood sexual abuse cases are
+not garden-variety litigation subject to traditional broad discovery concerning a victim's sexual
+history.
+Rule 412 is designed to protect victims of sexual misconduct from undue
+embarrassment and intrusion into their private affairs. See Fed R.Evid. 412. The committee
+notes explain that the Rule is also intended to prevent "sexual stereotyping that is associated with
+public disclosure of intimate sexual details and the infusion of sexual innuendo into the
+factfinding process." Rule 412, Advisory Committee Notes to 1994 Amendments. Common
+sense dictates that requiring a sexual abuse victim to disclose the intimate details and recordings
+sought by Epstein during the discovery process - which then would presumably lead to
+additional discovery of the victim's other sexual partners - would be at least as embarrassing and
+intrusive during the discovery process as it would be if the victim were questioned about these
+facts at trial, if not more. Thus, in order to carry out its purpose, Rule 412 "must inform the
+discovery process" and the Court "must impose certain restriction on discovery to preclude
+inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See
+Barta v. City and County of Honolulu, 169 F.R.D. at 135.
+5
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 6 of 10
+In Barta, the Court confronted this issue in the context of a discovery motion in a civil
+case. 169 F.R.D. at 133. A former employee brought a sexual harassment and battery claim
+against her former employer and individual employees. Id. The defendants asked questions at
+deposition which delved into the plaintiff's sexual conduct outside the workplace. Id. at 134. The
+Court did not allow these questions and wait until trial to determine admissibility. Id. at 135.
+Instead, the Court sustained the plaintiff's objections. Id. The Court based its decision on
+Fed.R.Evid. 412. Id. Although noting that Rule 412 controls the admissibility of evidence, the
+Court explained that it must also apply Rule 412 to "impose certain restrictions on discovery to
+preclude inquiry into areas which will clearly satisfy the balancing test of 412(b)(2)..." Id.
+Thus, the Court concluded that the defendants should not be permitted to inquire into the
+plaintiff's conduct while she was off-duty, outside the workplace, and which did not involve the
+same defendants. The same rationale should apply here. The Defendant should not be permitted
+to seek intimate details and recordings of Plaintiff's sexual conduct throughout her life.
+Defendant attached three Florida state court orders to its Motion, two of which are trial
+court decisions. These cases do not serve as precedent for this Court, and in any event, they are
+not persuasive. Unlike state courts, federal courts must focus on the interplay between
+Fed.R.Evid. 412 and Fed.R.Civ.P. 26(b), and in this regard must be concerned with
+embarrassment to the victim and protection of her privacy. Indeed, it does not appear that an
+analogous argument was made in any of the state court cases relied upon by Defendant.
+Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far
+narrower than that which is at issue here. It was limited to asking plaintiffs for their employment
+history (which admittedly included prostitution), employment records, electronic recording of the
+conduct which was the subject of the complaint, and a description of her damages. 703 So.2d
+6
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 7 of 10
+1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history
+beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to
+the Defendant, and should not deflect attention from the burden placed on the party in federal
+court seeking discovery of a victim's other sexual contacts.
+With regard to Request #1 for "all tax returns and supporting documentation", the
+Defendant has not (and cannot) show how these documents are conceivably relevant. Plaintiffs
+are not making a claim for lost income or wages. See Exhibit "A". Moreover, Plaintiffs have
+disclosed their entire employment history and agreed to execute authorizations allowing
+Defendant to obtain their employment personnel records. Given the nature of the claim
+involving sexual assault, it is inconceivable how the tax returns, W-2s, and 1099s, and all other
+"supporting documentation" could be relevant. Cases in which the plaintiff has been ordered to
+produce tax returns is limited to situations involving
+transactions or in which the plaintiff is
+seeking to recover lost wages, lost profits, royalty payments, or similar relief. See Bellose v.
+Universal Tile Restoration, 2008 WL 2620735 (S.D. Fla. June 30, 2008); United States v.
+Certain Real Property ,444 F.Supp.2d 1258 (S.D. Fla. 2006). The instant case involving sexual
+assault is readily distinguishable and the mere filing of a lawsuit does not place all of one's
+income and earnings at issue. Further, if it is Plaintiff's employment history or earnings that
+Defendants are seeking to discover, a request for all "supporting documentation" pertaining to
+their tax returns is overbroad and far more burdensome than necessary to acquire this
+information.
+Finally, Defendant's request for attorney's fees and costs is completely unwarranted. The
+present motion and response involve good-faith, timely and well-founded objections by Plaintiffs
+to over-reaching and harassing discovery efforts. Accordingly, Defendant's request for award of
+7
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 8 of 10
+reasonable expenses should be denied.
+Conclusion
+Based on the foregoing, Plaintiffs respectfully request that Defendant's Motion to
+Compel Response to First Request to Produce, Overrule Objections, and for an Award of
+Reasonable Expenses be denied in their entirety.
+Dated: May 6, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+8
+
+
+Case 9:08-cv-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 9 of 10
+CERTIFICATE OF SERVICE
+I hereby certify that on May 6, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+
+
+Case 9:08-cV-80380-KAM Document 100 Entered on FLSD Docket 05/06/2009 Page 10 of 10
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz
+10
diff --git a/vision-fixhub/court-01/dcff14c24824b53c8c60df9bf64f4dfeacdddb238b3312e5ee4227ebd99402f2.receipt.json b/vision-fixhub/court-01/dcff14c24824b53c8c60df9bf64f4dfeacdddb238b3312e5ee4227ebd99402f2.receipt.json
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diff --git a/vision-fixhub/court-01/dd1000128fc17a6378762a32027b3dec0b888485db7b55c56b691b9b4f2c6162.md b/vision-fixhub/court-01/dd1000128fc17a6378762a32027b3dec0b888485db7b55c56b691b9b4f2c6162.md
new file mode 100644
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@@ -0,0 +1,24 @@
+Case 9:08-cv-80736-KAM Document 249 Entered on FLSD Docket 05/07/2014 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER
+This cause is before the Court upon Jane Doe 1 and Jane Doe 2's Notice of Intent to Comply
+with Court Order Directing Filing of an Unredacted Motion and Correspondence in the Public Court
+File (DE 248).
+On April 18, 2014, the Eleventh Circuit affirmed several orders of this Court, and lifted the
+stay it had imposed in relation to one of the orders. However, no mandate has been issued thus far.
+Accordingly, petitioners should not comply with the Order Granting Petitioners' Motion to Proffer
+Government Correspondence in Support of CVRA Claims & Granting Motion to Unseal
+Correspondence and Related Unredacted Pleadings of Petitioners (DE 188) until further order of this
+Court.
+DONE AND ORDERED in
+this 7" day of May, 2014.
+at West Palm Beach, Palm Beach County, Florida,
+KENNETH A. MARRA
+United States District Court
diff --git a/vision-fixhub/court-01/dd1000128fc17a6378762a32027b3dec0b888485db7b55c56b691b9b4f2c6162.receipt.json b/vision-fixhub/court-01/dd1000128fc17a6378762a32027b3dec0b888485db7b55c56b691b9b4f2c6162.receipt.json
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diff --git a/vision-fixhub/court-01/dd26f928897712ea06edccb3d8c45231470c7efc46c21ebb7a0d15431ac1fd95.md b/vision-fixhub/court-01/dd26f928897712ea06edccb3d8c45231470c7efc46c21ebb7a0d15431ac1fd95.md
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@@ -0,0 +1,29 @@
+Case 9:08-cv-80119-KAM Document 514-1
+Entered on FLSD Docket 04/02/2010 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE
+LIMITATION IN RULE 4 APPEALS) RELATED TO THE MAGISTRATE'S
+ORDERS ENTERED AT DOCKET ENTRIES 462, 480, AND 513
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+to Exceed Page Limitation in his rule 4 Appeals) related to the Magistrate's Orders
+entered at DE 462, DE 480, and DE 513. Having considered Defendant's Motion to
+exceed page limitation, it is HEREBY ORDERED and ADJUDGED that:
+Defendant's motion is GRANTED. Defendant's Rule 4 Appeal may exceed the
+specified page limitation by 10-15 pages.
+DONE and ORDERED this
+_day of
+, 2010.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies: Counsel of Record
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diff --git a/vision-fixhub/court-01/dd7815b45d15cdb448c7f339d6f6abafa3e7a1d3f8f2013e7d3f7ff3cd5b2065.md b/vision-fixhub/court-01/dd7815b45d15cdb448c7f339d6f6abafa3e7a1d3f8f2013e7d3f7ff3cd5b2065.md
new file mode 100644
index 0000000000000000000000000000000000000000..d6c5a440c328e42417e4192d78f33abb82b05c49
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@@ -0,0 +1,31 @@
+Case 1:19-CV-09610-PAE-DCF Document 40 Filed 01/10/20 Page 1 of 1
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman"
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz(@troutman.com
+January 10, 2020
+ECF
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re: Jane Doe 17 v. Darren _. Indyke and Richard D. Kahn, Co-Executors of the Estate
+of Jeffrey E. Epstein, et al., 1:19-cv-09610-PAE-DCF; Status Report
+Dear Judge Freeman:
+We represent Defendants Darren _. Indyke and Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein, Nine East 71st Street Corporation, Laurel, Inc., Financial Trust Company
+Inc., NES, LLC, Maple, Inc., LSJE, LLC, HBRK Associates, Inc., Nautilus, Inc., Cypress, Inc.,
+and JEGE, Inc. (together, "Defendants"; and Defendants together with Plaintiff Jane Doe 17, the
+"Parties") in the referenced action. We provide this status report on behalf of all Parties.
+Per the Parties' Stipulation So Ordered on January 9, 2020 (ECF No. 39), the Court has stayed
+this action pending Plaintiff's participation in the Epstein Victims' Compensation Program.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+40985322v1
diff --git a/vision-fixhub/court-01/dd7815b45d15cdb448c7f339d6f6abafa3e7a1d3f8f2013e7d3f7ff3cd5b2065.receipt.json b/vision-fixhub/court-01/dd7815b45d15cdb448c7f339d6f6abafa3e7a1d3f8f2013e7d3f7ff3cd5b2065.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/dd7835c630df9109b4dd6a4c1f43cf91454ac73a8aab947ea1c6e1f0726db1e6.md b/vision-fixhub/court-01/dd7835c630df9109b4dd6a4c1f43cf91454ac73a8aab947ea1c6e1f0726db1e6.md
new file mode 100644
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@@ -0,0 +1,240 @@
+Case 9:08-CV-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 1 of 8
+Case 9:08-cV-80380-KAM
+Document 62
+Entered on FLSD Docket 02/27/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+SECOND AMENDED COMPLAINT
+Plaintiff, Jane Doe No. 4 ("Jane" or "Jane Doe"), brings this Amended Complaint against
+Jeffrey Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 4 is a citizen and resident of the State of Florida, and is sui juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+4. This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (i) is between citizens of different states.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein, which form part of
+- 1-
+
+•16=
+
+
+Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 2 of 8
+Case 9:08-cv-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 2 of 8
+the same case or controversy.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein"') was an adult male, 52
+years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires.
+He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+9.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2002-2003, Jane Doe, then approximately 15 years old, fell into Epstein's
+trap and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St.
+11. Epstein's scheme involved the use of young girls to recruit underage girls.
+a Palm Beach Community College student from Loxahatchee, Florida recruited girls
+ostensibly to give a wealthy man a massage for monetary compensation in his Palm Beach mansion.
+The young girls would be contacted when Epstein was planning to be at his Palm Beach residence
+or soon after he had arrived there.
+upon information and belief, generally sought out
+economically disadvantaged underage girls from western Palm Beach County who would be enticed
+by the money being offered - generally $200 to $300 per "massage" session - and who were
+perceived as less likely to complain to authorities or have credibility if allegations of improper
+- 2-
+
+
+Case 9:08-cV-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 3 of 8
+Case 9:08-cv-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 3 of 8
+conduct were made. This was an important element of Epstein's plan.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought to the kitchen entrance of Epstein's mansion, where she would be
+introduced to
+, Epstein's assistant.
+would then bring the girl up a flight of
+stairs to a bedroom that contained a massage table in addition to other furnishings. There were
+photographs of nude women lining the stairway!
+and in the bedroom. The girl would then find
+herself alone in the room with Epstein, who would be wearing only a towel. He would then remove
+his towel and lie naked on the massage table, and direct the girl to remove her clothes. Epstein
+would then perform one or more lewd, lascivious and sexual acts, including masturbation and
+touching the girl's vagina.
+13.
+Consistent with the foregoing plan and scheme, when Jane Doe was approximately 15
+years old, she was recruited by
+to give Epstein a massage for monetary compensation.
+Jane was brought to Epstein's mansion in Palm Beach, to the kitchen entrance. Once there, Jane
+was introduced to
+, who led her up the flight of stairs to the room with the massage
+table. In this room, Jane was directed by Epstein to remove her clothes and give him a massage.
+Jane initially kept her panties and bra on, and complied with Epstein's instructions. Jane was paid
+by Epstein for this massage.
+14.
+Jane returned on many occasions to the Palm Beach mansion to provide Epstein with
+massages. On those occasions, Epstein engaged in sexual contact and activity with the minor Jane,
+which included, among other things, directing Jane to remove all her clothes, masturbating during
+the massage, and digitally penetrating Jane's vagina. Jeffrey Epstein often used a vibrator on the
+minor Jane during the massage. This sexual abuse continued for approximately three years.
+15.
+As a result of these encounters with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+- 3 -
+
+
+Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 4 of 8
+Case 9:08-cv-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 4 of 8
+COUNTI
+Sexual Assault and Battery
+16.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+17.
+Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
+apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+18.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril.
+19.
+Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
+with the intent to cause such contact or the apprehension that such contact is imminent.
+20.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+21.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+22.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+23.
+24.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+Epstein's conduct was intentional or reckless.
+25.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+of decency.
+-4-
+
+
+Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 5 of 8
+Case 9:08-CV-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 5 of 8
+26.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
+emotional health to be significantly impaired.
+27.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+28.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+29.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 15 above.
+30.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+31.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMIB), for conduct involving the same plan and
+scheme as alleged herein.
+32.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f, (g), and (h) thereof), and other
+- 5-
+
+
+Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 6 of 8
+Case 9:08-CV-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 6 of 8
+criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+33.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+34.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+35.
+Plaintiff hired Herman & Mermelstein, P.A.., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: February 27, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz_
+Stuart S. Mermelstein (FL Bar No. 947245)
+Adam ox bureat ey. Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Ittorneys for Plaintif
+8205 Biscayne Blvd., Suite 221
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 6-
+
+
+Case 9:08-cv-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 7 of 8
+Case 9:08-CV-80380-KAM Document 62 Entered on FLSD Docket 02/27/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on February 27, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+/s/ Adam D. Horowitz
+- 7-
+
+
+Case 9:08-cV-80380-KAM Document 157-1 Entered on FLSD Docket 05/06/2010 Page 8 of 8
+Case 9:08-cv-80380-KAM Document 62
+Entered on FLSD Docket 02/27/2009 Page 8 of 8
+SERVICE LIST
+DOE Ys. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz.
+- 8 -
diff --git a/vision-fixhub/court-01/dd7835c630df9109b4dd6a4c1f43cf91454ac73a8aab947ea1c6e1f0726db1e6.receipt.json b/vision-fixhub/court-01/dd7835c630df9109b4dd6a4c1f43cf91454ac73a8aab947ea1c6e1f0726db1e6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..47588c8470501d181a76d23a3c7f39d161c09edc
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+++ b/vision-fixhub/court-01/dd7835c630df9109b4dd6a4c1f43cf91454ac73a8aab947ea1c6e1f0726db1e6.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.md b/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.md
new file mode 100644
index 0000000000000000000000000000000000000000..4c827e1fb1c76a2308928755e6eb72a5fdad706a
--- /dev/null
+++ b/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.md
@@ -0,0 +1,60 @@
+Case 9:08-cv-80119-KAM Document 431-2 Entered on FLSD Docket 12/02/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAI
+JANE DOE NO. 2,
+Plaintift,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+JANE DOE NOS.' 2,3, and 5-8 OBJECTION TO SUBPOENA DUCES TECUM
+DATED NOVEMBER 13, 2009 ISSUED TO PRESIDENTAL WOMEN'S CENTER
+Plaintiffs, Jane Doe Nos. 2, 3, and 5-8, by and through their undersigned counsel, and
+pursuant to Federal Rules of Civil Procedure 26 and 45, hereby object to the Subpoena Duces
+Tecum issued by Jeffrey Epstein to the records custodian of Presidential Women's Center dated
+November 13, 2009 on the basis that said subpoena is not reasonably calculated to lead to the
+discovery of admissible evidence and constitutes an invasion of the privacy rights of the
+plaintiffs. There is no evidence or other indication whatsoever to indicate that Jane Doe Nos. 2,
+3, and 5-8 have had an abortion at Presidential Women's Center, 100 Northpoint Parkway, West
+Palm Beach, Florida 33401 or otherwise been seen or treated at that facility. Accordingly, this
+subpoena seeking records relating to these Plaintiffs is a pure "shot in the dark" attempt to obtain
+discovery, rather than the reasonably calculated discovery effort as required by the Federal Rules
+of Civil Procedure. Pursuant to this objection, Plaintiffs Nos. 2, 3, and 5-8 request that non-party
+1
+"B"
+
+
+Case 9:08-cv-80119-KAM Document 431-2 Entered on FLSD Docket 12/02/2009 Page 2 of 2
+Presidential Women's Center not answer any questions or produce any records in response to the
+Subpoena Duces Tecum in the absence of a Court Order requiring such disclosure.
+Dated: November 25, 2009
+Respectfully submitted,
+By:
+.."-
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs Jane Doe Nos. 2-8
+18205 Biscayne Blvd., Suite 2218
+Miami. Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that a true copy of the foregoing has been sent to the following
+via e-mail transmission, this 25th day of November, 2009:
+Louis Silber, Esq.
+Attorney for Presidential Women's Center
+Isilber@svdlaw.net
+Robert D. Critton, Jr, Esq.
+rcrit@bclclaw.com
+Michael James Pike, Esq.
+MPike@bclclaw.com
+s/ Adam D. Horowitz
+2
diff --git a/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.receipt.json b/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b3e096c3f5c463c3f19f9e210150d4126632c0ca
--- /dev/null
+++ b/vision-fixhub/court-01/dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "dd7949cbe17876849a16af6c33d4c7c3c14a8c9aba932def65cb6c3fd6866e92",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d29dee70728415fb5320de3640bd2e4cebd8f765f7df54526f89af1cb77d9e09",
+  "output_sha256": "d725136e4471cd24a0591feb2aa0f494c0390c4f2af4bf3574b8f2fe576cc747",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.md b/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.md
new file mode 100644
index 0000000000000000000000000000000000000000..26dff20a167b5717bf229d889bb1e726efb1c43b
--- /dev/null
+++ b/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.md
@@ -0,0 +1,35 @@
+Case 1:19-cv-11869-MKV-DCF Document 4
+Filed 01/02/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ANASTASIA DOE,
+Plaintiff,
+Case No. 1:19-cv-11869
+VS.
+DARREN K. INDYKE AND RICHARD D.
+KAHAN, AS CO-EXECUTORS OF THE ESTATE
+OF JEFFREY E. EPSTEIN,
+MOTION FOR ADMISSION
+PRO HAC VICE
+Defendant.
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and
+Eastern Districts of New York,
+J.
+hereby moves this Court for an Order for
+admission to practice Pro Hac Vice to appear as counsel for Plaintiff ANASTASIA DOE in the
+above-captioned action.
+I am in good standing of the bar of the State of Florida and the State of New York and there
+are no pending disciplinary proceedings against me in any state or federal court. I have never been
+convicted of a felony. I have never been censured, suspended, disbarred or denied admission or
+readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3
+Dated: December 27, 2019
+Fort Lauderdale, Florida
+Respectfully submitted,
+POTTINGER, LLC
+NY Bar No.: 5749684
+Brittany N. M
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+(954)-524-2820
+Fax: (954)-524-2822
+(Seeking Admission Pro Hac Vice)
diff --git a/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.receipt.json b/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2dc8a8854edf1a90481b005692f2e47a4afb21c4
--- /dev/null
+++ b/vision-fixhub/court-01/dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "dd9d132453937a9c200456736e231dc00f80dc85cabd475452d4a4636d43b1f3",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "64e9a4e5b82004d4a9caeedaf8e5b36b1b10289d82e05ac62531ac5de807e754",
+  "output_sha256": "d0c504ef2b1cc77f2ab099d147fb08a65af6018d422e34c70de2f96be45aba7c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.md b/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.md
new file mode 100644
index 0000000000000000000000000000000000000000..9333addf46ec34676a422e12b0948f353319640f
--- /dev/null
+++ b/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.md
@@ -0,0 +1,72 @@
+Case 9:08-cv-80119-KAM Document 57-3 Entered on FLSD Docket 03/02/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+v.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS TO
+SECOND REQUEST FOR PRODUCTION, dated December 19, 2008
+Defendant, JEFFREY EPSTEIN, by and through his undersigned
+attorneys, serves his responses and objections to the Request to Produce, dated
+December 19, 2008 and states:
+Request No. 1. All policies of insurance, including the declarations
+page and all binders, amendments, and endorsements, covering Defendant's
+residence at 358 El Brillo Way, Palm Beach, FL 33480.
+Response: Objection, overly broad, not relevant and material and not
+calculated to lead to the discovery of admissible evidence. Plaintiff alleged
+claims occurred during a specific time period in 2004 - 2005, yet to be
+specifically identified. Yet, no time period whatsoever is set forth in the Request
+for Production. Additionally, Defendant objects in that the policies contain value
+and/or asset information which is not relevant, material nor calculated to lead to
+the discovery of admissible evidence at this point in time; said information is both
+private and confidential.
+
+
+
+Case 9:08-CV-80119-KAM Document 57-3 Entered on FLSD Docket 03/02/2009 Page 2 of 2
+Jane Doe No. 2 v. Epstein (
+Page 2
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sent
+via U.S. Mail and facsimile to the following addressees this
+26th
+_day of
+January, 2009.
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey
+Respectfully submitted,
+ROBERT D/CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclcfaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+Fax: 561-515-3148
+(Co-counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.receipt.json b/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5000eb397f377c66764c9f177bcb4a993aca7a77
--- /dev/null
+++ b/vision-fixhub/court-01/dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "dde81bc662ed0e1a394120de2128f83b1bae91e10e26cb22c562556b005a1fc3",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "850e5218947650d06a04f0373cd59670aa60b73b935abe24d829a836e054e8e1",
+  "output_sha256": "c25c56159864af01569205e9c3efc9bf2e20872cc085ecaefc31e045ee6b8fde",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.md b/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.md
new file mode 100644
index 0000000000000000000000000000000000000000..3aa3e070a13d49dea50968a3e70530fbbe4e6363
--- /dev/null
+++ b/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.md
@@ -0,0 +1,141 @@
+Case 9:08-cv-80119-KAM Document 514 Entered on FLSD Docket 04/02/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/||
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE LIMITATION IN
+RULE 4 APPEALS) RELATED TO THE MAGISTRATE'S ORDERS
+ENTERED AT DOCKET ENTRIES 462, 480, AND 513
+Defendant, Jeffiey Epstein (hereinafter "Epstein"), by and through his
+undersigned attorneys, and Pursuant to Rule 4, Review and Appeal - Southern District,
+and other applicable rules as well as this court's discretion, respectfully moves this Court
+for an
+Order granting Defendant's Motion to Exceed the Page Limitation in his Rule 4
+Appeals) related to te Magistrate's Orders entered at DE 462, DE 480 and DE 513. As
+good cause in support of granting the motion, Defendant states:
+This Court entered an Order on February 4, 2010 (DE 462) stating that
+Epstein must provide documents responsive to request to numbers 7, 9, 10, 12, and 13
+within 14 days from the date of said order. Defendant filed a Motion for Reconsideration
+and Rule 4 Appeal on February 26, 2010 (DE 477).
+
+
+Case 9:08-cv-80119-KAM Document 514 Entered on FLSD Docket 04/02/2010 Page 2 of 4
+2. On March 4, 2010, this Court entered an Order related to Net Worth
+Discovery (DE 480) requesting similar information addressed in DE 462. Defendant
+filed a Motion for Reconsideration and Rule 4 Appeal on March 15, 2010.
+3.
+On April 1, 2010, this Court entered an Order Denying Defendant's
+Motion for Reconsideration (DE 513). However, the Order allows the Defendant to file
+formal appeals with the District Court within ten (10) days.
+4.
+In order to present the Defendant's appeals in an organized and
+understandable manner, the 20 page limitation is required to be exceeded by
+approximately 10-15 pages.
+The Defendant does not believe that Plaintiffs' counsel will have an
+objection to this request.
+Wherefore, the undersigned respectfully requests the relief sought herein, and for
+such other and further relief as this court deems just and proper.
+Local Rule 7.1 Statement
+Counsel for the movant attempted to confer with counsel for the Plaintiffs',
+however at the time of this filing had not received a response.
+By: _/s/ Michael J. Pike_
+ROBERT D. CRITTON, JR.
+Florida Bar #224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+
+
+Case 9:08-cv-80119-KAM Document 514 Entered on FLSD Docket 04/02/2010 Page 3 of 4
+Certificate of Service
+THEREBY CERTIFY that the foregoing document is being served this day on all
+counsel of record identified on the following Service List in the manner specified by
+electronic mail (e-mail) on this 2nd day of April, 2010.
+Respectfully submitted,
+By: Is/ Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Case No. 0B 8019-MARRA JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Adam D. Horowitz, Esq.
+Fistos
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+, Jaffe, Weissing,
+& Lehrman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No.
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993, Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+
+
+Case 9:08-cv-80119-KAM Document 514 Entered on FLSD Docket 04/02/2010 Page 4 of 4
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469
diff --git a/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.receipt.json b/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9d9183288d65458e19e8a3ed77bbf249d4255c5f
--- /dev/null
+++ b/vision-fixhub/court-01/de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "de0a995cb7beccf84a11da219e6b4630d7727c9391d62d774fdc0bf92364cd1e",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "17e1e6231f07e5b68bce85782724b7b44a4db8bc92f3dd0260e774c0d55c50bc",
+  "output_sha256": "3349d9082fc059ee1102e360292d09499221cc2fc8abd2674cb2164081c585fc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/de3ae813d6aa13654f23220e11f5fa4c5199d4f9b276ad9768c860f20beffea1.md b/vision-fixhub/court-01/de3ae813d6aa13654f23220e11f5fa4c5199d4f9b276ad9768c860f20beffea1.md
new file mode 100644
index 0000000000000000000000000000000000000000..4314284c72716adf1f15e0fd6b59b3c3f3fb86b9
--- /dev/null
+++ b/vision-fixhub/court-01/de3ae813d6aa13654f23220e11f5fa4c5199d4f9b276ad9768c860f20beffea1.md
@@ -0,0 +1,293 @@
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+CASE NO.: 08-CV-80232-MARRA/_
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 2 of 10
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-MARRA/ l
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 3 of 10
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRAC
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOE NO. 101 AND JANE DOE NO. 102'S REPLY
+IN SUPPORT OF PLAINTIFFS' MOTION FOR AN ORDER FOR THE
+PRESERVATION OF EVIDENCE
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (collectively, "Plaintiffs") reply to
+Defendant Jeffrey Epstein's Response to Plaintiffs' Motion for an Order for the Preservation of
+Evidence ("Response") and state as follows:
+1.
+Defendant complains that Plaintiffs "once again mislead and mischaracterize the
+criminal counts to which Epstein pled guilty" (Resp. I 1) and that Plaintiffs' allegations in
+paragraphs 2 and 3 of Plaintiffs' Motion for an Order for the Preservation of Evidence ("Motion")
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 4 of 10
+are without factual basis (id. I| 2). While Plaintiffs strenuously disagree with Defendant's
+statements, these allegations and denials are irrelevant to this Motion for an Order for the
+Preservation of Evidence.
+2.
+Defendant asserts that he previously agreed to preserve all necessary evidence
+by way of an Order, attached to his Response as Exhibit "A," which Order was entered in another
+counsel's earlier-filed case, Jane Doe a/k/a Jane Doe No. 1 v. Epstein et al., Case No. 08-80804-
+CIV-MARRA
+[D.E. 20]. Defendant's attorneys state that they have no objections to a
+similar order being issued in the present case (see Resp. I| 4); however, defense counsel fail to
+mention in their Response that the Order in Jane Doe No. 1 does not provide for the preservation
+of evidence that Plaintiffs are requesting in the present case. The discovery request in Jane Doe No.
+1 pertains merely to items listed in a property receipt for evidence confiscated by the Palm Beach
+Police Department. Here, Plaintiffs, through their Motion, request the preservation of relevant and
+discoverable evidence beyond those confiscated items. Defendant asserts no specific objections to
+any of the items listed in paragraphs 8 through 10 of Plaintiffs' Motion, but, instead, asks the Court
+to enter an order similar to the Order in Jane Doe No. I, which would be tantamount to denying
+most of Jane Doe No. 101 and Jane Doe No. 102's preservation request.
+3.
+Defendant objects to Plaintiffs' request for preservation as being "grossly overly
+broad" (Resp. 9| 7), but fails to demonstrate any basis for this objection. Furthermore, this contention
+is hypocritical, considering that Defendant issued an equally, if not more, expansive request in his
+May 12, 2009 letter to Plaintiffs' counsel. See Ex. "A," attached hereto. Plaintiffs specify in
+paragraphs 8 through 10 of their Motion that the list of items to be preserved consists of relevant
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 5 of 10
+evidence.' In contrast, Defendant's letter requests the preservation of all computer files and
+electronic data, without any specification limiting his request to potentially relevant documents.
+4.
+Defendant complains that Plaintiffs" request to preserve evidence includes
+information that is not calculated to lead to the discovery of admissible evidence. However,
+potential admissibility is not relevant to a preservation order, as the court recognized in Capricorn
+Power Co. v. Siemens Westinghouse Power Corp., 220 F.R.D. 429, 434 (W.D. Pa. 2004): "[A]
+motion for a preservation order can be granted with regard to all items of evidence which are
+discoverable in accordance with Federal Rule of Civil Procedure 26(b)(1), without the necessity of
+establishing that the evidence will necessarily be relevant and admissible at trial."
+Defendant's Fifth Amendment concerns are premature, as Plaintiffs are not asking
+Defendant to produce evidence. Defendant admits in his Response that "It]he Fifth Amendment
+Privilege extends to the act of production ...." (Resp. I 7). Indeed, Defendant's entire Fifth
+Amendment privilege argument throughout his Response rests solely on case law dealing with the
+production of evidence. Defendant does not cite to any authority for his assertion that the privilege
+against self-incrimination applies to preserving, as opposed to producing, evidence. Unsurprisingly,
+Defendant merely posits, with no legal basis, that "Plaintiffs' motion to preserve evidence ... is in
+reality no different that [sic] propounding a discovery request upon Defendant, ...." (id.) Such an
+assertion is senseless.
+If and when a notice to produce is served, the Court will determine the
+One example of a relevant request by Plaintiffs in their Motion is for "records of
+domestic and international travel, including travel in Defendant's private airplanes; ...
+Motion I 8. Considering Count Two of Jane Doe No. 101's Amended Complaint, which is
+entitled "Travel with Intent to Engage in Illicit Sexual Conduct pursuant to 18 U.S.C. § 2255 in
+Violation of 18 U.S.C. § 2423(b)," (Amended Complaint 99 29-32), records of Defendant's
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 6 of 10
+validity of any claims of Fifth Amendment privilege. Until then, briefing Fifth Amendment
+privilege issues is a waste of the Court's and counsel's time.
+6.
+Finally, whether the Non-Prosecution Agreement is, as Defendant coins it, a
+"deferred prosecution agreement" (see Resp. I 6), is irrelevant to Plaintiffs' Motion for an Order for
+the Preservation of Evidence.
+WHEREFORE, Plaintiffs request that the Court enter the order that Plaintiffs submitted with
+their Motion for an Order for the Preservation of Evidence.
+DATED this 22"d day of June, 2009.
+By:
+Respectfully submitted,
+s/Robert C. Josefsberg
+Robert C. Josefsberg,
+Bar No. 040856
+Katherine W. Ezell, Bar No. 114771
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+(305) 358-2800
+(305) 358-2382 (fax)
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 7 of 10
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this 22™d day of June, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By:
+s/Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:08-cv-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 8 of 10
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+isx @searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:08-cV-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 9 of 10
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-80381,
+08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+1, Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+
+
+Case 9:08-cV-80119-KAM Document 177 Entered on FLSD Docket 06/22/2009 Page 10 of 10
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia (@ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
diff --git a/vision-fixhub/court-01/de3ae813d6aa13654f23220e11f5fa4c5199d4f9b276ad9768c860f20beffea1.receipt.json b/vision-fixhub/court-01/de3ae813d6aa13654f23220e11f5fa4c5199d4f9b276ad9768c860f20beffea1.receipt.json
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+}
diff --git a/vision-fixhub/court-01/de3d44d893774743a145b905ac520fcf212e28ba7a9e926fedd11f4d5d01c42e.md b/vision-fixhub/court-01/de3d44d893774743a145b905ac520fcf212e28ba7a9e926fedd11f4d5d01c42e.md
new file mode 100644
index 0000000000000000000000000000000000000000..63301b7624d301d5ac16f29ed1d5994b8420848b
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@@ -0,0 +1,287 @@
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Response To Plaintiff's, Jane Doe No.: 4, Motion for Protective Order (DE 534),
+With Incorporated Memorandum Of Law
+Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his
+undersigned attorneys, hereby files his Response In Opposition to Plaintiffs', Jane Doe's
+Motion for Protective Order (DE 534), With Incorporated Memorandum Of Law (the
+"Motion for Protective Order"). In support, Epstein states as follows:
+I.
+Introduction & Argument
+Plaintiff and her counsel have now resurrected their collective efforts to
+prevent discovery relating to Plaintiff's psychological, criminal and employment
+histories, as well as their general backgrounds. Plaintiff unreasonably continues to delay
+discovery knowing full well that the court has already entered orders allowing for
+discovery as to third parties. Plaintiffs once again requests that this court preclude Epstein
+from investigating these matters through one of the most traditional methods available in
+1
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 2 of 9
+the justice system, depositions.
+2.
+Epstein has been faced with several motions seeking to prevent or limit
+discovery with the primary goal being to send Epstein to trial with little or no discovery.
+Plaintiff continues to avert discovery, and now she wishes to shelter her pasts by
+requesting that this court enter an order broadly limiting the rules of discovery and thus
+preventing Epstein from deposing third parties, including two individuals that were Jane
+Doe 4's soccer coaches for years (i.e., Rocky Orezzoli and Bill
+. Limiting such
+discovery would undoubtedly result in reversible error. Plaintiff claims Epstein is
+harassing her by way of seeking those depositions; however, such is not the case.
+Coaches have an identifiably close relationship with their players and, often times, their
+players confide in them about events which they would not address with their very own
+parents. As such, these two deponents are clearly relevant, and their depositions are not
+being set as a means of harassment. Moreover, Defendant does not intend to violate the
+court's order at DE 433.
+3.
+As the court knows, Plaintiffs' have several preexisting and diagnosed
+conditions for which they now attempt to pawn off on Epstein in an effort to increase
+their damages. For instance, prior to any of their alleged encounters with Epstein, certain
+Plaintiffs have been raped, sexually abused, molested and physically and verbally abused.
+Some of them have been diagnosed with post traumatic stress disorder or obsessive
+compulsive disorder, and some have suicidal thoughts and/or have attempted suicide on
+more than one occasion. Moreover, some of the Plaintiffs have witnessed close friends or
+family members commit suicide. While the above incidents are nothing less than tragic,
+the impact of those incidents on each of the Plaintiffs must be taken into consideration
+2
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 3 of 9
+with the claims they make and the damages they seek against from Epstein.
+4.
+Plaintiff has objected to all meaningful discovery, and now she seeks to
+halt or limit traditional discovery methods at the very time she suspects Epstein is going
+to learn information that may diminish or disprove her claims. In fact, the questions
+outlined on pages 3-4 of DE 534 are clearly relevant to Plaintiff's general background
+(see infra), her sexually explicit experiences including, but not limited to, events taking
+place at strip clubs where Plaintiff was employed. Obviously, these questions go to the
+heart of the Epstein's defenses, including that of consent and ability to consent.
+5.
+If this court precludes Epstein's lawyers from seeking information from
+third parties about the claims asserted against him by Jane Doe 4 (and others) it will
+undoubtedly violate Epstein's due process rights by preventing him from defending the
+allegations made against him and it will further open the floodgates to additional
+challenges from others. This would result in rewriting the rules of discovery, and the
+intended purpose of the rules would largely be disregarded (i.e.., to obtain information
+necessary to prosecute and/or defend claims such that the element of unfair surprise is
+diminished). The overall purpose of discovery under the Federal Rules is to obtain a full
+and accurate understanding of the true facts in order to obtain a fair and just result.
+United States v. Proctor & Gamble Co., 356 U.S. 677, 682, 78 S.Ct. 983 (1958). This is
+evidenced through the intent of rule 26 disclosures.
+6.
+As this court has recognized, Defendant should not have to rely on only
+those "handpicked witnesses disclosed by Plaintiffl] in discovery, and would thereby
+prejudice Epstein in mounting his defense to the claims raised against him. (DE 299,
+p.4) (Exhibit "A"). Likewise, at DE 432 (Exhibit "B"), this court denied Defendant's
+3
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 4 of 9
+Motion for Protective Order seeking to prevent the deposition of Third Party witness Igor
+Zinoview despite the fact that Mr. Zinoview was employed by Epstein post-dates giving
+rise to the facts alleged in these actions. This was the case even though several affidavits
+were provided supporting Zinoview's Motion for Protective Order. The court found that
+an order completely prohibiting the deposition from going forward is rare, Salter v.
+Upjohn co., 593 F.2d 649, 651 (" Cir. 1979), and that Zinoview's conclusory affidavit
+in which he denies knowledge of the facts giving rise to these cases provide anything
+even approaching the rise of "extraordinary circumstances" necessary to prohibit the
+deposition. (DE 432). The same result should be reached here.
+7.
+The party resisting discovery has a heavy burden of showing why the
+requested discovery should not be permitted. Rossbach v. Rundel, 128 F.Supp.2d 1348,
+1354 (S.D. Fl. 2000) ("The onus is on the party resisting discovery to demonstrate
+specifically how the objected-to information is unnecessary, unreasonable or otherwise
+unduly burdensome."); Dunkin Donuts, Inc. v. Mary's Donuts, Inc., 2001 WL 34079319
+(S.D. Fla. 2001) ("the burden of showing that the requested information is not relevant to
+the issues in the case is on the party resisting discovery") citation omitted); Gober v. City
+of Leesberg, 197 F.R.D. 519, 521 (M.D. Fla. 2000)("The party resisting production of
+information bears the burden of establishing lack of relevancy or undue burden in
+supplying the requested information"'). To meet this burden, the party resisting discovery
+must demonstrate specifically how the objected-to request is unreasonable or otherwise
+unduly burdensome. See Fed. R. Civ. P.33(b)(4); Panola Land Buyers Ass'n v. Shuman,
+762 F.2d 1550, 1559 (11" Cir. 1985); Rossbach, 128 F.Supp.2d at 1353. Thus, to even
+merit consideration, "an objection must show specifically how a discovery request is
+=
+4
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 5 of 9
+overly broad, burdensome or oppressive, by submitting evidence or offering evidence
+which reveals the nature of the burden." Coker v.
+& Co.., 1777 F.R.D. 682, 686
+(M.D. Ala. 1998). Plaintiff has failed to make such a showing. Therefore, her Motion
+for Protective Order should be denied. See e.g., DE 377, Exhibit "C".
+8.
+Obviously, Defendant is entitled to test Plaintiff's credibility as to her
+alleged involvement with Epstein, to determine the alleged effects on her as a result of
+any involvement with Epstein, to determine whether she ever spoke of any alleged
+psychological trauma with the deponents, and to determine if the deponents have any
+information supporting or denying Plaintiff's claim that she sustained damages as a result
+of their alleged involvement with Epstein. It is well settled that relevant information is
+discoverable, even if not admissible at trial, so long as the discovery is reasonably
+calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.;
+Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). See
+Hickman v. Taylor, 329 U.S. 495, 507-08 (1947); Oppenheimer Fund, Inc. v. Sanders, 437
+U.S. 340, 351 (1978). In Oppenheimer, the Supreme Court discussed the concept of
+relevance in relation to Fed. R. Civ. P. 26(b) and noted that:
+The key phrase in this definition - "relevant to the subject matter in the
+pending action" - has been construed broadly to encompass any matter
+that bears on, or that reasonably could lead to other matters that could bear
+clarify the issues. Nor is discovery limited to the merits of a case, for a
+variety of fact-oriented issues may arise during litigation that are not
+related to the merits.
+See also Carenehammer v. Alber Corp., 138 F.R.D. 594 (S.D. Fla. 1991).
+9.
+Many Plaintiffs, including Jane Doe 4, claim Epstein is the sole or
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 6 of 9
+substantial contributing cause of their physical, psychological and emotional damages.
+However, as this court is aware, Plaintiffs have experienced several incidents in their
+lives which affected them emotionally and psychologically. See e.g., Exhibit "D",
+Affidavit of Richard C.W.
+outlining the psychological issues experienced by Jane
+Doe 4 as a result of incidents in her life prior to Epstein, which cannot be discounted. As
+such, Plaintiffs should not, once again, be able to "handpick" who Defendant deposes to
+refute their allegations.
+10.
+Accordingly, Plaintiffs cannot expect this court to limit Epstein's
+discovery of the claims asserted against him. To hold otherwise will negatively effect
+information sought, thereby prejudicing Epstein and impacting the one day he will have
+in court to defend these allegations.
+11.
+Furthermore, the pendency of a motion for protective order does not
+excuse the moving party from responding to discovery requests. Vipre Systems, LLC. v.
+NITV, LLC. 2007 WL 3202439 (M.D. Fla. 2007) and Sutherland v. Mesa Air Group,
+Inc.., 2003 WL 21402549 (S.D. Fla. 2003).
+III. Conclusion and Requested Relief
+12.
+It is critical for this entire case that Epstein be able to conduct regular
+discovery, which includes investigating the claims Plaintiff makes against him. As Dr.
+• stated in his affidavit, "there are a number of variables that combine to determine the
+effects of such alleged victimization, including the type and character of the alleged
+assault, and key victim variables such as demographics, psychological reactions at the
+time of the trauma, previous psychiatric or psychological history, previous victimization
+history ..., general personality dynamics and coping style, as well as sociocultural
+6
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 7 of 9
+factors such as drug use/abuse; poverty; social inequity and/or inadequate social support;
+any previous history of abuse within or outside the family; whether individuals were
+abused by strangers, acquaintances or family members; and whether there was any
+history of indiscriminate behavior that may have placed them at increased risk..." Id.
+It is also important to know about Plaintffs' "... previous sexual conduct, contact with
+police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity,
+contraceptive use, genital infections, or apparent indifference to previous abuse. .
+. whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc. .., and whether ... Plaintiffs' relationships with their
+families and familial factors, including social disadvantage, family instability, impaired
+parent/child relationship, and parental adjustment difficulties [were present]" Id. It is
+therefore critical for Epstein to conduct a thorough discovery, which will confirm or rebut
+Plaintiff's" allegations.
+To hold otherwise would cause this court to accept Plaintiff's
+allegations as true without allowing Epstein to retain information to refute same.
+Wherefore, Epstein requests that this court deny Plaintff Motion for Protective
+Order, and for such other and further relief as this court deem just and proper.
+ROBERTD. CRITTON, JR., ESQ.
+Florida Bar #224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTAY that a true copy of the foregoing was being served this day
+n all counsel of
+EMAIL on this e
+go aid the doing Santice List via clectronic mail.
+
+
+Case 9:08-cV-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 8 of 9
+Respectfully submitted,
+ROBERT D. CRITTÓN, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/253-0164 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz., Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232,
+. 08-80380, 08-80381, 08-80993,
+08-80994
+Esq.
+Brad pane, Weissing,
+| Fistos
+& Lehrman, PL
+425 N. Andrews Ave.
+Suite #2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+Brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+8
+
+
+Case 9:08-cv-80119-KAM Document 535 Entered on FLSD Docket 04/28/2010 Page 9 of 9
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+1, Esq.
+Tara A. Finnigan, Esq.
+• Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcial@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469
diff --git a/vision-fixhub/court-01/de3d44d893774743a145b905ac520fcf212e28ba7a9e926fedd11f4d5d01c42e.receipt.json b/vision-fixhub/court-01/de3d44d893774743a145b905ac520fcf212e28ba7a9e926fedd11f4d5d01c42e.receipt.json
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diff --git a/vision-fixhub/court-01/de80fbaae5e24fd8032f550fe5f56a0317d617ddb9fdb3d332d641524dc9c4b9.md b/vision-fixhub/court-01/de80fbaae5e24fd8032f550fe5f56a0317d617ddb9fdb3d332d641524dc9c4b9.md
new file mode 100644
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@@ -0,0 +1,121 @@
+Case 9:08-cv-80380-KAM Document 39
+Entered on FLSD Docket 08/05/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80380-CIV-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER DENYING MOTION TO STAY
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay
+(DE 13), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court
+has carefully considered the motion and is otherwise fully advised in the premises.
+Defendant Jeffrey Epstein ("Defendant") seeks a stay of this civil action under a federal
+statute which reads, in pertinent part, as follows:
+damage or injury to the person of a child exists, a criminal action is
+sending which arises out of the same occurrence and in which the child is
+the victim, the civil action shall be stayed until the end of all phases of the
+criminal action and any mention of the civil action during the criminal
+proceeding is prohibited. As used in this subsection, a criminal action is
+pending until its final adjudication in the trial court.
+18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006
+1
+
+
+Case 9:08-cv-80380-KAM Document 39 Entered on FLSD Docket 08/05/2008 Page 2 of 5
+CF 09454AXX (Fla. Cir. Ct. 2008)' and a federal case, In re Grand Jury, No. FGJ 07-103(WPB)
+(S.D. Fla.), that arise out of the same occurrences and are pending and thus require a stay of this
+civil case. The federal "case," according to Defendant, involves a "deferred-prosecution"
+agreement whereby the U.S. Attorney agreed to suspend its investigation of Defendant while
+"retaining the right to reactivate the grand jury." (DE 30.) Defendant essentially reasons,
+because the U.S. Attorney could bring criminal charges against Defendant, that a criminal action
+is "pending." The Court rejects this definition of a "pending criminal action."
+When interpreting the text of a statute, the Court begins with the plain meaning of the
+text. In re
+524 F.3d 1175, 1186 (11" Cir. 2008). If the plain meaning of a statute is
+clear, the Court should not deviate from that interpretation. Id. Pending is defined as "remaining
+undecided" and "awaiting decision." Blacks Law Dictionary (8"' ed. 2004).- Likewise, an
+'As Defendant recognizes, the state court case was "finally adjudicated" and thus no
+longer pending as of June 30, 2008. (See DE 17.)
+"Defendant attempts to argue that the fact that grand jury subpoenas are still
+"outstanding" and "not withdrawn" and that the grand jury will not be dismissed until Defendant
+completes his obligations under the state plea agreement means that a "criminal action" is
+"pending." (Def. Reply 4.) Defendant misunderstands the purpose of a grand jury. A grand
+jury's sole purpose is to inquire into whether there is probable cause to bring an individual before
+a tribunal to determine his guilt or innocence of an alleged crime. Id. The grand jury is simply
+an investigative body. See U.S. v. Alred, 144, F.3d 1405, 1413 (11" Cir. 1998). A "criminal
+action" is not instigated by the calling of a grand jury, because a grand jury is convened "to
+determine whether a crime has been committed and whether criminal proceedings should be
+instituted against any person." U.S. v. Calandra, 414 U.S. 338, 344 (1974). An "action" is
+commenced against a person after the grand jury actually finds probable cause to make an
+individual answer specific charges and renders a bill of indictment against that individual. Until
+a grand jury's investigation is complete and there has been a determination by a lawful authority
+that probable cause exists, there can be no criminal action.
+2
+
+
+Case 9:08-cv-80380-KAM Document 39 Entered on FLSD Docket 08/05/2008 Page 3 of 5
+"action" is defined as a "criminal judicial proceeding." Id. Because the U.S. Attorney has not
+filed an indictment or an information against Defendant, the Court fails to see how there is an
+undecided judicial proceeding in federal court against Defendant.
+Defendant argues that this statute should be read to include the definition of "criminal
+action" used in 18 U.S.C. § 1595(b)(2), which reads as follows: "In this subsection, a 'criminal
+action' includes investigation and prosecution and is pending until final adjudication in the trial
+court." Defendant argues that "Congress specifically intended that the term "criminal action'
+would be applied extremely broadly" under § 1595, so Congress "took pains to ensure that courts
+would give it the broadest possible construction" and defined "criminal action" as including
+investigatory stages. (Def. Reply 4.) Defendants argue that the Court should borrow this
+definition.
+The Court disagrees. The Court believes that Congress's inclusion of this broader
+definition under § 1595 evinces Congressional intent to depart from the normal meaning of the
+term "criminal action.". This addition to the text suggests that Congress knows the plain
+meaning of the term "criminal action" and that Congress decided, under § 1595, that the
+definition of "criminal action" should be broader. In contrast, Congress could have made such an
+addition to § 3509 had it intended the mandatory stay provision to apply to pre-indictment
+investigations, but it did not. In other words, by not broadening the definition of "criminal
+action" § 3509, Congress intended that the term should only have its ordinary meaning: that an
+indictment or information has been filed naming a specific defendant. Instead, it seems clear that
+'In fact, Congress made this intent clear by stating that this broader definition of a
+"criminal action" applied only "in this subsection."
+3
+
+
+Case 9:08-cv-80380-KAM Document 39 Entered on FLSD Docket 08/05/2008 Page 4 of 5
+Congress intended that these two statutory provisions should each have a different scope.
+Defendant's argument of statutory construction fails.
+The single case cited by Defendant in support of his motion is not on point. In Doe 1 v.
+Francis, No. 5:03CV260/MCR/WCS, 2005 WL 517847 (N.D. Fla. Feb. 10, 2005), the stay was
+entered because criminal charges had been filed against the defendant in a state court several
+months earlier (i.e., the defendants had been indicted by the state attorney). See Memorandum in
+Support of Motion to Stay Proceedings Pending Outcome of Parallel Criminal Proceedings at 3,
+Doe 1 v. Francis, No. 5:03CV260/MCR/WCS (N.D. Fla. Dec. 2, 2003). The Court agrees with
+Defendant that a stay under § 3509(k) is mandatory when a criminal action is pending; the Court
+simply disagrees that the "deferred-prosecution agreement" constitutes a pending criminal action.
+The Court also does not believe a discretionary stay is warranted. Defendant did not seek
+this relief in his motion; including such a request in the reply brief is inappropriate. Further, the
+Court sees no reason to delay this litigation for the next thirty-three months. After all, Defendant
+is in control of his own destiny - it is up to him (and him alone) whether the plea agreement
+reached with the State of Florida is breached. If Defendant does not breach the agreement, then
+he should have no concerns regarding his Fifth Amendment right against self-incrimination. The
+fact that the U.S. Attorney (or other law enforcement officials) may object to some discovery in
+these civil cases is not, in an of itself, a reason to stay the civil action. Any such issues shall be
+resolved as they arise in the course of this litigation.
+Accordingly, it is ORDERED AND ADJUDGED as follows:
+1. Defendant's Motion to Stay (DE 13) is DENIED.
+2. Defendant's Motion for Hearing (DE 33) is DENIED AS MOOT.
+4
+
+
+Case 9:08-cv-80380-KAM Document 39 Entered on FLSD Docket 08/05/2008 Page 5 of 5
+3. Plaintiff's Motion for an Extension of Time to File Response (DE 24) is GRANTED NUNC
+PRO TUNC.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 4" day of August, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+5
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diff --git a/vision-fixhub/court-01/de84b978e28d920188a7ead8f55dc1f6808d467406d8fc5c9a710f241e1ed569.md b/vision-fixhub/court-01/de84b978e28d920188a7ead8f55dc1f6808d467406d8fc5c9a710f241e1ed569.md
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@@ -0,0 +1,26 @@
+Case 9:09-cv-80591-KAM Document 57-1
+• Entered on FLSD Docket 07/02/2009 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-80656-MARRA/
+JANE DOE No. 101,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant,
+J
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S
+Unopposed Motion for Extension of Time in Which to Reply to Plaintiff, Jane Doe 101's
+Response to Defendant, Epstein's Motion to Dismiss Amended Complaint [DE 56].
+Having considered Defendant's Unopposed Motion and Plaintiff's counsel being in
+agreement with the requested extension, it is HEREBY ORDERED and ADJUDGED
+that:
+Defendant's Unopposed Motion is GRANTED. Defendant shall file a Reply to
+Plaintiff, Jane Doe 101's Response to Defendant, Epstein's Motion to Dismiss Amended
+Complaint on or before August 21, 2009.
+DONE and ORDERED this _
+_day of July, 2009
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies all counsel
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diff --git a/vision-fixhub/court-01/de98f67acc4cc833d5dc8a846fa8bfdc036b2ace7b9748ac7800d49d0ebf9543.md b/vision-fixhub/court-01/de98f67acc4cc833d5dc8a846fa8bfdc036b2ace7b9748ac7800d49d0ebf9543.md
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@@ -0,0 +1,43 @@
+Casese:190v*0557LJLJDDEF Dumumentt769 Fitet0891N20 Pagage off 1
+BSF
+BOlES
+SCHILLER
+I FLEXNER
+August 14, 2020
+VIA ECF
+The Honorable Debra Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007-1312
+Re:
+Jane Doe 1000 v. Darren _ Indyke and Richard D. Kahn, in their capacities as
+executors of the Estate of Jeffrey Edward Epstein, 19-10577-LJL-DCF
+Dear Judge Freeman:
+Pursuant to the Court's June 15, 2020, Order (ECF No. 63) Plaintiff and Defendants Darren
+•. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E. Epstein, jointly submit
+this status report.
+Plaintiff submitted her claim to the Epstein Victims' Compensation Program on June 26,
+2020, and has actively participated in the program since. Based on communications with the
+program's Administrator, Plaintiff expects to receive an eligibility and/or compensation
+determination in the coming weeks.
+To preserve the parties' resources and in the interests of judicial economy, the parties
+respectfully request an extension of forty-five (45) additional days to the current stay of discovery
+(and the resolution of any pending motions) in this case.
+Respectfully submitted,
+The requested extension of the stay
+is granted.
+Dated: 09/11/2020
+SO ORDERED
+/s/Sigrid S. McCawley
+Sigrid S. McCawley, Esq.
+Boies Schiller Flexner LLP
+DEBRA FREEMAN
+United States Magistrate Judge
+/s/Bennet J. Moskowitz
+Bennet J. Moskowitz, Esq.
+Troutman Sanders LLP
+ce: Counsel of Record (via ECF)
+BOIES SCHILLER FLEXNER LLP
+55 Hudson Yards, New York, NY 10001 | (t) 212.446.2300 | (f) 212.446.2350 | www.bsfllp.com
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diff --git a/vision-fixhub/court-01/dec21740c3110a86927b7523e6211f7875575adeaed9317b6b8f31d9e186a4c2.md b/vision-fixhub/court-01/dec21740c3110a86927b7523e6211f7875575adeaed9317b6b8f31d9e186a4c2.md
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+Filing # 101840557 E-Filed 01/17/2020 12:23:06 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+Div.: AG
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+NOTICE OF FILING
+Plaintiff, CA Florida Holdings, LL.C, by and through its undersigned counsel, hereby gives
+notice of filing the attached First Amended Complaint.
+Dated: January 17, 2020
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+NOT A
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+FL.Service@gtlaw.com
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/17/2020 12:23:06 PM
+
+
+By: Is/ Michael J Grygiel
+MICHAEL J GRYGIEL
+(Admitted Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: /s/ Nina D. Boyajian
+NINA D. BOYAJIAN
+(Pro Hac Vice application pending)
+1840 Century Park East, Suite 190(
+Los Angeles CA 90067
+Telephone: (310) 586 -7700
+Facsimile: (310) 586 =7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+CERTIFICATE OF SERVÍCE
+THEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+/s/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+NOT A
+2
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+Div.: AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+COPY
+FIRST AMENDED COMPLAINT
+CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its First Amended
+Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his
+official capacity ("State Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach
+County, Florida, in her official capacity (Court Clerk"), alleges as follows:
+JURISDICTION
+This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
+Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq.
+PARTIES
+The Palm Beach Post is a daily community newspaper published by Plaintiff CA
+Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
+3.
+Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth
+Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
+has authority in grand jury proceedings pursuant to Fla. Stat. Section 27.03. He is sued herein in
+
+
+his official capacity as his office is in possession and/or control of documents that are the subject
+of this action.
+Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach
+County, Florida. She is sued herein in her official capacity as her office is in possession and/or
+control of documents that are the subject of this action.
+INTRODUCTION
+5.
+In what is now widely if belatedly recognized as a colossal miscarriage of justice -
+which led to the further needless victimization of countless young girls and women - a wealthy,
+politically connected, and powerful financier was not held accountable for, nor even forced to
+confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008
+deal with the State of Florida was not consistent with the evidence gathered against him, what
+remains shrouded in mystery is how that evidence was presented - and the extent to which it was
+presented - to the grand jury that returned an indietment far more limited in scope than expected
+and deserved.
+6.
+Through this action, The Palm Beach Post seeks public access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled
+during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for
+example, in order to prevent the flight of those whose indictment may be contemplated and their
+ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an
+accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law
+expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
+including, as here, in the furtherance of justice. Fla. Stat. § 905.27(1)(c).
+It can no longer credibly be maintained that continued blanket secrecy over the
+proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.
+2
+
+
+To the contrary, transparency is required to promote public understanding of the criminal justice
+system and public confidence in the fair administration of justice. As detailed below, Epstein was
+accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
+other locations) over a period of several years while exploiting his wealth and political connections
+to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury
+proceedings will shed light on the extent to which those in our government entrusted with the
+solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties
+in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated
+like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
+who chose to give Epstein favorable - "unusual," in the words of the Town of Palm Beach Police
+Chief - treatment, are exposed and held accountable From what limited information is now in the
+public domain, the State Attorney's referral of Epstein's case to the grand jury - which would be
+out of the ordinary for this type of case - gives rise to a strong inference of favoritism and
+corresponding disregard for the rights of the minor victims of Epstein's sex trafficking. Access to
+the grand jury materials will allow the public to determine whether the grand jury process, and the
+secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and
+his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat.
+Section 905.27 authorizes the disclosure of Epstein's 2006 grand jury proceedings.
+8.
+Even in the absence of such a statutory basis, this Court is empowered to order
+public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
+Indeed, courts throughout the country in the past several decades have ordered the disclosure of
+high-profile grand jury proceedings pursuant to their inherent authority where the public's interest
+in those proceedings has outweighed the general need for secrecy. This is particularly so where,
+3
+
+
+as here, many of the details of Epstein's criminal misdeeds have already been made available in
+the public domain through extensive news reporting by, among others, The Palm Beach Post; by
+the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.
+In recognition of the sensitivity of the materials being sought, and in the interest of
+protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to
+copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County
+grand jury first being submitted to this Court for in camera review, where they may be redacted,
+as appropriate, to protect those who deserve such protection.
+FACTUAL BACKGROUND
+10. The following facts were gathered, in large part, from documents obtained by The
+Palm Beach Post through various Florida Public Records Law requests, documents unsealed or
+publicly available in other related judicial proceedings, and information and documents in the
+public record.
+A.
+Los tin Sex Crimes Investication, Indictment, and Plea Agreement:
+11. The investigation into Epstein's sex crimes began more than fourteen years ago,
+when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that
+Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
+required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
+$300. Epstein was 52 years old at the time.
+12.
+Following this initial report in 2005, the Town of Palm Beach Police, and later, in
+2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
+seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
+disturbingly similar details, with each of the other victims.
+4
+
+
+13.
+Both the victim/witness interviews, as well as evidence retrieved following a search
+of Epstein's home, showed that some of the girls involved were under the age of 18. The police
+search of Epstein's residence also found two hidden cameras and, throughout the house, large
+numbers of nude photos of girls, including victims whom the police had not interviewed in the
+course of their investigation.
+14.
+In March 2006, a State grand jury was scheduled at which all of the victims were
+expected to testify. The proceeding was postponed, however, due to meetings between the State
+Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan
+Dershowitz.
+15.
+to begin receiving evidence.
+Another grand jury was convened in April 2006, but canceled the day before it was
+(1) Police Chief Reiter's Letter to the State Attorney.
+16.
+On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
+"personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer,
+stating:
+17. Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach
+Police Department's probable cause affidavits charging Epstein and two of his assistants with
+multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
+5
+
+
+that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
+against him, which would be public.
+(2) The July 2006 State Grand Jury Presentation.
+18.
+Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
+mandatory for capital cases but rarely used for all other crimes. According to an official
+spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
+Beach County.
+19. In July 2006, after State Attorney Krischer presented testimony and evidence from
+one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
+There is no mention in the indictment of the victim being a minor.
+20.
+On information and belief, a second of Epstein's victims was supposed to testify
+before the grand jury, but was unable to attend because of a school exam.
+21.
+No reasonable explanation has been provided as to why the numerous other known
+victims were not presented as witnesses and crime victims to the grand jury convened in July 2006.
+Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
+initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do
+SO.
+On information and belief, during the grand jury appearance of the single victim
+who testified, the State Attorney presented evidence that vilified the victim and attacked her
+credibility, including soliciting testimony regarding underage drinking and questionable personal
+behavior that was unrelated to the charges against Epstein. Further upon information and belief,
+this information was initially brought to the attention of the State Attorney's office by Epstein's
+defense counsel.
+6
+
+
+23.
+(3) The FBI's Investigation and Epstein's Non-Prosecution
+Agreement With Federal Authorities.
+On information and belief, following the deficient July 2006 indictment, and with
+Chief Reiter's encouragement, the FBI began its own investigation of Epstein.
+24.
+Records unsealed in 2015 revealed that the FBI compiled reports on *34 confirmed
+minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI,
+a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the
+request of Epstein's lawyers, the indictment was never presented to a federal grand jury.
+Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
+negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with
+four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
+charges.
+26.
+Throughout the remainder of 2007 and through the first half of 2008, Epstein's
+lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
+belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept
+confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
+issued for Epstein's computers) be withdrawn.
+27.
+On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
+prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
+sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
+adjudicated as a convicted sex offender required to register twice a year in Florida.
+28.
+The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to
+receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
+
+
+On information and belief, based on public records, former State Attorney Krischer communicated
+with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.
+29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
+which he was convicted. Instead, he was placed in a private wing of the Palm Beach County
+Stockade, where, after 3 1/2 months, he was allowed to leave the jail on "work release" for up to
+12 hours a day, 6 days a week. His private driver provided his transportation to and from "work."
+30.
+31.
+Epstein was released five months early.
+Upon information and belief, Epstein violated the terms of his probation, but was
+not prosecuted
+32.
+(4) The Crime Victims' Rights Act Litigation.
+Epstein's victims only learned after the fact about his plea in State court and filed
+an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act
+(18 U.S.C. § 3771, "CVRA"), which
+undates certain rights for crime victims, including the right
+to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
+Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
+Epstein's victims before allowing him to plead guilty to only the two State offenses.
+33.
+The prosecution's failure to keep the victims apprised, among other things, also
+contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.
+34.
+Following publicity exposing the extraordinary leniency of the plea deal, dozens of
+civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.
+35.
+In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense)
+sex offender in New York, a lifelong designation. In 2011, the New York County District
+Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."
+8
+
+
+36.
+Upon information and belief, during the course of the Town of Palm Beach and FBI
+investigations, Epstein retained private investigators to follow, harass, and photograph his victims
+and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated
+the case against Epstein.
+37.
+Upon information and belief, Epstein's victims were threatened against cooperating
+with law enforcement and told that they would be compensated only if they did not cooperate with
+law enforcement.
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
+38. On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
+39. Upon information and belief, the United Stafes government's investigation of new
+allegations and charges stemmed, in part, from continued press investigations into and reporting
+on the mishandling of the 2006 charges and the civil suits that followed
+40.
+In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
+Southern District of New York, Epstein was described as "a serial sexual predator who preyed on
+dozens of minor girls over a period of years." The letter emphasized that "the Government has real
+concerns - grounded in past experience with this defendant - that if allowed to remain out on bail,
+the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this
+case, including victims and their families, and otherwise attempt to obstruct justice." It also
+described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex
+trafficking in the form of "hundreds - and perhaps thousands - of sexually suggestive photographs
+of fully- or partially-nude females," including underage females. In a locked safe, compact dises
+were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc
+nudes 1," and "Girl pics nude."
+9
+
+
+41.
+On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's
+office for the Southern District of New York charged Epstein with sex trafficking and conspiracy
+to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were
+brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry
+over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
+Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump
+administration, resigned from office.
+42.
+Epstein was denied bail and was placed into pretrial detention at the federal
+senion at the rederal
+Metropolitan Correction Center in lower Manhattan.
+43.
+On or about August 6, 2019, Florida Gov, Ron DeSantis ordered a state criminal
+probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their
+handling of the Epstein underage sex trafficking case.
+44.
+On August 10, 2019, Epstein was found dead in his cell at the Metropolitan
+Correctional Center. His cause of death was determined to be suicide.
+C. The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+On account of his death, prosecutors sought to dismiss the indictment against
+Epstein, while maintaining that they would continue to investigate his co-conspirators.
+46.
+United States Senior District Judge Richard M. Berman ordered a hearing on
+August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to
+speak at thé hearing.
+47.
+In the course of the hearing, more than two dozen victims delivered their personal
+stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
+violent rape by Epstein. Many more vietims were present in the courtroom but did not testify.
+10
+
+
+48.
+While some questioned the reasoning behind the court's decision to give the victims
+voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred
+vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings
+promote transparency and they provide the court with insights and information which the court
+may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that
+the court "is the institution that most people have confidence in, in these very troubled times."
+At the August 27th hearing, the girls, now women, spoke about their "exploitation
+and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme
+poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
+behalf...." One victim lamented that "as a victim, [she] never got to see what the agreement was
+or why the special treatment got approved" in the Florida case years earlier. Another noted how
+"completely different" the investigators leading to the 2019 federal indictment were from the
+prosecutors in the Florida case, both in their treatment of her and their investigation of her
+victimization by Epstein.
+50.
+A former federal judge in attendance at the August 27th hearing emphasized that
+"transparency is one of the overriding objectives in our criminal justice system."
+51. Nearly all of the victims expressed the conviction that the secrecy that shielded
+Epstein has caused them "irreparable harm" and that an opportunity to address his criminal
+wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
+at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts
+made to protect Epstein's name and legacy send a message to the victims that he wins and that he
+is untouchable." Another victim expressed fear that this is a world "where there are predators in
+power, a world where people can avoid justice if their pockets run deep enough." In short, the
+11
+
+
+"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and
+connections severely eroded the public's faith in the integrity and impartiality of the criminal
+justice system.
+D. The Palm Beach Post's Standing and the Public Interest.
+(1)
+The Palm Beach Post Has Reported Extensively On Ep
+Crimes For Nearly 15 Years.
+52. Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
+Beach County and the Treasure Coast vicinity.
+53.
+The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
+three other times.
+54.
+Beginning in 2004, The Palm Beach Post has extensively investigated and reported
+on the allegations against, the law enforcement investigatión of, and the crimes committed by,
+Epstein and his co-conspirators. The Newspaper's reportage has included publication of the
+following articles:
+• "The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends
+and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that:
+a local community college student, admitted in a sworn statement to
+police that "she had taken at least six girls to visit Epstein, all between the ages of 14
+and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;"
+"Dershowitz, the Harvard law professor, traveled to West Palm Beach with informatior
+about the girls," including social media discussions about "their use of alcohol and
+marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their
+‹decision to take the case to a grand jury;" Palm Beach Police subsequently "received
+complaints that two of the victims or their families had been harassed or threatened;"
+"relations between police and prosecutors were fraying" as the investigation continued;
+and "one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up" to testify before the grand jury.
+• "Trump Snags Gosman Estate for $41 Million" published on November 16, 2004,
+reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
+purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along
+the storied Raider's Row' " in Palm Beach.
+12
+
+
+• "Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that
+"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last
+year, according to an indictment charging him with felony solicitation of prostitution."
+The article further reported that "Epstein's case is unusual in that suspected prostitution
+johns are usually charged with a misdemeanor, and even a felony charge is typically
+made in a criminal information - an alternative to an indictment charging a person with
+the commission of a crime."
+• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006,
+reporting that "Palm Beach police thought there was probable cause to charge Epstein
+with unlawful sex acts with a minor and lewd and lascivious molestation." The article
+further reported that "Police Chief Michael Reiter was so angry with State Attorney
+Barry Krischer's handling of the case that he wrote a memo suggesting the county's
+top prosecutor disqualify himself," and identified a 20-year-old on-the-record female
+source who said "she gave Epstein a massage in the nude, then brought him six girls,
+ages 14 to 16, for massage and sex-tinged sessions at his home."
+• "Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006,
+reporting that "[flamed Harvard law professor Alan Dershowitz met with the Palm
+Beach County State Attorney's Office and proyided damaging information about
+teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein,
+sexually charged massages" and that "It]he state attorney's office said it presented the
+Epstein case to a county grand jury this month rather than directly charging Epstein
+because of concerns about the girls' credibility."
+• "Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006,
+reporting that "[r]ather than file charges, the state attorney's office presented the case
+to a county grand jury" which "indicted Epstein last week on a single, less serious
+charge of felony solicitation of prostitution," and that "[t]he case raised eyebrows
+because the state attorney's office rarely, if ever, kicks such charges to a grand jury."
+• "Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting
+that "[a] state attorney's spokesman would say only that the office refers cases to the
+grand jury when there are issues with the viability of the evidence or witnesses
+credibility."
+"Palm Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006,
+réporting that Chief Reiter "pressed for Epstein to be charged with the more serious
+crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in
+blunt language seldom used by one law enforcement official with another because of
+what he perceived as that office's mishandling of the case."
+• "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007,
+reporting that "In]early eight months after Palm Beach tycoon Jeffrey Epstein was
+charged with felony solicitation of prostitution, there has been no discernible progress
+in his case."
+13
+
+
+• "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
+on October 18, 2007, reporting on a lawsuit brought in New York State court against
+Epstein "by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model."
+• "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein,
+55, pleaded guilty... to felony solicitation of prostitution and procuring a person under
+the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex
+offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their
+investigation of Epstein, which they had taken to a grand jury."
+• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on
+August 13, 2008, reporting that "[dJuring his first month of confinement" Epstein was
+visited by
+, who allegedly escorted victims upon their arrival at his Palm
+Beach waterfront home to an upstairs room, where she prepared the massage table and
+provided the oils for their encounters" with Epstein, and by Nadia
+young woman whom Epstein purportedly described as his Yugoslavian sex slave."
+• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July
+1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade
+six days a week on a work-release program.
+"Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting
+that attorneys for women suing Epstein in various courts "want his [non-prosecution]
+agreement [NPA] with federal prosecutors unsealed" and were moving to unseal the
+agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces
+at least a dozen civil lawsuits in federal and state courts filed by young women who
+said they had sex with him and now are seeking damages." On that date, The Palm
+Beach Post moved to intervene in the matter for the purpose of obtaining public access
+to the NPA, which was ordered disclosed by this Court on June 25, 2009.
+"Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on
+September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,
+"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
+pleaded guilty to prostitution-related felonies in state court" and "also agreed not to
+charge any of Epstein's possible co-conspirators:
+Groff and
+" The article further reported that, according to an
+attorney representing three of Epstein's victims, "none of the 30 to 40 wom[e]n
+identified as victims in the federal investigation" were informed ahead of time about
+the NPA.
+• "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on
+January 27, 2010, reporting that "a judge . . • gave lawyers representing multi.
+millionaire sex offender Jeffrey Epstein the right to subpoena abortion records from
+women who are seeking millions in damages from the part-time Palm Beach resident."
+
+
+• "Epstein Journal's Findings Could Resurrect Abuse Case" published on March 20,
+2010, reporting that "[a] purloined journal that is said to contain the names of
+"hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen
+the investigation into the multi-millionaire's appetite for teenage girls."
+• "Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published
+on October 4, 2017, reporting that, according to court documents, Epstein "shelled out
+$5.5 million to settle lawsuits with three of more than two dozen teens who sued him."
+• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims'
+Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge
+Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had
+dropped plans to prosecute the billionaire on dozens of federal charges in connection
+• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
+Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9,
+2019, reporting on Epstein's appearance in U.S. District Court for the Southern District
+of New York in which he "pleaded not guilty to charges accusing him of creating a vast
+network of girls as young as 14 that he exploited for his sexual pleasure at his homes
+in Palm Beach and Manhattan."
+A true and correct copy of the above news articles, in either the computerized format in which they
+are maintained in The Palm Beach Post's electronic archives or the news print edition in which
+originally published, is annexed hereto as Exhibit 1.
+55.
+Since the filing of the initial Complaint in this matter, The Palm Beach Post- along
+with media worldwide - has continued to report on Epstein's crimes and the ongoing official
+proceedings resulting from those crimes.
+(2) The Palm Beach Post's Standing and the Public Interest.
+56.
+The press has a constitutional right of access to criminal proceedings, see, e.g.,
+Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
+proceedings.
+v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the
+judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
+proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ
+
+
+Co. v.
+, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in
+matters concerning the closure of judicial proceedings). The press also has a First Amendment
+interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
+Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists ... the protection afforded [by
+the First Amendment] is to the communication, to its source and to its recipients both."); Pittman
+, 267 F.3d 1269, 1283 n. 12 (11th Cir. 2001) ("The Supreme Court has recognized that the
+First Amendment offers protection to both speakers and those wishing to receive speech."); see
+also Stephens v. Cly. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff
+has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing
+to convey the information to her").
+57. Because of the unique role performed by the press as a "public surrogate"
+426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about
+criminal proceedings, news organizations *presumptively have a right to access judicial records,"
+Comm'r, Ala. Dep't of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019),
+and "standing to question the validity of an order restricting publicity because its ability to gather
+news is directly impaired or curtailed."
+, 426 So. 2d at 4; see also Carlson v. United States,
+837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee]
+has standing to assert [its] claim" to grand jury materials because such materials are "public records
+to which the public may seek access, even if that effort is ultimately unsuccessful").
+Here, the continued denial of access to information The Palm Beach Post seeks on
+behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury."
+Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
+Zerilli v.
+656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press' function as a vital
+16
+
+
+source of information is weakened whenever the ability of journalists to gather information is
+impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand
+jury materials).
+59.
+The Palm Beach Post has the right to maintain this private right of action because
+the furtherance of justice, an express legislative exception to grand jury secrecy, is intended for
+the public benefit, and The Palm Beach Post seeks access on behalf of the public, Fla. Stat.
+§ 905.27(1)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court
+to be the party to make the determination of disclosure. Fla. Stat. § 905.27(1). In other words, the
+legislature intended for recourse to the courts in considering and determining the propriety and
+scope of grand jury secrecy.
+E.
+The Court's Jurisdiction And Authority.
+(1)
+The Court's Supervision of the Grand Jury Process and Its
+Authority to Order Public Disclosure of the Epstein Evidence.
+60.
+The Florida Supreme Court has noted that "in states such as Florida, where the
+grand jury is preserved, it is an important appendage of the court which impanels it. At the same
+time it should not be forgotten that the judge of that court is equally important and he is generally
+charged with the supervision of the grand jury's activities...It is, therefore, of vital importance to
+maintain the dignity and the integrity of both the grand jury and the presiding judge." State v.
+Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
+Chapter 905 of the Florida Statutes governs the empanelment and conduct of
+Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
+about its legal duties. Fla. Stat. § 905.18.
+62.
+Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined
+before the grand jury ... or other evidence received by it" may be disclosed "when required by a
+17
+
+
+court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
+the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)
+Furthering justice." Fla. Stat. § 905.27(1)(a)-(c).
+63.
+Further, disclosure is appropriate pursuant to this Court's inherent authority over
+grand jury proceedings because of the exceptional public interest in this case and the compelling
+circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (*a district court
+has the inherent power to disclose [grand jury] materials in exceptional circumstances and ...
+historic importance can be a sufficient reason when there is little countervailing need for secrecy").
+64.
+The Florida Supreme Court has confirmed that grand jury secrecy is not absolute
+and that any "potential harm to public officeholders" from disclosure "will be the product of their
+own conduct, and not the consequence of an unrestrained body of misguided citizens." Miami
+Herald Pub. Co. v. Marko, 352 So. 2d 518 (1977) ("The benefits to be derived from this
+extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the
+fruits of that activity were not available to thé public on whose behalf it is undertaken. Implicit in
+the power of the grand jury to investigate and expose official misconduct is the right of the people
+to be informed of its findings. While public disclosure of grand jury findings inevitably entails the
+risk of reputational damage, the legislature has ensured that any potential harm to public
+officeholders will be the product of their own conduct, and not the consequence of an unrestrained
+body of misguided citizens.").
+(2) That Court's Jurisdiction To Declare Rights And Construe
+65.
+This Court has jurisdiction to declare rights, status, and other equitable or legal
+relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.
+
+
+66.
+Florida law specifically provides that a declaration may be sought from the Court
+concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person... whose
+rights, status, or other equitable or legal relations are affected by a statute, or any regulation made
+under statutory authority,
+..may have determined any question of construction or validity arising
+under such statute,.. or any part thereof, and obtain a declaration of rights, status, or other equitable
+or legal relations thereunder.").
+67.
+The Court's exercise of its power to declare rights "is to be liberally administered
+and construed." Florida Stat. Section 86.101.
+COUNT!
+(Declaratory Relief - Florida Stat. Sections 86,011 et seq.)
+68.
+The allegations set forth in paragraphs | through 67 are incorporated by reference
+as if fully set forth herein.
+69.
+This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes,
+and other supplemental relief.
+70.
+The Palm Beach Post respectfully requests that the Court declare that pursuant to
+Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence
+presented in 2006 to the Palm Beach County grand jury because such disclosure and access would
+be in the furtherance of justice. Fla. Stat. § 905.27(1)(c). Because The Palm Beach Post is not
+seeking these materials in connection with either a civil or criminal case, it seeks a declaration that
+the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2).
+71.
+The Palm Beach Post further seeks a declaration that disclosure of the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate
+19
+
+
+pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional
+public interest in this case and the compelling circumstances supporting transparency.
+72. The Palm Beach Post has sought from Defendants, but Defendants have refused to
+provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach
+County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the
+relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between
+the parties.
+73.
+Through this Complaint, The Palm Beach Post presently has a justiciable question
+so istible question
+concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Section 905.27(1)
+and the Court's inherent authority.
+74.
+A bona fide, actual, present, and practical need for the declaration exists in that
+Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury
+materials sought to be disclosed. The relief sought from the Court is therefore not merely the giving
+of legal advice or to answer hypothetical questions.
+WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the
+rights and obligations of the parties by declaring that pursuant to Fla. Stat. Section 905.27(1)(c)
+and the Court's inherent authority, The Palm Beach Post may gain access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those
+materials for the purpose of informing the public.
+COUNT II
+(Florida Stat. Section 905.27)
+75.
+The allegations set forth in paragraphs 1 through 74 are incorporated by reference
+as if fully set forth herein.
+20
+
+
+76.
+Based on information learned by The Palm Beach Post through its Florida Public
+Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence
+and proceedings, judicial documents obtained from independent but related court proceedings, and
+documents otherwise available in the public record, the State Attorney for Palm Beach County
+presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner
+that precluded his indictment for the serious crimes he committed, including sex trafficking and
+sexual assault.
+77.
+Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's
+victims and the public, and to provide public disclosure to illuminate whether Epstein received
+unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
+immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm
+Beach County grand jury.
+78.
+In a case of this magnitude and importance, where the accused is dead and so many
+of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the
+victims have already been exposed, the need for grand jury secrecy is no more. See United States
+v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jury's functions are
+ended, disclosure is wholly proper where the ends of justice require it.").
+WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
+Stat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk
+of the Court to file with this Court copies of the testimony, minutes, and other evidence presented
+in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
+that, following an in camera inspection, it can be made available to The Palm Beach Post and the
+21
+
+
+public on an expedited basis, and grant any other and further equitable or legal relief the Court
+deems just and proper.
+Dated: January 17, 2020
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: /s/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+FLService@gtlaw.com
+By:
+As/ Michael J Grygiel
+NOT A CER
+MICHAEL J GRYGIEL
+(Admitted Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: /s/ Nina D. Boyajian
+NINA D. BOYAJIAN
+(Pro Hac Vice application pending)
+1840 Century Park East, Suite 1900
+Los Angeles CA 90067
+Telephone: (310) 586 -7700
+Facsimile: (310) 586 - 7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+22
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+/s/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+NOT A CERTIFIED COP'
+23
+
+
+
+The Newspaper's Reportage on Jeffrey Epstein
+
+
+The Man Who Had Everything: Jeffrey Epstein craved big
+homes, elite friends and underage girls
+By Andrew Marra
+Posted Jul 17, 2019 at 6:02 AM
+From the archives: When Palm Beach detectives started asking
+questions and teenage girls started talking, a wave of legal resistance
+followed.
+Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
+Jeffrey Epstein's arrest in Palm Beach County on a charge of felóny solicitation of prostitution.
+WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,
+hidden cameras trolled two rooms, while the girls came and went.
+For the police detectives who sifted through the garbage outside and kept records of visitors, it
+was the lair of a troubling target.
+Epstein, one of the most mysterious of the country's mega-rich, was known as much for his
+secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
+friendships with the world's elite.
+But at Palm Beach police headquarters, he was becoming known for something else: the
+regular arrival of teenage girls he hired to give him massages and, police say, perform sexual
+favors.
+Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
+among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
+with some of the most prominent legal, scientific and business minds in the country.
+When detectives started asking questions and teenage girls started talking, a wave of legal
+resistance followed.
+
+
+» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease
+If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
+Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
+quietly, always in the background as he navigated New York high society.
+When he first attracted notice in the early 1990s, it was on account of the woman he was
+dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
+In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British
+Mail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a
+math teacher, a concert pianist or a corporate headhunter:
+"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both
+flamboyant and intensely private."
+The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
+flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
+Africa on his private jet.
+Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
+published lengthy profiles. The New York Post listed him as one of the city's most eligible
+bachelors and began describing him in its gossip columns with adjectives such as "mysterious"
+and "reclusive."
+Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
+Building a life of extravagance
+He was born blue-collar in 1953, the son of a New York City l
+department employee, and
+raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
+but became a math teacher at the prestigious Dalton School in Manhattan.
+The story goes that the father of one of Epstein's students was so impressed with the man that
+he put him in touch with a senior partner at Bear Stearns, the global investment bank and
+securities firm.
+
+
+In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
+Epstein and Co. That is when he began making his millions in earnest.
+Little is known or said about Epstein's business except this: He manages money for the
+extremely wealthy. He is said to handle accounts only of $1 billion or greater.
+It has been estimated he has roughly 15 clients, but their identities are the subject of only
+speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a
+former Palm Beacher who is said to have been a mentor to Epstein.
+Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
+block on Manhattan's Upper East Side. It is reported to have, among its finer features, closedcircuit television and a heated sidewalk to melt away fallen snow.
+That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
+the extravagant world Epstein built over time.
+In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
+outside Santa Fe. Many believed it to be the largest home in the state.
+In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
+private island in the Virgin Islands.
+» PHOTOS: The players in the Jeffrey Epstein saga
+Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
+the highest echelons of power. This includes not only socialites but also business tycoons,
+media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
+funds.
+"Just like other people collect art, he collects scientists," said
+Nowak, who directs the
+Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
+a $30 million research donation from Epstein.
+Epstein is said to have befriended former Harvard President Larry Summers, prominent law
+Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort
+Zuckerman.
+
+
+And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
+photographed
+"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
+and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article..
+Epstein's friendship with Clinton has attracted the most attention.
+Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
+an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
+close friends until after Clinton left the Oval Office and moved to New York.
+Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John
+Kerrys presidential bid, the reelection campaign of New Mexico Gov. Bill
+and the
+Senate bids of Joe L
+,, Hillary Rodham Clinton, Christopher Dodd and Charles
+Schumer.
+Powerful friends and enemies
+A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he
+left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
+Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20
+million loan.
+The article suggested that one of his business mentors and previous employers was Steven
+Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million
+in one of the largest Ponzi schemes in American history."
+As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
+man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
+than $16,000 in furnishings.
+A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
+thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
+owed him nothing.
+» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
+
+
+"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the
+retired former president of
+Electronics and Sega Corp. "Suffice it to say I have
+nothing good to say about him."
+Among the characteristics most attributed to Epstein is a penchant for women.
+He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
+and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
+model.
+"He's a lot of fun to be with," Donald Trump told New York magazine in 2002. "It is even said
+that he likes beautiful women as much as I do, and many of them are on the younger side. No
+doubt about it, Jeffrey enjoys his social life."
+Investigation leads to Epstein
+Although he was not a frequenter of the Palm Beach social scene, he made his presence felt.
+Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
+$100,000 to Ballet Florida.
+In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a
+Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
+private chef and a small staff stood at the ready. From a window in his mansion, he could look
+out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
+who had everything.
+But extraordinary wealth can fuel extraordinary desires.
+» Epstein wants to leave jail for mansion in sex-trafficking case
+In March 2005, a worried mother contacted Palm Beach police. She said another parent had
+overheard a conversation between their children.
+Now the mother was afraid her 14-year-old daughter had been molested by a man on the
+island.
+The phone call triggered an extensive investigation, one that would lead detectives to Epstein
+but leave them frustrated.
+
+
+Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
+Beach police report detailing the criminal probe offers a window into what detectives faced as
+they sought to close in on Epstein.
+Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
+perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
+said she was paid $300 after stripping to her panties and massaging the man while he
+masturbated.
+Police interview 5 alleged victims
+The investigation began in full after the girl identified Epstein in a photo as the man who had
+paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift
+through it. They set up a video camera to record the comings and goings at his home. They
+monitored an airport hangar for signs of his private jet's afrivals and departures.
+They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
+1, a Palm Beach Community College student from Loxahatchee. In a sworn
+statement at police headquarters,
+1, then 18, admitted she had taken at least six girls to
+visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.
+During the drive back to her house,
+told detectives, "I'm like a Heidi Fleiss."
+Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
+said they had been instructed to have sex with another woman in front of Epstein, and one said
+she had direct intercourse with him.
+In October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras were
+found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school
+transcript.
+Two of Epstein's former employees told investigators that young-looking girls showed up to
+perform massages two or three times a day when Epstein was in town.
+They said the girls were permitted many indulgences. A chef cooked for them. Workers gave
+them rides and handed out hundreds of dollars at a time.
+
+
+One employee told detectives he was told to send a dozen roses to one teenage girl after a high
+school drama performance. Others were given rental cars. One, according to police, received a
+$200 Christmas bonus.
+The cops moved to cement their case. But as they tried to tighten the noose, they encountered
+other forces at work.
+In Orlando they interviewed a possible victim who told them nothing inappropriate had
+happened between her and Epstein. They asked her whether she had spoken to anyone else.
+She said yes, a private investigator had asked her the same questions.
+» Jeffrey. Epstein: Acosta, Krischer trade barbs over sweetheart deal
+When they subpoenaed one of Epstein's former employees, he told them the same thing. He
+and a private eye had met at a restaurant days earlier to go over what the man would tell
+investigators.
+Detectives received complaints that private eyes were posing as police officers. When they told
+Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
+high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
+Kennedy
+While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
+professor, traveled to West Palm Beach with information about the girls. From their own
+profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
+their use of alcohol and marijuana.
+He took his research to a meeting with prosecutors in early 2006, where he sought to cast
+doubt on the teens' reliability.
+The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
+did some of the girls have issues with drugs or alcohol but also some had criminal records and
+other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
+told police she was younger than 18 when she started performing massages for Epstein.
+After the meeting, prosecutors postponed their decision to take the case to a grand jury.
+
+
+In the following weeks, police received complaints that two of the victims or their families had
+been harassed or threatened. Epstein's legal team maintains that its private investigators did
+nothing illegal or unethical during their research.
+By then, relations between police and prosecutors were fraying. At a key meeting with
+prosecutors and the defense, Detective
+Recarey, the lead investigator, was a no-show,
+according to Epstein's attorney.
+"The embarrassment on the prosecutor's face was evident when the police officer never
+showed up for the meeting," attorney Jack Goldberger said.
+Later in April, Recarey walked into a prosecutor's office at the state attorney's office and
+learned the case was taking an unexpected turn.
+The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein
+a plea deal that would not require him to serve jail time or receive a felony conviction.
+Recarey told her he disapproved of the plea offer.
+The deal never came to pass, however.
+Future unclear after charge
+On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
+counts of unlawful sexual activity with a minor and to charge his personal assistant,
+, now 27, fe her alleged role in arranging the visits. Police officials also wanted to
+charge
+the self-described Heidi Fleiss, with lewd and lascivious acts.
+By then, the department was frustrated with the way the state attorney's office had handled the
+case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
+wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
+he would not act.
+Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
+the grand jury.
+
+
+It is not known how many of the girls testified before the grand jury. But Epstein's defense
+team said one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up.
+The grand jury's indictment was handed down in July. It was not the one the police
+department had wanted.
+Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
+charged with one count of felony solicitation of prostitution, which carries a
+ximum penalty
+of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
+released hours later.
+Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
+he said their claims that they had sexual encounters with him lack credibility.
+"They are incapable of being believed," he said. "They had criminal records. They had
+accusations of theft made against them by their employers. There was evidence of drug use by
+some of them."
+What remains for Epstein is yet to be seen.
+The Palm Beach Police Department has asked the FBI to investigate the case. It also has
+returned the $90,000 Epstein donated in 2004.
+In New York, candidates for governor and state attorney general have vowed to return a total
+of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful
+friends have remained silent as tabloids and Internet blogs feast on the public details of the
+police investigation.
+Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
+plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
+"He will recover from this," he said
+Staff writer Larry
+Melanie Mena contributed to this story.
+and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
+amarra@pbpost.com
+
+
+@AMarraPBPost
+THIF MOST
+INTELLIGENT GRID
+IN AMERICA
+NOT A CERTIFIED
+NOT A CERTIFIED
+
+
+273 / 278 - Tuesday, November 16, 2004
+Section: A SECTION
+Page: 1A
+Source: By PAUL OWERS Palm Beach Post Staff Writer
+Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
+Memo: Ran all editions.
+Dateline: WEST PALM BEACH
+TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
+When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
+Donald was not about to be trumped.
+"Nobody was going to outbid me," the brash developer-turned-TV personality said from his
+New York office.
+Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
+seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
+But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
+513 N. County Road. He wants to - what else? - sell it and make more money.
+The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
+luxury house" that would be the "finest anywhere in the United States." He might build
+another house before flipping the entire package.
+"I've known about this house for quite some time," Trump said. "It's probably the best piece
+of land in Florida - and probably the country - for luxury real estate."
+Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
+Lesly
+said zoning regulations allow for only two houses - and maybe a third.
+said she's not worried about Trump's plans.
+"He's been a very good property owner in the town of Palm Beach," she said. "He does his
+projects very well. He's a perfectionist."
+Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
+Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
+distribution to creditors.
+The auction began at exactly noon after Judge Steven
+dismissed an objection from
+an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
+that Trump was not a qualified bidder because his contract stipulated that he would not close
+on the sale unless title insurance was in place beforehand.
+With Trump listening via conference call, Epstein began the bidding at $37.25 million -
+$250,000 higher than Trump's initial offer.
+Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn
+came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85
+million.
+Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had
+given up his right to bid by passing the first time.
+
+
+But
+allowed the offer to stand, and Pulte and Trump went back and forth until
+Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
+$38.6 million.
+closed the bidding 10 minutes after it started, leaving Trump with the right to buy
+the 29,000-square-foot home (a typical Palm Beach County single-family house is about
+2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
+quarters.
+The closing could take place within a week but probably won't happen until next month.
+Trustee Joe Luzinski and creditors said they were pleased with the outcome.
+"We knew we were dealing with some substantial people ... who were going tø bid it up a
+bit," Luzinski said.
+"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
+"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
+The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
+former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't
+receive a commission, he said
+Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.
+"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
+Pulte said Gosman asked him before the auction whether he would be willing to let him stay
+in the mansion after the closing until he decides where he wants to move. Trump and
+Luzinski said they have had no such discussions with Gosman.
+Gosman, 75, had the house built after paying $12,1 million for the land in 1986.
+The former health-care magnate declined interview requests before and after the auction
+Monday. He was at the courthouse but left before the auction took place.
+The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
+Beach home and guest house but falls short of the $45 million that Virginia home builder
+Dwight Schar paid for Ron Perelman's 26,000-square-foot estate, Casa Apava, a designated
+landmark.
+Schar also paid $18.6 million for a lakefront lot across the street from the main house, for a
+total of $63.6 million. Insiders say Schar spent a total of $70 million for his new property,
+making it the priciest residential sale in U.S. history.
+Gosman once had a fortune that Forbes magazine estimated at $480 million. He voluntarily
+filed for Chapter I1 bankruptcy protection in 2001, listing assets of $250 million and
+liabilities of $233.6 million.
+When a judge ruled that Gosman had to give up all of his exempt assets to creditors if he
+wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation.
+Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is
+invalid because Florida law does not recognize a Dominican Republic divorce that Lin
+Gosman tried to obtain from another man, Michael Castre.
+The judge's decision was a huge victory for creditors because it prevents Abe Gosman from
+protecting assets by claiming joint ownership with his wife. Gosman's assets, which include
+an extensive collection of artwork, could total as much as $70 million and will be sold later.
+Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's
+estate, said David Cimo, special counsel for the trustee.
+"We would have been thwarted... or at least substantially impaired," Cimo said.
+
+
+The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
+an ownership interest in his home and other belongings only to avoid losing them in
+bankruptcy. Gosman has denied any wrongdoing, saying he made the property transters in
+1999, well before he filed for bankruptcy.
+Lessen is expected to rule in the next two months whether Gosman made improper transfers,
+a decision that will affect how much money will be available to creditors.
+Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
+willing to move forward, in part because the upkeep of the estate now exceeds their means.
+"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
+said. "That's not a house you want to live in unless you're making large amounts of money
+like Donald Trump."
+paul_owers@pbpost.com
+NOT A CERTIFIED COP
+
+
+Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL
+Indictment: Billionaire Solicited 3 Times
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:30 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 25,
+2006)
+Billionaire money manager and Palm Beach part-time resident Jeffrey Epl
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
+of last year, according to an indictment charging him with felony solicitation of
+prostitution.
+Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
+was released on $3,000 bond.
+Epstein's case is unusual in that suspected prostitution johns are usually charged
+with a misdemeanor, and even a felony charge is typically made in a criminal
+information - an alternative to an indictment charging a person with the
+commission of a crime.
+His attorney, Jack Goldberger, declined to discuss the charge.
+State attorney's office spokesman Mike Edmondson also had little to say.
+"Generally speaking, there is a case that has a number of different aspects to it,"
+Edmondson said of a prostitution-related charge being submitted to a grand jury.
+"We first became aware of the case months ago by Palm Beach police."
+Prosecutors and police worked together to bring the case to the grand jury, he
+said.
+https://www.palmbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
+1/2
+
+
+Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL
+Palm Beach police confirmed that and said the department will release a report
+today regarding its investigation.
+Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
+pool and a boat dock on the Intracoastal Waterway since 1990, according to
+property records. A man answering the door there Monday said that Epstein
+wasn't home. A Cadillac Escalade registered to him was parked in the driveway,
+which is flanked by two massive gargoyles.
+Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the
+assessment of his home exceeded its fair market value. He dismissed his lawsuit
+in December 2002.
+A profile of Epstein in Vanity Fair magazine said he owns what are believed to
+be the largest private homes in Manhattan - 51,000 square feet - and in New
+Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
+U.S. Virgin Islands and fleet of aircraft.
+Epstein's friends and admirers, according to the magazine, include prominent
+businessmen, academics and scientists and famed Harvard law professor Alan
+Dershowitz.
+larry
+https://www.palmbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
+212
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+After long probe, billionaire faces solicitation
+charge
+Posted Jul 27, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:11 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 26,
+2006)
+Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young
+women brought to his home, where he received massages and sometimes sex,
+according to an investigation by the Palm Beach Police Department.
+Palm Beach police spent months sifting through Epstein's trash and watching his
+waterfront home and Palm Beach International Airport to keep tabs on his
+private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
+him with one count of felony solicitation of prostitution.
+Palm Beach police thought there was probable cause to charge Epstein with
+unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
+handling of the case that he wrote a memo suggesting the county's top
+prosecutor disqualify himself.
+"I must urge you to examine the unusual course that your office's handling of this
+matter has taken and consider if good and sufficient reason exists to require your
+disqualification from the prosecution of these cases," Reiter wrote in a May 1
+memo to Krischer.
+While not commenting specifically on the Epstein case, Mike Edmondson,
+spokesman for the state attorney, said his office presents cases other than
+murders to a grand jury when there are questions about witnesses' credibility and
+their ability to testify.
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+1/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+By the nature of their jobs, police officers look at evidence from a "one-sided
+perspective," Edmondson said. "A prosecutor has to look at it in a much broader
+fashion," weighing the veracity of witnesses and how they may fare under
+defense attorneys' questioning, he said.
+Epstein's attorney, Jack Goldberger, said his client committed no crimes.
+"The reports and statements in question refer to false accusations that were not
+charged because the Palm Beach County state attorney questioned the credibility
+of the witnesses," Goldberger said. A county grand jury "found the allegations
+wholly unsubstantiated and not credible," and that's why his client was not
+charged with sexual activity with minors, he said.
+Goldberger said Epstein passed a lie detector test administered by a reputable
+polygraph examiner in which he said he did not know the girls were minors.
+Also, a search warrant served on Epstein's home found no evidence to
+corroborate the girls' allegations, Goldberger said.
+According to police documents:
+- A Palm Beach Community College student said she gave Epstein a massage in
+the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
+sessions at his home.
+- A 27-year-old woman who worked as Epstein's personal assistant also
+facilitated the liaisons, phoning the PBCC student to arrange for girls when
+Epstein was coming to town. And she escorted the girls upstairs when they
+arrived, putting fresh sheets on a massage table and placing massage oils nearby.
+- Police took sworn statements from five alleged victims and 17 witnesses. They
+contend that on three occasions, Epstein had sex with the girls.
+A money manager for the ultra-rich, Epstein was named one of New York's most
+eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
+the likes of former President Clinton, former Harvard University President
+Summers and Donald Trump, and has lavish homes in Manhattan,
+New Mexico and the Virgin Islands.
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-facos-solicitation-charge
+2/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+He has contributed tens of thousands of dollars to Democratic Party candidates
+and organizations, including Sen. John Kerry's presidential bid, and the Senate
+campaigns of Joe
+1, Hillary Clinton,
+Dodd and Charles
+Schumer.
+COPY
+Goldberger is one of five attorneys Epstein has retained since he became the
+subject of an investigation, Edmondson said. Among the others: Alan
+Dershowitz, the well-known Harvard law professor and author, who is a friend
+of Epstein. Dershowitz could not be reached for comment.
+Police said the woman who enlisted young girls for Epstein was
+20, of|
+Palm Beach.
+has worked at an Olive Garden restaurant in
+Wellington and said she was a journalism major at Palm Beach Community
+College when she was questioned by police last October. She has an unlisted
+phone number and could not be reached for comment.
+said she met Epstein when, at age 17, a friend asked her if she would like
+to make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
+to a bedroom with a massage table and oils. Epstein and
+were both naked
+during the massage, she said, but when he grabbed her buttocks, she said she
+didn't want to be touched.
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+3/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+Epstein said he'd pay her to bring him more girls - the younger the better,
+told police. When she tried once to bring a 23-year-old woman to him,
+Epstein said she was too old,
+said.
+,, who has not been charged in the case, said she eventually brought six
+girls to Epstein who were paid $200 each time,
+said. "I'm like a Heidi
+Fleiss," police quoted her as saying. The girls knew what to expect when they
+were taken to Epstein's home,
+said. Give a massage - maybe naked - and
+allow some touching.
+One 14-year-old girl
+took to meet Epstein led police to start the
+investigation of him in March 2005. A relative of the girl called to say she
+thought the child had recently engaged in sex with a Palm Beach man. The girl
+then got into a fight with a classmate who accused her of being a prostitute, and
+she couldn't explain why she had $300 in her purse.
+The girl gave police this account of her meeting with Epl
+She accompanied
+and a second gitl to Epstein's house on a Sunday in
+February 2005. Once there, a woman she thought was Epstein's assistant told the
+girl to follow her upstairs to a room featuring a mural of a naked woman, several
+photographs of naked women on a shelf, a hot pink and
+sofa and a massage
+table.
+She stripped to her bra and panties and gave him a massage.
+Epstein gave the 14-yéar-old $300 and she and the other girls left, she said. She
+said Robson told her that Epstein paid her $200 that day.
+Other girls told similar stories. In most accounts, Epstein's personal assistant at
+the time,
+now 27, escorted the girls to Epstein's bedroom.
+, whose most recent known address is in North Carolina, has not been
+charged in the case.
+Palm Beach police often conducted surveillance of Epstein's home, and at Palm
+Beach International Airport to see if his private jet was there, so they would
+know when he was in town. Police also arranged repeatedly to receive his trash
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+4/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+from Palm Beach sanitation workers, collecting papers with names and phone
+numbers, sex toys and female hygiene products.
+One note stated that a female could not come over at 7 p.m. because of soccer.
+Another said a girl had to work Sunday - "Monday after school?" And still
+another note contained the work hours of a girl, saying she leaves school at 11:30
+a.m. and would come over the next day at 10:30 a.m.
+Only three months before the police department probe began, Epstein donated
+$90,000 to the department for the purchase of a firearms simulator, said Jane
+Struder, town finance director. The purchase was never made. The money was
+returned to Epstein on Monday, she said.
+NOT A CERTIFIED CO
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+5/5
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+Police say lawyer tried to discredit teenage
+girls
+Posted Jul 29, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 2:00 PM
+(EDITOR'S NOTE: This story originally was published in The Palm Beach Post on July
+29, 2006)
+Famed Harvard law professor Alan Dershowitz met with the Palm Beach County
+State Attorney's Office and provided damaging information about teenage girls
+who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
+charged massages, according to police reports.
+The reports also state that another Epstein attorney agreed to a plea bargain that
+would have allowed Epstein to have no criminal record. His current attorney
+denies this happened.
+And the documents also reveal that the father of at least one girl complained that
+private investigators aggressively followed his car, photographed his home and
+chased off visitors.
+Police also talked to somebody who said she was offered money if she refused to
+cooperate with the Palm Beach Police Department probe of Epstein.
+The state attorney's office said it presented the Epstein case to a county grand
+jury this month rather than directly charging Epstein because of concerns about
+the girls' credibility. The grand jury indicted Epstein, 53, on a single count of
+felony solicitation of prostitution, which carries a maximum penalty of five years
+in prison.
+Police believed there was probable cause to charge Epstein with the more serious
+crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
+Krischer a memo in May suggesting he disqualify himself from the case.
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+114
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+The case originally was going to be presented to the grand jury in February, but
+was postponed after Dershowitz produced information gleaned from the Web
+site myspace.com showing some of the alleged victims commenting on alcohol
+and marijuana use, according to the police report prepared by Detective
+Recarey.
+,, a 20-year-old
+Palm Beach woman who told police she
+recruited girls for Epstein, also is profiled on myspace.com. Her page includes
+photos of her and her friends, including one using the name "Pimpin' Made EZ."
+who was not charged in the case, is a potential prosecution witness.
+According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
+Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
+Epstein, accepted the deal, in which Epstein would plead guilty to one count of
+aggravated assault with intent to commit a felony, be placed on five years'
+probation and have no criminal record. The deal also called for Epstein to submit
+to a psychiatric and sexual evaluation and have no unsupervised visits with
+minors, according to Recarey's report. The plea bargain was made in connection
+with only one of the five alleged victims, the report states.
+Fronstin - who declined to comment on the case - was subsequently fired and
+veteran defense attorney Jack Goldberger was hired. He denies there was any
+agreement by any of Epstein's attorneys to a plea deal.
+"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek
+nor a state attorney's spokesman could be reached for comment.
+The parent or parents of alleged victims who complained of being harassed by
+private investigators provided license tag numbers of two of the men. Police
+found the vehicles were registered to a private eye in West Palm Beach and
+another in Jupiter, according to Recarey's report.
+"I have no knowledge of it," defense attorney Goldberger said.
+The report also says a woman connected to the Epstein case was contacted by
+somebody who was still in touch with Epstein. That person told her she would
+be compensated if she didn't cooperate with police, Recarey's report says. Those
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+214
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+who did talk "will be dealt with," the woman said she was told. Phone records
+show the woman talked with the person who allegedly intimidated her around
+the time she said, Recarey reported.
+Phone records also show that the person said to have made the threat then
+placed a call to Epstein's personal assistant, who in turn called a New York
+corporation affiliated with Epstein, the report states.
+The issue in the Epstein case is not whether females came to his waterfront
+home, but whether he knew their ages.
+"He's never denied girls came to the house," Goldberger said. But when Epstein
+was given a polygraph test, "he passed on knowledge of age," the attorney said.
+After the indictment against Epstein was unsealed this week, Police Chief Reiter
+referred the matter to the FBI. "We've received the referral, and we're reviewing
+it," said FBI spokeswoman Judy Orihuela in Miami.
+The chief himself has come under attack from Epstein's lawyers and friends in
+New York, where he has a home. The New York Post quoted Epstein's
+prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
+only "because of the craziness of the police chief."
+Reiter has declined to comment on the case.
+Prosecutors have not presented a sex-related case like Epstein's to a grand jury
+before, said Mike Edmondson, spokesman for the state attorney's office. "That's
+what you do with a case that falls into a gray area," he said.
+The state attorney's office did not recommend a particular criminal charge on
+which to indict Epstein, Edmondson said. The grand jury was presented with a
+list of charges from highest to lowest, then deliberated with the prosecutor out of
+the room, he said.
+"People are surprised at the grand jury proceeding," West Palm Beach defense
+attorney Richard Tendler said. "It's a way for the prosecutor's office to not take
+the full responsibility for not filing the (charge), and not doing what the Palm
+Beach Police Department wanted. I think something fell apart with those
+underage witnesses."
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+3/4
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
+must have been incredible or untrustworthy, I don't know," he said.
+Other attorneys said Epstein's case raises the issue of whether wealthy, connected
+defendants like Epstein - whose friends include former President Clinton and
+Donald Trump - are treated differently from others. Once he knew he was the
+subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
+Dershowitz and Lefcourt, who is a past president of the National Association of
+Criminal Defense Lawyers.
+Miami lawyer Roy Black - who became nationally known when he successfully
+defended William Kennedy
+on a rape charge in Palm Beach - also was
+involved at one point.
+Said defense attorney
+Suskauer: "I think it's unfortunate the public may
+get the perception that with power, you
+may be treated differently than the
+average Joe."
+CERTIFIE
+NOT A
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+414
+
+
+Expert: Ignorance of age isn't
+defense in sex cases
+Posted Aug 5, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 1:38 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 5, 2006)
+Even if Palm Beach money manager Jeffrey Epstein didn't
+know that girls who police say gave him sexual massages at
+his Intracoastal home were under the legal age, that alone
+wouldn't have exempted him from criminal charges of
+sexual activity with minors.
+"Ignorance is not a valid defense" said Bob Dekle, a legal
+skills professor who was a Lake City prosecutor for nearly
+30 years, half of that time speci
+zing in sex crimes against
+children.
+"There is no knowledge element as far as the age is
+concerned," Dekle said.
+After an 11-month investigation, Palm Beach police said
+there was probable cause to charge Epstein, 53, with
+unlawful sex acts with a minor and lewd and lascivious
+molestation. They contend that Epstein - friend of the rich
+and famous and financial patron of Democratic Party
+organizations and candidates - committed those acts with
+five underage girls.
+In the past week, New York Attorney General and
+gubernatorial candidate Eliot Spitzer has returned about
+$50,000 in campaign contributions he received from
+Epstein, and Mark
+,, a candidate to replace Spitzer in
+
+
+his current job, has returned $10,000 to him because of the
+Palm Beach scandal, the New York Daily News has
+reported
+Rather than file charges, the state attorney's office
+presented the case to a county grand jury. The panel
+indicted Epstein last week on a single, less serious charge of
+felony solicitation of prostitution.
+The case raised eyebrows because the state attorney's office
+rarely, if ever, kicks such charges to a grand jury. And it
+increases the difficulty of prosecuting child sex abuse cases,
+especially when the defendant is enormously wealthy and
+can hire high-priced, top-tier lawyers.
+At least one of Epstein's alleged victims told police he knew
+she was underage when the two of them got naked for
+massages and sexual activity. She was 16 years old at the
+time and said Epstein asked her questions about her high
+school, according to police reports.
+A girl who said she met Epstein when she was 15 said he
+told her if she told anybody what happened at his house,
+bad things could happen, the police reports state.
+Epstein's youngest alleged victim was 14 when she says she
+gave him a massage that included some sexual activity. She
+is now 16. The girl's father says he doesn't know whether
+she told Epstein her age.
+"My daughter has kept a lot of what happened from me
+because of sheer embarrassment," he said. "But she very
+much looked 14. Any prudent man would have had second
+thoughts about that."
+Defense attorney Jack Goldberger maintains that not only
+did Epstein pass a polygraph test showing he did not know
+the girls were minors, but their stories weren't credible.
+The state attorney's office also implied that their credibility
+was an issue when it decided not to charge Epstein directly,
+but instead give the case to the grand jury.
+
+
+"A prosecutor has to look at it in a much broader fashion," a
+state attorney's spokesman said last week.
+THE NOST
+INTELLIGENT GRID
+TAL ANERAL
+LEARN MORE D
+Epstein hired Harvard law Professor Alan Dershowitz
+when he became aware he was under investigation, and
+Dershowitz gave prosecutors information that some of the
+alleged victims had spoke of using alcohol and marijuana on
+a popular Web site, according to a Palm Beach police
+report.
+Prosecutors typically consider two things in deciding
+whether to charge somebody with sex-related offenses
+against minors - whether there is sufficient evidence and
+whether there is a public interest in doing so, Dekle said.
+Iftwo teens are in a sexual relationship and the boy turns
+18 before the girl, he could be charged with a sex crime if
+the sex continues. There would be no public interest in
+pursuing that, Dekle said.
+But where there is a large gap in ages - and especially in
+cases of teachers with students - there is a public interest in
+prosecuting, he said. Likewise if the accused has a track
+record of sex with minors.
+
+
+Still there is a "universal constant" in prosecuting these
+cases, Dekle said. Men who exploit underage children for
+sex often carefully choose their victims in ways that will
+minimize the risk to them, he said.
+Victims usually are from a lower social status, and they may
+suffer from psychological problems, Dekle said.
+"Lots of child sexual abuse victims have been victimized by
+multiple people over a period of time. Then the act of abuse
+produces behavior in the victims that further damages their
+credibility." Examples include promiscuous behavior and
+drug abuse.
+Some of the alleged victims in the Epstein case returned to
+his home multiple times for the massage sessions and the
+$200 to $300 he typically paid them per visit. "That would
+be a definite problem for the prosecutor," said Betty Resch,
+who prosecuted crimes against children in Palm Beach
+County for five years and now is in private practice in Lake
+Worth.
+"The victim becomes less sympathetic" to a jury, Resch said.
+"But she's a victim nevertheless. She's a kid."
+Most men charged with sex crimes against minors look
+normal, Dekle said. A jury expecting to see a monster
+seldom will. And the victims' ages work against them and in
+favor of the defendant in a trial, Dekle said.
+If a child and an adult tell different stories and both swear
+they're telling the truth, adult jurors are more likely to
+believe the adult, Dekle said.
+"You have all these things working against you in a child
+sex abuse case. Prosecutors normally try to be very careful
+in filing those cases because they know what they're getting
+into. There is no such thing as an iron-clad child sexual
+abuse case."
+
+
+Epstein camp calls female accusers
+liars
+Posted Aug 8, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:35 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 8, 2006)
+Attorneys and publicists for Palm Beach financier Jeffrey
+Epstein went on the offensive Monday, contending that
+teenage girls who have accused Epstein of sexual
+shenanigans at his waterfront home are liars and saying
+that the Palm Beach Police Department is "childish."
+"There never was any sex between Jeffrey Epstein and any
+underage women," his lead attorney, Jack Goldberger, said
+from Idaho where he was vacationing with his family.
+Epstein did have young women come to his house to give
+him massages, Goldberger said. "Mr. Epstein absolutely
+insisted anybody who came to his house be over the age of
+18. How he verified that, I don't know. The question is, did
+anything illegal occur. The law was not violated here."
+He had no explanation as to why Epstein would pay girls or
+women with no massage training - as the alleged victims
+said was the case - $200 to $300 for their visits. "The
+credibility of these witnesses has been seriously
+questioned," Goldberger said.
+Epstein, 53, was indicted by a county grand jury last month
+on a charge of felony solicitation of prostitution. After an
+11-month investigation that included sifting through
+Epstein's trash and surveilling his home, Palm Beach police
+concluded there was enough evidence to charge him with
+sexual activity with minors. When the grand jury indicted
+
+
+Epstein on the less serious charge, Police Chief Michael
+Reiter referred the case to the FBI to determine whether
+there were federal law violations.
+After a spate of stories about the case last week, New York
+publicist Dan Klores - whose client list has included Paris
+Hilton and Jennifer
+- said on Saturday that Epstein's
+camp was ready "to get their story out."
+They did that Monday via Goldberger and a Los Angeles
+publicist for Miami criminal defense attorney Roy Black,
+who also has represented Epstein in the case.
+"We just think there has been a distorted view of this case
+in the media presented by the Palm Beach police,
+Goldberger said.
+Reiter has consistently declined to comment on the case
+and did not respond to a request for comment Monday.
+NOT A
+The implication that State Attorney Barry Krischer was
+easy on Epstein by presenting the case to a grand jury
+rather than filing charges directly against him is wrong,
+Goldberger said.
+
+
+The Palm Beach Police Department was "happy and
+ecstatic" that the panel was going to review the evidence. "I
+think what happened is they weren't happy with the result.
+They decided to use the press to embarrass Mr. Epstein."
+But records show that Reiter wrote Krischer on May 1 -
+well before the case went to the grand jury - suggesting that
+Krischer "consider if good and sufficient reason exists to
+require your disqualification from the prosecution of these
+cases."
+Rather than flat-out decline to charge Epstein, Krischer
+referred the case to the grand jury to "appease" the chief,
+Goldberger said.
+A state attorney's spokesman would say only that the office
+refers cases to the grand jury when there are issues with the
+viability of the evidence or witnesses credibility.
+Both the state attorney and the grand jury concluded there
+was not sufficient evidence that Ep
+had sex with
+minors, according to Goldberger. "It was just a childish
+performance by the Palm Beach Police Department,"
+Goldberger said.
+The defense attorney said one of the alleged victims who
+claimed she was a minor was in fact over the age of 18.
+Another alleged victim who was subpoenaed to testify to
+the grand jury failed to do so. Epstein's accusers, he added,
+have histories of drug abuse and thefts. "These women are
+liars. We've established that."
+But why would they all invent their stories about meeting
+Epstein for sexual massages?
+"I don't have an answer as to what was the motivation for
+these women to come forward and make these allegations,"
+Goldberger said.
+
+
+Newspapers
+ly Blancestry
+The Palm Beach Post (West Palm Beach, Florida) • 14 Aug 2006, Mon • Page 7
+Downloaded on Nov 11, 2019
+Palm Beach chief focus
+of fire in Epstein case
+Reiter focus of fire in Epstein case
+Clipped By:
+reiter_m
+Sat, Apr 22, 2017
+Copyright © 2019 Newspapers.com. All Rights Reserved.
+Y
+Newspapers
+
+
+Delays in Epstein case unusual,
+lawyers say
+Posted Mar 13, 2007 at 12:01 AM
+Updated Oct 3, 2019 at 3:48 PM
+(EDITOR'S NOTE: This story originally published in The Palm
+Beach Post March 13, 2007)
+A federal probe or a plea deal could explain the wait in the
+Palm Beacher's solicitation case.
+Nearly eight months after Palm Beach tycoon Jeffrey
+Epstein was charged with felony solicitation of prostitution,
+there has been no discernible progress in his case. No
+witnesses deposed. No trial date set. Nothing, save for
+routine court hearings reset without explanation.
+"Usually that would be unusual," said criminal defense
+attorney Glenn Mitchell, who has no involvement in the
+case.
+"As a general rule, it would be unusual for nothing to have
+happened, agreed Michael Dutio, a criminal defense
+attorney in Fort Lauderdale. He represents
+20, of
+Palm Beach, potentially a key witness in the
+case.
+A routine hearing for Epstein was pulled from the court
+docket last week and reset for May 16. The delays and
+inaction could be due to a potential federal probe of Epstein
+or because a plea deal is in the works, attorneys say.
+Unusual is the word that best describes everything about
+the case against Epstein, 54, an enigmatic money manager
+in New York City who counts Bill Clinton and Donald
+Trump among his friends.
+
+
+"Highly unusual" is how Palm Beach Police Chief Michael
+Reiter described State Attorney Barry Krischer's handling
+of the case in a bluntly critical letter to Krischer last year
+before Epstein was indicted.
+Reiter referred the matter to the FBI to determine whether
+any federal laws had been violated. Epstein's allies
+countered by attacking the chief personally and
+professionally.
+Reiter's department investigated Epstein for 11 months.
+Police sifted repeatedly through his trash and conducted
+surveillance on his five-bedroom, 7 1/2-bath, 7,234-squarefoot home on the Intracoastal Waterway.
+Police said Epstein paid women and girls as young as 14 to
+give him erotic massages at his home. Police thought there
+was probable cause to charge him with unlawful sex acts
+with a minor and lewd and lascivious molestation.
+Epstein responded by hiring a phalanx of lawyers. One of
+them, Harvard law professor and author Alan Dershowitz,
+provided the state attorney's office with information about
+alcohol and marijuana use by some of the girls who said
+they were with Epstein.
+Prosecutors then referred the case to the grand jury rather
+than file charges directly against Epstein.
+Epstein's attorneys deny he had sex with underage girls.
+The lawyers say the girls' stories are not credible. But if the
+court file is any indicator, they've made no effort to depose
+the girls.
+Neither prosecutors nor defense attorneys have sought to
+question
+, said Dutko, her attorney. She recruited
+teenage girls to visit Epstein for massages and sexual
+activity, Palm Beach police said, and presumably would be a
+key witness.
+
+
+Epstein's attorney Jack Goldberger did not return phone
+messages.
+A source close to the case suggested it is languishing
+pending a decision by the FBI on whether to refer it to
+federal prosecutors.
+"We still have a pending case," FBI spokeswoman Judy
+Orihuela said Monday.
+State Attorney Krischer did not return a call for comment.
+His spokesman, Mike Edmondson, declined to say whether
+federal investigators are delaying the Epstein case. But, he
+added, "if another agency is looking at something, we
+wouldn't want to step on their toes."
+Attorneys say inertia in a criminal case often points to a
+pending plea deal.
+"It would not surprise me if something has happened that's
+not reflected in the court file," said Dutko, such as an
+agreement that will be for
+lized later.
+Defense attorney Mare Shiner said defense attorneys
+sometimes put off overtly conducting discovery -- deposing
+witnesses, requesting documents and the like -- because
+doing so creates more work for harried prosecutors who
+may become angry and not offer a plea deal.
+"Sometimes defense lawyers, knowing that, will try and do
+discovery without taking depositions," said Shiner, a former
+prosecutor for 13 years.
+Instead, they may conduct a below-the-radar probe such as
+having a private investigator check out leads, he said.
+Shiner and others say a plea deal for Epstein probably
+would result in pretrial intervention, in which a defendant
+may be ordered to undergo a psychological evaluation,
+counseling or other conditions in return for dropping the
+charge.
+
+
+Edmondson, spokesman for State Attorney Krischer, said
+there is no plea offer and no request for the prosecution to
+show its cards.
+"To my knowledge, it's never happened before on a filed
+case," he said.
+
+
+252 / 278 - Thursday, October 18, 2007
+Section: LOCAL
+Page: 5B
+Source: The Associated Press
+Illustration: PHOTO (B& W)
+Memo: Ran all editions.
+Dateline: NEW YORK
+WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
+A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
+prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model.
+The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had
+the teen perform a sex act when she brought photographs of herself for him to review in his Upper
+East Side mansion sometime in 2000.
+Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
+you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
+included massages and other favors.
+When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I
+won't tell anybody," court papers say.
+Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
+indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.
+The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
+sex acts" while she was a minor, the lawsuit says.
+Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
+stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
+40s). I love girls your age.'"
+The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
+lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
+of severe mental disease and defect."
+Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
+read a newspaper and recognize the word 'rich."
+Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly,
+and will almost certainly be dismissed.
+He refused to comment on Epstein's Florida charges.
+Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center
+of a $10 million lawsuit he filed last year against a neighbor who said he was having sex with
+underage girls. That case is pending.
+"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said
+Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve
+the case out of court.
+
+
+Palm Beacher pleads in sex case
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 3, 2019 at 1:47 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on July 1, 2008)
+Jeffrey Epstein will serve 1 1/2 years on teen solicitation
+charges.
+He lives in a Palm Beach waterfront mansion and has kept
+company with the likes of President Clinton, Prince
+Andrew and Donald Trump, but investment banker Jeffrey
+Epstein will call the Palm Beach County Jail home for the
+next 18 months.
+Epstein, 55, pleaded guilty Monday to felony solicitation of
+prostitution and procuring a person under the age of 18 for
+prostitution. After serving 18 months in jail, he will be
+under house arrest for a year. And he will have a lifelong
+obligation to register as a sex offender. He must submit to
+an HIV test within 48 hours, with the results being
+provided to his victims or their parents.
+As part of the plea deal, federal investigators agreed to drop
+their investigation of Epstein, which they had taken to a
+grand jury, two law enforcement sources said.
+Epstein was indicted two years ago after an 11-month
+investigation by Palm Beach police. They received a
+complaint from a relative of a 14-year-old girl who had
+given Epstein a naked massage at his five-bedroom, 7,234-
+square-foot, $8.5 million Intracoastal home.
+Police concluded that there were several other girls brought
+in 2004 and 2005 to an upstairs room at the home for
+similar massages and sexual touching.
+
+
+:
+The indictment charged Epstein only with felony
+solicitation of prostitution. The state attorney's office later
+added the charge of procuring underage girls for that
+purpose.
+Prosecutor Lanna Belohlavek said of the plea: "I took into
+consideration the length the trial would have been and
+witnesses having to testify" about sometimes embarrassing
+incidents.
+Epstein may have made a serious mistake soon after he was
+charged. He rejected an offer to plead guilty to one count of
+aggravated assault with intent to commit a felony,
+according to police documents. He would have gotten five
+years' probation, had no criminal record and not been a
+registered sex offender, the documents indicate.
+Epstein arrived in court Monday with at least three
+attorneys. He wore a blue blazer, blue shirt, blue jeans and
+and gray sneakers. After Circuit Judge Deborah Dale
+Pucillo accepted the plea, he was fingerprinted. Epstein
+then removed his blazer and was handcuffed for the trip to
+jail while his attorneys tried to shield him from
+photographers' lenses.
+When he eventually is released to house arrest, Epstein will
+have to observe a 10 p.m. to 6 a.m. curfew, have no
+unsupervised contact with anyone younger than 18 and
+neither own nor possess pornographic or sexual materials
+"that are relevant to your deviant behavior," the judge said.
+Epstein will be allowed to leave home for work. The New
+York-based money manager told the judge he has formed
+the not-for-profit Florida Science Foundation to finance
+scientific research. "I'm there every day," Epstein said.
+The foundation was incorporated in November. Epstein
+said he already has awarded money to Harvard and MIT.
+
+
+When he is released from jail, there is a chance that Epstein
+will be forced to move. Sex offenders are not allowed to live
+within 1,000 feet of a school, park or other areas where
+children may gather. No determination has been made as to
+whether Epstein's home complies, but attorneys said it
+likely does.
+Sex offenders also typically must attend counseling sessions.
+Belohlavek said that was waived for Epstein because his
+private psychiatrist is working with him. The judge was
+skeptical but agreed to it.
+Epstein's legal woes don't end with Monday's plea. There
+are four pending federal civil lawsuits and one in state court
+related to his behavior. At least one woman has sued him in
+New York, where he owns a 51,000-square-foot Manhattan
+mansion.
+"It's validation of what we're saying in the civil cases," said
+Miami attorney Jeffrey Herman, who represents the alleged
+victims in the federal lawsuits, West Palm Beach attorney
+Ted Leopold represents one alleged victim in a civil suit in
+state court. He said he anticipates amending that lawsuit to
+add "a few other clients" as well.
+In the criminal case, police went so far as to scour Epstein's
+trash and conduct surveillance at Palm Beach International
+Airport, where they watched for his private jet so they
+would know when he was in town. They concluded that
+Epstein paid girls $200 to $300 each after the massage
+sessions.
+"I'm like a Heidi Fleiss," L
+about her efforts in recruiting girls for Epstein.
+• now 22, told police
+There was probable cause to charge Epstein with unlawful
+sex acts with a minor and lewd and lascivious molestation,
+police concluded.
+
+
+The state attorney's office said questions about the girls'
+credibility led it to take the unprecedented step of
+presenting the evidence against Epstein to a grand jury,
+rather than directly charging him.
+Palm Beach Police Chief Michael Reiter was furious with
+State Attorney Barry Krischer, saying in a May 2006 letter
+that the prosecutor should disqualify himself. "I continue to
+find your office's treatment of these cases highly unusual,"
+he wrote. He then asked for and got a federal investigation.
+Epstein hired a phalanx of high-priced lawyers - including
+Harvard law professor and author Alan Dershowitz - and
+public relations people who questioned Reiter's competence
+and the victims' truthfulness.
+In addition to mansions in Palm Beach and Manhattan,
+Epstein owns homes in New Mexico and the Virgin Islands.
+He's a frequent contributor to Democratic Party candidates.
+He also donated $30 million to Harvard in 2003.
+Former New York Gov. Eliot Spitzer returned a $50,000
+campaign contribution from Epstein after his indictment,
+then resigned this year during his own sex scandal. And the
+same Palm Beach Police Department that vigorously
+investigated Epstein returned his $90,000 donation for the
+purchase of a firearms simulator.
+Staff writer Eliot Kleinberg and former staff researcher
+Quigley contributed to this story.
+
+
+Jeffrey Epstein: Scientist,
+stuntman, 'sex slave' visit jailed
+tycoon
+By LARRY
+/ Palm Beach Post Staff Writer
+Posted Aug 13, 2008 at 12:01 AM
+Updated Jul 16, 2019 at 4:54 PM
+Tycoon Jeffrey Epstein mingled with an eclectic mix of
+people, including beautiful young women, before he got
+into trouble for paying teenage girls to give him sexual
+massages at his Palm Beach mansion.
+Not much has changed, even though he now resides in a
+dorm at the Palm Beach County Sheriff's Office's 17-acre,
+967-bed stockade near the fairgrounds.
+During his first month of confinement, Epstein was visited
+by the female assistant who, girls told police, had escorted
+them to the room at his mansion where they gave him
+naked massages.
+Also trekking to the jail was a young woman whom Epstein
+purportedly described as his Yugoslavian sex slave.
+The wealthy financier and science wonk also has been
+visited by an expert on artificial intelligence, as well as a
+man who is a mixed martial arts aficionado and sometime
+movie stuntman.
+The only other people to visit him at the jail, according to
+records, are a
+Island man and an individual who
+listed Epstein's Palm Beach address as his own.
+Epstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,
+followed by a year of house arrest. Epstein paid teenage
+
+
+girls $200 to $300 in 2004 and 2005 for massages in his
+home that sometimes included sexual touching, Palm Beach
+police said
+His jail visitors in July included:
+, 29, who some of the teen masseuses said
+phoned them when Epstein was in town and escorted them
+upon their arrival at his Palm Beach waterfront home to an
+upstairs room, where she prepared the massage table and
+provided the oils for their encounters with him.
+visited Epstein three times in July, according to a jail
+visitor's log.
+lists a Manhattan home address.
+Reached by telephone, she declined to discuss Epstein.
+Op
+23, whose family in Yugoslavia
+Epstein paid money to so that he could bring her to the
+United States to be his "sex slave," two teenage girls told
+police. One girl told police that Epstein instructed
+and her to kiss and have sex while he watched
+and masturbated. Another said she engaged in sex with
+at Epstein's urging.
+visited Epstein
+in jail four times in 13 days. She lists her address as on the
+Upper East side of Manhattan, not far from Epstein's
+enormous apartment.
+- Roger Schank, 62, founder of the Institute for Learning
+Sciences at Northwestern University and an expert on
+artificial intelligence, paid one visit to Epstein. Schank has
+written numerous books on that subject and has a doctorate
+degree from Yale University in linguistics. He was one of 19
+people who applied to be president of Florida Atlantic
+University in 2003. He became "chief learning officer" at the
+online Trump University in 2005. Schank listed his address
+as being in Stuart, and records show he also owns a home
+in Lake Worth.
+
+
+Epstein has financed a number of scientists over the years,
+including Nobel Prize winners. He gave $30 million to
+Harvard University in 2003. In November, he formed the
+not-for-profit Florida Science Foundation, which he said
+finances scientific research.
+- Igor Zinoviev, a Russian mixed martial arts fighter, who
+coaches a Chicago team in the International Fight League.
+He also has worked as a personal trainer, celebrity
+bodyguard and movie stuntman, according to the league's
+Web site. The New Jersey resident visited Epstein seven
+times in July.
+Zinoviev, Schank and
+comment.
+could not be reached for
+Staff researcher
+N
+liels
+Heimeriks
+NOT A CERTIFIÉ
+contributed to this story.
+
+
+Billionaire sex offender leaves jail
+six days a week for work
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 4, 2019 at 9:27 AM
+Palm Beach billionaire Jeffrey Epstein, who's serving 18
+months in jail for soliciting an underage girl for
+prostitution, is allowed to leave the Palm Beach County
+Stockade six days a week on a work-release program.
+Teri Barbera, spokeswoman for the Palm Beach County
+OPY
+Sheriff's Office, confirmed that Epstein, 55, has been in the
+work-release program since Oct. 10.
+"He works six days a week: Friday through Wednesday 10
+a.m. to 10 p.m.," Barbera said via e-mail. "(He) works at his
+local West Palm Beach office, monitored on an active GPS
+system (he wears an ankle bracelet). Mr. Epstein hires a
+permit deputy, at his expense, for his own security at his
+workplace during the time he is out."
+Miami attorney Jeffrey Herman represents six young
+women who've sued Epstein, claiming he sexually abused
+them at his Palm Beach home when they were minors.
+Herman said he received a letter about the work-release
+program from the U.S. Attorney's Office within the past
+few days. But Herman says Epstein had been out on workrelease for several weeks before the notification.
+"My clients expressed shock and disappointment," Herman
+said. "I find it incredible that he's on work-release in the
+community and my clients aren't notified of this and we get
+this letter weeks after the fact."
+Jack Goldberger, Epstein's criminal attorney, said the
+
+
+arrangement is not unusual.
+"He goes to work every single day and goes back to jail at
+night, just like everybody else (in the program),"
+Goldberger said.
+Epstein pleaded guilty June 30 to two felony counts:
+soliciting prostitution and procuring a person under 18 for
+prostitution. As part of the plea agreement, Epstein must
+serve one year of house arrest and register as a lifelong sex
+offender.
+
+
+Women want Epstein sex plea deal
+unsealed
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:23 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post June 10, 2009)
+When wealthy money manager Jeffrey Epstein of Palm
+Beach pleaded guilty last year to procuring teens for
+prostitution, his case detoured around local and state rules
+regarding the sealing of court documents.
+At a plea conference on the state charges, a judge, a defense
+lawyer and a prosecutor huddled at the bench and decided
+that a deal Epstein had struck with federal prosecutors to
+avoid charges should be sealed, according to a transcript of
+the hearing.
+And so it was.
+But Florida rules of judicial administration, as well as rules
+of the Palm Beach County court system, require public
+notification that a court document has been or will be
+sealed, meaning kept from public view. The rules also
+require a judge to find a significant reason to seal, such as
+protecting a trade secret or a compelling government
+interest.
+Yet no notification or reason occurred in Epstein's case,
+according to court records.
+
+
+Epstein's own attorneys, in federal filings, have referred to
+his confidential deferred prosecution agreement with the
+U.S. attorney's office, struck in September 2007, as
+"unprecedented" and "highly unusual." And it was "a
+significant inducement" for Epstein to accept the state's
+deal, observed the state judge who accepted his plea,
+County Judge Deborah Dale Pucillo.
+Epstein now faces at least a dozen civil lawsuits in federal
+and state courts filed by young women who said they had
+sex with him and now are seeking damages.
+Attorneys for some of those women want his agreement
+with federal prosecutors unsealed and will ask Circuit Judge
+Jeffrey Colbath to do so today.
+"It is against public policy for these documents to be have
+been sealed and hidden from public scrutiny. As a member
+of the public, E. W. has a right to have these documents
+unsealed," wrote former Circuit Judge Bill Berger, now in
+private practice and representing one of the women.
+The Palm Beach Post also will ask Colbath to unseal the
+agreement. Post attorney Deanna Shullman will argue that
+the public has a right to know the specifics of Epstein's deal.
+According to various media accounts, Epstein moved in
+circles that included President Clinton, Donald Trump and
+Prince Andrew. "International Moneyman of Mystery,"
+declared a 2002 New York magazine profile of Epstein.
+Epstein, 56, is in the Palm Beach County Stockade, serving
+an 18-month sentence after pleading guilty nearly a year
+ago to felony solicitation of prostitution and procuring
+teenagers for prostitution.
+He is allowed out from 7 a.m. to 11 p.m., escorted by a
+deputy, said Palm Beach County Sheriff's Office
+spokeswoman Teri Barbera.
+
+
+During a Palm Beach Police Department investigation, five
+victims and 17 witnesses gave statements. They told of
+young women brought by his assistants to Epstein's
+mansion on El Brillo Way for massages and sexual activity,
+and then being paid afterward.
+At Epstein's plea conference last year, his attorney, Jack
+Goldberger, and then-Assistant State Attorney Lanna
+Belohlavek approached Pucillo in a sidebar conference.
+Pucillo, who had left the bench nine years earlier, was
+filling in temporarily as a senior judge.
+According to a transcript, Goldberger told Pucillo that
+Epstein had entered a confidential agreement with the U.S/
+attorney's office in which federal prosecutors brokered not
+pursuing charges against him if he pleaded guilty in state
+court. Pucillo then said she wanted a sealed copy of the
+agreement filed in his case, and Goldberger concurred that
+he wanted it sealed. Belohlavek later signed off on it.
+The Florida Supreme Court has expressed "serious concern"
+and launched an all-out inquiry into sealing procedures
+across the state following media reports in 2006 of entire
+cases being sealed and disappearing from court records.
+"The public's constitutional right of access to court records
+must remain inviolate, and this court is fully committed to
+safeguarding this right," justices wrote in their final report.
+Epstein's office on Tuesday referred any questions to
+Goldberger, who declined to comment. Pucillo also has
+declined to comment.
+
+
+Epstein secret pact with Feds
+reveals "highly unusual" terms
+Posted Jun 10, 2009 at 12:01 AM
+Updated Oct 4, 2019 at 9:23 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on September 19, 2009)
+A secret non-prosecution agreement multimillionaire
+financier Jeffrey Epstein struck with federal prosecutors is
+being called "highly unusual" by former federal prosecutors
+and downright outrageous by attorneys now representing
+young women who serviced him.
+The deal reveals that the FBI and the U.S. Attorney's Office
+investigated him for several federal crimes, including
+engaging minors in commercial sex. The crimes are
+punishable by anywhere from 10 years to life in prison.
+But federal prosecutors backed down and agreed to recall
+grand jury subpoenas if Epstein pleaded guilty to
+prostitution-related felonies in state court, which he
+ultimately did. He received an 18-month jail sentence, of
+which he served 13 months.
+The U.S. Attorney's Office also agreed not to charge any of
+Epstein's possible co-conspirators:
+1, Lesley Groff and
+The deal was negotiated in part by heavyweight New York
+criminal defense attorney Gerald Lefcourt.
+Unsealed on Friday after attorneys for some of Epstein's
+victims and The Palm Beach Post sought its release, it offers
+the first public look at the deal Epstein's high-powered legal
+counsel brokered on his behalf.
+
+
+Mark
+of Stuart, a former federal prosecutor,
+described the disparity in potential sentences as unusual,
+but even more so a provision on attorney payment.
+The first draft of the agreement in September 2007
+required that Epstein pay an attorney -- tapped by the U.S.
+Attorney's Office and approved by Epstein -- to represent
+some of the victims. That attorney is prominent Miami
+lawyer Bob Josefsberg.
+But an addendum to the agreement signed the following
+month struck Epstein's duty to pay Josefsberg if he and the
+victims did not accept settlements -- capped at $150,000 -
+and instead pursued lawsuits.
+said it appears the government was trying to
+balance the lesser sentence for Epstein with recovering
+$150,000 for each victim. "I've never, ever seen anything
+like that in my life," he said. "It's highly ynusual."
+The deal does not say whether any victims were contacted
+or consulted before the deal was made.
+Attorney Brad Edwards of Fort Lauderdale, who represents
+three of the young women, believes that none of the 30 to
+40 woman identified as victims in the federal investigation
+were told ahead of time. [
+said his clients received
+letters from the U.S. Attorney's Office months after the deal
+was signed, assuring them Epstein would be prosecuted.
+"Never consulting the victims is probably the most
+outrageous aspect of it," L
+said. "It taught them that
+someone with money can buy his way out of anything. It's
+outrageous and embarrassing for United States Attorney's
+Office and the State Attorney's Office."
+Epstein now faces many civil lawsuits filed by the women,
+who are represented by a variety of attorneys. In many, the
+allegations are the same: that Epstein had a predilection for
+teenage girls, identified poor, vulnerable ones and used
+
+
+other young women to lure them to his Palm Beach
+mansion. They walked away with between $200 and
+$1,000.
+Former Circuit Judge Bill Berger, also representing victims,
+called the agreement a "sweetheart deal."
+"Why was it so important for the government to make this
+deal?" Berger asked rhetorically. "We have not yet had an
+honest explanation by any public official as to why it was
+made ... and why the victims were sold down the river."
+Former federal prosecutor Ryon McCabe described the
+agreement as "very unorthodox." Such agreements, he said,)
+are usually reserved for corporations, not individuals.
+"It's very, very rare. I've never seen or heard of the
+procedure that was set up here," said McCabe, who has no
+involvement in any Epstein litigation.
+"He's essentially avoiding federal prosecution because he
+can afford to pay that many lawyers to help those victims
+review their cases. ^ If a person has no money, he couldn't
+be able to strike a deal like this and avoid federal
+prosecution."
+The backroom deal with federal prosecutors is all the more
+interesting in light of the legal powerhouses who have
+worked for Epstein, including Harvard professor Alan
+Dershowitz and Bill Clinton investigator Kenneth Starr.
+Lefcourt is a past president of the National Association of
+Criminal Defense Lawyers.
+Epstein's local defense attorney, Jack Goldberger, issued a
+statement Friday saying he had fought the release of the
+sealed agreement to protect the third parties named there.
+"Mr. Epstein has fully abided by all of its terms and
+conditions. He is looking forward to putting this difficult
+period in his life behind him. He is continuing his longstanding history of science philanthropy."
+
+
+The investigation triggered tensions between police and
+prosecutors, with then-Palm Beach Chief Michael Reiter
+saying in a May 2006 letter to then-State Attorney Barry
+Krischer that the chief prosecutor should disqualify himself..
+"I continue to find your office's treatment of these cases
+highly unusual," Reiter wrote. He then asked for and got
+the federal investigation that ended in the sealed deal.
+"The Jeffrey Epstein matter was an experience of what a
+many-million-dollar defense can accomplish," Reiter told
+the Palm Beach Daily News upon his retirement.
+
+
+187 / 278 - Wednesday, January 27, 2010
+Section: LOCAL & BUSINESS
+Page: 3B
+Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
+Dateline: WEST PALM BEACH
+JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
+In a decision that could spark a constitutional showdown over privacy rights, a judge
+Tuesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to
+subpoena abortion records from women who are seeking millions in damages from the parttime Palm Beach resident.
+Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
+the women's claims that they suffered psychological ills after being paid to give him
+sexually-charged massages at his Palm Beach mansion when they were as young as 14.
+Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
+he said, can't be sought until the women are asked whether they have ever had an abortion,
+how many and where. Further, he said, the records would not be made public and might not
+be admissible during trial.
+But, he said, since the women claim Epstein, now 57, is responsible for their emotional
+distress, his attorneys can explore the impact of other events. Medical records, Hafele said,
+are a better source of information than a person'S memory.
+Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm
+Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky
+constitutional grounds.
+"These records are protected by our constitutional right of privacy," he said, referring to the
+Florida Constitution.
+After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the
+records.
+In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
+can't be released without a court order. The ruling came after Epstein attorney Robert Critton
+complained that a video of Epstein being asked whether he had an "egg-shaped" penis
+became a youtube.com sensation. It first appeared on The Palm Beach Post Web site.
+Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record
+The civil suits began mounting after Epstein agreed to plead guilty to two state charges:
+procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18-
+month sentence. As part of the deal brokered with federal prosecutors, he agreed not to
+contest the accusations in the civil lawsuits. He can argue the women don't deserve the
+millions they are seeking.
+~jane_musgrave@pbpost.com
+
+
+Epstein Journal's Findings Could
+Resurrect Case
+By Jane Musgrave
+Posted Sep 17, 2019 at 12:01 AM
+Updated Oct 1, 2019 at 10:51 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on March 20, 2010)
+A purloined journal that is said to contain the names of
+"hundreds" of victims of convicted sex offender Jeffrey)
+Epstein could be used to reopen the investigation into the
+multi-millionaire's appetite for teenage girls, an attorney
+representing seven of the victims said Friday.
+New details about the contents of the journal were released
+this week when Alfredo Rodriguez, who worked as a
+property manager for the Palm Beach resident, pleaded
+guilty to obstruction of justice for lying to federal agents
+when asked if he had any information about his former
+boss' criminal activity. He later tried to sell the journal he
+stole from Ep
+for $50,000 to an unidentified person,
+who alerted authorities, according to court records.
+As part of the plea agreement, federal prosecutors said the
+journal "contains information material to the Epstein
+investigation, including the names of material witnesses
+and additional victims."
+"Had the items been produced in response to the inquiries
+of state or federal authorities ... the materials would have
+been presented to the federal grand jury," federal
+prosecutors wrote.
+1
+
+
+Instead, prosecutors short-circuited the grand jury
+investigation and cut a deal with Epstein. They agreed not
+to pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded
+guilty in July 2008 to procuring a minor for prostitution
+and soliciting prostitution. He served 13 months of an 18-
+month sentence.
+Attorney Adam Horowitz, who represents seven of the
+roughly 18 women who have filed civil suits against
+Epstein, said the new information could trump the socalled non-prosecution agreement.
+The multifaceted agreement, he said, deals only with a
+specific list of victims that the U.S. Attorney's Office knew
+about when it penned the deal in 2007. If additional victims
+are listed in the journal Rodriguez stole, Horowitz said
+federal prosecutors could reopen the investigation.
+"It opens the door for further prosecution," he said.
+In addition to turning over the journal to federal agents,
+Rodriguez told them he knew his former boss was having
+sex with underage girls when he worked for him in 2004
+and 2005. He had seen naked girls, who looked like minors,
+in the pool of Epstein's $8.6 million mansion. He had seen
+pornographic images of young girls on Epstein's computer,
+according to court records.
+Neither Epstein's criminal defense attorney, Jack
+Goldberger, nor attorney Robert Critton, who represents
+Epstein in the civil lawsuits, could be reached. Federal
+prosecutors have consistently declined comment.
+The wording of the controversial agreement is unclear. It
+says federal prosecutors would provide Epstein's attorneys
+"with a list of individuals whom it has identified as victims."
+Miami attorney Robert Josefsberg was appointed to
+
+
+represent any of the victims on the list who wanted to
+pursue Epstein in civil court. As part of the agreement,
+Epstein is to pay for Josefsberg to represent the women.
+Some of the women, most identified as Jane Doe in
+lawsuits, had already hired attorneys to represent them.
+Some have since settled their suits with Epstein, although
+terms were not disclosed.
+Horowitz said he has filed court papers to get the journal
+that Rodriguez stole. "It's another piece of evidence that
+shows our clients were at Epstein's mansion," he said.
+Rodriguez told prosecutors he didn't turn over the journal
+when both FBI and Palm Beach police asked for it because
+he wanted money for it. He also said he was afraid Epstein
+would make him "disappear." The information, he told
+investigators, was his "insurance policy."
+He faces a maximum 20 years in prison when he is
+sentenced on June 18.
+jane_musgrave@pbpost.com
+@pbpcourts
+NOT
+
+
+Epstein paid three women $5.5 million to end underagesex lawsuits
+By Jane Musgrave
+Posted Oct 3, 2017 at 12:01 AM
+Updated Oct 4, 2017 at 12:46 AM
+Ending years of speculation about how much Palm Beach billionaire Jeffrey Epl
+paid young
+women who claimed he used them as sex toys, court documents filed last week show he shelled
+out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.
+Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the
+sex scandal, attorney
+said the politically-connected 64-year-old convicted sex
+offender paid more than $1 million to each of the three women
+represented.
+Identified in court papers only by their initials or pseudonyms because of the nature of the
+allegations and their youthful ages, L.M, was paid $1 million, E. W. $2 million and Jane Doe
+$2.5 million,
+said of the settlements he negotiated with Epstein to end the lawsuits.
+Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on
+the revelations, citing confidentiality agreements that were part of the settlements. For the
+same reason, he declined to say whether Epstein paid similar amounts to settle roughly two
+dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
+when some were as young as 14 years old.
+Attorney Jack Scarola, who is representing
+, said his client was compelled to divulge
+the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move
+on their part," he said.
+Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have
+likely come out. He says the information will help him undermine Epstein's claims that
+"ginned up" the allegations to help his former law partner, imprisoned and disbarred
+Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
+
+
+The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
+between Epstein and Rothstein, both billionaires.
+A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
+minor for prostitution, he sued Rothstein and
+1, claiming they trumped up the
+allegations of sexual molestation to perpetuate the Ponzi scheme.
+Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
+successful law firm by forging the names of federal judges and others to persuade investors he
+had negotiated settlements in lawsuits against high-profile people. Investors were told they
+could get a cut of the cash.
+One of the high-profile people Rothstein used to lure investors was Epstein, according to a
+lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the
+lawsuit, Rothstein told investors Epstein, a money manager, had ag
+to settle the lawsuits
+with the teens for $200 million — a claim Critton described as "a complete fabrication."
+After Epstein dropped the lawsuit in 2012, |
+turned the tables on him.
+accused
+Epstein of filing the lawsuit maliciously to punish him for representing the young women.
+Although |
+was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
+no evidence
+was involved in the Ponzi scheme. Federal prosecutors successfully
+charged other attorneys and members of the firm, but |
+was never implicated, Scarola
+said in the malicious prosecution lawsuit.
+The revelations about the money Epstein paid to three of the young woman came last week in
+documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
+Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
+trial, in part, because she claimed she has been unable to talk to her client since his estate on his
+private island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had
+no ability to communicate with Mr. Epstein," she said.
+
+
+Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge
+Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those
+victimized by the storm that hammered the Caribbean and roared through South Florida, he
+said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
+Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
+before the case goes to trial.
+Despite Scarola's insistence that|
+• had nothing to do with Rothstein's Ponzi scheme,
+Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's
+well-known friends, such as now President Donald Trump, former President Bill Clinton and
+illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
+"The Epstein cases were used to fleece money and defraud inyestors," she said.
+Edward's malicious prosecution case has been difficult for both sides because both Epstein and
+have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
+his Fifth Amendment right against self-incrimination when questioned by Scarola.
+has claimed that much of the information Epstein is seeking is protected by attorney-client
+privilege.
+The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit
+¡ against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated
+the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
+Epstein.
+Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
+plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court
+records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's
+agreement to settle lawsuits filed against him by dozens of his underage victims.
+
+
+Judge rules feds' agreement with
+Jeffrey Epstein pact violated teen
+victims' rights
+By Jane Musgrave
+Posted Sep 17, 2019 at 4:02 PM
+Updated Oct 8, 2019 at 12:31 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on February 22, 2019)
+'OPY
+Federal prosecutors violated the rights of Jeffrey Epl
+teenage victims by failing to reveal they had dropped plans
+to prosecute the billionaire on dozens of federal charges in
+connection with the girls' claims that he paid them for sex
+at his Palm Beach mansion, U,S. District Judge Kenneth
+Marra ruled on Thursday.
+In a blistering 33-page ruling, Marra meticulously and
+methodically detailed the numerous steps federal
+prosecutors took to hide the agreement from more than 40
+young women who claim Epstein paid them for sex when
+they were as young as 14.
+"While the government spent untold hours negotiating the
+terms and implications of the NPA with Epstein's attorneys,
+scant information was shared with the victims," Marra
+wrote. "Instead, the victims were told to be 'patient' while
+the investigation proceeded."
+By then, it was too late. A deal had already been cut with
+then-South Florida U.S. Attorney Alex Acosta and Epstein's
+attorneys to shelve a 52-page federal indictment against
+Epstein, a former math teacher turned money manager
+who counts Presidents Donald Trump and Bill Clinton
+among his friends.
+
+
+Prosecutors' failure to alert the young women about the
+deal violated the Crime Victims' Rights Act, Marra ruled.
+"At a bare minimum the (act) required the government to
+inform (the young women) that it intended to enter into an
+agreement not to prosecute Epstein," he wrote.
+Still, Marra said he wasn't second-guessing prosecutors'
+decision not to pursue Epstein on federal charges if he
+pleaded guilty to minor state prostitution charges and
+agreed to compensate his victims for the trauma he caused.
+"The court is not ruling that the decision not to prosecute
+was improper," Marra wrote. "The court is simply ruling
+that, under the facts of this case, there was a violation under
+the CVRA."
+Further, he made no decision about what the remedy
+should be. He gave prosecutors and attorneys representing
+the young women 15 days to meet to decide how to unravel
+the complex legal web that has been hanging over Epstein
+and his young victims for more than a decade.
+The chances an accord will be reached are slim, said
+attorney Jack Scarola, who is representing the two Jane
+Does who challenged the prosecutors' actions.
+Further, he said, there is no road map to follow. The
+lawsuit attorney
+filed on behalf of the two
+unidentified young women, claiming prosecutors violated
+the federal act, is unique, he said
+"We are treading on virgin ground, to use what is probably
+an inappropriate phrase in this situation," he said.
+Scarola said he and
+will ask that the nonprosecution agreement be thrown out. That would open
+the possibility that the long-shelved federal indictment
+could be dusted off and filed against the 66-year-old
+Epstein, who spends most of his time on a private island he
+owns in the U.S. Virgin Islands.
+
+
+"I don't see the government conceding to that remedy,"
+Scarola admitted. Further, he said, it is likely Epstein will be
+allowed to weigh in. Miami attorney Roy Black years ago
+filed papers asking to intervene on Epstein's behalf.
+The U.S. Attorney's Office said it wouldn't comment on
+Marra's ruling. Neither Black nor New York City attorney
+Jay Lefkowitz, who led efforts to bury the federal
+indictment, responded to emails or phone calls for
+comment. West Palm Beach attorney Jack Goldberger, who
+represents Epstein, also didn't respond.
+Scarola said it is likely Epstein's star-studded legal team will
+argue that Epstein fully complied with the terms of the
+agreement he made in 2007 with federal prosecutors and
+therefore the agreement can't be undone.
+As he promised, Epstein pleaded guilty in June 2008 to state
+charges of soliciting a minor for prostitution and soliciting
+prostitution. He served 13 months of an 18-month jail term
+in a vacant wing of the county stockade that he was allowed
+to leave 12 hours a day, six days week.
+Further, as agreed, he paid settlements to the young women
+who sued him. While the settlements were confidential,
+court records show he paid three women a total of $5.5
+million.
+In return, federal prosecutors held up their end of the
+bargain. Their investigation ceased.
+Having done all that prosecutors asked of him, Scarola said
+Epstein will make a simple argument: "You can't turn
+around and deprive me of the benefits I bargained for."
+However, Scarola said, using Marra's ruling, he will counter
+that the contract Epstein signed was illegal and therefore
+unenforceable.
+
+
+Even if Marra agrees to toss out the non-prosecution
+agreement, Scarola conceded that doesn't mean Epstein will
+face federal charges.
+"The contract can be set aside and the federal government
+can attempt to enter into the same agreement," he said.
+"Except the spotlight of public attention will be on them
+and the 40 victims will be able to explain to the court why
+this sweetheart deal should not be approved."
+Scarola said that prosecutors may have had good reason not
+to pursue Epstein. "There may be a reasonable explanation
+but we don't know what that reason may have been," he
+said.
+In court papers, federal prosecutors have said that many of
+the young women were afraid to cross the powerful,
+politically connected money manager and simply refused to
+testify against him.
+In other cases, they said, the women changed their stories.
+Jane Doe 2, who is trying to have the non-prosecution
+agreement thrown out, initially described Epstein as "an
+awesome man" and told prosecutors she hoped "nothing
+happens" to him. While she later agreed to testify against
+Epstein, prosecutors said they feared Epstein's attorneys
+would use her words to destroy her if she ever took the
+witness stand.
+Marra, however, said the young woman's comments didn't
+mean she wasn't entitled to know about the prosecutors'
+plans to drop the charges. "There is no dispute that Epstein
+sexually abused Jane Doe 2 while she was a minor," he
+wrote. "Therefore, regardless of her comments to the
+prosecutor, she was a victim."
+Before the case is finally resolved, Scarola predicted that "a
+lot of people are going to have to answer a lot of questions."
+
+
+In his ruling, Marra detailed what appeared to be a cozy
+relationship between Acosta, his line prosecutors and
+Epstein's team of lawyers. His phalanx of lawyers included
+noted Harvard law professor Alan Dershowitz and Kenneth
+Starr, the former U.S. solicitor general whose investigation
+led to the impeachment of President Clinton.
+Marra describes an October 2007 breakfast meeting
+between Acosta, who is now U.S. labor secretary, and
+Lefkowitz shortly after the non-prosecution agreement was
+inked.
+After the meeting, Lefkowitz sent Acosta a note thanking
+him for "the commitment you made to me during our
+October 12 meeting in which you assured me that your
+Office would not ... contact any of the identified
+individuals, potential witnesses, or potential civil claimants
+and their respective counsel in this matter,"
+Marra quoted an equally pleasant note then-Palm Beach
+County State Attorney Barry Krischer sent to Assistant U.S.
+Attorney
+Villafana, who was the lead prosecutor in
+Epstein's case. "Glad we could get this worked out for
+reasons I won't put in writing," Krischer wrote, shortly
+after the non-prosecution agreement was signed. "After this
+is resolved 1 would love to buy you a cup at Starbucks and
+have a conversation."
+Many of the notes that were exchanged dealt with
+prosecutors' and Epstein's lawyers' shared desire to keep the
+deal secret from Epstein's accusers. In a September email,
+Villafana asked Lefkowitz for guidance about what she
+should reveal. "And can we have a conference call to discuss
+what I may disclose to ... the girls regarding the
+Agreement," she asked.
+
+
+Such cooperation between prosecutors and defense
+attorneys is unusual, Marra said. "It was a deviation from
+the government's standard practice to negotiate with
+defense counsel about the extent of crime victim
+notifications," he wrote.
+Further, he noted, that when
+and his two young
+clients asked for information, they were repeatedly misled.
+"The CRVA was designed to protect victims' right and
+ensure their involvement in the criminal justice process,"
+Marra wrote. "When the government gives information to
+victims it cannot be misleading."
+Ultimately, the terms of the non-prosecution agreement
+were revealed only after
+and attorneys for the
+press successfully sued to
+make
+them
+1 publie.
+jmusgrave@pbpost.com
+@pbpcourts
+NOT A CERTIFIE
+
+
+76 / 278 - Tuesday, July 9, 2019
+Edition: Final
+Section: A Section
+Page: 1A
+Source: By Jane Musgrave, The Palm Beach Post
+Epstein indicted on sex charges
+Part-time Palm Beacher pleads not guilty to sex
+trafficking, conspiracy charges in federal court in
+Manhattan
+Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
+to charges accusing him of creating a vast network of girls as young as 14 that he exploited
+for his sexual pleasure at his homes in Palm Beach and Manhattan.
+The 66-year-old money manager's appearance in U.S. District Court in New York City
+capped more than a decade of recriminations by young women and their attorneys who
+claimed Epstein used his money and political influence to avoid federal prosecution.
+Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
+charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
+County Jail for 13 months more than a decade ago.
+However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
+shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
+prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
+now U.S. labor secretary.
+"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
+Berman said at a
+morning news conference. "And while the charged conduct is from a number of years ago, it
+is still profoundly important to many of the alleged victims, now young women. They
+deserve their day in court."
+At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
+keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
+commit sex trafficking. Epstein paid dozens of young women to give him nude massages
+that, for most, led to sex, he said.
+If convicted of exploiting dozens of young women, including many Palm Beach County girls
+who were students at
+Palm Beach High School, Epstein faces a maximum 45-year
+prison sentence.
+Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin
+Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few
+conditions that could keep Epstein from fleeing to a foreign country to evade prosecution.
+
+
+"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince
+Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former
+President Bill Clinton on his jet, dubbed the Lolita Express.
+Berman's hard-line stance was welcomed by young women who for years have been told that
+Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement,
+promising not to charge Epstein in federal court.
+Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning
+her into his sex slave and forcing her to have sex with others, including Dershowitz and
+Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she
+told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. /
+New York prosecutors were able to ignore the controversial nonprosecution agreement
+because it contained some significant fine print, said former federal Judge Paul Cassell, who
+for years has fought to get the agreement thrown out. It says only that no charges could be
+filed against Epstein in South Florida, he said.
+Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
+Florida," he said. "The Southern District of New York is not bound by that agreement and
+wasn't a signatory of it."
+That means the sordid allegations that have been leveled at Epstein for years are now part of
+a federal indictment.
+Contrary to Epstein's claims, he knew the women who came to his homes in New York and
+Palm Beach were minors because they told him their ages, according to the indictment.
+Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
+prosecutors added.
+As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while
+he was in New York so they would be available for sex once he returned to Palm Beach, the
+indictment says. The employees weren't named. They were identified only as "Employee-1,"
+"Employee-2" and "Employee-3."
+To ensure he had a steady stream of young girls, Epstein would turn some victims into
+recruiters. He would pay them to bring new girls to his home on El Brillo Way along the
+Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East
+Side.
+"This allowed Epstein to create an ever-expanding web of new victims," Berman said.
+In both New York and Palm Beach, the lurid operation was similar. Unidentified employees
+of Epstein's would escort the teens into a room. They were told to take off all or most of their
+clothes before giving the naked billionaire massages, according to the indictment.
+"Epstein would also typically masturbate during these encounters, ask victims to touch him
+while he masturbated, and touch victims' genitals with his hands or with sex toys," the
+indictment says.
+As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over
+his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture
+of Epstein's house in Palm Beach.
+While heartened that Epstein now faces serious criminal charges in New York, Cassell said
+he would continue to push a West Palm Beach-based federal judge to throw out the
+nonprosecution agreement that Acosta forged with Epstein's star-studded legal team.
+
+
+U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime
+Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
+Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
+Monday, explaining what action Marra should take to redress that wrong.
+Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
+victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's
+victims with attorneys
+and Jack Scarola.
+Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
+he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
+how and why the agreement was reached.
+"There's been no explanation as to how a deal like this could have been cut and how the
+federal government could have been involved in a conspiracy to violate federal law," Scarola
+said of his interest in continuing the legal battle over the nonprosecution agreement.
+When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
+prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
+Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He
+was also forced to register as a sex offender and settle civil lawsuits more than 30 young
+women filed against him.
+U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out
+how the agreement came to be."I am especially more interested in why Epstein got the deal
+he got," Frankel said. "We need to know why he was given such an easy sentence.
+While she has asked the House Oversight Committee to investigate Acosta, Frankel said she
+is not sure that will happen. "It just seems to me it was a travesty that this guy got off the
+way he did and, without pre-judging it, let's have a proper court case," Frankel said.
+Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State
+Attorney Barry Krischer refused to charge Epstein with serious crimes. Reiter took the
+information his officers had gathered from dozens of Epstein's victims to Acosta, believing
+he would prosecute Epstein. He didn't.
+Reiter said he was heartened that 13 years later, Epstein will finally face justice.
+"Thankfully, U. S. Attorney Berman and the other authorities in New York have the good
+judgment to investigate and prosecute Epstein in the way that should have occurred in
+Florida over a decade ago," Reiter said in a statement.
+And, Scarola said, there are signals that Berman's investigation is far from over.
+Berman declined to answer questions about whether others, such as Epstein's high-powered
+friends, would be charged. He brushed off questions about the significance that the
+investigation was being handled by the Public Corruption Unit.
+While agents on Saturday were arresting Epstein aboard his private jet at the Teterboro
+Airport in New Jersey after returning from Paris, other officers were searching his New York
+City townhouse. Agents seized nude photos of young girls who appeared to be minors,
+Berman said.
+He said his focus was on finding more women who were exploited and abused by Epstein.
+Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a
+finger at a photo of the convicted sex offender who was once described as "a man of
+mystery."
+
+
+"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,"
+Berman said. A special number, 1-800-CALLFBI, will link victims of authorities.
+Bill Sweeney, assistant director of the FBI's New York office, said after years of being
+ignored by federal agents, the victims' voices will be heard.
+"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said
+Turning to address Epstein's victims directly, he said: "Your bravery may empower others to
+speak out against crimes against them."
+jmusgrave@pbpost.com
+NOT A CERTIFIED COP
\ No newline at end of file
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+Case 9:08-cv-80119-KAM Document 423 Entered on FLSD Docket 11/20/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+AND MEMORANDUM IN SUPPORT THEREOF
+(AS TO CMA v. EPSTEIN AND
+08-CIV-80811)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order allowing him to attend mediation in the above-styled
+matter and as grounds set forth would state:
+The Court entered a no contact order which may apply to
+| [DE 238].
+Plaintiff's counsel and plaintiff,
+have no objection to Mr.
+Epstein attending deposition, mediation and obviously trial.
+3.
+Therefore, Defendant, Jeffrey Epstein, in an abundance of caution,
+requests that the court enter the attached proposed Agreed Order which shall not
+
+
+Case 9:08-cv-80119-KAM Document 423 Entered on FLSD Docket 11/20/2009 Page 2 of 4
+Page 2
+preclude him from attending Plaintiff
+trial of this case.
+deposition, mediation, or the
+Rule 7.1 Certification
+Defense counsel has spoken with Plaintiff's counsel and he has no objection to
+the entry of the proposed agreed order.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 20 day of _November_ 2009
+Respectfully submitted,
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 423 Entered on FLSD Docket 11/20/2009 Page 3 of 4
+Page 3
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos.
+08-80069, 08- Paul G. Cassell, Esq.
+80119, 08-80232,
+08-80380, 08-80381, Pro Hac Vice
+08-80993, 08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A
+801-585-6833 Fax
+2290 10* Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A.
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+Jack P.
+, Esg.
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+Searcy
+Denney
+Scarola Barnhart & 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+kezell@podhurst.com
+
+
+Case 9:08-cv-80119-KAM Document 423 Entered on FLSD Docket 11/20/2009 Page 4 of 4
+Page 4
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/deeab2c0e5b887741e778b08245dffad2a1dd81d934682e0b90d91f01abda4c4.md b/vision-fixhub/court-01/deeab2c0e5b887741e778b08245dffad2a1dd81d934682e0b90d91f01abda4c4.md
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@@ -0,0 +1,27 @@
+Case 9:08-cv-80994-KAM Document 6 Entered on FLSD Docket 10/08/2008 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80994-CIV-Marra
+JANE DOE No. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CERTIFICATION AND ORDER OF TRANSFER TO MAGISTRATE JUDGE
+This matter comes before the undersigned on an Order of Transfer to United States
+District Court Judge Kenneth A. Marra signed by United States District Court Judge Daniel T. I
+Hurley. (DE 5). The undersigned certifies that the above-styled case presently has no referred,
+fully briefed pending motions and is therefore ready to be transferred to Judge Marra's paired
+Magistrate Judge.
+The Clerk of Court shall hereby transfer the Magistrate Judge assignment for the instant
+case to United States Magistrate Judge Linnea R.
+DONE and ORDERED in
+in the Southern District of Florida.
+this _8 day of October, 2008, at West Palm Beach
+James M. Heaptens
+JAMES M. L
+UNITED STATES MAGISTRATE JUDGE
+Copies to:
+United States District Judge Kenneth A. Marra
+United States Magistrate Judge Linnea R.
+Counsel of Record
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diff --git a/vision-fixhub/court-01/deedb9d6eebadb0aaae89a6ba9d3632b6c465c9906bee8b995c59111ab41eab9.md b/vision-fixhub/court-01/deedb9d6eebadb0aaae89a6ba9d3632b6c465c9906bee8b995c59111ab41eab9.md
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@@ -0,0 +1,440 @@
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80736-CIV-MARRAJ
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+V.
+UNITED STATES OF AMERICA,
+Respondent.
+VICTIMS' RESPONSE TO GOVERNMENT'S "NOTICE TO COURT REGARDING
+ABSENCE OF NEED FOR EVIDENTIARY HEARING" AND MOTION FOR
+PRODUCTION OF NON-PROSECUTION AGREEMENT AND OF REPORT OF
+INTERVIEW
+COME NOW the Petitioners, Jane Doe #1 and Jane Doe #2 (the "victims"), by and
+through their undersigned attorneys to file this Response to the Government's document styled as
+"Notice to Court Regarding Absence of Need for Evidentiary Hearing" as follows:
+INTRODUCTION
+At the conclusion of the oral argument on the victims' petition, victims Jane Doe #1 and
+Jane Doe #2 joined the Government in expressing to the Court a desire to work out a set of
+stipulated facts regarding this case. Towards that end, the Government sent a proposed set of
+stipulated facts to the victims' counsel (Exhibit 1 to this pleading) and, in turn, the victims' sent
+a responsive letter raising concerns about some of the Government's proposed stipulated facts
+and suggesting some additions and modifications (Exhibit 2 to this pleading). The victims also
+requested copies of two relevant documents from the Government: (1) the Non-Prosecution
+1
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 2 of 16
+Agreement with defendant Epstein that is at the center of this litigation and (2) the FBI's report
+of interview concerning a meeting with Jane Doe #1. These requests were also made in several
+telephone conversations with the attorney for the Government. Remarkably, rather than respond
+to the victims' suggestions, the Government has now suddenly reversed course and filed a terse
+document claiming an "absence of a need" for an evidentiary hearing. If anything, however, the
+victims' discussions with the Government have made clear that the Court should not enter
+judgment for the Government but rather should enter immediate judgment for the victims that the
+Government violated their rights under the CVRA. The Court should then schedule a hearing to
+determine the proper remedy for the violation of the victims' rights.
+In particular, the Government now apparently admits that the Non-Prosecution
+Agreement it struck with Epstein in September 2007 contained an "express confidentiality
+provision." See Exhibit 1 to this pleading, Government's Proposed Stipulated Facts, at page 3,
+paragraph 6. Assuming that the Government honored its agreement with the defendant (a fact
+that the victims have proposed to stipulate to), the Government could not have "conferred" with
+the victims about the proposed arrangement over the next nine months because doing so would
+have violated its confidentiality obligations with the defendant. As a result, the Government
+plainly has not afforded the victims' their right to "confer" about the proposed arrangement under
+the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771(a)(5). In addition, the Government
+effectively misled the victims that it had reached a Non-Prosecution Agreement with Epstein,
+plainly violating the victims' rights to be treated with "fairness" under the CVRA, 18 U.S.C.
+§3771(a)(8). The Court should therefore find that the victims' rights have been violated.
+The Court should also order the Government to produce the Non-Prosecution Agreement
+2
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 3 of 16
+to the victims. The victims are entitled to know what disposition has been made in their case.
+Moreover, that Agreement purportedly contains provisions pertaining to the civil liability of
+Epstein for crimes he has committed against Jane Doe #1 and Jane Doe #2. Epstein obviously
+knows what those provisions are. The victims are entitled to see those provisions and the
+surrounding document as well.
+The Court should also order the Government to produce a report of interview with Jane
+Doe #1 from about October 26, 2007, during which the Government apparently claims that it
+discussed the plea arrangement with the victims.
+Finally, after these documents are produced to the victims and the Court enters judgment
+that the victims' rights have been violated, the Court should schedule a hearing to determine the
+appropriate remedy for the violations of the victims' rights.
+THE VICTIMS' PROFFERED FACTS
+The Government's latest submission takes the position that "after consideration" it is now
+unnecessary to hold an evidentiary hearing. The Government apparently believes that the Court
+could rule in its favor based on just two submitted undisputed facts. In taking this position, the
+Government apparently believes that there are no set of facts that could sustain judgment for the
+victims. To the contrary, however, the available facts require judgment for the victims that their
+rights under the CVRA have been violated.
+Having attempted to confer with the Government about the facts in this case, counsel for
+the victims respectfully submit the following - and more complete -- set of facts that, on
+information and belief, they could establish if given the opportunity to do so:
+In 2006, at the request of the Palm Beach Police Department, the Federal Bureau of
+3
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 4 of 16
+Investigation opened an investigation into allegations that Jeffrey Epstein had used facilities of
+interstate commerce to induce young girls between the ages of thirteen and seventeen to engage
+in prostitution (among other offenses). The case was presented to the United States Attorney's
+Office for the Southern District of Florida, which accepted the case for investigation. Jane Doe
+#1 and Jane Doe #2 were victims of sex crimes committed by Epstein while they were minors.
+The U.S. Attorney's Office's investigation soon revealed that Epstein had committed
+federal sex crimes against Jane Doe #1 and Jane Doe #2. This made Jane Doe #1 and Jane Doe
+#2 "victims" protected by the Crime Victim's Rights Act, 18 U.S.C. § 3771. Accordingly, the
+U.S. Attorney's Office arranged to have victim notification letters sent to Jane Doe #1 and Jane
+Doe #2. For example, on about June 7, 2007, Assistant U.S. Attorney A.
+Villafaña sent a
+letter to Jane Doe #1 that began: "Pursuant to the [CVRA], as a victim and/or witness of a federal
+offense, you have a number of rights." The letter then listed the various rights of victims under
+the CVRA. The U.S. Attorney's Office would not have sent such a letter to Jane Doe #1 if it did
+not believe that she was a victim and was protected by the CVRA.
+By mid-2007, the U.S. Attorney's Office had ample information to file an indictment
+against Epstein charging multiple federal sex offenses. It elected not to file an indictment but
+instead to engage in pre-indictment plea discussions with Epstein.
+In September 2007, Epstein and the U.S. Attorney's Office reached an agreement
+blocking any federal prosecution of the federal offenses he had committed. This Non-
+Prosecution Agreement barred federal charges for Epstein's sex offenses in favor of prosecution
+by Florida, so long as several preconditions were met. Those included a conviction on a state
+sex offense that reflected that the victims were minors at the time the crimes occurred and that
+4
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 5 of 16
+would require sex offender registration. While the Agreement barred federal criminal
+prosecution, it envisioned that the victims would pursue a civil rights action against Epstein for
+his sexual offenses against them. Most important for present purposes, the Agreement contained
+an express confidentiality provision, which prevented the Government from disclosing the terms
+of the Agreement to the victims or others before it was consummated. The Agreement was
+subsequently modified in October and December 2007. The Agreement has several addenda that
+are relevant to the Agreement. (To date, although requested to do so, the Government has
+refused to provide to the victims the final Non-Prosecution Agreement or any of its earlier
+versions.) Through his attorneys, Epstein was aware of the confidentiality provision and of the
+fact that it would block the Government from conferring with the victims about the plea
+arrangement.
+On about October 26, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason
+Richards met in person with Jane Doe #1 at a restaurant. The Special Agents explained that there
+had been discussions with Epstein about a possible resolution of the charges against him.
+Consistent with the express confidentiality provision in the Non-Prosecution Agreement, the
+Special Agents did not disclose that the arrangement would bar any federal prosecution of
+Epstein. Nor did the Agents disclose that the Non-Prosecution Agreement had been finalized.
+Jane Doe #1's reasonable perception of the meeting was that only the State part of the Epstein
+investigation had been resolved, and that the federal investigation would continue, possibly
+leading to a federal prosecution. (While the Government has a report of interview regarding this
+meeting with the victim that could confirm the victims' understanding of the facts, the
+Government has refused Jane Doe #1's request to see the report.)
+5
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 6 of 16
+Following the signing of the Non-Prosecution Agreement and the modifications thereto
+by the U.S. Attorney's Office for the Southern District of Florida, Epstein received an unusual
+benefit that the Government does not ordinarily provide to other criminal defendants: his
+performance was delayed while he was given an opportunity to seek higher level review within
+the Department of Justice in Washington, D.C.
+On around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI
+advising them that "[this case is currently under investigation. This can be a lengthy process
+and we request you continued patience while we conduct a thorough investigation." The FBI
+sent these letters, under the direction of the U.S. Attorney's Office, because it believed that the
+CVRA applied to Jane Doe #1 and Jane Doe #2. The FBI did not notify Jane Doe #1 or Jane
+Doe #2 that the Non-Prosecution Agreement had been concluded four months earlier. Jane Doe
+#1 and Jane Doe #2 reasonably understood that a federal criminal investigation of Epstein was
+on-going and that federal criminal charges were possibility. At the time, Jane Doe #1 and Jane
+Doe #2 believed that criminal prosecution of Epstein was extremely important. They also
+desired to be consulted by the FBI and/or other representatives of the federal government about
+the prosecution of Epstein. In light of the letters that they had received around January 10
+(among other things), they reasonably believed that they would be contacted before the federal
+government reached any final resolution of that investigation.
+In the spring 2008, Jane Doe #1 contacted the FBI because Epstein's counsel was
+attempting to take her deposition and private investigators were harassing her. Assistant U.S.
+Attorney A.
+Villafaña secured pro bono counsel to represent Jane Doe #1 and several other
+identified victims in connection with the criminal investigation. Pro bono counsel was able to
+6
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 7 of 16
+assist Jane Doe #1 in avoiding the improper deposition. AUSA Villafaña secured pro bono
+counsel by contacting Meg Garvin, Esq. of the National Crime Victims' Law Institute in
+Portland, Oregon, which is based in the !
+& Clark College of Law. During the call, Ms.
+Garvin was not advised about the Non-Prosecution Agreement.
+In mid-June 2008, Mr.
+| contacted Assistant U.S. Attorney Villafaña to inform her
+that he represented Jane Doe #1 and, later, Jane Doe #2. Mr. |
+asked to meet to provide
+information about the federal crimes committed by Epstein, hoping to secure a significant federal
+indictment against Epstein. AUSA Villafaña and Mr.
+discussed the possibility of federal
+charges being filed. At the end of the call, AUSA Villafaña asked Mr.
+to send any
+information that he wanted considered by the U.S. Attorney's Office in determining whether to
+file federal charges. Because of the confidentiality provision in the Non-Prosecution Agreement,
+Mr.
+was not informed of the Agreement's existence. Mr.
+was also not
+informed that any resolution of the criminal matter was imminent.
+On July 3, 2008, Mr.
+sent to AUSA Villafaña a letter, a true and correct copy of
+which is attached as Exhibit 3. In the letter, Mr.
+indicated his desire that federal
+charges be filed against defendant Epstein. In particular, he wrote on behalf of his clients: "We
+urge the Attorney General and our United States Attorney to consider the fundamental import of
+the vigorous enforcement of our Federal laws. We urge you to move forward with the traditional
+indictments and criminal prosecution commensurate with the crimes Mr. Epstein has committed,
+and we further urge you to take the steps necessary to protect our children from this very
+dangerous sexual predator." When Mr.
+wrote this letter, he still had not been made
+aware that a Non-Prosecution Agreement had been reached with Epstein.
+7
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 8 of 16
+On about July 3, 2008, Jane Doe #1 and Jane Doe #2 learned, through telephones
+conversations had between Mr.
+and AUSA Villafaña, that the U.S. Attorney's Office
+and Epstein might be in the process of finalizing some sort of plea arrangement. Accordingly,
+they filed an emergency motion seeking to protect their rights under the CVRA, including in
+particular their right to confer about the proposed plea arrangement.
+Mr.
+- and thus his clients -- first learned of the Non-Prosecution Agreement on
+or after July 9, 2008, when the Government filed its responsive pleading to Jane Doe's
+emergency petition. That pleading was the first public mention of the non-prosecution agreement
+and the first disclosure to Mr.
+i and his clients. Epstein, through his attorneys, knew that
+the victims had not been informed about the plea arrangement.
+On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her
+attorney, Mr.
+, which is attached as Exhibit 6 to the Villafaña Declaration. That
+notification contains a written explanation of some of the terms of the Non-Prosecution
+Agreement between Epstein and the U.S. Attorney's Office. A full copy of the terms was not
+provided. This was the first time that Jane Doe #1 was told that the arrangement blocked any
+possibility of federal criminal charges being filed against Epstein. A notification was not
+provided to Jane Doe #2 because the agreement limited Epstein's liability to victims whom the
+United States was prepared to name in an indictment.
+On July 11, 2008, the Court held a hearing on the victims' emergency motion. During the
+hearing, the Government discussed in open court various provisions of the Non-Prosecution
+Agreement. At the conclusion of the hearing, victims' counsel and the Government agreed to
+8
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 9 of 16
+confer in an effort to determine the undisputed facts of the fact. The Court took the motion under
+advisement.
+On July 16, 2008, the Government sent to Mr.
+a proposed set of undisputed
+facts, which is attached to this pleading as Exhibit 1.
+On July 17, 2008, Mr.
+sent a response to the Government, which is attached to
+this pleading as Exhibit 2. The response made various suggestions to the proposed undisputed
+facts. The response also requested a copy of the Non-Prosecution Agreement and the Report of
+Interview with Jane Doe #1.
+On July 29, 2008, rather than attempt to work with victims' counsel to draft a set of
+undisputed facts, the Government filed its "Notice to Court Regarding Absence of Need for
+Evidentiary Hearing."
+At all times material to this statement of facts, it would have been easily practical and
+feasible for the Federal Government to inform Jane Doe #1 and Jane Doe #2 of the details of any
+proposed plea agreement with Epstein, including in particular the details of the Non-Prosecution
+Agreement. The reason that AUSA Villafaña and the FBI agents acting with her did not provide
+this information to Jane Doe #1 and Jane Doe #2 was because of the express confidentiality
+provision that had been entered into by the Federal Government and Epstein. This provision
+was requested by Epstein.
+The Government was under no obligation to enter into such an
+arrangement and would have been statutorily forbidden from entering into such an arrangement
+by the CVRA's requirement that it "confer" with the victims about any disposition of their cases.
+9
+
+
+Case 9:08-Cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 10 of 16
+THE GOVERNMENT SHOULD BE DIRECTED TO CONFER WITH THE VICTIMS
+REGARDING THE UNDISPUTED FACTS OF THE CASE
+The Government should be directed to confer with the victims about the facts in this case,
+rather than allowed to obscure the facts with its proposed "notice" that an evidentiary hearing is
+unnecessary. The reason that the Government abruptly terminated discussions about the facts
+with the victims seem obvious: The facts, if revealed, would plainly demonstrate that the victims
+did not receive their right under the CVRA to confer with the Government and to be treated
+fairly. The victims will not repeat all of their arguments from their earlier pleadings but would
+simply highlight for the Court the point that this case already reeks of favored treatment for a
+billionaire sex offender who has substantial influence. Regardless of how the Court proceeds, it
+should at least do so on the basis of fully developed factual record so that the victims and the
+public can be assured that justice has been done.
+If anything, the facts in this case now call for immediate judgment in favor of the victims.
+Based on the Government's proposed stipulated facts (Exhibit 1 to this pleading), it is now
+obvious that the Government could not have fulfilled its statutory obligations to confer with the
+victims. As now admitted by the Government, in September 2007, it had entered into a Non-
+Prosecution Agreement with Epstein containing what it describes as "an express confidentiality
+provision." While the Government has refused to disclose the text of this provision (or, indeed,
+the Non-Prosecution Agreement itself), it is apparent that the Government could not have
+conferred with the victims about the Agreement while abiding by the confidentiality provision.
+Likewise it is now apparent that the Government has not fulfilled its statutory obligation
+to treat the victims with fairness. The Government reached the Non-Prosecution Agreement with
+10
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 11 of 16
+Epstein in September 2007, yet affirmatively concealed that Agreement from the victims through
+a series of misleading statements and representations over the next nine months. For example,
+on around January 10, 2008, Jane Doe #1 and Jane Doe #2 received letters from the FBI advising
+them that "[Jhis case is currently under investigation. This can be a lengthy process and we
+request your continued patience while we conduct a thorough investigation." As the Government
+well knew, however, a Non-Prosecution Agreement had already been reached with Epstein at that
+time - a fact not disclosed in the letter.
+The victims therefore request judgment in their favor that their rights under the CVRA
+have been violated. In the alternative, the victims request that the Court direct that the
+Government confer in good faith with the victims to attempt to reach a set of stipulated facts that
+might form the basis for a final ruling in this case. As part of this conference, the victims request
+that the Government indicate which (if any) of the proposed facts set forth above it disputes.
+THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE
+THE NON-PROSECUTION AGREEMENT
+Remarkably, the Government has yet to disclose to the victims the very Non-Prosecution
+Agreement that lies at the heart of this case. This failure becomes even more curious when
+assessed against the Government's proposed stipulation of facts, which included the proposed
+fact that the victims had been told about the "full terms" of the Agreement. The proposed
+stipulated facts that the Government sent to the victims included this proposed stipulation:
+On July 9, 2008, AUSA Villafaña sent a victim notification to Jane Doe #1 via her
+Declaration. That notification contains a written explanation of the fill terms of
+which is attached as Exhibit 6 to the Villafaña
+the agreement between Epstein and the U.S. Attorney's Office.
+Contrary to its own proposed stipulation, the Government has never disclosed to the victims the
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 12 of 16
+"full terms" of its Non-Prosecution Agreement with Epstein. To protect the victims' right to be
+treated with fairness, 18 U.S.C. § 3771(a)(8), it should be required to do so now.
+Congress' main concern in passing the CVRA was that crime victims were "treated as
+non-participants in a critical event in their lives. They were kept in the dark by prosecutors too
+busy to care enough ... and by a court system that simply did not have a place for them." 150
+CONG. REC. S4262 (Apr. 22, 2004) (statement of Sen. Feinstein). To remedy this problem,
+Congress gave victims "the simple right to know what is going on, to participate in the process
+where the information that victims and their families can provide may be material and relevant...
+" Id. To date, Jane Doe #1 and Jane Doe #2 do not know what has happened to their case,
+because they have not been told how it has been resolved. Of course, no possible harm to the
+Government can come from the release of the Agreement, as this criminal matter is now
+concluded - at least from the Government's perspective.
+Production of the Non-Prosecution Agreement is also warranted because it has provisions
+in it that are designed to benefit Jane Doe #1 and Jane Doe #2. As described by the Government,
+the Agreement contains provisions in it that preclude Epstein from contesting civil liability for
+the sex offenses committed against a number of the victims, including Jane Doe #1. Obviously,
+Jane Doe #1 cannot take advantage of this provision if her attorneys are not able to review it.
+Jane Doe #1 and Jane Doe #2 intend to file civil suits against Epstein within the next few days.
+Epstein knows what is in the Non-Prosecution Agreement that may be helpful to him. Jane Doe
+#1 and Jane Doe #2 are entitled to see the Agreement for items that may be helpful to them.
+Finally, Epstein is apparently taking advantage of provisions in the Non-Prosecution
+Agreement to stall civil suits against him. For example, in Jane Doe v. Epstein et al., No. 08-
+12
+
+
+Case 9:08-Cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 13 of 16
+80804-MARRA
+(S.D. Fla. 2008), on July 25, 2008, Epstein filed a motion for a stay.
+That motion claims that the civil action is "a counterpart to a pending federal criminal action."
+The basis for that claim, so far as Jane Doe #1 and Jane Doe #2 can tell, is the federal Non-
+Prosecution Agreement. Epstein should not be permitted to use provisions in the Agreement to
+his advantage in private litigation without disclosing those provisions to the parties he is
+opposing.
+Indeed, as a simple matter of fairness to the victims, see 18 U.S.C. § 3771(a)(5)
+(victims right to "fairness"), the provisions should be disclosed.
+In sum, the Court should direct the Government to reveal to the victims what it has done
+to resolve the case by ordering production of the full Non-Prosecution Agreement and any
+accompanying addenda to the agreement.
+THE GOVERNMENT SHOULD BE REQUIRED TO PRODUCE THE REPORT OF
+INTERVIEW WITH JANE DOE #1
+The Government apparently has a report of interview indicating that two named FBI
+agents met with Jane Doe #1 on about October 26, 2007. The Government, however, has
+declined to produce it.
+The Government should be directed to produce this information to Jane Doe #1. Of
+course, a criminal defendant would be entitled to such a report. See Fed. R. Crim. P. 16(a)(1)(A)
+& (B). As an innocent victim in this matter, Jane Doe #1 should be treated with at least the same
+consideration. See 18 U.S.C. § 3771(a)(8) (victim's right to "be treated with fairness"). Jane
+Doe #1 requested this report in her letter regarding the proposed stipulated facts (see Exhibit 2 to
+this filing), a request that the Government has simply ignored.
+13
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 14 of 16
+AFTER ENTERING JUDGMENT FOR THE VICTIMS' ON THE VIOLATION OF THEIR
+RIGHTS, THE COURT SHOULD SCHEDULE A HEARING ON THE APPROPRIATE
+REMEDY
+For the reasons just explained, the Court should enter judgment for Jane Doe #1 and Jane
+Doe #2 on the violations of their rights under the CVRA and order the Government to produce
+the Non-Prosecution Agreement and the report of interview with Jane Doe #1. After doing that,
+the question then arises as to what is the proper remedy for the violations of victims' rights.
+To be clear, at this time, the victims seek two things: (1) a judicial declaration that the
+Government violated their rights under the CVRA and an apology from the Government; and (2)
+a hearing to discuss the appropriate remedy under the circumstances. At the same time, the
+victims are not asking to have any provision in the Non-Prosecution Agreement establishing
+liability in a civil suit to be vacated or declared invalid. Because the possible connection
+between these two things raises complex legal issues, the victims respectfully request that the
+Court order a hearing at which the appropriate remedy can be discussed. The victims also need
+to review the full text of the Non-Prosecution Agreement and any accompanying addenda to
+make an appropriate determination about the remedy that they wish to pursue.
+CONCLUSION
+The Court should find that the Government violated Jane Doe #1 and Jane Doe #2's
+rights under the CVRA to confer and to be treated with fairness during the negotiation and
+consummation of the Non-Prosecution Agreement. In the alternative, the Court should direct the
+Government to confer with the victims regarding what facts are undisputed in this matter and,
+should material facts actually be disputed, hold an evidentiary hearing regarding those facts. So
+that the victims can discuss these matters with the Government, the Court should order the
+14
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 15 of 16
+Government to provide to the victims the full Non-Prosecution Agreement (and accompanying
+addenda) that is central to this litigation as well as a report of interview with Jane Doe #1 from
+about October 26, 2007. The Court should then hold a hearing on the proper remedy for the
+violations of the victims' rights.
+DATED this 1st day of August, 2008.
+By:
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD M&
+ASSOCIATES, LLC
+s/ Brad
+Esquire
+Attorney for Petitioners
+Florida Bar No. 542075
+HI Street
+Hollywood, Florida 33020
+Telephone: 954-414-8033
+Facsimile:
+954-924-1530
+E-Mail:
+be@bradedwardslaw.com
+Paul G. Cassell
+Attorney for Petitioners
+Pro Hac Vice
+332 S. 1400 E
+Salt Lake City, UT 84112
+Telephone:
+801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+15
+
+
+Case 9:08-cv-80736-KAM Document 19 Entered on FLSD Docket 08/01/2008 Page 16 of 16
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on August 1, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Brad F
+Brad I
+I Esquire
+Attorney for Petitioner
+Florida Bar No. 542075
+SERVICE LIST
+Jane Doe 1 and Jane Doe 2
+Case No.: 08-80736-CIV-MARRA/J)
+United States District Court, Southern District of Florida
+Dexter A. Lee,
+Assistant U.S. Attorney
+99 N.E. 4th Street
+Miami, Florida 33132
+Telephone:
+305-961-9320
+305-530-7139
+16
diff --git a/vision-fixhub/court-01/deedb9d6eebadb0aaae89a6ba9d3632b6c465c9906bee8b995c59111ab41eab9.receipt.json b/vision-fixhub/court-01/deedb9d6eebadb0aaae89a6ba9d3632b6c465c9906bee8b995c59111ab41eab9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8a4f4628a6a96cb0543a6ab0a7ed76799c33589e
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/def78ff7e3fdc573f627942413384b7d7ad32441f94843c075c89e66101a2834.md b/vision-fixhub/court-01/def78ff7e3fdc573f627942413384b7d7ad32441f94843c075c89e66101a2834.md
new file mode 100644
index 0000000000000000000000000000000000000000..b4ade301c40e4338047c46acec775a3fabfde7cf
--- /dev/null
+++ b/vision-fixhub/court-01/def78ff7e3fdc573f627942413384b7d7ad32441f94843c075c89e66101a2834.md
@@ -0,0 +1,234 @@
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 1 of 9
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+- 1-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 2 of 9
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA
+JANE DOE NO. 7,
+CASE NO.: 08- 80993-CIV-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' MEMORANDUM IN OPPOSITION
+TO MOTION TO STAY AND OR CONTINUE ACTION
+Plaintiffs, JANE DOES 2-7, by and through undersigned counsel, file this Memorandum in
+Opposition to Stay and or Continue Action, as follows:
+I.
+Introduction
+In moving for stay, Defendant has the burden of demonstrating that, due to a parallel criminal
+proceeding, if he exercises his right against self incrimination he will certainly lose on summary
+judgment unless a stay is granted. Defendant has failed to satisfy this burden. There is no pending
+motion for summary judgment.
+There is also no criminal proceeding at this time arising from
+Epstein's acts against the Plaintiffs or other victims. Indeed, whether such a criminal proceeding is
+ever commenced is entirely within the Defendant's control, by complying with the terms of his
+Non-Prosecution Agreement with the U.S. Attorney's Office. Defendant relies upon an amorphous
+- 2-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 3 of 9
+possible breach of his Non-Prosecution Agreement with the U.S. Attorney, which does not give rise
+to the "special circumstances" necessary to warrant a stay. Finally, even if there were grounds for a
+stay, it would not be appropriate in these cases because Plaintiffs would be severely prejudiced by
+the delay occasioned by a stay.'
+II. Argument
+A.
+Defendant Has Not Demonstrated that He Faces a Certain
+Loss on Summary Judgment If a Stay Is Not Granted
+The Constitution doe not require a stay of civil proceedings pending the outcome of criminal
+proceedings involving a common defendant. Shell Oil Co. v. Altina Associates, Inc.., 866 F.Supp.
+536, 540 (M.D. Fla. 1994). A stay pending resolution of related criminal proceedings is warranted
+only when the defendant demonstrates that ""special circumstances" so require in the 'interests of
+justice.' " United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994).
+In the Eleventh Circuit, the "special circumstances" which may support a stay are limited.
+The fact that the Defendant may "risk a non-criminal disadvantage by remaining silent for fear of
+self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional
+infringement." Shell Oil, 866 F.Supp. at 540. Accordingly, the Defendant's right to silence is not
+a basis to stay the civil case pending resolution of a criminal action. Id. There is one exception
+applicable where a stay would be necessary to prevent an unconstitutional infringement of the
+' Defendant Epstein filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08-
+CIV 80893 MARRA/
+Plaintiffs concur in the arguments made by Jane Doe's counsel in
+that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same
+reasoning and arguments apply in the instant cases. Plaintiffs in this Memorandum will attempt to
+stream line and limit its arguments to avoid unnecessary repetition and duplication with the response
+in Jane Doe.
+" In this regard, The Defendant's silence by invoking the Fifth Amendment does not prohibit adverse
+inferences against him in the civil case. Shell Oil, 866 F.Supp. at 40.
+- 3-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 4 of 9
+defendant's right against self incrimination: "IT]he law in the Eleventh Circuit requires
+consideration of whether, as a result of invoking the privilege, the defendant faces certain loss of the
+civil proceeding on summary judgment if the civil proceeding were to continue." In re Financial
+Federation Title & Trust, Inc.., 252 B.R. 834, 837 (Bankr. S.D. Fla. 2000) (citing United States v.
+Lot 5. 23 F.3d at 364); accord Shell Oil, 866 F.Supp. at 540 (noting that there is a "recognized
+exception to this general rule: the Fifth Amendment is violated when a person, who is a defendant in
+both a civil and criminal case, is forced to choose between waiving his privilege against selfincrimination or losing the civil case in [summary proceedings]").
+The cases relied upon by Defendant are consistent with these authorities. In Ventura v.
+Brosky, 2006 WL 3392207 (S.D. Fla. 2006), the Court stated the rule that a stay is warranted to
+avoid a situation "where a defendant in both criminal and civil proceedings must choose between
+whether to waive his privilege against self-incrimination or to lose the civil case in summary or
+default judgment proceedings." Id. at *1. Moreover, the stay in Ventura was granted on motion of
+the defendant Miami-Dade County Police Department because it would be prejudiced by its
+codefendant, a former police officer, asserting the Fifth Amendment and refusing to answer 'in
+response to the civil Complaint and any discovery directed at him in the case." Id. Such concerns
+involving prejudice to a codefendant are not present here. In Securities and Exchange Comm'n v.
+Rehtorik, 755 F.Supp. 1018 (S.D. Fla. 1990), another case relied upon by Defendant, the Court
+denied a stay of the case, and made clear in its holding that the defendant had not demonstrated that
+it would be subject to "automatic liability" on a motion for summary judgment:
+The Court in Financial Federation Title & Trust noted that the standard in the Eleventh Circuit
+is "more narrow and less subjective" than in other Circuits where a multi-factor test is used. Id.
+at 837.
+- 4-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 5 of 9
+The defendants can exercise their Fifth Amendment rights in the face
+of the S.E.C.'s summary judgment motion by not presenting evidence
+which would implicate them in the alleged securities fraud. Though
+an adverse inference may be drawn due to their silence, the S.E.C.
+must still carry its burden of proving fraud committed by the
+defendants; their silence alone will not give rise to automatic liability.
+As such, the defendants would not be compelled to speak. To speak
+or not to speak becomes, in such a case, a question of strategy rather
+than one of unconstitutional compulsion.
+Id. at 1020.
+Accordingly, the Defendant's Motion to Stay is, at best, premature. Defendant Epstein fails
+to demonstrate that he is certain to lose on summary judgment if he exercises his constitutional right
+against self-incrimination. Indeed, there is no summary judgment motion pending. Defendant's
+Motion to Stay must accordingly be denied.
+This Court Has Previously Made It Clear That a Stay is
+Not Warranted, and Circumstances Have Not Changed
+Defendant previously moved for a mandatory stay pursuant to 18 U.S.C. §3509(k). This
+Court denied that Motion on the grounds that there was no criminal action pending, a requirement
+for a stay under §3509(k). (DE 33). The Court in its Opinion also stated that a discretionary stay
+was not warranted:
+it is up to him (and him alone) whether the plea agreement reached
+with the State of Florida is breached. If Defendant does not breach
+the agreement, then he should have no concerns regarding his Fifth
+Amendment right against self-incrimination. The fact that the U.S.
+Attorney (or other law enforcement officials) may object to some
+discovery in these civil cases is not, in an of itself, a reason to stay
+the civil action. Any such issues shall be resolved as they arise in the
+course of this litigation.
+(Order Denying Motion to Stay, p. 4). In again seeking a stay, Defendant seized on the last sentence
+- 5-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 6 of 9
+quoted above and takes it out of context in contending that the time is now ripe for a stay. The Court
+stated that issues arising in the event that the U.S. Attorney or other law enforcement officials object
+to discovery can be resolved during the course of the litigation. (DE 33, p. 4). The Court was not
+inviting the Defendant to file another motion for stay later in the course of discovery. In any event,
+there are no changed circumstances which would warrant a different analysis and conclusion from
+that reached by the Court last August.
+C.
+The Defendant Cannot Meet His Burden of Demonstrating Grounds
+for a Stay on the Basis of Vague Assertions of the Position of the USAO
+There is no criminal prosecution pending for the acts of Epstein against any of the Plaintiffs
+in these civil cases. Epstein's Motion thus fails at the outset because there is no parallel criminal
+action.* In any event, the Defendant vaguely asserts, without supporting documentation, that the
+"USAO has already attempted to claim violations of the Non-Prosecution Agreement." (Motion to
+Stay (DE 57), p. 2). The Defendant submits the Affidavit of his criminal attorney, Jack Goldberger,
+who asserts that "the USAO has taken the position on a number of occasions that it might consider"
+various actions by Epstein to be a breach of the Non-Prosecution Agreement. Nowhere does the
+Motion or this supporting Affidavit assert that the USAO has declared a breach of the Non-
+Prosecution Agreement, nor does it indicate that the issue of breach has been raised by either party
+in any court. It is therefore difficult to understand how this can be grounds for a stay. Defendant
+does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at
+best, premature.
+D.
+Plaintiffs Would Be Prejudiced by a Stay
+*The cases discussing the stay issues are premised on a pending criminal action parallel to the civil
+proceeding. See, e.g., Rehtorik, 755 F.Supp. at 1019-1020; United States v. Lot 5, 23 F.3d at 364
+(quoting United States v. Little Al, 712 F.2d 133, 136 (5th Cir. 1983)).
+- 6-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 7 of 9
+Because Defendant has failed to set forth circumstances that would support a stay, there is no
+need to proceed further. Nonetheless, Plaintiffs note that they will be severely prejudiced if a stay is
+granted. First, the stay requested is a lengthy one, to the end of 2010. Such a delay is simply unfair
+to the Plaintiffs, who are entitled to civil remedies for the wrongs that were committed by Epstein.
+Additionally, the delay in discovery will be prejudicial to Plaintiffs. Investigation and
+discovery will become more difficult with the passage of time. The bulk of the allegations occurred
+in 2004-05, when the Plaintiffs were minors. Plaintiffs should not have to wait to engage in
+discovery. Finally, the delay occasioned by a stay would prejudice these Plaintiffs vis-à-vis other
+victims of Epstein who brought their claims in state court and would not be stayed, particularly if
+these other victims recover punitive damage judgments against Epstein before Plaintiffs have even
+had an opportunity to litigate their claims.
+Conclusion
+Based on the foregoing, Plaintiffs respectfully request that Defendant's Motions to Stay
+and/or Continue Action be denied in their entirety.
+Dated: April 23, 2009
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 7-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 8 of 9
+CERTIFICATE OF SERVICE
+I hereby certify that on April 23, 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+- 8-
+
+
+Case 9:08-cv-80994-KAM Document 30 Entered on FLSD Docket 04/23/2009 Page 9 of 9
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Stuart S. Mermelstein
+- 9 -
diff --git a/vision-fixhub/court-01/def78ff7e3fdc573f627942413384b7d7ad32441f94843c075c89e66101a2834.receipt.json b/vision-fixhub/court-01/def78ff7e3fdc573f627942413384b7d7ad32441f94843c075c89e66101a2834.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..da6e03c5819b5f4eac104236beee54106a1f5325
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diff --git a/vision-fixhub/court-01/df0ddfc98f56914fb22d5c535d114f993c7abede87b05f1bca744f2247e8c355.md b/vision-fixhub/court-01/df0ddfc98f56914fb22d5c535d114f993c7abede87b05f1bca744f2247e8c355.md
new file mode 100644
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@@ -0,0 +1,115 @@
+Case 9:09-cv-80656-KAM Document 20 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/C_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80656-KAM Document 20 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:09-cv-80656-KAM Document 20 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:09-cv-80656-KAM Document 20 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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diff --git a/vision-fixhub/court-01/df585cfd4b6845f3b852e296cf8cce5b87d39a1069ebad5ef4b086611f01f2bc.md b/vision-fixhub/court-01/df585cfd4b6845f3b852e296cf8cce5b87d39a1069ebad5ef4b086611f01f2bc.md
new file mode 100644
index 0000000000000000000000000000000000000000..f32a26453df3efdec946ae560d3ad986924eb1f0
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+++ b/vision-fixhub/court-01/df585cfd4b6845f3b852e296cf8cce5b87d39a1069ebad5ef4b086611f01f2bc.md
@@ -0,0 +1,436 @@
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 1 of 7
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+26
+28
+JANE DOE,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Case No._1:20-cv-00484
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+MEMORANDUM IN
+SUPPORT OF PLAINTIFF'S
+MOTION TO PROCEED BY
+PSEUDONYM
+Plaintiff Jane Doe ("Plaintiff"), by her undersigned attorneys, respectfully submits this
+memorandum of law in support of her motion for leave to proceed under a pseudonym.
+I.
+INTRODUCTION
+Plaintiff Jane Doe suffered tremendous harm as a result of being sexually abused as a child
+by the late Jeffrey Epstein. Epstein and his associates, in particular, Ghislaine Maxwell, coerced
+Jane Doe into becoming their sexual puppet for years through power, money and exploitation.
+And like countless others, Plaintiff was victimized for so long by Epstein and Maxwell and at such
+an early age that she has done everything she could to remain anonymous and live a normal life
+now despite constant media requests for interviews and statements.
+The details underlying Plaintiff's sexual abuse are highly personal, intimate and
+humiliating to Plaintiff. Jane Doe has suffered drastically due to the Defendants' actions. Keeping
+her identity protected from public disclosure in this already high-profile matter is imperative.
+Indeed, public disclosure of her name in this litigation will expose some of the most intimate and
+humiliating moments of Plaintiff's life, furthering her ongoing psychological harm and injuring
+her family, including young children.
+Additionally, there is no public interest in revealing the identity of one of Epstein's many
+victims; to the contrary, allowing Plaintiff to proceed by pseudonym fosters the public interest in
+having victims come forward. Further, as other victims have already stated, revealing Plaintiff's
+1
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 2 of 7
+1
+identity could interfere with the Government's ongoing investigation of Epstein's associates.
+2
+For the foregoing reasons and those that follow, Plaintiff Jane Doe respectfully
+3
+requests that this Court permit her to proceed in this case under a pseudonym.
+4
+II.
+ARGUMENT
+5
+The Federal Rules of Civil Procedure do not explicitly authorize, nor absolutely prohibit,
+6
+the use of fictitious names by plaintiffs or other parties. In EW v. New York Blook Ctr., 213
+7
+F.R.D. 108 (2d Cir. 2003), the Second Circuit declared, "[a] plaintiff is entitled to proceed under a
+8
+pseudonym where revealing the plaintiff's name subjects him or her to the risk of public
+9 disapproval, harassment, or bodily harm."
+10
+11
+12
+In Does I Thru XXIII v. Advanced Textile Corp. 214 FR.3d 1058 (9th Cir. 2000), the Ninth
+Circuit held that "a party may preserve his or her anonymity in judicial proceedings in special
+circumstances when the party's need for anonymity outweighs prejudice to the opposing party and
+13
+the public's interest in knowing the party's identity." Id. at 1067. The Second Circuit has endorsed
+14
+this balancing of interests when determining whether a plaintiff may act under a pseudonym.
+15
+Sealed Plaintiff v. Sealed Defendant #1, 537 F.3d 189 (2d Cir. 2008). The Second Circuit has
+16
+gathered a non-exhaustive list of factors to consider when determining the need for anonymity.
+17
+This list of factors includes:
+18
+"(1) whether the litigation involves matters that are highly sensitive and of a personal
+19
+nature; (2) whether identification poses a risk of retaliatory physical or mental harm to the ...party
+20
+seeking proceed anonymously..; (3) whether identification presents other harms and the likely
+21
+severity of those harms...(4) whether the plaintiff is particularly vulnerable to the possible harms
+22
+of disclosure; (5) whether the suit is challenging the actions of the government or that of private
+23
+parties, (6) whether the defendant is prejudiced by allowing the plaintiff to press his claims
+24
+anonymously, ...; (7) whether the plaintiffs identity has thus far been kept confidential, ; (8)
+25
+whether the public's interest in the litigation is furthered by requiring the plaintiff to disclose his
+26
+identity…." Id. at 190 (internal citations removed).
+27
+New York state has made clear its intentions to protect the identities of survivors of sexual
+28
+assault. The Eastern District of New York recognized, "[w]ith regard to the second factor, courts
+2
+
+
+PANISH SHEA & BoyLE LLP
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 3 of 7
+1
+have granted anonymity to protect against disclosure of a wide range of issues involving matters
+of the utmost intimacy, including sexual assault. Indeed, many states in this country, including
+3
+New York, have enacted laws to protect the anonymity of sexual assault victims." Doe No. 2 v.
+Kolko, 242 F.R.D. 193, 196 (E.D.N.Y. 2006) (internal citations omitted). Specifically, N.Y. Educ.
+Law § 6448 states:
+6
+Pursuant to subdivision (i) of rule three thousand sixteen of the civil practice law
+and rules, in any proceeding brought against an institution which seeks to vacate or
+7
+modify a finding that a student was responsible for violating an institutions rules
+regarding a violation covered by this article, the name and identifying biographical
+8
+information of any student shall be presumptively confidential and shall not be
+9
+10
+11
+12
+13
+14
+included in the pleadings and other papers from such proceeding absent a waiver or
+cause shown as determined by the court. Such witnesses shall be identified only as
+numbered witnesses. If such a name or identifying biographical information
+appears in a pleading or paper filed in such a proceeding, the court, absent such a
+waiver or cause shown, shall direct the clerk of the court to redact such name and
+identifying biographical information and so advise the parties.
+Additionally, N.Y. Civ. Rights Law § 50-b states:
+The identity of any victim of a sex offense, as defined in article one hundred thirty
+or section 255.25, 255.26 or 255.27 of the penal law, or of an offense involving the
+alleged transmission of the human immunodeficiency virus, shall be confidential.
+No report, paper, picture, photograph, court file or other documents, in the custody
+15
+or possession of any public officer or employee, which identifies such a victim
+shall be made available for public inspection. No such public officer or employee
+16
+shall disclose any portion of any police report, court file, or other document, which
+tends to identify such a victim except as provided in subdivision two of this section.
+17
+Further, "lu]pon approving New York's rape shield law, then Governor Mario
+18
+stated, 'sexual assault victims have unfortunately had to endure a terrible invasion of their physical
+19
+20
+privacy. They have a right to expect that this violation will not be compounded by a further
+invasion of their privacy."" Doe No. 2 v. Kolko, 242 F.R.D. 193, 196 (E.D.N.Y. 2006) (internal
+citations omitted).
+22
+23
+24
+25
+26
+27
+28
+A.
+GOOD CAUSE EXISTS FOR PLAINTIFF TO PROCEED USING A
+PSEUDONYM
+Here, all of the relevant factors strongly weigh in favor of granting Plaintiff's motion to
+file this case using a pseudonym. Indeed, for similar reasons to those discussed below, numerous
+courts have permitted Epstein's victims to proceed under pseudonyms in prior cases. See Order,
+Doe v. Epstein, No. 08-cv-80119 (S.D. Fla. Aug. 7, 2009), ECF No. 253 (consolidating 11 Doe
+3
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 4 of 7
+1
+cases against Epstein and every plaintiff to proceed anonymously in the style of the case); see also
+2
+Hr'g Tr., United States v. Epstein, No. 19-cr-490 (S.D.N.Y. Aug. 27, 2019), ECF No. 53 (allowing
+3
+eight of Epstein's victims to present testimony under protective pseudonyms after Epstein's death
+4
+in connection with criminal case); Joint Rule 26(f) Report, Jane Doe 43 v. Epstein et al., No. 17-
+5
+cv-616 (S.D.N.Y. Apr. 5, 2017), ECF No. 28 at 4 (Rule 26 Report noting that "[d]ue to the nature
+6
+of the claim, the Plaintiff has proceeded anonymously through a pseudonym"); Order, Jane Doe
+7
+No. 103 v. Epstein, No. 10-cv-80309 (S.D. Fla. Mar. 9, 2010), ECF No. 5 (granting motion to
+proceed anonymously). These courts have recognized that, throughout their litigation again
+Epstein, these women "will be required to disclose highly sensitive and intimate information," and
+10
+disclosure of their real names "will cause ... much additional embarrassment, humiliation, and
+11
+12
+psychological trauma," as well as "adverse professional and economic consequences." See Order,
+Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. Oct. 6, 2008), ECF No. 15 at 2-3.
+13
+This Case Involves Details of a Highly Sensitive and Personal Nature
+14
+Jane Doe filed her complaint using a pseudonym in order to protect her identity so as to
+15
+mitigate damage done to her and her name as a result of the incidents alleged in her complaint.
+16
+The details surrounding her sexual abuse are highly sensitive and of a personal nature. There was a
+17
+fundamental privacy interest that was violated when Jane Doe was sexually assaulted and, as
+18
+stated by New York's Governor
+exposure of Jane Doe's true identity would only
+19
+compound that violation. Doe No. 2 v. Kolko, 242 F.R.D. 193, 196 (E.D.N.Y. 2006) (internal
+20 citations omitted).
+21
+Indeed, courts have recognized that "sexual assault victims are a paradigmatic example of
+22
+those entitled to a grant of anonymity." Doe No. 2 v. Kolko, 242 F.R.D. 193, 195 (E.D.N.Y.
+23
+2006); see also Doe v. Skyline Automobiles Inc., 375 F. Supp. 3d 401, 405 (S.D.N.Y. 2019)
+24
+(finding allegations of sexual assault and ongoing sexual harassment were "highly sensitive and
+25
+of an extremely personal nature"); Doe v. Colgate Univ., No. 15-cv-1069, 2016 WL 1448829, at
+26
+#3 (N.D.N.Y. Apr. 12, 2016); Doe v. Greiner, 662 F. Supp. 2d 355, 363 n.8 (S.D.N.Y. 2009)
+27
+noting that "the identity of a minor who was the victim of a sex assault" is among the
+28
+"exceptional circumstances" justifying anonymity in court materials). For that reason alone,
+4
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 5 of 7
+1
+permitting Plaintiff to proceed pseudonymously is warranted.
+2
+Moreover, because of the significant public attention surrounding Epstein's arrest and
+3
+untimely death, all of Plaintiff's potential harms would be more likely than not intensified should
+4
+her identity become public. Plaintiff has a legitimate fear that her public identification could put
+5
+her job, relationships and family at risk. And even though Epstein is deceased, a number of his
+6
+associates, like Maxwell, are the subjects of potential criminal investigation and civil lawsuits.
+7
+Many of these same individuals have already proven that they will intimidate and attempt to
+silence any of his identifiable victims. See Decision and Order Remanding Def., United States v.
+Epstein, No. 19- cr-490 (S.D.N.Y. July 18, 2019), ECF No. 32 at 15, 15-18. This well-established
+10
+11
+history of retaliation justifies permitting Plaintiff to proceed pseudonymously. See, e.g., Doe v.
+Solera Capital LLC, No. 18-cv-1769, 2019 WL 1437520, at *5 (S.D.N.Y. Mar. 31, 2019)
+12
+("[C]ourts have allowed plaintiffs to proceed anonymously where disclosure of their identities
+13
+created a risk of harm from third parties unaffiliated with the case."); L.H. v. Schwarzenegger, No.
+14
+15
+06-cv-2042, 2007 WL 662463, at *16 (E.D. Cal. Feb. 8, 2007); see also Does I thru XXIII v.
+Advanced Textile Corp., 214 F.3d 1058, 1070 (9th Cir. 2000) (noting that plaintiffs may proceed
+16
+anonymously "to protect themselves from retaliation by third parties").
+17
+2.
+Defendants Will Not Suffer Prejudice
+18
+Allowing Jane Doe to proceed by pseudonym will not prejudice the Defendants or interfere
+19
+in any way with the policy underlying Rule 10 of the Federal Rules of Civil Procedure which
+20 |
+apprises the parties of the identity of their opponent. Moreover, courts also balance
+21
+| the harm to the plaintiff with the potential prejudice to the defendant. See Sealed Plaintiff, 537
+22
+F.3d at 189. The relevant considerations are the damage to the defendant's reputation caused by
+23
+responding to anonymous allegations, difficulties in conducting discovery, and the fundamental
+24
+| fairness of proceeding in such a manner. E.W. v. N.Y. Blood Ctr., 213 F.R.D. 108, 112 (E.D.N.Y.
+25
+2009). None of these factors weigh against allowing Plaintiff to proceed by pseudonym here.
+26
+In light of Epstein's already well-known criminal and notorious actions, this case, more is
+27
+one in which "any reputational harm to defendants has already been inflicted." Doe #1 v. Syracuse
+28
+Univ., No. 18- cv-496, 2018 WL 7079489, at*8 (N.D.N.Y. Sep. 10, 2018). Further, Epstein's
+5
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 1:20-cv-00484-JGK-DCF Document 5 Filed 01/17/20 Page 6 of 7
+1
+estate and Maxwell will not be prevented from conducting discovery and reasonably defending
+this case. Plaintiff's counsel will provide Plaintiff's name to Defendants' counsel under conditions
+3
+that will reasonably protect the safety of Plaintiff, her family, and potential witnesses. Where a
+4
+defendant's counsel is made aware of plaintiff's identity, there is no "prejudice to [defendant's]
+5
+ability to conduct discovery or try the matter if plaintiff were to proceed under a pseudonym."
+6
+See E.W., 213 F.R.D. at 112; see also Kolko, 242 F.R.D. at 198 (finding that where defendants
+7
+know plaintiff's identity, "defendants will not be hampered or inconvenienced merely by
+8
+plaintiff's anonymity in court papers").
+9
+Public Policy Supports Keeping Plaintiff's Name Protected
+10
+Here, there is no public interest served by revealing the identity of Plaintiff Jane Doe who
+11
+is one of Epstein's many victims. To the contrary, the public interest would be best served by
+12
+permitting Plaintiff to seek justice under a protective pseudonym. As discussed above, New York
+13
+State has a strong public policy interest in protecting the privacy interests of victims of sexual
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+26
+27
+28
+abuse, as demonstrated by Section 50-b of the Civil Rights Law, which protects sex-abuse
+survivors from undesired identification in a range of public administrative contexts, including
+certain court proceedings. See N.Y. Civil Rights Law § 50-b (McKinney 2019) (shielding sexabuse victims from identification in, among other things, any "police report, court file, or other
+document").
+Moreover, in addition to the public's general interest in protecting the well-being of
+20 | victims, "the public generally has a strong interest in protecting the identities of sexual assault
+victims so that other victims will not be deterred from reporting such crimes." See Kolko, 242
+F.R.D. at 195-96. In consideration of that strong public policy, federal courts have permitted
+victims of sexual assault to proceed anonymously in similar cases.
+4.
+Plaintiff Jane Doe Has Preserved Her Confidentiality To Date
+Plaintiff has worked diligently to protect her identity. Indeed, despite numerous and
+ongoing attempts to interview her by the media and journalists, she has never spoken to the press
+or publicly identified herself in any way associated with her allegations. In the related criminal
+case, federal prosecutors have carefully protected her identity. These efforts weigh in favor of her
+6
+
+
+606 9Z|
+Case 1:20-cv-00484-JGK-DCF
+Document 5
+Filed 01/17/20 Page 7 of 7
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+petition to proceed by pseudonym in her civil action. See, e.g., Solera Capital, 2019 WL 1437520,
+at *7 (finding that "the fact that Doe's anonymity to the public has been preserved to date"
+counsels in favor of proceeding pseudonymously).
+II.
+CONCLUSION
+For the foregoing reasons, Plaintiff respectfully requests that the Court grant
+Plaintiff's motion and allow her to file her complaint using a pseudonym.
+Respectfully submitted,
+R-Olive
+Dated:
+January 16, 2020
+Kevin Boyle (admission pending)
+Robert Glassman (admission pending)
+Nathan Werksman (admission pending)
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, CA 90025
+Telephone: (310) 477-1700
+Facsimile: (310) 477-1699
+boyle@psblaw.com
+glassman@psblaw.com
+werksman@psblaw.com
+/s/ Benedict P. Morelli
+Benedict P. Morelli
+David T. Sirotkin
+Sara A. Mahoney
+MORELLI LAW FIRM PLLC
+777 Third Avenue, 31" Floor
+New York, NY 10017
+Telephone: (212) 751-9800
+Facsimile: (212) 751-0046
+bmorelli@morellilaw.com
+dsirotkin@morellilaw.com
+smahoney@morellilaw.com
+Attorneys for Plaintiff
+7
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/df5fb2e21fdddf7601269dcb00f52475c44de2de25b09fda1e42952c31f4428e.md b/vision-fixhub/court-01/df5fb2e21fdddf7601269dcb00f52475c44de2de25b09fda1e42952c31f4428e.md
new file mode 100644
index 0000000000000000000000000000000000000000..b3e19b1b01e56b0db4221b530e30911d39e8ea3b
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@@ -0,0 +1,441 @@
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 1 of 18
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CIV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant's Supplementary Brief Pursuant To The Magistrate's Order (DE 242)
+Requesting A More Particularized Showing Demonstrating How The 5* Amendment May
+Be Asserted To Plaintiff's Requests For Production, With Memorandum Of Law
+Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his
+undersigned attorneys, hereby files his Supplementary Brief Pursuant to the Magistrate's
+Order (DE 242) relative to Plaintiff's Request for Production Numbers 10, 11, 19 and 21.
+In support, Epstein states:
+Procedural Background
+Plaintiff served her First Request for Production, and Epstein served his
+responses and objections thereto. See Exhibit "A." Plaintiff filed her Motion to Compel
+(DE 57), and Epstein filed his Response thereto (the "Response Memorandum"). (DE
+63)
+The objections and responses set forth in Epstein's initial response and the
+arguments set forth in his Response Memorandum are incorporated herein such that a
+concise statement and more particularized showing can be made herein as to why
+Epstein's Fifth Amendment Privilege as to Request for Production Numbers 10, 11, 19
+and 21 should be sustained.
+1
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 2 of 18
+This court entered an order (DE 242) stating that Epstein must supplement
+his Response Memorandum to Plaintiff's Motion to Compel as to request for production
+numbers 10, 11, 19 and 21 (collectively, the "Specified Requests"). (DE 242, p. 19).
+Defendant's time to respond and submit this supplementary brief was extended to August
+31, 2009.
+3.
+Epstein is submitting this Supplementary Brief with supporting case law
+only as to the Specified Requests. An Amended Response will be provided as to Request
+to Produce Number 18.
+Il.
+Supplementary Brief, With Incorporated Memorandum of Law
+The Magistrate's Order (DE 242) Correctly Sustained Epstein's 5" Amendment
+Privilege As To Several Requests And Interrogatories Seeking Testimonial And
+Incriminating Information Similar To The Specified Requests
+The Magistrate Judge found that several of the requests were "...
+testimonial in nature, in that by production, Epstein would be implicitly communicating
+"statements of fact' to which the Fifth Amendment privilege may be validly asserted."
+(DE 242, p. 10). On that basis, and as a limited example, this Court denied Plaintiff's
+motion relative to request number 5 (seeking telephone records of calls made by Epstein)
+and request number 6 (seeking telephone calls made by Epstein to his employees).
+Likewise, this Court denied Plaintiff's motion relative to interrogatory numbers 1, 2, 10
+and 12 because those interrogatories sought the names of Epstein's employees or their
+telephone numbers and thus "would furnish a link in the chain of evidence needed to
+prosecute Epstein of a crime." (DE 242, p.8-9). Additionally, this Court denied
+Plaintiff's motion relative to interrogatory numbers 13, 14 and 17 because those asked
+Epstein to identify persons or witnesses that have knowledge of the events in question. Id.
+2
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 3 of 18
+at p. 8. In making the decision, the court recognized, much like this Supplementary Brief
+contends infra, that "... the facts alleged in the Complaints, the elements needed to
+convict Epstein of a crime, and ... the Court's knowledge concerning the cases at issue"
+provide a basis for Epstein to raise the privilege based upon "genuinely threatening
+questions" which could furnish a link in the chain of evidence needed to convict Epstein
+of a crime. (DE 242, p.18) United States v. Goodwin, 625 F.2d 693, 701 (St* Cir. 1980).
+As detailed below, the Specified Requests seek similar information or will
+lead to the production of the same exact information that this court has already ruled is
+protected by Epstein's Fifth Amendment Privilege.
+esponding to the Specified Requests Would Violate Epstein's 5 Amendment Privilege An
+Vould Expose Him to the Hazards of 18 U.S.C. 2422(b) And The 18 U.S.C. 2423(h
+6.
+Request for Production Numbers 10, 11, 19 and 21 seek the following
+information:
+Request No. 10. All documents referring to or relating to air travel and
+aircraft used by Defendant, including without limitation, flight logs and
+Request No. 11. Any and all documents referring to or relating to
+modeling agencies, including but not limited to documents relating to or
+reflecting communications with female models.
+Request No. 19. Any and all documents reflecting or consisting of
+communications between Jeffrey Epstein and MC2 Models or Jean-Luc
+Brunel, relating or referring to females coming into the United States from
+other countries to pursue a career in modeling, including, but not limited
+to, letters, notes and e-mails.
+Request No. 21. Any and all personal calendars or schedules of or for
+Jeffrey Epstein from January 1, 2003 to the present.
+7.
+As discussed below, production of the specified information is tantamount
+to compelled testimonial authentication of the information, its existence, its authenticity,
+3
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 4 of 18
+and as well Epstein's alleged possession, custody or control of same. Production may
+result in self incrimination and potential federal-criminal prosecution of Epstein.
+The Background Of This Case And Other Related Cases As Well As The Federal
+Statutory Claims And Elements Of Those Offenses Must Be Considered In
+Connection With Epstein's More Particularized Showing Demonstrating How The sl
+Amendment Is Validly Applied To Plaintiff's Requests For Production
+8.
+The circumstances of this case (and in other related cases) are such that
+not only does Epstein face allegations of sexual misconduct with and abuse, exploitation,
+and sexual battery of alleged minors in this and other civil actions in the State of Florida,
+but he also faces the potential of further federal criminal investigations and the possibility
+of further criminal prosecutions based on the same factual allegations. The Plaintiff's
+attorney represents Jane Doe Nos. 2, 3, 4, 5, 6, and 7, in civil actions against Epstein filed
+in this Court. In this and the other civil actions, the Plaintiffs reference and in certain
+respects discussed herein rely on allegations of the commission of federal and state
+criminal statutes in an attempt to make claims against Epstein ranging from sexual
+battery to intentional infliction of emotional distress, including, as to Jane Doe 2
+violations of 18 U.S.C. 2422, entitled "Coercion and enticement", contained in Chapter
+117 of Title 18 - "Transportation for Illegal Sexual Activity and Related Crimes," and as
+to other Jane Does, violations of 18 U.S.C. 2423(b) which criminalizes interstate or
+foreign travel for the purpose of having illicit sexual activity. Both 18 U.S.C. 2422(b)
+and 2423(b) are alleged by Jane Doe 2 and other Jane Does as predicate criminal offenses
+for federal damages lawsuits pursuant to 18 U.S.C. §2255 which creates a civil remedy
+for personal injuries when a plaintiff can first show a violation of specified federal
+statutory criminal statues.
+Most importantly for purposes of the Court's making a
+determination regarding whether Epstein has shown a specific risk of self-incrimination,
+4
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 5 of 18
+or that production of a document would constitute a link in the chain of evidence, (see
+DE242, at pgs 8-9, 18), the lynchpin for the exercise of federal criminal jurisdiction
+under 18 U.S.C. 2422(b) is "the use of "any facility or means of interstate or foreign
+commerce" and the analogous essential element of 18 U.S.C. 2423(b) is "travel (s) in
+interstate commerce or travels into the United States or {as) to a United States
+citizen...travels in foreign commerce". Thus, facially, an essential proof of any allegation
+of 18 U.S.C. 2422(b) - the statutory precondition alleged by Jane Doe 2 for a 2255 civil
+damage recovery - includes telephone, cellular phone, e-mail records or other
+"communications" as a facility of interstate commerce during which use there was
+persuasion, inducement, enticing, or coercing of an underage person to engage in
+prostitution or sexual activity. Contested requests for production numbers 10, 11, 19 and
+21 ask that Epstein produce information (e.g.. documents reflecting Epstein's air travel,
+aircraft used and flight manifests, all communications with female models, MC2 models
+or Jean Luc Brunel relating to or referring to females coming into the United States from
+other countries and his personal calendars and schedules) that could reveal the
+availability to him or use of such interstate facilities and thus would constitute a link in
+the chain of evidence that could potentially expose him to the hazards of selfincrimination as to 18 U.S.C. 2422(b) federal criminal violations.
+Likewise, other Jane Does such as Jane Doe 102 have contended that they
+are entitled to 18 U.S.C. 2255 damages based on Epstein's violation of 18 U.S.C.
+2423(b), a separate federal criminal statute that prohibits "a person who travels in
+interstate commerce or travels into the United States...for the purpose of engaging in
+illicit sexual activity".
+As more fully discussed, infra, contested request to produce
+5
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 6 of 18
+numbers 10, 11, 19 and 21 ask Epstein to produce information that could provide a link in
+the chain of evidence regarding: (a) Epstein's air travel within the United States and
+Foreign Territories; (b) Epstein's communications with female models, MC2 models, or
+Jean Lue Brunel relating to or referring to females coming into the United States from
+other countries; and (c) Epstein's personal calendars and schedules.
+Given that the
+essential proof of an allegation of 18 U.S.C. 2423(b) would include travel records,
+schedules regarding trips and locations, flight records, and calendars evidencing Epstein's
+whereabouts, the requested information, if ordered produced by this Court, would furnish
+evidence that could potentially expose Epstein to the hazards of self-incrimination as to
+18 U.S.C. 2423(b) violations. The is especially true given that, according to Jane Doe 2's
+complaint, he has residences and businesses in New York and the Virgin Islands as well
+as Florida. Responding to request numbers 10, 11, 19 and 21 may expose Epstein to the
+hazards of 18 U.S.C. 2423(b), which was a target offenses of the joint FBI-United States
+Attorney investigation discussed above, see par 12 and 13, infra
+The NPA And The Underlving Criminal Investigation
+That Led To The NPA Must Also Be Considered In Connection With
+Epstein's More Particularized Showing Demonstrating How The 5i
+Amendment Is Validly Applied To Plaintiff's Requests For Production'
+10.
+18 U.S.C. 2422(b) and 18 U.S.C. 2423(b) were offenses that were central
+to both the joint FBI-United States Attorney investigation, and the resulting Grand Jury
+6
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 7 of 18
+investigation, as well as the NPA itself, further demonstrating the extent to which
+Epstein's refusal to respond or produce information to each request is, as required, based
+on a specific apprehension of a compelled production and disclosure providing a link in
+the chain of evidence adverse to him. Blau v. United States, 340 U.S. 159 (1950). A
+more particularized showing will be filed in camera so that Epstein can more fully
+particularize the basis of his constitutional assertions.
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 8 of 18
+8
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 9 of 18
+9
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009
+
+10
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009
+
+11
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009
+
+12
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009
+
+Application Of The 5'" Amendment
+19.
+In the instant case, it is evident from the requests themselves, the
+allegations in the various Complaints, and the facts and circumstances surrounding these
+cases, that to demand from Epstein a more particularized showing, requires Epstein to
+walk a thin line with regard to "surrender[ing] the very protection which the privilege is
+designed to guarantee." Hoffman, 341 U.S. at 479. The United States Supreme Court
+has made clear that the scope of the Fifth Amendment Privilege also encompasses the
+circumstance where "the act of producing documents in response to a subpoena (or
+production request) has a compelled testimonial aspect." United States v. Hubbell, 530
+U.S. at 36; see also Fisher v. United States, 425 U.S. 391 (1976); McCormick on
+Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination, §138 (6th Ed.).
+The "implicit authentication" rationale appears to be the prevailing justification for the
+Fifth Amendment's application to documentary subpoenas, which is no different from
+producing documents responsive to a request for production. See U.S. v Hubbell, 530
+2 Paragraphs 11-18 of this Supplementary Brief are being provided to the court on an in camera basis as
+permitted by the Court's Order. (DE 242, p.20.)
+13
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 14 of 18
+U.S. 27, 36 (2000); Schmerber v. California, 384 U.S., 757, 763-764, (1966) ("the
+privilege reaches ... the compulsion of responses which are also communications, for
+example, compliance with a subpoena to produce one's papers; |
+v. United States,
+409 U.S. 322, 344-46 (1973) (the person complying with the subpoena "implicitly
+testifies that the evidence he brings forth is in fact the evidence demanded"); People v.
+Defore, 242 N.Y. 13. 27 (1926) ("A defendant is "protected from producing his
+documents in response to a Subpoena duces tecum, for his production of them in court
+would be his voucher of their genuineness.' There would then be testimonial
+compulsion' ").
+20.
+As stated, in responding to each request, Epstein would be compelled to
+provide assertions of fact, thereby admitting that such documents existed and further
+admitting that the documents were in his possession or control, and were authentic. In
+other words, the very act of production of the category of documents requested would
+implicitly communicate "statements of fact." Hubbell, supra; Hoffman v. United States.
+341 U.S. 479, 71 S.Ct. 814 (1951). As such, the act of production might not only provide
+evidence to support a conviction, but also a link in the chain of evidence for prosecution.
+Importantly, such compulsion to produce is the same as being compelled to testify. Thus,
+in those instances where the existence and/or location of the requested documents are
+unknown, or where the production would "implicitly authenticate" the requested
+documents, the act of producing responsive documents is considered "testimonial" and is
+protected by the Fifth Amendment. In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir.
+1993); see also Fisher v. U.S., 425 U.S. 391, 410 (1976)(issue expressed as whether
+compliance with a document request or subpoena "tactically conceded" the items
+14
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 15 of 18
+authenticity, existence or possession by defendant). Even more egregious is that fact that
+producing or responding to the Specified Requests could result in self-incrimination and
+potential prosecution.
+21.
+The United States Supreme Court has expressly encompassed the innocent
+citizen as well as the guilty within the ambit of Fifth Amendment protections (i.e., that
+Epstein may deny any allegation that he violated either of the above-described federal
+statutes is not in conflict with his constitutional right not to be compelled by requests to
+make disclosures that would further any investigation against him or incriminate him.)
+The Fifth Amendment privilege against self incrimination is accorded "liberal
+construction," Hoffman, 341 U.S. at 486, and extends not only to answers that would in
+themselves support a criminal conviction, but extends also to those answers (or responses
+as in the instant matter) that would furnish a link in the chain of evidence needed to
+prosecute the claimant for a crime. Id. The Fifth Amendment serves as a guarantee
+against testimonial compulsion and provides, in relevant part, that "In]o person. shall be
+compelled in any Criminal Case to be a witness against himself." (DE 242, p.5). In
+practice, the Fifth Amendment's privilege against self-incrimination "permits a person
+not to answer official questions put to him in any other proceeding, civil or criminal,
+formal or informal, where the answers might incriminate him in future criminal
+proceedings." Edwin v. Price, 778 F.2d 668, 669 (11" Cir. 1985), citing Lefkowitz v.
+Turley, 414 U.S. 70, 77 (1973)). Thus, information is protected by the privilege not only
+if it would support a criminal conviction, but also in those instances where "the responses
+would merely provide a 'lead or clue' to evidence having a tendency to incriminate."
+United States v., Neff, 615 F.2d 1235, 1239 (9" Cir.), cert. denied, 447 U.S. 825 (1980).
+15
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 16 of 18
+"The claimant must [also] be 'confronted by substantial and 'real,' and not merely trifling
+or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128
+(1980). Accordingly, responses to the requests propounded upon Epstein would provide
+information which is protected by the privilege i.e., "the responses [c]ould merely
+provide a 'lead or clue' to evidence having a tendency to incriminate [Epstein]" United
+States v., Neff, 615 F.2d 1235, 1239 (9"' Cir.), cert. denied, 447 U.S. 825 (1980).
+Brief Conclusion
+For all of the foregoing reasons, this Court should sustain Epstein's objections to
+the Specified Requests and uphold Epstein's right to assert his st* Amendment Privilege
+in connection with same.
+Wherefore, Epstein respectfully requests that this Court issue and order:
+finding that the danger Epstein faces by being forced to respond
+and produce documents relative to request numbers 10, 11, 19 and 21 is
+sustaining Epstein's Fifth Amendment Privilege as it relates to
+request numbers 10, 11, 19 and 21 and denying Plaintiff's Motion in that regard;
+for such other and further relief,
+as this Court deems just and
+proper.
+lll
+[AEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Respectfully Submitted,
+
+
+Case 9:08-cv-80119-KAM Document 283 Entered on FLSD Docket 08/31/2009 Page 17 of 18
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssmn@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+, Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+
+
+Case 9:08-cv-80119-KAM
+Document 283 Entered on FLSD Docket 08/31/2009 Page 18 of 18
+reelrhw@hotmail.com
+Jack Scarola, Esq.
+Jack P. L
+Searcy Denney Scarola Barnhart & Shipley,
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+18
diff --git a/vision-fixhub/court-01/df5fb2e21fdddf7601269dcb00f52475c44de2de25b09fda1e42952c31f4428e.receipt.json b/vision-fixhub/court-01/df5fb2e21fdddf7601269dcb00f52475c44de2de25b09fda1e42952c31f4428e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..793130415d3fdc6e02644e18349074c09a7cc606
--- /dev/null
+++ b/vision-fixhub/court-01/df5fb2e21fdddf7601269dcb00f52475c44de2de25b09fda1e42952c31f4428e.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 23,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.md b/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.md
new file mode 100644
index 0000000000000000000000000000000000000000..25a112b04fce090c1209b7b7554f76fe47111e45
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+++ b/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.md
@@ -0,0 +1,227 @@
+Case 9:08-cv-80232-KAM Document 140-1 Entered on FLSD Docket 03/12/2010 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CIV -MARRA/
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+NOTICE OF TAKING VIDEOTAPED DEPOSITION
+PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of
+Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 a.m., at:
+".,
+Esquire Court Reporters
+One Penn Plaza
+Suite 4715
+New York, NY 10119
+The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure
+and shall continue day to day, weekends and holidays excepted, until completed.
+¡HEREBY CERTIFY that a true and correct copy of the foregoing has been served
+by U.S. Mail and email transmission this //162 day of August, 2009 to all those on the
+attached Service List.
+1
+
+
+Case 9:08-cv-80232-KAM Document 140-1 Entered on FLSD Docket 03/12/2010 Page 2 of 5
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for Plaintiff
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Tel: (954) 522-3456
+Fax: (954) 527-8663
+Email: bedwards@rra-law.com
+By: =
+sale
+BRAD
+, ESQ.
+Florida Bar No.: 542075
+CC:
+Esquire Court Reporters
+
+
+Case 9:08-cv-80232-KAM Document 140-1 Entered on FLSD Docket 03/12/2010 Page 3 of 5
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+JANE DOE
+Plaintif
+V.
+JEFFREY EPSTEIN
+Civil Action No.
+08-90893CIV-MARRA/JOHNSO
+(If the action is pending in another district, state where:
+Defendant
+SUBPOENA TO TESTIFY AT A DEPOSITION
+OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION
+To: Jean Luc Bruhel, 301 E. 66th Street, New York, NY
+• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
+depositione be take in chiors, i actinging age as, or deganize in et person a party in it rest you not designate
+about the following matters, or those set forth in an attachment:
+Place: Esquire Court Reporters, One Penn Plaza
+Suite 4715, New York, NY
+Date and Time:
+09/22/2009 10:00 am
+The deposition will be recorded by this method:
+] Production: You, or your representatives, must also bring with you to the deposition the following documents
+lectronically stored information, or objects, and permit their inspection, copying, testing, or sampling of thi
+material:
+The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
+45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are
+attached.
+Date:
+CLERK OF COURT
+OR
+Signature of Clerk or Deputy Clerk
+Attorney's signature
+The name, address, e-mail, and telephone number of the attorney representing (name of party)
+Brad
+Es. Rtain Resented die, 401 E. as Ola Bid. Suh ise or re dis lopera, are.
+Bedwards@rra-law.com. (954) 522 2346
+
+
+Case 9:08-cv-80232-KAM Document 140-1 Entered on FLSD Docket 03/12/2010 Page 4 of 5
+AO 8SA (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 2)
+Civil Action No. 08-90893CIV-MARRA/JOHNSO
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 45.)
+This subpoena for (name of individual and title, if any)
+was received by me on (date)
+• I personally served the subpoena on the individual at (place)
+on (date)
+i or
+• I left the subpoena at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the subpoena on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+, who is
+on (date)
+; or
+• 1 returned the subpoena unexecuted because
+• Other (specify):
+; or
+Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also
+tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of
+$
+My fees are $
+for travel and S
+for services, for a total of $
+0.00
+1 declare under penalty of perjury that this information is true.
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc:
+
+
+Case 9:08-cv-80232-KAM Document 140-1 Entered on FLSD Docket 03/12/2010 Page 5 of 5
+AO 88A (Rev, 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action (Page 3)
+Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)
+(c) Protecting a Person Subject to a Subpoena.
+(d) Duties in Responding to a Subpoena.
+(1) Avoiding Undue Burden or Expense; Sanctions. A party or
+(1) Producing Documents or Electronically Stored Information.
+attorney responsible for issuing and serving a subpoena must take
+These procedures apply to producing documents or electronically
+reasonable steps to avoid imposing undue burden or expense on a
+person subject to the subpoena. The issuing court must enforce this
+duty and impose an appropriate sanction - which may include lost
+earnings and reasonable attorney's fees - on a party or attorney
+(2) Command to Produce Materials or Permit Inspection.
+(A) Appearance Not Required. A person commanded to produce
+documents, electronically stored information, or tangible things, or
+to permit the inspection of premises, need not appear in person at the
+place of production or inspection unless also commanded to appear
+for a deposition, hearing, or trial.
+(B) Objections. A person commanded to produce documents or
+tangible things or to permit inspection may serve on the party or
+attorney designated in the subpoena a written objection to
+inspecting, copying, testing or sampling any or all of the materials or
+to inspecting the premises - or to producing electronically stored
+information in the form or forms requested. The objection must be
+served before the earlier of the time specified for compliance or 14
+days after the subpoena is served. If an objection is made, the
+following rules apply:
+(l) At any time, on notice to the commanded person, the serving
+party may move the issuing court for an order compelling production
+(ii) These acts may be required only as directed in the order, and
+the order must protect a person who is neither a party nor a party's
+officer from significant expense resulting from compliance.
+(3) Quashing or Modifying a Subpoena.
+(A) When Required. On timely motion, the issuing court must
+quash or modify a subpoena that:
+(i) fails to allow a reasonable time to comply;
+(ii) requires a person who is neither a party nor a party's officer
+to travel more than 100 miles from where that person resides, is
+employed, or regularly transacts business in person — except that,
+subject to Rule 45(c)(3)(B)(iii), the person may be commanded to
+attend a trial by traveling from any such place within the state where
+(iii) requires disclosure of privileged or other protected matter, if
+no exception or waiver applies; or
+(iv) subjects a person to undue burden.
+(B) When Permitted. To protect a person subject to or affected by
+a subpoena, the issuing court may, on motion, quash or modify the
+subpoena if it requires:
+(i) disclosing a trade secret or other confidential research,
+development, or commercial information;
+(ii) disclosing an unretained expert's opinion or information that
+does not describe specific occurrences in dispute and results from
+the expert's study that was not requested by a party; or
+(lil) a person who is neither a party nor a party's officer to incur
+substantial expense to travel more than 100 miles to attend trial.
+(C) Specifying Conditions as an Alternative. In the circumstances
+described in Rule 45(c)(3)(B), the court may, instead of quashing or
+modifying a subpoena, order appearance or production under
+specified conditions if the serving party:
+(i) shows a substantial need for the testimony or material that
+cannot be otherwise met without undue hardship; and
+(ii) ensures that the subpoenaed person will be reasonably
+compensated.
+(A) Documents. A person responding to a subpoena to produce
+documents must produce them as they are kept in the ordinary
+course of business or must organize and label them to correspond to
+the categories in the demand.
+(B) Form for Producing Electronically Stored Information Not
+Specified. If a subpoena does not specify a form for producing
+electronically stored information, the person responding must
+produce it in a form or forms in which it is ordinarily maintained or
+in a reasonably usable form or forms.
+(C) Electronically Stored Information Produced in Only One
+Form. The person responding need not produce the same
+electronically stored information in more than one form.
+(D) Inaccessible Electronically Stored Information. The person
+responding need not provide discovery of electronically stored
+information from sources that the person identifies as not reasonably
+accessible because of undue burden or cost. On motion to compel
+discovery or for a protective order, the person responding must show
+that the information is not reasonably accessible because of undue
+burden or cost. If that showing is made, the court may nonetheless
+order discovery from such sources if the requesting party shows
+good cause, considering the limitations of Rule 26(bX(2)(C). The
+court may specify conditions for the discovery.
+(2) Claiming Privilege or Protection.
+(A) Information Withheld. A person withholding subpoenaed
+information under a claim that it is privileged or subject to
+protection as trial-preparation material must:
+(i) expressly make the claim; and
+(ii) describe the nature of the withheld documents,
+communications, or tangible things in a manner that, without
+revealing information itself privileged or protected, will enable the
+parties to assess the claim.
+(B) Information Produced. If information produced in response to a
+subpoena is subject to a claim of privilege or of protection as trialpreparation material, the person making the claim may notify any
+party that received the information of the claim and the basis for it.
+reasonable steps to retrieve the information if the party disclosed it
+before being notified; and may promptly present the information to
+the court under seal for a determination of the claim. The person
+who produced the information must preserve the information until
+the claim is resolved.
+(e) Contempt. The issuing court may hold in contempt a person
+who, having been served, fails without adequate excuse to obey the
+subpoena. A nonparty's failure to obey must be excused if the
+subpoena purports to require the nonparty to attend or produce at a
+place outside the limits of Rule 45(c)(3XA)(ii).
diff --git a/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.receipt.json b/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..464c46ee9cc62aec471a8b5c3eb9f6bbfe01feaf
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+++ b/vision-fixhub/court-01/df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "df7a2e302fc83ff955776d9fa6c77d909156d832a015e105da19fc20fe602eea",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "0afcb05d61f9b911d25426cea4742e6eb92e7d144b99d006b841d45d6cbb2d06",
+  "output_sha256": "76f863b2c483b599f589de285884c5d8032f7594629b2c3b48171122362447f8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4.md b/vision-fixhub/court-01/df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4.md
new file mode 100644
index 0000000000000000000000000000000000000000..2ce44bdab391f1e9c850a5e75cdda78f059c3616
--- /dev/null
+++ b/vision-fixhub/court-01/df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4.md
@@ -0,0 +1,53 @@
+Case 9:08-cv-80381-KAM Document 37 Entered on FLSD Docket 08/05/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER DENYING MOTION TO SEAL
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File
+Under Seal, filed July 28, 2008. Defendant seeks to file his reply to his Motion to Stay under
+seal.' The Court has carefully considered the motion and the record and is otherwise fully
+advised in the premises.
+As the Court has previously explained to the parties, the Local Rules for the Southern
+District of Florida state that "proceedings in the United States District Court are public and Court
+filings are matters of public record." S.D. Fla. L.R. 5.4(A). It is well settled that the media and
+the public in general possess a common-law right to inspect and copy judicial records. See Nixon
+v. Warner Communications, Inc., 435 U.S. 589, 597 (1978). "The right to inspect and copy
+records is not absolute, however. As with other forms of access, it may interfere with the
+administration of justice and hence may have to be curtailed."
+v. Graddick, 696 F.2d
+'The parties are reminded that all documents filed conventionally (including those filed
+under seal) must be filed with the Clerk's Office in West Palm Beach, Florida.
+1
+
+
+Case 9:08-cv-80381-KAM Document 37 Entered on FLSD Docket 08/05/2008 Page 2 of 2
+796, 803 (11th Cir. 1983). This right of access creates a presumption in favor of openness of court
+records, which "must be balanced against any competing interest advanced." United States v.
+Noriega, 752 F. Supp. 1037, 1040 (S.D. Fla. 1990). For example, courts may look to see whether
+the records sought are for illegitimate purposes.
+•. 696 F.2d at 803. Likewise, the Court
+may consider whether "the press has already been permitted substantial access to the contents of
+the records." Id.
+In his motion to seal, Defendant states that he seeks to file this document under seal "to
+comply with the confidentiality clause" in the agreement between Defendant and the U.S.
+Attorney cited in his brief. (Def. Mot. 2.) The Court is familiar with the U.S. Attorney's
+objections to unsealing any part of the agreement, see In re: Jane Doe, No. 08-80736-CIV (S.D.
+Fla. July 11, 2008). However, as the Court has previously held, the U.S. Attorney's objections
+do not outweigh the public interest in having access to court records. Further, the details of the
+agreement contained in Defendant's Reply brief have, in large part, already been unsealed and
+released to the public. The Court finds no justification to keep these documents under seal.
+Accordingly, it is ORDERED AND ADJUDGED that Defendant's Motion to File
+Under Seal is DENIED. The Clerk shall UNSEAL docket entries 33 and 34 and make them
+available for public inspection through CM/ECF at the earliest possible time.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 4' day of August, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to: all counsel of record
+2
diff --git a/vision-fixhub/court-01/df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4.receipt.json b/vision-fixhub/court-01/df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2a3bd285e58fe29f7d89323b42007514bbc8335c
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@@ -0,0 +1,14 @@
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+  "doc_id": "df91c60ecd7efa43140b706f8c74dac2c24294e7a2637782b64b8726acbf8ee4",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b6caa94a44774e6bd8ee343f7f192a0d7148edab0a4622fe98b98ef8dd3597af",
+  "output_sha256": "7da73b89a55820d1876085554467d6e3ec3d02f737aeba0b2c015e863aab108f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dfa329c88ec3b1c93e2212d1da06c437f0ad8b719ab29d2fcde2c8dfa01e97b2.md b/vision-fixhub/court-01/dfa329c88ec3b1c93e2212d1da06c437f0ad8b719ab29d2fcde2c8dfa01e97b2.md
new file mode 100644
index 0000000000000000000000000000000000000000..a67d580f7e430ee5343a0f4215e68df313758309
--- /dev/null
+++ b/vision-fixhub/court-01/dfa329c88ec3b1c93e2212d1da06c437f0ad8b719ab29d2fcde2c8dfa01e97b2.md
@@ -0,0 +1,91 @@
+• Filing # 99387584 E-Filed 11/25/2019 10:37:31 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 50-2019-CA-014681-XXXX-MB
+Division: AG
+CA FLORIDA HOLDINGS, LLC
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+Beach County, Florida,
+Defendants.
+COPY
+NOTICE OF FILING RETURN OF SERVICE
+Plaintiff, CA FLORIDA HOLDINGS, LEC, Publisher of The Palm Beach Post
+("Plaintiff"), by and through undersigned counsel, files the attached Return of Service of Summons
+and Complaint served on Dave Aronberg as State Attorney of Palm Beach County, Florida on
+November 18, 2019.
+Dated: November 25, 2019
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+FT.Service@gtlaw.com
+-and-
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/25/2019 10:37:31 AM
+
+
+Case No. 50 2019 CA 014681 XXXXMB AG
+By: Is/ Michael J Grygiel
+MICHAEL J GRYGIEL
+(Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+NOT A CERTIFIED COPY
+
+
+RETURN OF SERVICE
+County of Palm Beach
+State of Florida
+Case Number: 502019CA0146B1XXXXMBAG
+15th Circuit Court
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST
+VS.
+Defendant:
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+Boach, county Ford Comptroller of Palm
+Stephen Mendelshn
+Greenberg Traurig, P.A.
+5100 Town Center Circle
+Suite 400
+COPY
+Boca Raton, FL 33486
+Received by Rock Legal Services & Investigations inc on the 18th day of November, 2019 at 9:19 am to be served
+on Dave Aronberg, as State Attorney of Palm Beach County, Florida, 401N. Dixie Highway, West Palm Beach,
+FL 33401.
+1, Nixon Fleurimond, do hereby affim that on the 18th day of November, 2019 at 10:45 am, I:
+GOVERNMENT AGENCY: served by delivering a true copy of the Summons, Complaint and Exhiblt 1 with the
+date and hour of service endorsed thereon by me, to: Leigh
+Las Assistant State Attorney for Dave Aronberg,
+as State Attorney of Palm Beach County, Florida, at the address of 401 N. Dixie Highway, West Palm Beach,
+FL 33401 and informed said person of the contents therein, in compliance with State Statutes.
+Description of Person Served: Age: 60, Sex: F, Race/Skin Color:
+- Height: 5'5", Weight: 140, Hair: Light
+, Glasses: N
+Under penalties of perjury, I declare that I have read the foregoing and that the facts stated in it are true. I am over
+the age of 18, have no interest in the above action, and am a Certified Process Server, in good standing, in the
+county in which service was effected in accordance with State Statutes.
+NOT
+Nixon Fleurimond
+Process Server 1316
+Rock Legal Services & Investigations Inc
+2048 Ponce De
+(661) 91-757 ach, FL 33407
+Jur Job Serial Number: ROC-2019019891
+Ref: 127136.025100
diff --git a/vision-fixhub/court-01/dfa329c88ec3b1c93e2212d1da06c437f0ad8b719ab29d2fcde2c8dfa01e97b2.receipt.json b/vision-fixhub/court-01/dfa329c88ec3b1c93e2212d1da06c437f0ad8b719ab29d2fcde2c8dfa01e97b2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fd80b4bb6db14a998dd1e055abdcb585c46f327f
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "db5b43814b49488da37c9c047b46d935c106a234cce83f88f0aa3880688bf610",
+  "output_sha256": "206b63ae57c811b814defa689733706af4a678247a5c5a7a552b6be0bd44e0a5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/dfb3896a81e6a34b7cef006c091afac78d3f1ec0bb47888984677bc99d7495f5.md b/vision-fixhub/court-01/dfb3896a81e6a34b7cef006c091afac78d3f1ec0bb47888984677bc99d7495f5.md
new file mode 100644
index 0000000000000000000000000000000000000000..06e0866ae1a7510cf4264a4a9886346b9e6c2f8d
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@@ -0,0 +1,209 @@
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFF JANE DOE NO. 4's MOTION FOR PROTECTIVE ORDER
+AS TO THE DEPOSITIONS OF CERTAIN NON-PARTY WITNESSES
+Plaintiff, Jane Doe No. 4 ("Plaintiff"), by and through undersigned counsel, hereby files
+Plaintiff Jane Doe No. 4's Motion for Protective Order, pursuant to S.D.Fla.L.R. 7.1, and states
+as follows:
+On April 19, 2010, Defendant Epstein's counsel advised Plaintiff's counsel that
+he was setting dates for additional depositions related to Jane Doe No. 4. The persons to be
+subpoenaed for deposition include two of Jane Doe No. 4's soccer coaches. To Plaintiff's
+knowledge, neither of them is aware that Jane Doe No. 4 has a case against Defendant Epstein,
+nor are they aware of the underlying facts of Jane Doe No. 4's visits to Epstein's mansion in
+Palm Beach.
+1
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 2 of 8
+2.
+To date, Defendant Epstein has taken ten (10) depositions relating to Jane Doe
+No. 4. Jane Doe No. 4's deposition was taken over a two day period, encompassing 595
+transcript pages.
+In addition, her mother, father and sister had their depositions taken by
+Defendant Epstein, as have her current boyfriend and ex-boyfriend, and her current mental health
+counselor.
+Defendant's counsel has also questioned other plaintiffs about Jane Doe No. 4,
+particularly Jane Doe No. 3 and Jane Doe No. 7, who are friends of Jane Doe No. 4.'
+3.
+The extensive depositions taken of Jane Doe No. 4, her family, friends, counselor,
+and boyfriends have not indicated that Plaintiff had a close relationship with either of her soccer
+coaches. They are scarcely mentioned at all. See Deposition of Jane Doe No. 4, Pp. 517-518
+attached hereto as Exhibit "1"; see also Deposition of Jane Doe No. 4's father [RZ], p. 145
+attached hereto as Exhibit "2". Given the lack of testimony about them, and their unawareness
+of the allegations of sexual abuse underlying this case, Plaintiff verily believes their testimony
+can provide no material and relevant information. At the same time, the inevitable disclosures of
+Jane Doe 4's childhood sexual abuse and other private information during the depositions of Jane
+Doe No. 4's soccer coaches will serve to embarrass and humiliate Jane Doe No. 4. Any value
+they might hypothetically provide as witnesses is far outweighed by these adverse effects to Jane
+Doe No. 4.
+4.
+The depositions of the soccer coaches is a continuation of the Defendant's pattern
+of harassing, embarrassing, intimidating, and attempting to ruin the reputations of Jane Doe No.
+4 and his other victims. As has been demonstrated on prior occasions, these victims feel shame
+' Additionally, Jane Doe No. 4 does not object to the deposition of Plaintiff's former college
+roommate, whose deposition is now being set for a mutually agreeable date. Additionally, she
+does not object to the deposition of another close friend in high school and college,
+whose deposition was scheduled for April 7, 2010, but was cancelled by Defendant.
+2
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 3 of 8
+and fear about people in their communities learning the most intimate and embarrassing details
+of their lives, including their personal, sexual, and medical histories. See, e.g., Plaintiffs Jane
+Doe No. 101 and Jane Doe No. 102's Motion for No-Contact Order (D.E. 113); Plaintiffs Jane
+Does 2-7's Response to Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of
+this Case (D.E. 144); Plaintiffs Jane Does' 2-7 Motion for Protective Order and Incorporated
+Memorandum of Law (D.E. 223); Plaintiffs Jane Doe Nos. 2-8's Motion for Protective Order as
+to Jeffrey Epstein's Attendance at Deposition of Plaintiffs, and Incorporated Memorandum of
+Law (D.E. 292); Affidavit of Dr. Kliman (D.E. 223, Ex. A); Jane Doe No. 4's Motion for
+Sanctions and Motion for Protective Order (D.E. 306); Order, dated October 23, 2009 (D.E. 369)
+(forbidding Epstein from attending Jane Doe No. 4's deposition); Omnibus Order (forbidding
+Epstein's attorneys from repetitive and abusive questioning during Plaintiffs' depositions) (D.E.
+433). See also Plaintiff's Motion for Protective Order (regarding deposition of Jane Doe No. 4's
+sister, Y.B.) (DE 267).
+5.
+Defendant Epstein's counsel has on prior occasions consistently and
+unnecessarily used depositions as a means to inform non-party witnesses about the most intimate
+details of the Plaintiffs' lives by using leading questions that disclose facts to the witnesses,
+without establishing any foundation for what the witnesses already know. For example, Jane
+Doe No. 4's father was asked the following questions that were gratuitously and unnecessarily
+loaded with personal information about Jane Doe No. 4:
+"During the time that [Jane Doe No. 4] was dating [her ex-boyfriend], were you
+aware that she was having relationships with other individuals? And by relationships, I
+mean other sexual relationships with other individuals, and was cheating on him?" (Exh.
+3, p. 132);
+3
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 4 of 8
+"[Jane Doe No. 4] testified also in deposition that she had been—there had been a
+videotape made of her and another female in various positions that some of her friends at
+least, or she was accused of having done, that would have been quote, unquote, a lesbian
+affair. Were you ever aware of that fact?" (Exh. 3, p. 137);
+*
+"Were you ever aware that [Jane Doe No. 4] made a video or video was made of
+she and a person named Tammy when she was in high school that ended up on the
+Internet that showed them in, I don't know sexually explicit but in, what some people
+have said, in their underwear but it looked sexually explicit?" (Exh. 3, p. 138); and
+*
+"Did your daughter ever tell you that she worked at a gentleman's club, a strip
+club?"; after the witness answered "no", Epstein's counsel asked: "If I ask you to assume
+that she testified that she tried out for three hours at a strip club called Dancers Royale in
+Orlando, has anyone told you that?" (Exh. 3, p. 143-44).
+See Exhibit 3, deposition excerpts of Jane Doe No. 4's father.
+6.
+Jane Doe No. 4's mother was asked questions similar to those asked of Jane Doe
+No. 4's father, as well as questions such as "Did she ever tell you that she had made a video of
+she and [her ex-boyfriend] in an intimate relationship which she then showed to other people?",
+without first being asked if she had any knowledge of her daughter's sex life or her daughter
+making a video. See Exhibit 4, deposition excerpt of Jane Doe No. 4's mother.
+7.
+Defendant now wants to take the deposition of Rocky Orezzoli, Jane Doe No. 4's
+college soccer coach, and Bill
+Doe No. 4's soccer coach in middle and high school. The
+past conduct of Epstein's counsel suggests that they intend to disclose to these witnesses through
+deposition questioning private, personal details relating to Jane Doe No. 4, including her
+allegations of child sexual abuse and her sexual history.
+4
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 5 of 8
+8.
+Fed. R. Civ. P. 26 (c)(I) allows the court to issue an order to protect a party from
+annoyance, embarrassment, oppression, or undue burden or expense by several methods,
+including "(A) forbidding the disclosure or discovery," and "(D) forbidding inquiry into certain
+matters, or limiting the scope of disclosure or discovery to certain matters" upon good cause
+shown by the moving party. "The good cause standard for issuing a protective order requires the
+Court to balance the moving party's interest in preventing the discovery sought against the other
+person's interest in seeking the discovery." [
+v. Burlage, 2009 WL 2230794 # 4 (S.D.
+Fla. 2009) (citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d 1304 (11th Cir.
+2001)).
+The persons sought to be deposed would not have information probative of Jane
+Doe No. 4's claims or Defendant's defenses. At best, they are fishing expeditions. The limited
+information the witnesses may be able to provide about Jane Doe No. 4 would be cumulative of'
+other information already provided by the plethora of witnesses who have testified about Jane
+Doe No. 4.
+10. Accordingly, Rule 26(c)(I) protective order is appropriate. If this Court is not
+inclined to prohibit the depositions of the soccer coaches entirely, then Plaintiff respectfully
+requests that the deposition questioning be restricted or limited to prevent leading questions that
+cause unnecessary disclosures of private, embarrassing and humiliating facts and information to
+the soccer coach witnesses.
+WHEREFORE, Plaintiff Jane Doe 4 respectfully requests that this Court issue a
+protective order prohibiting or restricting the depositions of Rocky Orezzoli and Bill
+, and
+all such other relief this Court deems just and appropriate.
+5
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 6 of 8
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: April 27, 2010
+Respectfully submitted,
+By: s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+Jessica D. Arbour (FL Bar No. 67885)
+jarbour@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+6
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on April 27, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+7
+
+
+Case 9:08-cv-80119-KAM Document 534 Entered on FLSD Docket 04/27/2010 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Stuart S. Mermelstein
+8
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@@ -0,0 +1,592 @@
+Filing # 144580390 E-Filed 02/24/2022 05:05:27 PM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+AMENDED RESPONSE AND MEMORANDUM OF LAW OF
+PLAINTIFF CA HOLDINGS, LLC IN OPPOSITION TO STATE ATTORNEY
+DAVE ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES UNDER
+FLORIDA STATUTES SECTION 57.105
+Plaintiff, CA Florida Holdings, LLC, publisher of The Palm Beach Poisi ("Plaintiff" or the
+"Newspaper") submits this Amended Response and Memorandum of Law in Opposition to State
+Attorney Dave Aronberg's ("Aronberg") November 9, 2020 Amended Motion for Attorneys' Fees
+under Florida Statutes Section $7. 105 [DE 50] ("Amended Motion").' For the reasons set forth
+below, the Amended Motion should be denied, with prejudice.
+INTRODUCTION
+Aronberg's November 9, 2020 Amended Motion for sanctions is légally and factually
+insufficient to meet the requirements of Section 57.105, Florida Statutes.
+' While the Amended Motion references Florida Rule of Civil Procedure 1.525 in the introductory
+paragraph, that Rule sets forth a deadline by which "[a]ny party seeking a judgment taxing costs,
+attorneys' fees, or both shall serve a motion[,I" but does not itself provide grounds to those fees or
+costs. Rather, the Amended Motion is based upon, and seeks relief of sanctions under, Florida
+Statutes Section 57.105.
+Party JOINT
+ID#. J31 EV#J31
+DATEADMITTED: 9/6/2022.
+Case No. 2019-CA-01468
+CA/Aronberg-001485
+ABRUZZO CLERI
+FILED: PALM BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 4:10:49 PM
+Joint Exhibit
+J31
+
+
+Firsi, as a crucial threshold matter, the Amended Motion fails as a matter of law because
+Aronberg did not comply with the strict 2:1-day safe harbor notice requirement set forth in Section.
+57.105(4) prior to filing his November 9, 2020 Amended Motion, which was materially different
+than, and raised new arguments and cited record evidence not included in his first Motion for
+Attorneys' Fees ("First Motion") served on June 8, 2020 and filed on July 1, 2020 [DE 35]. This
+technical failure alone requires the denial of the Amended Motion for sanctions.
+Second, as to the merits, the Amended Motion should be denied because Afonberg; in his
+official capacity as the State Attorney, was a proper party defendant The State Attorney was
+undisputedly an interested party to the Newspaper's action seeking access to grand jury records,
+and,he would have had the right to intervene in the lawsuit häd he not been named in the Complaint.
+The State Attorney was at the very least a nominal defendant, Sanctions are inappropriate under
+Section. 57.105.
+Third, the Amended Motion fails under Section 57:105 because Aronberg cannot meet.the
+burden for sanctions under the statute and cannot demonstrate that Plaintiff's claim, was so devoid
+of merit both on the facts and the law as to be completely untenable, as required to satisfy Section
+57.105(1). Rather, the claim at issue, Count I of Plaintiff's First Amended Complaint, is exactly
+the type of claim specifically excepted from sanctions under Section 57.105(3)(a), as the Plaintiff's
+claim, was presented to the Court as a good faith argument for the interpretation of existing law or,
+at least, the establishment of new law; as it applied to the material facts, with. a reasonable.
+expectation of success. In short, Plaintiff's claim was made and pursued in good faith and based
+on sufficient grounds, which insulates it from sanctions. Indeed, the Court's December 20, 2021
+Final Judgment described Plaintiff' s arguments as "sincere,""palatable and persuasive" and noted
+this was a case of. "first impression. that "implicated] issues of constitutional import," in the
+2
+CAVArophers:฿14861 BEACH COUNTY, FL,
+
+
+context of "genuine subjects of public interest and concern...." See, e.g., [DE 78, pp. 5, 11, 13].
+Aronberg's continued positión (which he has declined. to withdraw) that the Plaintiff's claim was.
+made in bad faith is squarely contradicted by the Court's Final. Judgment and the record
+Fourih, even if Aronberg had met the technical 21-day safe harbor notice requirement and
+could satisfy the heavy burden under the statute, which he did not and. cannot, the amount of fees.
+sought by his counsel is not supported by Florida law. Specifically; the contingency risk multiplier
+that Aronberg's counsel seeks cannot be applied where, as here, the only basis for fees is Section
+57.105
+As set forth. in more detail, below, the Amended Motion should be denied in its entirety:
+BACKGROUND
+On January 17, 2020; Plaintiff filed a First Amended Complaint [DE 17]
+("Complaint") against State Attorney. Aronberg and the Clerk and Comptroller of Palm Beach.
+County, Florida, Sharon Bock (now Joseph Abruzzo) ("Clerk"), for declaratory relief (Count I)
+and relief under Florida Statutes Section 905.27 (Count II, seeking to obtain access to records
+from the grand jury proceeding and criminal prosecution of the late Jeffrey Epstein, a convicted
+sex offender, by former State Attorney Barry Krischer:
+On January 24, 2020, Aronberg filed an Answer to Count I and a Motion to Dismiss
+Count II ("Aronberg Ariswer") [DE 22]?
+3K
+In his Answer to Count I of the Complaint, Aronberg admitted that Plaintiff sought
+but Defendants "have refused to provide access to testimony, minutes, and other evidence.
+presented in 2006" in the grand jury proceeding. Aronberg Answer, 9 72 [DE 2].
+2 The same day, the Clerk also filed an Answer to Count I and Motion to Dismiss Count II [DE
+3.
+CAVArophers 9148M BEACH COUNTY, FL,
+
+
+4.
+On June 8, 2020, the Court entered an Order Granting the Defendants' Motions to
+Dismiss Count II of Plaintiff's First Amended Complaint With Prejudice [DE 33]. The Order
+specifically did not address the merits of Count I.
+5.
+On: July 1, 2020, Aronberg filed his First Motion seeking sanctions against Plaintiff
+under Florida Statutes Section 57.105. [DE 35].
+6:
+On June 8, 2020, prior to filing his First Motion, Aronberg's attorney (Douglas A.
+Wyler, Esq.) served via email to Plaintiff's counsel an unfiled copy of the First Motion with an
+enclosure letter. The enclosure letter was not filed along with the First. Motion [DE 35], which has
+no exhibits?
+7.
+The June 8, 2020 enclosure letter accompanying the First Motion (but not the First
+Motion itself) alleged in conclusory fashion that Aronberg did not have possession, custody, or
+control of the grand, jury documents sought by Plaintiff. See [DE 45] at Ex. A. Importantly;
+however, there was no evidence in the record to confirm this allegation, and the First Motion did
+not refute or even address the State Attorney's ability to object to or impede attempts by the
+Plaintiff (or any other third party) to seek grand jury documents, whether through the Clerk or
+other means.
+At the time of Aronberg's First Motion for sanctions, which he expressly admitted
+was a "place-marker" motion to the extent he ultimately prèvailed on the merits, no motions for
+summary judgment had been filed and Aronberg had not served any affidavits) or identified any
+evidence relating to this matter or any allegations in the Complaint.
+3 Aronberg later attached the June 8, 2020 enclosure letter as Exhibit A to his October 14, 2020
+Response to Plaintiff's Memorandum of Law in Opposition to the State Attorney's Fla. Stat.
+Section 57. 105 Motion ("Aronberg's October 14, 2020 Reply") [DE. 45].
+1 See Aronberg's October 14, 2020 Reply [DE 45], at.5, 13.
+4
+CA/AropheEs-08149% BEACH COUNTY, FL,
+
+
+9.
+On or about August 18, 2020, Aronberg filed a Motion for Summary Judgment [DE
+38] and an affidavit [DE 39] averring that.he did not have possession or control over the Epstein.
+grand jury materials and had,no authority to demand that the Clerk provide access to the materials;
+This was the first record evidence relating to Aronberg's lack of possession or control of the grand
+jury materials sought by Plaintiff. Notably, Aronberg's affidavit still did not refute or address the
+State Attorney's ability to object to or otherwise impede an aftempt by Plaintiff to seek grand jury
+documents.
+10.
+On October 21, 2020, Aronberg filed a motion to set a hearing on his Motion for
+Summary Judgment [DE 47]. On that same date, Plaintiff filed a Notice of Dropping Party as to
+Aronberg, dismissing him from the case [DE 48].
+1]; Nineteen days after Plaintiff dismissed Aronberg from the action by filing an
+October 21, 2020 notice dropping Aronberg as a party [DE 48], on November 9, 2020, Arönberg
+filed his Amended Motion [DE 50], seeking sanctions under Florida Statutes Section 57.105
+against Plaintiff relating to all fees and costs incurred by Aronberg after June 8, 2020;
+12.
+The Amended Motion, unlike his First "place-marker" Motion filed on: July 1, 2020,
+referenced Aronberg's August 18, 2020 Motion for Summary Judgment and exhibits.
+13.
+Importantly, unlike his First Motion, which was served via email upon Plaintiff's
+counsel. 21 days before filing, Aronberg's Amended Motion was never served via any method. of
+delivery before it was filed on November 9, 2020.
+14.
+On August 12, 2021, Aronberg filed an Amended Memorandum of Law in Support
+of his Amended Motion for Attorneys' Fees. [DE 74].
+15.
+Ás to the Plaintiff's remaining claim against the Clerk, on April 22, 2021, Plaintiff
+filed a motion for summary judgment against the Clerk as to Count I of the Complaint. [DE 58].
+5
+CAVArophers- P1499 BEACH COUNTY, FL,
+
+
+16.
+The hearing on the Plaintiff's motion for summary judgment against the Clerk.as
+to Count I of the Complaint took place on October 22, 2021.
+On December 20, 2021, the Court entered an order on Plaintiff's motion for
+summary judgment. Because the only other count of the Complaint, Count II, had been disposed
+of by Order filed June 7, 2020 [DE 33], the Court's December 20, 2021. order was a final judgment
+in the case ("Final Judgment"), [DE 78].
+On January 27, 2022, Plaintiff filed a notice of appeal as to the Final Jüdgment.
+[DE 83],*
+19.
+The evidentiary hearing on Aronberg's Amended Motion for sanctions is set on the
+Couit's ten-week docket between March 14 and May 20, 2022. [DE 73].
+MEMORANDUM OF LAW
+1.
+LEGAL STANDARD
+Under Section 57.105,, Florida Statutes, the Court may award, reasonable attorneys' fees
+only if it finds that a party or its attomey knew or should have known that a claim or defense when
+initially presented to the Court or at any time before trial was not supported by material facts
+necessary to establish the claim or defense, or would not be supported by the application of thenexisting law to those material facts. To award sanctions, "the trial court must find that there were
+no justiciable issues of law or fact and that the losing party's attorney did not act in good faith
+based on the representations of his or her client." Siegel v
+, 71 So. 3d 205, 211 (Ela 2d DCA
+2011) (quotation omitted).
+Indeed, [w]here there is an arguable basis in law and fact for a party's claim, a trial court:
+may not sanction that party under section 57.105." Minto PBLH, ELC v. 1000 Friends of Florida,
+5 Although the Clerk had previously filed a motion to amend the Final Judgment on January 3,
+2022 [DE 81], the Clerk withdrew the motion to amend on January 26, 2022 [DE 89].
+6
+CAVArOPhED 9149R1 BEACH COUNTY, FL,
+
+
+Inc., 228 So. 3d 147, 149 (Fla. 4th DCA 2017) (citing Kowallek v. Rehm, 189 So. 3d. 262, 263-64
+(Fla. 4th DCA 2016)) (emphasis added). Courts must apply Section 57.105 "with restraint to
+ensure that it serves its intended, purpose of discouraging baseless claims without casting a chilling
+effect on use of the courts." MacAlister v. Bevis Consti:, Inc., 164 So. 3d. 773, 776 (Fla. 2d. DCA
+2015).
+Taking into account the amendments that broadened the statute after 1999, "Florida courts
+have continued to caution that section 57.105 must be carefully applied to ensure that it seives the
+purpose for which it was intended - to deter frivolous pleadings. " MC. Liberty Express, Inc. v. All
+Points Servs;, Inc., 252 So. 3d 397, 403 (Fla. 3d DCA.2018) ("Thus, an award of fees under section.
+57.105 requires more than the moving party succeeding in obtaining a dismissal of the action. or
+the entry of a summary judgment in its favor, ta. and a party does not need to have conclusive
+evidence to prove its case at the time of filing in order to avoid sanctions. Where a party reasonably
+believes the factual basis for its claim exists, it is entitled to proceed with its claims and seek to
+prove those facts. If attempts to prove those facts are fruitless, that is still not cause for sanctions
+where the party's initial belief was well-founded.") (internal citations omitted). Thus, a voluntary
+dismissal does not automatically equate to sanctionable conduct.
+Before awarding sanctions, the trial court must make "explicit findings" that "the action.
+was "frivolous or so dévoid of merit both on the facts and the law as to be completely untenable.'
+This burden is a heavy one" Id. (internal citations omitted) (emphasis added). Additionally,
+the trial court's findings "must be based on substantial competent evidence presented to the court
+at the hearing on attorney's fees or otherwise before the court and in the trial court record." Trust
+Morig: LLC v. Ferlanti, 193 So. 3d.997, 1001 (Fla, 4th DCA. 2016). The trial court "must make
+an inquiry into what the losing party knew or should have known during the fact-establishment
+7
+CAVArophers 9149M BEACH COUNTY, FL,
+
+
+process, both before and after suit was filed." See Chue v. Lehman, 21. So. 3d. 890, 891-92 (Fla.
+4th DCA. 2009).
+11.
+ARONBERG'S AMENDED MOTION MUST BE DENIED FOR FAILURE TO
+COMPLY WITH THE 21-DAY SAFE HARBOR PROVISION IN SECTION
+57.105(4).
+A.
+ARONBERG FAILED TO SERVE 21 DAYS PRIOR TO FILING THE AMENDED
+MOTION ASSERTING NEW ARGUMENTS, IN ViOLATION OF SECTION 57.105(4).
+Aronberg's Amended Motion failed to comply with the 21-day notice provision set forth
+in Florida Statutes Section 57.105(4) and, as a result, the Amended Motion must be denied
+outright. Aronberg's Amended Motion raised arguments not raised in his First Motion, and cited
+evidence not in the record at the time the First Motion was filed, thus. Aronberg was required to
+independently comply with the 21-day safe harbor provision of Section 57,105(4) as to the
+Amended Motion. See Lago v. Kame By Design, LLC, 120 So. Sd 73, 75: (Fla. 4th DCA 2013)
+("We hold that if a party files a subsequent or amended motion for sanctions under section 57.105
+and raises an argument that was not raised in the original motion for section 57,105 sanctions, the
+subsequent motion must independently comply with the twenty-one-day "safe harbor' provision
+of section 57.105(4).")
+Thus, Aronberg's failure to serve the Amended. Motion on Plaintiff at any time prior to
+filing it, alone, requires denial of the Amended Motion. See id: As the Fourth District Court of
+Appeal. noted in Lago, "[tlo hold otherwise would allow a party to raise a new ground for sanctions
+in a subsequent motion under section 57:105 without giving the other side the opportunity to
+withdraw the offending claim or defense within twenty-one days after receiving notice of the new
+6 There is at least one instance where Florida Epstein grand jury materials have been disclosed,
+though who did so, when and how they were disclosed is not presently known. The United States
+Department of Justice acknowledges that Florida Epstein grand jury materials are in its possession.
+See Plaintiff's Motion for Summary Judgment, 1 76 [DE 58].
+8
+CAVAropherg°9149R1 BEACH COUNTY, FL,
+
+
+ground for sanctions." 120 So. 3d at 75; see also Moore y. Estate of Albee by Benzenhafer, 239
+So. 3d 192, 195, n.2 (Fla. 5th DCA. 2018) (court could not consider amended motion for section
+57,105 fees because it raised additional grounds for sanctions not raised in the defendant's prior
+motion for fees and there was "no indication that [defendant] complied with the twenty-one-day
+"safe harbor' provision of section 57.105(4)") (citing Lago, 120 So. 3d at 75);
+y. Garcia,
+147 So: 3d $69, 572 (Fla, 3d DCA 2014) (also citing Lago, and denying motion for section 57.105
+fees on other grounds and "find[ing] it significant" that the defendant's motion for 57,105 fees did
+not allege qualified immunity—the defense which was successful on the merits--as a grounds for
+entitlement to an award of fees).
+Because Aronberg's barebones First Motion did not include the substantive arguments nor
+cite any evidence later raised in the Amended Motion, Aronberg was required to serve the
+Amended Motion at least 21 days before filing same, in örder to give Plaintiff the opportunity to
+withdraw the count that remained against Aronberg (Count I). The Amended Motion was filed in
+violation of Section 57. 105(4) and should be denied.
+B.
+THE COURT CANNOT CONSIDER THE AMENDED MOTION FOR SANCTIONS
+BECAUSE IT WAS FILED AFTER ARONBERG WAS DISMISSED AS A PARTY FROM
+THE ACTION.
+On November 9, 2020, Aronberg filed the Amended Motion seeking sanctions against
+Plaintiff relating to Count I of the Complaint against him. However, the entire action, which
+necessarily included Count I, was dismissed as to Aronberg on October 21, 2020, nineieen days
+before Aronberg filed his Amended Motion. [DE 48, 50]. Because, at the time Aronberg filed the
+Amended Motion, Aronberg had already been dismissed as a party, the Court does not have
+jurisdiction over and cannot consider the later-filed. Amended Motion. See Sidlosca v. Olympus
+Ins. Co., 276 So. 3d 987, 989 (Fla. 3d DCA 2019) ("Because entitlement to fees was premised
+upon a motion for sanctions filed after the voluntary dismissal, and it is well-established that a
+9
+CA Arophere 91493 BEACH COUNTY, FL,
+
+
+trial court has continuing jurisdiction to consider a section 57.105 motion for sanctions only where
+the motion for sanction was filed with the court before a voluntary dismissal, we are constrained
+to reverse and remand" the trial court's award of fees under section 57:105) (quoting Lago, 120
+So. 3d at 74, where the court stated that "[b]ecause appellee's second motion for section 57.105
+sanctions did not comply with the twenty-one-day safe harbor' provision of section 57.105(4),
+the trial court erred in granting that motion."); see also Pino v: Bank of N.Y., 121 So. 3d 23, 42
+(Fla. 2013) (in light of the 21-day safe harbor provision under Fed. R. Civ. P. 11, which is. "nearly
+identical" to and interpreted as Fla. Stat, § 57.105(4), the motion for sanctions at issue must be
+submitted prior to dismissal of the claim for the court to have jurisdietion, as the safe harbor
+provision allows the party to withdraw the offending pleading):
+Plaintiff's prior dismissal of Aronberg as a party means that the Court does not have
+jurisdiction to consider the later-filed Amended Motion for sanctions. As a result, the Amended
+Motion should be denied
+C.
+ARONBERG's SELF-DESCRIBED "PLACE-MARKER" FIRST MOTION FOR
+SANCTIONS WAS INSUFFICIENT AND DID NOT ABSOLVE ARONBERG OF THE
+REQUIREMENT TO SERVE THE AMENDED MOTION PRIOR TO FILING.
+Aronberg. specifically admitted that his First Motion for sanctions under Florida Statutes
+Section 57,105 was filed as a "place-marker" to "notify Plaintiff of the State Attorney's intention
+to seek sanctions should he prevail on the merits at a future substantive hearing. " See Aronberg's
+October 14, 2020 Reply [DE 45], at 5, 13 ("The 57:105 Motion was filed... to further put the
+Plaintiff on notice that the State Attorney would seek sanctions should he prevail on the merits of
+the lawsuit.").
+The First Motion for sanctions was insufficient under Section 57.105 when filed - it set
+forth no substantive arguments as to why Count I of the Amended Complaint was, insupportable
+based on material facts in the record or the application of existing law to those facts. Rather, at the:
+CA/Arophere 91494 BEACH COUNTY, FL,
+
+
+time the First Motion was filed, there was no evidence in the record supporting the statement by
+Aronberg's counsel that it was impossible for him or the State Attorney's Office to provide the
+documents sought in the Complaint.
+Essentially, what Aronberg argued in his "place-marker" First Motion is that if he prevailed
+in defending the lawsuit, his attorneys" fees should be awarded as sanctions against Plaintiff in his
+favor? There is no such mechanism as a "place-marker" motion for sanctions: Otherwise, any
+defendant could file a threadbare and conclusory "place-marker" notice of his intent to seek fees
+if he ultimately prevails, and then seek fees based on later-filed evidence and arguments. A motion
+for sanctions must be supported by the record evidence at the time it is filed. Because the First
+Motion was not so supported, it fails under the statute. Further, as explained above, service of the
+First Motion did not absolve Aronberg of his obligation to serve the Amended Motion on Plaintiff
+through counsel prior to filing the Amended Motion. The First Motion cannot be a "place-marker"
+for the mandated service of the Amended Motion under Section 57.105(4).:
+II. STATE ATTORNEY ARONBERG WAS A PROPER PARTY.
+The material facts in the Tecord at all times supported Plaintiff's claim against Aronberg
+When Count I was filed, and throughout the litigation prior to Aronberg's dismissal, Plaintiff had
+a good faith basis for understanding that the State Attorney's Office had either access to, control
+över, or the ability to impinge, prevent, or thwart Plaintiff's attempts to obtain public accéss to the
+Epstein grand jury materials. See, e.g.y Ferlanti, 193 So, 3d at 1000 (reversing trial court's award
+of 57.105 fees for naming husband as defendant in mortgage foreclosure proceeding, even though
+husband was never a signatory to mortgage or note and plaintiff made no such allegations, but:
+"Aronberg's "place-marker" First Motion appeared to be based erroneously on a prevailing party
+standard (see Reply, at 5, 13), which is not the applicable standard for imposing sanctions expressly
+set forth in Section 57.105.
+CA Arophers 0914951 BEACH COUNTY, FL,
+
+
+there was at least some triable set of facts under which defendant could have been liable); see also
+Grove Key Marina, LI.C. v. Casamayor, 166 So. 3d 879, 885-86 (Fla. 3d DCA 2015) (affirming
+denial of section 57,105 motion for fees even though lessees prevailed in defeating the county"s
+claim against them for unpaid taxes, as the law at issue was a complicated matter, the county
+"simply covered its bases," and the county's position that it could take remedial action against the
+lessees even after it became clear that the city, not the lessees, owed the taxes, "while novel, [was]
+not completely unreasonable.").
+Nowhere in the record did Aronberg eyer refute his office's ability to object to or otherwise
+impede atfempts by the Newspaper to seek grand jury materials. While Aroriberg's August 18,
+2020 affidavit filed with his Motion for Summary Judgment averred that he did. not have
+possession or control over the Epstein grand jury erials, his affidavit was notably silent as to
+whether the State Attorney could or would seek to intervene in or object to the Newspaper's
+attempts to obtain the: Epstein grand jury materials. See [DE 38, 39]. On October 21, 2020, when
+Aronberg filed a motion to set a hearing on his Motion for Summary Judgment, Plaintiff made the
+strategic decision to dismiss Aronberg as a party from the action, despite it still having a substantial
+good faith basis to keep Aronberg in the case even at that point. See [DE 47, 48]%
+As State Attorney, Aronberg was not named in this action solely as a custodian of the grand
+jury records. Rather, he was a defendant in his official capacity because; his office has "as its
+& It is also worth noting that while Aronberg alleged in the June 8, 2020 enclosure letter to his First
+Motion that his office did not have physical possession of the Epstein grand jury materials, h
+lévertheless argued in that same letter, relying on Séction 905.27, that thé Clerk should no
+produce them. By taking a position against disclosure, Aronberg, in effect, asserted his right to the
+secrecy of the Epstein grand jury materials Stated another way, Aronberg claimed the statutory
+right for the State Attorney's Office to prevent access to the Epstein grand jury materials, a position
+which actually supported the propriety of naming him, in his official capacity, as a party defendant
+in this action.
+12.
+CA/Arophers 814961 BEACH COUNTY, FL,
+
+
+primary interest the protection of its grand jury system." In re Grand Jury Proceedings, 832 F. 2d
+554, 559 (1.1th Cir. 1987) (italics in original). In that case, the federal government petitioned. a
+Florida State Attomey to turn over state grand jury transcripts. In opposition, the Broward County
+State Attorney argued against their release, citing to Section 905.27. Later, a federal grand jury
+served a subpoena upon the same State Attorney seeking grand jury transcripts. The State Attorney
+advised the federal court that he would produce the transcripts, thereby demonstrating that
+irrespective of physical possession, he had legal authority to obtain and deliver them pursuant to
+the subpoena. For these same reasons, State Attorney Aronberg, in his official capacity, was a
+necessary party, at the very least as a nominal defendant.
+Plaintiff had a legitimate and good faith basis to name Aronberg in his capacity as the Stäte
+Attorney as a party defendant and to include him in the lawsuit, As the public official charged with
+protecting the grand jury process, the State Attorney was a necessary party, and he would have.
+had the right to intervene as a defendant even if he was not named as a party in the Complaint. As
+the Court noted in the Final Judgment, the State Attorney had been dismissed and "there have been
+no attempts fo intervene in this case to take a position against disclosure" of the grand jury
+materials: See [DE 78, pp. 2-3].
+Further, even assuming the State Attorney did not have physical possession, Florida law
+does not prohibit his office from requesting the Epstein grand jury materials from the Clerk.
+Indeed, ás the State Attorney is well aware, Florida Statutes Chapter 905 does not bar any State:
+Attorney from accessing grand jury materials, even after a defendant has been convicted and
+sentenced.
+13
+CAVArOPED 811% BEACH COUNTY, FL,
+
+
+IV.
+THE ISSUES RAISED IN COUNTI OF THE COMPLAINT WERE A MATTER
+OF FIRST IMPRESSION, WERE NOVEL AND COMPLEX AND PRESENTED A
+GOOD FAITH ARGUMENT FOR THE INTERPRETATION OF EXISTING LAW
+OR ESTABLISHMENT OF NEW LAW, THUS SANCTIONS ARE NOT
+APPROPRIATE.
+A. ARONBERG CANNOT SATISFY THE REQUIREMENTS OF SECTION 57.105(1).
+Sanctions are plainly inappropriate under Section 57,105(1) where, as here, a good faith
+basis exists for a proposed interpretation of the law applied to the material facts. See Fla: Stat.
+§ 57.105(1). Nothing in the record supports Aronberg's position that the Newspaper's claim for
+declaratory relief in Count I lacked good faith and was unsupported by fact or law? Tọ the
+contrary, even the Court's Final Judgment described the Newspaper's arguments as "strong,"
+"sincere," "palatable and persuasive," and noted that the Newspaper's position was supported. by
+case law from other jurisdictions, See, e.g. [DE 78], at p. 5, p. 7 (The Newspaper makes strong
+arguments to advance its more expansive construction.
+..") p. 9 ("'The Newspaper provides
+several passages from state and federal cases
+"), p: 1l (the court acknowledges the
+Newspaper's vibrant and sincere arguments"). The Court went so far as to "commen[d] both
+parties' attorneys for their exceptional oral and written presentations." Id. at p. 13.
+Moreover, the Court noted this was a case of "first impression," which "implicate[d] issues
+of constitutional import regarding the historic tension between grand jury secrecy and the First
+Amendment," in the context of "genuine subjects of public interest and concern." Id. atip. 5. There
+" Aronberg's November 9, 2020 Amended Motion appears to relate only to Count I of the
+Complaint (although, as set forth above, no count was pending against Aronberg as of October 21,
+2020). While Count II alleged that the Newspaper has constitutional and statutory standing to
+overcome grand jury secrecy provisions "in furtherance of justice," Count I, in contrast, did not
+allege a Section 905.27 private right of action. Instead, Count I sought declaratory relief under the
+U.S. Constitution's First Amendment and the Florida Constitution's analogous provisions. As to
+Count II, Plaintiff presented various reasoned arguments why Section 905.27 creates a private right.
+of action in favor of the media on both constitutional, and statutory grounds. See Plaintiff's
+Opposition.to Aronberg's Motion to Dismiss Count II of the First. Amended Complaint; [DE.26]
+at pp. 10-15
+14
+CAVAropheEss091493 BEACH COUNTY, FL,
+
+
+is no basis, for Aronberg's position that Plaintiff's claim was devoid of merit both on, the facts and
+law as to be completely untenable, in this case of first impression, involving important
+constitutional issues. See MC Liberty Express, 252 So. 3d at 403, Where a claim presents novel
+and complex issues, such as here, sanctions under Section 57.105(1) are not appropriate. See Grove
+Key Marina, LEC v. Casamayor, 166 So. 3d 879, 885-86 (Fla. 3d DCA 2015). Requesting a ruling.
+on an issue of first impression, by its very nature, is a good-faith effort to interpret or extend
+existing law—and is not baseless or unsupported. It is Aronberg's continued position seeking
+sanctions, not Plaintiff's claim, that iș baseless.
+Unlike the State Atforney or the Clerk, who did not cite to any case that previously resolved
+the issues presented relating to the media's implied private right of action under: Florida Stätutes
+Section 905.27 (as alleged in Count II) or for declaratory relief to obtain grand jury materials (as
+alleged in Count. I), Plaintiff cited federal case and, other state court cases in which the courts
+granted disclosure of grand jury materials like those sought here. Plaintiff appropriately relied
+upon such authorities in its prior filings in this matter to argue that the Constitutional provisions
+and interpretive case law, along with Florida Statutes Section 905.27, provided ample grounds, for
+the Court to direct the release of the Epstein grand jury materials to the Newspaper as a surrogate
+for the public, or to require the Court to conduct an in camera examination of the same, to balance
+the public's right to know through a free media with Florida's qualified statutory interest in grand.
+jury secrecy. See, e.g., First Amended Complaint [DE 17], at 15-19; Plaintiff's Opposition to.
+Aronberg's Motion to Dismiss Count II of the First Amended Complaint [DE 26], at 10-20;
+Plaintiff's Memorandum of Law in Opposition to Aronberg's First Motion [DE 43], at 5-7. In
+short, Plaintiff proposed a good faith interpretation of existing law in support of its declaratory
+relief claim in Count I.
+15
+CAVArophers 914901 BEACH COUNTY, FL,
+
+
+:
+B.
+THE EXCEPTION FROM SANCTIONS UNDER SECTION 57.105(3)(A) APPLIES
+HERE.
+Even in the absence of supportive law properly relied upon by Plaintiff, "[a]n award of fees
+pursuant to section 57:105 is inappropriate when a party makes a good-faith, effort to change an
+existing rule of law," and in such a circumstance, Section 57.105(3)(a) provides an explicit
+exception from sanctions. See
+602 So. 2d 644, 646 (Fla. 2d DCA 1999) (trial court
+abused its discretion in awarding fees against plaintiff's attorney who swore in an affidavit that he
+filed a subsequent action in a good-faith effort to change the law regarding the doctrine: of
+interspousal immunity to argue the court should create an exception to the doctrine); Key Biscayne
+Gateway Partners, Lid. v. Village Council for Village of Key Biscayne, 240 So. 3d 84, 87 (Fla. 3d
+DCA 2018) (reversing order of sanctions under 57, 105 as good faith argument was presented for
+extension of existing law with reasonable expectation of success).
+Specifically, Section 57.105(3)(a) mandates that monetary sanctions shall hot be awarded
+if the court determines that the claim or defense was initially
+presented to the court as a good faith argument for the extension,
+modification, or reversal of existing law or the establishment of new
+Law, as it applied to the material facts, with a reasonable expectation
+of success.
+Fla. Stat. § 57.105(3)(a) (emphasis added).
+At the very least, Plaintiff provided a good-faith argument for the extension or modification
+of existing law or the establishment of new law, and thus sanctions are not appropriate under
+Section 57.105(3)(a). See also Final Judgment, pp. 12-13 ("Perhaps the circumstances presented
+above will induce the Legislature to amend section 905.27 to grant thé courts additional authority
+or leeway in ruling on unique cases such as this one. ... Until that time, this court is bound by the
+fundamental doctrines of statutory construction, separation of powers and stare decisis to rule
+according to het law as it exists today.")
+16
+CA/Aropher99915901 BEACH COUNTY, FL,
+
+
+The Amended Motion for sanctions should be denied based on the express provisions of
+Section. 57.105(1)(a)-(b) and the exception set forth in Section 57.105(3)(a).
+V.
+THE AMOUNT OF FEES SOUGHT, INCLUDING A MULTIPLIER, IS NOT
+APPROPRIATE.
+No amount of fees may be awarded as sanctions under Section 57:105. Even assuming,
+arguendo, that Aronberg somehow met the technical 21-day safe harbor notice requirement and
+could satisfy the heavy burden under Section 57.105(1), which he did not and cannot, the
+contingency risk multiplier sought by his counsel cannot be applied as a matter of law:
+The State Attorney's counsel, Douglas A. Wyler, Esq., was hired pursuant to a retainer
+agreement, which is attached as Exhibit G to the Amended Motion [DE 50]. The retainer
+agreement provided that fees would be paid to Mr. Wyler and his firm only if attorneys' fees were:
+awarded to the State Attorney pursuant to a court order, [DE, 50], at Ex: G ("You will not be liable
+of required to pay any monies to our office unless we are successful in our representation of you
+in the above-referenced litigation and receive a court order awarding attorneys? fees."). However,
+Aronberg, did not file a counterclaim or any other affirmative claims seeking monetary damages
+in the litigation. And the causes of action. in the Plaintiff's conplaints (for declaratory judgment
+and for relief under Chapter 905, Florida Statutes) did not provide any basis for an award of
+attorneys' fees or the shifting of fees for a prevailing party. Thus, the only basis for attorneys' fees
+was through sanctions under Section 57.105, Florida Statutes.
+It is well-settled under Florida law that a contingency risk multiplier, as sought by
+Aronberg's counsel here, cannot be applied where the only basis for fees is sanctions under Section
+57,105. See, e.g.» Swortz v. Southern Rainbow Corp., 603 So. 2d 107, 108 (Fla, 3d DCA 1992)
+("[W]hen a case is so patently frivolous as to cause counsel to represent his or her client for a fee
+that is solely contingent upon a section 57.105 récovery, it cannot reasonably be treated as
+17
+CAVArophers: 8159M BEACH COUNTY, FL,
+
+
+=
+involving a risk that would support a multiplier.") (citing Transflorida Bank V.
+576 So. 2d
+752, 754 (Fla. 4th DCA 1991)); see also
+v. Mèrkle, 646 So: 2d 289, 290 (Fla. 2d DCA
+1994) (holding it was error to apply a contingency risk multiplier to an award of fees based on
+Section. 57.105, and reversing as to the amount of the multiplier); see also Wolfe v. Nazaire, 758
+So. 2d 730, 733 (Fla. 4th DCA 2000) (reversing and remanding trial court's award of fees where
+court did not explain its reasons for award using a multiplier, as the court is required to state the
+ground on which it justifies the enhancement or reduction of'fees):
+The multiplier sought by Aronberg's counsel cannot be awarded as a matter of law, Beyond
+that, Plaintiff objects to any and all amounts of fees sought by Aronberg's counsel and requires
+strict proof of the reasonableness of those fees at the evidentiary hearing. No fees aré appropriate
+under Section 57.105.
+CONCLUSIÓN
+Based on the foregoing, Plaintiff, CA Florida Holdings, LLC, publisher of The Palm Beach
+Post, respectfully requests that the Court deny State Attorney Dave Aronberg's Amended Motion
+for Attorneys' Fees in its entirety, with prejudice, and grant such other and further relief as the
+Court deems necessary or proper,
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LEC,
+Publisher of The Palm Beach Post
+Is/ Lauren Whetstone:
+LAUREN WHETSTONE
+Florida Bar No. 45.192
+MARK F. BIDEAU İ
+Florida Bar No. 564044
+REENBERG TRAURIG, P.A
+77 South Flagler Drive, Suité 300 Eas
+West Palm Beach, FL 33401
+CAVAropheES 9159R BEACH COUNTY, FL, L
+
+
+Tel.: 561.650.7900
+whetstonel@gtlaw.com
+bideauin@gtlaw.com
+sandra.famadas@gtlaw.com
+thomasd@gtlaw.com/
+ELService@gtlaw.com
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+GREENBERG TRAURIG, P.A.
+401 East Las Olas Boulevard, Suite 2000
+Fort Lauderdale, FL, 3330K
+Tel.: 954.768.8225
+mendelsohns@gtlaw.com
+smithl@gtlaw.com
+MICHAEL J, GRYGIEL
+(Admitted Pro Hac Vice)
+GREENBERG TRAURIC, P.A.
+54 State Street, 6th Floor
+Albany, NY 12207
+Tel.: $18:689.1400
+grygielm@gtlaw.com
+NINA D. BOYAJAN
+(Admitted Pro Hac Vice)
+GREENBERG TRAURIG, P.A.
+1840 Century Park East, Suite 1900
+Los Angeles, CA 90067
+Tel.: 310:586.7700
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 24th day of February; 2022, a true and correct copy of
+I A CER
+the foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system,
+which will send a noticê of electronic service for all parties of record herein.
+Is/ Lauren Whetstone; Esq.
+Lauren Whetstone, Esq.
+CAVAropheEs 91593 BEACH COUNTY, FL,
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/dfcc1c03ecb7c04abff17263206accc4af82ed4a71a1c548f414df3a34b1dd17.md b/vision-fixhub/court-01/dfcc1c03ecb7c04abff17263206accc4af82ed4a71a1c548f414df3a34b1dd17.md
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+Case 9:08-CV-80994-KAM Document 7 Entered on FLSD Docket 10/09/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80994-CIV-MARRA
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendants.
+ORDER REQUIRING COUNSEL TO CONFER, FILE JOINT SCHEDULING REPORT
+AND FILE JOINT DISCOVERY REPORT
+THIS ORDER has been entered upon the filing of the complaint. Plaintiff's counsel is
+hereby ORDERED to forward to all defendants, upon receipt of either an answer or a motion
+pursuant to Fed. R. Civ. P. 12(b), a copy of this order.
+It is further ORDERED:
+1. Every motion when filed shall be accompanied by a proposed order, except that
+motions to dismiss and motions for summary judgment need not be accompanied by a proposed
+order.
+2. Pretrial discovery in this case shall be conducted in accord with Local Rule 16.1 and
+Rule 26 of the Federal Rules of Civil Procedure.
+3. Pursuant to Rule 26(f) of the Federal Rules of Civil Procedure, unless this action is
+excluded under Rule 26(a)(1)(E), the parties must confer within twenty-one (21) days after the
+last responding party either files an answer or a motion pursuant to Fed. R. Civ. P. 12(b),
+whichever is earlier, to consider the nature and basis of their claims and defenses and the
+possibilities for a prompt settlement or resolution of the case, to make or arrange for the
+disclosures required by Rule 26(a)(1), and to develop a proposed discovery plan that indicates the
+
+
+Case 9:08-cv-80994-KAM Document 7 Entered on FLSD Docket 10/09/2008 Page 2 of 2
+parties" views and proposals concerning the matters listed in Rule 26(f).
+4. The parties are jointly responsible for submitting a written report of this conference
+outlining the proposed discovery plan within 14 days after the conference.
+5. Counsel for the parties shall hold a scheduling conference either at the same time as
+the discovery conference described in Rule 26(f) or within fourteen (14) calendar days thereafter.
+See Local Rule 16.I(B).
+6. Within fourteen (14) days of the scheduling conference, counsel shall file a joint
+scheduling report pursuant to Local Rule 16.1(B)(2). This report shall indicate the proposed
+month and year for the trial plus the estimated number of trial days required, as well as an
+indication of whether the trial is to be a jury trial or bench trial.
+7. The parties may submit a single report combining the discovery plan report and the
+scheduling conference report.
+8. Failure of counsel or unrepresented parties to file a discovery plan report or joint
+scheduling report may result in dismissal, default, and the imposition of other sanctions including
+attorney's fees and costs.
+DONE AND SIGNED in
+at West Palm Beach, Palm Beach County, Florida,
+this 8" day of October, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+All counsel
+2
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diff --git a/vision-fixhub/court-01/dfd8482565c730edde074ddc2edde8fa85e2bfd80922eac9e170758720a5bd42.md b/vision-fixhub/court-01/dfd8482565c730edde074ddc2edde8fa85e2bfd80922eac9e170758720a5bd42.md
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@@ -0,0 +1,45 @@
+Case 1:19-cv-10577-LJL-DCF Document 38 Filed 03/23/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Case No. 1:19-cv-10577-LJL-DCF
+Plaintiff,
+-against-
+DARREN I INDYKE and RICHARD D.KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY EDWARD EPSTEIN,
+Defendant.
+NOTICE OF CHANGE OF ADDRESS
+TO:
+ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES
+I have cases pending
+I have no cases pending
+Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for:
+Mary "Molly" S. DiRago
+FILL IN ATTORNEY NAME
+_ My State Bar Number is _6282757
+My SDNY Bar Number is:
+1am,
+•
+An attorney
+A Government Agency attorney
+A Pro Hac Vice attorney
+FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number):
+OLD FIRM:
+FIRM NAME: TROUTMAN SANDERS LLP
+FIRM ADDRESS: One North Wacker Drive, Suite 2905 Chicago, IL 60606
+FIRM TELEPHONE NUMBER: 3121759-1926
+FIRM FAX NUMBER: 1712759-1939
+NEW FIRM:
+FIRM NAME: TROUTMAN SANDERS LLP
+FIRM ADDRESS: 227 W. Monroe Street, Suite 3900, Chicago, IL 60606.
+FIRM TELEPHONE NUMBER: 13121759-1928
+FIRM FAX NUMBER: 312759-1939
+I will continue to be counsel of record on the above-entitled case at my new firm/agency.
+•
+I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance
+was entered on
+by Judge
+Dated: 03/20/2020
+Is/ Mary "Molly" S. DiRago
+ATTORNEY'S SIGNATURE
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+  "doc_id": "dfd8482565c730edde074ddc2edde8fa85e2bfd80922eac9e170758720a5bd42",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "77079b314e11a3c9d81e3b48ff3d192d15129abbce23eaeecd248ea60a6c382d",
+  "output_sha256": "d98dc02217008cbe16fb9b32d08a1c916ea373104cccfa345081e1e0a1539268",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.md b/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.md
new file mode 100644
index 0000000000000000000000000000000000000000..ba63365bb9e654550892bc62a0f897b7f3050cca
--- /dev/null
+++ b/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.md
@@ -0,0 +1,82 @@
+Case 9:08-cv-80119-KAM Document 229-2 Entered on FLSD Docket 07/29/2009 Page 1 of 3
+AFFIDAVIT OF RYAN C.W.
+M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+c.w.L
+On this day personally appeared before me, the undersigned authority, Ryan
+M.D., who, being by me first duly sworn under oath deposes and says:
+My name is Ryan C.W.
+M.D. I am over the age of majority, and
+make this affidavit and declaration upon the basis of personal knowledge
+of the factual matters contained herein.
+2.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 2008.
+3.
+4.
+I, also, currently serve as an Affiliate Instructor of the Department of
+Psychiatry and Behavioral Medicine at the University of South Florida,
+Tampa, Florida, and Assistant Professor of the University of Central
+Florida College of Medicine.
+I received my undergraduate degree from the Johns
+University
+and medical degree from the Georgetown University.
+I have been requested to perform an Independent Medical Examination.
+Scope of examination: Time: 9 am, 8/20/09
+EXHIBT B,
+
+
+Case 9:08-cv-80119-KAM Document 229-2 Entered on FLSD Docket 07/29/2009 Page 2 of 3
+Place: Burman, Critton, Luttier & Coleman, 515 N. Flagler Dr, Ste. 400,
+West Palm Beach, FL 33401
+7. Manner: Face-to-face Independent Medical/Psychiatric Examination
+8. Duration: Anticipated 6-8 hours
+9. Conditions: Exam to take place with only evaluator and evaluee in the
+room with the evaluation being videotaped with appropriate audio and
+visual recordings.
+10.
+Scope: Full medical and psychiatric history, including chief complaint,
+history of present illness, specific complaints of symptoms or injury,
+medical history, past psychiatric history, family history, abuse history,
+birth history, childhood history, school history, occupational history,
+violence history, legal history, relationship history, substance use history,
+sexual history, review of systems, activities of daily living, mental status
+examination, diagnoses using DSM-IV axes, and discussion of case
+findings and opinions.
+11.
+Psychological tests and questionnaires: Zung Depression Scale, Zung
+Anxiety Scale, Mini Mental State Examination, MCMI-II, MMPI -2 with
+forensic implications, Life History Questionnaire, and Forensic
+Questionnaire.
+2
+
+
+Case 9:08-cv-80119-KAM Document 229-2 Entered on FLSD Docket 07/29/2009 Page 3 of 3
+No opinion of mine has ever been disqualified in a legal proceeding.
+I declare under penalty and perjury that the foregoing is true and correct.
+12.
+13.
+Executed this 29 day of July
+2009, in Lake Mary, Florida.
+Now cropall MD
+RYAN C.W
+L, M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+BEFORE ME, the undersigned authority, personally appeared RYAN C.W.
+-. M.D., who is () personally known to me or () who has produced
+as identification, and who did take an oath, deposes and says
+that the attached Affidavit is true and correct to the best of his knowledge and belief.
+SWORN TO AND SUBSCRIBED before me on this 29th day of
+July
+, 2009.
+Marcia f. Appar
+Jotary Publi
+Printed Name:
+My Commission Expires:
+•MARCIA CHAPMAN'*
+Comm# DD0561004
+Expires 6/6/2010
+Florida Notary Assn., Inc
+3
diff --git a/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.receipt.json b/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..98825199fa456a2ef71641df32b3a514b7627d8b
--- /dev/null
+++ b/vision-fixhub/court-01/e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "e0066547bbdd44df0450a76b5faf2331ad732d5cb5c8af378e2d875f5e25a118",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0a4586a4f60f4ab8c938c116a2f21fdcfb94d057024ad85716cf654e35620abc",
+  "output_sha256": "6602e55f24a4c0619a4ff0112858abf53020637246ea395571a074cfae3b53ba",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.md b/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.md
new file mode 100644
index 0000000000000000000000000000000000000000..86686bf612bd418cacbfe73e03360e75bd7f358f
--- /dev/null
+++ b/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.md
@@ -0,0 +1,181 @@
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFF JANE DOE NO. 4'S SECOND MOTION FOR
+PROTECTIVE ORDER AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 4, by and through undersigned counsel, hereby files this Second
+Motion for Protective Order and Incorporated Memorandum of Law, and states as follows:
+Defendant, Jeffrey Epstein ("Epstein") has scheduled the deposition of Jane Doe
+No. 4 for October 27, 2009 at 11 p.m.
+2.
+Jane Doe No. 4 does not oppose the taking of her deposition, but instead objects
+to her deposition taking place without adequate precautions to ensure that Jeffrey Epstein does
+not repeat the offensive conduct he engaged in on September 16, 2009 when Jane Doe No. 4 first
+appeared for her deposition. (D.E. 306).
+Jeffrey Epstein crossed paths with Jane Doe No. 4 and terrorized her immediately
+before her last scheduled deposition on September 16, 2009, despite a prior written stipulation
+between the parties that Epstein would not attend the depositions, nor be seen by the Plaintiffs,
+including Jane Doe No. 4, at their depositions. (D.E. 306, Ex. 3).
+1
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 2 of 7
+4.
+Jane Doe No. 4 now seeks an Order in advance of the deposition directing that
+Jeffrey Epstein not attend the deposition of Jane Doe No. 4 or make himself seen by Jane Doe
+No. 4 at her deposition, or else automatic sanctions will be entered against Epstein. Epstein has
+refused such an order.
+5.
+Prior to the last scheduled deposition of Jane Doe No. 4 on September 16, 2009,
+the Plaintiffs filed a Motion for Protective Order to preclude Jeffrey Epstein from attending the
+depositions of the Plaintiffs. (D.E. 292). The Motion was filed for the specific purpose of
+preventing Epstein from intimidating or harassing the Plaintiffs as he has repeatedly done in the
+past. (D.E. 292). As the Motion had not been adjudicated prior to the deposition of Jane Doe
+No. 4, Plaintiff's counsel stipulated with defense counsel that "Jeffrey Epstein will not attend the
+deposition of Jane Doe No. 4." (D.E. 306). It was further stipulated under no circumstances was
+Epstein to be seen by Jane Doe No. 4 at her deposition. (D.E. 306). These were express
+conditions agreed to by Epstein's counsel before Jane Doe No. 4 appeared for deposition on
+September 16, 2009 at 1:00 p.m. (D.E. 306).
+6.
+At approximately 1:00 p.m. on September 16, 2009, Jane Doe No. 4 and her
+counsel were walking in the lobby of 250 Australian Ave South, Suite 115, West Palm Beach,
+Florida, toward the ground-floor conference room where her deposition was to be held. Just a
+few feet away from this conference room, Epstein crossed paths with Jane Doe No. 4. Epstein
+stopped walking and began staring at her. He intimidated her until she began to cry. Jeffrey
+Epstein made no immediate attempt to walk away from the Plaintiff. Instead, he stopped and
+continued to stare at her until she ran away. Jane Doe No. 4 became an emotional wreck upon
+this encounter. As a result of her distress, Jane Doe No. 4 did not sit for deposition and left the
+2
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 3 of 7
+building, but only after her counsel assured her that Epstein was not waiting for her in the
+parking ramp. (D.E. 306).
+7.
+In addition to violating the Stipulation between the parties, Jeffrey Epstein's
+contact with and intimidation of Jane Doe No. 4 is a clear violation of this Court's No-Contact
+Order dated July 31, 2009. In that Order, this Court stated that Jeffrey Epstein shall have no
+"direct or indirect contact" with the Plaintiffs. (D.E. 238). The July 31, 2009 Order mirrored the
+June 30, 2008 criminal court order entered by Palm Beach Circuit Court Judge Deborah Dale
+Pucillio, wherein she ordered Epstein to have "no direct or indirect contact" with the Plaintiffs.
+(D.E. 238).
+8.
+The Motions for Protective Order and Motion for Sanctions that resulted from
+Jeffrey Epstein's reckless conduct remain pending before this Court. (D.E. 306). In the Motion
+for Protective Order, Plaintiff requested an Order preventing Jeffrey Epstein from attending in
+person the depositions of all Plaintiffs, directing that any depositions of Plaintiffs in the future be
+at a court reporter's office selected by Plaintiffs' counsel, and that a special
+be appointed
+to preside at Plaintiffs' depositions and control the proceedings, at Epstein's expense. (D.E. 306).
+Although these motions remain pending, Epstein has insisted on scheduling the
+deposition of Jane Doe No. 4 for October 27, 2009. Plaintiffs' counsel advised Defendant's
+counsel that since the motions for protective order were still pending, counsel would only
+produce Jane Doe No. 4 and other Plaintiffs for deposition upon an agreed order directing that
+(1) Epstein not attend the depositions of the Plaintiffs; (2) a sanction be entered against Epstein if
+he does attend any deposition of a Plaintiff which provides that Epstein may not take that
+Plaintiff's deposition, and (3) the depositions will be held in a neutral location, which does not
+include Epstein's office building.
+3
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 4 of 7
+10.
+Epstein refuses to allow the deposition to take place anywhere other than in his
+office building. Attorneys for Jane Doe No. 4 suggested using a court reporter's office in the
+same building where Epstein's defense counsel is located. He refused. Yet Epstein has not
+shown why he is prejudiced by holding the deposition of Jane Doe No. 4 in any West Palm
+Beach location other than his very own office building. If anything, Jane Doe No. 4 will be
+traumatized by being forced to go to the same location where she was already re-victimized by
+Epstein.
+11. Epstein also refused to agree to a self-executing sanction in the event he again
+appears at Jane Doe No. 4's deposition, despite the fact that it is entirely within his control
+whether to make himself seen by the plaintiff at her deposition. Thus, Epstein should have little
+to worry about unless he plans to terrorize Jane Doe No. 4 before her deposition again. Without
+a self-executing sanction, the parties are in the same place they were before the September 16,
+2009 deposition of Jane Doe No. 4: in agreement on a stipulation that Epstein clearly deems
+worthless.
+As has been well-documented, Epstein flagrantly violated that stipulation. Given
+Jeffrey Epstein's status as a felon and registered sex offender, as well as his prior violations of
+two No-Contact Orders and the written stipulation of the parties, a protective order with selfexecuting sanctions is absolutely necessary in advance of the scheduled deposition to ensure
+Epstein does not repeat his reckless and abusive behavior. His blatant refusal to let the deposition
+take place anywhere other than in his office building makes it even more apparent that he has
+every intention of terrorizing Jane Doe No. 4 yet again.'
+' Under his community control conditions, Epstein is only allowed to leave his home to go to his
+office building.
+4
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 5 of 7
+12. Finally, Epstein has scheduled the deposition of Jane Doe No. 4 to start at 11 p.m.
+This is wholly unacceptable. Nevertheless, Epstein refused to change the starting time even
+when specifically requested by Plaintiff's counsel. On October 14, 2009, Plaintiff's counsel sent
+an email to defendant's counsel that stated, "Not only is the location not agreeable, but neither is
+the 11 pm start time." See Exhibit "A". In response, Epstein's counsel wrote the following terse
+response: "So file a prot order I tried to work this out and your response was unacceptable, bob".
+Id. No explanation was offered as why an 11 p.m. starting time was necessary or appropriate.
+WHEREFORE, Plaintiff, Jane Doe No. 4, respectfully requests that her deposition be set
+for a mutually agreeable time, date and location with the aforementioned precautions in place
+before the deposition.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.4.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so.
+Dated: October 21, 2009.
+Respectfully submitted,
+By:-
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz.@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Tel: (305) 931-2200
+5
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 6 of 7
+CERTIFICATE OF SERVICE
+I hereby certify that on October 21 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Adam D. Horowitz
+6
+
+
+Case 9:08-cv-80119-KAM Document 364 Entered on FLSD Docket 10/21/2009 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+7
diff --git a/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.receipt.json b/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0bef1c7e1b87bb789dff9d636dc3aa0f9f6fb03d
--- /dev/null
+++ b/vision-fixhub/court-01/e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -86,
+  "dataset": "marble-joined",
+  "doc_id": "e00be45f8f84dd9c16acade0e5e0de312f63d67882baf428ac5f21802003b90f",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "c19d7375f1f7c0d7b3e8a961c4d8ae32482f4519250d6381c8263a2f5f16b710",
+  "output_sha256": "2c430378fb0dc60a01a8f7e7c13f6feca5ad4b85f29ce5f79bea12db0b362d38",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e011627249431489a985687f4deff247a2e0d7530ac019c2f0942c1f1c010868.md b/vision-fixhub/court-01/e011627249431489a985687f4deff247a2e0d7530ac019c2f0942c1f1c010868.md
new file mode 100644
index 0000000000000000000000000000000000000000..b9aa9c545bcebaf51da4923092b4730501d761ea
--- /dev/null
+++ b/vision-fixhub/court-01/e011627249431489a985687f4deff247a2e0d7530ac019c2f0942c1f1c010868.md
@@ -0,0 +1,140 @@
+Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80804-CIV-MARRA/_
+JANE DOE, a/k/a,
+JANE DOE NO. 1,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+1, and
+Defendants.
+/
+PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
+CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1
+Plaintiff Jane Doe moves, pursuant to Rule 7.1(A) of the Local Rules of the United States
+District Court for the Southern District of Florida, for an enlargement of time to file a Civil
+RICO Case Statement under Local Rule 12.1 until fifteen days after the Court rules on her
+motion to remand, which will be filed on or about August 18, 2008.
+1. Defendants removed this action to federal court on July 21, 2008. (DE 1).
+2. Because Plaintiff has pleaded a cause of action under section 772.103, Florida
+Statutes, she is required to file a Civil RICO Case Statement within thirty days of
+removal. See S.D. Fla. L.R. 12.1.
+3.
+Plaintiff believes this action was improperly removed from state court and shall file
+a motion to remand on or about August 18, 2008. It is Plaintiff's contention that the
+Court lacks subject matter jurisdiction over this case because it does not involve a
+federal question or parties with complete diversity of citizenship.
+
+
+Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 2 of 5
+4. If this action was improperly removed, Plaintiff should not be required to expend the
+time and expense necessary to create and file a Civil Rico Cast Statement, which
+would not be required in Florida state court.
+WHEREFORE, Plaintiff respectfully request the Court grant her motion for an
+enlargement of time to file a Civil RICO Case Statement until fifteen days after the Court rules
+on her motion to remand
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+On August 13, undersigned counsel conferred with counsel for the Defendants in a good
+faith effort to resolve the issues raised in this motion, and Defendants" counsel advised that
+Defendants do not oppose this motion.
+s/ Spencer T. Kuvin
+Spencer T. Kuvin (Florida Bar Number 089737)
+Certificate of Services
+I hereby certify that on August 13, 2008, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record or pro se parties identified on the attached Service List in
+the manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those counsel or parties who are not authorized
+to receive electronically Notices of Electronic Filing.
+_s/ Spencer T. Kuvin
+Spencer T. Kuvin (Florida Bar Number 089737)
+Attorney E-Mail Address:
+RICCI~LEOPOLD, P.A.
+Counsel for Plaintiff Jane Doe
+2 of4
+
+
+Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 3 of 5
+SERVICE LIST
+Doe v. Epstein, et. al.
+CASE NO: 08-80804-Civ-MARRA/.
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Burman, Critton, Luttier & Coleman, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+Counsel for Jeffrey Epstein
+Served via U.S. Mail, postage prepaid
+Guy Alan
+Esq.
+Email:
+Tein
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Phone: (305) 442-1101
+Fax: (305) 442-6744
+Counsel for Jeffrey Epstein
+Served via CM/ECF
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+Counsel for
+Served via U.S. Mail, postage prepaid
+Michael R. Tein, Esq.
+Email: tein@lewistein.com
+Tein
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL
+, 33133
+Phone: (305) 442-1101
+Fax: (305) 442-6744
+Counsel for Jeffrey Epstein
+Served via CM/ECF
+3 of 4
+
+
+Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 4 of 5
+Douglas M. McIntosh, Esq.
+Jason A. l
+McIntosh, Sawran, Peltz & Cartaya, P.A.
+Centurion Tower, Suite 1110
+1601 Forum Place
+West Palm Beach, FL 33401
+Phone: (561) 682-3202
+Fax: (561) 682-3206
+Counsel for
+Served via U.S. Mail, postage prepaid
+4 of 4
+
+
+Case 9:08-cv-80804-KAM Document 9 Entered on FLSD Docket 08/13/2008 Page 5 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80804-CIV-MARRA/_
+JANE DOE, a/k/a,
+JANE DOE NO. 1,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+1, and
+Defendants.
+PROPOSED ORDER
+THIS CAUSE having come before this Court upon Plaintiff Jane Doe's UNOPPOSED
+MOTION FOR ENLARGEMENT OF TIME TO FILE CIVIL RICO CASE STATEMENT
+PURSUANT TO LOCAL RULE 12.1, and this Court being fully advised, it is hereby
+ORDERED AND ADJUDGED that:
+1. The Motion is hereby granted.
+2. Plaintiffs shall have an enlargement of time to file a Civil RICO Case Statement until
+fifteen (15) days after their motion for remand is decided.
+DONE AND ORDERED this .
+day of
+_ 2008.
+HON. KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: All counsel
diff --git a/vision-fixhub/court-01/e011627249431489a985687f4deff247a2e0d7530ac019c2f0942c1f1c010868.receipt.json b/vision-fixhub/court-01/e011627249431489a985687f4deff247a2e0d7530ac019c2f0942c1f1c010868.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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@@ -0,0 +1,544 @@
+Filing # 104805004 E-Filed 03/12/2020 04:17:41 PM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-
+MB
+Div.: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+PLAINTIFF'S OPPOSITION TO DEFENDANT SHARON R. BOCK, CLERK &
+COMPTROLLER OF PALM BEACH COUNTY'S MOTION TO DISMISS COUNT II
+Plaintiff CA Florida Holdings, LLC, publisher of The Palm Beach Post ("The Palm Beach
+Post") files this opposition to Defendant Sharon R. Bock, Clerk and Comptroller of Palm Beach
+County's Motion to Dismiss Count Tof The Palm Beach Post First Amended Complaint:
+I.
+SUMMARY OF ARGUMENT
+This action is an opportunity for an institution of the State of Florida to exercise its
+authority, not to shield the sordid and powerful, but instead to further justice and restore the
+public's confidence in the criminal justice system.
+The Clerk argues that Florida Statute § 905.27 does not allow The Palm Beach Post to seek
+disclosure of the grand jury records in furtherance of justice for purposes of informing the public.
+The Clerk also appears to argue that the Court lacks the inherent authority and supervisory powers
+over the grand jury to order such disclosure. Motion at 13. Both arguments fail.
+The Palm Beach Post has sufficiently pled its right to maintain an action under Section
+905.27 for the benefit of the public and consistent with the general legislative scheme, and its right
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/12/2020 04:17:41 PM
+
+
+to use the grand jury materials to inform the public, which is consistent with Section 905.27.
+The Palm Beach Post has further stated a claim that either together with, or independently
+of, Section 905.27, the Court has inherent authority to order the release of the grand jury records.
+The exercise of such authority is regularly made for purposes as varied as promoting court
+efficiency to providing transparency for the judicial system.
+The Palm Beach Post has therefore stated a claim under both Section 905.27 and pursuant
+to the Court's inherent powers by which this Court may order the release of the grand jury records
+sought in this action.
+Il.
+FACTUAL BACKGROUND
+The facts underlying this action are largely uncontested. See Answer of State Attorney;
+Answer of Clerk. Indeed, they are now largely a matter of public record as a result of the extensive
+legal proceedings arising out of the various crimes of Epstein and his co-conspirators over the
+course of more than a decade. While the complete factual allegations are set forth in the First
+Amended Complaint, a summary of the relevant facts is set forth below.
+A.
+First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005 - 2008
+The investigation into Epstein's sex crimes began more than fifteen years ago, when a 14-
+year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that Epstein and
+others who worked for him arranged for her to give Epstein a "massage." Epstein required the girl
+to strip, exposed himself, and masturbated while touching her. The girl was paid $300. Epstein
+was 52 years old at the time. First Amended Complaint (FAC") 1 11.
+Following this initial report in 2005, the Town of Palm Beach Police, and later, in 2006,
+the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
+seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
+disturbingly similar details, with each of the other victims. Id. 9 12.
+2
+
+
+Both the victim/witness interviews, as well as evidence retrieved following a search of
+Epstein's home, showed that some of the girls involved were under the age of 18. The police search
+of Epstein's residence also found two hidden cameras and, throughout the house, large numbers
+of nude photos of girls, including victims whom the police had not interviewed in the course of
+their investigation. Id. 9 13.
+In March 2006, a State grand jury was scheduled at which all of the victims were expected
+to testify. The proceeding was postponed, however, due to meetings between the State Attorney's
+office and Epstein's prominent criminal defense lawyer and personal friend, Alan Dershowitz.
+Id. 1 14. Another grand jury was convened in April 2006, but canceled the day before it was to
+begin receiving evidence. Id. 1 15.
+(1) Police Chief Reiter's Letter to the State Attorney
+On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a "personal and
+confidential" letter to then Palm Beach County State Attorney Barry Krischer, stating:
+I must renew my prior observation to you that I continue to find your office's treatment of
+[the Epstein] cases highly unusual. It is regrettable that I am forced to communicate in this
+manner, but my most recent telephone calls to you and those of the lead detective to your
+assigned attorneys have been unanswered and messages remain unreturned. After giving
+this much thought and consideration, I must urge you to examine the unusual course that
+your office's handling of this matter has taken and consider if good and sufficient reason
+exists to require your disqualification from the prosecution of these cases. (Emphasis
+supplied)
+Id. 116.
+Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach Police
+Department's probable cause affidavits charging Epstein and two of his assistants with multiple
+counts of unlawful sex acts with a minor and one count of sexual abuse, and requested that either
+an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges against
+him, which would be public. Id. 9 17.
+3
+
+
+(2) The July 2006 State Grand Jury Presentation
+Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
+mandatory for capital cases but rarely used for all other crimes. According to an official
+spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
+Beach County. Id. 1 18
+In July 2006, after State Attorney Krischer presented testimony and evidence from just one
+victim, the grand jury returned an indictment on a sole count of solicitation of prostitution. There
+is no mention in the indictment of the victim being a minor. Id. 9| 19. Another of Epstein's victims
+was supposed to testify before the grand jury, but did not. Id. | 20. No reasonable explanation has
+been provided as to why the numerous other known victims were not presented as witnesses and
+crime victims to the grand jury convened in July 2006. Id. 121. Nor has any reasonable explanation
+been provided as to why State Attorney Krischer, who was initially eager to investigate and
+prosecute Epstein for his crimes, over time lost the desire to do so. Id.
+During the grand jury appearance of the single victim who testified, the State Attorney
+presented evidence that vilified the victim and attacked her credibility, including soliciting
+testimony regarding underage drinking and questionable personal behavior that was unrelated to
+the charges against Ep
+• Id. 122. This information was initially brought to the attention of the
+State Attorney's office by Epstein's defense counsel. Id.
+(3) The FBI's Investigation and Epstein's Non-Prosecution Agreement
+With Federal Authorities
+Following the deficient July 2006 indictment, and with Chief Reiter's encouragement, the
+FBI began its own investigation of Epstein. Id. 9| 23. Records unsealed in 2015 revealed that the
+FBI compiled reports on "34 confirmed minors" that were victims of Epstein's sexual predations.
+Based on evidence gathered by the FBI, a 53-page indictment was prepared by the U.S. Attorney's
+4
+
+
+Office in June 2007. Id. 1| 24. However, at the request of Epstein's lawyers, the indictment was
+never presented to a federal grand jury. Id.
+Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
+negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with
+four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
+charges. Id. 9 25. Throughout the remainder of 2007 and through the first half of 2008, Epstein's
+lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
+belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept
+confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
+issued for Epstein's computers) be withdrawn. Id. 1 26.
+On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
+prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
+sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
+adjudicated as a convicted sex offender required to register twice a year in Florida. Id. 9 27.
+The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to receive
+immunity from federal sex-trafficking charges that could have sent him to prison for life. Public
+records reveal that former State Attorney Krischer communicated with then U.S. Attorney Acosta
+concerning the NPA's negotiation with Epstein's lawyers. Id. 4 28.
+Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for which he
+was convicted. Instead, he was placed in a private wing of the Palm Beach County Stockade,
+where, after 3 12 months, he was allowed to leave the jail on "work release" for up to 12 hours a
+day, 6 days a week. His private driver provided his transportation to and from "work." Id. 1 29.
+Epstein was also known to have violated the terms of his probation, but was not prosecuted. Id.
+5
+
+
+Epstein was then released five months early. Id. 1 30.
+Following publicity exposing the extraordinary leniency of the plea deal, dozens of civil
+suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court. Id. | 34.
+(4) The Crime Victims' Rights Act Litigation
+During the course of the Town of Palm Beach and FBI investigations, Epstein retained
+private investigators to follow, harass, and photograph his victims and their families, as well as
+Chief Reiter and the Town of Palm Beach detective who investigated the case against Epstein. Id.
+136. Epstein's victims were threatened against cooperating with law enforcement and told that they
+would be compensated only if they did not cooperate with law enforcement. Id. 137.
+To add insult to injury, Epstein's victims only learned after the fact about his plea deal in
+State court and filed an emergency petition to force federal prosecutors to comply with the Crime
+Victims' Rights Act (18 U.S.C. § 3771, "CVRA"), which mandates certain rights for crime victims,
+including the right to be informed about plea agreements and the right to appear at sentencing. U.S.
+District Judge Kenneth A. Marra ruled in 2019 that federal prosecutors violated the CVRA by
+failing to notify Epstein's victims before allowing him to plead guilty to only the two State offenses.
+Id. " 32. The prosecution's failure to keep the victims apprised, among other things, also
+contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001. Id. 9 33.
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019
+On July 6, 2019, Epstein was arrested on federal sex trafficking charges. Id. 9 38.
+The United States government's prosecution of Epstein based on new allegations and charges
+stemmed, in part, from continued press investigations and reporting on the mishandling of the 2006
+charges and the civil suits that followed. Id. 139.
+In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the Southern
+District of New York, Epstein was described as "a serial sexual predator who preyed on dozens of
+6
+
+
+minor girls over a period of years." The letter emphasized that "the Government has real concerns
+- grounded in past experience with this defendant - that if allowed to remain out on bail, the
+defendant could attempt to pressure and intimidate witnesses and potential witnesses in this case,
+including victims and their families, and otherwise attempt to obstruct justice." It also described
+the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex trafficking in the
+form of "hundreds-and perhaps thousands—of sexually suggestive photographs of fully- or
+partially-nude females," including underage females. In a locked safe, compact discs were found
+with handwritten labels including the descriptions: "Young [Name] + [Name]," "Mise nudes 1,"
+and "Girl pics nude." Id. 1 40.
+On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's office
+for the Southern District of New York charged Epstein with sex trafficking and conspiracy to traffic
+minors for sex. The grand jury indictment alleges that "dozens" of underage girls were brought into
+Epstein's mansions for sexual encounters. A few days later, owing to public outcry over the NPA
+with Epstein entered into by the U.S. Attorney for the Southern District of Florida, Alexander
+Acosta, who by then was serving as U.S. Secretary of Labor in the Trump administration, resigned
+from office. Id. 141.
+On or about August 6, 2019, Florida Governor Ron DeSantis ordered a state criminal probe
+into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their handling of
+the Epstein underage sex trafficking case. Id. 1 43.
+On August 20, 2019, Epstein was found dead, by apparent suicide, at the federal
+Metropolitan Correction Center in lower Manhattan where he was being held without bail.
+Id. 111 42, 44.
+C.
+The August 27, 2019, SDNY Hearing: Epstein's Victims Speak
+Following Epstein's death, prosecutors sought to dismiss the indictment against Epstein,
+7
+
+
+while maintaining that they would continue to investigate his co-conspirators. Id. 9| 45. United
+States Senior District Judge Richard M. Berman ordered a hearing on August 27, 2019, on the
+prosecutors' decision to dismiss the indictment and allowed victims to speak at the hearing.
+Id. 9 46.
+In the course of the hearing, more than two dozen victims delivered their personal stories of
+pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke q
+olent rape by
+Epstein. Many more victims were present in the courtroom but did not testify. Id 147.
+While some questioned the reasoning behind the court's decision to givé the victims voice
+after Epstein's death, Judge Berman noted that "a public hearing is [the] preferred vehicle of
+resolution," emphasizing that "public hearings are exactly what judges do. Hearings promote
+transparency and they provide the court with insights and information which the court may not
+otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that the court
+"is the institution that most people have confidence in, in these very troubled times." Id. 48.
+At the August 27th hearing, the girls, now women, spoke about their "exploitation and
+coercion," and to the fact that many of them "were in very vulnerable situations and in extreme
+poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
+behalf...." One vietim lamented that "as a victim, [she] never got to see what the agreement was or
+why the special treatment got approved" in the Florida case years earlier. Another noted how
+"completely different" the investigators leading to the 2019 federal indictment were from the
+prosecutors in the Florida case, both in their treatment of her and their investigation of her
+victimization by Epstein. Id. 1 49. A former federal judge in attendance at the August 27th hearing
+emphasized that "transparency is one of the overriding objectives in our criminal justice system."
+Id. 1 50.
+8
+
+
+Nearly all of the victims expressed the conviction that the secrecy that shielded Epstein has
+caused them "irreparable harm" and that an opportunity to address his criminal wrongdoings, and
+those of the individuals who enabled his sexual racketeering, would allow for at least some measure
+of justice to be served after his death. Indeed, one victim stated: "Any efforts made to protect
+Epstein's name and legacy send a message to the victims that he wins and that he is untouchable."
+Another victim expressed fear that this is a world "where there are predators in power, a world
+where people can avoid justice if their pockets run deep enough." Id. 9 51,
+In short, the "unusual" treatment Epstein received in Florida in 2006 based on his wealth,
+social status, and connections severely eroded the public's faith in the integrity and impartiality of
+the criminal justice system. Allowing The Palm Beach Post's claims to proceed in this action would
+allow for public examination and understanding of the operation of the criminal justice system in
+Florida.
+III.
+LEGAL ARGUMENT
+A.
+Legal Standard
+Fla. R. Civ. P. 1.110(b) provides that a pleading that sets forth a claim for relief shall contain
+a short and plain statement of the grounds of the ultimate facts showing that the pleader is entitled
+to relief. Fla. R. Civ. P. 1.110(g) permits a party to "set up in the same action as many claims or
+causes of action ... as the pleader has, and claims for relief may be stated in the alternative." The
+Rule further provides "[a] party may also state as many separate claims or defenses as that party
+has, regardless of consistency and whether based on legal or equitable grounds or both." Fla. R.
+Civ. P. 1.110(g).
+Here, The Palm Beach Post brings two claims: one pursuant to Fla. Stat. § 905.27, and one
+for declaratory relief based on the principles set forth in Section 905.27 as well as constitutional
+9
+
+
+principles of freedom of the press as protected by the Court's inherent authority and supervisory
+powers. The Clerk concedes that the declaratory relief claim is adequately plead. For the same
+reasons requiring that concession
+-and those set forth below-the Court should, respectfully, find
+that both claims have been sufficiently plead.
+B. Relevant Legal Framework: Fla. Stat. § 905.27
+Typically, grand jury proceedings are conducted and maintained in secret. Fla. Stat.
+§ 905.24. But this secrecy has never been—and was never intended to be-absolute. First, as a
+practical matter, grand jury proceedings are already subject to public disclosure, as a testifying
+grand jury witness is free to disclose her grand jury testimony. In Butterworth v.
+the United
+States Supreme Court, weighing the competing interests of grand jury secrecy and the First
+Amendment, held unconstitutional Section 905.27's purported prohibition on a witness revealing
+her own testimony.' 494 U.S. 624, 626 (1990). The "sécrecy" of grand juries in Florida is thus
+qualified - not absolute - based on principles embodied in the First Amendment.?
+Second, Section 905.27(1) specifically provides exceptions to grand jury secrecy: "the
+testimony of a witness examined before the grand jury or other evidence received by it" may be
+disclosed "when required by a court... for the purpose of: (a) Ascertaining whether it is consistent
+with the testimony given by the witness before the court; (b) Determining whether the witness is
+The Supreme Court in Butterworth further "recogniz[ed] that the invocation of grand jury interests is not ""some
+talisman that dissolves all constitutional protections.'" 494 U.S. at 630-31 (quoting U.S. v. Dionisio, 410 U.S. 1,
+11 (1973)); see also Landmark Communications, at 838 (balancing state's interest in preserving confidentiality
+of judicial review proceedings against rights of newspaper reporting on such proceedings).
+2 The Florida Supreme Court has similarly confirmed that grand jury secrecy is not absolute and that any "harm to
+public officcholders" from disclosure will be the product of their own conduct, and not the consequence of an
+unrestrained body of misguided citizens." Miami Herald Pub. Co. v. Marko, 352 So. 2d 518 (Fla. 1977). The
+decision in Marko emphasized that a grand jury's important role in "expos[ing] official misconduct" precludes
+restricting access to its activities for the purpose of protecting "public officeholders." Id. ("[t]he benefits to be
+derived from this extraordinary exercise in citizen participation [in the grand jury] would be severely limited if
+the fruits of that activity were not available to the public on whose behalf it is undertaken. Implicit in the power
+of the grand jury to investigate and expose official misconduct is the right of the people to be informed of its
+findings.").
+10
+
+
+guilty of perjury; or (c) Furthering justice." Fla. Stat. § 905.27(1)(a)-(c). The Florida legislature
+therefore clearly intended to empower a court to order the disclosure of grand jury proceedings to,
+among other things, further justice, as this Court should do here.
+Subsequent to such disclosure, The Palm Beach Post is not, as the Clerk argues, constrained
+by the statute from using the materials for public disclosure-nor could it be, under the First
+Amendment.? The Clerk argues that "grand jury testimony "can only be used in the defense or
+prosecution of the civil or criminal case and for no other purpose whatsoever'...
+" Motion at 13. But
+that limitation only applies "[w]hen such disclosure is ordered by a court pursuant to subsection (1)
+for use in a civil case." Fla. Stat. § 905.27 (emphasis added). Here, The Palm Beach Post is not
+asking the Court to order the disclosure of grand jury records "for use in a civil case;" rather, it
+seeks disclosure for the express reason set forth in Section 905.27(1)(c)-i.e., to further justice by
+allowing the public, through the efforts of The Palm Beach Post, access to this information.4
+The Palm Beach Post's ability to inform the public is critical to the role it plays in public
+discourse and its safeguarding of the judicial process. As explained in the FAC (11 56-59), the
+Supreme Court has further recognized that the press has a constitutional right of access to criminal
+proceedings, see, e.g., Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including
+pre-trial criminal proceedings.
+| v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the
+3
+In this regard, the Clerk's interpretation of Section 905.27 would render the statute a prior restraint, "the most
+serious and the least tolerable infringement on First Amendment rights." Nebraska Press Ass 'n v. Start, 427 U.S.
+539, 559 (1976) (noting a "deeply-seated American hostility to prior restraints"). To the extent redactions to the
+grand jury materials may be required to protect the privacy of unnamed victims or third parties, the Court of
+course may require such redactions prior to ordering disclosure of the records.
+* While the Clerk (unlike the State Attorney) does not expressly make the argument that The Palm Beach Post
+lacks standing to seck the disclosure of the grand jury records, it bears noting that The Palm Beach Post has the
+right to maintain this private right of action because the furtherance of justice, an express legislative exception to
+grand jury secrecy, is intended for the public benefit, and The Palm Beach Post seeks access on behalf of the
+public it serves. Fla. Stat. § 905.27(1)(c). It is further mandated in Fla. Stat. § 905.27 that the legislature intended
+for a court to be the party to make the determination of disclosure. Fla. Stat. § 905.27(I). In other words, the
+legislature granted the courts the power to consider and determine the propriety and scope of grand jury secrecy.
+11
+
+
+integrity of the judicial process, which public scrutiny is supposed to safeguard, is just as much at
+issue in proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald
+Publ. Co. v.
+, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate"
+in matters concerning the closure of judicial proceedings). The press also has a First Amendment
+interest in receiving information from willing speakers. See Va. State Bd. of Pharmacy v. Va.
+Citizens Consumer Council, Inc., 425 U.S. 748, 756-57 (1976) ("Where a speaker exists ... the
+protection afforded [by the First Amendment] is to the communication, to its source and to its
+recipients both."); Pittman v.
+, 267 F.3d 1269, 1283 n.12 (11th Cir 2001) (The Supreme Court
+has recognized that the First Amendment offers protection to both speakers and those wishing to
+receive speech."); see also Stephens v. Cty. of Albemarle VA, 524 F.3d 485, 492 (4th Cir. 2008)
+(providing that a plaintiff has "standing to assert a right to receive speech" by "show[ing] that there
+exists a speaker willing to convey the information to her").
+Because of the unique role performed by the press as a "public surrogate"
+, 426 So.
+2d at 6-7) in protecting the right of access and its interest in reporting information about criminal
+proceedings, news organizations "presumptively have a right to access judicial records," Comm'r,
+Ala. Dep't of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019), and
+"standing to questión the validity of an order restricting publicity because its ability to gather news
+is directly impaired or curtailed."
+1. 426 So. 2d at 4; see also Carlson v. United States, 837
+F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee] has
+standing to assert [its] claim" to grand jury materials because such materials are "public records to
+which the public may seck access, even if that effort is ultimately unsuccessful").
+Here, the continued denial of access to information sought by The Palm Beach Post on
+behalf of its journalists and the public "unquestionably constitutes irreparable injury." Gainesville
+12
+
+
+Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also Zerilli v.
+656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press's function as a vital source of information
+is weakened whenever the ability of journalists to gather news is impaired," as it is by Attorney
+General's refusal to disclose unredacted report and underlying grand jury materials).
+C.
+This Court has Inherent Power to Release Grand Jury Records in Order to Further
+Justice and Vindicate Confidence in the Judicial Process
+As set forth in the FAC (11 60-64), even in the absence of the statutory framework in Section
+905.27, disclosure is appropriate pursuant to this Court's inherent authority over grand jury
+proceedings because of the exceptional public interest in this case and the compelling circumstances
+supporting transparency rather than continued secrecy.
+1. The Grand Jury is Under the Court's Supervision and Jurisdiction
+It is well-settled that the grand jury is "a judicial proceeding in a court of justice...an
+appendage or adjunct to the circuit court." In re Grand Jury Investigation, 287 So. 2d 43 (Fla.
+1973) (quoting Craft v. State, 42 Fla. 567, 29 So. 418 (1900)). Indeed, it is the court that gives the
+grand jury its initial charge and advises the grand jury about its legal duties. Fla. Stat. § 905.18.
+"It has long been understood that "[c]ertain implied powers must necessarily result to our
+Courts of justice from the nature of their institution,' powers "which cannot be dispensed with in a
+Court, because they are necessary to the exercise of all others."
+v. NASCO, Inc., 501 U.S.
+32, 43 (1991). "There can be no question of the inherent power of a court "to protect itself, and
+hence society, as an instrument of justice.'' In re Osborn, 376 F.2d 808, 810 (6th Cir. 1967).
+Thus, in a variety of contexts, it has been held that "courts have the inherent power to protect
+the integrity of the judicial process from perversion and abuse." Vitakis-Valchine v. Valchine, 793
+So. 2d 1094, 1099-1100 (Fla. 4th DCA 2001); Attwood v. Singletary, 661 So. 2d 1216 (Fla. 1995)
+(invoking court's inherent authority to prevent "abusive filer" from filing additional cases to
+13
+
+
+prevent interference with orderly process of judicial administration); Tramel v. Bass, 672 So. 2d 78
+(Fla. Ist DCA 1996) (invoking court's inherent authority to strike pleadings to sanction fraud
+perpetrated on the court).
+The Florida Supreme Court has noted that it is "of vital importance to maintain the dignity
+and the integrity of both the grand jury and the presiding judge." State v. Clemmons, 150 So. 2d
+231, 233-34 (Fla. 1963).S "[I]n states such as Florida, where the grand jury is preserved, it is an
+important appendage of the court which impanels it... [and] it should not be forgotten that the judge
+of that court is equally important and he is generally charged with the supervision of the grand
+jury's activities..." Id. "The importance of public confidence in the integrity of judges stems from
+the place of the judiciary in the government." (
+- Yulee v. Fla/Bar, 575 U.S. 433, 445 (2015).
+Courts do not command armies and have "no influence over either the sword or the purse[.]" Id.
+(citing The Federalist No. 78, p. 465 (C. Rossiter ed. 1961) (A.
+D). "The judiciary's
+authority therefore depends in large measure on the public's willingness to respect and follow its
+decisions." Id.; see also In re Petition)to Inspect & Copy Grand Jury Materials, 735 F.2d 1261,
+1269-70 (11th Cir. 1984) (upholding the exercise of the court's inherent power to release grand jury
+records to further "a matter of great societal importance" that affected "the public confidence in the
+judiciary"). "The perception of a viable healthy judiciary is of critical importance to our system of
+justice." Id. at 1271. This "perception" is of equal importance with respect to state courts, which
+are invested with primary responsibility for overseeing the investigation and prosecution of crimes.
+The Supreme Court of the United States, while acknowledging the values in grand jury
+secrecy, has long authorized the disclosure of grand jury records where the need for transparency
+outweighs any remaining interest in secrecy. Douglas Oil Co. of California v. Petrol Stops
+• State v. Clemons was superseded by statute. See Kelly v. Sturgis, 453 So. 2d 1179 (Fla. 5th DCA 1984).
+14
+
+
+Northwest, 441 U.S. 211, 223 (1979). Courts around the country have followed suit. See, e.g., In re
+Petition of Nat'l Sec. Archive, No. 08 CIV. 6599, 2008 WL 8985358 (S.D.N.Y. Aug. 26, 2008)
+(release of grand jury records concerning the indictment of Julius and Ethel
+D; In re
+Petition of Nat'/ Sec. Archive, 104 F. Supp. 3d 625 (S.D.N.Y. 2015) (same); In re Petition of Kutler,
+800 F. Supp. 2d 42 (D.D.C. 2011) (release of President Nixon's grand jury deposition testimony in
+connection with the third Watergate grand jury); In re Unseal Dockets Related to the Indep.
+Counsel's 1998 Investigation of President Clinton, 308 F. Supp. 3d 314 (D.D.C. 2018) (release of'
+records related to independent counsel's investigation of President Clinton). Most recently, the D.C.
+Circuit ordered the Trump administration to provide the House Judiciary Committee redacted
+portions of grand jury materials from former special counsel Robert Mueller's probe into Russian
+election interference. In Re: Application of the Committee on the Judiciary, U.S. House of
+Representatives, For an Order Authorizing the Reléase of Certain Grand Jury Materials,
+Committee on the Judiciary, United States House of Representatives v. U.S. Department of Justice,
+No. 19-5288 (D.C. Cir. March 20, 2020). There is no evidence that the disclosures resulting from
+these cases have adversely affected the grand jury process. On the other hand, there is no doubt that
+the release of these materials has contributed greatly to the historical record of significant events in
+our country's history, as well as exposing failures in our justice system.
+Courts have identified nine "non-exhaustive" factors that a court may consider when
+determining whether their inherent authority should be exercised to order the release of grand jury
+documents. These factors include:
+(i) the identity of the party seeking disclosure; (ii) whether the defendant to the grand jury
+proceeding or the government opposes the disclosure; (i11) Why disclosure is being sought
+in the particular case; (iv) what specific information is being sought for disclosure; (v) how
+long ago the grand jury proceedings took place; (vi) the current status of the principals of
+the grand jury proceedings and that of their families; (vii) the extent to which the desired
+material—either permissibly or impermissibly—has been previously made public; (viii)
+15
+
+
+whether witnesses to the grand jury proceedings who might be affected by disclosure are
+still alive; and (ix) the additional need for maintaining secrecy in the particular case in
+question.
+Kutler, at 47-48 (quoting In re Petition of Craig, 131 F.3d 99, 106).°
+The vast majority of these factors weigh in favor of disclosure in this case. First, the party
+seeking disclosure does so pursuant to its First Amendment right to receive information in order to
+inform the public. See Va. Pharmacy Bd., 425 U.S. at 756-57; Pittman, 267 F.3d at 1283. Second,
+the defendant to the grand jury proceeding is deceased, although the government is opposed to the
+disclosure. The Palm Beach Post respectfully submits that the government's opposition should be
+given little weight where, as here, the disclosure of records is sought to uncover the alleged
+misconduct of a prior State Attorney (as opposed to, for example, witness perjury). Third, disclosure
+is being sought—based on information learned by The Palm Beach Post from (1) a series of Florida
+Public Records Law requests, (2) law enforcement sourees with direct knowledge of the grand jury
+evidence and proceedings, (3) judicial documents obtained from independent but related court
+proceedings, and (4) documents otherwise available in the public record—to inform the public as
+to whether the then State Attorney for Palm Beach County presented truncated evidence of
+Epstein's criminal wrongdoing to the 2006 grand jury in a manner that precluded Epstein's
+indictment for the serious crimes he committed, including sex trafficking and sexual assault. Fourth,
+the records being sought are the testimony, minutes, and other evidence presented in 2006 to the
+Palm Beach County grand jury, which appear to have been whitewashed so that Epstein would not
+• While it is largely federal courts that have applied these nine factors, (1) there can be no dispute that Florida
+courts are endowed with inherent authority like their federal counterparts, see supra at 13-14; and (2) notably,
+federal courts consider these factors when the enumerated exceptions to grand jury secrecy set forth in Federal
+Rule of Criminal Procedure 6(e)(3)(E) do not appear to apply. See, e.g., In re Petition to Inspect & Copy Grand
+Jury Materials, 735 F.2d 1261, 1268 (11th Cir. 1984) (*it has been authoritatively said that [Rule 6(e)] is not the
+true source of the district court's power with respect to grand jury records but rather is a codification of standards
+pertaining to the scope of the power entrusted to the discretion of the district court"). Thus, to the extent the Court
+does not find that it is authorized by Fla. Stat. § 905.27 to order disclosure of the Epstein grand jury materials, its
+inherent authority provides "ample[]" (id.) grounds for such disclosure.
+16
+
+
+be charged with serious crimes of which there was ample evidence. Fifth, the grand jury
+proceedings took place nearly fifteen years ago. Sixth, the current status of the principals of the
+grand jury proceedings are unknown. Seventh, because much of the requested information has now
+entered the public domain through victims protesting their mistreatment by and misgivings
+concerning prosecutors (both state and federal), other lawsuits surrounding Epstein and his coconspirators, and public records requests and extensive news reporting, this factor weighs in favor
+of full disclosure. Eighth, the status of the witnesses who appeared is unknown-indeed, The Palm
+Beach Post's request is made, in part, to learn who the witnesses were that the State Attorney did
+decide to call.? Finally, The Palm Beach Post submits that with the death of the defendant, the
+widely-known and litigated acts of his co-conspirators, the length of time that has passed, and the
+widely reported nature of this miscarriage of justice, there is no additional need for maintaining
+secrecy. See U.S. v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jury's
+functions are ended, disclosure is wholly proper where the ends of justice require it.").
+Courts have long realized that a transparent criminal justice system, affords "significant
+community therapeutic value." Richmond Newspapers v. Virginia, 448 U.S. at 570-71. "IT]he
+open processes of justice serye an important prophylactic purpose, providing an outlet for
+community concern, hostility, and emotion." Id. at 571. "The crucial prophylactic aspects of the
+administration of justice cannot function in the dark; no community catharsis can occur if justice
+is done in a corner [or] in any covert manner." Id.
+The Palm Beach Post has accordingly stated a claim pursuant to this Court's inherent
+authority and supervisory powers, which allow the Court to take appropriate and necessary action
+to preserve and promote the integrity of the justice system. The citizens of Palm Beach County and
+With respect to the sixth and eighth factors, an in camera review by this Court, followed by appropriate redactions,
+would remedy any potential harm to innocent parties.
+17
+
+
+throughout the State of Florida are entitled to nothing less in this case of exceptional importance
+and public interest.
+IV.
+CONCLUSION
+Pursuant to Fla. Stat. § 905.27 and this Court's inherent supervisory authority, The Palm
+Beach Post has sufficiently pleaded its claims.
+Dated: March 13, 2020
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq-
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen 4, Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+NOT A CER
+mendelsohns@gtlaw.com
+enh@gtlaw.com
+FL.Service@gtlaw.com
+Michael J
+Grygiel
+MICHAEL J GRYGIEL
+(Admitted Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Boyajian
+NINA D. BOYAJIAN
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+ACTIVE 49239002v1
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+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-,
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+FILED by
+- D.C.
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+OCT 2 2 2009
+STEVEN US ARRES
+S.D. OF FLA. - W.PB
+DEFENDANT EPSTEIN'S EMERGENCY RESPONSE IN OPPOSITION
+TO PLAINTIFFS', JANE DOE 2-8, SECOND MOTION FOR
+PROTECTIVE ORDER, WITH INCORPORATED MEMORANDUM OF
+LAW
+Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to all
+applicable rules, including Local Rule 7.1(e), hereby files and serves his Response In Opposition
+To Plaintiffs' Second Motion For Protective Order (DE 364), With Incorporated Memorandum
+Of Law. In support, Epstein states:
+Introduction and Background
+1.
+As this Court is well aware, Plaintiffs continue to prevent discovery. As such,
+several Motions, Responses and Replies have been unnecessarily litigated, and these cases have
+been unnecessarily delayed by Plaintiffs.
+One of the Plaintiffs has taken various positions only to abandon those positions
+after extensive briefing, thereby resulting in substantial delay. Other Plaintiffs have taken the
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 2 of 8
+Page 2
+position that Independent Medical Exams must be limited in scope, which is contrary to what
+this court has already ruled. DE 289.
+3.
+In this particular case, Jane Doe 4 requests that this Court enter an order
+preventing Epstein from being in attendance at her deposition set for October 27, 2009.'
+Without jeopardizing the substance of certain Motions, Responses and Replies currently pending
+before this Court on the same subject matter, Jeffrey Epstein will agree to the following in an
+effort to move this particular case forward:
+a.
+b.
+That Epstein will not be in attendance at the deposition.
+That Epstein will view the deposition from a video-feed in a separate room on the 14t'
+floor of the building located at 250 Australian Ave., South, Suite 115, West Palm Beach, Florida.
+Plaintiff will be responsible for the associated costs of the video-feed (as another Plaintiff agreed
+to do without incident)
+c.
+That Epstein will arrive at the building 1 hour before the deposition is set to begin at
+11:00 a.m. on the above date.
+d.
+That Jane Doe 4's attorney will contact Epstein attorney by cellular telephone upon
+their arrival and, at that time, Epstein will be in the room where the video-feed monitor is
+located.
+e.
+That once the deposition is over, Epstein will remain located in the room where the
+video-feed monitor is located until such time as Jane Doe 4 and her attorney have exited the
+building, which her attorney will confirm by cellular telephone with the undersigned.
+4.
+Plaintiffs' counsel offers an absurd sanction (i.e., if Jeffrey Epstein ever comes
+within sight of Jane Doe 4, Epstein waives the right to take her deposition in this lawsuit where
+' Plaintiff, CMA, recently withdrew her Motion for Protective Order seeking to prevent Jeffrey Epstein from
+appearing at deposition.
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 3 of 8
+Page 3
+Plaintiffs seek to recover millions of dollars.) Again, a proposal that was offered by Plaintiff
+only to prevent and/or delay discovery. The deposition is set to occur at the office of Prose
+Court Reporting located at 250 Australian Ave., South, Suite 115. Jeffrey Epstein's office is
+located on an entirely separate floor from Prose Court Reporting. The location is neutral and
+convenient. If Plaintiff wishes to absorb the costs of renting another room and paying for the
+video-feed costs, Jeffrey Epstein will not object to same. Epstein simply desires to move these
+cases forward and complete meaningful discovery.
+5.
+In Mugrage v. Mugrage, 763 A.2d 347, 349-352 (N.J. 2000), the court reasoned
+that "[a]lthough [the wife was] in fear of [her husband], and [was] in good faith in asking that he
+be excluded, and even though she ha[d] been the victim of domestic violence in the past, as well
+as protected by an existing order, the court conclude[d] that Mr. Mugrage ha[d] respected the
+judicial process in the past and almost certainly [would] abide by the terms of any court order
+regulating his attendance at the deposition. He has not violated past court orders and the court
+conclude[d] that security concerns for her safety can be addressed in a carefully crafted
+protective order. Therefore, Ms. Mugrage [did] not establish] sufficient "exceptional
+circumstances" to justify excluding Mr. Mugrage from her deposition in the matrimonial action."
+Id. at 352 (even when it is not appropriate to exclude the other party from the protected party's
+deposition, a protective order can be crafted which would allow the other party to be present
+under the least restrictive conditions possible). In an effort to move this case forward, Epstein
+offers Jane Doe 4 an even more restrictive setting for her deposition than what Mugrage
+provides.
+In addition, Epstein offers a more restrictive setting than what is permitted under the law. See e.g., Christian v
+‹hode, 41 F.3d 461, 465-66 (C.A. Ariz. 1994). See also, Coy v. Iowa, 487 U.S. 1012, 1015, 108 S.Ct. 2798, 2800
+101 L.Ed.2d 857 (1988). The Clause *
+before he zai so facts) at Close g SC. a thl. this dan sic a contronte on tinhanch the asses appearing
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 4 of 8
+Page 4
+Wherefore, Epstein respectfully requests that this Court enter an order denying Plaintiffs'
+Second Motion for Protective Order, entering an order allowing for the above releif, and for such
+other and further relief as this court deems just and proper.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk sere this day onal co and are alien ted on i baring Serie it me.
+manner specified by CM/ECF on this 22nd day of October, 2009
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+finding by reducing the risk that a witness will wrongfully implicate an innocent person." Maryland v. Craig, 497
+U.S. 836, 846, 110 S.Ct. 3157, 3164, I|| L.Ed.2d 666 (1990); see also Coy, 487 U.S. at 1019, 108 S.Ct. at 2802 ("A
+witness 'may feel quite differently when he has to repeat his story looking at the man whom he will harm greatly by
+distorting or mistaking the facts." ") (quoting Z. Chafee, The Blessings of Liberty 35(1956)). The Confrontation
+Clause thus gives the defendant the right to be present and to confront witnesses giving testimony during a pretrial
+deposition, where the deposition is intended for use at trial. Don v. Nix, 886 F.2d 203 (8th Cir.1989); United States
+y. Benfield, 593 F.2d 815 (8th Cir. 1979). Moreover, 1 McCormick on Evid., §19 (6" ed.) states, in pertinent part,
+that: "[fJor two centuries, common law judges and lawyers have regarded the opportunity of cross-examination as an
+essential safeguard of the accuracy and completeness of testimony. They have insisted that the opportunity is a
+right, not a mere privilege. This right is available at the taking of depositions as well as during the examination of
+witnesses at trial." See
+1. 91 Conn. 404, 408, 99 A. 1032 (1917); Helfferich v. Farley, 36
+Conn.Sup. 333, 334, 419 A.2d 913 (1980).
+
+
+Case 9:08-cv-80119-KAM
+Page 5
+Document 370 Entered on FLSD Docket 10/23/2009 Page 5 of 8
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/,
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Brad
+Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz., P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+ahorowitz@sexabuseattorney.com
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232,
+08-80380, 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10" Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No. 08-
+80811
+reelrhw@hotmail.com
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+_ Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+Counsel for Plaintif in Related Case No. 08.
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 6 of 8
+Page 6
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-
+08804
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 7 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-L
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+PROPOSED ORDER
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Emergency
+Response in Opposition to Plaintiffs, Jane Doe 2-8', Second Motion for Protection Order, with
+Incorporated Memorandum of Law. Having considered Defendant's motion, it is HEREBY
+ORDERED and ADJUDGED that:
+a.
+The deposition shall go forward on October 27, 2009.
+b.
+Epstein will not be in attendance at the deposition.
+c.
+Epstein will view the deposition from a video-feed in a separate room on the 14t*
+floor of the building located at 250 Australian Ave., South, Suite 115, West Palm Beach, Florida.
+Plaintiff will be responsible for the associated costs of the video-feed (as another Plaintiff agreed
+to do without incident)
+d.
+Epstein will arrive at the building 1 hour before the deposition is set to begin at 11:00
+a.m. on the above date.
+
+
+Case 9:08-cv-80119-KAM Document 370 Entered on FLSD Docket 10/23/2009 Page 8 of 8
+Jane Doe No. 4 v. Epstein
+Page 2
+e.
+Jane Doe 4's attorney will contact Epstein attorney by cellular telephone upon their
+arrival and, at that time, Epstein will be in the room where the video-feed monitor is located.
+f.
+Once the deposition is over, Epstein will remain located in the room where the videofeed monitor is located until such time as Jane Doe 4 and her attorney have exited the building.
+which her attorney will confirm by cellular telephone with the undersigned.
+DONE and ORDERED this _
+- day of
+→ 2009.
+United States Magistrate Judge
+Courtesy Copies:
+Counsel of Record
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+++ b/vision-fixhub/court-01/e0870de6102993b3dc9903ae55582f2814932a002c41e9099918b256fc36cb2d.md
@@ -0,0 +1,34 @@
+Case 9:08-cv-80119-KAM Document 338-1 Entered on FLSD Docket 10/06/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO EXCEED PAGE
+LIMITATION IN RESPONSE IN OPPOSITION TO PLAINTIFF'S MOTION TO
+COMPEL RESPONSE TO PLAINTIFF'S REQUEST FOR PRODUCTION
+WITH INCORPORATED MEMORANDUM OF LAW
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+to Exceed Page Limitation in Response in Opposition to Plaintiff's Motion to Compel
+Responses to Request for Production with Incorporated Memorandum of Law. Having
+considered Defendant's motion to exceed page limitation by one (1) page, it is HEREBY
+ORDERED and ADJUDGED that:
+Defendant's motion is GRANTED. Defendant's Response to Plaintiff's Motion
+to Compel Response to Request for Production with Incorporated Memorandum of Law
+may exceed 20 pages by one (1) additional page.
+DONE and ORDERED this _
+_day of
+, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 338-1 Entered on FLSD Docket 10/06/2009 Page 2 of 2
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies: Counsel of Record
diff --git a/vision-fixhub/court-01/e0870de6102993b3dc9903ae55582f2814932a002c41e9099918b256fc36cb2d.receipt.json b/vision-fixhub/court-01/e0870de6102993b3dc9903ae55582f2814932a002c41e9099918b256fc36cb2d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ded66175043c7ec197e7530eb1b17499eb1229aa
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new file mode 100644
index 0000000000000000000000000000000000000000..798304b183b949d28d70fed7061cca805f42582d
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@@ -0,0 +1,133 @@
+Case 9:08-cv-80736-KAM Document 141 Entered on FLSD Docket 01/24/2012 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+RESPONDENT'S UNOPPOSED MOTION FOR A Two (2) DAY ENLARGEMENT OF TIME TO
+SErVe ITs RePLY To PETITIONERS' RESPONSES TO GOVERNMENT's MoTIon To DISMIsS
+AND ITS RESPONSE TO PETITIONERS' PROTECTIVE MOTION FOR REMEDIES
+Respondent, by and through its undersigned counsel, hereby files its Unopposed Motion
+for a Two (2) Day Enlargement of Time to Serve Its Reply Petitioners' Responses to Government's
+Motion to Dismiss and Its Response to Petitioners' Protective Motion for Remedies, and states:
+On December 5, 2011, Petitioners filed their Response to Government's Sealed
+Motion to Dismiss for Lack of Subject Matter Jurisdiction (D.E. 127), as well as an accompanying
+Sealed Supplemental Response; a Response to Government's Sealed Motion to Stay (D.E. 129); a
+Protective Motion for Remedies (D.E. 128); and a Protective Motion to Compel (D.E. 130).
+Respondent's replies to Petitioners' responses were due on December 15, 2011, while responses to
+Petitioners' two motions were due on December 22, 2011.
+On December 15, 2011, Respondent moved for an enlargement of time, up to and
+including January 6, 2012, to file its responses and replies. The Court granted Respondent's
+motion on December 15, 2011. D.E. 137.
+On January 6, 2012, Respondent moved for a second enlargement of time, up to and
+1
+
+
+Case 9:08-cv-80736-KAM Document 141 Entered on FLSD Docket 01/24/2012 Page 2 of 5
+including January 24, 2012, to file its responses and replies. The Court granted that motion on
+January 9, 2012. D.E. 139.
+4.
+Since the Petitioners' December 5th filings, Assistant U.S. Attorney |
+Villafaña has been occupied with, inter alia, investigating and preparing for an evidentiary hearing
+that was originally scheduled for January 24, 2012, on a motion filed pursuant to 28 U.S.C. § 2255
+by an incarcerated individual. She has also been involved in an investigation involving an active
+death threat, and she is scheduled to begin back-to-back trials before Judge Ryskamp on January
+30, 2012 in United States v. Anes
+, Case No. 11-80165-Cr-Ryskamp(s) (S.D. Fla.), and
+United States v. Keslin
+Case No. 12-80003-Cr-Ryskamp (S.D. Fla.). Assistant U.S.
+Attorney Dexter Lee was similarly preparing for trial in a civil case, M.C. v. United States, Case
+No. 11-20216-Civ-Ungaro (S.D. Fla.), during that period. That trial began on Monday, January
+23, 2012, and concluded this afternoon following the conclusion of plaintiff's case pursuant to
+Fed. R. Civ. P. 52(c). As a result of these commitments and obligations, AUSAs Villafaña and
+Lee have had very little time to devote to the instant matter during the preceding weeks, and the
+undersigned, who has previously had limited involvement with the matter, undertook to assist
+them in preparing the pertinent responses and replies.
+5.
+Although the undersigned has worked diligently - including late into the evenings
+and during the preceding two weekends and federal holiday - to prepare the government's reply to
+the Petitioners' responses to the government's Motion to Dismiss and the government's response
+to the Petitioners' Motion for Protective Remedies, the undersigned has not yet been able to
+complete those memoranda and will be unable to file them by the current due date.' In addition,
+' The government, however, has today filed its reply to Petitioners' Response to
+Government's Sealed Motion to Stay (D.E. 129) and its response to Petitioners' Protective Motion
+2
+
+
+Case 9:08-cv-80736-KAM Document 141 Entered on FLSD Docket 01/24/2012 Page 3 of 5
+due to the undersigned's limited involvement with this matter, those memoranda must be reviewed
+prior to filing by others who have a complete working knowledge of the matter and its history,
+including AUSA Lee, who has been handling this matter for the last three years but who is
+currently in trial.
+In order to complete the government's reply to the Petitioners' responses to the
+government's Motion to Dismiss and the government's response to the Petitioners' Motion for
+Protective Remedies, the government will need an additional two (2) days, through and including
+January 26, 2012.
+This motion is not made for purposes of delay or for any other improper purpose.
+Rather, the requested extension of time is necessary for the government to prepare its responses
+and replies in this matter. Given the circumstances in this case and the nature of the issues raised
+in the Petitioners' filings, the requested extension of time is reasonable and should not cause the
+Petitioners any undue prejudice. Indeed, Petitioners' counsel,
+Esq., has
+represented that Petitioners do not oppose the extension of time requested in this motion.
+WHEREFORE, respondent respectfully requests a two (2) day enlargement of time, up to
+and including January 26, 2012, to serve its reply to petitioners' responses to the government's
+sealed motion to dismiss for lack of jurisdiction and to serve its response to Petitioners' protective
+motion for remedies.
+to Compel (D.E. 130).
+3
+
+
+Case 9:08-cv-80736-KAM Document 141 Entered on FLSD Docket 01/24/2012 Page 4 of 5
+DATED:
+January 24, 2012
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+s/ Eduardo I.
+Eduardo I.
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9057; Fax: (305) 536-4676
+Email:
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on January 24, 2012, the foregoing Unopposed Motion for a
+Two (2) Day Enlargement of Time to Serve Its Reply Petitioners' Responses to Government's
+Motion to Dismiss and Its Response to Petitioners' Protective Motion for Remedies was filed with
+the Clerk of the Court and served on counsel on the attached list using CM/ECF.
+s/ Eduardo L
+Eduardo I.
+Assistant United States Attorney
+4
+
+
+Case 9:08-cv-80736-KAM Document 141 Entered on FLSD Docket 01/24/2012 Page 5 of 5
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Brad
+Esq.,
+-Jaffe, Weissing,
+, Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+5
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diff --git a/vision-fixhub/court-01/e09a3ce1a95a0f7721895f6e2e7493be874b4615151aaba22645ce613b71a6d4.md b/vision-fixhub/court-01/e09a3ce1a95a0f7721895f6e2e7493be874b4615151aaba22645ce613b71a6d4.md
new file mode 100644
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@@ -0,0 +1,405 @@
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 1 of 11
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition Te
+Defendant's Emergency Motion For Independent Examination Of Plaintiff, With
+Incorporated Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition To
+Defendant's
+Emergency Motion For Independent Examination Of Plaintiff, With
+Incorporated Memorandum Of Law (the "Emergency Motion"), and in support, states as
+follows:
+1.
+On July 29, 2009, Defendant, Jeffrey Epstein filed the Emergency Motion.
+Since the filing of the Emergency Motion, the undersigned has learned and
+this court has been informed that Plaintiff is in the hospital.
+3.
+On August 11, 2009, this court entered an order granting Plaintiff's
+Motion for Protective Order relative to her deposition based upon Plaintiff's medical
+status. Defendant understands that this court will make a similar ruling relative to
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 2 of 11
+Plaintiff's independent medical evaluation and, thus, will not allow same to go forward
+while Plaintiff is in the hospital. In that specific regard, Defendant does not seek an
+alternative ruling; however, Defendant must address other aspects of Plaintiff's
+Response.
+4.
+Plaintiff seems to forget that this court issued its trial order requiring
+various deadlines to be met. In fact, Plaintiff's counsel was in a three or four-week trial
+County and, therefore, an agreement regarding dates of availability for
+Plaintiff's deposition and IME could not be reached. As such, the undersigned had no
+option but to unilaterally set same and file the Emergency Motions addressing those
+events.
+5.
+Up until May 20, 2009, Plaintiff refused to allow Defendant to identify her
+by name in various third-party subpoenas directed to Plaintiff's health care providers,
+past and current; basic personal injury discovery. If defendant could not use CMA's
+name, how could the provider have provided records from a "CMA" designation? Then,
+on May 20, 2009, C.M.A. capitulated and filed her Notice of Withdrawal of Previously
+Raised Objections to Epstein's Motion to Compel and/or Identify C.M.A. in the Style of
+this Case and Motion to Identify C.M.A. in Third-Party Subpoenas for Purposes of
+Discovery, or Alternatively, Motion to Dismiss Sue Sponte (DE 23)(the "Notice of
+Withdrawal").
+Subsequent thereto, Defendant sought records by way of subpoena.
+However, on June 5, 2009, Plaintiff then filed a Motion for Protective Order Regarding
+Treatment Records From Parent-Child Center, Inc. and Dr. Serge Thys (DE 114). On
+June 17, 2009, Plaintiff filed a subsequent Motion for Protective Order Regarding
+Treatment Records From Palm Beach County School District, Good Samaritan Hospital,
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 3 of 11
+St. Mary's Hospital Dr. Gloria C. Hakkarinen, and Florida Atlantic University (DE 121).
+Thus, while Plaintiff agreed to allow Defendant to identify her in various third-party
+subpoenas directed to her physicians, she utilized another delay tactic to prevent
+discovery of her past medical and psychological history from being discovered. After
+Plaintiff allowed Defendant to use her name in third party subpoenas, Defendant served
+subpoenas on:
+a. Palm Beach County School District
+b. Dr. Serge Thys
+c. Parent/Child Center
+d. Good Samaritan Hospital
+e. St. Mary's Hospital
+I. Dr. Gloria C. Hakkarinen
+g. Florida Atlantic University
+CMA then filed two (2) protective orders, and all records that were obtained (or were to
+be obtained) went sent to her attorney, ie. discovery was halted by CMA not the
+Defendant. Without the health care provider information, including psychological/
+psychiatric records, Defendant contended that it would be impossible to have a
+meaningful compulsory psychological examination by a defense expert. For example,
+Defendant's attorneys recently took the deposition of Susan Pope, who counseled
+Plaintiff for the last 12 years. Significantly, Susan Pope could not identify anywhere in
+her records from 2003 through 2009 wherein Plaintiff ever mentioned Jeffrey Epstein.
+See Exhibit "A". Obviously, such information (or lack thereof) is telling and goes
+directly to the heart of Plaintiff's alleged damages claim and Defendant's defenses
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 4 of 11
+thereto.
+As such, Plaintiffs continued requests for this court to allow her to assert
+allegations against Defendant and subsequently limit the discovery he seeks to disprove
+those allegations should be denied.
+6. In furtherance of Plaintiff's continued efforts to delay and prevent discovery,
+Plaintiff now asks this court in her Response Motion to:
+a. limit the time for conducting the examination, including any testing to six
+(6) hours;
+b. limit the scope of the examination to preclude Plaintiff from being
+subjected to repeated questioning on multiple occasions regarding
+personal and highly sensitive areas including Plaintiffs' medical history,
+psychiatric history, sexual history social history, sexual abuse history,
+substance abuse history, etc... and
+c. authorizing the presence of a representative from Plaintiff's counsel's
+office to attend the examination.
+Defendant Should Be Afforded Between 6-8 Hours To Conduct The IME And The
+Examination Proposed By Defendant's Expert Should Not Be Limited Since Such A
+Limitation Would Unduly Prejudice Defendant's Expert's Analysis Of Plaintiff
+7. Fed.R.Civ.P. 35(a). Rule 35(a) provides, in pertinent part:
+When the mental or physical condition (including the blood group) of a party or
+of a person in the custody or under the legal control of a party, is in controversy,
+the court in which the action is pending may order the party to submit to a
+physical or mental examination by a suitably licensed or certified examiner or to
+produce for examination the person in the party's custody or legal control. Th
+order may be made only on motion for good cause shown and upon notice to the
+person to be examined and to all parties and shall specify the time, place, manner,
+condition, and scope of the examination and the person or persons by whom it is
+to be made. (emphasis added)
+8. A Cursory review of the Amended Complaint shows that Plaintiff has alleged 31
+Counts against the Defendant. Limiting the IME to only 6 hours would allow for
+Defendant's expert to dedicate only 12 minutes of his time and evaluation to each count
+in Plaintiff's complaint.
+Accordingly, the full six to eight (8) hours is required, as
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 5 of 11
+requested by Dr
+While different, Rule 30 governing depositions allows for seven
+(7) hours - this court has the discretion to enter an order allowing for 8 hours relative to
+an IME. See infra. Furthermore, Defendant's expert has provided an affidavit consistent
+with Rule 35 stating the scope of his examination and the time needed to complete same.
+See (DE 228) Dr. has adequately set forth his need to conduct his evaluation, and
+his analysis would suffer should this court restrict same in time or scope. Lahr V.
+Fullbright & Jaworski, LLP., 164 F.R.D 196, 202-204 (N.D. Texas 1995)(refusing to
+limit examination); Morton v.
+Co., No. 94-976-CIV-J-20, 1995 WL 819182, at
+*3 (N.D.Fla. Sept.12, 1995) (declining to limit duration of examination); See also
+Affidavit of Dr.
+
+v. Newport Tankers Corp., 96 F.R.D. 31, 33
+(S.D.N.Y. 1982)(requiring Plaintiff to submit to 2 day examination).
+9. As to the scope of the deposition, see supra, Plaintiff once again seeks to have
+this court enter an order protecting her from discovery (i.e., from filling out the
+applicable questionnaire required by Defendant's expert and from answering questions
+relative to her damages). This is simply specious.
+10. CMA is seeking millions of dollars in personal injury damages. In fact, Plaintiff's
+allegations place her mental, emotional and psychological states at issue. For instance, in
+her answers to interrogatory nos. 9 and 10, which seek information about C.M.A.'s
+damage claims, Plaintiff answered that:
+I have bi-polar disorder and manic depression. I lost my self-esteem. I
+began cutting myself on my arms and legs and developed drug problems.
+Permanent injuries are psychological. (Interrog. No. 9).
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 6 of 11
+least the statutory minimum established by 18 U.S.C.A. §2255. (Interrog.
+No. 10).
+11. In her 1 Amended Complaint, relevant to her damages claims, Plaintiff alleges:
+... C.M.A., has in the past suffered, and will in the future suffer, physical
+injury, pain and suffering, emotional distress, psychological trauma, mental
+anguish, humiliation, embarrassment, loss of self-esteem, loss of dignity,
+invasion of her privacy and other damages .... The then minor Plaintiff
+incurred medical and psychological expenses ... and will in the future suffer
+additional medical and psychological expenses. The Plaintiff C.M.A. has
+suffered loss of income, a loss of the capacity to earn income in the future, and a
+loss of capacity to enjoy life. These injuries are permanent in nature and the
+Plaintiff, C.M.A., will continue to suffer these losses in the future.
+(1 Am. Complaint, Counts I - XXX (18 U.S.C. §2255), 1125, 31, 37, 43, 49,
+55, 61, 67, 73, 79, 85, 91, 97, 103, 109, 115, 121, 127, 133, 139, 145, 151, 157,
+163, 169, 175, 181, 187, 193; Count XXXI (Sexual Battery), 1199.)
+See Fajardo v. Pierce County, 2009 WL 1765756 (W.D. Wash. 2009) (allegations of
+specific disorders amount to more than garden variety disorders and thus Plaintiff waived
+physician-patient privilege as it involved a complex medical issue); Alexander v. City of
+Bellingham, 2008 WL 2077970 (W.D. Wash. 2008); Grit v. Target Corp., 2008 WL
+1777744 (M.D. Fla. 2008); Trenary v. Bush Entertainment Corp., 2006 WL 3333621
+(M.D. Fla. 2006)(responses to interrogatories placed plaintiff's mental condition at
+issue; Tracey P. v. Sarasota County, 2006 WL 1678908 (M.D. Fla. 2006)(responses to
+interrogatories delineating depression and bi-polar disorder are more than simple
+allegations of emotional distress thus placing plaintiff's mental condition at issue).
+12. Next, the following represents conduct and events that had to have had a
+substantial effect on CMA's life and emotional/psychological makeup. These are merely
+examples and just the tip of the iceberg, but are necessary for Defendant's expert to cover
+due to the damages Plaintiff seeks.
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 7 of 11
+• On March 27, 2000, in Palm Beach County Sheriff's Office Case #00-54914,
+CMA threw a cinder block at her mother's boyfriend's car.
+• On April 11, 2000, in Palm Beach County Sheriff's Office Case #00-61772,
+officers responded to the house in reference to child abuse involving CMA, her
+brothers, and her mother.
+• On June 29, 2000, in Palm Beach County Sheriff's Office Case #00-95746,
+CMA's mother contacted the police after hearing CMA's friends threaten to kill
+her (CMA).
+• On July 26, 2000, in Palm Beach County Sheriff's Office Case #00-106500,
+officers responded in reference to Criminal Mischief. CMA was a victim of
+having her window broken at her house by a Tonya
+stated she went
+to CMA's house to confront CMA about CMA having sexual relations with her
+boyfriend. CMA would have been thirteen (13) years old at this time.
+• On August 24, 2000, in Palm Beach County Sheriff's Office Case #00-118442,
+CMA was arrested for aggravated assault after chasing her brother around the
+house with a knife.
+• On September 5, 2001, in Palm Beach County Sheriff's Office Case #01-119103,
+CMA's mother reported her missing. At the time CMA was on house detention
+Tor previous crimes and for being truant from school. A pick-up order was in
+effect and CMA was subsequently detained.
+• On November 24, 2001, in Palm Beach County Sheriff's Office Case #01-
+150237, officers responded in reference to a Battery. CMA and her brother
+witnessed their mother being beaten by her then boyfriend, Lance Bell.
+• On March 26, 2002, in Palm Beach County Sheriff's Office Case #02-48096,
+officers responded to the house in reference to child abuse involving CMA, her
+brothers, and her mother.
+• On April 6, 2002, in Palm Beach County Sheriff's Office Case #02-571, CMA's
+mother was arrested for possession of crack cocaine and CMA and her brothers
+were removed from their home.
+• On October 8, 2002, in Palm Beach County Case #02MH1402, CMA's mother
+filed a Marchman Act Petition naming CMA after she told a judge that she was
+hospitalized for overdosing on Xanax and Marijuana, was truant from school,
+has anger issues, mental disabilities, and needs treatment for self inflicting
+wounds. The case was closed on October 31, 2002, because CMA was to be in
+court the following day for a probation violation.
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 8 of 11
+• On July 27, 2004, in Palm Beach County Case #04MH1530, CMA's mother filed
+a Marchman Act Petition naming CMA after she told a judge that she was
+constantly testing positive for cocaine and marijuana.
+• On August 16, 2004, in Palm Beach County Case #04MH1676, CMA's mother
+filed a Marchman Act Petition naming CMA after she told a judge that treatment
+at home was not working and a residential facility would be needed.
+• On August 22, 2004, in Palm Beach County Case #0SMH1934, CMA's mother
+filed a case naming CMA for a Petition for Involuntary Assessment for
+Substance Abuse. CMA's mother stated that CMA was homeless, unclean, and
+prostituting herself.
+• On August 22, 2005, in Palm Beach County Case #05MH1667, CMA's mother
+filed a case naming CMA for a Petition for Involuntary Assessment for
+Substance Abuse. CMA's mother claimed that CMA was homeless, unclean, has
+been prostitution herself for crack cocaine, is addicted to Xanax, is a cutter and
+self mutilator, living in a hotel, and has been diagnosed as Bipolar and
+Schizophrenic.
+13. Clearly, Plaintiff has alleged specific psychological disorders (bi-polar and manic
+depression), and seeks to recover medical expenses associated with those complex
+medical issues. Moreover, she has alleged and seeks to recover personal injury damages
+including, but not limited to, physical injury, pain and suffering, emotional distress,
+psychological trauma, mental anguish, humiliation, embarrassment, loss of self-esteem,
+loss of dignity, invasion of her privacy and other damages. As such, full knowledge of
+Plaintiff's past and present medical and psychological histories is not only permitted
+under the law, but is necessary to arrive at a full level of damages. To hold otherwise
+will result in reversible error, and will prevent Epstein from defending himself and this
+case, thereby violating his due process rights. Further, this court has already entered
+similar orders allowing for such discovery - this matter should not be treated any
+differently. Accordingly, Plaintiff's request to limit the time or scope of the IME should
+be denied.
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 9 of 11
+14. As for Plaintiff's request to have a representative in the room with her during the
+IME, same should be denied. See Affidavit of Dr.
+LEx. "B". First, consistent with
+the related cases, Plaintiff may have the IME videotaped. However, the operator of the
+video-camera may not be present. Second, the undersigned will agree that an agent may
+be present at the undersigned's firm during the IME; however, that person may not be
+present in the room where the examination is taking place. However, that person shall be
+permitted to sit right outside the office where the examination is taking place. Third,
+Plaintiff has failed to specify which representative she intends to be present at the IME.
+As the court is well aware, IMEs are adversarial in nature. Therefore, having an attorney
+and/or Plaintiff's expert in the room would create an adversarial forum that would
+undoubtedly interfere with the IME. Finally, Plaintiff has failed to cite any case law
+supporting her request to have someone present in the room with her during the IME.
+Accordingly, same should be denied.
+WHEREFORE, Epstein, through his counsel, requests that this court enter an Order:
+a. requiring that Plaintiff's counsel keep the undersigned updated as to
+Plaintiff's medical condition and provide Plaintiff's counsel with a date to
+conduct the IME within 2 weeks after her release from the hospital;
+b. refusing to limit the time and scope of CMA's IME and requiring her to
+c. instructing Plaintiff that she may videotape the IME but she may not have
+someone present in the room with her, which includes an operator of the
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+
+
+Case 9:08-cV-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 10 of 11
+the manner specified by CM/ECF on this IZ day of flees, 2009
+eing served this day on all counsel of record identified on the following Service List it
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Brad
+Rothstein Rosented Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232,
+08-80380, 08-80381,
+08-80993, Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+
+
+Case 9:08-cv-80119-KAM Document 273 Entered on FLSD Docket 08/17/2009 Page 11 of 11
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Esq.
+Counsel for Plaintiff in Related Case No.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+Jack P. L
+Esq
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff. C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+lack Alan Goldberger, Esq
+\terbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+jagesq@bellsouth.net
+Spencer T. Kuvin, Esq.
+Counsel for Defendant Jeffrey Epstein
+_eopold, Kuvin, P.A
+2925 PGA Blvd.. Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
diff --git a/vision-fixhub/court-01/e09a3ce1a95a0f7721895f6e2e7493be874b4615151aaba22645ce613b71a6d4.receipt.json b/vision-fixhub/court-01/e09a3ce1a95a0f7721895f6e2e7493be874b4615151aaba22645ce613b71a6d4.receipt.json
new file mode 100644
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+}
diff --git a/vision-fixhub/court-01/e0d8306d45020c04f879f0a2d803247a380a4d132d2aa1f24dc66323ae2daaf9.md b/vision-fixhub/court-01/e0d8306d45020c04f879f0a2d803247a380a4d132d2aa1f24dc66323ae2daaf9.md
new file mode 100644
index 0000000000000000000000000000000000000000..4f35d975e83aaa1b33adff49dc54aed7e29f8416
--- /dev/null
+++ b/vision-fixhub/court-01/e0d8306d45020c04f879f0a2d803247a380a4d132d2aa1f24dc66323ae2daaf9.md
@@ -0,0 +1,204 @@
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRAL
+JANE DOE NO. 5,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+Defendant, Jeffrey Epstein's Reply to Plaintiff's Response In Opposition To Defendant's
+Motion To Stay And/Or Continue Action For Time Certain With Incorporated
+Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Reply to Plaintiff's Response In Opposition to
+Defendant's Motion to Stay and/or Continue Action, and states:
+I.
+Introduction and Argument
+Plaintiff's Response in Opposition challenging the stay should not prevail when
+5" Amendment principles are at issue and when there exists a real, substantial and not
+remote possibility that Epstein may face criminal prosecution by the United States
+Attorneys' Office ("USAO") if the USAO unilaterally determines that Epstein somehow
+violated that certain Non-Prosecution Agreement dated June 30, 2008 ("NPA") and/or if
+Epstein is forced to waive those 5" Amendment rights and participate in civil discovery
+in order to defend this civil action.
+Epstein should not be confronted with the substantial risk of loosing this civil
+action by virtue of asserting his 5' Amendment privileges. Despite Plaintiff's contention,
+Epstein's Motion does not concentrate solely on the fact that the pleadings are not at
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 2 of 7
+Page 2
+the summary judgment stage. The motion also concentrates on Epstein's risk of loosing
+this entire civil action as a result of Epstein invoking his 5* Amendment rights. Severino
+y. Klytie's Developments, Inc., 2008 WL 1782637, *2 (D. Colo)(recognizing that a stay is
+appropriate under similar circumstances as in the instant case); see also infra.
+In fact, waiver of Epstein's 5" Amendment privileges should not be compelled to
+defend this civil action (and could be remedied by a reasonable stay), especially when
+civil discovery may lead to the USAO unilaterally declaring a violation of the NPA.
+The USAO has already unilaterally claimed that EPSTEIN violated the NPA by,
+among other things, "investigating the Plaintiffs (by and though his attorneys)
+whom brought civil suits against him for purposes of defending those civil
+actions" and "by contesting damages in this action and in the other civil actions."
+See Motion to Stay and Jack Goldberger Affidavit attached thereto as Exhibit "B". Thus,
+these are not vague assertions as Plaintiff claims. How can Epstein truly defend these
+matters and be afforded his due process rights when to do so might result in the USAO
+claiming a breach of the NPA? The fact is that he cannot. Notwithstanding the
+allegations against Epstein, this Court has an obligation to ensure his due process
+rights are upheld in both the civil and criminal contexts.
+Next, in her response, Plaintiff claims that a stay should not be entered because
+a parallel criminal proceeding against Epstein does not exist. Not only is Plaintiff's
+theory incorrect for reasons set out herein and in the Epstein's Motion to Stay, but her
+response ignores the significant fact that a stay may be issued in light of an ongoing
+investigation. It is clear from the NPA and Jack Goldberger's Affidavit (attached to the
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 3 of 7
+Page 3
+Motion to Stay) "...that the criminal matters against Epstein remain ongoing until the
+NPA expires by its terms in late 2010..., and the threat of criminal prosecution against
+Epstein by the USAO continues presently and through late 2010." See Jack
+Goldberger's Affidavit, 15 (attached to the Motion to Stay). In fact, the FBI refused to
+provide information regarding this case and other related cases filed against Epstein "..
+•stating the materials are at this time exempt from disclosure because they are in an
+investigative file, i.e., the matter is still an ongoing criminal investigation." See Jack
+Goldberger's Affidavit, 117 (attached to the Motion to Stay)
+Additionally, Plaintiff's response downplays the fact that civil discovery may result
+in the USAO claiming a breach of the NPA. Epstein wishes to vigorously defend this
+case and others filed against him; however, he does not wish to risk waiver of his 5"h
+Amendment privileges, at least before the NPA expires or any investigation is closed.
+Further, Plaintiff adopts the arguments set forth in Jane Doe's Response to the
+Motion to Stay filed in 08-CIV-80893, which asserts that the NPA is not attached to
+Epstein's Motion to Stay. The Court has a copy of the NPA. While it may be sealed,
+this Court may review same, in camera. As such, Plaintiff's Best Evidence argument
+(as adopted in the instant response) is entirely misplaced and should be disregarded.
+a.
+Justice Requires The Entry of A Stay
+As set out in the Motion to Stay, once the NPA expires, EPSTEIN intends to
+testify to all relevant and non-objectionable inquiries made to him in discovery be it a
+deposition, in interrogatories or in production requests.
+However, the current
+circumstances are such that by testifying or responding to discovery, EPSTEIN will be
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 4 of 7
+Page 4
+required to waive his constitutional privileges, thereby subjecting himself to scrutiny by
+the USAO as a result of matters alleged in this civil action (and others before this Court
+and in the State of Florida 15* Judicial Circuit Court, Palm Beach County).
+When an ongoing criminal investigation exists, courts have granted motions to
+stay civil proceedings. In St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct
+513 (1991); the court held that staying a civil action for 6-9 months was reasonable in
+light of a pending criminal investigation so long as the movant met certain elements
+(see infra) and the stay was not immoderate or unreasonable. Taking into consideration
+the Motion to Stay and this Reply as well as facts alleged by Plaintiff in her operative
+pleading against Epstein, it is clear that Epstein has met the elements of St. Paul Fire
+necessary for this Court to enter a stay:
+1.
+Epstein has made a clear showing, by direct or indirect proof, that
+the issues in the civil action are "related" as well as "substantially similar"
+to the issues in the criminal investigation.
+Epstein has made a clear showing of hardship or inequity if
+required to go forward with this civil case while the NPA and/or the
+ongoing investigation exist. (see supra and see also Motion to Stay and
+attached affidavit of Jack Goldberger, Esq. discussing Epstein's 5'h
+Amendment Rights and how those rights affect this civil litigation - see
+supra); and
+3. Epstein, in light of the stays granted by other courts, has shown
+that a stay in the instant matter until late 2010 (the date the NPA expires)
+and the likely date any ongoing investigation will be closed is not
+immoderate or unreasonable.
+St. Paul Fire and Marine Insurance Company v. U.S., 24 CI.Ct at 515-16; see also
+Wilson v. National Association of Letter Carriers, 2006 WL 3791313, *1 (E.D. La.
+2006) (granting motion to stay civil proceeding for 2 years and 7 months pending
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 5 of 7
+Page 5
+criminal investigation); Ostrow v. U.S., 1986 WL 6855, *1 (M.D. Fla.)(recognizing a
+defendant's constitutional rights and allowing for a stay of the civil case until the criminal
+aspects/investigation of Defendant's companion case are closed).
+Here, Epstein is not required to "contemplate an in haec verba iron-clad
+comparison of separate issues by direct proof." St. Paul Fire and Marine Insurance
+Company v. U.S., 24 CI.Ct at 516. Instead, a reading of the complaint, the NPA (in
+camera), the pleadings in support of and against Epstein's Motion to Stay along with
+other pleadings in the clerk's file, makes it clear that the facts in the instant matter and
+those in the ongoing investigation are "related" and/or "substantially similar." Id. As
+such, permitting this civil action to go forward would create a hardship on Epstein in that
+he will be forced to invoke his 5" Amendment Privilege and risk loosing this case by
+virtue of not being able to present evidence, or waive that right and risk a potential
+criminal prosecution. Eastwood v. U.S., 2008 WL 5412857, *1 (E.D. Tenn.)) "When a
+party to a civil action is subject to criminal proceedings and/or investigations that relate
+to such civil action, courts will often stay the civil proceeding so as to prevent the use of
+civil discovery and evidentiary procedures to obtain evidence for use in the criminal
+matter). Id. Courts will also stay a civil case to preserve 5" Amendment rights. Id.
+Further, a comparison of Fed.R.Civ. Pro. 26 may expand the rights of criminal discovery
+beyond the limits of Fed.R.Crim.Pro. 16(b). Epstein satisfies the requirements to stay
+this action as set forth in St. Paul Fire and in Eastwood, including the similarity of issues
+underlying the civil litigation and ongoing criminal investigation. As such, a stay should
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 6 of 7
+Page 6
+be entered in the instant matter. See also U.S. v. $75,020.00 In United States Funds, et
+al., 2009 WL 1010359 (M.D. G.a. 2009).
+Ill. Conclusion and Reguest for Relief
+Based upon the foregoing, Epstein is entitled to a full stay of this proceeding (and
+other related matters) until such time as the NPA expires and until the ongoing
+investigation by the USAO is closed (i.e., until late 2010). Alternatively, in an effort to
+protect Epstein's 5" Amendment and his due process rights in connection with
+defending these civil matters, this court should enter a stay of any discovery directed to
+Epstein and strike this case from the trial docket until the NPA and the ongoing
+investigation are both concluded and/or expired. In this manner, Plaintiff's investigation
+and discovery as to third parties will continue and will not be delayed. Epstein is
+invoking his 5* Amendment rights in the first place, which means that objections to
+discovery and deposition questions are being asserted so as not to waive those 5*
+Amendment rights. Once the NPA and the ongoing investigation terminate, this court
+could allow additional time for Plaintiff to complete Epstein's deposition and discovery
+directed to him, and then set this case on the Court's most available docket. Despite
+Plaintiff's contentions, Epstein's 5" Amendment rights and his due process rights
+associated therewith and in connection with defending this civil case should trump any
+civil claim for money damages when it comes to timing. Eastwood v. U.S., 2008 WL
+5412857, *6 (reasoning that a stay is warranted when the risk to an individual's
+constitutional rights is magnified).
+
+
+Case 9:08-cv-80381-KAM Document 89 Entered on FLSD Docket 05/13/2009 Page 7 of 7
+Page 7
+WHEREFORE, Epstein requests the following relief set forth above, and for such
+other and further relief as this court deems just and proper.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this If day of May, 2009:
+Stuart S. Mermelstein, Esq.
+Jack Alan Goldberger
+Adam D. Horowitz, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Mermelstein & Horowitz, P.A.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 1400
+Suite 2218
+West Palm Beach, FL 33401-5012
+Miami, FL 33160
+561-659-8300
+305-931-2200
+Fax: 561-835-8691
+Fax: 305-931-0877
+jagesq@bellsouth.net
+ssm@sexabuseattorney.com
+Co-Counsel for Defendant Jeffrey Epstein
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+ROBERT B. CRITON, IR, ESC
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e0d8306d45020c04f879f0a2d803247a380a4d132d2aa1f24dc66323ae2daaf9.receipt.json b/vision-fixhub/court-01/e0d8306d45020c04f879f0a2d803247a380a4d132d2aa1f24dc66323ae2daaf9.receipt.json
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/e0e1961bce87181b533290f88f57b071efb3aedca117307d9c825f3586883c8a.md b/vision-fixhub/court-01/e0e1961bce87181b533290f88f57b071efb3aedca117307d9c825f3586883c8a.md
new file mode 100644
index 0000000000000000000000000000000000000000..319c74a5f1cf3fc897c04fadd6bc7656057e3045
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@@ -0,0 +1,71 @@
+Case 9:08-cv-80119-KAM Document 267 Entered on FLSD Docket 08/14/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+NOTICE OF FILING DECLARATIONS OF JANE DOE NO. 4 AND Y.B. IN FURTHER
+SUPPORT OF PLAINTIFFS' JANE DOES 2-7 MOTION FOR PROTECTIVE ORDER
+Plaintiffs, Jane Does 2-7, by and through their undersigned counsel, hereby file the
+attached Declarations of Jane Doe No. 4 and Y.B. in further support of Plaintiffs' Jane Does 2-7
+Motion for Protective Order (DE 226).
+Dated: August 14, 2009.
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssmm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+
+
+Case 9:08-cv-80119-KAM Document 267 Entered on FLSD Docket 08/14/2009 Page 2 of 3
+CERTIFICATE OF SERVICE
+I hereby certify that on August 14, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Stuart S. Mermelstein
+2
+
+
+Case 9:08-cv-80119-KAM Document 267 Entered on FLSD Docket 08/14/2009 Page 3 of 3
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+3
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+}
diff --git a/vision-fixhub/court-01/e106459828c8e6f568f679f15c3c52d4aef864977c5cd10fbad54d7bcf89eec0.md b/vision-fixhub/court-01/e106459828c8e6f568f679f15c3c52d4aef864977c5cd10fbad54d7bcf89eec0.md
new file mode 100644
index 0000000000000000000000000000000000000000..37c23a23f9516705cb1e22c6890663e6246f169c
--- /dev/null
+++ b/vision-fixhub/court-01/e106459828c8e6f568f679f15c3c52d4aef864977c5cd10fbad54d7bcf89eec0.md
@@ -0,0 +1,99 @@
+Case 9:08-cv-80119-KAM Document 400 Entered on FLSD Docket 11/05/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER
+This cause is before the Court upon Plaintiff Jane Doe's Motion for Injunction
+Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of
+Property of Epstein, and to Post a S15 Million Bond to Secure Potential Judgment (DE 165).
+Defendant Jeffrey Epstein filed a response in opposition to the motion (DE 198), and Plaintiff
+filed a reply (DE 217). The motion is now fully briefed and ripe for review.
+Plaintiff's motion argues that Defendant is fraudulently transferring his assets with the
+specific intent to defeat any judgment that might be entered against him in this and other similar
+cases. Plaintiff therefore seeks an order enjoining Defendant from fraudulent transfers of his
+assets, appointing a receiver to take charge of Defendant's property, and requiring Defendant to
+post a $15 million dollar bond against any potential judgment in this case.
+
+
+Case 9:08-cv-80119-KAM Document 400 Entered on FLSD Docket 11/05/2009 Page 2 of 4
+The relief sought by Plaintiff is injunctive and, essentially, amounts to a prejudgment writ
+of attachment.
+v. Cascade Intern., Inc., 21 F.3d 1520, 1530 (11" Cir. 1994) (vacating
+district court's preliminary injunction freezing defendant's assets). "No relief of this character
+has been thought justified in the long history of equity jurisprudence." De Beers Consol. Mines,
+Ltd. v. United States, 325 U.S. 212, 222-23 (1945).
+"Preliminary injunctive relief freezing a defendant's assets in order to establish a fund
+with which to satisfy a potential judgment for money damages is simply not an appropriate
+exercise of a federal district court's authority." |
+1. 21 F.3d at 1530. Indeed, "li]t is entirely
+settled by a long and unbroken line of Florida cases that in an action at law for money damages,
+there is simply no judicial authority for an order requiring the deposit of the amount in
+controversy into the registry of the court.... or indeed for any restraint upon the use of a
+defendant's unrestricted assets prior to the entry of judgment." Id. at 1531, guoting Konover
+Realty Assoc.., Ltd. v. Mladen, 511 So.2d 705, 706 (Fla. 3d DCA 1987).
+In Florida, an injunction cannot be entered to prevent a party from using or disposing of
+his assets prior to the conclusion of a legal action. Briceno v. Bryden Investments, Ltd., 973
+So.2d 614, 616 (Fla. 3d DCA 2008). See also SME Racks, Inc. v. Sistemas Mecanicos Para,
+Electronica, S.A.., 243 Fed.Appx. 502 (11" Cir. 2007) (affirming district's court's denial of
+preliminary injunction to freeze defendant's assets); Proctor v. Eason,651 So.2d 1301, 1301-02
+(Fla. 2d DCA 1995) (Defendant not required to deposit funds in court registry prior to final
+judgment where Plaintiff failed to show unavailability of' an adequate remedy at law and the
+likelihood of irreparable harm, two elements essential to entry of an injunction); Lawhon v.
+Mason, 611 So.2d 1367 (Fla. 2d DCA 1993) (quashing trial court order requiring defendant to
+2
+
+
+Case 9:08-cv-80119-KAM Document 400 Entered on FLSD Docket 11/05/2009 Page 3 of 4
+give plaintiffs ten days notice prior to the transfer of any assets in excess of $500).
+Additionally, as the Eleventh Circuit explained in l
+In actions at law, plaintiffs in Florida possess an adequate, exclusive prejudgment
+remedy for the sequestration of assets under the attachment statute, Fla.Stat.Ann.
+$ 76.04-.05 (West 1987), provided that they can satisty the enumerated statutory
+grounds for relief. Accordingly, the use of injunctive relief as a substitute for
+the remedy of prejudgment attachment, with its attendant safeguards, is
+improper.
+21 F.3d at 1531 (emphasis added). Here, Plaintiff did not move to amend her complaint to allege
+a claim under the Florida Uniform Fraudulent Transfers Act ("FUFTA"), Fla. Stat. § 726.101, et
+seq.' Rather, she filed the present motion for injunctive relief. Even if she had moved to amend
+her complaint, it is certainly not clear that she could meet the required statutory elements.
+Plaintiff's motion is premised on the contention that Defendant is fraudulently transferring his
+assets. However, Plaintiff's motion is entirely devoid of evidence of Defendant's alleged
+fraudulent transfers. The Court declines to conclude that Defendant is fraudulently transferring
+assets based upon the adverse inferences relied upon by Plaintiff. Plaintiff's supplemental filing
+regarding the titles of approximately five of Defendant's vehicles is clearly de minimis,
+particularly in light of Plaintiff's repeated characterization of Defendant as a "billionaire."
+Based upon the foregoing, it is hereby
+ORDERED AND ADJUDGED that
+'Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent
+Transfers Act ("FUFTA"), Fla. Stat. § 726.101, et seq.. FUFTA, as set forth in Florida Statute §
+726.105, provides the substantive requirements that must be pled to state a valid fraudulent
+transfer claim. Nationsbank, N.A. v. Coastal Utilities, Inc., 814 So.2d 1227, 1229 (Fla. Dist Ct.
+App. 2002). The plaintiff must show that "(1) there was a creditor to be defrauded; (2) a debtor
+intending fraud; and (3) a conveyance of property which could have been applicable to the
+payment of the debt due." Id.
+3
+
+
+Case 9:08-cv-80119-KAM Document 400 Entered on FLSD Docket 11/05/2009 Page 4 of 4
+(1) Plaintiff Jane Doe's Motion for leave to Provide Recently-obtained Deposition
+Testimony and Affidavit (DE 386 in 08-80119) is GRANTED.
+(2) Plaintiff Jane Doe's Motion for Injunction Restraining Fraudulent Transfer of Assets,
+Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a S15 Million
+Bond to Secure Potential Judgment (DE 165 in 08-80119) is DENIED.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 5" day of November, 2009.
+KENNETH A. MARRA
+United States District Judge
+Copies to:
+all counsel of record
+4
diff --git a/vision-fixhub/court-01/e106459828c8e6f568f679f15c3c52d4aef864977c5cd10fbad54d7bcf89eec0.receipt.json b/vision-fixhub/court-01/e106459828c8e6f568f679f15c3c52d4aef864977c5cd10fbad54d7bcf89eec0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ed5bbca17892ff7eb32b4c00f8726f48f197d3d1
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.md b/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.md
new file mode 100644
index 0000000000000000000000000000000000000000..ab8bb58cd9b8162b91ada7b959249a9a3be8f4ec
--- /dev/null
+++ b/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.md
@@ -0,0 +1,22 @@
+Case 9:08-cv-80736-KAM Document 67-1
+Entered on FLSD Docket 04/14/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+[PROPOSED] ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+MOTION FOR EXTENSION OF TIME TO COORDINATE FILING DEADINE FOR
+RESPONSE TO MOTION TO INTERVENE
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Extension of Time to Coordinate Filing Deadline for Response to Motion to
+Intervene, filed April 14, 2011.
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims may file
+a response to the putative intervenors' Motion to Intervene (DE 56) on or before May 2, 2011.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this
+day of April, 2011.
+KENNETH A. MARRA
+United States District Judge
diff --git a/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.receipt.json b/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e3f0150de1054f7bdcdf7980295be539bd9f58d0
--- /dev/null
+++ b/vision-fixhub/court-01/e1125af31fd3c23556f38774ae0e92e25089418c95a792937060529de8931f82.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.md b/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.md
new file mode 100644
index 0000000000000000000000000000000000000000..26ff475ae5e323b1c5148e816ec6c140a6a09650
--- /dev/null
+++ b/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.md
@@ -0,0 +1,16 @@
+Case 9:08-cv-80994-KAM Document 79-3 Entered on FLSD Docket 07/29/2009 Page 1 of 1
+DECLARATION OF JANE DOE NO. 6
+state as follows:
+I am the Plaintiff identified as Jane Doe No. 6 in this lawsuit.
+On July 9, 2009, an investigator came to the office of my former employer, A
+Affordable Auto Insurance, in Lake Worth, Florida.
+After the investigator left, 1 was contacted by my former employer and told that
+the investigator was asking personal questions about me.
+I am worried that Jeffrey Epstein will continue to send investigators to speak with
+other people I know who do not know that I am a Plaintiff in this lawsuit. I am concerned that
+the investigators will ask these people very personal questions about my life and disclose that I
+am a Plaintiff in a sexual abuse lawsuit against Jeffrey Epstein.
+I declare under penalty of perjury the foregoing to be true and correct.
+→ 2009
+Dated this 22 day of July
+mika line Doc Nigo
diff --git a/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.receipt.json b/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d17fdeb7c0bb0004b838489e45d5a5569a3f83ac
--- /dev/null
+++ b/vision-fixhub/court-01/e113a49fb35d5c2fc83988af5a729c2f73fae2f71af33c6a914ed1f2e318d661.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "output_sha256": "d0b9fcfa9a3869c6bb0e6361565d0ab22e3784b2565c5a1187f909db4232727c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e132bf7a817982b9f6cb15bc47d79f6b78d5917a48efdff2f25df37be55e68b2.md b/vision-fixhub/court-01/e132bf7a817982b9f6cb15bc47d79f6b78d5917a48efdff2f25df37be55e68b2.md
new file mode 100644
index 0000000000000000000000000000000000000000..e084dff1efd9d61f0e454f87e3a2b2a1def4c8ce
--- /dev/null
+++ b/vision-fixhub/court-01/e132bf7a817982b9f6cb15bc47d79f6b78d5917a48efdff2f25df37be55e68b2.md
@@ -0,0 +1,43 @@
+Filing # 193210480 E-Filed 03/04/2024 04:52:58 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-AG
+CA FLORIDA HOLDINGS, LLC
+Publisher of THE PALM BEACH POST,
+Plaintiff
+DAVE ARONBERG, as State Attorney
+of Palm Beach, County, Florida; SHARON
+BOCK, as Clerk and Comptroller o
+Palm Beach County, Florida,
+Defendants.
+COPY
+THE MCCLATCHY COMPANY, LL'S NOTICE
+THAT ITS MOTION TO INTERVENE IS UNOPPOSED
+The McClatchy Company, LLC ("McClatchy"") filed its Motion to Intervene on March 1,
+2024. In the time since then, counsel for plaintiff and both defendants have informed counsel for
+McClatchy that their respective clients do not oppose McClatchy intervening in this action for the
+limited purpose of seeking access to the grand jury materials. McClatchy's motion is thus
+unopposed.
+1o,
+Respectfully submitted,
+HOLLAND & KNIGHT LLP
+701 Brickell Avenue, Suite 3300
+Miami, Florida 33131
+(305) 374-8500 (telephone)
+(305) 789-7799 (facsimile)
+By: /s/ Scott D. Ponce
+Scott D. Ponce (FBN 0169528)
+sponce@hklaw.com
+Attorneys for McClatchy
+*** FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK. 03/04/2024 11:21:16 AM ***
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that I filed this document on March 4, 2024 using Florida's e-filing
+portal, which will serve a copy on all counsel of record.
+By: Is/ Scott D. Ponce
+NOT A CERTIFIED COPY
+2
+#243489283_v1
diff --git a/vision-fixhub/court-01/e132bf7a817982b9f6cb15bc47d79f6b78d5917a48efdff2f25df37be55e68b2.receipt.json b/vision-fixhub/court-01/e132bf7a817982b9f6cb15bc47d79f6b78d5917a48efdff2f25df37be55e68b2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..210f735f33ee699bee47d24caeb840e963eeb3e8
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+  "output_sha256": "3269828a8f8a57d09034119fd5d5e73fddf30f6574eaa47840ede948fd862d8b",
+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7.md b/vision-fixhub/court-01/e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7.md
new file mode 100644
index 0000000000000000000000000000000000000000..8daa1ae3cf1139837e3ad2dd6b6a19f7aeb05a97
--- /dev/null
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@@ -0,0 +1,41 @@
+Case 9:08-cv-80119-KAM Document 264-1
+Entered on FLSD Docket 08/13/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON DEFENDANT'S MOTION FOR EXTENSION DIRECTED
+TO THE COURT PURSUANT TO RULE 4, REVIEW AND APPEAL-
+SOUTHERN DISTRICT, IN CONNECTION WITH THIS COURT'S ORDER
+DATED AUGUST 4, 2009 [DE 2421
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+For Extension Directed to the Court Pursuant to Rule 4, Review and Appeal-Southern
+District, In Connection With This Court's Order [DE 242] Dated August 4, 2009.
+Having considered Defendant's motion it is HEREBY ORDERED and ADJUDGED that
+the motion is GRANTED as follows:
+The Defendant shall file with the clerk of Court, and serve on all parties, written
+objections which shall specifically set forth the order, or part thereof, appealed from an a
+concise statement of the alleged error in ruling, along with statutory, rule or case
+authority in support of his position, on or before August 31, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 264-1 Entered on FLSD Docket 08/13/2009 Page 2 of 2
+08-CIV-80119-Marra
+Related cases 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+Page 2
+DONE and ORDERED this
+day of
+, 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record
diff --git a/vision-fixhub/court-01/e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7.receipt.json b/vision-fixhub/court-01/e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7.receipt.json
new file mode 100644
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+++ b/vision-fixhub/court-01/e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "e13867417cc2e1050d17682edf524a5fc9b48d2895e8c40ae02f17a4df44e7b7",
+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e170b5b55891419df311fda6c51a76151e0689bed45b379d582d491abc7110c4.md b/vision-fixhub/court-01/e170b5b55891419df311fda6c51a76151e0689bed45b379d582d491abc7110c4.md
new file mode 100644
index 0000000000000000000000000000000000000000..34139e3675ebee63e7f82f89d0dde7cc9ae63a54
--- /dev/null
+++ b/vision-fixhub/court-01/e170b5b55891419df311fda6c51a76151e0689bed45b379d582d491abc7110c4.md
@@ -0,0 +1,173 @@
+Case 1:20-cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 1 of 6
+
+
+
+Case 1:20-cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 2 of 6
+EPSTEIN VICTIMS' COMPENSATION PROGRAM ("EVCP")
+GENERAL RELEASE
+day of
+This General Release is made this
+20_
+WHEREAS,
+(the "Claimant"), submitted a claim for
+compensation to the Epstein Victims' Compensation Program ("EVCP"') asserting that
+she is a victim of sexual abuse by Jeffrey E. Epstein; and
+WHEREAS, the EVCP Program Administrator (the "Administrator") determined
+pursuant to the EVCP Protocol that Claimant is eligible to participate in the EVCP; and
+WHEREAS, after reviewing Claimant's submissions and after careful consideration of
+documentation and proof, and after due deliberation, the Administrator issued a
+compensation determination to Claimant ("Compensation Offer""); and
+WHEREAS, several jurisdictions within the United States have enacted claims revival
+statutes concerning the timeliness of claims of sexual abuse; and
+WHEREAS, Claimant is aware that, by accepting this Compensation Offer from the
+EVCP, Claimant waives and releases certain individuals and entities from any and all
+claims or causes of action arising from Mr. Epstein's conduct, whether pursuant to claims
+revival statutes or otherwise; and
+WHEREAS, after careful consideration of the proposed Compensation Offer, including
+consultation with her legal counsel regarding the Compensation Offer, Claimant
+informed the Administrator that Claimant has decided to accept the Compensation Offer.
+NOW THEREFORE,
+Claimant, for and on behalf of herself and her heirs, devisees, legatees, distributees,
+executors, administrators, trustees, personal representatives, successors and assigns
+(collectively, "Releasor"), for and in consideration of
+Dollars (S
+_) (the Compensation Offer) to be received from the EVCP, the
+adequacy and sufficiency of which are hereby acknowledged, hereby releases and forever
+discharges the Co-Executors of the Estate of Jeffrey E. Epstein (the "Epstein Estate"), the
+Co-Trustees of The 1953 Trust, the Epstein Estate, any entities owned or controlled in
+whole or part by the Epstein Estate (the "Epstein Entities") and their respective current
+
+
+Case 1:20-cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 3 of 6
+and former principals, officers, directors, stockholders, managers, members, partners,
+limited partners, trustees, beneficiaries, administrators, agents, employees, attorneys,
+predecessors, successors, assigns and affiliates, and any entities or individuals who are
+or have ever been engaged by (whether as independent contractors or otherwise),
+employed by, worked in any capacity for, or provided any services to Mr. Epstein, the
+Epstein Entities or the Epstein Estate (jointly and severally, the "Releasees"), from any
+and all claims, demands, actions, causes of action, suits, debts, dues, sums of money,
+accounts, variances, trespasses, damages and judgments, whether sounding in equity,
+tort, common law, contract, statute, regulation or otherwise and whether now existing,
+hereafter existing or revived in the future whatsoever in law, admiralty, equity or
+otherwise, including without limitation any and all claims or causes of action that arise
+or may arise from or which otherwise concern acts of sexual abuse by Mr. Epstein (the
+"Claims") which against the Releasees, Releasor ever had, now has or hereafter can, shall
+or may have, for, upon, or by reason of any matter, cause or thing whatsoever from the
+beginning of the world through the date of this General Release.
+This General Release is a broad release of any and all Claims of Releasor against
+any and all Releasees, including without limitation any and all causes of action, lawsuits,
+claims, demands, damages and liability whatsoever, and also including without
+limitation to the extent of their respective liability for the same, any and all such claims
+against any and all Releasees for contribution as to any other person or persons who may
+be determined to have been joint tortfeasors arising out of or in any way related to any
+and all known and unknown personal injuries, and also including without limitation any
+derivative claims for loss of consortium, under any federal, state or local law, without
+limitation. This General Release is all-encompassing and is specifically made and given
+on the premise that any and all Claims by Releasor are hereby released and extinguished,
+whether said Claims arose in Florida, New Mexico, New York, the United States Virgin
+Islands, France or any other country, state, territory, possession or jurisdiction, or
+otherwise.
+This General Release extends to released Claims that Releasor does not know or
+suspect to exist in her favor, which, if known by Releasor, would have materially affected
+her decision to enter into this General Release, and Releasor understands and agrees that
+she is releasing any and all such unknown or unsuspected Claims in Releasees' favor.
+Releasor acknowledges that she is familiar with Section 1542 of the California Civil Code,
+which provides as follows:
+A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE
+CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 4 of 6
+HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF
+KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER
+SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.
+Releasor expressly waives and relinquishes any right or benefit that Releasor has
+or may have under Section 1542 of the California Civil Code and under any other statute
+or legal principle with similar effect. In connection with such waiver and relinquishment,
+Releasor acknowledges that she is aware that, after executing this General Release,
+Releasor or Releasor's attorneys or agents may discover released Claims or facts in
+addition to, or different from, those which they now know or believe to exist with respect
+to the subject matter of this General Release, but that it is Releasor's intent hereby to fully,
+finally and forever settle and release all of the Claims, whether known or unknown,
+suspected or unsuspected, which now exist, may exist, or heretofore may have existed.
+In furtherance of this intent, this General Release shall be, and remain in effect as, a full
+and complete release of the Claims notwithstanding the discovery or existence of any
+such additional or different Claims or facts.
+The Administrator of the EVCP has retained Garretson Resolution Group, Inc.
+d/b/a Epiq Mass Tort ("Epiq") to verify and resolve any lien or reimbursement claim
+that may be owed to Medicare Part A and/or Part B ("Medicare") and/or Medicaid with
+respect to compensation awarded to any participating claimant under the EVCP. If either
+entity asserts a lien or reimbursement claim, Epiq is hereby authorized to act on behalf of
+the EVCP to verify and resolve such lien or reimbursement claim. In the Claim Form,
+Releasor authorized the Administrator to use and/or disclose information as to Releasor
+for the resolution of Medicare and/or Medicaid liens. This includes providing to Epiq
+certain information as to Releasor, including: (1) first name, last name and middle initial,
+(2) Social Security number; (3) date of birth, (4) gender and (5) basic information
+regarding the nature of Releasor's Claims, and authorizing the Administrator and Epiq
+to use, exchange and report this information to Medicare and Medicaid, as may be
+necessary, for purposes of verifying and resolving Medicare and/or Medicaid liens
+and/or reimbursement claims and ensuring compliance with the Medicare Secondary
+Payer Act, 42 U.S.C. § 1395(y)(b), and its accompanying regulations. In the event that
+Epiq resolves the asserted claim or lien, the Epstein Estate will pay the negotiated amount
+in addition to any Compensation Offer determined by the Administrator.
+Releasor represents and acknowledges that she is voluntarily and freely granting
+this General Release in exchange for payment of the Compensation Offer, and that she is
+legally competent to execute and deliver this General Release. Releasor further
+represents that she is represented by legal counsel and has received legal advice prior to
+3
+
+
+Case 1:20-cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 5 of 6
+entering into this General Release and that she has been advised by said attorney
+regarding the terms and conditions of this General Release, which she has completely
+read and fully understands, including that accepting the Compensation Offer and signing
+this General Release is a full and final compromise, adjustment and resolution of any and
+all Claims that Releasor may now have or ever will have against Releasees.
+Pursuant to the EVCP Protocol, the Administrator will maintain the confidentiality
+of all information and documentation relating to claimants who participate in the EVCP
+Program. This General Release does not require participating claimants to maintain such
+confidentiality and Releasor may -- at Releasor's voluntary and sole option -- disclose
+such information regarding the claims process and/or the Compensation Offer and any
+other information pertaining to her claim.
+This General Release specifically does not include
+as a Releasee or
+released party under this Agreement, and all parties expressly acknowledge, agree and
+understand that any and all claims that Releasor has or may have against
+are expressly preserved.
+Releasor represents and warrants that she has not assigned any Claims released
+pursuant to this General Release.
+Releasor will dismiss with prejudice any and all legal actions -- whether lawsuits,
+probate claims or otherwise - that Releasor has filed against any of Releasees, with each
+party to bear her, his or its own costs and attorneys' fees and will submit proof of
+dismissal to the Administrator along with or prior to the signed acceptance of the
+Compensation Offer and this executed Release.
+This General Release contains the entire understanding of the Releasor and the Co-
+Executors of the Epstein Estate. Any modification of any of the provisions of this General
+Release shall be effective only if made in writing and executed by Releasor and the Co-
+Executors of the Epstein Estate with the same formality as this General Release.
+4
+
+
+Case 1:20-Cv-00484-JGK-DCF Document 93-1 Filed 01/29/21 Page 6 of 6
+IN WITNESS WHEREOF, Claimant has executed this General Release on the date
+below her signature.
+(Signature: Claimant)
+(Date)
+STATE OF
+SS:
+COUNTY OF
+-)
+On
+_, 20_ before me personally came.
+→ to
+me known, who, by me duly sworn, did depose and say that deponent is the Releasor
+who executed the foregoing General Release.
+Notary Public
+Reviewed and approved:
+Type (or print) Name of Claimant:
+Attorney for Releasor:
+Type (or print) Name of Attorney: _
+Signature:
+5
+96483947_5
diff --git a/vision-fixhub/court-01/e170b5b55891419df311fda6c51a76151e0689bed45b379d582d491abc7110c4.receipt.json b/vision-fixhub/court-01/e170b5b55891419df311fda6c51a76151e0689bed45b379d582d491abc7110c4.receipt.json
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diff --git a/vision-fixhub/court-01/e1803b445dab6e918781002ed1386f8ba2ca46a7d2af87619550f54b10f02212.md b/vision-fixhub/court-01/e1803b445dab6e918781002ed1386f8ba2ca46a7d2af87619550f54b10f02212.md
new file mode 100644
index 0000000000000000000000000000000000000000..86e95aa59ca0ca276bcc10d3eb95818d88513f83
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@@ -0,0 +1,53 @@
+Case 1:19-cv-11869-MKV-DCF Document 25
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman.com
+Filed 04/14/20 Page 1 of 2
+troutman™
+sanders
+Bennet J. Moskowitz
+D: 212-704-6000
+bennet.moskowitz@troutman.com
+April 14, 2020
+VIA ELECTRONIC COURT FILING
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl Street
+New York, New York 10007
+Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe,
+1:19-cv-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-cv-
+11869-MKV-DCF
+Dear Judge Freeman:
+We represent Defendants in the above-referenced actions. In light of the ongoing pandemic
+and the various difficulties it has presented, we write with Plaintiffs' consent to request that the
+Court extend the remaining deadlines in the above-refenced actions, as set by this Court's
+Order dated February 11, 2020, by thirty (30) days, as follows:
+• the deadline for Plaintiffs to file any motions to amend the pleadings or to join any
+additional parties be extended from April 30, 2020 to June 1, 2020;
+• the deadline for the Parties to submit joint status reports to the Court, regarding
+discovery and the progress of settlement discussions, be extended from April 30, 2020
+to June 1, 2020;
+• the deadline for the completion of fact discovery be extended from June 10, 2020 to July
+10, 2020;
+• the deadline for service of Plaintiffs' expert reports be extended from June 10, 2020 to
+July 10, 2020;
+• the deadline for service of the Defendants' rebuttal reports be extended from July 10,
+2020 to August 10, 2020; and
+• the deadline for the completion of expert discovery be extended from July 31, 2020 to
+August 31, 2020.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 25
+April 14, 2020
+Page 2
+Filed 04/14/20 Page 2 of 2
+troutman™
+sanders
+This is the first request for an extension of these deadlines.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)
diff --git a/vision-fixhub/court-01/e1803b445dab6e918781002ed1386f8ba2ca46a7d2af87619550f54b10f02212.receipt.json b/vision-fixhub/court-01/e1803b445dab6e918781002ed1386f8ba2ca46a7d2af87619550f54b10f02212.receipt.json
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diff --git a/vision-fixhub/court-01/e1fccb6b8c5b72033bdfc95106ca9c1e221b7b150947207d45847c21a65a41c6.md b/vision-fixhub/court-01/e1fccb6b8c5b72033bdfc95106ca9c1e221b7b150947207d45847c21a65a41c6.md
new file mode 100644
index 0000000000000000000000000000000000000000..27b898928429e3501e24c9487d7e9773a71710ae
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@@ -0,0 +1,24 @@
+Case 9:10-cv-80309-KAM Document 23 Entered on FLSD Docket 05/19/2010 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 10-CV-80309-MARRA_
+JANE DOE NO. 103,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+FINAL ORDER OF DISMISSAL WITH PREJUDICE
+THIS CAUSE is before the Court upon the parties' Stipulation Of
+Dismissal With Prejudice [DE 22]. Having considered the submission, and
+being otherwise fully advised in the premises, it is hereby
+ORDERED AND ADJUDGED that this Cause be, and the same is,
+hereby DISMISSED with prejudice. Fed. R. Civ. P. 41(a). Any pending
+motions are denied as moot. The Court shall retain jurisdiction to enforce the
+terms of the parties' settlement. This case is CLOSED.
+DONE AND ORDERED in
+at West Palm Beach, Florida, this
+19th day of May, 2010.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to:
+All counsel of record
diff --git a/vision-fixhub/court-01/e1fccb6b8c5b72033bdfc95106ca9c1e221b7b150947207d45847c21a65a41c6.receipt.json b/vision-fixhub/court-01/e1fccb6b8c5b72033bdfc95106ca9c1e221b7b150947207d45847c21a65a41c6.receipt.json
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diff --git a/vision-fixhub/court-01/e241c6003cdbf75a11c8327670eb2e33ed41f961dac206f0ead2137cf6d8186e.md b/vision-fixhub/court-01/e241c6003cdbf75a11c8327670eb2e33ed41f961dac206f0ead2137cf6d8186e.md
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@@ -0,0 +1,486 @@
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 1 of 18
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CIV-80119-MARRA/.
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT'S REPLY TO PLAINTIFF'S RESPONSE TO
+DEFENDANT'S MOTION FOR RECONSIDERATION AND/OR REQUEST FOR RULE
+4 REVIEW AND APPEAL, WITH INCORPORATED MEMORANDUM OF LAW
+Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned
+attorneys,
+hereby files his Reply To Plaintiff's Response To Defendant's Motion For
+Reconsideration And/Or Request For Rule 4 Review And Appeal, With Incorporated
+Memorandum Of Law.' In support, Epstein states:
+The Requests For Production, Argument And Memorandum Of Law
+a.
+Request Number 7,9 and 10
+(i)
+Plaintiff Limited the Scope of the Requests In Her Reply
+Plaintiff is not only chameleon like in her Response in Opposition to the Motion For
+Reconsideration And/Or Rule 4 Appeal ("Response to the Rule 4 Appeal") but her arguments
+simply parrot back the Magistrate's Order at DE 462 without addressing the substantive
+arguments made by Epstein.
+'Epstein reincorporates his arguments set out in his initial Rule 4 Appeal.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 2 of 18
+Page No. 2
+First, Plaintiff's arguments in the Response to the Rule 4 Appeal change color as her
+covert strategy seems to fade. For instance, it was Plaintiff in her Reply to the Response in
+Opposition to her Motion to Compel (the "Reply to the Motion to Compel")(DE 354, p.3) that
+further defined or limited for the court exactly what Plaintiff expected to receive in response to
+request numbers 7, 9 and 10. Plaintiff stated in no uncertain terms that "[t]hese requests simply
+seek information that the federal government gave to Epstein. ..." DE 354, p.3.
+Before this specious limitation was made by Plaintiff, Epstein argued in his response in
+opposition (DE 339, p.7-8) that these requests are the same type requests the court found subject
+to the Fifth Amendment. (DE 464) With the limitation made by Plaintiff and her counsel in the
+Reply, the court ruled "It)hat the earlier requests referenced by Epstein were significantly
+broader than the narrow requests at issue here, including for example, a request for all documents
+"relating to' the federal non-prosecution agreement, and all documents "relating to' either the
+federal or state criminal investigations. These requests would have required Epstein to pick and
+choose which documents were responsive and in this way force Epstein to use to effectively
+make 'use of the content his mind,' an action that would undeniably implicate the Fifth
+Amendment." (DE 462, p.9) Clearly the instant requests (as Plaintiff now defines them) are
+exactly the same type of broad requests this court has already ruled upon. See Response in
+Opposition (DE 339) Had the Plaintiff not limited the scope of the requests in her Reply (DE
+354, p.3), the court would not have labeled these requests as "narrow" because these requests
+now seek all information related to the federal non-prosecution agreement and all documents
+relating to either the federal or state criminal investigations, which clearly require Epstein to
+effectively make use of the content his mind to determine what is and what is not responsive to
+these broad requests. Simply put, Plaintiff is flip-flopping her arguments.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 3 of 18
+Page No. 3
+As a result of the limitation made by Plaintiff in her Reply and as a result of this court's
+Order (DE 462), Epstein responded - "[a]s to Request Number 7, Epstein and his attorneys do
+not have any "discovery information" provided to them by the federal government and lajs to
+Request Number 9, Epstein has not been given any evidentiary materials or evidentiary
+documents by the federal government." (DE 477) Certainly, these responses were not intended
+to "gild the lily" as Plaintiff contends. The responses were made based upon Plaintiff's
+limitation in what she sought from Epstein and because this court entered an Order based upon
+that limitation. Had the limitation not been made, neither this court nor Epstein would have been
+misled down this primrose path.
+Nonetheless, Plaintiff now seeks to obtain the full breadth of information sought under
+request numbers 7, 9 and 10. However, that argument shall meet a short death in that Plaintiff
+herself limited the scope of the requests in her Reply and failed to timely file her own Rule 4
+Appeal after the court entered its order at DE 462, which adopted Plaintiff's limited scope of the
+requests (which Plaintiff now wishes to change). See S.D. Fla., Rule 4(a)(1), Mag. J. 2009. If
+the court made a mistake in adopting the limited scope of the requests (which it did not), Plaintiff
+should have timely appealed. Instead, Plaintiff now attempts to backdoor a Rule 4 Appeal in her
+Response In Opposition to Defendant's Rule 4 Appeal. Again, if Plaintiff believed that this
+court improperly interpreted her limitation of the requests set out in her reply motion, Plaintiff
+had the obligation to timely file an appeal, which she did not. As such, Plaintiff's requested
+relief in this regard should be denied.
+(ii)
+Mr.
+Already Has the Information He Seeks Pursuant to this
+Improper Motion Practice
+Several depositions have occurred over the last 4 weeks wherein it appears Mr.
+already has the information he seeks responsive to these requests, which is likely the reason Mr.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 4 of 18
+Page No. 4
+has not filed any affidavits supporting the specious arguments set forth in Plaintiff's
+Motions. As such, there is no substance or factual representations made by Plaintiff to support
+her argument. Plaintiff is wasting attorney time and judicial resources in her effort to obtain
+what she already has in her possession. For example, at a deposition of Mr. Epstein on February
+17, 2010, the following exchange occurred:
+Mr.
+The 87-page Palm Beach Police Department
+incident report
+where there are numerous underage females
+describing their interaction with Mr. Epstein at his house. I'm
+specifically reading from page 41 related to A.H., who was one of
+the victims he pled guilty to.
+Mr. Pike: Is that the same document that you're seeking
+production of, in this same exact case?
+Mr.
+I don't know what you're talking about.
+This is something from the state attorneys' file.
+response above (attached as Exhibit "A") that he has the
+It is clear from Mr.
+information from the Palm Beach Police Department and the information from the State
+Attorneys' file. This begs the question - if plaintiff already has the information she seeks, why
+is Plaintiff wasting valuable attorney time and judicial resources to obtain what is already in
+hand?
+At the deposition of AR on March 15, 2010, the following exchange occurred:
+Mr.
+: Well, at some point in time what's been marked as
+defense Exhibit "1", you received a grand jury investigation target
+letter, correct?
+***
+Mr.
+There's another message from 9/11/05 saying "I
+got a car for," and then the name is blotted out. The State
+Attorneys' Office blotted the names of minors out sometimes in
+their file...
+***
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 5 of 18
+Page No. 5
+Once again, Mr.
+response above (attached as Exhibit "B") establishes that he
+has the information from both the Palm Beach Police Department and the State Attorneys' file.
+In fact, as argued infra, Mr.
+has certain information from the Palm Beach Police
+Department, which resulted from various alleged "trash pulls" from a residence on Palm Beach
+(e.g., certain notepads).
+Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on
+March 19, 2010, the following exchange occurred:
+Mr. Kuvin: Okay. And what were the dates of the surveillance?
+Witness: [Referencing his Report] It appears she met with
+members of the B.S.F. unit, Burglary Strike Force....
+*****
+Mr. Kuvin: [Referencing the Report] If we go down to page 40 in
+your report, first let me back up.
+Mr. Kuvin: Okay. So the chain of custody which we have marked
+as Exhibit 5 shows that all the evidence you had in this case was
+given to the FBI...
+**$
+The undersigned was at Detective Recarey's deposition, copies of which are attached as
+Exhibit "C". Mr. Kuvin and Mr.
+had copies of various reports and also had copies of
+various message pads claimed to be "pulled" from Epstein's trash by the Palm Beach Police
+Department. It is clear from these deposition transcripts that opposing counsel has information
+from the Palm Beach Police Department and the State Attorneys' file. See also, infra for
+additional argument.
+(ili)
+Work-Product - Palm Beach State Attorneys' File
+Next, as to any information obtained from the State Attorney at any phase, the State
+Attorney has not provided anything to Epstein or his attorneys. While the State Attorneys' file
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 6 of 18
+Page No. 6
+was made available for inspection, Jack Goldberger, Epstein's criminal lawyer, went over to the
+State Attorneys' Office and hand selected information from the file for copying, including
+certain witness interviews. See Exhibit "D," Affidavit of Jack Goldberger. Accordingly, the
+information hand selected by Mr. Goldberger falls under the work-product doctrine as
+production of same would reveal Mr. Goldberger's mental impressions, thought processes and
+strategy relative to the defense of Epstein.
+v. Florida Power & Light Company, 632 So.2d
+696, 698 (Fla. 3'd DCA 1994)(even if individual documents are not work-product, "the selection
+process itself represents defense counsel's mental impressions and legal opinions as to how the
+evidence in the documents relates to the issues and the defenses in the litigation"). Id. The
+information simply falls under the "highly protected category of opinion work-product." Id; see
+also Fla.R.Civ.Pro. 1.280.
+Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a
+copy of the file retained by the Palm Beach State Attorneys' Office. How did Mr. Horowitz
+obtain the file? Did Mr. Horowitz obtain the records by virtue of a Chapter 119 request or a
+Freedom of Information Act Request? Certainly, Mr.
+is able make such public records
+requests or can subpoena the requested information, neither of which would implicate the work
+product privilege as outlined above.
+Here, the standard is a showing of a need to obtain the information, and the inability to
+obtain the substantial equivalent without undue hardship. Metric Engineering, Inc. v. Small, 861
+So. 2d 1248, 1250 (Fla. Ist DCA 2003)(To show 'need,' a party must present testimony or
+evidence demonstrating the material requested is critical to the theory of the requestor's case, or
+to some significant aspect of the case); Ashemimry v. Ba Nafa, 847 So.2d 603 (Fla. 5th DCA
+2003). In addition, Florida Rule of Civil Procedure 1.280(b)(3), does allow discovery of fact
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 7 of 18
+Page No. 7
+work product where the requesting party can show need and the inability to obtain the substantial
+equivalent by other means without undue hardship. Vesta Fire Ins. Corp. V.
+821 So.2d
+1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome
+the work product immunity must include specific explanations and reasons). Again, Mr.
+fails to submit any affidavit or any other document meeting the above criteria.
+Additionally, this court should consider placing the Palm Beach State Attorney and the
+USAO on Notice that their investigative files are being requested. Since Plaintiff seeks
+information given by federal government and the state attorney to Epstein, including
+correspondence, Epstein reincorporates the arguments setout in his initial Rule 4 Appeal as that
+information is within the penumbra of the protections of Federal Rules of Evidence 408 and 410.
+Moreover, despite Plaintiff's contention, Federal Rule of Evidence 410 is applicable because
+negotiations did not end with a federal plea. Furthermore, Federal Rule of Evidence 408 is
+applicable given that 18 U.S.C. 2255 is quasi-civil remedy. Clearly, the information sought by
+Plaintiff has no evidentiary value - given that Plaintiffs have the raw materials and police reports
+and affidavits resulting from state investigation. Accordingly, there is a chance that the Palm
+Beach State Attorney and the USAO may not want to disclose their files for one reason or
+another.
+Based upon the foregoing and based upon the arguments made in Epstein initial Rule 4
+Appeal, Epstein's Fifth Amendment Privilege as it relates to the above requests should be
+sustained and Plaintiff's Motion requested relief should be denied as untimely. To the extent this
+court overrules Epstein's Fifth Amendment Privilege, this court should order an in camera
+inspection (as requested in the Rule 4 Appeal) to determine what information, if any, is workproduct and thus subject to Federal Rule of Evidence 502.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 8 of 18
+Page No. 8
+b. Request Numbers 12 and 13
+As set forth in more detail in DE 282 and 283 (which were provided to the court in
+camera) and in Epstein's Rule 4 Appeal, Epstein cannot provide answers/responses to questions
+relating to his financial history and condition without waiving his Fifth, Sixth, and Fourteenth
+Amendments as guaranteed by the United States Constitution, which includes his tax returns.
+An elementary review of Plaintiff's Response In Opposition to the Rule 4 Appeal (DE 485)
+clearly shows that the information Plaintiff seeks may provide a link in the chain of evidence and
+thus presents a real and substantial danger of self-incrimination in this case, in other related cases
+and as well in areas that could result in criminal prosecution.
+First, Plaintiff claims to require the tax returns to advance her theory that ".. Epstein
+used his wealth and power to lure economically disadvantaged minor girls to his homes in palm
+where they were sexually assaulted." (the "First Theory") DE
+Beach, New York and St.
+485, p. 18) Second, without attaching any affidavits, Plaintiff claims that "...Epstein is moving
+all of his assets overseas in an effort to defeat collection of any judgment that Jane Doe and other
+plaintiffs may obtain." (DE 485, p.19)(the "Second Theory"); see also fn. 5 therein. Third,
+Plaintiff claims she has limited evidence (although she does not attach same or provide it in
+camera) proving that Epstein is using "modeling agencies" to lure underage girls to him for
+sexual purposes, and that his tax returns may reveal the existence and location of such modeling
+agencies (the "Third Theory").
+Finally, Plaintiff's Fourth theory is that the tax returns may
+provide a link in the chain of evidence used to establish a nexus to Epstein's alleged offenses
+under 18 U.S.C. 2255 (the "Fourth Theory"). Plaintiff's admissions here are fatal, and
+furthermore require Epstein to produce information that is tantamount to Epstein being a witness
+against himself or incriminating himself.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 9 of 18
+Page No. 9
+Again, to the extent that the Court determines that the tax returns are relevant and that
+there is a compelling need for at least their disclosure of Epstein's wealth for punitive damage
+purposes, Epstein would agree to stipulate, through his attorneys, that he has a net worth of over
+$50,000,000. Such a stipulation more than satisfies any necessity for the disclosure of the tax
+returns or any additional net worth information.
+(i) Plaintiff's First Theory Is Fatal To Request Numbers 12 and 13
+Based upon the above admissions, it is clear that Plaintiff now seeks information that
+may provide a link in the chain of evidence used to prosecute Epstein. As a result, DEs 282 and
+283 (in camera), other related Orders and the Order at DE 480 must be analyzed to reach the
+correct legal conclusion. With regard to Plaintiffs First Theory, the court must be cognizant of
+the allegations in the related cases regarding sexual misconduct with and abuse, exploitation, and
+sexual battery of alleged minors.
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 10 of 18
+Page No. 10
+2 See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495
+(1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "i]t would be incongruous to have different standards determine the validity of a claim of
+privilege based on the same feared prosecution, depending on whether the claim was asserted in state or federal
+Evidence §592. Defendants in civil actions. - *... a civil defendant who raises an affirmative defense is not
+precluded from asserting the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+
+
+Case 9:08-cV-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 11 of 18
+Page No. 11
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 12 of 18
+Page No. 12
+Accordingly, it is clear that Plaintiff and her counsel seek this information not to further their
+civil case, but to gain information to aid in the future prosecution of Epstein in direct violation of
+his Fifth Amendment rights. In fact, the Mermelstein and Horowitz firm was quoted in the Palm
+Beach Post stating, among other things, that the book sold to undercover agents could open the
+door to future prosecution of Epstein. As such, Plaintiffs' counsels' intention is clear - to use the
+civil
+discovery
+process
+to
+attempt
+to further prosecute
+Epstein.
+See
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 13 of 18
+Page No. 13
+http://jessicaarbour.blogspot.com/2010/03/horowitz-discusses-possibility-of.html. Accordingly,
+Epstein's 5" Amendment rights in this regard should be sustained.
+(ii) Plaintiff's Second Theory Is Fatal To Request No. 12
+Plaintiff claims that "
+...Epstein is moving all of his assets overseas in an effort to defeat
+collection of any judgment that Jane Doe and other plaintiffs may obtain" and, as a result, his tax
+returns may help to provide such affirmative evidence. (DE 485, p.19).
+As the court previously ruled, "[alpart from Defendant's justified concerns regarding
+waiver, are the very real concerns that by forcing Defendant to respond to the subject discovery
+requests regarding his financial status and history, the Court risks providing the government with
+a link in the chain of evidence needed to convict Defendant of a crime. The potential for
+providing such a 'link' is high when one considers that by forcing Defendant to respond, he will
+be implicitly communicating statements of fact, authenticating documents and testifying to their
+location, as well as providing clues as to the identity and location of witnesses that by such
+disclosure may serve to further a criminal investigation against him." (DE 480) Further, the
+instant requests here would require disclosure in connection with Defendant's ownership of
+assets and transfers of assets inside and outside the United States, such disclosure could reveal
+the availability to him and/or use by him of interstate facilities, which again may implicate
+Defendant in additional crimes. See also DE480 for the same reasoning. In short, like the
+requests outline in DE 480, the requests here "... seek to have Defendant be a witness against
+himself, assist the Plaintiffs' investigation and identify areas that could result in future
+prosecution of Defendant, a result clearly prohibited by the Constitution." DE 480 See Rudy-
+Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-incrimination does not depend
+upon the likelihood, but upon the possibility of prosecution and also covers those circumstances
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 14 of 18
+Page No. 14
+where the disclosures would not be directly incriminating, but could provide an indirect link to
+incriminating evidence). Accordingly, the court at DE 480 sustained Epstein's Fifth Amendment
+Privilege as it related to each of the subject net worth/asset discovery requests. Since the tax
+returns could result in the production of the same asset/net worth information, the requests are
+subject to the Fifth Amendment and, thus, this court should sustain Epstein's Fifth Amendment
+privilege.
+(i) Plaintiff's Third Theory Is Fatal To Request Numbers 12 and 13
+Under Plaintiff's Third Theory, she claims Epstein's tax returns may reveal the existence
+and location of modeling agencies Epstein uses to lure underage girls to him for sexual purposes.
+(E 485) These issues have been addressed at DE 293. In particular, this court sustained
+Epstein's objections to producing information regarding "…. MC2 models or Jean Luc Brunel
+relating or referring to females coming into the United States from other countries .... [because
+it] could reveal the availability to him of and/or use by him of interstate facilities...." DE 293,
+p.6. In making such a ruling, the court recognized much of the argument set out above and
+herein including, but not limited to, various federal and state criminal statutes claimed to have
+been violated by Epstein (i.e., 18 U.S.C. 2422(b) and 18 U.S.C. 2423(b)), argument for which
+was provided in camera and considered by this court. See e.g., DE 242 and 293.
+While the government (i.e., the IRS) may have Epstein's tax returns and passport in some
+form or another, it does not have information that may corroborate Plaintiffs' claims of travel in
+interstate commerce, use of interstate facilities to commit crimes and/or violations of various
+federal and state criminal statutes. Given the recent news reports regarding the potential for
+Epstein to be re-indicted due the alleged finding of the "black book," responding to request
+numbers 12 and 13 may provide a link in the chain of evidence and, thus, presents a real and
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 15 of 18
+Page No. 15
+substantial danger of self-incrimination in this case, in other related cases and as well in areas
+that could result in criminal prosecution. Accordingly, this court should sustain Epstein's Fifth
+Amendment privilege as to request numbers 12 and 13.
+(iv) Plaintiff's Third Theory Is Fatal To Request Number 12
+Finally, Plaintiff's Fourth Theory is that the tax returns may provide a link in the chain of
+evidence used to establish a nexus to Epstein's alleged offenses under 18 U.S.C. 2255. As state
+above,
+This is exactly why Plaintiff wishes to obtain the requested information - to
+further prosecute Epstein or assist in the progress of same. Accordingly, for the same reasons
+expressed herein, Epstein's Fifth Amendment Privilege should be sustained.
+Wherefore, Epstein respectfully requests that this Court issue and order:
+finding that the danger Epstein faces by being forced to testify in this case
+relative to the above requests is substantial and real, and not merely trifling or imaginary;
+b.
+sustaining Epstein's Fifth Amendment Privilege as it relates to the above
+requests and denying Plaintiff's Motion in that regard;
+C.
+reversing and/or revising the Magistrate's Order (DE 462) relative to
+Request Numbers 10, 12 and 13 and entering an amended order sustaining Epstein's
+objections to the Magistrate's Order as to those specific requests and not requiring him to
+produce information relative to same;
+striking as untimely Plaintiff's new arguments in her response in
+opposition (DE 495) relative to Request Numbers 7, 9 and 10 for failure to file the
+appropriate Rule 4 Appeal and/or reversing and/or revising the Magistrate's Order (DE
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 16 of 18
+Page No. 16
+462) relative to Request Numbers 7, 9 and 10 and entering an amended order sustaining
+Epstein's objections to the Magistrate's Order as to those specific requests and not
+requiring him to produce information relative to same;
+e.
+remanding this appeal to the Magistrate-Judge for her reconsideration of
+these portions of her order;
+alternatively, if this court rules that any of the information requested
+herein is relevant, it shall only do so after an in camera hearing and only after this court
+ensures that each and every documents produced is the subject of a heightenedconfidentiality order;
+for such other and further relief as this Court deems just and proper.
+Respectfully submitted,
+By: /s/ Michael J... Pike
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 26% day of March, 2010.
+Respectfully submitted,
+By: /s/ Michale J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+
+
+Case 9:08-cv-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 17 of 18
+Page No. 17
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+, Fistos &
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+, Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No. 08-
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08- Paul G. Cassell, Esq.
+80232,
+08-80380, 08-80381,
+08-80993, 08- Pro Hac Vice
+80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Do
+sidro M.
+_ Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plainif in Related Case No. 08.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+
+
+Case 9:08-cV-80119-KAM Document 502 Entered on FLSD Docket 03/26/2010 Page 18 of 18
+Page No. 18
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Case
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/e263c5560f2c2e687a61fc0b210536faa75ce548d751f16007a7aedca60967cc.md b/vision-fixhub/court-01/e263c5560f2c2e687a61fc0b210536faa75ce548d751f16007a7aedca60967cc.md
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@@ -0,0 +1,109 @@
+Herman &Mermelstein, P
+Document 101-1 Entered on FLSD02p6ken 05/96/89889 Page 129524
+Side
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA-|
+JANE DOE NO. 4,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+PLAINTIFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES
+Plaintiff, JANE DOE 4, by and through their undersigned counsel, and pursuant
+to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+:
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law. Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+vague, ambiguous, incomprehensible and/or overly broad.
+A"
+CC.NE.NG, DI
+
+
+15-9312200Case 9:08-MiRe helf, Document 101-1 Entered on FLSD deskeh05/26/20289 Page 270524
+Doe No. 4 v. Epstein
+Page 6
+Answer:
+See Plaintiff's Answer to Interrogatory No. 5.
+Were you suffering from physical infirmity, disability, disease,
+sickness, or
+psychiatric/psychological condition at the time of the incidents) described in the
+complaint? If so, what was the nature of the infirmity, disability, or sickness
+Answer:
+No.
+Did you consume any alcoholic beverages or take any drugs or medications
+within 12 hours before the time of each incidents) described in the complaint? If
+so, state the type and amount of alcoholic beverages, drugs, or medication which
+were consumed, and when and where you consumed them.
+Answer:
+No.
+9.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury, and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+Answer:
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation, corruption of morals, anxiety, intrusive thoughts, disturbed
+sleep, impaired concentration, disruption and distortion of normal development,
+loss of innocence.
+Plaintiff's psychological and emotional injuries will be analyzed by a forensic
+expert, whose opinions and related information will be disclosed in accordance
+with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff
+further reserves the right to supplement this response in accordance with the
+Federal Rules of Civil Procedure.
+
+
+305-9312200
+Document 101-1 Entered on FLSD Docket 05/06/2009
+Page 3 ot 4
+Herman &Mermelstein, P
+10:30:31 p.m.
+Doe No. 4 v. Epstein
+Page 14
+25.
+Please describe any statements made to you by any federal or state law
+enforcement agent or prosecutor regarding the availability of civil remedies
+against Mr. Epstein and regarding whether there would be any benefit from your
+voluntary cooperation with law enforcement.
+VERIFICATION
+_being duly sworn, deposes and says that the
+foregoing answers to interrogatories are true and correct to the best of her knowledge,
+information and belief.
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+following identification
+within the past five years and bears a serial or other identifying number.
+
+
+105-9312200
+Her-an ermeisten, Document 101-1 Entered on FLSD D.30.25.0556-00-2
+0 Page 4,0152
+Doe No. 4 v. Epstein
+Page 13
+January 24,2009
+Respectfully submitted:
+HERMAN & MERMELSTEIN P.A.
+18205 Biscayne Bivd., Suite 2218
+Miami, Florida 33160
+www.hermanlaw.com
+Tel: 305-931-2200
+Fax: 305-931-0877
+By: Mr
+iherman@hermanlaw.com
+Florida Bar No. 52164/
+Stuart S. Mermelstein
+mermelstein@hermanlaw.cor
+lorida Bar No. 94724
+Adam D. Horowitz
+ahorowitz@hermanlaw.com
+Florida Bar No. 376980
\ No newline at end of file
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+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 1 of 25
+Date Filed: 06/11/2014 Page: 1 of 1
+UNITED STATES COURT OF APPEALS
+FOR THE ELEVENTH CIRCUIT
+LBERT PARR TUTTLE COURT OF APPEALS BUILDIN
+6 Forsyth Street, N. W
+Atlanta, Georgia 30303
+John Ley
+Clerk of Court
+FILED BY MC
+Jun 11, 2014
+STEVEN M. LARIMORE
+CLERK U.S. DISTRICT CT.
+S.D, OF FLA, MIAMI
+For rules and forms visit
+www.cal1.uscourts.gov
+June 11, 2014
+Steven M. Larimore
+U.S. District Court
+400 N MIAMI AVE
+MIAMI, FL 33128-1810
+Appeal Number: 13-12923-CC
+Case Style: Jane Doe v. Roy Black
+District Court Docket No: 9:08-cv-80736-KAM
+The enclosed judgment is hereby issued as the mandate of this court.
+A copy of this letter, and the judgment form if noted above, but not a copy of the court's
+decision, is also being forwarded to counsel. A copy of the court's decision was previously
+forwarded to counsel on the date it was issued.
+Sincerely,
+JOHN LEY, Clerk of Court
+Reply to: Joe Caruso
+Phone #: (404) 335-6177
+Enclosure(s)
+MDT-1 Letter Issuing Mandate
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 2 of 25
+Date Filed: 06/11/2014 Page: 1 of 1
+UNITED STATES COURT OF APPEALS
+For the Eleventh Circuit
+No. 13-12923
+District Court Docket No.
+9:08-cv-80736-KAM
+JANE DOE NO. 1,
+JANE DOE NO. 2,
+Plaintiffs - Appellees,
+versus
+UNITED STATES OF AMERICA,
+Defendant,
+ROY BLACK,
+G. WEINBERG,
+JEFFREY EPSTEIN,
+Intervenors - Appellants.
+Appeals from the United States District Court for the
+Southern District of Florida
+JUDGMENT
+It is hereby ordered, adjudged, and decreed that the opinion issued on this date in this appeal is
+entered as the judgment of this Court.
+Entered: April 18, 2014
+For the Court: John Ley, Clerk of Court
+By: Jeff R. Patch
+Issued as Mandate
+June 11, 2014
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 3 of 25
+Date Filed: 04/18/2014
+Page: 1 of 23
+[PUBLISH]
+IN THE UNITED STATES COURT OF APPEALS
+FOR THE ELEVENTH CIRCUIT
+No. 13-12923
+D.C. Docket No. 9:08-cv-80736-KAM
+JANE DOE NO. 1,
+JANE DOE NO. 2,
+Plaintiffs-Appellees,
+versus
+UNITED STATES OF AMERICA,
+Defendant,
+ROY BLACK,
+G. WEINBERG,
+JEFFREY EPSTEIN,
+Intervenors-Appellants.
+Before PRYOR and
+Judge.
+Appeals from the United States District Court
+for the Southern District of Florida
+(April 18, 2014)
+Circuit Judges, and HONEYWELL," District
+"Honorable Charlene
+Honeywell, United States District Judge for the Middle District
+of Florida, sitting by designation.
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 4 of 25
+Date Filed: 04/18/2014 Page: 2 of 23
+PRYOR, Circuit Judge:
+This appeal requires us to decide two issues: whether we have jurisdiction
+over an interlocutory appeal by criminal defense attorneys and their client who
+intervened in a proceeding ancillary to a criminal investigation to claim a privilege
+that would prevent the disclosure of their plea negotiations; and, if so, whether a
+privilege bars crime victims from discovering plea negotiations. The United States
+investigated Jeffrey Epstein's sexual abuse of minors, but failed to confer with the
+victims before entering a non-prosecution agreement with Epstein. Two victims
+filed suit against the United States to enforce their rights under the Crime Victims'
+Rights Act, 18 U.S.C. § 3771, and sought to discover the correspondence between
+Epstein's attorneys and the United States regarding the non-prosecution agreement.
+Epstein and his attorneys then intervened to object to that discovery as privileged.
+The district court overruled their objection and ordered the United States to
+disclose the correspondence to the victims. After the intervenors filed this appeal,
+the victims moved to dismiss it for lack of jurisdiction. Because we conclude that
+we have jurisdiction to decide this appeal and that the plea negotiations are not
+privileged from discovery, we affirm.
+I. BACKGROUND
+2
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 5 of 25
+Case: 13-12923 Date Filed: 04/18/2014
+Page: 3 of 23
+In 2006, the Federal Bureau of Investigation began investigating allegations
+that Jeffrey Epstein had sexually abused several minor girls. The United States
+Attorney's Office for the Southern District of Florida accepted Epstein's case for
+prosecution, and the Federal Bureau of Investigation issued victim notification
+letters to two minors, Jane Doe No. 1 and Jane Doe No. 2, in June and August
+2007. Extensive plea negotiations ensued between the United States and Epstein.
+On September 24, 2007, the United States entered into a non-prosecution
+agreement with Epstein in which the United States agreed not to file any federal
+charges against Epstein in exchange for his offer to plead guilty to the Florida
+offenses of solicitation of prostitution and procurement of minors to engage in
+prostitution. Fla. Stat. §$ 796.07, 796.03.
+Not only did the United States neglect to confer with the victims before it
+entered into the agreement with Epstein, it also failed to notify them of its
+existence for at least nine months. The United States sent post-agreement letters to
+the victims reporting that the "case is currently under investigation" and explaining
+that "[t]his can be a lengthy process and we request your continued patience while
+we conduct a thorough investigation." And in June 2008, the United States asked
+the victims to explain why federal charges should be brought against Epstein
+without mentioning the agreement to them.
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 6 of 25
+Case: 13-12923 Date Filed: 04/18/2014 Page: 4 of 23
+On June 27, 2008, the United States informed the victims that Epstein
+planned to plead guilty to the Florida charges three days later, on June 30, 2008.
+But the United States failed to disclose that Epstein's pleas to those state charges
+arose from his federal non-prosecution agreement and that the pleas would bar a
+federal prosecution. The victims did not attend the state court proceedings.
+On July 7, 2008, Jane Doe No. 1 filed a petition alleging that she was a
+victim of federal crimes committed by Esptein involving sex trafficking of children
+by fraud and enticing a minor to commit prostitution and that the United States had
+wrongfully excluded her from plea negotiations and violated the Crime Victims'
+Rights Act. 18 U.S.C. § 3771. She alleged that the United States violated her right
+to confer with federal prosecutors, her right to be treated with fairness, her right to
+receive timely notice of relevant court proceedings, and her right to receive
+information about restitution. The United States answered that it used its "best
+efforts" to comply with the rights afforded to victims under the Act, but that the
+Act did not apply to pre-indictment negotiations with potential federal defendants.
+After Jane Doe No. 2 joined the initial petition, the district court found that both
+women qualified as "crime victims" under the Act. 18 U.S.C. § 3771(e). Among
+other relief, the victims sought rescission of the non-prosecution agreement.
+4
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 7 of 25
+Case: 13-12923 Date Filed: 04/18/2014 Page: 5 of 23
+The victims' petition remained dormant for years while they pursued a
+federal civil suit against Epstein and reached a settlement agreement with him. As
+a basis for relief against Epstein in the civil suit, the victims relied on Epstein's
+waiver of his right to contest liability in the non-prosecution agreement. Over
+Epstein's objection, the district court in that civil suit ordered the United States to
+produce the documents given to Epstein's attorneys during his plea negotiations.
+The victims received correspondence written by the United States, but they never
+received any correspondence written by Epstein's attorneys during the plea
+negotiations with the United States.
+In 2011, the victims renewed the prosecution of their petition against the
+United States. The victims moved to use correspondence between the United States
+and Esptein's attorneys during the plea negotiations to prove violations of their
+rights under the Act. And the victims later moved the district court to compel the
+United States to produce all requested discovery about the plea negotiations.
+Epstein and his criminal defense attorneys, Roy Black and |
+Weinberg,
+moved to intervene for the limited purpose of challenging the disclosure and use of
+the correspondence they wrote during plea negotiations. After the district court
+granted their permissive intervention, Fed. R. Civ. P. 24(b), the intervenors moved
+for protective orders. The intervenors argued that the work-product privilege
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 8 of 25
+Date Filed: 04/18/2014 Page: 6 of 23
+protects their correspondence; that Federal Rule of Evidence 410 and Federal Rule
+of Criminal Procedure 11 create a privilege for plea negotiations; and that their
+correspondence contained confidential grand jury material. They also urged the
+district court to recognize a common-law privilege for plea negotiations. The
+United States responded that the court should consider the correspondence
+privileged, but that it would disclose the correspondence if the court ordered it to
+do so.
+Epstein later filed two other motions to intervene in a limited capacity—one
+to challenge the disclosure of grand jury materials and another to challenge any
+remedy that would violate constitutional and contractual rights under the nonprosecution agreement. The attorney-intervenors did not join either of these
+motions. The district court has not yet ruled on Epstein's motion to intervene to
+prevent disclosure of grand jury materials, but the district court has "allowed [him]
+to intervene with regard to any remedy issue concerning the non-prosecution
+agreement."
+The district court then issued two discovery orders, both of which the
+intervenors challenge in this appeal. In the first, the district court denied the
+intervenors' motions for protective orders and granted the victims the right to
+proffer the correspondence between the United States and Epstein's attorneys, but
+6
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 9 of 25
+Date Filed: 04/18/2014 Page: 7 of 23
+the district court reserved "ruling on the relevance or admissibility" of any of the
+correspondence to prove violations of the Act. In the second, the district court
+required the United States to file answers to all outstanding requests for admissions
+and to produce documents in response to the requests for production by the
+victims, including "any documentary material exchanged by or between the federal
+government and persons or entities outside the federal government (including
+without limitation all correspondence generated by or between the federal
+government and Epstein's attorneys)." After the intervenors filed this interlocutory
+appeal, the victims moved to dismiss the appeal for lack of jurisdiction. This Court
+later entered a stay of the second order, which required the United States to
+disclose the correspondence to the victims.
+II. STANDARDS OF REVIEW
+Two standards of review govern the issues in this appeal. We review de
+novo whether we have jurisdiction to decide this interlocutory appeal before
+addressing the merits. United States v. 413 F.3d 1295, 1299 (11th Cir.
+2005). We also review de novo the interpretation of the Federal Rules of Evidence.
+See United States v. Campa, 459 F.3d 1121, 1174 (11th Cir. 2006); Pickett v. lowa
+Beef Processors, 209 F.3d 1276, 1279 (11th Cir. 2000). And the issue of whether
+to recognize a privilege under Federal Rule of Evidence 501 is a mixed question of
+7
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 10 of 25
+Case: 13-12923 Date Filed: 04/18/2014 Page: 8 of 23
+law and fact that we review de novo. Adkins v. Christie, 488 F.3d 1324, 1327 (11th
+Cir. 2007). But we review for clear error factual findings made by a district court.
+Morrissette-
+v. Mobile Infirmary Med. Ctr., 506 F.3d 1317, 1319 (11th Cir.
+2007).
+I. DISCUSSION
+We divide our discussion in two parts. First, we explain that we have
+jurisdiction over this interlocutory appeal by limited intervenors who, as claimants
+of a privilege, challenge a disclosure order directed at the United States, a
+disinterested party. Second, we explain that the plea negotiations are not privileged
+from disclosure.
+A. We Have Jurisdiction To Decide This Interlocutory Appeal.
+The victims argue that we should dismiss this appeal for lack of jurisdiction
+for two reasons. First, they argue that the Perlman doctrine, which permits a
+claimant of a privilege to appeal a non-final judgment, applies only to grand jury
+subpoenas. Perlman v. United States, 247 U.S. 7, 38 S. Ct. 417 (1918). Second,
+they argue that a decision of the Supreme Court, Mohawk Industries, Inc. v.
+Carpenter, 558 U.S. 100, 130 S. Ct. 599 (2009), forecloses an interlocutory appeal
+of a denial of a claim of privilege.
+8
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 11 of 25
+Case: 13-12923 Date Filed: 04/18/2014 Page: 9 of 23
+The courts of appeals "have jurisdiction of appeals from all final decisions
+of the district courts of the United States, ... except where a direct review may be
+had in the Supreme Court." 28 U.S.C. § 1291. A "final decision" is one "by which
+a district court disassociates itself from the case," Mohawk, 558 U.S. at 106, 130 S.
+Ct. at 604-05 (2009) (alteration omitted) (quoting Swint v.
+Cnty.
+Comm'n, 514 U.S. 35, 42, 115 S. Ct. 1203, 1208 (1995)), and "ends the litigation
+on the merits and leaves nothing more for the court to do but execute the
+judgment," Carpenter v. Mohawk Indus., Inc., 541 F.3d 1048, 1052 (11th Cir.
+2008) (quoting McMahon v. Presidential Airways, Inc., 502 F.3d 1331, 1338 (11th
+Cir. 2007)), aff'd, 558 U.S. 100, 130 S. Ct. 599. Discovery orders are ordinarily not
+final orders that are immediately appealable. Id. Five notable exceptions to this
+rule exist: the Perlman doctrine; the collateral-order doctrine,
+v. Beneficial
+Indus. Loan Corp., 337 U.S. 541, 69 S. Ct. 1221 (1949); a certification provided by
+statute, 28 U.S.C. § 1292(b); a petition for a writ of mandamus; or an appeal of a
+contempt citation.
+The Perlman doctrine allows an intervenor to file an interlocutory appeal of
+an order denying a motion to quash a grand jury subpoena. See, e.g., In re Grand
+Jury Proceedings, 832 F.2d 554, 556-58 (11th Cir. 1987). "This exception, derived
+from Perlman v. United States, ... permits an order denying a motion to quash to
+9
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 12 of 25
+Date Filed: 04/18/2014 Page: 10 of 23
+be 'considered final as to the injured third party who is otherwise powerless to
+prevent the revelation."" Id. at 558 (quoting In re Grand Jury Proceedings (Fine),
+641 F.2d 199, 202 (5th Cir. Unit A Mar. 1981)). Under Perlman, "a discovery
+order directed at a disinterested third party is treated as an immediately appealable
+final order because the third party presumably lacks a sufficient stake in the
+proceeding to risk contempt by refusing compliance." Church of Scientology of
+Cal. v. United States, 506 U.S. 9, 18 n.11, 113 S. Ct. 447, 452 n.11 (1992); see also
+In re Air Crash at Belle Harbor, N.Y. on Nov. 12, 2001, 490 F.3d 99, 106 (2d Cir.
+2007) (*IT]he Perlman exception is relevant only to appeals brought by the holder
+of a privilege where the disputed subpoena is directed at someone else."). We have
+exercised jurisdiction under the Perlman doctrine when the party ordered to
+disclose the information "has no direct and personal interest in the suppression of
+the information" and would be reluctant to risk a contempt citation, such that "the
+order is definitely final as to the [claimant of the privilege]." Fine, 641 F.2d at
+201-02. We have not invoked the Perlman doctrine to exercise jurisdiction over an
+interlocutory appeal outside the context of a grand jury proceeding. See, e.g., In re
+Fed. Grand Jury Proceedings (
+), 975 F.2d 1488, 1491-92 (11th Cir. 1992);
+In re Grand Jury Proceedings, 832 F.2d at 558; Fine, 641 F.2d at 201-02. But we
+have exercised jurisdiction over interlocutory appeals by claimants of a privilege in
+10
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 13 of 25
+Date Filed: 04/18/2014 Page: 11 of 23
+some civil proceedings. See Castle v. Sangamo Weston, Inc., 744 F.2d 1464, 1465-
+66 (11th Cir. 1984) (exercising jurisdiction because the appellant "claims a
+privilege of non-disclosure relating to materials that another party has been
+directed to produce"); Int'l Horizons, Inc. v. Comm. of Unsecured Creditors (In re
+Int'l Horizons, Inc.), 689 F.2d 996, 1001-02 (11th Cir. 1982) (holding that an
+order compelling production of allegedly privileged material is immediately
+appealable because "the privilege-holder has no power to compel the custodian of
+the material to risk a contempt citation for his refusal to comply" (internal
+quotation marks omitted)); Overby v. United States Fid. & Guar. Co., 224 F.2d
+158, 162 & n.5 (5th Cir. 1955) (exercising interlocutory jurisdiction and citing
+Perlman in a civil action to recover damages for breach of a bond against a surety
+company where "denial of the privilege could [not] be reviewed on appeal either
+from the final judgment or from a contempt order").
+The victims argue that we should not extend Perlman beyond an
+intervenor's appeal of a grand jury subpoena, but we decline to draw an arbitrary
+line. The victims' argument has an ipse dixit quality—that is, because our Court
+has never before applied the Perlman doctrine outside of the grand jury context,
+we should not do so now. But we must ask instead whether applying the doctrine
+here makes sense.
+11
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 14 of 25
+Date Filed: 04/18/2014 Page: 12 of 23
+The logic of the Perlman doctrine applies with equal force in this appeal.
+Like a claimant objecting to a grand jury subpoena cannot challenge an indictment
+to remedy the disclosure of his privileged information, the intervenors cannot
+challenge a final judgment in this proceeding to remedy the disclosure of their plea
+negotiations. And the victims' petition, like a grand jury proceeding, is ancillary to
+a criminal investigation. The rights and remedies provided by the Act arise in a
+criminal prosecution and affect how the United States prosecutes that action. See
+18 U.S.C. § 3771 (a), (d).
+The victims argue that Epstein has made himself an ordinary litigant through
+his intervention, but we disagree. The district court has allowed Epstein's attorneys
+to intervene only to contest the disclosure of their correspondence, and the district
+court has granted Epstein limited intervention to challenge only the disclosure of
+his attorneys' correspondence and any remedy that involves the non-prosecution
+agreement. Epstein's only opportunity to challenge the disclosure order is now
+because there will not be an adverse judgment against him or his attorneys. The
+district court instead will enter any judgment against either the victims or the
+United States. And, even if the victims succeed in their petition to rescind the nonprosecution agreement, Epstein can challenge only that remedy, not the judgment
+against the United States. The victims intend to use the correspondence from
+12
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 15 of 25
+Date Filed: 04/18/2014 Page: 13 of 23
+Epstein's attorneys to prove that the United States violated the Act, which is an
+issue separate from the kind of relief necessary to remedy that violation. And it is
+all the more likely that the district court would fashion a remedy that does not
+involve the non-prosecution agreement, if the district court were to conclude that
+rescission is unavailable, which might then bar an appeal by Epstein of that
+remedy.
+The intervenors claim a privilege, and only claimants of a privilege may
+appeal under the Perlman doctrine. In re Grand Jury Proceedings, 832 F.2d at
+558-59. Contrary to the victims' argument, jurisdiction under the Perlman doctrine
+does not rise or fall with the merits of an appellant's underlying claim for relief.
+See, e.g., id. at 558-60 (permitting an interlocutory appeal based on Perlman, but
+holding that "we find that the privilege asserted by appellants is without a basis in
+Florida law" and that appellants "have no privilege of nondisclosure under state
+law");
+v. City of Memphis, 423 F.3d 596, 599 (6th Cir. 2005) ("[Perlman]
+jurisdiction does not depend on the validity of the appellant's underlying claims for
+relief."); see also, e.g., Perlman, 247 U.S. at 13-15, 38 S. Ct. at 420 (reviewing
+Perlman's claim on interlocutory appeal, but finding no violation of the Fifth
+Amendment in later use by the United States of exhibits made public in previous
+litigation). The intervenors claim a privilege based on Rule 410, the work-product
+13
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 16 of 25
+Date Filed: 04/18/2014 Page: 14 of 23
+privilege, and the Sixth Amendment right to effective assistance of counsel as well
+as a new common-law privilege for plea negotiations. These claims of privilege,
+however tenuous, are sufficient to establish jurisdiction under Perlman.
+Absent an interlocutory appeal, the intervenors would be left with no
+recourse to appeal the disclosure order. The intervenors cannot defy the disclosure
+order and risk a contempt citation because the order is directed at the United States,
+which has expressed an intent to comply with the order. The United States is a
+disinterested party because it does not purport to hold the privilege claimed by the
+intervenors. Even if the United States earlier shared the common goal of resolving
+the criminal investigation quickly and without a federal indictment, any interest of
+the United States in asserting a privilege for plea negotiations dissipated when
+Epstein disclosed the correspondence written by the United States to the victims in
+the civil suit.
+The intervenors are also likely unable to pursue their claims through the
+remaining "established mechanisms for [immediate] appellate review." See
+Mohawk, 558 U.S. at 112, 130 S. Ct. at 608. Because a crime victim's petition
+under the Act arises in a criminal action, the text of section 1292(b), which applies
+to a "civil action," renders a certification of this appeal unavailable. See also In re
+Grand Jury Proceedings, 832 F.2d at 557 (holding that grand jury proceedings are
+14
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 17 of 25
+Date Filed: 04/18/2014 Page: 15 of 23
+not civil actions for purposes of section 1292(b)). And if the intervenors were to
+seek a writ of mandamus, it is unlikely that the disclosure order would amount to a
+"judicial usurpation of power or a clear abuse of discretion" or "otherwise work[] a
+manifest injustice." Mohawk, 558 U.S. at 111, 130 S. Ct. at 607 (internal quotation
+marks omitted).
+The victims argue that, even if the logic of the Perlman doctrine applies
+here, the decision of the Supreme Court in Mohawk forecloses this interlocutory
+appeal, but they misconstrue both the decision in Mohawk and the Perlman
+doctrine. Mohawk considered whether the Court had jurisdiction under the
+collateral-order doctrine, which provides an exception to the general bar of
+interlocutory appeals if an order "(1) conclusively determines the disputed
+question; (2) resolves an important issue completely separate from the merits of the
+action; and (3) is effectively unreviewable on appeal from a final judgment." Id. at
+105, 130 S. Ct. at 604. In Mohawk, the Supreme Court foreclosed an interlocutory
+appeal of an order requiring the disclosure of materials protected by the attorneyclient privilege because the claimant was a party who could appeal a final
+judgment. Id. at 114, 130 S. Ct. at 609. The Supreme Court explained that an
+appeal from a final judgment suffices "to protect the rights of litigants and ensure
+the vitality of the attorney-client privilege" because "[a]ppellate courts can remedy
+15
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 18 of 25
+Date Filed: 04/18/2014 Page: 16 of 23
+the improper disclosure of privileged material in the same way they remedy a host
+of other erroneous evidentiary rulings: by vacating an adverse judgment and
+remanding for a new trial in which the protected material and its fruits are
+excluded from evidence." Id. at 109, 130 S. Ct. at 606-07. The Court found
+unpersuasive that these disclosures may "have implications beyond the case at
+hand" and ruled that, although imperfect, postjudgment review is sufficient. Id. at
+108-12, 130 S. Ct. at 606-09. The Court also explained that three traditional routes
+of immediate review could still afford the claimant of the privilege adequate relief
+in a civil action: the claimant could ask the district court to certify the appeal of "a
+controlling question of law," the resolution of which "may materially advance the
+ultimate termination of the litigation"; the claimant could petition the court of
+appeals for a writ of mandamus; or the claimant could defy a disclosure order and
+appeal a sanction for contempt. Id. at 110-11, 130 S. Ct. at 607-08 (internal
+quotations marks omitted). The Supreme Court in Mohawk never cited Perlman
+nor discussed appeals by claimants of a privilege who are limited intervenors in a
+proceeding ancillary to a criminal investigation and seek to prevent the disclosure
+of information held by a disinterested party. See In re Grand Jury, 705 F.3d 133,
+146 (3d Cir. 2012) ("[T]he Mohawk Court... did not discuss, mention, or even
+cite Perlman...."). Understandably so—-claimants of a privilege under the
+16
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 19 of 25
+Date Filed: 04/18/2014 Page: 17 of 23
+Perlman doctrine remain "powerless to avert the mischief of [a discovery] order,"
+Perlman, 247 U.S. at 12-13, 38 S. Ct. at 419, because the materials in question are
+held by a disinterested party who is likely "to forgo suffering a contempt citation
+and appealing in favor of disclosure," United States v. Krane, 625 F.3d 568, 573
+(9th Cir. 2010). As the Seventh Circuit explained about the scope of the Perlman
+doctrine after Mohawk, "lo]nly when the person who asserts a privilege is a nonlitigant will an appeal from a final decision be inadequate." Wilson v.
+, 621
+F.3d 641, 643 (7th Cir. 2010); see also In re Grand Jury, 705 F.3d at 145-46 &
+n.11 (rejecting that Mohawk narrowed Perlman "at least in the grand jury
+context"); Holt-Orsted v. City of Dickson, 641 F.3d 230, 239 (6th Cir. 2011)
+(recognizing that Perlman jurisdiction remains when a nonparty asserts a
+privilege); Krane, 625 F.3d at 572 (ruling that "Perlman and Mohawk are not in
+tension" when the claimant of a privilege is not a party). But see United States v.
+Copar Pumice Co., Inc., 714 F.3d 1197, 1207-09 (10th Cir. 2013) (holding that
+jurisdiction under the Perlman doctrine is limited to only the grand jury context,
+but declining jurisdiction because the privilege holder was also a party to the
+litigation). And, as we explained above, the intervenors cannot appeal a final
+judgment against the United States, which leaves them without an avenue to appeal
+their denial of their claims of privilege.
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 20 of 25
+Date Filed: 04/18/2014 Page: 18 of 23
+B. The Intervenors' Correspondence Is Not Privileged.
+The intervenors argue that the district court erred when it ordered the
+disclosure of the plea negotiations because three privileges protect the
+correspondence: a privilege under Federal Rule of Evidence 410, the work-product
+privilege of attorneys, and a common-law privilege for plea negotiations in
+criminal proceedings. We disagree. No privilege prevents the disclosure of the plea
+negotiations.
+1. Federal Rule of Evidence 410 Provides No Privilege for Plea Negotiations.
+Federal Rule of Evidence 410 does not protect against the discoverability of
+plea negotiations and, even if it did, Epstein clearly falls outside its protection
+because he entered a guilty plea and the victims intend to use the correspondence
+against the United States, not against Epstein. Rule 410 "create[s], in effect, a
+privilege of the defendant," United States v. Mezzanatto, 513 U.S. 196, 205, 115 S.
+Ct. 797, 803 (1995) (internal quotation marks and alteration omitted), but not a
+privilege of non-disclosure as the intervenors assert. The text of Rule 410
+unambiguously states that the evidence "is not admissible against the defendant
+who made the plea or participated in the plea discussions" if the "guilty plea...
+was later withdrawn" or "did not result in a guilty plea." Fed. R. Evid. 410(a). Rule
+410 governs the admissibility of plea negotiations, not the discoverability of them.
+18
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 21 of 25
+Date Filed: 04/18/2014 Page: 19 of 23
+Moreover, Epstein cannot invoke Rule 410 because he pleaded guilty to state
+charges based on the same conduct and has not withdrawn those pleas. See, e.g.,
+United States v.
+, 794 F.2d 345, 349 (8th Cir. 1986) (admitting guilty plea
+from state court in federal proceeding). The victims intend to admit the
+correspondence to prove violations of the Act allegedly committed by the United
+States, not "against" Epstein. And even if rescission of the non-prosecution
+agreement abuts Epstein's interests, the purpose of the admission does not change.
+Rule 410 does not bar disclosure of the correspondence written by the attorneyintervenors.
+2. The Intervenors Waived Any Work-Product Privilege.
+The intervenors next contend that the correspondence falls under the workproduct privilege, but the finding of the district court that the intervenors waived
+any privilege when they voluntarily sent the correspondence to the United States
+during the plea negotiations is not clearly erroneous. Disclosure of work-product
+materials to an adversary waives the work-product privilege. See, e.g., In re
+Chrysler Motors Corp. Overnight Evaluation Program Litig., 860 F.2d 844, 846
+(8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it
+shared the common goal of reaching a quick settlement, the United States was
+undoubtedly adverse to Epstein during its investigation of him for federal offenses,
+19
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 22 of 25
+Date Filed: 04/18/2014 Page: 20 of 23
+and the intervenors' disclosure of their work product waived any claim of
+privilege.
+As a last-ditch effort, the intervenors contend that "[ilf more is needed in
+addition to the plain language of Rule 410 to preclude disclosure of the
+correspondence to plaintiffs, it can be found in the conjunction of Rule 410, the
+work-product privilege, and the Sixth Amendment right to the effective assistance
+of counsel in the plea bargaining process," but this novel argument fails too. As
+explained above, Rule 410 does not create a privilege and the intervenors waived
+any work-product privilege. The intervenors concede too that the right to counsel
+under the Sixth Amendment had not yet attached when the correspondence was
+exchanged. Lumley v. City of Dade City, Fla., 327 F.3d 1186, 1195 (11th Cir.
+2003) ("IT]he Sixth Amendment right to counsel ordinarily does not arise until
+there is a formal commitment by the government to prosecute," such as a "formal
+charge, preliminary hearing, indictment, information, or arraignment."). The
+"conjunctive" power of three false claims of privilege does not rescue the
+correspondence from disclosure.
+3. We Decline To Recognize a Common-Law Privilege for Plea Negotiations.
+The intervenors also invite us to recognize a common law privilege for plea
+negotiations, Fed. R. Evid. 501, but we decline to do so. The intervenors have not
+20
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 23 of 25
+Date Filed: 04/18/2014 Page: 21 of 23
+established a "compelling justification" to prevent the discovery of plea
+negotiations in criminal proceedings, In re Int'l Horizons, 689 F.2d at 1004.
+Although Congress empowered the federal courts through Rule 501 to "continue
+the evolutionary development of testimonial privileges," Trammel v. United States,
+445 U.S. 40, 47, 100 S. Ct. 906, 910 (1980), we disfavor newly minted privileges,
+which "contravene the fundamental principle that the public has a right to every
+man's evidence," Adkins v. Christie, 488 F.3d 1324, 1328 (11th Cir. 2007)
+(quoting Univ. of Pa. v. EEOC, 493 U.S. 182, 189, 110 S. Ct. 577, 582 (1990)).
+"Accordingly, there is a presumption against privileges which may only be
+overcome when it would achieve a 'public good transcending the normally
+predominant principle of utilizing all rational means for ascertaining truth." Id.
+(quoting Trammel, 445 U.S. at 50, 100 S. Ct. at 912).
+The Supreme Court has identified several considerations relevant to whether
+a court should recognize an evidentiary privilege-the needs of the public, whether
+the privilege is rooted in the imperative for confidence and trust, the evidentiary
+benefit of the denial of the privilege, and any consensus among the states, Jaffee v.
+Redmond, 518 U.S. 1, 10-15, 116 S. Ct. 1923, 1928-31 (1996)— but none of these
+considerations weighs in favor of recognizing a new privilege to prevent discovery
+of the plea negotiations. Although plea negotiations are vital to the functioning of
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 24 of 25
+Date Filed: 04/18/2014 Page: 22 of 23
+the criminal justice system, a prosecutor and target of a criminal investigation do
+not enjoy a relationship of confidence and trust when they negotiate. Their
+adversarial relationship, unlike the confidential relationship of a doctor and patient
+or attorney and client, warrants no privilege beyond the terms of Rule 410. See
+Jaffee, 518 U.S. at 10, 116 S. Ct. at 1928. But the victims would enjoy an
+evidentiary benefit from the disclosure of plea negotiations to prove whether the
+United States violated their rights under the Act. As for any consensus among the
+states, the majority of the state statutes the intervenors cite adopted Rule 410
+verbatim. Compare, e.g., Fla. Stat. § 90.410 ("Evidence of a plea of guilty, later
+withdrawn; a plea of nolo contendere; or an offer to plead guilty or nolo
+contendere to the crime charged or any other crime is inadmissible in any civil or
+criminal proceeding."), with Fed. R. Evid. 410.
+Even if we were to accept the intervenors' argument that plea negotiations
+are de facto confidential in criminal practice, that custom alone would not protect
+them from discovery because Rule 410 militates against the establishment of a new
+privilege. The Supreme Court has cautioned federal courts to be "especially
+reluctant to recognize a privilege in an area where it appears that Congress has
+considered the relevant competing concerns but has not provided the privilege
+itself." Univ. of Pa., 493 U.S. at 189. Congress weighed the evidentiary concerns
+22
+
+
+Case 9:08-cv-80736-KAM Document 254 Entered on FLSD Docket 06/11/2014 Page 25 of 25
+Date Filed: 04/18/2014 Page: 23 of 23
+related to criminal plea negotiations when it enacted Rule 410, which enables a
+defendant to negotiate without fear that the prosecutor will use his statements
+against him. Rule 410 contemplates that plea negotiations should ordinarily be
+inadmissible against a defendant, but not always. The rule does not bar the
+admission of plea negotiations, for example, when the defendant pleads guilty, in a
+proceeding for perjury, or when the defendant introduces the statements so long as
+they are not self-serving hearsay. If we were to recognize a privilege for plea
+negotiations, we would upset the balance that Congress struck when it adopted
+Rule 410. See In re MSTG, Inc., 675 F.3d 1337, 1344 (Fed. Cir. 2012) (rejecting a
+privilege for settlement negotiations because Congress, by enacting Rule 408, "did
+not take the additional step of protecting settlement negotiations from discovery.").
+We will not go further than Congress stated was necessary to promote the public
+good in criminal plea negotiations.
+IV. CONCLUSION
+We AFFIRM the disclosure order and LIFT the stay of the order
+compelling the United States to disclose the correspondence.
+23
\ No newline at end of file
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+Case 9:08-CV-80381-KAM Document 70-1 Entered on FLSD Docket 04/02/2009 Page 1 8f8
+Westlaw.
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+Page 1
+District Court of Appeal of Florida,
+Fifth District.
+Kimberly BALAS and Teresa Shumate, Petitioners,
+V.
+Marjorie A. RUZZO, and Exec.., Inc., etc., Re-
+spondents.
+No. 97-82.
+307Ak31 k. Relevancy and Materiality.
+Most Cited Cases
+Party may be permitted to discover evidence that
+would be inadmissible at trial, if it would lead to
+discovery of relevant evidence. West's F.S.A. RCP
+Rule 1.280(b)(1).
+[3] Pretrial Procedure 307A €36.1
+Oct. 10, 1997.
+307A Pretrial Procedure
+(Fla.
+307 AIl Depositions and Discovery
+Plaintiffs brought action against alleged house of 1998). 307AII(A) Discovery in General
+prostitution for, inter alia, coercion of prostitution.
+307 Ak36 Particular Subjects of Disclos- ure
+The Circuit Court, Brevard County, !
+Pound,
+307Ak36.1 k. In General. Most Cited
+J., granted in part defendants' motion to compel discovery. Plaintiffs filed petition for writ of certiorari. The District Court of Appeal, W. Sharp, J., held
+that evidence of plaintiffs' past prostitution and
+their revenues relating to such activities was discoverable.
+Petition denied.
+Harris, J., concurred specially and filed opinion.
+West Headnotes
+[1] Pretrial Procedure 307A €31
+Cases
+Evidence of plaintiffs' past prostitution and their
+revenues relating to such activities, including activities with alleged house of prostitution against
+which they had filed suit, was discoverable, where
+plaintiffs brought action not only for coercion of
+prostitution, but also for battery, false imprisonment, invasion of privacy, intentional infliction of
+emotional distress, violation of their civil rights,
+and racketeering. Violent Crime Control and Law
+Enforcement Act of 1994, § 40302, 42 U.S.C.A. §
+13981; West's F.S.A. §§ 772.014, 796.09; West's
+F.S.A. RCP Rule 1.280(b)(1).
+*1076 Richard E.
+and Heather Fisher Lindsay, of Spriggs
+&
+Tallahassee, for Petitioners.
+307A Pretrial Procedure
+307AII Depositions and Discovery
+307AII(A) Discovery in General
+307Ak31 k. Relevancy and Materiality.
+Most Cited Cases
+Discovery in civil cases must be relevant to subject
+matter of case and must be admissible or reasonbly calculated to lead to admissible evidence
+Nest's F.S.A: RCP Rule 1.280(b)(1)
+[2] Pretrial Procedure 307A €m 31
+307A Pretrial Procedure
+307 AlI Depositions and Discovery
+307AII(A) Discovery in General
+Mark S. Peters of Amari, Theriac & Eisenmenger,
+P.A., Cocoa, for Respondents.
+W. SHARP, Judge.
+Balas and Shumate petition this court for a writ of
+certiorari to review certain portions of the lower
+@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 PagE 3 8f8
+Page 2
+703 So.2d 1076, 22 Fla. L.. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+compelled to disclose intimate details of their sexual history. We decline to issue the writ of certiorari.
+Balas and Shumate filed suit against Ruzzo and Ex-
+ec, Inc., doing business as "The Boardroom." Ac-
+cording to Balas and Shumate, The Boardroom operates ostensibly as *1077 a leisure spa but actually
+is a house of prostitution. Balas worked at The
+Boardroom from December 1993 until February
+1996; Shumate worked there from October 1992
+until March 1996. Ruzzo, the sole officer and
+shareholder of Exec, Inc., collected about fifty to
+sixty percent of each employees' earnings from performing sexual acts.
+According to Balas and Shumate, Ruzzo exerted
+mental and emotional control over her employees
+and thus she was able to exploit them as prostitutes.
+Ruzzo required her employees to pay her substantial sums of money to attend "metaphysical workshops" conducted by Ruzzo or persons associated
+with her. At the work place, the employees were required to participate in religious and quasi-religious
+"circles," rituals and incantations. These practices
+titioners against their will. Count IV alleges that respondents' actions constituted an invasion of petitioners' privacy. Count V is a claim for the intentional infliction of emotional distress. Count VI alleges a civil rights action-that respondents have violated petitioners' right to be free from crimes of violence motivated by gender within the meaning of
+42 U.S.C. section 13981. Finally, count VII seeks
+civil remedies for criminal practices or racketeering
+pursuant to section 772.104, Florida Statutes. The
+petitioners claim that they suffered emotional pain,
+anguish, humiliation, insult, indignity, loss of selfesteem, inconvenience, hurt and emotional distress.
+They seek an award of general and punitive damages, among other relief.
+The discovery to which the petitioners are being required to respond is as follows:
+their submission to these searches and that they
+might be arrested on felony charges if they refused
+to submit to the searches.
+Balas and Shumate's second amended complaint
+against Ruzzo contains seven counts. Count I is an
+action for coercion of prostitution pursuant to section 796.09, Florida Statutes. Petitioners allege the
+requirement that they perform sexual acts to retain
+their employment constitutes inducement and coercion to engage in prostitution. Count Il is a claim
+for battery for the unwanted and offensive touching
+of the petitioners' bodies. Count IIl is a claim for
+false imprisonment for physically confining the pe-
+Interrogatory 8: Please advise how long have you
+been engaged in prostitution....
+Il.
+Interrogatory 22: State with specificity the manner in which the acts as described in your Complaint have materially affected how you interact
+with your husband, boyfriend, fiancée' [sic] or
+any other individual of the opposite sex.
+III.
+Request for Production 30: A copy of any photographs, movies or videotapes in which you perormed sexual acts and/or simulated sexual acts
+n exchange for money or other consideration
+IV.
+Interrogatory 16: Please list the names, addresses,
+telephone numbers and rates of pay for all employers for which you worked, including the
+@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMIE&ifm=NotSet&mt... 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 patfe 3 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+nature of the work, during the five years immediately preceding the date of employment with the
+Boardroom and from the date of your termination
+with the Boardroom to the present, providing the
+names of your immediate supervisors at each
+place of employment and the reason for your
+leaving each place of employment.
+Page 3
+V.
+Interrogatory 26: Please state your total income
+while employed at the Boardroom, and state the
+source of that income including any income from
+other employment or *1078 income earned from
+prostitution other than at the Boardroom.
+VI.
+Request for Production 34: Business records from
+any selfemployment or owned business ventures
+in the last 5 years, including any records or list of
+customers,
+"special customer lists" or "sugar
+daddy's list."
+[1][2] Discovery in civil cases must be relevant to
+the subject matter of the case and must be admissible or reasonably calculated to lead to admissible
+evidence. See Allstate Insurance Co. V. Langston,
+655 So.2d 91 (Fla. 1995); Amente v.
+So.2d 1030 (Fla. 1995);
+ers, Inc., 690 So.2d 743 (Fla. 5th DCA 1997). The
+concept of relevancy is broader in the discovery
+context than in the trial context and a party may be
+permitted to discover evidence that would be inadmissible at trial, if it would lead to the discovery of
+relevant evidence. Allstate; Amente. Florida Rule of
+Civil Procedure 1.280(b)(1) delineates the proper
+scope of discovery:
+In General. Parties may obtain discovery regardnature, custody, condition, and location of any
+books, documents, or other tangible things and
+the identity and location of persons having knowledge of any discoverable matter. It is not ground
+for objection that the information sought will be
+inadmissible at the trial if the information sought
+appears reasonably calculated to lead to the discovery of admissible evidence.
+Nonetheless, the discovery of certain kinds of information may cause material injury of an irreparable nature. This includes the "cat-out-of-the-bag"
+material that could be used to injure another person
+or party outside the context of the litigation, material protected by privilege, trade secrets or work
+product. Discovery was never intended to be used
+as a tactical tool to harass, embarrass or annoy
+one's adversary. Rather, pretrial discovery was implemented to simplify the issues in a case, to eliminate the elements of surprise, to encourage the settlement of cases, to avoid the cost of litigation, and
+to achieve a balanced search for the truth to ensure
+a fair trial. Elkins v. Syken, 672 So.2d 517 (Fla. 1996).
+Here the petitioners argue that the information
+sought to be discovered regarding prostitution and
+their sexual activities was propounded solely to embarrass them and to invade their right to privacy.
+The petitioners also claim that this information is
+privileged under section 796.09 and is not calculated to lead to evidence which would be admissible at trial.
+Section 796.09 provides a person with a civil cause
+of action for compensatory and punitive damages
+against anyone who coerces that person into prostitution, who coerces that person to remain in prostitution, or who uses coercion to collect or receive
+Let my time to got wils plant ay
+seeking discovery or the claim or defense of any
+other party, including the existence, description,
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 page 48f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+ness for the plaintiffs cannot be used against the
+plaintiffs or witness in any other investigation or
+proceeding, except one for perjury.
+Section 796.09(5) specifically provides that it is not
+a defense that the plaintiff was paid or otherwise
+compensated for prostitution, that the plaintiff had
+engaged in prostitution prior to any involvement
+with the defendant or that the plaintiff made no attempt to escape from the defendant. Section
+796.09(6) provides that convictions for prostitution
+or prostitution-related offenses are inadmissible for
+the purpose of attacking the plaintiffs' credibility.
+This legislation was the result of the Florida Su-
+preme Court Gender Bias Study Commission,
+which conducted an extensive investigation of prostitution in this state. The Commission's activities
+included interviews with law enforcement and corrections personnel,*1079 judges, public defenders,
+prosecutors, drug rehabilitation counselors, social
+workers, medical personnel, prostitutes, clients and
+. The Commission found
+prostitution to be
+prevalent and uniform throughout the state and law
+enforcement largely unable to deter it under prevailing social attitudes and judicial
+practices. The
+Commission further found that prostitutes are often
+victims of economic, physical, and
+psychological
+coercion, that most persons do not chose to become
+prostitutes, but do so to survive, and that ninety
+percent of street prostitutes,
+both adult and children, are controlled by pimps who use a variety of
+coercive methods to maintain this control. The
+Commission determined that clients and pimps are
+rarely prosecuted and, when prosecuted, receive
+light sentences; whereas prostitutes, who are mainly
+frequently prosecuted and receive
+harsher treatment in the courts. The Commission
+Page 4
+cest to the judicial system without for having to ac
+arrested.
+Under section 796.09, the petitioners' prior involvement in prostitution and their earnings from prostitution would be irrelevant. Hence discovery should
+not be permitted because such information would
+not be admissible at trial nor would it be reasonably
+calculated to lead to evidence ultimately admissible
+at trial. Even though the scope of discovery is generally quite broad, section 796.09 is designed to encourage prostitutes to sue their pimps. Thus the
+usually broad scope of discovery may be constricted so that prostitutes will not be embarrassed, harassed or hindered in their actions.
+[3] Had the petitioners brought their lawsuit against
+Ruzzo and The Boardroom only under section
+796.09, evidence of petitioners past prostitution,
+including with the Boardroom, and their earnings
+relating to such activities, may not have been discoverable. However, the petitioners filed a multicount complaint for compensatory and punitive
+damages, alleging
+numerous causes of
+against the respondents.
+These other causes carry
+no such protection from discovery. Since the information sought by discovery may be relevant or
+may lead to the discovery of admissible evidence in
+one or more of these other causes of action or to
+determination of damages, we cannot conclude that
+the trial court departed from the essential requirements of law in granting this discovery. See
+v. TIB Bank of the Keys, 687 So.2d 895 (Fla. 3d
+DCA 1997) (by alleging fraud as well as breach of
+contract, purchaser placed at issue her reliance on
+venders' assertions, the veracity of financial documents she submitted to the vender, and the state of
+her mental health, including memory problems she
+was experiencing at the time of the alleged tortious
+conduct, thus deposition questions concerning her
+state of mind were relevant).
+Petition for Writ of Certiorari DENIED.
+THOMPSON, J., concurs.
+HARRIS,
+concurs specially with opin
+ion.HARRIS, Judge, concurring specially:
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Case 9:08-CV-80381-KAM Document 70-1 Entered on FLSD Docket 04/02/2009 Plife 5 8f 8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+There is a temptation in cases such as this to inquire
+which, the pot or the kettle, is imbued with the
+darker hue. Indeed that may ultimately be the question uppermost in the jurors' minds. But the issue
+presently before us is simply whether the pot, in order to establish the parties' comparative complexion, may discover the historical condition and the
+inherent characteristics of the kettle.
+We are here involved with parties that the limited
+record before us indicates were co-conspirators in a
+joint effort to violate Florida's laws against prostitution. The defendants are the owner/operators of a
+"social club" whose primary service is prostitution;
+the plaintiffs are employees of the club who
+provide such services. The employees are suing the
+owner/operators for, among other counts, taking advantage of their vulnerabilities ("coercing" them to
+be prostitutes) through manipulation and exploitation. In order to prepare a defense to the action, defendants have filed certain interrogatories for the
+employees to answer. These interrogatories*1080
+request such information as how long the employees have been engaged in prostitution; how the employees have been affected by the defendants' conduct; copies of photographs, movies, and videotapes in which the employees have performed sexual acts or simulated sexual acts; the names of previous employers and previous rates of pay; and a
+statement of income received from defendants.
+These interrogatories survived the employees' objections. I agree certiorari should be denied.
+The employees' primary cause of action is based on
+section 796.09(l), Florida Statutes, which provides:
+(1) A person has a cause of action for compensatory
+and punitive damages against:
+{a) A person who coerces that person into prostitution;
+(b) A person who coerces that person to remain in
+prostitution, or
+(e) A person who uses coercion to collect or receive
+Page 5
+any part of that person's earnings derived from
+prostitution.
+The employees resist discovery of their past prostitution or their past or present earning experience on
+the basis of subparagraph 5 of section 796.09:
+5) It does not constitute a defense to a complaint
+under this section that:
+1) The plaintiff was paid or otherwise compensate
+for acts of prostitution
+b) The plaintiff engaged in acts of prostitution prior to any involvement with the defendant...
+But the question before us is not whether prior acts
+of prostitution (or the receipts of earnings therefrom) which might be revealed by answering the interrogatories could be used as a defense to the complaint, but rather whether evidence of such conduct
+or such earnings would be relevant in determining
+whether the employees were, in fact, "coerced" into
+prostitution, into remaining prostitutes, or into sharing the proceeds of their services with defendants.
+The relevancy of this information depends, of
+course, on what constitutes coercion.
+If we apply the definition of "coercion" which is
+commonly accepted, then the relevancy of the requested information is apparent and this appeal has
+no merit at all. Webster defines "coercion" as: (1)
+to restrain or dominate by force, (2) to compel an
+act or choice, or (3) to enforce or bring about by
+force or threat. In sexual battery cases, the legislature has adopted the common meaning of the
+word "coercion" and has even placed limits on it. It
+has provided that consent will not be recognized if
+ence if the victim reasonably believes the perpetratcoerced by a threat of retaliation against the victim
+or another if the victim reasonably believes that the
+erpetrator has the ability to execute the threat
+le future. And in sexual battery cases, the 1
+gislature has vitiated what might otherwise be con-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt... 3/26/2009
+
+
+Case 9:08-CV-80381-KAM Document 70-1 Entered on FLSD Docket 04/02/2009 På€ & 8f §
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+sidered as consensual if one exploits a known physical or mental weakness of the victim to achieve his
+or her goal or takes advantage of one who is physically helpless or involuntarily intoxicated.FN3
+Therefore, even in sexual battery cases, before coercion or exploitation will vitiate consent, the free
+will of the victim must be overcome by force or
+threat or some unfortunate circumstance suffered
+by the victim.
+FN1. Section 794.011(4)(b), Florida Statutes.
+FN2. Section 794.011(4)(c), Florida Statutes.
+FN3. Section 794.011(4)(a),(d),(e), and (f),
+Florida Statutes.
+But then we get to the definition of "coercion" contained in section 796.09(3):
+3) As used in this section, the term "coercion"
+means any practice of dominion, restraint, or inducement for the purpose of or with the reasonably foreseeable effect of causing another person
+to engage in or remain in prostitution or to relinquish earnings derived from prostitution, and includes, but is not limited to:
+{a) Physical force or threats of physical force.
+{b) Physical or mental torture.
+(c) Kidnapping.
+*1081 (d) Blackmail.
+(e) Extortion or claims of indebtedness.
+(f) Threats of legal complaint or report of delinquency.
+(g) Threat to interfere with parental rights of responsibilities, whether by judicial or administrative action or otherwise.
+(h) Promise of legal benefit.
+Page 6
+]) Promise of greater financial rewards.
+j) Promise of marriage.
+(k) Restraint of Speech or communications with
+others.
+1) Exploitation of a condition of developmental
+disability, cognitive limitation, affective disorder,
+or substance dependency.
+"m) Exploitation of victimization by sexual abuse.
+in) Exploitation of pornographic performance.
+"o) Exploitation of human needs for food, shelter,
+safety, or affection.
+The definition urged by the employees herein is the
+"promise of a greater financial reward." Whether
+the requested information is relevant to the issue of
+coercion in this case will depend on what the legislature intended by subsection (I) in the meaning of
+"coercion."
+I agree with Judge Altenbernd's thoughtful analysis
+in State v. Brigham, 694 So.2d 793 (1997):
+There can be no dispute that the legislature's unusual definition of "percent" is not a common dietionary definition. This is perhaps an appropriate
+case in which to remind ourselves of Learned
+Hand's famous observation that a "mature and developed jurisprudence" does not "make a fortress
+out of the dictionary."
+But even so, one would expect some nexus between
+from a prit Dane the oles should nevertees
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Case 9:08-CV-80381-KAM Document 70-1 Entered on FLSD Docket 04/02/2009 Påge 7 8f 8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+before a definition is construed so as to expand the
+meaning of a well-known word to include its antonym ..., the intention of the legislature to that effect must be clear." As Judge
+observed in
+Catron v. Roger Bohn, D.C., P.A., 580 So.2d 814,
+818 (Fla. 2d DCA 1991):
+It is our primary duty to give effect to legislative
+intent and, if a literal interpretation of a statute
+leads to unreasonable results, then we should exercise our power to interpret reason and logic to it.
+*****
+Unfortunately, it is apparent that in enacting this legislation, the legislature has, without redefining
+the terms for the purposes of this legislation, often used terms with commonly accepted meanings for purposes at great variance from those
+commonly accepted meanings.
+1 our case, the legislature did detine the term fo
+e purpose of the act. But because the terr
+(coercion) as so defined can be interpreted two
+ways-one consistent with the commonly accepted
+meaning and one at variance-we should not accept
+the "antonym" unless such
+legislative intent is
+clear. A free will decision, even if based on a hope
+of financial gain, is the opposite of a coerced decision.
+The employees urge that the mere promise of a
+greater reward brings them within the act. But if the
+mere promise of a greater reward is sufficient to establish coercion, then anyone who makes a voluntary and reasoned exercise of free will motivated by
+the hope of economic gain has been coerced. This
+Page 7
+of an opportunity to make a decision with the coercion of that decision. But subsection (I) can also
+mean *1082 that the promise of a greater reward is
+coercion only if such promised reward is sufficient
+to overcome one's natural revulsion to selling one's
+body for money. If there is no such revulsion, there
+can be no coercion. Becoming a prostitute only because one likes the hours and wages or "because it
+beats the heck out of working for a living" simply
+should not meet the test of section 796.09(1).
+At oral argument herein, it was suggested without
+contradiction, that at least one of the employees has
+a college degree and gave up a well-paying, legitimate job in order to engage in this profession for
+the greater reward. Section 796.09 does not appear
+to be a general prostitute's relief act. It is based on a
+report by the Gender Bias Study Commission which
+recommended the equalization of treatment in relation to the prostitute, the client and the "pimp." It is
+based on the premise that prostitutes are generally
+victims of economic, physical, and psychological
+coercion and choose prostitution in order to survive. Further, the Commission was concerned that
+90 percent of the street prostitutes are controlled by
+"pimps" who use a variety of coercive methods to
+maintain control. It seems clear that the legislature
+was not intending to depart from the precepts of the
+commonly understood meaning of "coercion" and
+to redefine it to include both free will decisions and
+compelled decisions.. The interpretation urged by
+the employees seems at variance with the stated
+goal of the legislature and the Gender Bias Commission.
+Since there is no cause of action provided for one
+who makes a reasoned and
+voluntary exercise of
+solely for financial rewards (assuming "coercion" is
+given the definition more consistent with its comancial gain. The employees herein assert that since
+they were offered "a greater financial reward" for
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Case 9:08-CV-80381-KAM Document 70-1 Entered on FLSD Docket 04/02/2009 Påff 8 8f 8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+This is a case of first impression based on a relatively new statute. As indicated, the legislative history of the new law suggests that the statute is designed to assist those who were forced to enter
+prostitution in order to keep a roof over their heads
+or food on their table. It does not appear to be intended to aid those who voluntarily enter the profession in order to drive a Mercedes instead of a
+. The limited record before us indicates that
+even beginning employees of the defendants (those
+who do not have an established clientele) bring in
+$700 a day and can keep 50% of their earnings.
+Based on a five-day work week, this would reflect
+an income of $87,500 a year even with a two week
+vacation. And the employees herein are not beginners.
+There is no indication that the legislature intended
+to legalize prostitution or to make it a respectable
+profession. It merely intended to place the prostitute on the same footing with the client and the
+"pimp." If a prostitute voluntarily makes the decision to participate, free from force, intimidation,
+or disadvantageous circumstance, then he or she is
+on the same footing as the other participants and
+should be treated the same.
+Although it might well serve a legitimate public
+purpose to permit the cannibalistic demise of such
+enterprises (and I am not unsympathetic with this
+view), that does not appear to be the policy behind
+the current statute. Therefore, in cases where coercion is not present (and this may or may not be
+one), the court should continue its tradition of not
+interceding in civil conflicts involving transactions
+that are either illegal or are against public policy.
+See Wechsler v. Novak, 157 Fla. 703, 26 So.2d 884
+V. Ratiner, 462 So.2d 1157, 1160
+(Fla. 3d DCA 1984), rev. denied, 472 So.2d 1182
+(Fla. 1985) ("An action may lie for interference with
+an unenforceable contract and even perhaps a voidable contract. No such cause of action lies for interrence with a contract void as against public polic
+ectoria yers ilegal personal injury soniciatio
+Page 8
+in the hospital] and which makes one who is a party
+thereto, as the appellant in the instant case, guilty of
+a criminal act for entering into such an agree- ment.")
+We are not asked in this proceeding to rule on the
+admissibility of the discovered information as evidence at the trial of this cause. We are to determine
+only if the information might lead to admissible
+evidence. Even *1083 though we deny the Writ ]
+suggest we certify the following question:
+DOES ONE, FREE FROM FORCE, INTIMIDA
+TION, OR DISADVANTAGEOUS CIRCUM-
+STANCE, WHO MAKES A REASONED DE-
+CISION TO BECOME OR REMAIN A PROSTI-
+TUTE OR TO SHARE THE PROCEEDS
+THEREOF BECAUSE OF A PROMISE OF A
+GREATER FINANCIAL REWARD HAVE A
+CAUSE OF ACTION UNDER SECTION
+796.09(1), FLORIDA STATUTES?
+ON MOTIONS FOR REHEARING, FOR CLARI-
+FICATION, FOR CERTIFICATION, AND FOR RE-
+HEARING EN BANC
+W. SHARP, Judge.
+Petitioners Balas and Shumate have filed motions
+for rehearing, clarification and certification.
+deny the motions in full except for one regard. We
+delete the sentence in the last full paragraph of the
+opinion which reads: "These other causes of action
+carry no such protection from discovery."
+Motion for Clarification GRANTED as stated
+above; Motion for Rehearing and Certification
+DENIED.
+HARRIS and THOMPSON, JJ., concur.
+Fla.App. 5 Dist.,1997.
+Balas v. Ruzzo
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla.
+L. Weekly D169
+END OF DOCUMENT
+@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e29fcc7a241fb8b87eb0a0d3346deb74b451523de6ee58a326acee8e15f93c0f.receipt.json b/vision-fixhub/court-01/e29fcc7a241fb8b87eb0a0d3346deb74b451523de6ee58a326acee8e15f93c0f.receipt.json
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diff --git a/vision-fixhub/court-01/e2c71df9d23c89359ae1e2bbb283b30e4793d24aa13dcfcdd13d3e918c74f45a.md b/vision-fixhub/court-01/e2c71df9d23c89359ae1e2bbb283b30e4793d24aa13dcfcdd13d3e918c74f45a.md
new file mode 100644
index 0000000000000000000000000000000000000000..3e7d2b02bb671d7e45dda0568b32453d443729f9
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@@ -0,0 +1,202 @@
+Case 9:08-cv-80994-KAM Document 85
+Entered on FLSD Docket 11/16/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+REPLY TO ROTHSTEIN ROSENFELDT ADLER'S P.A.'S
+RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER
+FOR THE PRESERVATION OF EVIDENCE [DE 405]
+(AS TO JANE DOE v. EPSTEIN CASE NO.: 08-CIV- 80893)
+Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned attorneys,
+hereby files his Reply to Rothstein Rosenfeldt Adler P.A.'s ("RRA") Response to
+Defendant's Emergency Motion for Order for the Preservation of Evidence [DE 405],
+and states:
+It now appears that the Honorable Herbert Stettin (Mr. Stettin") is the
+sole individual, as the Chief Restructuring Officer, in charge of RRA assets, including
+electronic and paper records. There also appears to be no objection to the entry of the
+preservation order consistent with his fiduciary/trustee duties for RRA, although certain
+documents may no longer exist within his possession.
+2.
+Par. 4 of the response reflects that some 40 plus boxes of documents were
+obtained by the Department of Justice from search warrants served on the offices of
+
+
+Case 9:08-cv-80994-KAM Document 85 Entered on FLSD Docket 11/16/2009 Page 2 of 5
+RRA; "it is believed that the Department of Justice also sequestered about (13) boxes of
+documents related to this [Epstein] case." In fact there are three Epstein cases which
+have been brought by the RRA firm, one being in federal court, two in state court. Mr.
+Stettin confirms Defendant's belief that there are serious ethical and potentially criminal
+issues that may impact Plaintiffs' ability to pursue their cases.
+3.
+Unfortunately, time is critical with regard to this case in that there are
+deadlines to Disclose Experts and Exchange Reports by October 29, 2009 (but Plaintiff
+has not seen her expert, has no report and only made herself available for the Defendant's
+exam on November 13, 2009), deposition discovery deadline is November 28, 2009 and
+a calendar call of February 19, 2010 for the February 22, 2010 trial docket. While the
+undersigned understands that Mr. Stettin may be working expeditiously to deal with
+critical and pressing needs of stabilizing the firm, a delay of 45 days for his deposition
+(which has been set in the state court case in the 15" Judicial Circuit Court, Palm Beach
+County, State of Florida, L.M. v. Epstein, Case No. 502008CA028051XXXXMB AB,
+not the case sub-judice) will place his deposition sometime during the first 15 days of
+January, after every pre-trial deadline has expired.
+4.
+If in fact there has been inappropriate and/or illegal conduct associated
+with the prosecution of this case by RRA or any of its attorneys or by the Plaintff herself,
+which might result in sanctions, dismissal or other remedy, Defendant Epstein will be
+severely prejudiced.
+WHEREFORE, Defendant Epstein request that the court's preservation order be
+made permanent, which does not seem inconsistent with Mr. Stettin's position as
+expressed by his lawyers but deny the relief sought for delaying the deposition unless the
+
+
+Case 9:08-cv-80994-KAM Document 85
+Entered on FLSD Docket 11/16/2009 Page 3 of 5
+court is disposed to modify the current scheduling deadlines and trial date that exist in
+this case.
+By: _
+Robert D. Critton, Jr. .
+Florida Bar #224162
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+ROBERT D./CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Brad
+1 Esq.
+Rothstein Rosenfeldt Adler
+
+
+Case 9:08-cv-80994-KAM Document 85 Entered on FLSD Docket 11/16/2009 Page 4 of 5
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 B, Room 101
+ichard Horace Willits, B
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10" Avenue North
+801-585-6833 Fax
+Suite 404
+Lake Worth, FL 33461
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Counsel for Plaintiff in Related Case No.
+Esq.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+
+
+Case 9:08-cv-80994-KAM Document 85 Entered on FLSD Docket 11/16/2009 Page 5 of 5
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Charles H. Lichtman, Esq.
+Isaac Marcushamer, Esq.
+Berger Singerman, P.A.
+350 East Broward Boulevard, 10" Floor
+954-525-9900
+954-523-2872 Fax
+clichtman@bergersingerman.com
+imarcushamer@bergersingerman.com
+Proposed Attorneys for Alleged Debtor
diff --git a/vision-fixhub/court-01/e2c71df9d23c89359ae1e2bbb283b30e4793d24aa13dcfcdd13d3e918c74f45a.receipt.json b/vision-fixhub/court-01/e2c71df9d23c89359ae1e2bbb283b30e4793d24aa13dcfcdd13d3e918c74f45a.receipt.json
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diff --git a/vision-fixhub/court-01/e2d5a848dfac022f25af82b27a42693dfb7ac9e746e15efd8b8dde5f3bc2cbcd.md b/vision-fixhub/court-01/e2d5a848dfac022f25af82b27a42693dfb7ac9e746e15efd8b8dde5f3bc2cbcd.md
new file mode 100644
index 0000000000000000000000000000000000000000..a6e9837f3ab949e4fea015a35b4387b75899ab82
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@@ -0,0 +1,38 @@
+Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 1 of 2
+CASE NO: 08-CV-80119-MARRA1
+Notice of Supplemental Authority on Plaintiff Jane Doe's Motion for an Order to Show
+Cause and for an Order to Compel and Incorporated Memorandum of Law [DE 138]
+
+
+
+Case 9:08-Cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2
+Beth Williamson
+From:
+Sent:
+To:
+Subject:
+Tama Beth Kudman [tama@tkudmanlaw.com]
+Monday, January 25, 2010 4:10 PM
+Beth Williamson
+Re: Regarding: Epstein - Depo of Jean Luc Brunel
+I have just been informed that my client will be out of the country until the end of March. Please ask Mr
+to call me to discuss this.
+Thank you
+Sent from my iPhone
+Tama Beth Kudman
+On Jan 25, 2010, at 3:22 PM, Beth Williamson <beth@pathtojustice.com> wrote:
+Dear Ms. Kudman:
+My name is Beth. I am assisting Brad
+in the Epstein matters. I just wanted to follow-up
+on the voicemail I left you. I understand your client Jean Luc Brunel will be available the first
+two weeks of February for deposition. Please provide me dates of availability as soon as
+Thank you,
+Beth Williamson, FRP
+Florida Registered Paralegal
+, Jaffe, Weissing,
+Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+954-524-2820
+954-524-2822 fax
+beth@pathtojustice.com
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.md b/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.md
new file mode 100644
index 0000000000000000000000000000000000000000..ed76e35e14929b3befe7f7558b108e8ee03af51e
--- /dev/null
+++ b/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.md
@@ -0,0 +1,97 @@
+Case 9:08-cv-80119-KAM Document 534-2 Entered on FLSD Docket 04/27/2010 Page 1 of 2
+1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/|
+4
+JANE DOE 2,
+Plaintiff,
+CERTIFIED
+COPY
+7
+8
+9
+D
+L
+2
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811,
+09-80591; 09-80656, 09-80802, 09-81092
+4
+5
+- -
+DEPOSITION TRANSCRIPT
+TAKEN AS TO JANE DOE #4
+OF RO
+7
+LOCATION:
+D
+DATE:
+TIME:
+REPORTED BY:
+Accurate Reporting & Video Service
+814 E. Silver Springs Blvd.
+Suite A
+Ocala, FL 34470
+Thursday, January 21, 2010
+1:18 p.m. - 4:46 p.m.
+Darlene G. Robisón, RPR
+Notary Public, state of Florida
+ACCURATE REPORTING & VIDEO SERVICE
+352-368-2545
+
+2
+
+
+Case 9:08-cv-80119-KAM Document 534-2 Entered on FLSD Docket 04/27/2010 Page 2 of 2
+145
+to meet with her.
+A.
+That's all I know.
+okay. As to what the conversation was, or what
+his report was, or what -- you have no idea, correct?
+A.
+correct.
+Q. Who was her
+-- did she have the same soccer
+coach at | University all four years?
+A.
+Yeah.
+Q.
+what was his or her name?
+A.
+Rocky -- he's got a crazy last name.
+I can't
+pronounce his last name. Arrouzzo (phonetic) or
+something like that.
+Q.
+Arrouzzo?
+A.
+Q.
+A.
+I can't really pronounce his last name.
+Is he still there now or at least --
+NO.
+He's gone now?
+Q.
+A.
+Yes.
+Q.
+Do you know where he went?
+A.
+No.
+Q.
+in high school?
+Did she have the same soccer coach when she was
+A.
+Yes.
+A.
+Who was that?
+Bill
+•
+ACCURATE REPORTING & VIDEO SERVICE
+352-368-2545
diff --git a/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.receipt.json b/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e39c4e04b8b1d9e57348c20f981d1d98b4d75a88
--- /dev/null
+++ b/vision-fixhub/court-01/e2d647cfe12631185fb43844b06f4c2aff529b71bf18113477de260f89d96994.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "2ad9d9d0f96cd6c9c7e59bd7eb02e0f53716714c8cfeb5e7eb2224bfd05bde73",
+  "output_sha256": "7a49ca251c6aa987ce832a47aa563d49fab168b446092f020a91c65fac3fca91",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.md b/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.md
new file mode 100644
index 0000000000000000000000000000000000000000..d274f98bf7cdce456c1e76d80f4674a64dd77e5f
--- /dev/null
+++ b/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.md
@@ -0,0 +1,321 @@
+Entered on FLSD Docket 07/31/2009 Page 1 of 11
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAJ
+JANE DOE NO. 2,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+1
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 2 of 11
+JANE DOE NO. 6,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+CASE NO.: 08-CV-80993-MARRA
+CASE NO.: 08-CV-80811-MARRAJ
+CASE NO.: 08-CV-80893-MARRAJ
+2
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 3 of 11
+DOE II,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-CV-80469-MARRA/
+CASE NO.: 09-CV-80591-MARRA/
+CASE NO.: 09-CV-80591-MARRA/
+PLAINTIFF'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE A REPLY TO
+DEFENDANT. JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFF,
+MOTION FOR PROTECTIVE ORDER
+REGARDING TREATMENT RECORDS FROM PARENT-CHILD CENTER, INC.., DR.
+SERGE THYS, RECORDS OF DOMINIQUE HYPPOLITE/SCHOOL DISTRICT OF
+PALM BEACH COUNTY, GOOD SAMARITAN HOSPITAL, ST. MARY'S HOSPITAL,
+FLORIDA ATLANTIC UNIVERSITY AND GLORIA C. HAKKARAINEN, M.D., WITH
+INCORPORATED MEMORANDUM OF LAW (DE 207), AND A RESPONSE TO
+DEFENDANT, JEFFREY EPSTEIN'S MOTION TO STRIKE C.M.A.'S CONDITIONAL
+NOTICE OF INTENT TO EXCLUSIVELY RELY ON STATUTORY DAMAGES
+PROVIDED BY 18 U.S.C. $2255 (DE 113), WITH INCORPORATED
+MEMORANDUM OF LAW
+3
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 4 of 11
+Plaintiff, C.M.A., by and through her undersigned attorneys, respectfully moves
+this Court for an extension of time in which to file a reply to D.E. 216, Defendant, Jeffrey
+Epstein's Response in Opposition to Plaintiff,
+Motion for
+Protective Order Regarding Treatment Records From Parent-Child Center, Inc., Dr.
+Serge Thys, Records of Dominique Hyppolite/School District of Palm Beach County,
+Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C.
+Hakkareinen, M.D., With Incorporated Memorandum of Law (DE 207), and a response
+to Defendant, Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional Notice of Intent to
+Exclusively Rely On Statutory Damages Provided by 18 U.S.C. §2255 (DE 113), With
+Incorporated Memorandum of Law. Local General Rule 7.1 A.1 and Rule 6, Fed. R.
+Civ. P. (2009). Plaintiff seeks an extension until August 7, 2009, to file her reply and
+response. As good cause in support of granting the motion, Plaintiff states:
+Defendant, Jeffrey Epstein's Response in Opposition to Plaintiff,
+Motion for Protective Order Regarding Treatment Records From
+Parent-Child Center, Inc., Dr. Serge Thys, Records of Dominique Hyppolite/School
+District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida
+Atlantic University and Gloria C. Hakkareinen, M.D., With Incorporated Memorandum of
+Law (DE 207), and Defendant, Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional
+Notice of Intent to Exclusively Rely On Statutory Damages Provided by 18 U.S.C.
+§2255 (DE 113), With Incorporated Memorandum of Law were jointly filed on July 21,
+2009. Pursuant to Rule 15(3), Fed.R.Civ.P., Plaintiff's reply and response would be due
+on July 31, 2009.
+Defendant's counsel is in agreement with the requested extension until
+August 7, 2009, for Plaintiff to file a reply to D.E. 216, Defendant, Jeffrey Epstein's
+Response in Opposition to Plaintiff, [
+Motion for Protective
+Order Regarding Treatment Records From Parent-Child Center, Inc., Dr. Serge Thys,
+Records of Dominique Hyppolite/School District of Palm Beach County, Good
+Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C.
+Hakkareinen, M.D., With Incorporated Memorandum of Law (DE 207), and a response
+4
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 5 of 11
+to Defendant, Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional Notice of Intent to
+Exclusively Rely On Statutory Damages Provided by 18 U.S.C. §2255 (DE 113), With
+Incorporated Memorandum of Law.
+3.
+The undersigned counsel has been in a five week trial which was
+concluded on July 27, 2009.
+4. The requested extension is fair and reasonable under the circumstances
+as it will provide time to allow Plaintiff, C.M.A., to fully and adequately prepare a reply to
+D.E. 216, Defendant, Jeffrey Epstein's Response in Opposition to Plaintiff,
+Motion for Protective Order Regarding Treatment Records From
+Parent-Child Center, Inc., Dr. Serge Thys, Records of Dominique Hyppolite/School
+District of Palm Beach County, Good Samaritan Hospital, St. Mary's Hospital, Florida
+Atlantic University and Gloria C. Hakkareinen, M.D., With Incorporated Memorandum of
+Law (DE 207), and a response to Defendant, Jeffrey Epstein's Motion to Strike C.M.A.'s
+Conditional Notice of Intent to Exclusively Rely On Statutory Damages Provided by 18
+U.S.C. §2255 (DE 113), With Incorporated Memorandum of Law.
+WHEREFORE, Plaintiff, C.M.A., requests that this Court enter an order granting
+Plaintiff an extension until August 7, 2009, to file a reply to D.E. 216, Defendant, Jeffrey
+Epstein's Response in Opposition to Plaintiff,
+Motion for
+Protective Order Regarding Treatment Records From Parent-Child Center, Inc., Dr.
+Serge Thys, Records of Dominique Hyppolite/School District of Palm Beach County,
+Good Samaritan Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C.
+Hakkareinen, M.D., With Incorporated Memorandum of Law (DE 207), and a response
+to Defendant, Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional Notice of Intent to
+Exclusively Rely On Statutory Damages Provided by 18 U.S.C. §2255 (DE 113), With
+Incorporated Memorandum of Law.
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 6 of 11
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Counsel for the movant conferred via telephone with counsel for the Defendant
+and counsel for the Defendant is in agreement with requested extension until August 7,
+2009, for Plaintiff to file a reply to to D.E. 216, Defendant, Jeffrey Epstein's Response in
+Opposition to Plaintiff,
+Motion for Protective Order
+Regarding Treatment Records From Parent-Child Center, Inc. Dr. Serge Thys, Records
+of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan
+Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkareinen,
+M.D.., With Incorporated Memorandum of Law (DE 207), and a response to Defendant,
+Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional Notice of Intent to Exclusively
+Rely On Statutory Damages Provided by 18 U.S.C. §2255 (DE 113), With Incorporated
+Memorandum of Law.
+s/ Jack P.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on the 31th day of July, 2009, I electronically filed the
+foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice
+of electronic filing to all counsel of record on the attached service list.
+Is/Jack P.
+Jack Scarola
+Florida Bar No.: 169440
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+(561) 383-9424
+Attorneys for Plainti, C.M24.
+6
+
+
+Entered on FLSD Docket 07/31/2009 Page 7 of 11
+COUNSEL LIST
+Richard H. Willits, Esquire
+Richard H. Willits, P.A
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Phone:
+(561) 582-7600
+Fax:
+(561) 588-8819
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+(561) 842-2820
+(561) 844-6929
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Phone:
+(561) 863-9100
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Phone:
+(561) 202-6360
+Fax:
+(561) 828-0983
+7
+
+
+Entered on FLSD Docket 07/31/2009 Page 8 of 11
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 9 of 11
+JANE DOE NO. 6,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+CASE NO.: 08-CV-80993-MARRAJ
+CASE NO.: 08-CV-80811-MARRA/
+CASE NO.: 08-CV-80893-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 10 of 11
+DOE II,
+CASE NO.: 09-CV-80469-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 09-CV-80591-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+AGREED ORDER ON PLAINTIFF'S MOTION FOR EXTENSION OF TIME IN WHICH
+TO FILE A REPLY TO DEFENDANT. JEFFREY EPSTEIN'S RESPONSE IN
+OPPOSITION TO PLAINTIFF,
+MOTION FOR
+PROTECTIVE ORDER REGARDING TREATMENT RECORDS FROM PARENT-
+CHILD CENTER, INC., DR. SERGE THYS, RECORDS OF DOMINIQUE
+HYPPOLITE/SCHOOL DISTRICT OF PALM BEACH COUNTY, GOOD SAMARITAN
+HOSPITAL, ST. MARY'S HOSPITAL, FLORIDA ATLANTIC UNIVERSITY AND
+GLORIA C. HAKKARAINEN, M.D., WITH INCORPORATED MEMORANDUM OF
+LAW (DE 207), AND A RESPONSE TO DEFENDANT, JEFFREY EPSTEIN'S
+MOTION TO STRIKE C.M.A.'S CONDITIONAL NOTICE OF INTENT TO
+EXCLUSIVELY RELY ON STATUTORY DAMAGES PROVIDED BY 18 U.S.C. §2255
+(DE 113), WITH INCORPORATED MEMORANDUM OF LAW
+This matter came before the Court upon the Plaintiff's Motion for Extension of
+Time in Which to File a reply to D.E. 216, Defendant, Jeffrey Epstein's Response in
+
+
+Case 9:08-cv-80119-KAM Document 234 Entered on FLSD Docket 07/31/2009 Page 11 of 11
+Opposition to Plaintiff,
+Motion for Protective Order
+Regarding Treatment Records From Parent-Child Center, Inc., Dr. Serge Thys, Records
+of Dominique Hyppolite/School District of Palm Beach County, Good Samaritan
+Hospital, St. Mary's Hospital, Florida Atlantic University and Gloria C. Hakkareinen,
+M.D., With Incorporated Memorandum of Law (DE 207), and a response to Defendant,
+Jeffrey Epstein's Motion to Strike C.M.A.'s Conditional Notice of Intent to Exclusively
+Rely On Statutory Damages Provided by 18 U.S.C. §2255 (DE 113), With Incorporated
+Memorandum of Law. Having considered the motion and the agreement with the
+requested extension, it is hereby ORDERED and ADJUDGED that:
+Plaintiff's motion is hereby granted. Plaintiff has until August 7, 2009, to file a
+reply to D.E. 216, Defendant, Jeffrey Epstein's Response in Opposition to Plaintiff,
+Motion for Protective Order Regarding Treatment Records
+From Parent-Child Center, Inc., Dr. Serge Thys, Records of Dominique
+Hyppolite/School District of Palm Beach County, Good Samaritan Hospital, St. Mary's
+Hospital, Florida Atlantic University and Gloria C. Hakkareinen, M.D., With Incorporated
+Memorandum of Law (DE 207), and a response to Defendant, Jeffrey Epstein's Motion
+to Strike C.M.A.'s Conditional Notice of Intent to Exclusively Rely On Statutory
+Damages Provided by 18 U.S.C. §2255 (DE 113), With Incorporated Memorandum of
+Law.
+DONE AND ORDERED this.
+day of
+- 2009.
+KENNETH A. MARRA
+United States District Judge
+Copies to all Counsel of Record
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.receipt.json b/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..69da6592663beb9370aa303ec52909320e9bde35
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+++ b/vision-fixhub/court-01/e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "e3130d97c7299c7ff261e841353471a9e024cb5572f8a80e96f3a209cf1f7e06",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "6c1a28d356039ec3e983bd1a46f00a645408c39704a553a7afb7bfcf203ce1a3",
+  "output_sha256": "7460eef9da2f5deffe9dddfaa557b32556c6a3d3caa16edefafc275d8ecb03a9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.md b/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.md
new file mode 100644
index 0000000000000000000000000000000000000000..ac9447507a3bcb43af0bb400c11eaaaf2ebbbc6d
--- /dev/null
+++ b/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.md
@@ -0,0 +1,114 @@
+Filing # 201184781 E-Filed 06/24/2024 01:09:07 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+VS.
+SHARON BOCK, as Clerk and Comptroller
+of Palm Beach County, Florida,
+Defendant.
+/
+UNOPPOSED MOTION FOR LIMITED INTERVENTION
+Case No. 50-2019-CA-014681-AG
+COPY
+American Broadcasting Companies, Inc.; Bloomberg L.P., the publisher of
+Bloomberg News; Cable News Network, Inc.; CMG Media Corporation stations
+WFTV/WRDQ (Orlando) and WJAX/WFOX (Jacksonville); Court TV Media, LLC;
+& Company, Inc.; Gray Media Group, Inc. stations WCJB (Gainesville),
+WCTV (Tallahassee-Thomasville), WFLX (West Pam Beach-Ft. Pierce), WJHG-TV
+(Panama City) and WWSB (Tampa-St. Petersburg (Sarasota)); NBCUniversal Media,
+LLC; The New York Times Company; Orlando Sentinel Media Group; Scripps Media,
+Inc. and its stations WPTV-TV (West Palm Beach), WFTS-TV (Tampa), WFTX-TV (Ft.
+Myers-Naples), WSFL-TV (Miami), and WTXL-TV (Tallahassee); Sun Sentinel Media
+Group; Telemundo Network Group LLC; and Univision Networks & Studios, Inc.
+(collectively, the "Media Intervenors") move to intervene in this action for the limited
+purpose of asserting their right of access, pursuant to Section 905.27, Florida Statutes, to
+any released grand jury materials involving Jeffrey Epstein, and state as follows:
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 06/24/2024 01:09:07 PM
+
+
+1.
+The Media Intervenors are national, regional and local news and media
+organizations that publish and broadcast information throughout the United States,
+including Florida. Each of the Media Intervenors has reported on the controversies
+surrounding Mr. Epstein and employ public and court records as important newsgathering
+sources.
+2.
+The Plaintiff in this case, The Palm Beach Post, has sought to obtain grand
+jury materials relating to Mr. Epstein. The controversy surrounding Mr, Epstein, the
+criminal investigation into his alleged sex trafficking of minors, and the resulting plea
+deal, are well known to the Court.
+3.
+On February 29, 2024, the Court entered an order ruling that under the
+current iteration of Section 905.27, Florida Statutés, releasing the grand jury materials
+would not further the interests of justice. [DIN 184] Yet the court explained that, pursuant
+to an amendment of Section 905.27 slated to take effect on July 1, 2024, the Court would
+entertain a motion for reconsideration once the statute changes.
+On June 12, 2024, The Palm Beach Post ("Post") filed a Motion for
+Reconsideration of the Trial Court's February 29, 2024 Order. [DIN 208] The motion
+explained that the
+dments to Section 905.27 were intended to remove all prior
+statutory hurdles tó disclosure of the Epstein grand jury materials and that access to the
+grand jury materials serves the public interest.
+5.
+Like the Post, Media Intervenors fulfill the requirements of Section
+905.27(2)(c), as amended. They are requesting disclosure of grand jury materials as
+members of the media and, as explained in the Post's motion, all statutory conditions for
+release have been met: Mr. Epstein was the target of grand jury testimony relating to
+2
+
+
+criminal sexual activities between and adult and a minor, Mr. Epstein is deceased, the
+Fourth District Court of Appeals ordered release of the grand jury materials for an in
+camera review (which has been completed), and the current State Attorney was a party to
+this litigation and ultimately adopted a neutral position concerning disclosure.
+As such, Media Intervenors seek to intervene in this matter for the limited
+purpose of procuring access to any materials that, upon reconsideration, the Court orders
+to be disclosed
+7.
+The Media Intervenors possess standing to intervene in this matter, see
+Miami Herald Publ'g Co. v. Melntosh, 340 So. 2d 904, 908 (Fla. 1976), for the purpose
+of "imparting a more complete understanding to the public of the judicial system." Miami
+Herald Publishing Co. v.
+426 So.2d 1, 6 (Fla. 1983). See also WESH Television,
+Inc. v. Freeman, 691 So. 2d 532, 535 (Fla. 5th DCA 1997) (media must be permitted to
+intervene and be heard on motion seeking access to public records); News-Press Publ'g
+Co. v. State, 345 so. 2d 865, 866 (Fla. 2d DCA 1977) (media permitted to intervene with
+respect to order that had the "practical effect of making it more difficult for the press to
+obtain information about the case which it may wish to publish").'
+The Media Intervenors communicated with counsel for both Plaintiff and
+Defendant, neither of whom oppose the relief sought in this motion.
+' By an agreed order dated February 28, 2024, the Court permitted the Associated Press
+to intervene in this action. [DIN 183] The Court similarly entered an agreed order on
+March 5, 2024, granting the McClatchy Company, LL's motion to intervene. [DIN 187]
+3
+
+
+WHEREFORE, the Media Intervenors seek intervention in this case for the
+limited purpose of obtaining access to the grand jury materials related to Mr. Epstein.
+Respectfully submitted,
+SHULLMAN FUGATE PLLC
+/s/ Rachel E. Fugate
+Rachel E. Fugate
+Florida Bar No. 0144029
+rfugate@shullmanfugate.com
+Deanna K. Shullman
+Florida Bar No. 514462
+dshullman@shullmanfugate.com
+Minch Minchin
+Florida Bar No. 1015950
+mminchin@shullmanfugate.com
+2101 Vista Parkway Suite 4006
+West Palm Beach, Florida 33411
+Tel: (813) 935-5098
+Attorneys for the Media Intervenors
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been
+furnished via the Florida Courts E-Filing Portal this 24* day of June 2024, which will
+provide service to all counsel of record.
+NOT
+Is/ Rachel E. Fugate
+Attorney for the Media Intervenors
+4
diff --git a/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.receipt.json b/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a780ea7e08e90bb0c0f06625270520bd877d80c1
--- /dev/null
+++ b/vision-fixhub/court-01/e32a1e422710434e35146592a5ba6774029c039b7c31c78a91ed76d034870dcb.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "7cdc850a917b50731627c2b0f597ba2839f0f0f347fee836429d457f272872dc",
+  "output_sha256": "36b303b059320ed6b59da327e486bb49b86be84327ba07e0f8d33c5316772f5c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e33f942b0fde46e9452429e902d1eef88bab38eba0b6e3e993da3970a924c5bb.md b/vision-fixhub/court-01/e33f942b0fde46e9452429e902d1eef88bab38eba0b6e3e993da3970a924c5bb.md
new file mode 100644
index 0000000000000000000000000000000000000000..e28ae51c03315f1865d14064ec9dec2a58a1d46d
--- /dev/null
+++ b/vision-fixhub/court-01/e33f942b0fde46e9452429e902d1eef88bab38eba0b6e3e993da3970a924c5bb.md
@@ -0,0 +1,127 @@
+Case 9:08-cv-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S REPLY MEMORANDUM IN SUPPORT OF MOTION FOR
+PROTECTIVE ORDER AGAINST PIECEMEAL DEPOSITIONS, AND
+MOTION TO CONSOLIDATE FOR PURPOSES OF DISCOVERY
+Plaintiff, by and through undersigned counsel, files this Reply Memorandum In Support of
+Motion for Protective Order Against Piecemeal Depositions, and Motion to Consolidate for Purposes
+of Discovery, as follows:
+DEFENDANT FAILS TO SET FORTH ANY PREJUDICE
+OR CONFUSION THAT WOULD MILITATE AGAINST
+CONSOLIDATING THESE CASES FOR PURPOSES OF DISCOVERY
+In response to Plaintiffs' Motion to Consolidate, Defendant asserts that not all common
+issues of fact are present and the parties are not identical. These are not reasons to deny
+consolidation, particularly the limited consolidation for purposes of discovery sought here.' Rule
+42(a), Fed.R.Civ.P., requires only a common question of law or fact, and there need not be an
+identity of parties. Defendant also asserts without support or explanation that "confusion will result
+and motions in limine will undoubtedly be filed...." In Ramsay v. Broward County Sheriff's
+Office, 303 Fed. Appx. 761, 2008 WL 5237162 (11th Cir. 2008), the Court affirmed the District
+' In a case relied upon by Defendant, Kelly v. Kelly, 911 F.Supp. 66 (N.D.N.Y. 1996), the issue was
+consolidation for purposes of joint trial, so that case is inapposite here.
+- 1-
+
+
+Case 9:08-cv-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 2 of 6
+Court's consolidation of two employment discrimination actions, noting that the party opposing
+consolidation "has failed to show that the district court abused its discretion by consolidating the two
+actions insofar as she has introduced no evidence establishing confusion or prejudice." Id. at *3 &
+n. 5.
+The risk of confusion or prejudice is generally more likely to arise when there is
+consolidation for purposes of trial, which is not being sought in the present cases at this time. See
+Hendrix v. Raybestos - Manhattan, Inc., 776 F.2d 1492, 1495 (11th Cir. 1985). Here, the common
+and overlapping motion practice in these cases attests to the efficiencies to be gained by
+consolidating for purposes of discovery. Additionally, these cases are on the same or similar
+discovery tracks, so there would be no prejudice or confusion arising from the cases being at
+different stages of litigation. See Borough of Olyphant v. PPL Corp., 153 Fed. Appx. 80, 2005 WL
+2673489 (3d Cir. 2005) (a case cited by Defendant, the Court noted that it has discretion to deny a
+motion to consolidate "if it would cause delay in one of the cases or if one of the cases is further
+into discovery than the other case"); see also
+Motor Credit Co. v. Chiorazzo, 529 F.Supp. 2d
+535, 542 (D.N.J. 2008) (denying consolidation of two actions because discovery was nearly
+complete in one while the other was in its preliminary stages).
+It is within this Court's broad discretion to consolidate: "[Rule 42(a)] is a codification of a
+trial court's inherent managerial power to control disposition of the causes on its docket with
+economy of time and effort for itself, for counsel, and for litigants.' " Hendrix, 776 F.2d at 1495
+(citation omitted). Given the nature of these cases, the common facts alleged and the common issues
+of law, consolidation for purposes of discovery would be in the interests of judicial economy and
+efficiency. Defendant fails to set forth anything to the contrary.
+- 2-
+
+
+Case 9:08-cV-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 3 of 6
+II. THERE SHOULD BE ONLY ONE DEPOSITION FOR EACH PLAINTIFF
+In response to Plaintiff's Motion for Protective Order to limit Defendant to a single
+deposition of each Plaintiff, Defendant fails to set forth any reason why it needs to take two separate
+depositions of each Plaintiff. Defendant asserts that it has the right to take both party depositions
+and witness depositions, which Plaintiff does not dispute. Where the same person is both party and
+witness in related cases, however, it makes eminent sense that there should be only one deposition of
+that person. The Court's authority to grant a protective order in this regard falls squarely within
+Rule 26(c), which allows such an order to be issued to protect a party from annoyance,
+embarrassment, oppression, or undue burden or expense. The unnecessary burden and harassment
+that would arise from more than one deposition of a plaintiff/victim in these cases is patent and
+obvious, particularly since these cases concern sensitive fact issues of sex with minors.
+In opposition to the Motion, Defendant makes a vague reference to "proper preparation", but
+fails to articulate how its preparation will be prejudiced or otherwise adversely affected by a single
+deposition of each Plaintiff.? To the contrary, separate depositions would create an artificial,
+awkward dividing line between which questions are of the deponent as a witness and which are of
+the deponent as a party, likely giving rise to unnecessary disputes and motion practice. Given the
+common and overlapping facts in these cases, there is no reason why a party witness cannot be
+questioned in a single sitting on all facts pertinent to Epstein. A protective order is therefore
+warranted in these cases so that each Plaintiff has her deposition taken only once.
+Conclusion
+" Defendant offers as a "compromise" to limit each Plaintiff to two depositions. This would not
+sufficiently ameliorate the problem and concern raised in the Motion. Defendant fails to proffer any
+reason why it is necessary to take two separate depositions of the same witness.
+- 3-
+
+
+Case 9:08-cv-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 4 of 6
+Based on the foregoing, and for the reasons set forth in Plaintiff's Motion for Protective
+Order, Motion to Quash Subpoena, and Motion to Consolidate for purposes of discovery, Plaintiff
+respectfully requests an Order (i) consolidating these cases for purposes of discovery; (ii) limiting
+the Defendant to a single deposition of each Plaintiff; and (iii) such other and further relief this
+Court deems just and proper.
+Dated: April 27, 2009
+Respectfully submitted,
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 4 -
+
+
+Case 9:08-cV-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 5 of 6
+CERTIFICATE OF SERVICE
+I hereby certify that on April 27 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+s/ Stuart S. Mermelstein
+- 5-
+
+
+Case 9:08-cV-80380-KAM Document 92 Entered on FLSD Docket 04/27/2009 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+s/ Stuart S. Mermelstein
+- 6-
diff --git a/vision-fixhub/court-01/e33f942b0fde46e9452429e902d1eef88bab38eba0b6e3e993da3970a924c5bb.receipt.json b/vision-fixhub/court-01/e33f942b0fde46e9452429e902d1eef88bab38eba0b6e3e993da3970a924c5bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ce9d68035b9d5c3ff8acde6477f140c365f7c8b9
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+}
diff --git a/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.md b/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.md
new file mode 100644
index 0000000000000000000000000000000000000000..0ae65953e3a4b771cf01d6092519f70ba7829271
--- /dev/null
+++ b/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.md
@@ -0,0 +1,57 @@
+Case 1:20-cv-00484-JGK-DCF Document 5-2 Filed 01/17/20 Page 1 of 1
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+=
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+JANE DOE,
+Plaintiff,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Case No. 1:20-cv-00484
+[PROPOSED] ORDER ON
+PLAINTIFF'S MOTION FOR LEAVE
+TO PROCEED UNDER
+PSEUDONYM
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, Califomia 90025
+310.477.1700 phone - 310.477.1699 fax
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+The Court, having reviewed the Plaintiff's Motion to Proceed by Pseudonym, the
+Plaintiff's memorandum of law in support of her motion and any opposition thereto, the pleadings
+and papers filed herein, and upon any such other matters as may be presented to the Court at the
+time of the hearing on this motion, if any, hereby GRANTS the Plaintiff's Motion to Proceed by
+Pseudonym as follows:
+Jane Doe is permitted to proceed by pseudonym in the above-captioned matter.
+DATED:
+United States District Judge
+1
diff --git a/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.receipt.json b/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..278019e1a9956220483a815b251a9c19826ceb23
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+++ b/vision-fixhub/court-01/e344df1c58a390992686a8a62d403dc161430243d2ce08f1120b05719b2dc34f.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.md b/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.md
new file mode 100644
index 0000000000000000000000000000000000000000..8d5f0350fcb7d611522aabb8f11b8b84f008d687
--- /dev/null
+++ b/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.md
@@ -0,0 +1,26 @@
+Case 9:08-cv-80736-KAM Document 175-1 Entered on FLSD Docket 05/23/2012 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER GRANTING LIMITED INTERVENORS JEFFREY EPSTEIN AND
+BLACK, WEINBERG & LEFKOWITZ'S UNOPPOSED MOTION For
+EXTENSION OF TIME TO RESPOND TO PLAINTIFFS'
+NOTICE OF SUPPLEMENTAL AUTHORITY
+THIS CAUSE comes before the Court on Limited Intervenors Jeffrey Epstein and Black,
+Weinberg & Lefkowitz's Unopposed Motion For Extension Of Time To Respond To Plaintiffs'
+Notice Of Supplemental Authority, filed May 23, 2012. It is
+ORDERED AND ADJUDGED that the Motion is GRANTED. The limited intervenors may
+file a response or objection to Plaintiffs' Notice of Supplemental Authority [DE 173] on or before
+June 8, 2012.
+DONE AND ORDERED in
+at Palm Beach County, Florida, on May
+_ 2012.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies to:
+All counsel of record via CM/ECF
diff --git a/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.receipt.json b/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4d50c8416e7b2c4e5b42af61007535131b09fd35
--- /dev/null
+++ b/vision-fixhub/court-01/e35afaed68c53fa9dbceb40bd24fc08a5503e7d0cda7972069b2cb70e36f7a8f.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "eeffd3c5ca08cc72ba351d5f4efff17246fc350dbb0b31e6e9bd395bd4c5de09",
+  "output_sha256": "f3a525077945a9ee67b6c557d16b5a914738b2b2ef05db783c34c8fe683d3f3b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e36135287cf8a35cb7440aab2382975c7ca53420a1abd1b30d6b16095d9d1fa6.md b/vision-fixhub/court-01/e36135287cf8a35cb7440aab2382975c7ca53420a1abd1b30d6b16095d9d1fa6.md
new file mode 100644
index 0000000000000000000000000000000000000000..3c9562ffd9b47aef52c9e46d57d965a5810c7fe9
--- /dev/null
+++ b/vision-fixhub/court-01/e36135287cf8a35cb7440aab2382975c7ca53420a1abd1b30d6b16095d9d1fa6.md
@@ -0,0 +1,283 @@
+Case 9:08-cv-80119-KAM Document 536
+Entered on FLSD Docket 04/29/2010. Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+EPSTEIN'S MOTION FOR PROTECTIVE ORDER
+REGARDING THE DEPOSITION OF STORY COWLES
+AND INCORPORATED MEMORANDUM OF LAW
+Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of
+Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and
+states:
+1.
+Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles
+for May 12, 2010 (Notice and Subpoena attached as Exhibit A).
+2.
+Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on
+July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowles was hired
+as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case
+while he was serving his jail sentence at the Palm Beach County Stockade. Mr. Cowles was
+employed to be, among other things, a conduit for information between the attorneys (criminal
+
+
+Case 9:08-cV-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 2 of 8
+and civil) and Mr. Epstein. See Affidavit of Jack Goldberger attached as Exhibit B and affidavit
+of Story Cowles attached as Exhibit C.
+3.
+Mr. Goldberger, as well as Mr. Epstein's civil attorneys, have used Mr. Cowles to
+transmit attorney-client and work product information and documents to Mr. Epstein with the
+clear understating and belief that the communications to Mr. Epstein from his attorneys and staff,
+and from Mr. Epstein to his attorneys and staff, would be protected by the attorney-client and
+work product privileges. See Exhibit B; see also Affidavit of Robert D. Critton, Jr. attached as
+Exhibit D:
+4.
+Mr. Cowles did not know, nor did he have any knowledge of, Mr. Epstein prior to
+his employment with Mr. Goldberger. See Exhibit C.
+Mr. Cowles did not know, nor did he have any knowledge of,
+to his employment with Mi. Goldberger.
+See Exhibit C.
+prior
+6.
+While Mr. Cowles and
+have dated and continue to date, they
+specifically have not and do not discuss the facts of the cases against her and Mr. Epstein. See
+
+7.
+Moreover, all plaintiffs who have sued Mr. Epstein have based their claims on a
+time period prior to October 2005 (or even earlier). As Mr. Cowles was not hired by Mr.
+Goldberger until July 2008, he has no personal knowledge of any relevant information. See
+
+8.
+Mr. Epstein has never discussed the claims asserted against him with Mr. Cowles
+other than when his attorneys were present or when he was transmitting information between
+Epstein and his attorneys. See Exhibit C.
+2
+
+
+Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8
+9.
+In October, 2009, Mr. Cowles was subpoenaed for a deposition in the companion
+state court case B.B. v. Epstein for the purpose of establishing the address of
+Counsel for Jane Doe was also seeking to depose Mr. Cowles. See 10/07/09 Correspondence
+attached as Exhibit E. Thereafter, counsel for Jane Doe, counsel for B.B. and Epstein's counsel
+agreed on a conference call that Mr. Cowles would not be deposed if
+was made
+available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike
+attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While
+counsel for Jane Doe did not confirm this agreement in writing, he represented same in the
+aforementioned telephone conference. See Exhibit F. Now counsel for Jane Doe appears to be
+going back on his word and reneging on his agreement by attempting to depose Mr. Cowles.
+The Court should not condone this type of duplicitous conduct and hold counsel for Jane Doe to
+his word.
+10.
+Rule 26(c), Federal Rules of Civil Procedure, provides that, "[a] party or any
+person from whom discovery is sought may move for a protective order in the court where the
+action is pending...
+The court may, for good cause, issue an order to protect a party or person
+from annoyance, embarrassment, oppression, or undue burden or expense, including one or more
+of the following: (A) forbidding the disclosure or discovery."
+11. Moreover, "a party may not discover documents and tangible things that are
+prepared in anticipation of litigation or for trial by or for another party or its representative
+(including the other party's attorney ... or agent)." See Fed. R. Civ. P. 26(b)(3)(A) (emphasis
+added). The court must also "protect against disclosure of the mental impressions, conclusions,
+opinions,
+or legal theories of a party's attorney or other representative concerning the
+litigation. See Fed. R. Civ. P. 26(b)(3)(B) (emphasis added). Rule 26 makes clear that the work
+3
+
+
+Case 9:08-cV-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010
+1. Page 4 of 8
+product privilege extends to paralegals, investigators and legal assistants - agents or
+representatives of a party's attorney.
+12. The attorney-client privilege also extends to subordinates of a party's attorney.
+See Seebeck v. General Motors Corp., 1996 WL 742914 (N.D. Ga. 1996). In Seebeck, the court
+noted that to invoke the attorney client privilege:
+(I) the asserted holder of the privilege is ... a client; (2) the person
+to whom the communication was made (a) is a member of a bar of
+a court, or his subordinate and (b) in connection with this
+communication is acting as a lawyer; (3) the communication
+relates to a fact of which the attorney was informed (a) by his
+client (b) without the presence of strangers (c) for the purpose of
+securing primarily either (i) an opinion on law or (ii) legal services
+or (iii) assistant in some legal proceedings, and not (d) for the
+purpose of committing a crime or tort; and (4) the privilege has
+been (a) claimed and (b) not waived by the client.
+Id. at *2 (emphasis added), citing U.S. v. Noriega, 917 F.2d 1543, 1550 (11th Cir. 1990).
+13.
+In Seeback, the court granted a protective order where a party sought to discover
+information from a party's investigator. The investigator submitted an affidavit (substantially
+similar to the affidavits submitted in support of the instant motion) in which he attested that he
+was hired by GM with the understanding that communications would be protected by the
+attorney-client privilege, that he was retained to perform work in anticipation of litigation, and
+that the identities of persons interviewed by the him and legal assistants reflected attorney-client
+communications and work product information. 1996 WL 742914 at *2. The court agreed and
+entered a protective order, concluding that "It]he nature of the information set forth in the
+affidavit is sufficiently compressive to establish the privileged nature of the material sought." Id.
+at *3. See also S.E.C. v. World-Wide Coin Investments, Ltd., 92 F.R.D. 65, 66-67 (N.D. Ga.
+1981) (denying defendant's motion to compel an investigator to produce documents and answer
+deposition questions, finding that the documents prepared by the investigator were protected by
+4
+
+
+Çase 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 5 of 8
+the work product privilege and that any communications between the investigator and attorneys
+and staff were protected by the attorney-client privilege); Huet v. Tromp, 912 So. 2d 336 (Fla.
+Sth DCA 2005) (quashing trial court's discovery order denying motion for protective order to
+prohibit deposition of defendant's investigators); Quarles & Brady, LLP v. Birdsall, 802 So. 2d
+1205, 1206 (Fla. 2d DCA 2002) (quashing order compelling law firm secretary to answer
+deposition questions regarding her conversations with her supervising partner as the questions
+invaded the attorney-client privilege).
+14.
+Regarding the scope of discovery, Judge Linnea
+noted in her October 28,
+2009 Omnibus Order (DE #377), "Iw]hile the scope of discovery is broad, it is not without
+limits. Washington v.
+& Williamson Tobacco, 959 F.2d 1566, 1570 (11th Cir. 1992).
+Indeed the 2000 Amendment to Rule 26 has effectively limited the scope of discoverable
+information to those matters which are relevant to a claim or defense in the lawsuit. Dellacas,
+LLC v. John Moriarty & Ass. of Fla., Inc., 2007 WL 4117261 at*3 (S.D. Fla. 2007). Courts
+have long held that "[w]hile the standard of relevancy [in discovery] is a liberal one, it is not so
+liberal as to allow a party to roam in the shadow zones of relevancy and to explore matter which
+does not presently appear germane on the theory that it might conceivably become so.' Food
+Lion, Inc. v. United Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A.
+D.C. 1997) (string cite omitted)." (Emphasis added).
+15.
+Also,
+in
+the related
+matter
+of Epstein V. Rothstein, Case No.
+502009CA040800XXXXMBAG, Judge
+entered an order on April 19, 2010 (attached as
+Exhibit H), in which he granted a protective order regarding the depositions of Michael Fisten
+and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler
+("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion.
+5
+
+
+Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010. Page 6 of 8
+16.
+While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their
+knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order
+prohibiting their depositions until Epstein can "establish the relevance and discoverability of the
+information." See Exhibit H
+17.
+Yet unlike Fisten and Fandrey who likely have non-privileged information
+regarding Scott Rothstein's massive fraud and admitted criminal activity, any information that
+Mr. Cowles might have is protected by the attorney-client and work product privileges.
+18.
+As a practical matter, if the Court permits the deposition of Mr. Cowles, what is to
+prevent Jane Doe and other plaintiffs from attempting to depose other paralegals, secretaries,
+legal assistants, investigators or even attorneys employed by Epstein? As Judge
+noted,
+"while the scope of discovery is broad, it is not without limits." See DE #377. Jane Doe is
+clearly attempting to exceed the limits of permissible discovery in attempting to depose Mr.
+Cowles.
+19.
+Given the foregoing, it appears Jane Doe is attempting to depose Mr. Cowles for
+the sole purpose of harassing and intimidating him as he clearly has no discoverable information
+to which Jane Doe is entitled.
+20.
+Accordingly, the Court should enter a protective order to prohibit his deposition
+as he cannot possibly provide any information that is not protected by the attorney-client and
+work product privileges.
+WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court enter a protective
+order prohibiting the deposition of Story Cowles and grant any additional relief the Court deems
+just and proper.
+By: /s/ Jack Alan Goldberger
+Florida Bar No. 262013
+6
+
+
+Çase 9:08-cV-80119-KAM . Document 536 Entered on FLSD Docket 04/29/2010 Page 7 of 8
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this _
+day of April, 2010:
+Respectfully submitted,
+By: Is Jack Alan Goldberger. _
+Jack Alan Goldberger, Esq.
+Florida Bar No. 262013
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRAJ
+Stuart S. Mermelstein, Esq-
+Brad
+Adam D. Horowitz, Esq.
+Fistos &
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintifjs
+Esq.
+1, Jaffe, Weissing,
+Lehman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232,
+08-80380, 08-80381,
+08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Salt Lake City, UT 84112
+801-585-5202
+
+
+Çase 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 8 of 8
+Podhurst Orseck, P.A
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+Esq.
+| Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-
+80469
+8
diff --git a/vision-fixhub/court-01/e36135287cf8a35cb7440aab2382975c7ca53420a1abd1b30d6b16095d9d1fa6.receipt.json b/vision-fixhub/court-01/e36135287cf8a35cb7440aab2382975c7ca53420a1abd1b30d6b16095d9d1fa6.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/e37ff08dda5a331a67165b29d5681b1bdca237c6d90f6f6108346d4ebee77ba7.md b/vision-fixhub/court-01/e37ff08dda5a331a67165b29d5681b1bdca237c6d90f6f6108346d4ebee77ba7.md
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@@ -0,0 +1,33 @@
+Case 1:19-cv-08673-KPF-DCF Document 64
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman.com
+Filed 04/30/20 Page 1 of 1
+troutman"
+sanders
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+April 30, 2020
+VIA ELECTRONIC COURT FILING
+Hon. Katherine Polk Failla
+Thurgood Marshall
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re:
+Jane Doe, 1:19-cv-08673 (KPF) (DCF)
+Dear Judge Failla:
+We represent Defendants Darren _. Indyke and Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write to
+further supplement the Co-Executors' pending motion to dismiss (ECF Doc. 46) with the
+enclosed copy of the Opinion & Order entered today by The Hon. Paul A. Engelmayer in
+another personal injury action against the Co-Executors (Jane Doe 15 v. Darren |. Indyke and
+Richard D. Kahn, as executors of the Estate of Jeffrey E. Epstein, 19-civ-10653 (PAE) (DCF)).
+In His Honor's Opinion & Order, Judge Engelmayer grants the Co-Executors' motion to dismiss
+the plaintiff's punitive damages claim against them as a matter of law on grounds applicable to
+Plaintiff's claim for punitive damages in this action.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c7a29b0b7cae02c45430bcaf8ef1cf2203c1c30a2b9d640588427ef94d56f452",
+  "output_sha256": "d5b0e6884f42f33bf48f46de834b8517974c8172b3b900a1ae104a810c8ac7cd",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e38ffce9dc6cad8919d4de8837d9ce761e2f7bb7a7e536cbef8feb00c1b2afb8.md b/vision-fixhub/court-01/e38ffce9dc6cad8919d4de8837d9ce761e2f7bb7a7e536cbef8feb00c1b2afb8.md
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@@ -0,0 +1,453 @@
+Case 9:08-cv-80119-KAM Document 282-1
+Entered on FLSD Docket 08/31/2009 Page 1 of 11
+fier
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S RESPONSE & OBJECTIONS
+TO PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+serves his responses and objections to Plaintiffs December 9, 2008 Amended First Set
+Of Interrogatories To Defendant Jeffrey Epstein, attached hereto.
+Certificate of Service
+1S. Mail to the tolving a dresses eco of the fore or a large sent by far and
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+iherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 282-1
+Entered on FLSD Docket 08/31/2009 Page 2 of 11
+Page 2
+Respectfully submitted,
+ROBERT D.ERITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclglaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 3 of 11
+Page 3
+DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO
+PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES
+Interrogatory No. 1.
+the Palm Beach Residence.
+Identify all employees who performed work of services inside
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for a time period from
+January 1, 2003 until present. Also, see "Employee" as defined in paragraph g of
+Plaintiff's interrogatories.
+Interrogatory No. 2.
+Identify all Employees not identified
+in
+response to
+interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and | must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for "all Employees" who at
+any time" came to the residence. Also, see "Employee" as defined in paragraph g of
+Plaintiff's interrogatories.
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 4 of 11
+Page 4
+Interrogatory No. 3.
+Identify all persons who came to the Palm Beach Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005.
+Interrogatory No. 4.
+Identify all persons who came to the New York Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that | cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as
+• the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005."
+Interrogatory No. 5.
+Identify all persons who came to the New Mexico Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 5 of 11
+Page 5
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005.
+Interrogatory No. 6.
+Identify all persons who came to the St.
+and who gave a massage or were asked to give a massage to Defendant.
+Residence
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his
+constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005."
+Interrogatory No. 7.
+List all the time periods during which Jeffrey Epstein was
+present in the State of Florida, including for each the date he arrive and the date he
+departed.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 6 of 11
+Page 6
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for a time period from
+January 1, 2003 until present.
+Interrogatory No. 8.
+Identify all of Jeffrey Epstein health care providers in the
+past (10) ten years, including without limitation, psychologists, psychiatrists, mental
+health counselors, physicians, hospitals and treatment facilities.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. In addition, such information is privileged pursuant to
+Rule 501, Fed. Evid., and §90.503, Fla.Evid. Code. In addition, such information is
+protected by the provisions of the Health Insurance Portability and Accountability Act
+(HIPAA).
+Interrogatory No. 9.
+List all items in Jeffrey Epstein's possession in Palm Beach,
+Florida, at any time during the period of these interrogatories, which were used or
+intended to be used as sexual aids, sex toys, massage aids, and/or vibrators, and for
+each, list the manufacturer, model number (if applicable), and its present location.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Amended Complaint alleges a time period
+of "in or about 2004 - 2005," while Plaintiff's interrogatory seeks information from
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 7 of 11
+Page 7
+January 1, 2003, until present. Further, the request is meant to embarrass and harass
+the Defendant.
+Interrogatory No. 10.
+Identify all persons who provide transportation services to
+Jeffrey Epstein, whether as employees or independent contractors, including without
+limitation, chauffeurs and aircraft crew.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff places no time limitation.
+Interrogatory No. 11.
+Identify all telephone numbers used by Epstein, including
+cellular phones and land lines in any of his residences, by stating the complete
+telephone number and the name of the service provider.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's allegations claim a time period of "in or
+about 2004-2005" and involve Defendant's Palm Beach residence.
+Interrogatory No. 12.
+Identify all telephone numbers of employees of Epstein,
+used in the course or scope of their employment, including cellular phones and land
+lines in any of his residences, by stating the complete telephone number and the name
+of the service provider.
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 8 of 11
+Page 8
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's allegations claim a time period of "in or
+about 2004-2005" and involve Defendant's Palm Beach residence.
+Interrogatory No. 13.
+List the names and addresses of all persons who are
+believed or known by your, your agents, or your attorneys to have any knowledge
+concerning any of the issues in this lawsuit; and specify the subject matter about which
+the witness has knowledge.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, the interrogatory seeks information
+that is attorney-client and work product privileged as it seeks information known by
+Defendant's attorneys.
+The interrogatory is so overbroad that Defendant cannot
+reasonably form a response, including the raising of additional privileges which may
+apply. Without waiving any objection, see Rule 26 disclosures made by Defendant's
+counsel in this case.
+Interrogatory No. 14.
+State the name and address of every person known to you,
+your agents, or your attorneys who has knowledge about, possession, or custody, or
+control of, any model, plat, map, drawing, motion picture, videotape or photograph
+pertaining to any fact or issue involved in this controversy; and describe as to each,
+what item such person has, the name and address of the person who took or prepared
+it, and the date it was taken or prepared.
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 9 of 11
+Page 9
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, the interrogatory seeks information
+that is attorney-client and work product privileged as it seeks information known by
+Defendant's attorneys.
+Interrogatory No. 15.
+Identify all persons who have made a claim, complaint,
+demand or threat against you relating to alleged sexual abuse or misconduct on a
+minor, and for each provide the following information:
+a. The person's full name, last known address and telephone number;
+b. The person's attorney, if represented;
+c. The date of the alleged incidents);
+d. If a civil case has been filed by or on behalf of the person, the case number
+and identifying information.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges and without waiving such objection,
+with regard to subparagraph (d), Defendant's counsel states that such information is
+public record and equally attainable by Plaintiff.
+Interrogatory No. 16.
+State the facts upon which you intend to rely for each denial
+of a pleading allegation and for each affirmative defense you intend to make in these
+cases.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges.
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 10 of
+Page 10
+losing my Sixth Amendment right to effective representation. Accordingly, 1 assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, no answer to the Amended
+Complaint has been filed by defense counsel in this case; however, Defendant does not
+intend to waive his constitutional privilege against self-incrimination. Defendant further
+objects in that Plaintiff's interrogatory attempts to obtain discovery in other cases filed
+by her undersigned counsel.
+Interrogatory No. 17.
+Identify all witnesses from whom you have obtained or
+requested a written, transcribed or recorded statement relating to any issue in these
+cases, and for each, in addition to the witness's identifying information, state the date of
+the statement and identify the person taking the statement.
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects to this
+interrogatory in that it seeks information that is attorney-client and work product
+privileged. In addition, the request is overbroad in that it seeks information "relating to
+any issue."
+STATE OF Florida
+)
+)
+COUNTY OF Palm Beach)
+I hereby certify that on this day, before me, an officer duly authorized to administer oaths
+and take acknowledgments, personally appeared Jeffrey
+Epstein
+_, known to
+me to be the person described in and who executed the foregoing Interrogatories who
+
+
+Case 9:08-cv-80119-KAM Document 282-1 Entered on FLSD Docket 08/31/2009 Page 11 of
+Page 11
+acknowledged before me that he/she executed the same, that I relied upon the following form of
+identification of the above-named person: personally known/identification, and that an oath
+was/was not taken.
+WITNESS my hand and official seal in the County and State last aforesaid this _ 26 th
+day of
+January
+, 2009.
+Nauancia
+Alonis
+(SEAL)
+NOTARY PUBLIC-STATE OF FLORIDA
+Nayanira Alanis
+Com DEC. 01, 2012
+BONDED THRU ATLANTIC BONDING CO., INC.
+Commission #:
+My Commission Expires:_
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/e3aa12707ccada5d6fd3feda250cafb8d8e288368895846c96e4a17cc6712638.md b/vision-fixhub/court-01/e3aa12707ccada5d6fd3feda250cafb8d8e288368895846c96e4a17cc6712638.md
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@@ -0,0 +1,39 @@
+Case 9:08-cv-80119-KAM Document 263 Entered on FLSD Docket 08/11/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+NOTICE TO PARTIES
+THIS CAUSE is before the Court sua sponte. In the interests of judicial and clerical
+efficiency, it is hereby ORDERED AND ADJUDGED as follows:
+The above-styled cases have previously been consolidated for purposes of discovery and
+for procedural motions that relate to multiple cases.
+Hereinafter, all motions and other court filings that relate to discovery and all procedural
+motions that relate to multiple cases shall be styled consistent with the styling of this Order, and
+shall be FILED ONLY in Jane Doe No. 2 v. Epstein, case no. 08-80119, which is the
+lowest-numbered pending case. Any motions styled incorrectly or filed in multiple cases will be
+stricken from the docket for failure to follow the Court's Order.
+The parties may continue to file separate motions to dismiss, answers to the complaint,
+1
+
+
+Case 9:08-cv-80119-KAM Document 263 Entered on FLSD Docket 08/11/2009 Page 2 of 2
+summary judgment motions, motions in limine and other substantive motions that pertain to
+their individual cases and their individual trials under their individual case styles.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 11" day of August, 2009.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+Magistrate Judge Linnea R.
+2
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@@ -0,0 +1,634 @@
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 1 of 18
+
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 2 of 18
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+& ST. JOHN
+********************************
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+)
+Deceased.
+PROBATE NO. ST-19-PB-80
+ACTION FOR TESTATE
+ADMINISTRATION
+CO-EXECUTORS' STATUS REPORT ON VOLUNTARY COMPENSATION
+PROGRAM AND PRESENTATION OF PROGRAM PROTOCOL
+On November 14, 2019, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-
+Executors") filed their Expedited Motion for Establishment of a Voluntary Claims Resolution
+Program (the "Expedited Motion") seeking to establish an independent and voluntary claims
+resolution program (the "Program") for purposes of resolving sexual abuse claims against Jeffrey
+E. Epstein, deceased. As promised in the Expedited Motion, the Co-Executors now submit to the
+Court the detailed Program protocol (the "Protocol," copy attached as Exhibit A hereto) designed
+and developed over several months by independent, nationally recognized claims administration
+experts with extensive input from the Co-Executors and other interested parties, including
+claimants and their legal representatives. Because the need for the Program has grown increasingly
+urgent and with the support of claimants' counsel and the Attorney General of the United States
+Virgin Islands, the Co-Executors intend to authorize commencement on Monday, June 15, 2020
+of formal claims resolution proceedings under the Program, absent contrary direction from the
+Court.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 3 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Page 2
+1. BACKGROUND
+As detailed in the Expedited Motion and the Co-Executors' subsequent filings with the
+Court, the Program will provide all eligible claimants an opportunity to receive compensation and
+voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, nonadversarial alternative to litigation, utilizing a process that is sensitive to the experiences and
+concern of claimants and treats them with compassion, dignity and respect.'
+On February 4, 2020, the Court heard extensive witness testimony concerning the Program
+(February 4, 2020 Hearing Tr. at 103:12-186:14); at that hearing, multiple claimants' counsel also
+spoke in favor of implementing the Program. (Id. 84:11-85:2; 85:6-19; 92:24-93:8.) As Your
+Honor recognized, the Program is not only consistent with the fiduciary duties of the Co-
+Executors, but in fact "... we agreed that everybody believes this program is a great program..."
+(Id. at 113:24-25.) That drumbeat of approval continues to swell; since the Co-Executors' most
+recent filing with the Court concerning the Program, counsel for 69 individual claimants have
+come forward to the Court in support of the Program.?
+1. Expedited Motion at 1; see also Co-Executors' Request for Ruling on Expedited Motion for Establishment of a
+Voluntary Claims Resolution Program (filed December 4, 2019); Co-Executors' Request for Immediate Hearing
+or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program (filed
+December 13, 2019); Co-Executors' Reply to Creditor Jane Doe's Response to Co-Executors' Expedited Motion
+for Establishment of a Voluntary Claims Resolution Program (filed January 15, 2020); Co-Executors' Reply to
+Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program (filed
+January 31, 2020); Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation
+Program and Request for Ruling (filed March 24, 2020); Co-Executors' Corrections to Attorney General's Status
+Report on Voluntary Compensation Program and Renewed Request for Ruling (filed April 10, 2020).
+2. Co-Executors' Notice of Related Filing, dated April 17, 2020 (attaching Co-Executors" correspondence with
+claimants' New York counsel concerning commencement of the Program).
+3. See Status Report from Claimants dated April 20, 2020 (urging on behalf of 12 claimants that "the Program can
+and should proceed without delay"); Status Report from Claimants dated April 21, 2020 (stating on behalf of 5
+claimants that "permitting the Program to proceed would be in the best interests of the victims at this time");
+Motion for Status Conference Regarding the Victim Compensation Program dated April 28, 2020 (seeking on
+behalf of 52 claimants an Order "permitting the Program to proceed as agreed amongst the parties").
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 4 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+Page 3
+and Presentation of Program Protocol
+IS THE PROGRAM PROTOCOL
+The Program Administrator and Designers have now finalized the Protocol for the
+Program, in close consultation with claimants' counsel and the Co-Executors.* As contemplated
+in the Expedited Motion, the Protocol sets forth the following non-exclusive guiding principles:
+• The Program is purely voluntary. It does not affect any rights a claimant may
+have unless and until she accepts the offered compensation and executes a
+release. A claimant may reject the offer of compensation and may stop
+participating in the Program and withdraw the claim at any time prior to
+execution of the release.
+• The Program is independent and will in no way be administered, controlled, or
+overseen by the Co-Executors. The Program Administrator is responsible for
+all decisions relating to the review, processing and evaluation of individual
+claims submitted to the Program. The Administrator will have final, binding,
+and exclusive authority to determine claimant eligibility and the valuation of
+each eligible individual claim. Decisions of the Administrator made pursuant
+to the Protocol are not subject to review or modification in any way by the Co-
+Executors or any other party or entity.
+• Subject to total Estate assets available, there is no cap or limitation on the
+aggregate amount of funds available to compensate all eligible claimants or on
+the amount of compensation to be made to each individual claimant. Each
+individual claim will be evaluated separately by the Program Administrator.
+The Administrator will determine, in her sole and exclusive discretion, issues
+of eligibility and the amount of compensation and the Estate will pay all eligible
+claims based on the Administrator's determination.
+• All claimants will be treated with respect, dignity, and fairness without regard
+to race, color, sexual orientation, national origin, religion, gender, or disability.
+To ensure claims will be adjudicated fairly, the Program Administrator will
+manage the process so that all claimants can equally access the Program's claim
+process. Individuals with disabilities will be given the opportunity to
+effectively communicate their claims and to request special process
+accommodations.
+(See Protocol at pp. 1-2.)
+4. The Attorney General of the U.S. Virgin Islands also expressed her detailed views on the structure and formation
+of the Program, both through filings with the Court and direct communications with the Program Administrator.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 5 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+Page 4
+and Presentation of Program Protocol
+The Protocol also sets forth detailed aspects of the Program's administration, including
+eligibility criteria for the Program, proof requirements and claims procedures, the methodology
+for claims evaluation and determining compensatory awards, and timing and regular reports to the
+Court, as follows:
+• Eligibility. The Protocol identifies the criteria to determine whether a claimant
+is eligible to receive compensation under the Program. (See Protocol at pp. 3-
+4.)
+• Proof Requirements and Claims Procedures. The Protocol determines what
+types of supporting documentation or other evidence each individual will be
+required to submit to substantiate her claim, satisfy Program requirements, and
+allow the Program Administrator to review, process and evaluate that claim.
+(See Protocol at pp. 4-5.)
+• Claims Evaluation and Determination Methodology. The Protocol defines
+the factors and considerations to be used to determine the amount of
+compensation to be offered to any eligible claimant. (See Protocol at pp. 5-6.)
+•
+Timing. The Protocol sets forth the timeframe of the Program, including an
+effective commencement date and deadline for submission of all claims. (See
+Protocol at pp. 4-5.)
+Reporting. The Protocol reflects the Program Administrator's commitment to
+provide the Court with regular monthly reports regarding the aggregate number
+and total value of claims paid each month through the Program. (See Protocol
+at p. 9.)
+Ill.
+URGENT NEED TO COMMENCE OF PROGRAM OPERATIONS
+In their fiduciary capacity, the Co-Executors engaged in extensive discussions with
+relevant parties in interest regarding the independent, fair, and timely resolution of the sexual abuse
+claims against Mr. Epstein. As noted above, many existing and potential claimants have expressed
+through their representatives their preference to participate in the Program rather than proceeding
+with litigation. Although there will be significant expense in administering the Program, the Co-
+Executors contemplate that the Program will substantially reduce the expenses to the Estate of
+litigating multiple lawsuits in numerous jurisdictions, and thus ultimately reduce expenses to the
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 6 of 18
+Estate of Jeljrey E. Epstein
+Co-Executors' Status Report on Voluntary Compensation Program
+Page 5
+and Presentation of Program Protocol
+benefit of all parties with an interest in the Estate, including claimants and creditors. The
+expedited nature of the Program will also ensure resolution and compensation to claimants in a far
+more timely manner than through litigation.
+As described above, the Protocol is designed to ensure the proportionate restitution of
+approved claims for all claimants, in a manner that will provide similar compensation to similarly
+situated claimants. The Program is in the best interests of both claimants and the Estate because,
+among other things, it avoids the potential of disproportionate and inconsistent awards and should
+help to reduce the time, exposure and burden of handling claims through the courts, which could
+involve years of litigation and appeals and consume enormous resources, along with inflicting on
+all affected parties costs attendant to delay and uncertainty.
+IV. FUNDING FOR THE PROGRAM
+As the Court is aware, the Attorney General on January 31, 2020 unilaterally imposed
+criminal activity liens on the Estate's bank account in the Virgin Islands, freezing then-available
+funds - funds over which this Court has exclusive jurisdiction - for administration of the Estate
+and implementation of the Program.® On February 24, 2020, the Attorney General imposed similar
+liens against Southern Trust Company, Inc., one of the entities within the Estate. The Co-
+Executors have challenged the validity of the Attorney General's liens, and moved the Superior
+5. In the absence of the Program, litigation alleging sexual abuse by Mr. Epstein has increased in scope, pace and
+expense: there are now 22 separate lawsuits brought by 34 individual claimants pending against the Cr
+ixecutors, primarily in the state and federal courts of New York. Discovery proceedings in those actions -
+including document demands, interrogatories, non-party subpoenas, and motions to compel — continue to ratchet
+up each passing week.
+6. Following the Co-Executors' resulting emergency motion for release of funds necessary for administration of the
+Estate, the Court directed the Attorney General to lift her liens in amounts sufficient to allow the Co-Executors
+to pay the Estate's operational expenses and legal fees.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 7 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+Page 6
+and Presentation of Program Protocol
+Court to vacate them in their entirety? However, pending determination of that motion - as well
+as this Court's approval of the estimated budget for and expenses of designing, implementing and
+administering the Program, submitted by the Co-Executors on February 4, 2020 - the Co-
+Executors and the Attorney General have reached consensual resolution in which the latter will
+promptly lift those liens to pay amounts owed for the Program and to begin funding of the
+Program's active operations, including payment of compensation determinations to eligible
+claimants.
+*
+*
+*
+*
+Because the need for the Program has grown increasingly urgent, and with the support of
+claimants' counsel and the USVI Attorney General - and because the remaining impediments have
+been resolved and the interested parties have consented to the Protocol attached as Exhibit A hereto
+- the Co-Executors intend to move forward with the Program on Monday, June 15, 2020, absent
+contrary direction from the Court.?
+Dated: June 1, 2020
+Respectfully,
+/s/
+, Kroblin
+KROBLIN, ESQ.
+ANDREW W. HEYMANN, ESQ.
+WILLIAM L. BLUM, ESQ.
+SHARIN. D'ANDRADE, ESQ.
+MARJORIE WHALEN, ESQ.
+7. See Expedited Motion to Vacate Liens, dated March 17, 2020 (Government of the U.S. Virgin Islands vs. Indyke,
+et al., Case No. ST-20-CV-14). The Attorney General filed no response to that expedited motion.
+8. As part of that resolution, the Co-Executors agreed not to assert that the Attorney General's release of such limited
+funds will act as a waiver of Government's ability, if any, to object to the Program's administrative expenses,
+including those paid with these initial funds.
+themselves available.
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 8 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Page 7
+V.I. Bar Nos. 136, 966, 1221 & R2019
+KELLERHALS
+KroBLIN PLLC
+Palms Professional Building
+9053 Estate
+,, Suite 101
+St.
+1. V.I. 00802
+Telephone: (340) 779-2564
+Facsimile: (888) 316-9269
+Email: wblum@solblum.com
+ckroblin@kellfer.com
+sdandrade@kellfer.com
+mwhalen@kellfer.com
+
+
+Case 1:19-CV-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 9 of 18
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Page 8
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this Ist day of June 2020, I caused a true and exact copy
+of the foregoing Co-Executors' Status Report on Voluntary Claims Resolution Program and
+Presentation of Program Protocol to be served via electronic mail upon:
+John H. Benham, Esq.
+Law Office of John H. Benham, P.C.
+P.O. Box 11720
+St.
+I VI 00801
+john@benhamlawvi.com
+Douglas B. Chanco, Esq.
+ChancoSchiffer P.C.
+3355 Lenox Road, Suite 750
+Atlanta, GA 30326
+doug@csfirm.com
+Richard Bourne-Vanneck, Esq.
+Law Offices of Richard Bourne-Vanneck
+9800 Buccaneer Mall Suite #9
+St.
+VI 00802
+richard@rpvblawoffices.com
+John K. Dema
+Law Offices of John K. Dema
+1236 Strand Street, Suite 103
+St. Croix, VI
+jdema@demalaw.com
+Denise N.
+, Esq.
+Attorney General
+Ariel M.
+1. Esq.
+Chief. Civil Division
+Virgin Islands Department of Justice
+34-38 Krondprinsdens Gade
+GERS Complex, 2°° Floor
+St.
+. Virgin Islands 00804
+A. Jeffrey Weiss, Esq.
+A.J. Weiss & Associates
+6934 Vessup Lane
+St.
+I. VI 00802
+jeffweiss@weisslaw-vi.net
+Sean
+Esq.
+Marjorie Rawls
+P.C.
+S.O. Box 6347
+1. VI 00804
+sean@marjorierobertspc.com
+Kevin F. D'Amour
+Gaylin Vogel, Esq.
+5143 Palm Passage, 18b & 19b
+St.
+VI 00802
+kevin.damour@comcast.net
+gaylin.vogel@comcast.net
+Melody D. Westfall, Esq.
+Westfall Law PLLC
+5032 Anchor Way, Suite 8
+Christiansted, St. Croix 00820
+mwestfall@westfalllaw.com
+Kevin Boyle, Esq. (Pro Hac Vice)
+Robert Glassman, Esq. (Pro Hac Vice)
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Blvd., Ste. 700
+Los Angeles, CA 90025
+boyle@psblaw.com
+glassman@psblaw.com
+/s/ Shari N. D'Andrade
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 10 of 18
+Independent
+Epstein Victims' Compensation Program
+PROTOCOL
+May 29, 2020
+I.
+PURPOSE AND OVERVIEW
+The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
+has been established to compensate and resolve the claims of victims-survivors of sexual abuse by
+Jeffrey Epstein ("Epstein").
+The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
+administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H.
+to design the
+Program.
+will also serve as the Administrator of the Program (the "Administrator""). This
+Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and
+representatives of the Estate.
+Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and
+offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
+The Program is governed by the following non-exclusive guiding principles:
+• The Program is purely voluntary. It does not affect any rights a Claimant may have
+unless and until the Claimant accepts the offered compensation and executes a
+Release. A Claimant may reject the offer of compensation and may stop
+participating in the Program and withdraw the claim at any time prior to execution
+of the Release.
+• The Program is independent and will in no way be administered, controlled or
+overseen by the Estate. The Administrator is responsible for all decisions relating to
+the review, processing and evaluation of individual claims submitted to the
+Program. The Administrator will have final, binding and exclusive authority to
+determine Claimant eligibility and the valuation of each eligible individual claim.
+Decisions of the Administrator made pursuant to this Protocol are not subject to
+review or modification in any way by the Estate or any other party or entity.
+• There is no cap or limitation on the aggregate amount of funds available to
+compensate all eligible Claimants or on the amount of compensation to be made to
+each individual Claimant. Each individual claim will be evaluated separately by the
+Administrator. The Administrator will determine, in her sole and exclusive
+discretion, issues of eligibility and the amount of compensation and the Estate will
+pay all eligible claims based on the Administrator's determination.
+1| Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 11 of 18
+• All Claimants will be treated with respect, dignity and fairness without regard to
+race, color, sexual orientation, national origin, religion, gender or disability. To
+ensure claims will be adjudicated fairly, the Administrator will manage the process
+so that all Claimants can equally access the Program's claim process. Individuals
+with disabilities will be given the opportunity to effectively communicate their
+claims and to request special process accommodations.
+The Program is available to all victims-survivors regardless of where they were harmed, when they were
+harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they
+have previously filed a lawsuit against or settled with Epstein and/or the Estate.
+The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
+individual claims filed with the Program must be filed within this period.
+To complement the Program's resources, the Administrator will, at her discretion and with the consent
+of the Claimant, consult with Professor Marci A.
+, a nationally recognized sexual abuse expert,
+leading legal academic and advocate of victims' rights.
+role will be to further inform the
+Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse,
+and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or
+updating policies and procedures; to advise the Administrator regarding sensitivities involved in
+interactions with victims; and to serve as a referral source for the Administrator in providing postdetermination information to claimants who seek guidance, counseling or other services. The
+Administrator may, at her discretion and with the Claimant's prior written consent, request that
+review an individual claimant file. The Administrator will determine on a case-by-case basis, in
+her discretion, the need to anonymize individual claimants' files before sharing them with
+As set forth above, the Administrator is solely responsible for all decisions relating to the administration
+of the Program, including the review, processing, evaluation, and determination of individual claims
+submitted to the Program.
+During the term of the Program,
+will not meet or speak with a Claimant or her
+representatives concerning any aspect of the Program without the Administrator present.
+will maintain in strict confidence and will not disclose outside the Program any information she obtains
+through her participation in the Program, including individual Claimants' submissions.
+2|Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 12 of 18
+Il.
+ELIGIBILITY REQUIREMENTS
+A. Eligibility Criteria
+The persons eligible to participate in this Program are individuals who allege they were sexually abused
+by Epstein. In addition, the following criteria apply:
+• The claim of sexual abuse must be directed against Epstein.
+• An individual whose claim is time-barred by the applicable statute of limitations may
+participate in the Program provided that other eligibility criteria are met.
+• An individual who previously entered into a settlement agreement resolving a claim of sexual
+abuse against Epstein may participate in the Program provided that other eligibility criteria are
+met.
+• An individual who allegedly assisted Epstein in procuring other victims-survivors may
+participate in the Program where there is a credible basis to determine that the individual
+acted under duress as a result of her own sexual abuse by Epstein, provided that other
+eligibility criteria are met.
+• If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
+prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities
+and/or related individuals. The Claimant must provide proof of such dismissal along with or
+prior to the signed acceptance of the compensation determination offer letter and executed
+Release in order to receive payment.
+B. Legal Representatives of Claimants
+An individual may file a claim on a victim's behalf where that individual has been granted legal authority
+to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
+individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
+guardian authorized by law to serve as the minor's legal representative; (2) in the case of an
+incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's
+legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person
+who has been duly appointed to act as the personal representative of the Claimant's estate by a court of
+competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to
+represent the Claimant for purposes of pursuing a claim through this Program.
+Legal Representatives must provide proper documentation demonstrating representative capacity. Such
+proof may include a power of attorney; documentation showing the individual's appointment as
+guardian or guardian ad litem; documentation showing the individual's appointment as personal
+representative of the Claimant's estate (such as letters of administration); a copy of a retainer
+3 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 13 of 18
+agreement showing legal representation signed by both the Claimant and the attorney or a signed
+statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her
+behalf.
+III. CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION
+A. Claims Submission Process
+Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
+otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the
+Effective Date will be sent a Claim Form and other relevant Program information, including Instructions
+for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed
+a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to
+be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain
+free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals
+must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at
+the time of acceptance of a compensation determination offer in order to receive payment.
+Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
+not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before
+the Effective Date may register to participate in this Program on the Program's website at
+www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their
+name, contact information, a summary description of the nature of the claim and other requested
+information. Upon registration, the Administrator will perform a preliminary review to consider if the
+individual is eligible to participate in the Program. If the Administrator deems that the individual is
+eligible to participate in the Program, she will then send that individual a Claim Form and other relevant
+Program information.
+Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
+that the Administrator has determined that such individual is eligible to participate in the Program. It
+does not indicate that the Administrator has determined that such individual is eligible to receive
+compensation. That determination is made only after a Claim Form and all required documentation has
+been submitted and evaluated by the Administrator.
+Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the
+Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the
+Administrator on or before the Effective Date will be accepted by the Administrator from the Effective
+Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important
+to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained
+above, all claims must be filed by the Filing Deadline.
+4 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 14 of 18
+All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing
+Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed
+via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator
+at the following address:
+Epstein Victims' Compensation Program
+Attn: Jordana H
+. Administrator
+P.O. Box 65488
+Washington, D.C. 20035
+Claimants are invited to provide documentation identified in the Claim Form, and any other
+corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility
+requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is
+being presented by a Legal Representative, then the Legal Representative will be responsible for
+submitting the necessary documentation relating to the represented Claimant.
+Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
+and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
+relevant to the Administrator's evaluation and determination of the claim before the Administrator's
+final disposition of the claim.
+If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant,
+explain the additional information that is needed, and work with the Claimant or the Claimant's Legal
+Representative (where applicable) to assist in submitting a complete claim.
+B. Claims Evaluation and Determination
+Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
+submitted individual claim in a prompt and fair manner. Claims will only be determined once all
+required documentation has been submitted to the Administrator, with due consideration granted to
+Claimant's good faith explanations for delays and/or absence of documentation.
+1. Factors Considered in Evaluating Claims
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, whether the allegations of sexual abuse are credible. The Administrator will
+consider appropriate factors and corroborative support, including but not limited to:
+• The level of documentation, corroboration or other circumstantial evidence regarding the
+nature and extent of the abuse, the frequency, location and other details of the abuse, and the
+age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include
+(i) medical or psychiatric counseling/therapy records relevant to the abuse, and
+(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
+abuse by the Claimant to law enforcement authorities, parents, friends or others. The
+Administrator acknowledges that some Claimants may not be able to provide any
+5 Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 15 of 18
+documentation to corroborate their Claim based on the nature and circumstances of Epstein's
+conduct. If a Claimant's written and oral presentation is deemed to be credible by the
+Administrator, the Claimant may still be eligible for compensation under the Program.
+• Whether there exists any information and/or pertinent findings offered by the appropriate
+Office of the District Attorney, United States Attorney's Office, or other law enforcement
+agency.
+• Whether the Administrator finds the claims of the individual to be credible after complete
+review of all relevant documentation and other evidence provided by the Claimant and the
+Estate.
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, the amount of compensation that should be offered to each eligible Claimant.
+The Administrator will consider appropriate factors and corroborative support, including but not limited
+to:
+• The nature, duration and extent of the sexual abuse suffered by the Claimant.
+• The age of the Claimant at the time of the sexual abuse.
+• The nature and extent of the Claimant's physical or psychological damage resulting from the
+sexual abuse, and the effect of the sexual abuse on the Claimant.
+• The credibility of the claim based upon all of the facts and circumstances, supporting
+documentation and corroborating evidence.
+• Whether the Claimant previously entered into a settlement agreement with Epstein and
+received a payment pursuant to such agreement.
+The Administrator will confidentially send the Claimant a compensation determination offer letter
+including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of
+compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered
+compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from
+the date of the compensation determination offer letter.
+The Administrator's determinations in this Program will not be binding on any potential criminal
+investigation involving Claimant's claims.
+2. Opportunities to be Heard
+The Claimant will be afforded an opportunity to be heard, either before or after the Administrator
+renders her determination. Upon request by the Claimant, the Administrator will be available to meet in
+person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to
+further discuss the claim. These meetings are completely optional and voluntary. Requests to meet
+6 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 16 of 18
+with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be
+scheduled at a mutually convenient time and location. The Administrator may also request a meeting
+with a Claimant or her Legal Representative at a reasonable mutually convenient time and location,
+though the Claimant is not obligated to attend any such meeting.
+3. Release
+By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations
+of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the
+Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the
+Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all
+past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of
+sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the
+offer of compensation and may stop participating in the Program and withdraw the claim at any time
+prior to the execution of the Release.
+The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
+may have to assert any claims relating to allegations of sexual abuse against the Estate, related
+entities and/or related individuals, to file an individual legal action relating to such allegations, or to
+participate in any civil legal action associated with such allegations, except as a witness. However,
+the Release will not operate to preclude or limit the Claimant's ability to report and discuss
+allegations of sexual abuse with law enforcement officials or anyone else. In other words, the
+Release will not impose any rules of confidentiality on claimants, who are expressly permitted to
+discuss their allegations without restriction, should they choose.
+Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the
+Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal
+counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and
+binding nature of the Release.
+No one affiliated with the Program will provide tax or legal advice to those receiving payments under
+the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding
+tax liability for payments pursuant to the Program.
+4. Payments
+Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
+the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing
+lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the
+Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as
+directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All
+payments made under the Program shall be for a Claimant's physical injuries, physical sickness and
+7| Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 17 of 18
+resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code.
+C. Program Integrity
+For the purpose of protecting both the integrity of the Program and financial resources for eligible
+Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
+claims, including taking steps to verify claims and analyze submissions for inconsistencies,
+irregularities or duplication.
+Each Claimant who signs the Claim Form at the time of submission certifies that the information
+provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the
+Claimant understands that false statements or claims made in connection with such submission may
+result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be
+potentially fraudulent or to contain information known by the Claimant to be false when made will be
+forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the
+District Attorney and/or United States Attorney's Office for possible investigation and prosecution.
+D. Confidentiality/Privacy
+The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
+Representative (where applicable) agrees that information submitted by the Claimant pursuant to
+the Program will be used and/or disclosed by the Administrator and her designees only for the
+following purposes:
+I) Processing and evaluating the Claimant's claim;
+2) Administering the Program and other Program-related work; and
+3) Reports to law enforcement where appropriate, related to potentially fraudulent claims.
+When documents or other information maintained or submitted by the Estate become part of a
+Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to
+assist in processing and evaluating the claim, but will otherwise remain confidential. No information
+provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s)
+and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and,
+for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant
+alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained
+solely through the Program will be disclosed publicly or used by the Estate in defending itself from any
+claim, regardless of forum. The Program's files are not available for inspection, review or copying by
+the Estate or the Claimant or her representatives during or after the Program, and all pertinent
+mediation privileges, settlement privileges and other privileges apply.
+" All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims
+of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent
+privileges), and protection from disclosure under applicable law.
+8 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 67-1 Filed 06/01/20 Page 18 of 18
+To protect the privacy of Claimants participating in the Program, all personal information provided by
+the Claimant during this process will be returned or destroyed within one year after the conclusion of
+the Program.
+Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may,
+at their sole and voluntary option, disclose information in their possession regarding their claim, their
+compensation and their experience with the Program.
+All confidentiality requirements are subject to law, regulation and judicial process.
+E. Reporting
+The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and
+total value of claims paid each month to the Probate Court of the United States Virgin Islands and the
+Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level
+only. No individual Claimant information will be published or disclosed in a way that compromises
+Claimant confidentiality.
+9 | Page
\ No newline at end of file
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@@ -0,0 +1,521 @@
+Entered on FLSD Docket 04/02/2009 Page 1 0f8
+Westlaw.
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+Page 1
+District Court of Appeal of Florida,
+Fifth District.
+Kimberly BALAS and Teresa Shumate, Petitioners,
+V.
+Marjorie A. RUZZO, and Exec.., Inc., etc., Re-
+spondents.
+No. 97-82.
+307Ak31 k. Relevancy and Materiality.
+Most Cited Cases
+Party may be permitted to discover evidence that
+would be inadmissible at trial, if it would lead to
+discovery of relevant evidence. West's F.S.A. RCP
+Rule 1.280(b)(1).
+[3] Pretrial Procedure 307A €36.1
+Oct. 10, 1997.
+307A Pretrial Procedure
+307 AIl Depositions and Discovery
+Plaintiffs brought action against alleged house of 1998). 307AII(A) Discovery in General
+prostitution for, inter alia, coercion of prostitution.
+307 Ak36 Particular Subjects of Disclos- ure
+The Circuit Court, Brevard County, !
+Pound,
+307Ak36.1 k. In General. Most Cited
+J., granted in part defendants' motion to compel discovery. Plaintiffs filed petition for writ of certiorari. The District Court of Appeal, W. Sharp, J., held
+that evidence of plaintiffs' past prostitution and
+their revenues relating to such activities was discoverable.
+Petition denied.
+Harris, J., concurred specially and filed opinion.
+West Headnotes
+[1] Pretrial Procedure 307A €31
+Cases
+Evidence of plaintiffs' past prostitution and their
+revenues relating to such activities, including activities with alleged house of prostitution against
+which they had filed suit, was discoverable, where
+plaintiffs brought action not only for coercion of
+prostitution, but also for battery, false imprisonment, invasion of privacy, intentional infliction of
+emotional distress, violation of their civil rights,
+and racketeering. Violent Crime Control and Law
+Enforcement Act of 1994, § 40302, 42 U.S.C.A. §
+13981; West's F.S.A. §§ 772.014, 796.09; West's
+F.S.A. RCP Rule 1.280(b)(1).
+*1076 Richard E.
+and Heather Fisher Lindsay, of Spriggs
+&
+Tallahassee, for Petitioners.
+307A Pretrial Procedure
+307AII Depositions and Discovery
+307AII(A) Discovery in General
+307Ak31 k. Relevancy and Materiality.
+Most Cited Cases
+Discovery in civil cases must be relevant to subject
+matter of case and must be admissible or reasonbly calculated to lead to admissible evidence
+Nest's F.S.A: RCP Rule 1.280(b)(1)
+[2] Pretrial Procedure 307A €m 31
+307A Pretrial Procedure
+307 AII Depositions and Discovery
+307AII(A) Discovery in General
+Mark S. Peters of Amari, Theriac & Eisenmenger,
+P.A., Cocoa, for Respondents.
+W. SHARP, Judge.
+Balas and Shumate petition this court for a writ of
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 Page 3 8f8
+Page 2
+703 So.2d 1076, 22 Fla. L.. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+compelled to disclose intimate details of their sexual history. We decline to issue the writ of certiorari.
+Balas and Shumate filed suit against Ruzzo and Ex-
+ec, Inc., doing business as "The Boardroom." Ac-
+cording to Balas and Shumate, The Boardroom operates ostensibly as *1077 a leisure spa but actually
+is a house of prostitution. Balas worked at The
+Boardroom from December 1993 until February
+1996; Shumate worked there from October 1992
+until March 1996. Ruzzo, the sole officer and
+shareholder of Exec, Inc., collected about fifty to
+sixty percent of each employees' earnings from performing sexual acts.
+According to Balas and Shumate, Ruzzo exerted
+mental and emotional control over her employees
+and thus she was able to exploit them as prostitutes.
+Ruzzo required her employees to pay her substantial sums of money to attend "metaphysical workshops" conducted by Ruzzo or persons associated
+with her. At the work place, the employees were required to participate in religious and quasi-religious
+"circles," rituals and incantations. These practices
+titioners against their will. Count IV alleges that respondents' actions constituted an invasion of petitioners' privacy. Count V is a claim for the intentional infliction of emotional distress. Count VI alleges a civil rights action-that respondents have violated petitioners' right to be free from crimes of violence motivated by gender within the meaning of
+42 U.S.C. section 13981. Finally, count VII seeks
+civil remedies for criminal practices or racketeering
+pursuant to section 772.104, Florida Statutes. The
+petitioners claim that they suffered emotional pain,
+anguish, humiliation, insult, indignity, loss of selfesteem, inconvenience, hurt and emotional distress.
+They seek an award of general and punitive damages, among other relief.
+The discovery to which the petitioners are being required to respond is as follows:
+their submission to these searches and that they
+might be arrested on felony charges if they refused
+to submit to the searches.
+Balas and Shumate's second amended complaint
+against Ruzzo contains seven counts. Count I is an
+action for coercion of prostitution pursuant to section 796.09, Florida Statutes. Petitioners allege the
+requirement that they perform sexual acts to retain
+their employment constitutes inducement and coercion to engage in prostitution. Count Il is a claim
+for battery for the unwanted and offensive touching
+of the petitioners' bodies. Count IIl is a claim for
+false imprisonment for physically confining the pe-
+Interrogatory 8: Please advise how long have you
+been engaged in prostitution....
+Il.
+Interrogatory 22: State with specificity the manner in which the acts as described in your Complaint have materially affected how you interact
+with your husband, boyfriend, fiancée' [sic] or
+any other individual of the opposite sex.
+III.
+Request for Production 30: A copy of any photographs, movies or videotapes in which you perormed sexual acts and/or simulated sexual act
+1 exchange for money or other consideratio
+IV.
+Interrogatory 16: Please list the names, addresses,
+telephone numbers and rates of pay for all employers for which you worked, including the
+@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMIE&ifm=NotSet&mt... 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 Påtff 3 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+nature of the work, during the five years immediately preceding the date of employment with the
+Boardroom and from the date of your termination
+with the Boardroom to the present, providing the
+names of your immediate supervisors at each
+place of employment and the reason for your
+leaving each place of employment.
+Page 3
+V.
+Interrogatory 26: Please state your total income
+while employed at the Boardroom, and state the
+source of that income including any income from
+other employment or *1078 income earned from
+prostitution other than at the Boardroom.
+VI.
+Request for Production 34: Business records from
+any selfemployment or owned business ventures
+in the last 5 years, including any records or list of
+customers,
+"special customer lists" or "sugar
+daddy's list."
+[1][2] Discovery in civil cases must be relevant to
+the subject matter of the case and must be admissible or reasonably calculated to lead to admissible
+evidence. See Allstate Insurance Co. V. Langston,
+655 So.2d 91 (Fla. 1995); Amente v.
+So.2d 1030 (Fla.1995);
+ers, Inc., 690 So.2d 743 (Fla. 5th DCA 1997). The
+concept of relevancy is broader in the discovery
+context than in the trial context and a party may be
+permitted to discover evidence that would be inadmissible at trial, if it would lead to the discovery of
+relevant evidence. Allstate; Amente. Florida Rule of
+Civil Procedure 1.280(b)(1) delineates the proper
+scope of discovery:
+In General. Parties may obtain discovery regardnature, custody, condition, and location of any
+books, documents, or other tangible things and
+the identity and location of persons having knowledge of any discoverable matter. It is not ground
+for objection that the information sought will be
+inadmissible at the trial if the information sought
+appears reasonably calculated to lead to the discovery of admissible evidence.
+Nonetheless, the discovery of certain kinds of information may cause material injury of an irreparable nature. This includes the "cat-out-of-the-bag"
+material that could be used to injure another person
+or party outside the context of the litigation, material protected by privilege, trade secrets or work
+product. Discovery was never intended to be used
+as a tactical tool to harass, embarrass or annoy
+one's adversary. Rather, pretrial discovery was implemented to simplify the issues in a case, to eliminate the elements of surprise, to encourage the settlement of cases, to avoid the cost of litigation, and
+to achieve a balanced search for the truth to ensure
+a fair trial. Elkins v. Syken, 672 So.2d 517 (Fla. 1996).
+Here the petitioners argue that the information
+sought to be discovered regarding prostitution and
+their sexual activities was propounded solely to embarrass them and to invade their right to privacy.
+The petitioners also claim that this information is
+privileged under section 796.09 and is not calculated to lead to evidence which would be admissible at trial.
+Section 796.09 provides a person with a civil cause
+of action for compensatory and punitive damages
+against anyone who coerces that person into prostitution, who coerces that person to remain in prostitution, or who uses coercion to collect or receive
+Let my time to about with plant te
+seeking discovery or the claim or defense of any
+other party, including the existence, description,
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 PRE 4 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+ness for the plaintiffs cannot be used against the
+plaintiffs or witness in any other investigation or
+proceeding, except one for perjury.
+Section 796.09(5) specifically provides that it is not
+a defense that the plaintiff was paid or otherwise
+compensated for prostitution, that the plaintiff had
+engaged in prostitution prior to any involvement
+with the defendant or that the plaintiff made no attempt to escape from the defendant. Section
+796.09(6) provides that convictions for prostitution
+or prostitution-related offenses are inadmissible for
+the purpose of attacking the plaintiffs' credibility.
+This legislation was the result of the Florida Su-
+preme Court Gender Bias Study Commission,
+which conducted an extensive investigation of prostitution in this state. The Commission's activities
+included interviews with law enforcement and corrections personnel,*1079 judges, public defenders,
+prosecutors, drug rehabilitation counselors, social
+workers, medical personnel, prostitutes, clients and
+. The Commission found
+prostitution to be
+prevalent and uniform throughout the state and law
+enforcement largely unable to deter it under prevailing social attitudes and judicial
+practices. The
+Commission further found that prostitutes are often
+victims of economic, physical, and
+psychological
+coercion, that most persons do not chose to become
+prostitutes, but do so to survive, and that ninety
+percent of street prostitutes,
+both adult and children, are controlled by pimps who use a variety of
+coercive methods to maintain this control. The
+Commission determined that clients and pimps are
+rarely prosecuted and, when prosecuted, receive
+light sentences; whereas prostitutes, who are mainly
+frequently prosecuted and receive
+harsher treatment in the courts. The Commission
+Page 4
+cest to the judicial system without for having to ae
+arrested.
+Under section 796.09, the petitioners' prior involvement in prostitution and their earnings from prostitution would be irrelevant. Hence discovery should
+not be permitted because such information would
+not be admissible at trial nor would it be reasonably
+calculated to lead to evidence ultimately admissible
+at trial. Even though the scope of discovery is generally quite broad, section 796.09 is designed to encourage prostitutes to sue their pimps. Thus the
+usually broad scope of discovery may be constricted so that prostitutes will not be embarrassed, harassed or hindered in their actions.
+[3] Had the petitioners brought their lawsuit against
+Ruzzo and The Boardroom only under section
+796.09, evidence of petitioners past prostitution,
+including with the Boardroom, and their earnings
+relating to such activities, may not have been discoverable. However, the petitioners filed a multicount complaint for compensatory and punitive
+damages, alleging
+numerous causes of
+against the respondents.
+These other causes carry
+no such protection from discovery. Since the information sought by discovery may be relevant or
+may lead to the discovery of admissible evidence in
+one or more of these other causes of action or to
+determination of damages, we cannot conclude that
+the trial court departed from the essential requirements of law in granting this discovery. See
+v. TIB Bank of the Keys, 687 So.2d 895 (Fla. 3d
+DCA 1997) (by alleging fraud as well as breach of
+contract, purchaser placed at issue her reliance on
+venders' assertions, the veracity of financial documents she submitted to the vender, and the state of
+her mental health, including memory problems she
+was experiencing at the time of the alleged tortious
+conduct, thus deposition questions concerning her
+state of mind were relevant).
+Petition for Writ of Certiorari DENIED.
+THOMPSON, J., concurs.
+HARRIS,
+concurs specially with opin
+ion.HARRIS, Judge, concurring specially:
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Case 9:08-CV-80232-KAM Document 59-1 Entered on FLSD Docket 04/02/2009 Plife 5 8f 8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+There is a temptation in cases such as this to inquire
+which, the pot or the kettle, is imbued with the
+darker hue. Indeed that may ultimately be the question uppermost in the jurors' minds. But the issue
+presently before us is simply whether the pot, in order to establish the parties' comparative complexion, may discover the historical condition and the
+inherent characteristics of the kettle.
+We are here involved with parties that the limited
+record before us indicates were co-conspirators in a
+joint effort to violate Florida's laws against prostitution. The defendants are the owner/operators of a
+"social club" whose primary service is prostitution;
+the plaintiffs are employees of the club who
+provide such services. The employees are suing the
+owner/operators for, among other counts, taking advantage of their vulnerabilities ("coercing" them to
+be prostitutes) through manipulation and exploitation. In order to prepare a defense to the action, defendants have filed certain interrogatories for the
+employees to answer. These interrogatories*1080
+request such information as how long the employees have been engaged in prostitution; how the employees have been affected by the defendants' conduct; copies of photographs, movies, and videotapes in which the employees have performed sexual acts or simulated sexual acts; the names of previous employers and previous rates of pay; and a
+statement of income received from defendants.
+These interrogatories survived the employees' objections. I agree certiorari should be denied.
+The employees' primary cause of action is based on
+section 796.09(l), Florida Statutes, which provides:
+(1) A person has a cause of action for compensatory
+and punitive damages against:
+{a) A person who coerces that person into prostitution;
+(b) A person who coerces that person to remain in
+prostitution, or
+(e) A person who uses coercion to collect or receive
+Page 5
+any part of that person's earnings derived from
+prostitution.
+The employees resist discovery of their past prostitution or their past or present earning experience on
+the basis of subparagraph 5 of section 796.09:
+5) It does not constitute a defense to a complaint
+under this section that:
+1) The plaintiff was paid or otherwise compensate
+for acts of prostitution
+b) The plaintiff engaged in acts of prostitution prior to any involvement with the defendant...
+But the question before us is not whether prior acts
+of prostitution (or the receipts of earnings therefrom) which might be revealed by answering the interrogatories could be used as a defense to the complaint, but rather whether evidence of such conduct
+or such earnings would be relevant in determining
+whether the employees were, in fact, "coerced" into
+prostitution, into remaining prostitutes, or into sharing the proceeds of their services with defendants.
+The relevancy of this information depends, of
+course, on what constitutes coercion.
+If we apply the definition of "coercion" which is
+commonly accepted, then the relevancy of the requested information is apparent and this appeal has
+no merit at all. Webster defines "coercion" as: (1)
+to restrain or dominate by force, (2) to compel an
+act or choice, or (3) to enforce or bring about by
+force or threat. In sexual battery cases, the legislature has adopted the common meaning of the
+word "coercion" and has even placed limits on it. It
+has provided that consent will not be recognized if
+ence if the victim reasonably believes the perpetratcoerced by a threat of retaliation against the victim
+or another if the victim reasonably believes that the
+erpetrator has the ability to execute the threat
+le future. And in sexual battery cases, the 1
+gislature has vitiated what might otherwise be con-
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt... 3/26/2009
+
+
+Case 9:08-Cv-80232-KAM Document 59-1 Entered on FLSD Docket 04/02/2009 PålE & 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+sidered as consensual if one exploits a known physical or mental weakness of the victim to achieve his
+or her goal or takes advantage of one who is physically helpless or involuntarily intoxicated.FN3
+Therefore, even in sexual battery cases, before coercion or exploitation will vitiate consent, the free
+will of the victim must be overcome by force or
+threat or some unfortunate circumstance suffered
+by the victim.
+FN1. Section 794.011(4)(b), Florida Statutes.
+FN2. Section 794.011(4)(c), Florida Statutes.
+FN3. Section 794.011(4)(a),(d),(e), and (f),
+Florida Statutes.
+But then we get to the definition of "coercion" contained in section 796.09(3):
+3) As used in this section, the term "coercion"
+means any practice of dominion, restraint, or inducement for the purpose of or with the reasonably foreseeable effect of causing another person
+to engage in or remain in prostitution or to relinquish earnings derived from prostitution, and includes, but is not limited to:
+{a) Physical force or threats of physical force.
+{b) Physical or mental torture.
+(c) Kidnapping.
+*1081 (d) Blackmail.
+(e) Extortion or claims of indebtedness.
+{f) Threats of legal complaint or report of delinquency.
+(g) Threat to interfere with parental rights of responsibilities, whether by judicial or administrative action or otherwise.
+(h) Promise of legal benefit.
+Page 6
+]) Promise of greater financial rewards.
+j) Promise of marriage.
+(k) Restraint of Speech or communications with
+others.
+1) Exploitation of a condition of developmental
+disability, cognitive limitation, affective disorder,
+or substance dependency.
+"m) Exploitation of victimization by sexual abuse.
+in) Exploitation of pornographic performance.
+"o) Exploitation of human needs for food, shelter,
+safety, or affection.
+The definition urged by the employees herein is the
+"promise of a greater financial reward." Whether
+the requested information is relevant to the issue of
+coercion in this case will depend on what the legislature intended by subsection (I) in the meaning of
+"coercion."
+I agree with Judge Altenbernd's thoughtful analysis
+in State v. Brigham, 694 So.2d 793 (1997):
+There can be no dispute that the legislature's unusual definition of "percent" is not a common dietionary definition. This is perhaps an appropriate
+case in which to remind ourselves of Learned
+Hand's famous observation that a "mature and developed jurisprudence" does not "make a fortress
+out of the dictionary."
+But even so, one would expect some nexus between
+from a lakat Dane, the cours should nevertheless
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 Påge 7 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+before a definition is construed so as to expand the
+meaning of a well-known word to include its antonym ..., the intention of the legislature to that effect must be clear." As Judge
+observed in
+Catron v. Roger Bohn, D.C., P.A., 580 So.2d 814,
+818 (Fla. 2d DCA 1991):
+It is our primary duty to give effect to legislative
+intent and, if a literal interpretation of a statute
+leads to unreasonable results, then we should exercise our power to interpret reason and logic to it.
+******
+Unfortunately, it is apparent that in enacting this legislation, the legislature has, without redefining
+the terms for the purposes of this legislation, often used terms with commonly accepted meanings for purposes at great variance from those
+commonly accepted meanings.
+the pucas the enclace did because he on
+(coercion) as so defined can be interpreted two
+ways-one consistent with the commonly accepted
+meaning and one at variance-we should not accept
+the "antonym" unless such
+legislative intent is
+clear. A free will decision, even if based on a hope
+of financial gain, is the opposite of a coerced decision.
+The employees urge that the mere promise of a
+greater reward brings them within the act. But if the
+mere promise of a greater reward is sufficient to establish coercion, then anyone who makes a voluntary and reasoned exercise of free will motivated by
+the hope of economic gain has been coerced. This
+Page 7
+of an opportunity to make a decision with the coercion of that decision. But subsection (I) can also
+mean *1082 that the promise of a greater reward is
+coercion only if such promised reward is sufficient
+to overcome one's natural revulsion to selling one's
+body for money. If there is no such revulsion, there
+can be no coercion. Becoming a prostitute only because one likes the hours and wages or "because it
+beats the heck out of working for a living" simply
+should not meet the test of section 796.09(1).
+At oral argument herein, it was suggested without
+contradiction, that at least one of the employees has
+a college degree and gave up a well-paying, legitimate job in order to engage in this profession for
+the greater reward. Section 796.09 does not appear
+to be a general prostitute's relief act. It is based on a
+report by the Gender Bias Study Commission which
+recommended the equalization of treatment in relation to the prostitute, the client and the "pimp." It is
+based on the premise that prostitutes are generally
+victims of economic, physical, and psychological
+coercion and choose prostitution in order to survive. Further, the Commission was concerned that
+90 percent of the street prostitutes are controlled by
+"pimps" who use a variety of coercive methods to
+maintain control. It seems clear that the legislature
+was not intending to depart from the precepts of the
+commonly understood meaning of "coercion" and
+to redefine it to include both free will decisions and
+compelled decisions.. The interpretation urged by
+the employees seems at variance with the stated
+goal of the legislature and the Gender Bias Commission.
+Since there is no cause of action provided for one
+who makes a reasoned and
+voluntary exercise of
+solely for financial rewards (assuming "coercion" is
+given the definition more consistent with its comancial gain. The employees herein assert that since
+they were offered "a greater financial reward" for
+© 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
+
+
+Entered on FLSD Docket 04/02/2009 Page 8 8f8
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla. L. Weekly D169
+(Cite as: 703 So.2d 1076)
+This is a case of first impression based on a relatively new statute. As indicated, the legislative history of the new law suggests that the statute is designed to assist those who were forced to enter
+prostitution in order to keep a roof over their heads
+or food on their table. It does not appear to be intended to aid those who voluntarily enter the profession in order to drive a Mercedes instead of a
+even beginning employees of the defendants (those
+who do not have an established clientele) bring in
+$700 a day and can keep 50% of their earnings.
+Based on a five-day work week, this would reflect
+an income of $87,500 a year even with a two week
+vacation. And the employees herein are not beginnets.
+There is no indication that the legislature intended
+to legalize prostitution or to make it a respectable
+profession. It merely intended to place the prostitute on the same footing with the client and the
+"pimp." If a prostitute voluntarily makes the decision to participate, free from force, intimidation,
+or disadvantageous circumstance, then he or she is
+on the same footing as the other participants and
+should be treated the same.
+Although it might well serve a legitimate public
+purpose to permit the cannibalistic demise of such
+enterprises (and I am not unsympathetic with this
+view), that does not appear to be the policy behind
+the current statute. Therefore, in cases where coercion is not present (and this may or may not be
+one), the court should continue its tradition of not
+interceding in civil conflicts involving transactions
+that are either illegal or are against public policy.
+See Wechsler v. Novak, 157 Fla. 703, 26 So.2d 884
+V. Ratiner, 462 So.2d 1157, 1160
+(Fla. 3d DCA 1984), rev. denied, 472 So.2d 1182
+(Fla. 1985) ("An action may lie for interference with
+an unenforceable contract and even perhaps a voidable contract. No such cause of action lies for interrence with a contract void as against public polic
+ectoria yers ilegal personal injury soniciatio
+Page 8
+in the hospital] and which makes one who is a party
+thereto, as the appellant in the instant case, guilty of
+a criminal act for entering into such an agree- ment.")
+We are not asked in this proceeding to rule on the
+admissibility of the discovered information as evidence at the trial of this cause. We are to determine
+only if the information might lead to admissible
+evidence. Even *1083 though we deny the Writ ]
+suggest we certify the following question:
+DOES ONE, FREE FROM FORCE, INTIMIDA
+TION, OR DISADVANTAGEOUS CIRCUM-
+STANCE, WHO MAKES A REASONED DE-
+CISION TO BECOME OR REMAIN A PROSTI-
+TUTE OR TO SHARE THE PROCEEDS
+THEREOF BECAUSE OF A PROMISE OF A
+GREATER FINANCIAL REWARD HAVE A
+CAUSE OF ACTION UNDER SECTION
+796.09(1), FLORIDA STATUTES?
+ON MOTIONS FOR REHEARING, FOR CLARI-
+FICATION, FOR CERTIFICATION, AND FOR RE-
+HEARING EN BANC
+W. SHARP, Judge.
+Petitioners Balas and Shumate have filed motions
+for rehearing, clarification and certification.
+deny the motions in full except for one regard. We
+delete the sentence in the last full paragraph of the
+opinion which reads: "These other causes of action
+carry no such protection from discovery."
+Motion for Clarification GRANTED as stated
+above; Motion for Rehearing and Certification
+DENIED.
+HARRIS and THOMPSON, JJ., concur.
+Fla.App. 5 Dist.,1997.
+Balas v. Ruzzo
+703 So.2d 1076, 22 Fla. L. Weekly D2375, 23 Fla.
+L. Weekly D169
+END OF DOCUMENT
+@ 2009 Thomson Reuters/West. No Claim to Orig. US Gov. Works.
+http://web2.westlaw.com/print/printstream.aspx?sv=Split&prft=HTMLE&ifm=NotSet&mt.. 3/26/2009
\ No newline at end of file
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+  "doc_id": "e3e35969a8561c607d16258be0e4fbeb71c3ea269be37b4eb594a87d1d7e73df",
+  "engine": "marble-apple-vision",
+  "event_count": 142,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "9aadc6c99479c3cafd25c3cdb7f03705126e5e68ccab7a66802efae7bf71cf5b",
+  "output_sha256": "116892d798e98625b8d3ae820d138159f08971f7da81a38995d694b959a2e389",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.md b/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.md
new file mode 100644
index 0000000000000000000000000000000000000000..b9613626b6c0362c9053d237af14c671f41560cb
--- /dev/null
+++ b/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.md
@@ -0,0 +1,128 @@
+Entered on FLSD Docket 03/06/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRA-
+JANE DOE NO. 5,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND
+TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO INTERROGATORIES
+AND PRODUCTION OF DOCUMENTS
+Defendant,
+Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+respond to Plaintiff's Motion to Compel Answers to Interrogatories And Production of
+Documents, dated March 2, 2009. Local General Rule 7.1 A.1 and Rule 6, Fed. R. Civ.
+P. (2009). Defendant seeks an extension until March 25, 2009, to file his response. As
+good cause in support of granting the motion, Defendant states:
+1. Defendant's response to the motion to compel would be due on March 16, 2009
+(10 days to respond, not including weekends). As certified below, Plaintiff's counsel is
+in agreement with the requested extension of March 25, 2009.
+2. Plaintiff's counsel also represents other Plaintiffs pursuing claims against
+Defendant, EPSTEIN. A total of four of the Plaintiffs have also filed motions to compel
+bearing the same dates. In order to fully and adequately respond to this and the other
+motions, Defendant is in need of an extension until March 25, 2009.
+
+
+Case 9:08-cv-80381-KAM Document 64 Entered on FLSD Docket 03/06/2009 Page 2 of 4
+Jane Doe No. 5 v. Epstein
+Page 2
+3. In addition to the multiple motions to compel, good cause for the extension also
+includes that counsel has been attempting to resolve discovery issues in this and other
+cases against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel
+who works extensively on this case was out of the office for two weeks during the month
+February caring for two of her children who had the flu, and the associate herself also
+caught the flu; Defendant's counsel is also in the midst of preparing for two state court
+trials - one on a March trial docket and the other specially set in mid-May, (OLD
+MARSH GOLF CLUB, INC. v. OLD MARSH PARTNERS, et al, Case No. 50
+2006CA001667XXXXMBAD - set on trial docket beginning March 16, 2009;
+CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A v.
+j. M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+through 15, 2009). Discovery in both of these cases is ongoing with several depositions
+set to prepare for trial.
+4. The requested extension is fair in reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately respond to this
+and the other motions to compel.
+WHEREFORE, Defendant requests that this Court enter an order granting the
+Defendant an extension until March 25, 2009, in which to respond to Plaintiff's Motion to
+Compel Answers to Interrogatories and Production of documents.
+Local Rule 7.1 Certification
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and
+Counsel for Plaintiff is in agreement with the requested extension until March 25, 2009
+
+
+Entered on FLSD Docket 03/06/2009 Page 3 of 4
+Jane Doe No. 5 v. Epstein
+Page 3
+for Defendant to respond to the motion to compel.
+Robert D. Critte
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this le day of March, 2009:
+Adam D. Horowitz, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #5
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRÍTTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+Co-Counsel for Defendant Jeffrey Epstein
+
+
+Entered on FLSD Docket 03/06/2009 Page 4 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRA|
+JANE DOE NO. 5,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+ORDER ON DEFENDANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO
+RESPOND TO PLAINTIFF'S MOTION TO COMPEL ANSWERS TO
+INTERROGATORIES AND PRODUCTION OF DOCUMENTS
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+For Extension of Time in Which to Respond to Plaintiff's Motion to Compel Answers to
+Interrogatories and Production of Documents. Having considered Defendant's motion
+and Plaintiff's counsel being in agreement with the requested extension, it is HEREBY
+ORDERED and ADJUDGED that:
+Defendant's motion is GRANTED. Defendant shall respond to Plaintiff's Motion
+to Compel Answers to Interrogatories and Production of Documents on or before March
+25, 2009.
+DONE and ORDERED this
+day of
+_ 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies: Counsel of Record
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.receipt.json b/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..45e39cf8aa90224ae83b28f2ad5588a02ed0368e
--- /dev/null
+++ b/vision-fixhub/court-01/e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -154,
+  "dataset": "marble-joined",
+  "doc_id": "e3fdda59b5a1758fceb7fb97f7fae8c25168dba3b2626240e5ee96f77abe35ca",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "a3390276d64a8be8f976f38ee1b65d1a3462ba504edbcb4877dc25d599d05e4c",
+  "output_sha256": "5496200a2b2c2feba569412bbb997b2ae0b9bd556d69a0042dab960b908ae8c6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e41099351d7cf71473df7337c168aa78fc4f126a28304b84393c0269aaaef384.md b/vision-fixhub/court-01/e41099351d7cf71473df7337c168aa78fc4f126a28304b84393c0269aaaef384.md
new file mode 100644
index 0000000000000000000000000000000000000000..903fc7f7805a0b409fe1b5f92581a440c7e56df9
--- /dev/null
+++ b/vision-fixhub/court-01/e41099351d7cf71473df7337c168aa78fc4f126a28304b84393c0269aaaef384.md
@@ -0,0 +1,460 @@
+Case: 19194088675RPP@E Draman68 Filed 02463920 PRyge 8191212
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+No. 19 Civ. 8673 (KPF) (DCF)
+Jeffrey E. Epstein,
+Defendants.
+STIPULATED [PROPOSED| PROTECTIVE ORDER
+WHEREAS, certain documents and information have been and may be sought, produced
+or exhibited by and between the Parties to this proceeding (the "Proceeding"), which relate to the
+Parties' personal identifying information, financial information, or other kinds of sensitive
+information that the Party (including any non-Party) making the production deems confidential;
+and
+WHEREAS, it has been agreed by and among the Parties to the Proceeding, through their
+respective counsel, that a Stipulated Protective Order (Protective Order") preserving the
+confidentiality of certain documents and information should be entered by the United States
+District Court for the Southern District of New York; and
+WHEREAS, the Court has reviewed the terms and conditions of this Protective Order
+submitted by the Parties;
+IT IS HEREBY ORDERED that any person subject to this Protective Order—including
+without limitation the Parties to the action; their attorneys, representatives, employees, agents,
+experts, investigators and consultants, acting as such; all third Parties providing discovery in this
+action; and all other interested persons with actual or constructive notice of this Order-shall
+adhere to the following terms, upon pain of contempt:
+Plaintiff's Identity
+1. The Order on Plaintiff's Anonymity (ECF No. 41) governs disclosure of Plaintiff' s
+identity. Nothing in this Protective Order shall be construed as superseding or limiting
+the Order on Plaintiff's Anonymity. In the event of a conflict, the terms of the Order on
+Plaintiff's Anonymity shall govern.
+1
+
+
+Case 1994088675RPAØEr Duman Fier043920 PA292 310122
+Discovery Materials May Be Designated as Confidential Information
+2. A Party (the Plaintiff and Defendants, collectively the "Parties") producing "Discovery
+Material" (i.e., all documents, the information contained therein, and all other
+information produced or disclosed during the Proceeding, whether revealed in a
+document, deposition, other testimony, discovery response, or otherwise) (the "Supplying
+Party") to any other Party (the "Receiving Party") may, through counsel, designate as
+"Confidential Information" any confidential or private personal information (hereinafter
+"Designated Material").
+3. A non-Party producing Discovery Material voluntarily or pursuant to a subpoena or a
+court order may designate such material or information as Confidential Information or
+may redact Financial Information, as described in Paragraph 5, pursuant to the terms of
+this Protective Order. A non-Party's use of this Protective Order to protect its
+Confidential Information and/or Financial Information does not entitle that non-Party
+access to the Confidential Information and/or Financial Information produced by any
+Party in this case.
+4. "Confidential Information" includes but is not limited to:
+a. personally identifying information, including but not limitect to contact
+DF
+information, addresses, phone numbers, email addresses, social security
+numbers, identification card numbers, driver's license numbers, passport
+numbers, or other government identification numbers, and any other
+similar information, but excluding Financial Information (as defined in
+Paragraph 5 below);
+b. medical information, including documents containing medical and/or
+psychological conditions, diagnoses, or treatment, communications with health
+care providers and their staff (including any doctor, surgeon, psychiatrist, dentist,
+nurse, psychologist, therapist, counselor, medical advisor, mental health provider,
+or specialist), and any information that would be protected under The Health
+Insurance Portability and Accountability Act of 1996 ("HIPAA");
+c. any material or portion thereof that contains trade secrets, proprietary
+business information, or other information the disclosure of which
+would, in the good faith judgment of the designating person, be
+seriously detrimental to the producing person's business or personal
+interests;
+d. any material or information that could be used to identify Plaintiff, including, but
+not limited to, images, recordings, names of family members, past or current
+employers; and
+2
+
+
+Case: 19194088675RPP@E Draman68 Filed 02463920 PRygs 3191212
+e. any other category of information given confidential status by this Court after the
+date of this Order.
+5. The Supplying Party must redact unique identifiers pertaining to financial records,
+including bank account numbers, credit card numbers, usernames and passwords
+("Financial Information"). Documents containing Financial Information shall be
+redacted but shall not be designated as Confidential Information in full solely on the
+grounds that they contain Financial Information.
+6. In designating material as Confidential Information, the Supplying Party will make such
+designation only as to that material that it in good faith believes to be entitled to such
+treatment pursuant to this Protective Order.
+7. Discovery Material produced by a Supplying Party shall, if appropriate, be designated as
+Confidential Information by marking the first page of the document and each subsequent
+page thereof containing Confidential Information as follows:
+
+All Confidential Information not reduced to documentary, tangible, or physical form,
+or which cannot be conveniently designated by marking it shall be designated by the
+Supplying Party informing the Receiving Party of the designation in writing.
+8. A Party or non-Party (or its counsel) may designate as Confidential Information
+testimony disclosed at a deposition taken in connection with this Proceeding by:
+a. designating testimony given on the record during the taking of the deposition, in
+which case the court reporter shall mark each page as provided in Paragraph 7,
+above; or
+b. notifying all other Parties in writing, within thirty (30) calendar days of receipt of
+the transcript of a deposition of specific pages and lines of the transcript which are
+designated as Confidential Information.
+Whereupon each Party shall attach a copy of such written designation to the face of the
+transcript and each copy thereof in that Party's possession, custody, or control. During
+the 30-day period following a deposition, all Parties will treat the entire deposition
+transcript as if it had been designated Confidential Information.
+Who May Receive Designated Material
+9. Designated Material shall be disclosed by the Receiving Party only to the following
+persons:
+a. the Parties to this action;
+3
+
+
+Case: 19194088675RPP@E Draman68 Filed 02463920 PRyga 6101212
+b. counsel retained specifically for this action, including any paralegal, clerical, or
+other assistant employed by such counsel to work on this action;
+c. as to any document, its author, its addressee, and any other person shown on the
+face of the document as having received a copy;
+d. any witness who counsel for a Party in good faith intends to call to testify at trial
+or deposition in this action, provided such person, other than those persons set
+forth in subparagraphs 9 (a), (b), and (c) has first executed a Non-Disclosure
+Agreement in the form annexed hereto as Exhibit A (the "Non-Disclosure
+Agreement") and only to the extent necessary to prepare the witness to testify;
+e. any person retained by a Party to serve as an expert witness or consultant or
+otherwise provide specialized advice to counsel in connection with this action,
+provided such person has first executed the Non-Disclosure Agreement, and
+further provided that any such support staff are subject to contractual or
+professional duties of confidentiality with respect to such material;
+f. stenographers and video technicians engaged to transcribe or record depositions
+conducted in this action, provided such persons are subject to contractual or
+professional duties of confidentiality with respect to such material;
+g. independent photocopying, graphic production services, or other litigation support
+services employed by the Parties or their counsel to assist in this action, including
+computer service personnel performing duties in relation to a computerized
+litigation system, provided such persons are subject to contractual or professional
+duties of confidentiality with respect to such material;
+h. the Court and its staff;
+i. any mediators engaged by the parties;
+j. any claims administrator for the Epstein Victims' Compensation Program and
+such administrator's support staff, if, and only if, Plaintiff chooses to participate
+in said program; and
+k. any other person whom the producing person, or other person designating the
+Discovery Material as Confidential, agrees in writing may have access to such
+Designated Material.
+10. Counsel shall take all reasonable and necessary steps to ensure the security of any
+Designated Material and will limit access to Designated Material to those persons listed
+in Paragraph 9 of this Protective Order.
+4
+
+
+Case: 19194088675RPP@E Draman68 Filed 02463920 Paggs 5191212
+11. All persons to whom Designated Material is to be disclosed pursuant to Subparagraphs 9
+(c)-(g) and (i) as applicable above, as well as Plaintiff and Defendants, shall, prior to
+disclosure, be advised of the contents of this Stipulation and Protective Order and be
+required to execute the Non-Disclosure Agreement evidencing their agreement to the
+terms of the Protective Order. To the extent that any such person refuses to sign the Non-
+Disclosure Agreement, a Party may seek proper recourse including, but not limited to, an
+order directing that such person is subject to the terms set forth herein.
+12. Counsel for the Party that obtains signed Non-Disclosure Agreements, as required
+herein, shall retain them for six (6) months following the final termination of this
+Proceeding, including any appeals, and shall make them available to the other Party upon
+good cause shown. Counsel of record shall maintain a list of the names of all persons to
+whom such Designated Material is disclosed and such list shall be available for
+inspection by counsel for the Party claiming confidentiality upon order of the Court
+following a show of good cause.
+13. Nothing shall prevent disclosure beyond the terms of this Protective Order if the
+Supplying Party (or its counsel) designating the material as Confidential Information
+consents in writing to such disclosure, or if the Court, after reasonable written notice to
+all affected Parties, orders such disclosure.
+14. Any Party may request at any time permission to disclose Designated Material to a
+person other than those permitted under Paragraph 9 above or to use such information in
+a manner prohibited by this Protective Order, by serving a written request upon the
+Supplying Party's counsel. Any such request shall state the Designated Material the
+Party wishes to disclose, to whom it wishes to make disclosure, and the reason(s) and
+purposes) therefore. The Supplying Party or its counsel shall thereafter respond to the
+request in writing (by hand delivery, courier, or email transmission) as soon as
+practicable, but within ten (10) business days of its receipt of such request. If consent is
+withheld, the Supplying Party or its counsel shall state the reasons why it is withholding
+such consent. If, where consent is withheld, the requesting Party and the Supplying Party
+are subsequently unable to agree on the terms and conditions of disclosure, disclosure
+may only be made in accordance with the Supplying Party's designation of the material
+as Confidential Information (i.e., the requesting Party may disclose the Designated
+Material only as permitted under Paragraph 9 above) unless and until differing treatment
+is directed pursuant to an order of the Court.
+Responding to a Subpoena
+15. In the event a Party or non-party having possession, custody, or control of any
+Designated Material received as part of this Proceeding receives a subpoena or other
+process or order to produce such information, such subpoenaed Party or non-party shall
+5
+
+
+Case: 19194088675RPP@E Draman68 Filed 02463920 PRy98 6191212
+promptly notify by e-mail the attorneys of record of the Supplying Party (or, if the
+subpoenaed person is a non-party, the Parties) and shall furnish those attorneys with a
+copy of said subpoena or other process or order. The Party or non-party receiving the
+subpoena or other process or order shall not produce the requested Designated Material
+unless and until a court of competent jurisdiction so directs, except if the Supplying Party
+(a) consents, or (b) fails to file a motion to quash or fails to notify the Party or non-party
+receiving the subpoena or other process in writing of the Supplying Party's intention to
+contest the production of the Designated Material prior to the date designated for
+production of the subpoenaed information, in which event the Party or non-party who
+received the subpoena or other process may produce on the designated production date,
+but no earlier. The Supplying Party asserting the confidential treatment shall have the
+burden of defending against such subpoena, process, or order. The Party or non-party
+receiving the subpoena or other process or order shall be entitled to comply with it except
+to the extent the Party asserting the confidential treatment is successful in obtaining an
+order modifying or quashing it.
+Later Designation of Confidential Information
+16. Any Supplying Party may designate as Confidential Information (or withdraw a
+designation regarding) any material that it has produced; provided, however, that such
+designation shall be effective only as of the date of such designation. Such designation
+shall be accomplished by providing written notice to counsel of record for each Party
+identifying (by production number, transcript line and page number, or other individually
+identifiable information) the document, testimony, or other information whose
+designation is to be changed and, promptly after providing such notice, by providing relabeled copies of the material to the Receiving Party reflecting the new
+designation. Upon receipt of any such written designation, counsel of record shall: (i) not
+make any further disclosure or communication of such newly Designated Material except
+as provided for in this Protective Order; (ii) take reasonable steps to notify any persons
+known to have possession of any newly Designated Material of the treatment of such
+material required under this Protective Order pursuant to the designation; (iii) promptly
+endeavor to procure all copies of such newly Designated Material from any persons
+known to have possession of any such Designated Material who are not entitled to receipt
+of Designated Material under Paragraph 9 above; and (iv) replace the newly Designated
+Material with the re-labeled copies of the material and make reasonable efforts to destroy
+the copies of the Designated Material produced prior to such designation.
+Objecting to Designations of Confidential Information
+17. Any Party may object to the propriety of the designation or the lack of designation of
+specific material as Confidential Information or Financial Information (the "Objecting
+Party"). A Party shall not be obliged to challenge the propriety of the designation at the
+6
+
+
+Case: 19194088675RPP@E Draman68 Filed 02463920 Payage 8191212
+time of production or later designation, and failure to do so shall not preclude a
+subsequent challenge thereto. The Objecting Party should serve a written objection upon
+the Supplying Party's counsel who shall thereafter, within ten (10) business days, respond
+to such objection in writing (by hand delivery, courier, or email transmission) by either:
+(i) agreeing to remove, change, or add the designation; or (ii) stating the reasons for such
+designation or lack thereof. If the Objecting Party and the Supplying Party are
+subsequently unable to agree upon the terms and conditions of disclosure for the
+material(s) in issue, the Objecting Party shall be free to move the Court for an Order
+removing or modifying the disputed designation or lack thereof. On such a motion, it
+will be the burden of the Party imposing a limitation on circulation of discovery materials
+to justify that limitation. The material(s) in issue shall continue to be treated in the
+manner imposing the greatest limitation on circulation sought by a Party until the Court
+orders otherwise.
+Inadvertent Disclosure of Confidential Information
+18. If a Receiving Party receives documents or other materials that it has reason to believe
+are subject to a good faith claim of attorney-client privilege, work product protection, or
+other privilege or immunity from disclosure, the receiving party must refrain from
+examining the documents or other materials any more than is essential to ascertain
+whether the documents or other materials are reasonably subject to such a claim. The
+Receiving Party shall promptly notify the Supplying Party in writing that the Receiving
+Party possesses documents or other material that appears to be privileged or otherwise
+protected from disclosure.
+19. If, in connection with this litigation, a Supplying Party inadvertently discloses
+information that is subject to a claim of attorney-client privilege, attorney work product
+protection, or any other privilege or immunity from disclosure ("Inadvertently Disclosed
+Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of
+any claim of privilege, work product protection, or other privilege or immunity from
+discovery with respect to the Inadvertently Disclosed Information or its subject matter.
+In addition, a Supplying Party may use its own document (e.g., as a deposition exhibit)
+containing material that is subject to a claim of privilege or immunity from disclosure for
+the purpose of establishing the basis of such claim without waiver of any applicable
+rivilege or immunity from disclosure, unless the producing person attirmatively uses o
+lies upon the specific material contained in the document that is subiect to the claim o
+privilege or immunity from disclosure for any purpose other than establishing the basis of
+such claim.
+20. If a Supplying Party makes a claim of inadvertent disclosure, the Receiving Party shall,
+within five business days, return or destroy all copies of the Inadvertently Disclosed
+Information, and provide a certification of counsel that all such information has been
+returned or destroyed.
+7
+
+
+Case 1994088675RPAØEr Dman68 Filer043920 PA298 810122
+21. Within five business days after the notification that such Inadvertently Disclosed
+Information has been returned or destroyed, the Supplying Party shall produce a privilege
+log with respect to the Inadvertently Disclosed Information.
+22. The Receiving Party may move the Court for an Order compelling production of the
+Inadvertently Disclosed Information. Pursuant to the Parties' obligations set forth herein,
+the motion shall not quote or paraphrase the substance of the document subject to the
+motion to compel beyond the description of the document contained in the privilege log
+entry for the document. The motion shall be filed under seal, and shall not assert as a
+ground for entering such an Order the fact or circumstances of the inadvertent production
+in this action.
+23. The Supplying Party retains the burden of establishing the privileged or protected nature
+of any Inadvertently Disclosed Information. Nothing in this Order shall limit the right of
+any Supplying Party or Receiving Party to request an in camera review of the
+Inadvertently Disclosed Information.
+Filing Designated Material in This Action
+24. All Designated Material that is filed with the Court, or any pleadings, motions or other
+papers filed with the Court that reveals any information that has been designated as
+Confidential Information by any Party or non-Party, shall be filed as redacted or under
+seal consistent with Section 1.C of Magistrate Judge Freeman's Individual Practices,
+Section 9 of Judge Failla's Individual Rules of Practice in Civil Cases, and the Court's
+Order on Plaintiff's Anonymity (ECF No. 41).
+25. Prior to filing with the Court Designated Material, the Parties shall meet and confer
+concerning any redactions, and cooperate in seeking to resolve any disputed issues of
+confidentiality. The Party intending to file the Designated Material with the Court shall
+make all reasonable efforts to provide the redacted documents) to the other Party for
+review two (2) business days prior to filing. If the Parties cannot resolve a dispute arising
+from this Paragraph, they shall follow the procedures set forth in Section 1.C of
+Magistrate Judge Freeman's Individual Practices or Section 3.C of Judge Failla's
+Individual Rules of Practice in Civil Cases.
+Use of Confidential Information/Designated Material
+26. Persons having knowledge of Confidential Information only by virtue of their
+participation in the Proceeding shall use that Confidential Information only in connection
+with the Proceeding or appeal thereof, and shall neither use such Confidential
+Information for any other purpose nor disclose such Confidential Information to any
+person who is not listed in Paragraph 9 of this Protective Order.
+8
+
+
+Case 1994088675RPABEr Duman Filled#3920 PA299 810122
+27. Designated Material, any copies and/or extracts thereof, and anything derived therefrom,
+shall not be disclosed in any way for use in any other litigation or contemplated litigation,
+or for any other purpose extraneous to this Proceeding.
+28. Nothing in this Protective Order shall restrict any Party's counsel from rendering advice
+to its clients with respect to this Proceeding and, in the course thereof, relying upon
+Designated Material, provided that in rendering such advice, counsel shall not disclose
+any other Party's Designated Material, other than in a manner provided for in this
+Protective Order.
+29. If Designated Material is used during depositions or in preparing a witness for testimony,
+it shall not lose its status through such use, and counsel shall exercise their best efforts
+and take all steps reasonably required to protect its designated status during such use.
+30. Nothing herein shall be construed to affect in any manner the admissibility at trial of any
+document, testimony or other evidence, or to affect any Party's right to assert that
+documents or information may be withheld on grounds of relevance, privilege, or any
+other ground.
+31. Nothing contained in this Protective Order will be construed as: (a) a waiver by a Party or
+person of its right to object to any discovery request; (b) a waiver of any privilege or
+protection; or (c) a ruling regarding the admissibility at trial of any document, testimony,
+or other evidence.
+32. Nothing contained in this Protective Order prejudices a Party's ability to seek discovery
+in this and any other legal proceeding, without prejudice to any other Party's right to
+object to such discovery.
+33. Nothing in this Protective Order shall prevent any Party from seeking further protection
+with respect to the use of any such Designated Material in connection with the trial, a
+hearing, or other proceeding in this litigation.
+34. Nothing contained herein shall preclude any Party from using its own Designated
+Material in any manner it sees fit, without prior consent of any Party or the Court.
+Improper Disclosure of Designated Material
+35. If Designated Material is disclosed to any person other than in the manner authorized by
+this Protective Order, the Party responsible for the disclosure shall, immediately upon
+learning of such disclosure, inform the Supplying Party of all pertinent facts relating to
+such disclosure and make all reasonable efforts to recover all copies of the Designated
+Material and prevent further disclosure or dissemination by each unauthorized person
+who received such Designated Material.
+9
+
+
+Case:19194088675RP₽BE DramAn 0#3½0 Pay920910{212
+36. In the event of a proven willful violation of this Protective Order by any Party in this
+action or others designated in Paragraph 9 hereof, all Parties acknowledge that the
+offending Party or persons may be subject to sanctions determined in the discretion of the
+Court.
+Destruction of Designated Material
+37. Upon the conclusion of the Proceeding, including any appeals related thereto, at the
+written request and option of the Supplying Party, all Designated Material and any and all
+copies shall be returned or destroyed within sixty (60) calendar days of receipt of the
+request to the Supplying Party; provided, however, that attorney work product, briefs and
+other court papers prepared for use in this Proceeding need not be returned or destroyed,
+but may be retained only by the Parties' counsel and, if so retained, shall continue to be
+maintained as Confidential in accordance with the provisions of this Stipulation.
+Notwithstanding the foregoing, Designated Material that has been received electronically
+and that cannot be returned or destroyed must be electronically deleted and deleted from
+"trash" files, and the Receiving Party must take reasonable measures to ensure that
+unauthorized persons do not have access to Designated Material residing on the
+recipient's computer server and back-up media.
+Retention of Jurisdiction
+38. The foregoing provisions concerning confidentiality of Designated Material shall
+continue through the trial and any appeals related to this Proceeding, unless otherwise
+modified by agreement of the Parties or order of the Court. The Parties shall be free to
+use any admissible Designated Material at trial and any appeals related to this Proceeding
+but shall work together to fashion appropriate measures to limit the disclosure of such
+Designated Materials to the general public. The Court shall issue any relief, if necessary,
+prior to trial or to the hearing in open court upon motion or agreement of the Parties.
+39. The terms of this Protective Order may be amended or modified by written agreement of
+the Parties or upon motion and order of the Court. This Protective Order shall continue
+in force until amended or superseded by express order of the Court and shall survive any
+final judgment or settlement in this Proceeding.
+Time of Effect
+40. This Protective Order shall become effective as between the Parties immediately upon
+submission to the Court for approval, notwithstanding the pendency of approval by the
+Court. If approval by the Court is ultimately denied, withheld, or made conditional, no
+10
+
+
+Case: 1994088675RDSE DruMn F0#90 PAy9$118591212
+The Parties, by their counsel, hereby consent to entry of the foregoing Order:
+Dated: New York, New York
+April 28, 2020
+Respectfully Submitted,
+By:
+Roberta A. Kaplan
+Kate L. Doniger
+Alexandra Conlon
+Kyla P.S. Magun
+Louis W. Fisher
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, NY 10118
+(212) 763-0883
+rkaplan@kaplanhecker.com
+kdoniger@kaplanhecker.com
+aconlon@kaplanhecker.com
+kmagun@kaplanhecker.com
+Ifisher@kaplanhecker.com
+Attorneys for Plaintiff Jane Doe
+BJM /KPsm
+Bennet J. Moskowitz
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, NY 10022
+Telephone: (212) 704-6000
+Bennet.Moskowitz@troutman.com
+Attorney for Defendants
+Indyke and Richard D. Kahn, Co-
+Executors of the Estate of Jeffrey E.
+Epstein
+IT IS SO ORDERED this 30
+_day of April
+Ala Im
+The Hon. Debra Freeman
+United States Magistrate Judge
+_ 2020
+As modified in paragraph 4(a).
+11
+
+
+Case:19194088675RPPE DrummF#3½ Pa99218101212
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff.
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+Jeffrey E. Epstein,
+Defendants.
+No. 19 Civ. 8673 (KPF) (DCF)
+NON-DISCLOSURE
+AGREEMENT
+, acknowledge that I have read and understand the
+Protective Order in this action governing the non-disclosure of Designated Material (the
+"Protected Material"). I agree that (1) I will hold in confidence all Protected Material to the
+extent required by the Protective Order and agree to be bound by the terms of that Order; (2) |
+will use such Protected Material only for purposes of this litigation and for no other purpose
+whatsoever; and (3) I will take all due precautions to prevent the unauthorized or inadvertent
+disclosure of such Protected Material.
+By acknowledging these obligations under the Protective Order, I understand that I am
+submitting myself to the jurisdiction of the United States District Court for the Southern
+District of New York for the purpose of any issue or dispute arising hereunder, and that my
+willful violation of any term of the Protective Order could subject me to punishment for
+contempt of court.
+Dated:
+[Signature]
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+Case 1:20-cv-00484-JGK-DCF Document 4
+Filed 01/17/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE
+Plaintiff,
+-against-
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN, et.al
+Defendant.
+1:20- Civ. 00484
+MOTION FOR ADMISSION
+PRO HAC VICE
+_(
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern
+Districts of New York,
+Kevin R. Boyle
+hereby move this Court
+for an Order for admission to practice Pro Hac Vice to appear as counsel for
+Jane Doe
+_in the above-captioned action.
+I am in good standing of the bar(s) of the state(s) of_ California and Washington D.C
+_and
+there are no pending disciplinary proceedings against me in any state or federal court. I have
+never been convicted of a felony. I have never been censured, suspended, disbarred or denied
+admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+Dated: January 10, 2020
+Respectfully Submitted,
+Kevin R. Boyle
+Apiam Siame 1181
+Applicant's Name:_ Kevin R Boyle
+Firm Name:_PANISH SHEA & BOYLE, LLP
+Address:_11111 Santa Monica Blvd. Ste 700
+City/State/Zip:_ Los Angeles, California 90025
+Telephone/Fax:_310-477-1700/ 310-477-1699
+Email:_Boyle@psblaw.com
+
+
+Case 1:20-cv-00484-JGK-DCF Document 4 Filed 01/17/20 Page 2 of 3
+DOBAR
+• •
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,
+the District of Columbia Bar does hereby certify that
+Kevin RBoyle
+was duly qualified and admitted on June 4, 1999 as an attorney and counselor entitled to
+practice before this Court; and is, on the date indicated below, an Active member in good
+standing of this Bar.
+In Testimony Whereof,
+I have hereunto subscribed my
+name and affixed the seal of this
+Court at the City of
+Washington, D.C., on January
+16, 2020.
+Gulis i. Entelle
+JULIO A. CASTILLO
+Clerk of the Court
+Issued By:
+District of Columbia Bar Membership
+For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email
+memberservices@dcbar.org.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 4
+Filed 01/17/20
+
+The State Bar
+of California
+180 Howard Street, San Francisco, CA 94105
+888-800-3400
+OFFICE OF ATTORNEY REGULATION
+& CONSUMER RESOURCES
+AttorneyRegulation@calbar.ca.gov
+CERTIFICATE OF STANDING
+January 11, 2020
+TO WHOM IT MAY CONCERN:
+This is to certify that according to the records of the State Bar, KEVIN RICHARD
+BOYLE, #192718 was admitted to the practice of law in this state by the Supreme
+Court of California on December 11, 1997 and has been since that date, and is at
+date hereof, an ACTIVE licensee of the State Bar of California; and that no
+recommendation for discipline for professional or other misconduct has ever been
+made by the Board of Trustees or a Disciplinary Board to the Supreme Court of the
+State of California.
+THE STATE BAR OF CALIFORNIA
+Dina DiLoreto
+Custodian of Records
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diff --git a/vision-fixhub/court-01/e4377260dc77e90d8786811d9ac0fe2fde531866952ee8b4eec82794dd4641a3.md b/vision-fixhub/court-01/e4377260dc77e90d8786811d9ac0fe2fde531866952ee8b4eec82794dd4641a3.md
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@@ -0,0 +1,563 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+-V.-
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the Estate
+of Jeffrey E. Epstein,
+19 Civ. 8673 (KPF)
+OPINION AND ORDER
+Defendants.
+KATHERINE POLK FAILLA, District Judge!:
+Plaintiff Jane Doe? brings this action under New York law against
+Darren K. Indyke and Richard D. Kahn in their capacities as appointed
+executors of the Estate of Jeffrey Epstein (together, "Defendants"). Plaintiff
+asserts tort claims for sexual assault, sexual battery, intentional infliction of
+emotional distress, and negligent infliction of emotional distress, for which she
+seeks actual, compensatory, statutory, consequential, and punitive damages.
+Defendants seek to dismiss Plaintiff's claim for punitive damages, arguing that:
+(i) New York law applies to the punitive damages claim because the torts
+allegedly occurred in New York; (ii) New York law bars the recovery of punitive
+damages against a decedent tortfeasor's estate; and (iii) even if the law of the
+United States Virgin Islands ("USVI") were to apply, it also would prohibit the
+recovery of punitive damages against a decedent tortfeasor's estate. For the
+arah Pyun, a rising second-year student at Fordham Law School and an intern in m
+provided substantial assistance in researching and drafting this Opinion
+Plaintiff has been granted leave to proceed pseudonymously. (Dkt. #26).
+
+
+reasons explained below, the Court dismisses Plaintiff's claim for punitive
+damages.
+BACKGROUND3
+A.
+Factual Background
+The Court accepts as true the well-pleaded allegations of the Complaint
+for purposes of this motion. In broad summary, Plaintiff presents a disturbing
+and corrosive pattern of sexual abuse and emotional manipulation of herself
+and others over the course of three years by Jeffrey Epstein. (Compl. 11 15-
+60). At all times relevant to this suit, Plaintiff was an economically
+disadvantaged minor child living in New York City. (Id. at 11 12, 22). She was
+raised by her single mother for the majority of her life. (Id. at 1 21). Financial
+hardships afflicted Plaintiff and her family throughout her childhood, in part
+because of the extensive medical care required to treat Plaintiff's younger
+sister, who suffered from serious medical conditions. (Id. at 1 22).
+In or around 2002, when Plaintiff was approximately fourteen years old,
+she learned of Epstein through an older teenage girl from her neighborhood,
+who approached Plaintiff with an opportunity to meet a "wealthy man" and
+earn money. (Compl. 1 23). By that time, Plaintiff had been forced to move out
+of her home and take on certain jobs after school to help support her family.
+(Id. at 1 24). As a result, Plaintiff agreed to meet Epstein. (Id.). The older
+3
+The facts contained in this Opinion are drawn primarily from Plaintiff's Complaint
+("Complaint" or "Compl." (Dkt. #1)), which is the operative pleading in this case.
+For ease of reference, the Court refers to Defendants' opening brief as "Def. Br." (Dkt
+#47); Plaintiff's opposition brief as "PI. Opp." (Dkt. #51); Defendants' reply brief as "Def
+Reply" (Dkt. #55); and Plaintiff's Reply Letter as "Pl. Rep. Lt." (Dkt. #62).
+2
+
+
+teenage girl brought Plaintiff to Epstein's Upper East Side mansion, where they
+waited in a room until Epstein arrived, wearing only a robe. (Id. at 11 25-27).
+Epstein asked Plaintiff her name and age, to which she responded truthfully.
+(Id.). With this knowledge, Epstein began to test Plaintiff's boundaries by
+engaging in escalating levels of sexual abuse on numerous occasions, paying
+her several hundred dollars after each encounter. (Id. at 11 42-43).
+The Complaint is harrowing in its detail of how Epstein's actions and
+demands intensified over the course of three years, to the point where he
+caused Plaintiff physical pain by forcing her to express pleasure as he violated
+her. (Compl. 11 34-44). The Complaint further alleges that Epstein was aided
+by his associates, who allowed, facilitated, and participated in his abuse of
+Plaintiff and other young women. (Id. at 11 45-53). As Plaintiff grew financially
+reliant on Epstein, she stopped attending school to spend her time "working" at
+his home, gratifying him sexually, or bringing other girls to do the same, just
+as she had been brought to him initially. (Id. at 9| 41). Epstein's conduct, for
+which the adjective egregious seems an understatement, caused Plaintiff to
+develop post-traumatic stress disorder; she continues to suffer from lasting
+emotional repercussions that have affected her mental health, family life, and
+education. (Id. at 11 54-80).
+Plaintiff was one of several minor victims who suffered sexual abuse and
+exploitation at the hands of Epstein. (Compl. 91| 43-44). In July 2019, Epstein
+was indicted in this District for his decades-long child abuse scheme after an
+investigation to which Plaintiff contributed by cooperating, confidentially, with
+3
+
+
+authorities. (Id. at 19 61-62). On August 8, 2019, two days before his reported
+suicide, Epstein executed his last will and testament (the "Will"), which
+provided for his Estate to be probated in the USVI. (Id. at 11 63-65). Epstein
+appointed Defendants to administer his Estate. (Id. at 11 65, 67-68). Plaintiff
+seeks to obtain recovery from the Estate for the years of pain and suffering
+Epstein inflicted on her. (Id. at 11 6, 63).
+B. Procedural History
+Plaintiff filed the Complaint in this action on September 18, 2019. (Dkt.
+#1). The Complaint seeks relief for actual, compensatory, statutory,
+consequential, and punitive damages. (Compl. | 88). On November 1, 2019,
+Plaintiff filed a letter notifying the Court of several cases brought by other
+plaintiffs against the Epstein Estate alleging similar claims of sexual abuse.
+(Dkt. #16). All such cases, including the present one, were later consolidated
+for discovery purposes before Magistrate Judge Debra Freeman. (Dkt. #23).
+On December 2, 2019, Defendants filed a letter requesting a pre-motion
+conference concerning their anticipated motion to dismiss Plaintiff's punitive
+damages claim. (Dkt. #35). Plaintiff filed a letter in opposition on August 4,
+2019. (Dkt. #36). The Court held a pre-motion conference on December 11,
+2019. (Dkt. #40 (transcript)). Following the conference, the Court set a
+briefing schedule and denied a stay of discovery pending resolution of
+Defendants' motion to dismiss. (Dkt. #39).
+On January 15, 2020, Defendants filed their partial motion to dismiss,
+arguing that New York law applies to the issue of punitive damages because
+4
+
+
+the alleged torts occurred in New York and, further, that as a matter of New
+York law, punitive damages cannot be recovered against personal
+representatives of an estate. (Dkt. #46, 47).4 Defendants further argue that
+even if USVI law were to apply, as Plaintiff claims, punitive damages would still
+be unavailable. (Id.). On February 14, 2020, Plaintiff filed a memorandum of
+law in opposition to Defendants' motion. (Dkt. #51). The memorandum was
+supported by a declaration from Roberta A. Kaplan, Esq., that attached copies
+of Epstein's Will and the Complaint filed in Government of the United States
+Virgin Islands v. Estate of Jeffrey E. Epstein, et al., ST-20-CV-14 (V.I. Super. Ct.
+Jan. 15, 2020). (Dkt. #52). Defendants filed a reply brief on February 28,
+2020. (Dkt. #55).
+On April 28, 2020, Defendants filed a letter notifying the Court of
+supplemental authority from a sister court in this District. (Dkt. #61). Plaintiff
+filed a reply letter on April 29, 2020. (Dkt. #62). On April 30, 2020,
+Defendants filed a letter with additional supplemental authority. (Dkt. #64).
+And on June 19, 2020, Defendants filed a letter with still further supplemental
+Plaintiff contends that Defendants' motion is more properly denominated a motion to
+strike under Federal Rule of Civil Procedure 12(t), inasmuch as the motion does not
+seek to dismiss any of Plaintiff's four causes of action, but rather seeks to excise
+Plaintiff's demand for punitive damages. (See Pl. Opp. 1 n.1). As a sister court in this
+District concluded in Mary Doe v. Indyke, — F. Supp. 3d -, No. 19 Civ. 10758 (PAE),
+2020 WL 2036707, at *4 (S.D.N.Y. Apr. 28, 2020), this Court need not weigh in on this
+conceptual debate because Defendants' motion to dismiss under Rule 12(b)(6) can,
+alternatively, be treated as a motion to strike under Rule 12(f). See 5C Charles A.
+& Alan R.
+_. FEDERAL PRACTICE AND PROCEDURE § 1380 (3d ed.) (*|T]he
+technical name given to a motion challenging a pleading is of little importance
+inasmuch as prejudice to the nonmoving party hardly can result from treating a motion
+that has been inaccurately denominated a motion to strike as a motion to dismiss the
+complaint.").
+5
+
+
+authority. (Dkt. #75). Accordingly, the motion is fully briefed and ripe for
+decision.
+DISCUSSION
+A. Applicable Law
+When a court considers a motion to dismiss under Federal Rule of Civil
+Procedure 12(b)(6), it must "draw all reasonable inferences in Plaintiff|'s] favor,
+assume all well-pleaded factual allegations to be true, and determine whether
+they plausibly give rise to an entitlement to relief." Faber v. Metro. Life Ins. Co.,
+648 F.3d 98, 104 (2d Cir. 2011) (quoting Selevan v. N.Y. Thruway Auth., 584
+F.3d 82, 88 (2d Cir. 2009)) (internal quotation marks omitted). A plaintiff will
+survive a motion to dismiss if she alleges "enough facts to state a claim to relief
+that is plausible on its face." Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570
+(2007); see also In re Elevator Antitrust Litig., 502 F.3d 47, 50 (2d Cir. 2007)
+("While Twombly does not require heightened fact pleading of specifics, it does
+require enough facts to nudge [a plaintiff's] claims across the line from
+conceivable to plausible." (internal quotation marks and citation omitted)).
+The Court is not, however, bound to accept "conclusory allegations or
+legal conclusions masquerading as factual conclusions." Rolon v. Henneman,
+517 F.3d 140, 149 (2d Cir. 2008) (citation omitted); see also Harris v. Mills, 572
+F.3d 66, 72 (2d Cir. 2009) ("[A]lthough a court must accept as true all of the
+allegations contained in a complaint, that tenet is inapplicable to legal
+conclusions, and threadbare recitals of the elements of a cause of action,
+
+
+supported by mere conclusory statements, do not suffice." (internal quotation
+marks, brackets, and citation omitted)). 5
+B. Analysis
+The issue before the Court concerns whether the executors of Epstein's
+Estate may be held liable for punitive damages — recovery that would
+indisputably be available were Epstein still alive. (Pl. Opp. 2; Def. Reply 1).
+Defendants assert at the outset that New York estate law, rather than USVI
+law, applies to bar punitive damages against executors of an estate in a
+personal injury suit. (See Def. Br. 1-2). Plaintiff maintains that USVI law
+governs her punitive damages claim and allows it to stand, but that even if New
+York law applied, relevant choice-of-law rules enable her to bring this action
+under USVI law. (See Pl. Opp. 1-2, 17-18). By contrast, Defendants argue
+that, even under USVI law, punitive damages are unavailable. (See Def. Br. 4-
+6). The Court addresses each of these arguments in turn.
+5
+A similar analysis would obtain were the motion construed as one to strike Plaintiff's
+claim for punitive damages. Under Rule 12(f) of the Federal Rules of Civil Procedure, a
+party may move to "strike from a pleading an insufficient defense or any redundant,
+immaterial, impertinent, or scandalous matter." Fed. R. Civ. P. 12(f). Courts in this
+District have found that "[t)he standard that applies to a motion to strike is the 'mirror
+image' of the standard on a 12(b)(6) motion to dismiss for failure to state a claim." Bd.
+of Managers of Trump Tower at City Ctr. Condo. v. Palazzolo, 346 F. Supp. 3d 432, 471
+(S.D.N.Y. 2018) (internal citations and quotations omitted); see generally Rosa v. TCC
+Commens, Inc., No. 15 Civ. 1665 (WHP), 2016 WL 67729, at *7 (S.D.N.Y. Jan. 5, 2016)
+(granting motion to strike punitive damages claim). Courts have also observed that
+such motions are "generally disfavored." Oram v. SoulCycle LLC, 979 F. Supp. 2d 498,
+511 (S.D.N.Y. 2013).
+7
+
+
+1.
+The New York Statute Authorizing Personal Injury Actions
+Against a Decedent's Estate Precludes Punitive Damages
+Claims in Such Actions
+To begin, Defendants seek dismissal of Plaintiff's punitive damages claim
+on the ground that New York law bars such claims in personal injury suits
+against representatives of a decedent's estate. The statute in question, § 11-
+3.2(a)(1) of New York's Estates, Powers and Trusts Law ("EPTL"), provides:
+No cause of action for injury to person or property is lost
+because of the death of the person liable for the injury.
+For any injury, an action may be brought or continued
+against the personal representative of the decedent, but
+punitive damages shall not be awarded nor penalties
+adjudged in any such action brought to recover damages
+for personal injury.
+EPTL § 11-3.2 (a)(1) (emphasis added).
+As three recent cases in this District, presenting similar claims against
+the same Defendants, have recognized, this provision clearly prohibits the
+award of punitive damages in the situation at hand. See Mary Doe v. Indyke,
+— F. Supp. 3d —, No. 19 Civ. 10758 (PAE), 2020 WL 2036707, at *3 (S.D.N.Y.
+Apr. 28, 2020) (holding that EPTL § 11-3.2(a)(1) involves a categorical
+preclusion of punitive damages against a deceased tortfeasor's estate); see also
+Lisa Doe v. Indyke, No. 19 Civ. 7773 (ER), 2020 WL 3073219, at *14-15
+(S.D.N.Y. June 9, 2020) (same); Doe 15 v. Indyke, No. 19 Civ. 10653 (PAE),
+2020 WL 2086194, at *2 (S.D.N.Y. Apr. 30, 2020) ("New Mexico common law as
+announced by the state supreme court, like EPTL § 11-3.2(a)(1), bars punitive
+damages in a personal injury action against a tortfeasor's estate."). Both
+federal courts addressing constitutional-tort claims under New York law, and
+8
+
+
+state courts in personal injury actions governed by New York law, have
+concluded similarly. See Mary Doe, 2020 WL 2036707, at *2 (collecting New
+York federal and state cases).
+This position is also reflected in the majority of United States
+jurisdictions, as the Restatement (Second) of Torts indicates. See Restatement
+(Second) of Torts § 908 cmt. a (Am. Law Inst. 1979) ("Punitive damages are not
+awarded against the representatives of a deceased tortfeasor."). The common
+justification for the majority rule is that "punishment and deterrence — the
+recognized bases for imposing punitive damages on a tortfeasor — are not
+advanced by imposing punitive damages on his or her estate." Mary Doe, 2020
+WL 2036707, at *3; see also Blissett v. Eisensmidt, 940 F. Supp. 449, 457
+(N.D.N.Y. 1996) (brackets and citation omitted) ("There is a strong policy
+against the assessment of punitive damages against an estate on account of
+wrongful conduct of the decedent.").
+Thus, as a threshold matter under New York law, punitive damages are
+unavailable in a case against personal representatives of a decedent tortfeasor's
+estate.
+2.
+New York Law Governs Plaintiff's Punitive Damages Claim
+Plaintiff does not dispute that she would be barred from recovering
+punitive damages if her claim were strictly governed by EPTL § 11-3.2(a)(1). 6
+In Lisa Doe v. Indyke, No. 19 Civ. 7773 (ER), 2020 WL 3073219, at *14 (S.D.N.Y.
+9
+
+
+Instead, Plaintiff makes two distinct arguments: (i) New York choice-of-law
+rules allow Plaintiff to seek punitive damages under USVI law, even if she
+pursues her personal injury claims under New York law; and (ii) Plaintiff has a
+statutory right to sue Epstein's estate under either USVI or New York law. (See
+Pl. Opp. 1-2, 17-18).
+With respect to Plaintiff's first argument, this Court, like many courts
+before it, recognizes New York choice-of-law rules, which apply an "interest
+analysis" to resolve conflicts of law in tort actions. See, e.g., Mary Doe, 2020
+WL 2036707, at *5; Golden v. Wyeth, Inc., No. 04 Civ. 2841 (JS), 2013 WL
+4500879, at *1-2 (E.D.N.Y. Aug. 20, 2013). As construed by the Second
+Circuit, the "interest analysis" requires application of the law of the jurisdiction
+with the greatest interest in the litigation. In re Thelen LLP, 736 F.3d 213, 219
+(2d Cir. 2013) (brackets, alteration, and internal quotation marks omitted).
+Further, the jurisdiction with more "significant contacts" relating to the
+purpose of the law in conflict has the greater interest. See GlobalNet
+Financial. Com, Inc. v.
+Crystal & Co., 449 F.3d 377, 384 (2d Cir. 2006)
+(citing
+v. Boy Scouts of Am., Inc., 65 N.Y.2d 189, 197 (1985)).
+Torts are divided into two types: conduct-regulating rules, such as "rules
+of the road," and loss-allocation rules, "such as those limiting damages in
+wrongful death actions, vicarious liability rules, or immunities from suit." In re
+Thelen, 736 F.3d at 220 (citation omitted). "If conflicting conduct-regulating
+laws are at issue, the law of the jurisdiction where the tort occurred will
+generally apply because that jurisdiction has the greatest interest in regulating
+10
+
+
+behavior within its borders." Id. (quoting Cooney v. Osgood Mach., Inc., 81
+N.Y.2d 66, 72 (1993)) (emphasis added).
+The parties do not dispute that punitive damages rules are conductregulating. See, e.g., Mary Doe, 2020 WL 2036707, at *5 (collecting cases
+reaching the same conclusion). Defendants argue that because Plaintiff's
+causes of action occurred entirely in New York, EPTL § 11-3.2(a)(1) applies to
+bar punitive damages. (Def. Br. 3). Plaintiff counters that the conductregulating classification does not end the inquiry, because a court must still
+consider whether there is a "good reason not to apply" the law of the
+jurisdiction where the tort occurred. (PI. Opp. 9 (quoting Nat'l Jewish
+Democratic Council v. Adelson, 417 F. Supp. 3d 416, 426 (S.D.N.Y. 2019))).
+In particular, Plaintiff identifies two circumstances that, she claims, give
+the Court "good reason" to apply USVI law to the issue of punitive damages.
+(See Pl. Opp. 8-11). First, Plaintiff contends that the fact that Defendants are
+USVI domiciliaries counsels in favor of applying USVI estate law. (See id. at 9-
+10). And in this regard, Plaintiff relies on Adelson to argue the importance of
+deferring to a defendant's domicile in applying a particular jurisdiction's law.
+(See id. at 9, 11; Pl. Rep. Lt. 1, 2 n.2 (citing Adelson, 417 F. Supp. at 426
+(reasoning that defendant's domiciliary, Nevada, "points in favor" of applying
+Nevada punitive damages law))). But while Plaintiff's invocation of Adelson's
+"points in favor" language is well-argued, that language is ultimately only a
+partial recitation of the interest-analysis test described above. See GlobalNet,
+449 F.3d at 384 (quotations and citations omitted) (explaining how under the
+11
+
+
+interest-analysis test, significant contacts are, almost exclusively, the parties'
+domiciles and the locus of the tort). In context, the weight afforded to domicile
+in Adelson was largely due to the irrelevance of the locus of the tort factor, as
+the suit's sole connection to New York was that it was filed there. Adelson, 417
+F. Supp. 3d at 426. Furthermore, Adelson's previous attempt to avail himself
+of the benefits of Nevada defamation law granted Nevada the greater interest in
+governing punitive damages as compared to New York. Id.
+To describe Adelson is thus to highlight its insignificance to the instant
+case. At all times material to the conduct alleged in the Complaint, Plaintiff
+was domiciled in New York. All of the alleged torts took place in the home
+Epstein maintained in New York. (Cf. Compl. 1 13 ("All of the events giving rise
+to these causes of action occurred in the Southern District of New York, thus
+venue in this district is proper.")). Further, Plaintiff chose to sue in New York,
+where her causes of action are timely pursuant to the New York Child Victims
+Act, N.Y.P.L. § 130.52-55. (See id. at 11 73, 77, 82, 86). And Plaintiff's case,
+like Mary Doe and unlike Adelson with Nevada law, "does not build on a prior
+litigation in, or based on the law of, the USVI." Mary Doe, 2020 WL 2036707,
+at *7. These facts, taken together, demonstrate that New York's interest in
+applying its punitive damages rules to this case outweighs the USVI's interest,
+which exists only because of Epstein's decision to probate his estate there. See
+Lisa Doe, 2020 WL 3073219, at *15 (concluding that New York punitive
+damages law, rather than USVI punitive damages law, applied to plaintiff's case
+"allegling] torts under New York law committed entirely within New York"). If
+12
+
+
+anything, it is the USVI, and not New York, that has a "merely fortuitous
+relationship with the case," minimizing its interest in governing punitive
+damages. Adelson, 417 F. Supp. 3d at 427 (citation omitted).
+In addition to her domicile argument, Plaintiff asserts that the USVI has
+a greater interest than New York in preventing Epstein and his Estate from
+availing themselves of the benefits, but not the burdens, of USVI probate law.
+Despite her plausible policy concerns, Plaintiff provides little in the way of
+precedential support for her contention that "where a tortfeasor commits
+suicide to avoid imposition of punitive damages, considerations of fairness no
+longer counsel in favor of protecting his estate." (PI. Opp. 12). Nor does she
+substantiate her claim that "[p]rohibiting punitive damages in this case would
+not protect innocent heirs; it would punish traumatized victims deserving of
+adequate compensation." (Id.). In Mary Doe, the plaintiff asserted a
+comparable argument, claiming that Epstein's decision to alter his Will shortly
+before his suicide was strategically motivated, and thus his executors should
+not be permitted to selectively avail themselves of certain benefits of USVI law
+but avoid aspects that they do not like. Mary Doe, 2020 WL 2036707, at *5.
+But, as with the Mary Doe court, this Court is left unpersuaded. Id. at *6
+("[Mary] Doe's point that the estate may prosper from being probated in the
+USVI is disconnected from her claims.").
+Meanwhile, New York's interest in governing Plaintiff's punitive damages
+claim remains clear, as the place of the allegedly wrongful conduct "generally
+has superior interests in protecting the reasonable expectations of the parties
+13
+
+
+who relied on the laws of that place to govern their primary conduct and in the
+admonitory effect that applying its law will have on similar conduct in the
+future." Mary Doe, 2020 WL 2036707, at *6 (quoting AHW Inv. P'ship, MFS v.
+Citigroup, Inc., 661 F. App'x 2, 5 (2d Cir. 2016) (internal quotations and
+citations omitted)). With numerous personal injury actions pending against the
+Epstein Estate under New York law for alleged conduct that largely occurred in
+New York, the state has abundant interest in "vindicating the rights of [these]
+victims]" and "assuring that the perpetrator of that abuse is adequately
+punished and deterred." Id. And as previously noted, New York's interest is
+reinforced by the fact that Plaintiff's suit is timely only by virtue of the New
+York Child Victims Act. (See Compl. 11 73, 77, 82, 86). Cf. 5 V.I.C. § 31(5)(A)
+(specifying two-year statute of limitations for personal injury actions in the
+USVI).
+Separate and distinct from her choice-of-law argument, Plaintiff asserts a
+statutory right to sue Epstein's Estate under either USVI or New York law.
+First, Plaintiff claims a right to sue under USVI law because the Complaint
+does not specifically invoke EPTL § 11-3.2(a)(1). The Court rejects this
+argument out of hand: Plaintiff's ability to sue Defendants originates from
+EPTL § 11-3.2(a)(1), as her causes of action are all personal injury claims based
+on alleged conduct that occurred exclusively in New York. (Compl. 99 12-13).7
+Plaintiff's strategic decision to omit reference to the provision in her Complaint
+ee generally N.Y. Gen. Constr. Law § 37-a (defining "personal injury" as including "a
+ssault, battery, false imprisonment, or other actionable injury to the person either ‹
+the plaintiff, or of another").
+14
+
+
+does not change this fact, let alone preclude New York law from applying. See
+Mary Doe, 2020 WL 2036707, at *6 ("It is problematic for [plaintiff] to
+cherrypick within [EPTL § 11-3.2(a)(1)], invoking the part that authorizes a
+personal injury suit against an executor while disclaiming the balance, which
+delimits the recovery available in such a suit."). As the district court in Blissett
+recognized, "it would be an anomalous situation indeed if plaintiff were allowed
+to proceed with this [8] 1983 action ... because of [8] 11-3.2(a)(1), while at the
+same time he was allowed to recover relief, in the form of punitive damages,
+which clearly is beyond the scope of relief which that statute authorizes."
+Blissett, 940 F. Supp. at 457. Plaintiff asserts that Blissett is inapplicable, as
+the claim there sought punitive damages for federal civil rights violations,
+which are governed by different choice-of-law principles than personal injury
+cases. (Pl. Opp. 18 n.9). However, the Blissett court concluded that this was a
+distinction without a difference: The plaintiff there argued that the statute was
+irrelevant because he sought redress for a constitutional violation, not a
+personal injury. Id. The court disagreed because "stripped to its core, in
+essence, [the plaintiff's] claim is one for personal injury." Id. It is only logical,
+therefore, to infer that the anomaly identified in Blissett would counsel against
+the grant of punitive damages that are disallowed under EPTL § 11-3.2(a)(1).
+Second, Plaintiff asserts that she possesses a statutory right under USVI
+law because it, specifically 15 V.I.C. § 601, allows personal injury claims
+against a decedent tortfeasor's estate. Whether Virgin Islands law or New York
+law applies to her ability to sue the Estate, Plaintiff claims she is authorized to
+15
+
+
+bring this action under the law of either jurisdiction. But this argument fails
+for several reasons, including that: (i) Plaintiff cites no legal authority
+permitting a New York litigant to file a personal injury suit under § 601 in New
+York in order to recover for torts occurring in New York; and (ii) Plaintiff does
+not explain how she can bring this lawsuit pursuant to § 601 and avail herself
+of USVI law governing punitive damages, while simultaneously maintaining
+that the action is timely pursuant to the New York Child Victims Act.
+Finally, echoing her choice-of-law argument, Plaintiff asserts that the
+doctrine of dépeçage permits different jurisdictions' laws to govern the
+availability of punitive damages and the availability of a cause of action. (See
+Pl. Opp. 19).8 The Mary Doe court resolved the same question by holding that
+dépeçage does not invite the application of two different sets of laws to a single
+issue, and thus may not be invoked to cherrypick from EPTL § 11-3.2(a)(1).
+Mary Doe, 2020 WL 2036707, at *6. Plaintiff argues that the availability of
+punitive damages and the availability of a cause of action are not a "single
+issue," and therefore that dépeçage may be invoked. (See Pl. Rep. Lt. 3). In
+particular, Plaintiff points out that the "New York Court of Appeals has
+recognized that the doctrine lof dépeçage] may sometimes require that a
+plaintiff's demand for punitive damages be analyzed under the law of a state
+other than the one under whose law the cause of action arises." Fed. Hous.
+8
+Under the doctrine of dépeçage, "the rules of one legal system are applied to regulate
+certain issues arising from a given transaction or occurrence, while those of another
+system regulate the other issues." Hunterv. [
+, 734 F.2d 896, 901 (2d Cir. 1984)
+(citation omitted).
+16
+
+
+Fin. Agency v. Ally Fin. Inc., No. 11 Civ. 7010 (DLC), 2012 WL 6616061, at *5
+(S.D.N.Y. Dec. 19, 2012). In such an analysis, "a court must consider the
+object or purpose of the wrongdoing, and give controlling effect to the law of the
+jurisdiction with the strongest interest in the resolution of the particular issue
+presented." Id. (citation omitted). While this statement may be persuasive in a
+vacuum, the Ally Financial court still applied the punitive damages law of the
+states in which the alleged fraud took place, reasoning that the states where
+the "primary conduct allegedly took place ha|d] a stronger interest in deterring
+such [fraud]." Id. at *5. By extension, and regardless of whether Plaintiff's
+alleged causes of action and prayer for punitive damages are considered a
+single issue, New York has the stronger interest in resolving Plaintiff's punitive
+damages claim. Thus, dépeçage would be inapplicable here.
+3. USVI Law Is Likely in Accord with New York Law Under a
+Banks Analysis
+Even if the Court assumed, arguendo, that USVI law applied, the
+outcome would be the same. The USVI does not have a statute addressing the
+availability of punitive damages against a decedent tortfeasor's estate. See
+Powell v. Chi-Co's Distrib., Inc., No. ST-13-TOR-14, 2014 WL 1394183, at *2
+n. 11 (V.I. Super. Ct. Apr. 3, 2014) (pointing out the lack of standard for
+asserting punitive damages in the USVI). When considering a question not
+foreclosed by statute or precedent, USVI courts apply three "non-dispositive"
+factors: (i) whether any USVI courts have previously adopted a particular rule;
+(ii) the position taken by a majority of courts from other jurisdictions; and (iii)
+17
+
+
+most importantly, which approach represents the soundest rule for the USVI.
+Gou't of Virgin Islands v.
+60 V.I. 597, 600 (2014) (citing Matthew v.
+Herman, 56 V.I. 674, 680 (2012)). The test, known as the "Banks analysis,"
+determines the common-law disposition of the USVI on a given issue. See id.
+(citing Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967, 979 (2011)).
+Plaintiff argues that the Banks analysis makes "clear that punitive
+damages are available in this case." (PI. Opp. 13). Defendants champion the
+opposite conclusion. (Def. Br. 4-5). This Court is ultimately persuaded by the
+position taken by its sister court, viz., that the USVI would not allow the
+imposition of punitive damages on a tortfeasor's estate, thereby aligning itself
+with New York, the majority of states, and § 908 of the Restatement (Second) of
+Torts. See Mary Doe, 2020 WL 2036707, at *7-8 (citing supporting cases);
+accord Doe 15, 2020 WL 2086194, at *1.
+As to the first factor, multiple courts in the USVI have recited the
+Restatement's rule precluding punitive damages. See, e.g.,
+V. Dowson
+Holding Co., 51 V.I. 619, 628 (D.V.I. 2009); Booth v. Bowen, Civ. No. 2006-217
+(CVG), 2008 WL 220067, at *5 (D.V.I. Jan. 10, 2008). While these cases
+address punitive damages in wrongful death actions, they are still relevant, in
+spite of Plaintiff's objections, as support for the USVI's longstanding application
+of § 908 of the Restatement (Second) of Torts within the USVI. See Pappas v.
+Hotel on the Cay Time-Sharing Ass'n, 69 V.I. 3, 15 n.8 (V.I. Super. Ct. 2015)
+(relying on this accepted application in finding the Restatement's provision to
+be the soundest rule for USVI courts with respect to the imposition of punitive
+18
+
+
+damages and local public policy). Plaintiff has not cited any countervailing
+authority within the USVI.
+Plaintiff claims that Defendants exaggerate the degree to which the
+second Banks factor favors prohibiting punitive damages against an estate, but
+concedes that this is the majority rule. (Pl. Opp. 16). That "most of the
+jurisdictions adopting the majority rule" have passed a statute codifying a
+prohibition of punitive damages against a decedent's estate, and the USVI has
+not, does not suggest that the majority rule would not apply in the USVI. This
+is especially true considering that, before the adoption of the Banks analysis
+less than a decade ago, USVI courts strictly followed the Restatements. See
+Isaac v. Crichlow, 63 V.I. 38, 58-60 (V.I. Super. Ct. 2015) (concluding,
+pursuant to a Banks analysis, that § 222A of the Restatement (Second) of Torts
+reflects the common law of the USVI, despite the fact that the Restatements "no
+longer constitute binding legal authority in this jurisdiction"); Mary Doe, 2020
+WL 2036707, at *7 (explaining how the distinction between adopting this result
+by statute or by court decision "does not appear germane to the Banks
+inquiry").
+Plaintiff focuses on the third factor, asserting that the Mary Doe court
+reached its conclusion by "essentially eliminating the third Banks factor — i.e.,
+which approach represents the soundest rule for the USVI - from its analysis,
+even though that factor is the 'most important' of the three." (Pl. Rep. Lt. 3
+(citing Antilles Sch., Inc. v. Lembach, 64 V.I. 400, 428 (V.I. 2016))). The
+soundest rule, according to Plaintiff, is to permit punitive damages because:
+19
+
+
+(i) the USVI Attorney General has articulated this very position on behalf of the
+Virgin Islands in her pending lawsuit against the Estate; and (ii) punitive
+damages in the USVI are designed both to punish wrongdoers and to deter
+others from engaging in similar conduct. This Court does not give weight to
+the Attorney General's suit, as "the decision by a government lawyer to attempt
+to obtain such damages in a high-profile case involving allegations of extreme
+conduct ... doles] not speak to the question that the third Banks factor assays."
+Mary Doe, 2020 WL 2036707, at *8. And while the Court does not deny the
+USVI's interest in punishing tortfeasors on its land, or even its interest in
+holding Epstein's Estate accountable for his tortious actions in the USVI,
+Plaintiff's alleged causes of action arose exclusively in New York. The Court is
+skeptical that that it would be the policy of the USVI to regulate conduct
+occurring in New York.° Thus, consideration of the Banks factors leads the
+Court to conclude that USVI law, if applied, would likely be in accord with New
+York law and bar Plaintiff's recovery of punitive damages in this action. 10
+10
+Notably, none of the available cases from the USVI relying on the Restatement
+questions the validity of its prohibition against punitive damages recovery from a
+decedent's estate. But courts have held that it is that "the Restatement (Second) of
+Torts § 908(2) represents the soundest rule for the Virgin Islands, and is in accord with
+local public policy." Powell v. Chi-Co's Distrib., Inc., No. ST-13-TOR-14, 2014 WL
+1394183, at *2 n.11 (V.I. Super. Ct. Apr. 3, 2014).
+Because the Court finds New York law applies to this issue, and USVI law would be in
+accord, it declines Plaintiff's request to certify the question to the Supreme Court of the
+Virgin Islands.
+20
+
+
+CONCLUSION
+To be clear, the conduct alleged in Plaintiff's Complaint is as shocking as
+it is reprehensible. That said, even for egregious fact patterns, the Court is not
+free to overlook the law, and the law here is clear. For the reasons detailed
+above, Defendants' motion to dismiss Plaintiff's prayer for punitive damages is
+GRANTED. The Clerk of Court is directed to terminate the motion pending at
+Docket No. 46.
+SO ORDERED.
+Dated:
+June 23, 2020
+New York, New York
+Katherin Pall Faula
+KATHERINE POLK FAILLA
+United States District Judge
+21
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+Case 9:08-cv-80736-KAM Document 45 Entered on FLSD Docket 12/17/2010 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOES #1 and #2,
+Petitioners,
+V.
+UNITED STATES,
+Respondent.
+STATUS REPORT
+Respondent, United States of America, by and through its undersigned counsel, files this
+Status Report, with concurrence of counsel for Petitioners, to inform the Court of the status of this
+matter.
+On October 28, 2010, the Court filed its Order reopening the matter and stated that
+it would "allow the parties to continue their attempt to resolve this matter. In the event that the
+parties cannot reach a resolution, the Court will schedule a status conference to determine how this
+case will proceed." (DE 44 at 1-2.)
+2.
+The parties have continued to meet telephonically and in person in an attempt to
+resolve this matter but have not yet reached a resolution.
+3.
+Based upon recent communications received from Petitioners' counsel, the U.S.
+Attorney's Office has determined that it must seek an opinion from the Justice Department regarding
+whether it can continue to represent the United States in this matter, or whether outside counsel from
+another part of the Justice Department is required.
+4.
+The undersigned and AUSA Dexter Lee have communicated this decision to counsel
+
+
+Case 9:08-cv-80736-KAM Document 45 Entered on FLSD Docket 12/17/2010 Page 2 of 3
+for Petitioners, and have explained that this will necessarily suspend activity on the case until an
+opinion is obtained and, if necessary, new counsel is in place.
+Petitioners have agreed with the filing of this Status Report to inform the Court of
+this development and to ask the Court to allow the parties additional time to determine whether
+resolution of the matter is possible.
+6.
+Consistent with the Court's Order, (DE44,) once this interim question of
+representation is decided, the parties will continue their attempts to resolve this case. If the parties
+determine that resolution without court intervention is impossible, one or both parties will ask the
+Court to set the matter for a Status Conference.
+Respectfully submitted,
+WIFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+SAI
+— Villafaña
+A.
+VILLAFAÑA
+Assistant U.S. Attorney
+Fla. Bar No. 0018255
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail:
+Attorney for Respondent
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on December 17, 2010, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+S/ A.
+A.
+Villafaña
+VILLAFAÑA
+Assistant U.S. Attorney
+2
+
+
+Case 9:08-cv-80736-KAM Document 45 Entered on FLSD Docket 12/17/2010 Page 3 of 3
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Brad
+, Esq.,
+Jaffe Weissing
+425 N Andrews Ave Ste 2
+Fort Lauderdale, FL 33301-3268
+(954) 524-2820
+Fax: (954) 524-2822
+brad@pathtojustice.com
+Fistos Lehrman
+Paul G. Cassell
+Ronald N. Boyce Presidential Professor of Criminal Law
+S.J. Quinney College of Law at the University of Utah
+332 S. 1400 E., Room 101
+Salt Lake City, UT 84112-0730
+(801) 585-5202 (phone)
+(801) 581-6897 (fax)
+cassellp@law.utah.edu
+Attorneys for Petitioners
+3
diff --git a/vision-fixhub/court-01/e451d70133b1ff3493220633cbdca1fd5632e2b86f1ebdda28a7331f274bfec4.receipt.json b/vision-fixhub/court-01/e451d70133b1ff3493220633cbdca1fd5632e2b86f1ebdda28a7331f274bfec4.receipt.json
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diff --git a/vision-fixhub/court-01/e45f07547ca6e8bb5b45e24b104b95df3d25ae5b324424433d245025369a8172.md b/vision-fixhub/court-01/e45f07547ca6e8bb5b45e24b104b95df3d25ae5b324424433d245025369a8172.md
new file mode 100644
index 0000000000000000000000000000000000000000..11a790e258ae80408c10583eef42ba8f4e246cfa
--- /dev/null
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@@ -0,0 +1,119 @@
+Case 9:08-cv-80380-KAM Document 15 Entered on FLSD Docket 06/25/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S REPLY MEMORANDUM
+IN SUPPORT OF MOTION FOR DEFAULT JUDGMENT
+Plaintiff, Jane Doe No. 4, by and through her undersigned counsel, submits this Reply
+Memorandum in Support of Motion for Default Judgment, as follows:
+Introduction
+Defendant Jeffrey Epstein claims that service of process on him was ineffective under
+Florida or Federal law, based solely on a "bare bones" affidavit that raises more questions than it
+answers. At a minimum, the issue of whether service was effective under Florida or Federal law is
+at this point one of fact which should be the subject of discovery.
+The Affidavit Attached to the Defendant's
+Response to the Motion is Insufficient
+Service of process was effected at Jeffrey Epstein's New York residence on May 7, 2008, at
+7:45 a.m. by handing a copy of the Summons and Complaint to a person in Defendant's residence
+who refused to identify himself. (See D.E. 4, Affidavit of Service). A Clerk's Default was entered
+against Defendant Jeffrey Epstein in this action on June 2, 2008. Defendant has filed the Affidavit
+of Richard Barnett, who claims to have received the copies of the Summons and Complaint on May
+7, 2008 at Defendant Epstein's residence. In this Affidavit, Mr. Barnett states very little. He asserts
+HERMAN & MERMELSTEIN, P. A.
+- 1-
+
+
+Case 9:08-cv-80380-KAM Document 15 Entered on FLSD Docket 06/25/2008 Page 2 of 5
+that he does not now, nor has he ever, resided at 9 E. 71st Street, New York, New York (Mr.
+Epstein's residence). He fails to state in this Affidavit, however, where he does live, if not at the
+residence in question; what he was doing at the subject address when service was made; his
+relationship with Defendant Epstein, and how often he was at the residence; or why he refused to
+identify himself to the process server. He also fails to state who instructed him to answer the door
+on May 7, 2008 and take service anonymously.
+The Court may grant limited discovery on the issue of service of process. Commonwealth of
+Puerto Rico v. SS Zoe Colocotroni, 61 F.R.D. 653, 656-57 (D.P.R. 1974) ("discovery regarding the
+legal sufficiency of service of process so as to acquire in personam jurisdiction over the person of a
+defendant is permitted by the Federal Rules of Civil Procedure, specifically Rule 26"). See also
+Blair v. City of Worcester, 522 F.3d 105, 111 (Ist Cir. 2008); Monteiro v. San Nicolas, S.A., 254
+F.2d 514, 516-17 (2d Cir. 1958) (holding that discovery was appropriate on disputed issues of
+service of process). The parties do not dispute that if the person who in fact received the copies of
+the summons and complaint resided at the residence, then service would have been valid under
+Florida or Federal law on May 7, 2008.' See National Development Co. v. Triad Holding Corp.,
+930 F.2d 253 (2d Cir. 1991) (upholding service of process on housekeeper of defendant's New York
+apartment, under Fed.R.Civ.P. 4(d)(1) [now 4(e)(2)], because the defendant was actually living in
+the apartment at the time service was effected). Alternatively, if the extraordinary difficulties
+encountered in serving Mr. Epstein were the result of Mr. Epstein's deliberate avoidance or
+'Defendant notes that under Rule 4(e) there is no priority between alternative methods of service.
+This means that Plaintiff has the option of perfecting service under either federal law, the law of the
+forum state, or the law of the state where service is made: "Either may be turned to with no
+attempted prior resort to the other." Fed.R.Civ.P. 4 (Commentary C4-22). It does not stand,
+however, for the proposition that the defendant can accept service under New York law, while
+ignoring valid service under Florida or Federal law. Accordingly, once valid service was made on
+Defendant Epstein under Federal or Florida law on May 7, 2008, Defendant was required to answer
+Herman & Mermelstein, P. A.
+- 2-
+
+
+Case 9:08-cv-80380-KAM Document 15 Entered on FLSD Docket 06/25/2008 Page 3 of 5
+deception, while knowing of the lawsuit, then it would likewise be appropriate to find good service
+and a default. See
+Keevan & Son , Inc. v. Callier Pipe & Tube, Inc., 107 F.R.C. 665, 671-72
+(S.D. Fl.a. 1985) ("[e]ffective service is most likely found when a defendant has engaged in
+deception to avoid service of process"). Based on what Mr. Barnett's Affidavit does not disclose,
+the entry of default judgment is appropriate. In the alternative, Plaintiff should be granted discovery
+to determine whether service was proper under Florida or Federal law. Plaintiff would at a
+minimum like to take the depositions of Mr. Barnett and Mr. Epstein with regard to the service of
+process issues that have arisen in this matter.
+Conclusion
+Based on the foregoing, Plaintiff requests that this Court allow Plaintiff to take discovery on
+the issue of service of process; conduct an evidentiary hearing on the validity of service under
+Florida or Federal law; that a default judgment be entered; the amounts set forth in the judgment be
+assessed by a jury after hearing; and such other and further relief as this Court deems just and
+proper.
+Dated: June 25, 2008.
+Respectfully submitted,
+By:
+s/ Jeffrey M. Herman
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman@hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+or otherwise respond to the Complaint by May 27, 2008 to avoid default, which he failed to do.
+HERMAN & MERMELSTEIN, P. A.
+- 3-
+
+
+Case 9:08-cv-80380-KAM Document 15 Entered on FLSD Docket 06/25/2008 Page 4 of 5
+CERTIFICATE OF SERVICE
+I hereby certify that on June 25, 2008, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Jeffrey M. Herman
+Herman & MermelsteIn, P. A.
+- 4-
+
+
+Case 9:08-cv-80380-KAM Document 15 Entered on FLSD Docket 06/25/2008 Page 5 of 5
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+CASE NO.: 08-CV-80380-MARRA/_
+United States Distriet Court, Southern District of Florida
+Jack Alan Goldberger
+jagesq@bellsouth.net
+Is/ Jeffery M. Herman
+Herman & Mermelstein, P. A.
+- 5-
\ No newline at end of file
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new file mode 100644
index 0000000000000000000000000000000000000000..458fa823f316c768820626f3c257f54ce0676136
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+}
diff --git a/vision-fixhub/court-01/e4876185cb2760a86a779588d52ffdf962419b51a719ce464435f056a0460162.md b/vision-fixhub/court-01/e4876185cb2760a86a779588d52ffdf962419b51a719ce464435f056a0460162.md
new file mode 100644
index 0000000000000000000000000000000000000000..553c6fd8b0f8e2d60293160ef65bfdc544da275d
--- /dev/null
+++ b/vision-fixhub/court-01/e4876185cb2760a86a779588d52ffdf962419b51a719ce464435f056a0460162.md
@@ -0,0 +1,459 @@
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 1 of 17
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+CASE NO.: 08-CV-80119-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+CASE NO.: 08-CV-80232-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+CASE NO.: 08-CV-80380-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-
+MARRA/
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 2 of 17
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80994-
+MARRA/JOHNSON
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+CASE NO.: 08-CV-80993-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/_
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 3 of 17
+JANE DOE,
+CASE NO.: 08-CV-80893-MARRA/_
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+CASE NO.: 08-CV-80469-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 09-CV-80591-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 09-CV-80656-
+MARRA/
+
+
+Case 9:08-cv-80994-KAM
+Document 60 Entered on FLSD Docket 05/29/2009 Page 4 of 17
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS JANE DOE NO. 101 AND JANE DOE NO. 102's REPLY IN
+SUPPORT OF MOTION TO PROCEED ANONYMOUSLY AND RESPONSE IN
+OPPOSITION TO MOTION TO COMPEL AND/OR IDENTIFY JANE DOE NO.
+101 AND JANE DOE NO. 102 IN THIRD-PARTY SUBPOENAS FOR PURPOSES
+OF DISCOVERY
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together, "Plaintiffs"), by and
+through their undersigned attorneys, hereby file their Reply in Support of Motion to
+Proceed Anonymously and Response in Opposition to Motion to Compel and/or Identify
+Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of
+Discovery, and, as grounds, state as follows:
+1.
+Exposure of Plaintiffs to the public disclosure of their identity and the
+resultant shame and humiliation accompanying their sexual exploitation is wholly
+unnecessary and premature, and may cause further damage. Plaintiffs respectfully assert
+that this Court should first decide the threshold issues of retroactivity and calculation of
+damages. Plaintiffs, and all other victims of Defendant who have filed an action against
+Defendant in federal court, will have to litigate these two following threshold issues
+being reviewed by the Court in the C.M.A. action against Defendant (Case No. 08-CV-
+80811-MARRA/
+): 1) whether the most recent version of the statute, which
+provides for a minimum recovery of $150,000 (instead of the previous minimum of
+' Plaintiffs respectfully file this Reply in the consolidated action, as the issue at hand pertains to discovery
+issues.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 5 of 17
+$50,000) applies to cases arising from incidents predating the 2006 amendment to the
+statute; and 2) whether the applicable minimum amount is recoverable per incident and/or
+per count, or per victim. Defendant has attempted to force settlements on any victims as
+possible without considering the possibility that the minimum amount recoverable under
+18 U.S.C. § 2255 is $150,000 per count and/or per incident. Much of this Court's
+caseload will be alleviated once the Court resolves these issues related to the minimum
+recovery; at that point, many of Defendant's victims will likely agree to settle for the
+minimum statutory damages to which they are entitled, thus obviating Defendant's
+specified need to destroy his vietims" anonymity and expose them to further harm and
+humiliation.
+2.
+This Court has discretion to deny Defendant's Motion to Compel and/or
+Identify Plaintiffs in Third Party Subpoenas for Purposes of Discovery. See Doe v.
+Stegall, 653 F.2d 180, 184 (5th Cir. Aug. 10, 1981)' ("Fed.R.Civ.P. 26(c) vests in the
+trial court discretion over litigants' requests for protection from 'annoyance,
+embarrassment, oppression, or undue burden or expense' in the discovery process.")
+(internal quotation omitted). As more fully discussed in Plaintiffs' Response to
+Defendant's Motion to Stay, which is adopted and incorporated herein, Defendant waived
+his right to contest liability in actions filed pursuant to 18 U.S.C. § 2255. Thus, third
+party discovery is relevant only if Plaintiffs seek recovery of damages in excess of the
+statutory minimum. Additionally, if and when the parties are ready to proceed with
+discovery from non-party sources, the Court can put numerous measures in place to
+maximize Plaintiffs' anonymity. At the outset, Defendant can obtain records from
+" In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc), this circuit adopted as
+binding precedent all decisions of the former Fifth Circuit handed down before October 1, 1981.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 6 of 17
+various non-party sources through Plaintiffs' counsel, who can demonstrate and certify
+that they have obtained the very records being sought, or through an independent special
+, who could be given releases by Plaintiffs to obtain such records on behalf of
+Defendant to eliminate any question of authenticity or completeness. If Defendant
+nevertheless insists on conducting his own third-party discovery (needlessly increasing
+the cost of litigating these actions and causing unnecessary delay), subpoenas seeking
+documents from sources such as health care providers or employers should not disclose
+the type of action or identify Defendant. Because of the highly-publicized nature of
+Defendant's crimes as well as his designation as a sexual offender, the mere mention of
+Defendant's name in any subpoena or deposition notice will automatically expose the
+subject Plaintiff as one of Defendant's victims and may result in unnecessary public
+humiliation. Similarly, records custodian depositions do not require the disclosure of the
+nature of the action and/or the identity of the defendant in the action.?
+3.
+Defendant's only purpose in opposing Plaintiffs' motions is harassment.
+Defendant's intentions are clear. He seeks to destroy these young women by outing them
+as being among his many victims, a pattern of behavior consistent with his status as a
+designated sex offender. Defendant openly admits to his desire to reveal the victims'
+names in newspapers so that individuals in their community can come forward to assault
+their credibility and tarnish their reputations (and, as a result, their dignity). See
+Defendant's Response in Opposition to Motion to Proceed Anonymously (DE# 5) at 9| 6
+("[O]nce the Plaintiff is identified, other individuals come forward in the discovery phase
+with information which often directly contradicts allegations as to the events and
+" Depending upon claims of Plaintiffs, certain documents will be relevant. At this point, however,
+Plaintiffs do not waive their privilege to prevent the release of each of their names under the doctor-patient
+relationship.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 7 of 17
+damages. For instance, witnesses may testify that Plaintiff was paid by others for similar
+sexual acts she claims Mr. Epstein forced upon her or that she willingly participated in
+certain acts(s) that would negate or lessen her damages"). Each of Defendant's victims
+whom undersigned counsel represents continues to experience trauma and humiliation
+associated with sexual abuse. See Ellen Bass & Laura
+, The Courage to Heal: A
+Guide for Women Survivors of Child Sexual Abuse 3 (4th ed. 2008) (*The long-term
+effects of child sexual abuse can be so pervasive that it's sometimes hard to pinpoint
+exactly how the abuse affected you. It can permeate everything: your sense of self,
+intimate relationships, sexuality, parenting, working, even your sanity.")* The U.S.
+Supreme Court in Coker v. Georgia, 433 U.S. 584, 597 (1977), discussed the grave
+nature of the crimes at issue in the cases against Defendant, stating:
+[Rape] is highly reprehensible, both in a moral sense and in its almost total
+contempt for the personal integrity and autonomy of the female victim ... Short of
+homicide, it is the "ultimate violation of self."
+Defendant committed crimes constituting the "ultimate violation of self" against minors.
+Because of the disdainful nature of these types of crimes, courts, including the Eleventh
+Circuit, "have carved out a limited number of exceptions to the general requirement of
+disclosure, which permit plaintiffs to proceed anonymously." Roe v. Aware Woman Ctr.
+for Choice, Inc., 253 F.3d 678, 685 (11th Cir. 2001) (internal citation omitted). "The
+* Although some Plaintiffs no longer live in the Palm Beach area, this should not undermine Plaintiffs'
+need for anonymity. As the Court in Doe No. 2 v. Kolko, 242 F.R.D. 193, 197 (E.D.N.Y. 2006) (internal
+citation omitted), points out, "[I]t is now possible to determine whether a given individual is a party to a
+lawsuit in federal court anywhere in the country by the simplest of computer searches, to access the docket
+sheet of any such case electronically, and ... that entire case files will be accessible over the Internet."
+Given the ease with which the public could access court files in these cases, it is reasonable that Plaintiffs'
+fears extend beyond ostracism in the Palm Beach community. The Palm Beach Post is available online all
+over the world. In addition, many of Plaintiffs' family members remain in the Palm Beach area and remain
+unaware of their daughter/granddaughter/niece's involvement in Defendant's sordid child sex exploitation
+enterprise. Furthermore, Plaintiffs are exposed to harassment through social networking sites such as
+Facebook and MySpace as well as other forms of online harrassment.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 8 of 17
+ultimate test for permitting a plaintiff to proceed anonymously is whether the plaintiff has
+a substantial privacy right which outweighs the customary and constitutionally-embedded
+presumption of openness in judicial proceedings." Id. (internal quotation and citation
+omitted).
+Cases regarding sexual assault are the paradigmatic examples of the type
+of highly sensitive and personal matter that warrant a grant of anonymity. See Doe No. 2
+v. Kolko, 242 F.R.D. 193, 195-98 (E.D.N.Y. 2006) (adult plaintiff, who, many years later,
+alleged that he was sexually abused by rabbi at private Jewish school when he was a
+child, was entitled to proceed anonymously because he feared retaliation and ostracism
+from his community; Doe v.
+1. 202 F.R.D. 173, 176 (E.D. Pa. 2001) (sexual assault
+victim granted use of pseudonym); Doe v.
+105 F. Supp. 2d 40, 44 (E.D.N.Y. 1999)
+(victim of assault, molestation, and sexual abuse granted anonymity because victim
+otherwise psychologically and emotionally unable to proceed with action); Roe v. Borup,
+500 F. Supp. 127, 130 (E.D. Wis. 1980) ("It is beyond argument that [a suit involving
+charges of sexual abuse of a child] is a highly sensitive issue"; thus, plaintiffs were
+entitled to use fictitious names in prosecuting the suit); see also Doe v. Blue Cross &
+Blue Shield United of Wis., 112 F.3d 869, 872 (7th Cir. 1997) ("[F]ictitious names are
+allowed when necessary to protect the privacy of children, rape victims, and other
+particularly vulnerable parties or witnesses."). The intensely personal nature of sexual
+exploitation creates an unusual case, and, in such a case, the general policy of full
+disclosure should give way to a policy of protecting privacy in a very private matter.
+This protection is especially necessary when the Court is dealing with young women who
+recently were sexually abused as minors.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 9 of 17
+5.
+Defendant is using the threat of publicity to attempt to intimidate victims
+to cause them not to file suit or to settle their claims for the absolute minimum in order
+for them to avoid being held up to public ridicule and hostility. His intention to attack the
+victims is at the heart of the protection afforded by numerous rape shield statutes, of
+which Defendant and his counsel are surely aware. In 1994, Congress amended the
+Federal Rules of Evidence to promote the strong social policy of protecting a victim's
+privacy and encouraging victims of crime to come forward. 'The reason for extending
+Rule 412 to civil cases is equally obvious. The need to protect alleged victims against
+invasions of privacy, potential embarrassment, and unwarranted sexual stereotyping, and
+the wish to encourage victims to come forward when they have been sexually molested
+do not disappear because the context has shifted from a criminal prosecution to a claim
+for damages or injunctive relief." Fed. R. Evid. 412 advisory committee's note. Rule
+412 now provides that, in civil trials in federal court involving alleged sexual misconduct,
+evidence that the victim engaged in other sexual behavior or evidence offered to prove
+any alleged victim's sexual predisposition can be admitted only in unusual circumstances,
+none of which apply to Plaintiffs' cases. Fed. R. Evid. 412 (a), (b). "The rule aims to
+safeguard the alleged victim against the invasion of privacy, potential embarrassment and
+sexual stereotyping that is associated with public disclosure of intimate sexual details and
+the infusion of sexual innuendo into the factfinding process. By affording victims
+protection in most instances, the rule also encourages victims of sexual misconduct to
+institute and to participate in legal proceedings against alleged offenders." Fed. R. Evid.
+412 advisory committee's note; see also Michigan v. Lucas, 500 U.S. 145, 149-50 (1991)
+(Rape shield statutes represent the valid legislative determination that victims of rape and
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 10 of 17
+attempted rape "deserve heightened protection against surprise, harassment, and
+unnecessary invasions of privacy."); United States v. Elbert, 561 F.3d 771, 776-77 (8th
+Cir. 2009) (evidence that child plaintiffs had previously engaged in prostitution was
+rightfully excluded in federal sex trafficking suit); Stephens v.
+, 13 F.3d 998, 1010
+(7th Cir. 1994) (Cummings, C.J., dissenting) ("The Indiana rape shield statute furthers
+laudable and pragmatic goals. It protects victims from needless exposure of their sexual
+past conduct; [and] ensures that the focus of rape trials remains the guilt or innocence of '
+the accused rather than the sexual history of the complainant."); United States v. Kasto,
+584 F.2d 268, 271-72 n.3 (8th Cir. 1978) (*[U]nchastity of a victim has no relevance
+whatsoever to [the victim's] credibility as a witness. Such a proposition would
+'necessarily imply the absurd (corollary) that the extramarital sexual history of a female
+witness would be admissible to impeach her credibility in any case in which she
+testified."") (internal citation omitted). Procedural protections such as the rape shield
+statutes reduce the embarrassment and anguish of trial, encouraging victims to report
+sexual offenses and offendors. "Without the protection provided by rape shield statutes,
+victims may find trial an ordeal not worth enduring." Stephens, 13 F.3d at 1010
+(Cummings, C.J., dissenting) (quoting 124 Cong. Rec. H11944 (1978) (statement of Rep.
+Elizabeth Holtzman)); see Fed. R. Evid. 412 advisory committee's note ("Too often in
+this country victims of rape are humiliated and harassed when they report and prosecute
+the rape... [RJape trials become inquisitions into the victim's morality, not trials of the
+defendant's innocence or guilt ...."). Indeed, "many [victims] find the trial almost as
+degrading as the rape itself." Fed. R. Evid. 412 advisory committee's note.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 11 of 17
+6.
+In addition, Congress enacted the Child Victims' and Child Witnesses'
+Rights Act (18 U.S.C. § 3509) in an effort to provide protection for victims who, while
+minors, were victims of physical abuse, sexual abuse, or sexual exploitation, or who have
+witnessed a crime committed upon another. One of the primary protections provided by
+the statute is the restriction on the disclosure of the name of, or other information
+concerning, the victim. See 18 U.S.C. § 3509(d)(3) (2008). Further, pursuant to 18
+U.S.C. § 3509(d)(2), "[a]ll papers to be filed in court that disclose the name of or any
+other information concerning a child shall be filed under seal without necessity of
+obtaining a court order."
+7.
+Indeed, numerous states, including Florida and New York, have enacted
+laws to protect the anonymity of sexual assault victims. See Fla. Stat. §$ 794.024,
+794.026 (2008); N.Y. Civ. Rights Law § 50-b (McKinney 2009). In 1994, the Florida
+Legislature passed The Crime Victims Protection Act. The legislative stated purpose for
+passage of the Act was "to protect the identity of victims of sexual crimes." Fla. AGO
+2003-56, 2003 WL 22971082 (Dec. 15, 2003) ("IT]he Legislature intended to make the
+identity of a victim of a sexual crime confidential in a court record or proceeding.")
+Under Florida Section 794.024 of the Florida Statutes, court records that identify the
+name and/or address of a victim of a sexual crime are presumed to be confidential and
+exempt from public access. Id. That statute further imposes criminal and civil liability
+for the disclosure or communication of information identifying the victim of a sexual
+crime. Fla. AGO 2003-56, 2003 WL 22971082 (citing Fla. Stat. §§ 794.024, 794.026
+(2008)). Similarly, upon approving New York's rape shield law, then Governor Mario
+stated, "[S]exual assault victims have unfortunately had to endure a terrible
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 12 of 17
+invasion of their physical privacy. They have a right to expect that this violation will not
+be compounded by a further invasion of their privacy." 1991 N.Y. Sess. Laws page nos.
+2211-12, quoted in Kolko, 242 F.R.D. at 196 (internal citations omitted).
+Finally, Defendant should be estopped from outing his victims. Plaintiffs
+attempted to utilize the process established by the Non-Prosecution Agreement ("NPA")
+with the reasonable expectation that a specific purpose of the NPA was to allow
+Defendant's victims to maintain anonymity, only to be subjected to deliberate and
+unreasonable delays and Defendant's failure to engage in meaningful, good faith
+settlement discussions. This left Plaintiffs no choice but to file suit. Under these
+circumstances, Defendant should be estopped from seeking to lift anonymity.
+9.
+Many of Defendant's victims are awaiting this Court's decision regarding
+whether they will be allowed to proceed anonymously before making the difficult
+decision as to whether to pursue their claims against Defendant. All of Defendant's
+victims and any future victims of sexual exploitation must know that they can protect
+what remains of their personal dignity when appealing to the Federal Courts for justice.
+WHEREFORE, Plaintiffs respectfully move this Court to grant Plaintiffs' Motion
+to Proceed Anonymously and to deny Defendant's Motion to Compel and/or Identify
+Jane Doe No. 101 and Jane Doe No. 102 in Third-Party Subpoenas for Purposes of
+Discovery.
+Date: May 29, 2009
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 13 of 17
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 14 of 17
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that, on this 29th day of May, 2009, we electronically
+filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify
+that the foregoing document is being served this day on all counsel of record identified on
+the attached Service List either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those counsel or parties who are not
+authorized to receive electronically Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 15 of 17
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 16 of 17
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10" Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80871
+Brad
+Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards @ira-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+
+
+Case 9:08-cv-80994-KAM Document 60 Entered on FLSD Docket 05/29/2009 Page 17 of 17
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e4876185cb2760a86a779588d52ffdf962419b51a719ce464435f056a0460162.receipt.json b/vision-fixhub/court-01/e4876185cb2760a86a779588d52ffdf962419b51a719ce464435f056a0460162.receipt.json
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diff --git a/vision-fixhub/court-01/e49f69ee6a287d9424ddfee83aad2c694427f0b88312b05c2fd12b95699534a2.md b/vision-fixhub/court-01/e49f69ee6a287d9424ddfee83aad2c694427f0b88312b05c2fd12b95699534a2.md
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@@ -0,0 +1,22 @@
+Case 9:09-cv-80656-KAM Document 34-1
+Entered on FLSD Docket 06/18/2009 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-80656-MARRA/
+JANE DOE No. 102,
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant,
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S
+Unopposed Motion for Extension of Time in Which to Serve a Responsive Pleading to
+Plaintiff, Jane Doe 102's, Complaint. Having considered Defendant's Unopposed Motion
+and Plaintiff's counsel being in agreement with the requested extension, it is HEREBY
+ORDERED and ADJUDGED that:
+Defendant's Unopposed Motion is GRANTED. Defendant shall file a Responsive
+Pleading to Plaintiff, Jane Doe 102's, Complaint on or before July 5, 2009.
+DONE and ORDERED this _
+_ day of June, 2009
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies all counsel
diff --git a/vision-fixhub/court-01/e49f69ee6a287d9424ddfee83aad2c694427f0b88312b05c2fd12b95699534a2.receipt.json b/vision-fixhub/court-01/e49f69ee6a287d9424ddfee83aad2c694427f0b88312b05c2fd12b95699534a2.receipt.json
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diff --git a/vision-fixhub/court-01/e4a537283d9bb99bf02dfe417b630090e1ffdfadb2bcb57068ac75b48a72a341.md b/vision-fixhub/court-01/e4a537283d9bb99bf02dfe417b630090e1ffdfadb2bcb57068ac75b48a72a341.md
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@@ -0,0 +1,118 @@
+Case 9:08-cv-80736-KAM Document 245 Entered on FLSD Docket 02/13/2014 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:08-ev-80736-Civ-KAM
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR EXPEDITED
+RULING ON EPSTEIN'S UNOPPOSED MOTION FOR INTERVENTION
+IN ADVANCE OF ELLEVENTH CIRCUIT ARGUMENT
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to file this unopposed motion for an expedited ruling granting
+Epstein's unopposed motion for intervention (DE 207) on or before February 27, 2014, so that
+the Eleventh Circuit will have the benefit of that ruling on February 28, 2014, during oral
+argument on the interlocutory appeal in this case.
+As the Court is aware, on July 8, 2013, Jeffrey Epstein filed a Motion for Prospective
+Limited Intervention at the Remedy Stage of these Proceedings (DE 207). In it, he argued that if
+the Court reaches the issue of the appropriateness of the rescission of the non-prosecution
+agreement (NPA) between him and the Government as a remedy for violations of the Crime
+Victims' Rights Act, then he should have an opportunity to be heard on that issue. Epstein
+contended that the NPA was an agreement that protected his rights and, accordingly, he should
+be allowed to intervene to contest any invalidation of that agreement. DE 207 at 4-6.
+1
+
+
+Case 9:08-cv-80736-KAM Document 245 Entered on FLSD Docket 02/13/2014 Page 2 of 4
+Four days later, on July 12, 2013, the victims filed their response (DE 209), indicating
+that they did not oppose Epstein's motion for limited intervention. The victims did, however,
+indicate several consequences that followed from the fact that Epstein had belatedly filed his
+motion and that the motion sought only limited intervention. DE 209 at 3-4.
+In the seven months that Epstein's motion has been pending, Epstein has attempted to
+take an interlocutory appeal to the Eleventh Circuit on the Court's ruling that the Government
+just provide certain correspondence regarding the NPA to the victims. See Jane Doe No. 1 and
+Jane Doe No. 2 v. United States, No. 13-12923 (filed in the 11th Circuit June 27, 2013). The
+Eleventh Circuit has set oral argument for that appeal on February 28, 2014. One of the main
+issues in the appeal is whether Epstein can even file for interlocutory relief. The victims have
+contended that, under Mohawk Industries, Inc. v. Carpenter, 130 S. Ct. 599 (2009), an
+interlocutory appeal is improper. Epstein has responded that, under Perlman v. United States,
+247 U.S. 7 (1918), he is entitled to seek immediate review as a "disinterested third party" in the
+proceedings below. Epstein's Merits Br. at 46, No. 13-12923 (filed Aug. 5, 2013) (internal
+quotation omitted).
+To resolve the dispute as to the applicability of Mohawk, it will likely be important for
+the Eleventh Circuit to know whether this Court is going to grant Epstein's unopposed motion
+for limited intervention. Otherwise, the Eleventh Circuit might be forced to make two, separate
+rulings: one regarding whether Epstein could take an interlocutory appeal if his intervention
+motion were ultimately to be granted by this Court, the other regarding whether he could do so if
+his motion were to be denied by this Court. Rather than force the Eleventh Circuit to make a
+
+
+Case 9:08-cv-80736-KAM Document 245 Entered on FLSD Docket 02/13/2014 Page 3 of 4
+bifurcated ruling, it will serve judicial efficiency if the Eleventh Circuit can render its decision
+knowing whether or not this Court has granted Epstein's (unopposed) intervention motion.
+So that the victims can present this information to the Eleventh Circuit during oral
+argument on February 28, 2014, they respectfully request that this Court issue a ruling on
+Epstein's limited intervention motion (DE 207) on or before February 27, 2014.
+Both the Government and Epstein do not oppose this motion for an expedited ruling. A
+proposed order granting the motion is also attached.
+CONCLUSION
+The Court should grant Epstein's unopposed, limited intervention motion (DE 207) and
+should do so on or before February 27, 2014.
+DATED: February 13, 2014
+Respectfully Submitted,
+/s/
+_ FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+3
+
+
+Case 9:08-cv-80736-KAM Document 245 Entered on FLSD Docket 02/13/2014 Page 4 of 4
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on February 13, 2014, on the following
+using the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoj.gov
+E-mail:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Email: pleading@royblack.com
+(305) 37106421
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Email: lefkowitz@kirkland.com
+(212) 446-4970
+G. Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Boston, 02116
+Email: owlmgw@att.net
+(617) 338-9538
+Criminal Defense Counsel for Jeffrey Epstein
+Isl
+4
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+• Case 9:08-cv-80381-KAM Document 68-2 Entered on FLSD Docket 03/25/2009 Page 1 of 3
+..
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+1.
+1, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A..,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+3.
+I represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida.
+(The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+• Case 9:08-cv-80381-KAM Document 68-2 Entered on FLSD Docket 03/25/2009 Page 2 of 3
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+6.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+• Case 9:08-cv-80381-KAM Document 68-2 Entered on FLSD Docket 03/25/2009 Page 3 of 3
+The NPA expires in late 2010.
+FURTHER THE AFFIANT SAYETH NAUGHT,
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer
+oaths and take
+acknowledgments, personally
+appeared
+Jack A. Goldberger, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+executed the same, that ! relied upon the following form of identification of the
+above named person: Awon tersonally
+-, and that an oath was/was
+not taken.
+this
+¿NINESS my hand and official seal in the County and State last aforesaid
+rebruary
+(SEAGE
+dotary Public State of Flonia
+LE Rosin
+My Commission DD489790
+Expires 11/13/2009
+KIn E ReSIr
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11/13/2009
+Page - 3 -
diff --git a/vision-fixhub/court-01/e4be864e6f541da24f4fdce025af1dfe042fe4a69859f64a397b90da75fd4708.receipt.json b/vision-fixhub/court-01/e4be864e6f541da24f4fdce025af1dfe042fe4a69859f64a397b90da75fd4708.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/e4e19ca3f6547ed5dfc5522b253f38dda417ab0c37f1a18c2b94e44afafff7e5.md b/vision-fixhub/court-01/e4e19ca3f6547ed5dfc5522b253f38dda417ab0c37f1a18c2b94e44afafff7e5.md
new file mode 100644
index 0000000000000000000000000000000000000000..af56a70708fb2bd874dd926364ee73ebbcf0d95a
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@@ -0,0 +1,139 @@
+Case 9:08-cv-80119-KAM Document 492 Entered on FLSD Docket 03/18/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+JOINT MOTION FOR AN EXTENSION OF TIME
+TO COMPLETE DISCOVERY DEADLINES AND SHORTEN EXPERT DISCLOSURES
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys, and
+Plaintiffs, JANE DOES 2-7, by and through their undersigned attorneys respectfully moves this
+Court for an extension of time to complete discovery deadlines, and as good cause in support of
+granting the motion, states as follows:
+These cases are currently set on a two week trial docket commencing on
+September 27, 2010.
+The majority of the depositions of Plaintiffs have been taken but the majority
+have not been completed. A number of witness depositions have yet to occur. In fact, Defendant
+has over thirty (30) depositions that he believes are needed to complete discovery, dates for
+which Defendant's counsel requested from Plaintiffs' counsel on March 9, 2010. Plaintiffs
+
+
+Case 9:08-cv-80119-KAM Document 492 Entered on FLSD Docket 03/18/2010 Page 2 of 4
+Page 2
+counsel is working on the scheduling of these depositions. Additionally, the deposition of Jeffrey
+Epstein has not been completed, and Plaintiffs have additional depositions to take, some of'
+which are out of state.
+The scheduling of depositions in this matter has become much more difficult
+since the case was consolidated on May 14, 2009, due to the number of attorneys involved and
+the fact that witnesses, plaintiffs and the defendant may only be deposed once. (See Order
+Consolidating Cases for Purpose of Discovery and Procedural Motions That Relate to Multiple
+Cases). Additionally, many of the witnesses retained their own counsel, and the depositions
+need to be coordinated with those attorneys' schedules.
+Due to the fact that depositions are still being scheduled, both Plaintiffs and
+Defendant are in agreement with extending the discovery cutoff in Jane Does 2-4 an additional
+two (2) weeks from April 12, 2010, making the new discovery cutoff date April 30, 2010 and
+extending the discovery cutoff in Jane Does 5-7 to May 28, 2010.
+6.
+Further, the current scheduling order requires expert reports to be disclosed on
+July 1, 2010. The parties have agreed to disclose the expert reports in Jane Does 2-4 on May 14,
+2010 and in Jane Does 5-7 on June 6, 2010.
+WHEREFORE, Plaintiffs and Defendant request that this Court enter an order granting
+the Motion for Extension of Time to Complete Discovery Deadline and Shorten Expert
+Disclosures.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Counsel for the parties conferred via e-mail and are in agreement with moving the above
+dates.
+
+
+Case 9:08-cV-80119-KAM Document 492 Entered on FLSD Docket 03/18/2010 Page 3 of 4
+Page 3
+By: Is/ Robert D. Critton
+ROBERT D. CRITTON, ESQ.
+Florida Bar # 224162
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+Respectfully submitted,
+By: Is/ Robert D. Critton
+ROBERT D. CRITTON, JR., ESQ.
+crit@bciclaw.com
+MICHAEL J. PIKE, ESO
+BURMAN, CRITTON, LUTTIER & COLEMAN
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 492 Entered on FLSD Docket 03/18/2010 Page 4 of 4
+Page 4
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+I, Jaffe, Weissing,
+, Fistos &
+Adam D. Horowitz, Esq.
+Lehrman, PL
+Mermelstein & Horowitz, P.A.
+425 N. Andrews Avenue
+18205 Biscayne Boulevard
+Suite 2
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-524-2820
+305-931-2200
+Fax: 954-524-2822
+Fax: 305-931-0877
+brad@pathtojustice.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08- Paul G. Cassell, Esq.
+80232, 08-80380, 08-80381,
+08-80993, 08- Pro Hac Vice
+80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Jack Alan Goldberger, Esq.
+801-585-5202
+Atterbury Goldberger & Weiss, P.A.
+801-585-6833 Fax
+250 Australian Avenue South
+cassellp@law.utah.edu
+Suite 1400
+Co-counsel for Plaintiff Jane Doe
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+L. Esq.
+HI! Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+Robert C. Josefsberg, Esq.
+561-832-7137 F
+Katherine W. Ezell, Esq.
+isidrogarcia@bellsouth.net
+Podhurst Orseck, P.A.
+Counsel for Plaintiff in Related Case No. 08-
+25 West Flagler Street, Suite 800
+80469
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e4e19ca3f6547ed5dfc5522b253f38dda417ab0c37f1a18c2b94e44afafff7e5.receipt.json b/vision-fixhub/court-01/e4e19ca3f6547ed5dfc5522b253f38dda417ab0c37f1a18c2b94e44afafff7e5.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/e51ce937717c7a0f1e52b7aa4e80f67b8fb39d206fee9124bc84ee9bb987eec2.md b/vision-fixhub/court-01/e51ce937717c7a0f1e52b7aa4e80f67b8fb39d206fee9124bc84ee9bb987eec2.md
new file mode 100644
index 0000000000000000000000000000000000000000..0bf7c68a4a8311df259e1edb210e1af2a24507e2
--- /dev/null
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@@ -0,0 +1,35 @@
+Case 1:19-cv-08673-KPF-DCF Document 52 Filed 02/14/20 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+Jeffrey E. Epstein,
+Defendants.
+Case No. 19 Civ. 8673 (KPF) (DCF)
+DECLARATION OF ROBERTA A. KAPLAN IN SUPPORT OF
+PLAINTIFFS' OPPOSITION TO DEFENDANTS' MOTION TO DISMISS
+I, Roberta A. Kaplan, pursuant to 28 U.S.C. § 1746, declare as follows:
+I am a member of the Bar of the State of New York, and I am admitted to appear
+before this Court. I am a partner with the law firm Kaplan Hecker & Fink LLP, counsel for Plaintiff
+Jane Doe in the above-captioned action. I respectfully submit this Declaration in support of
+Plaintiffs' Opposition to Defendants' Motion to Dismiss. Unless stated otherwise, the facts stated
+herein are of my own personal knowledge, and if called as a witness I could competently testify
+thereto.
+2.
+Attached hereto as Exhibit 1 is a true and correct copy of the Complaint filed in,
+Government of the United States Virgin Islands v. Estate of Jeffrey E. Epstein, et al., ST-20-CV-
+14.
+Attached hereto as Exhibit 2 is a true and correct copy of the Last Will and
+Testament of Jeffrey E. Epstein.
+I declare under penalty of perjury that the foregoing is true and correct.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 52 Filed 02/14/20 Page 2 of 2
+Dated: February 14, 2020
+New York, New York
+Is/ Roberta A. Kaplan
+Roberta A. Kaplan
+-2-
diff --git a/vision-fixhub/court-01/e51ce937717c7a0f1e52b7aa4e80f67b8fb39d206fee9124bc84ee9bb987eec2.receipt.json b/vision-fixhub/court-01/e51ce937717c7a0f1e52b7aa4e80f67b8fb39d206fee9124bc84ee9bb987eec2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a1b7bee930f660084433366b5f17f4165d308564
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+  "output_sha256": "717543c6970ea17329508f36763f7fe7b38049d079d1c46906280ba451b6a212",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.md b/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.md
new file mode 100644
index 0000000000000000000000000000000000000000..763e75b9878b416ce530277c852b925ed9ac1f30
--- /dev/null
+++ b/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.md
@@ -0,0 +1,32 @@
+Case 9:09-cv-80591-KAM Document 84-1
+Entered on FLSD Docket 11/20/2009 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+AGREED ORDER ON DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+(AS TO CMA V. EPSTEIN AND
+, 08-CIV-80811)
+This matter came before the Court on Defendant Epstein's Motion to Attend
+Mediation and Plaintiffs counsel being in agreement with the entry of this order, it is
+HEREBY ORDERED and ADJUDGED that:
+The court's no contact order, [DE 238], shall not preclude Defendant Epstein
+deposition, mediation, or the trial of this
+from attending Plaintiff
+case.
+DONE and ORDERED this
+_day of
+_ 2009
+Linnea R.
+United States Magistrate Judge
+Courtesy Copies:
+Judge Kenneth Marra
+Counsel of record
diff --git a/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.receipt.json b/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1c56de4cb899853b253f7a8c279dddca0ee0fdc1
--- /dev/null
+++ b/vision-fixhub/court-01/e51d80fc01b9ab7383701e752f057ee6dbdf0339d270109fa8f183ebdc9b5746.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "output_sha256": "8908813619a16b2cd4dc7a03c6c83aef907e4d80fa81d5ed0ca497ad7dff2d69",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e52af3e9b9fa72269751a03dec8e9b65a99cc66b94a7593370c1952a42d8612f.md b/vision-fixhub/court-01/e52af3e9b9fa72269751a03dec8e9b65a99cc66b94a7593370c1952a42d8612f.md
new file mode 100644
index 0000000000000000000000000000000000000000..933615e2965aec257b91baffb277564279a4071c
--- /dev/null
+++ b/vision-fixhub/court-01/e52af3e9b9fa72269751a03dec8e9b65a99cc66b94a7593370c1952a42d8612f.md
@@ -0,0 +1,135 @@
+Case 9:09-cv-80591-KAM Document 48
+Entered on FLSD Docket 06/09/2009 Page 1 of 5
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+JANE DOE No. 101,
+Plaintiff,
+Civil Action No. 09-80591-CIV-Marra/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF JANE DOE NO.101'S MOTION FOR ENLARGEMENT OF TIME
+AND PAGE LIMITS FOR RESPONSE TO DEFENDANT'S MOTION TO DISMISS
+THE FIRST AMENDED COMPLAINT OR, IN THE ALTERNATIVE,
+FOR A MORE DEFINITE STATEMENT
+Plaintiff, Jane Doe No. 101 ("Plaintiff"), moves this Court for an order enlarging the time
+and page limits in which she must reply to Defendant's Motion to Dismiss the First Amended
+Complaint or, in the Alternative, for a More Definite Statement. The grounds for this motion are as
+follows:
+Plaintiff's First Amended Complaint [DE 9] was filed on May 1, 2009.
+Pursuant to an unopposed motion for enlargement, Defendant filed his Motion to
+Dismiss Plaintiff's First Amended Complaint or, in the Alternative, for a More Definite Statement
+("'Motion to Dismiss") on May 26, 2009. [DE 29] The Motion is 36 pages.
+3.
+Ordinarily, a response to the Motion to Dismiss would be due on June 12, 2009. As
+it happens, however, the Court has set a hearing on that very day for all cases consolidated for
+discovery and procedural issues under the case known as Jane Doe No. 2 vs. Jeffrey Epstein, Case
+No.09-CV-80119-MARRA/
+• Apparently the Court set the hearing as the result of
+
+
+Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 2 of 5
+Defendant's seeking to stay/continue all civil cases pending against him and the Court's own inquiry
+as to whether the Defendant is in breach of the Non-Prosecution Agreement between the Defendant
+and the United States.
+Under any circumstances, responding to Defendant's Motion would take more
+than the usual time allotted under the Local Rules for the Southern District of Florida, because of
+its length, comprehensiveness and complexity. In this instance, however, the fact and importance
+of the hearing set for June 12" is a further complication which will likely affect the substance of
+Plaintiff's response, as well as its timing. Furthermore, Defendant's motion combines two motions
+in one 36 page document. Plaintiff seeks leave to file an equal number of pages in response.
+5.
+The issues raised by Defendant's Motion to Stay/Continue the Civil Cases Pending
+Against Him and the Court's inquiry are intertwined with many of those issues that will necessarily
+be involved in Plaintiff's response to Defendant's Motion to Dismiss. It would be a waste of the
+time of the undersigned attorneys to prepare a response to the Motion to Dismiss and of the judicial
+labor involved in reviewing it, when the response may be made obsolete, irrelevant or incomplete
+on the very day it is due as the result of matters to be discussed at the hearing on June 12'.
+6.
+This motion is not made for the purpose of delay and should be granted in the interest
+of equity and fairness.
+WHEREFORE, Plaintiff, Jane Doe No. 101, requests an enlargement of time of up to 14
+days and page limits of up to 36 pages in which she must reply to Defendant's Motion to Dismiss
+the First Amended Complaint or, in the Alternative, for a More Definite Statement, so as to make
+her reply due five (5) days after the Court issues its ruling resulting from the hearing set for June 12,
+2009, or on June 26, 2009, whichever is later.
+2
+
+
+Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 3 of 5
+CERTIFICATE OF HAVING CONFERRED WITH OPPOSING
+COUNSEL PURSUANT TO S.D.L.R. 7.1.A.3
+Katherine W. Ezell, one of the undersigned counsel for the Plaintiff hereby certifies that she
+has conferred with one of the attorneys for the Defendant, Robert Critton, Esq. about the matters
+raised in this Motion. Mr. Critton advised that the Defendant does not oppose the Motion or the
+relief sought herein.
+DATED this 9" day of June, 2009.
+Respectfully submitted,
+By:
+Robert C. Josefsberg
+Robert C. Josefsberg,
+Bar No. 040856
+Katherine W. Ezell, Bar No. 114771
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+(305) 358-2800
+(305) 358-2382 (fax)
+rjosetsberg@podhurst.com
+kezell@podhurst.com
+Attorneys for Plaintiff
+3
+
+
+Case 9:09-cv-80591-KAM Document 48 Entered on FLSD Docket 06/09/2009 Page 4 of 5
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this 9* day of June, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By:
+s/Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+4
+
+
+Case 9:09-cv-80591-KAM Document 48
+Entered on FLSD Docket 06/09/2009 Page 5 of 5
+SERVICE LIST
+JANE DOE NO. 101 v. JEFFREY EPSTEIN
+Case No. 08-CV-80591-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+rcrit@bclclaw.com
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+jagesq@bellsouth.net
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ect@brucereinhartlaw.com
+Counsel for Co-Defendant, Sarah
+5
diff --git a/vision-fixhub/court-01/e52af3e9b9fa72269751a03dec8e9b65a99cc66b94a7593370c1952a42d8612f.receipt.json b/vision-fixhub/court-01/e52af3e9b9fa72269751a03dec8e9b65a99cc66b94a7593370c1952a42d8612f.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/e53ea514ce0d0e5a7f53f244ad7a5ce55d655b4c3789843536f5adadba705c1e.md b/vision-fixhub/court-01/e53ea514ce0d0e5a7f53f244ad7a5ce55d655b4c3789843536f5adadba705c1e.md
new file mode 100644
index 0000000000000000000000000000000000000000..01dfdb0cd276fac38fabd84735c7cfbb3c845465
--- /dev/null
+++ b/vision-fixhub/court-01/e53ea514ce0d0e5a7f53f244ad7a5ce55d655b4c3789843536f5adadba705c1e.md
@@ -0,0 +1,336 @@
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 1 of 13
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant,
+ROY BLACK, et al.,
+Intervenors.
+INTERVENORS' MOTION FOR A PROTECTIVE CONFIDENTIALITY
+ORDER AND INCORPORATED MEMORANDUM OF LAW
+Intervenors Roy Black,
+Weinberg, and Jeffrey Epstein, pursuant to Rule 26(c)
+of the Federal Rules of Civil Procedure and Local Rule 26.1, respectfully move this Court
+for the entry a Protective Confidentially Order which (1) limits the dissemination of certain
+Confidential Discovery Material ("CDM") described below, to a designated list of the
+Plaintiffs' counsel and support staff, and (2) prohibits any party from filing pleadings, briefs,
+memorandums or exhibits purporting to reproduce, quote, paraphrase or summarize any
+CDM or portions thereof, absent leave of the Court to file the document or portion thereof
+under seal in accordance with Local Rules of the United States District Court for the
+Southern District of Florida. See Exhibit 1, Proposed Protective Confidentiality Order.
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 2 of 13
+In support of this motion, the Intervenors submit the following Memorandum. Part I
+sets forth the background of this matter. Part II demonstrates why the Court can and should
+issue the requested protective order.
+MEMORANDUM
+1. BACKGROUND
+Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with
+the government in September, 2007. Under that agreement, Mr. Epstein pled guilty to two
+state felony offenses and served a prison sentence and a term of community control
+probation. The agreement, with which he has fully complied, also required that he pay the
+legal fees of the attorney-representative of identified victims and that he not contest liability
+in any cases brought against him solely under 18 U.S.C. § 2255. Plaintiffs sued under § 2255
+and received settlements as the direct result of Mr. Epstein's agreement not to contest
+liability in those cases. Plaintiffs, such as the Jane Does in this case, "relied on the [NPA]
+when seeking civil relief against Epstein ... and affirmatively advanced the terms of the
+[NPA] as a basis for relief from Epstein." United States' Reply in Support of its Motion to
+Dismiss for Lack of Subject Matter Jurisdiction, Doc. 205-6 at 12-13.
+After reaping the benefits of the NPA, the plaintiffs seek herein, among other
+remedies, the rescission of that agreement. During the course of civil litigation against Mr.
+Epstein, Mr. Epstein was ordered, over his strenuous objection, to produce documents given
+to him by the government during the course of his settlement/plea negotiations with it. See
+-2-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 3 of 13
+Jane Doe #2 v. Epstein, No. 08-80119-MARRA, Doc. 462. Once the CVRA action was
+reactivated - after plaintiffs had successfully pursued their civil monetary remedies against
+Mr. Epstein to completion - plaintiffs sought to use that correspondence in the CVRA case
+and thereafter also sought disclosure from the government of correspondence authored and
+sent to the government by Mr. Epstein's attorneys in the course of their efforts on behalf of
+their client to resolve the ongoing criminal investigation of him. Both Mr. Epstein and his
+criminal defense attorneys - Intervenors Roy Black and l
+Weinberg - filed motions to
+intervene for the limited purpose of challenging the use and disclosure of the settlement/plea
+negotiation correspondence (Doc. 56, 93), followed by supplemental briefing and motions
+contending, among other things, that the correspondence fell within the bounds of privilege
+under Fed. R. Evid. 501. Doc. 94, 160,161, 162.
+This Court granted the motions to intervene (Doc. 158, 159), but ultimately ruled that
+the correspondence - the CDM at issue in the instant motion - was subject to disclosure.
+Doc. 188. Among other things, the Court rejected Intervenors' argument based on Rule 501
+on the ground that Congress has already addressed the issue in Fed. R. Crim. P. 11(f) and
+Fed. R. Evid. 410 and likewise rejected the Intervenors' request that the Court recognize a
+privilege for plea negotiation communications. Id. at 8-9. The Intervenors appealed the
+Court's ruling to the Eleventh Circuit. However, on April 14, 2014, the Eleventh Circuit
+affirmed the Court's rulings using the same rationales.
+-3-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 4 of 13
+II. ARGUMENT
+Although the Court ruled that the Plaintiffs could discover the CDM, the Court
+reserved ruling on how the Plaintiffs could use the material thereafter, expressly cautioning
+that "this order is not intended to operate as a ruling on the relevance or admissibility of any
+particular piece of correspondence, a matter expressly reserved for determination at the time
+of final disposition." Doc 188, p. 10. Unless and until the Court determines those reserved
+issues, the Court should bar the Plaintiffs from disseminating and/or publicly disclosing the
+substance of the CDM absent further order of the Court.
+A. Discovery Should Not Be Routinely Made Available to the Public
+"The Eleventh Circuit has repeatedly acknowledged the private nature of discovery"
+Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48349, at *3, citing Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263 F.3d
+1304, 1316 (11" Cir. 2001) ("Discovery, whether civil or criminal, is essentially a private
+process because the litigants and the courts assume that the sole purpose of discovery is to
+assist trial preparation.") (quoting United States v.
+799 F.2d 1438, 1441 (11" Cir.
+1986; emphasis in original). See also
+, 799 F.2d at 1441 ("Historically, discovery
+materials were not available to the public or press.") (citation omitted); In re: Denture
+Cream Products Liability Litigation, No. 09-2051-MD-Altonaga/Simonton (S.D. Fla. Jan.
+18, 2013), 2013 U.S. Dist. LEXIS 8114, at *37 ("the common law right of access to judicial
+proceedings does not apply to discovery materials, 'as these materials are neither public
+-4-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 5 of 13
+documents nor judicial records'") (quoting Chicago Tribune, 263 F.3d at 1311; citation
+omitted). Thus, "[a] court may restrict distribution of discovery material even if there
+"certainly is a public interest in knowing more' about its contents." Tillman v. C.R. Bard,
+Inc., Case No. 3:13-cv-222-J-34JBT (M.D. Fla. March 13, 2014), 2014 U.S. Dist. LEXIS
+41406, at *6, quoting Seattle Times Co. v. Rhinehart, 467 U.S. 20, 31 (1984)
+Placing limitations on the dissemination and use of pretrial discovery is particularly
+important since "[t]he overwhelming majority of documents disclosed during discovery are
+likely irrelevant to the underlying issues..." Federal Trade Commission v. Abbvie Products
+LLC, 713 F.3d 54, 63 (11" Cir. 2013). Therefore, "[s]uch documents, prior to admission into
+the record in support of a motion or as evidence at trial, 'play no role in the performance of
+Article III functions' of a federal judge." Travelers Indemnity Co. v. Excalibur Reinsurance
+Corp., No. 3:11-CV-1209 (CSH) (D. Conn. Aug. 5, 2013), 2013 U.S. Dist. LEX/S 110400,
+at *37, quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995).
+These principles are vitally important here where counsels' private communications
+with prosecutors "if publicly released could be damaging to reputation and privacy" and
+would likely constitute an "abuse of [a court's] processes." Seattle Times, 467 U.S. at 35
+While courts have recognized that settlement agreement materials may sometimes be
+discoverable, see, e.g., In re MSTG, Inc., 675 F.3d 1337, 1348 (Fed. Cir. 2012),' they are
+' But see Wagner v. Wastiffs, Case No. 2:08-cv-431 (S.D. Ohio May 14, 2013), 2013 U.S. Dist.
+LEXIS 68349 (denying motion to compel discovery of settlement agreement on relevancy grounds);
+Duncan v. Phoenix Supported Living, Inc., No. 2:05cv1 (W.D. N.C. Sept. 12, 2006), 2006 U.S. Dist.
+(continued...)
+-5-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 6 of 13
+rarely admissible as evidence at trial, see, e.g, LaserDynamics, Inc. v. Quanta Computer,
+Inc., 694 F.3d 51, 78 (Fed. Cir. 2012) (reversing district court for admitting settlement
+agreement at trial); Apple, Inc. v. Samsung Electronics Co., Ltd., Case No. 11-CV-01846-
+LHK (N.D. Cal. Nov. 7, 2013), 2013 U.S. Dist. LEXIS 160337, at **51-54 (barring parties
+from relying on settlement agreement at trial under Fed. R. Evid. 403).
+For this reasons alone, it is appropriate to limit the dissemination and use of discovery
+concerning settlement discussions, even if not privileged. See Charles E. & Associates,
+Inc. v. ABT Electronics, Inc., 854 F. Supp. 2d 427, 430 (E.D. Tex. 2012) (designating
+discovery material including settlement communications as "Outside Counsel Eyes Only
+Confidential Information" and cautioning parties that while it is allowing the discovery it
+intends to later weigh relevance carefully and noting that settlement negotiations are "always
+suspect to some degree and are often littered with unreal assertions and unfounded
+expectations ... And are not always grounded in facts or reason."). Indeed, unless and until
+the Plaintiffs demonstrate a bona fide need to use the discovery at trial or in pleadings, the
+Intervenors need not even demonstrate "good cause" in order to obtain relief. As the Hon.
+Karon Owen Bowdre, Chief Judge of the U.S. District Court for the Northern District of
+Alabama recently held:
+(..continued)
+LEXIS 66742, at **9-11 (finding settlement communications non-discoverable as "not... Likely to
+lead to the disclosure of admissible evidence" and would tend to chill settlement efforts) (citations
+omitted).
+-6-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 7 of 13
+Based on this standard of practice, the court finds that restricting
+the use of discovery materials to case-related purposes only,
+even over Plaintiffs' objection, is within this court's discretion
+and authority even without the application of the Rule 26(c)
+good cause standard. By its text, Rule 26(c) applies to situations
+where the court is either limiting what a party has to produce at
+all in the discovery process, or limiting public access to
+documents that are actually filed in the case. Fed. R. Civ. Pro.
+26(c). The disputed limitation in this case does not fall into
+either of these categories...
+Looney v. Moore, No. 2:13-CV-00733-KOB (N.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48349, at ** 4-5 (emphasis in original).
+B. Good Cause Exists For the Protective Order In Any Event
+Even if the Intervenors would be required to demonstrate "good cause" for the
+requested protective order at this point, that standard is met where restrictions are appropriate
+under Rule 26(c) to protect the Intervenors from "annoyance, embarrassment, oppression,
+or undue burden or expense." See Looney, 2014 U.S. Dist. LEXIS 48349, at *5; Irizarry-
+v. Essilor Industries, 293 F.R.D. 100, 104 (D. P.R. 2013). The Intervenors include
+not only the third-party client whose non-prosecution agreement is the one Plaintiffs are
+trying to undo but also the client's attorneys, who are even further removed from the actual
+litigants. Counsels' lengthy arguments may or may not have had any influence on the
+government's decision-making and, therefore, their relevance is particularly remote. Cf.
+United States v. Byrd, Crim. No. 13-0266-WS (S.D. Ala. April 7, 2014), 2014 U.S. Dist.
+LEXIS 48035, at **14-18 (denying newspaper's motion to obtain copies of unsolicited
+sentencing letters mailed to the judge prior to sentencing, despite "no formal promises of
+-7-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 8 of 13
+secrecy or confidentiality," because "the privacy interests of the letter writers and the
+interests of the judicial system in obtaining hones, uncensored input" outweighed public's
+interest in disclosure, especially where the sentencing letters "neither drove no significantly
+impacted the sentencing decision" which was based on a plea agreement).
+Like the situation at issue in Looney, the instant case is a "high profile" one and
+should not be "tried in the media, rather [than] in the courtroom." Looney, 2014 U.S. Dist.
+LEXIS 48349, at *5. Moreover, there is a well documented history in this case of the media
+reporting inflammatory statements made by Plaintiffs' counsel, either directly to the press or
+in pleadings, and these statements have frequently been based on discovery materials. See,
+e.g., Attorneys Say Miami Prosecutors Violated Crime Victims' Rights Act, Main Justice,
+March 22, 2011 (quoting Plaintiffs' motion asserting that the U.S. Attorney's Office
+"deliberately misled' them and claiming that the "only reason" the U.S. Attorney's Office
+"concealed the existence of the non-prosecution agreement from them was "to avoid a
+firestorm of public controversy that would have erupted if the sweetheart plea dal with a
+politically connected billionaire had been revealed"); Attorneys want Jeffrey Epstein
+agreement thrown
+out,
+PalmBeachDailyNews.com, March 21, 2011 (repeating
+aforementioned accusations from Plaintiffs' motion attacking the U.S. Attorney's Office,
+adding that the Office had allegedly engaged in a "pattern of deception" and noting that
+Plaintiffs' motion had made references to "e-mails and letters from the federal office to
+Epstein's lawyers"); News Reports about Billionaire Pedophile Jeffrey Epstein Highlight the
+-8-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 9 of 13
+Importance of Victims Rights, BriefingWire.com, March 8, 2011 (quoting Plaintiffs' counsel
+saying "we took on powerful people and sought to level the playing field to protect victims"
+and that he "hopes that the media attention" will "inspire victims" to "hold predators
+accountable"); Judge Receives Epstein Tape Ruling Pending, Palm Beach Daily News, May
+5, 2010 (quoting plaintiffs' counsel as arguing that a 22-minute tape recording of Mr. Epstein
+was ""critical"" in showing his alleged ""lack of remorse"" and that he was a "pitiless" sexual
+abuser); Lawyer: Epstein Made Admissions On Tape, Palm Beach Daily News (FL), April
+29,2010 (quoting Plaintiffs' motion concerning the same tape recording); Attorney For
+Epstein Victims: 'Thave Never Seen A Stranger Case', Palm Beach Daily News, September
+20, 2009, p. A.1 (quoting Plaintiffs' counsel as opining that Mr. Epstein "could have gone
+to prison for life," that he had "never seen a stranger case" and that the U.S. Attorney's
+Office was effectively "saying we'll do everything in our power to see he doesn't get
+punished"); Palm Beach sex offender's secret plea deal: Possible co-conspirators not
+charged, presses victims to settle civil suits, The Palm Beach Post, September 18, 2009
+(quoting Plaintiffs' counsel as saying that non-prosecution agreement "taught [the victims]
+that someone with money can buy his way out of anything.
+It's outrageous and
+embarrassing..."); Judge to Rule on Sealed Plea-Deal Papers Today, Palm Beach Daily
+News, June 25, 2009, p. A.1 (reporting Plaintiffs' counsel saying that he wanted to use the
+settlement documents in depositions); Hearing Set to Consider Secrecy of Plea Bargain,
+Sun-Sentinel (Ft. Lauderdale, Florida), Palm Beach Edition, June 15, 2009, p. 3B (in
+-9-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 10 of 13
+response to reporter's question about whether he thought Mr. Epstein had received special
+treatment, Plaintiffs' counsel quoted as saying: "Are you kidding? It's transparent.
+Certainly, no one else gets treated like that"). See Composite Exhibit 2.
+The publicity-generating comments by Plaintiffs' counsel have continued since the
+Eleventh Circuit's ruling. The wave began on April 21, 2014. That day, the Washington
+Post published a lengthy letter written by one of Plaintiffs' lead counsel containing his
+editorialized history of the case criticizing the Intervenors' arguments and concluding with
+his opinion that "the federal prosecutors deliberately concealed the sweetheart plea deal."
+See Composite Exhibit 3. The same attorney was also quoted by the Sun-Sentinel as making
+the unsupported accusation that somehow Mr. Epstein "used his political connections and
+great wealth" to secure a plea bargain that, in counsel's opinion "was unheard of, frankly, if
+you look at these charges." Id. Also that same day, the Plaintiffs' other lead counsel was
+quoted by the Palm Beach Daily News as referring to Mr. Epstein as "[a] well-connected
+billionaire" who "got away with molesting many girls." Appeals court rules against sex
+offender; Attorneys for underage victims seek to overturn
+"sweetheart plea',
+PalmBeachDailyNews.com, April 21, 2014. Id.
+On April 22, 2014, the same attorney issued a "press release" likewise trumpeting the
+appellate victory, identifying Mr. Epstein's counsel by name and containing a personal
+statement from counsel. See Composite Exhibit 4. In a parallel article published in the
+Daily Business Review, Plaintiffs' counsel was quoted as follows: "
+said the
+-10-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 11 of 13
+documents at this point will be disclosed only to the plaintiffs and will not become part of
+the public record." Id. (emphasis added). The implication of the "at his point" qualifier
+suggests that Plaintiffs' counsel plan to inject the private discovery into "the public record"
+at a later date.
+The next day, April 23, 2014, the Facebook page for the |
+Jaffe Weissing law
+firm began posting multiple photographs of Mr. Epstein with links to numerous newspaper
+articles about the case, along with snippets of prejudicial quotations from Plaintiffs' counsel.
+See Composite Exhibit 5. The same comments were then posted on the law firm's blog
+"www.pathtojustice.com with yet another large photograph of Mr. Epstein, resembling a mug
+shot. Id. The blog includes such personalized opinions, such as: "We have a very strong
+case that, prodded by Epstein, the federal prosecutors deliberately concealed the sweetheart
+plea deal." Id.
+In light of the prominence of this case in the media, the repeated use of the media by
+Plaintiffs counsel to drum up support for their case (and to prejudice the community against
+Mr. Epstein and his counsel), and the Plaintiffs' suggestion that they could make the CDM
+available to the public in the future (just not "at this point"), the requested protective order
+is more than justified. As Chief Judge Bowdre likewise concluded in a similar, but less
+egregious, situation:
+The court has already expressed to the parties its concern that
+this potentially high profile case will be tried in the media, rather
+in the courtroom. Significant media coverage of the case has
+already occurred. In the interest of justice, this court is
+-11-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 12 of 13
+committed to giving both parties a fair trial, which includes
+protecting the Defendants from the "annoyance, embarrassment,
+[and] oppression" that could occur from allowing their names to
+be dragged through the metaphorical mud before a jury has even
+made any determination of wrongdoing. At least one other court
+has cited the risk of excessive publicity preventing the selection
+of an impartial jury as legitimate support for a finding of good
+cause under Rule 26(c). See
+v. Cryovac, Inc., 805 F.2d
+1, 4 (Ist Cir. 1986) (overturning the district court's decision on
+other grounds). As such, the court finds that good cause exists
+to support the Protective Order as written....
+Looney v. Moore, 2014 U.S. Dist. LEXIS 48349, at **5-6.
+LOCAL RULE 7.1(a)(3) CERTIFICATION
+Counsel hereby certify that they have conferred with all parties who may be affected
+by the relief sought in this motion in a good faith effort to resolve the issues raised in the
+motion and have been unable to do so. Plaintiffs oppose this motion.
+CONCLUSION
+For all of the foregoing reasons, the Court should GRANT this motion and enter the
+requested Protective Order.
+Respectfully submitted,
+Is/Roy Black
+Roy Black
+Jackie Perczek
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 So. Biscayne Blvd., Suite 1300
+Miami, Florida 33131
+Tele: (305) 371-6421
+- 12-
+
+
+Case 9:08-cv-80736-KAM Document 247 Entered on FLSD Docket 05/02/2014 Page 13 of 13
+Fax: (305) 358-2006
+rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+/S.
+G. Weinberg.
+G. Weinberg
+20 Park Plaza, Suite 1000
+Boston, Massachusetts 02116
+Tele: (617) 227-3700
+Fax: (617) 338-9538
+owlmgw@att.net
+Attorney for Intervenors
+CERTIFICATE OF SERVICE
+THERE CERTIFY that a true copy of the foregoing was filed via CM/ECF, this
+2nd day of May, 2014.
+Is/Roy Black
+Roy Black
+-13-
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diff --git a/vision-fixhub/court-01/e53ebc56c04393f75beb952327357ea226f564d11346332fdb42c1f0e311f101.md b/vision-fixhub/court-01/e53ebc56c04393f75beb952327357ea226f564d11346332fdb42c1f0e311f101.md
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@@ -0,0 +1,38 @@
+IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
+FOURTH DISTRICT, 110 SOUTH TAMARIND AVENUE, WEST PALM BEACH, FL 33401
+July 9, 2024
+CA FLORIDA HOLDINGS, LLC, Publisher of THE CASE NO. - 4D2024-0681
+PALM BEACH POST,
+L.T. No. - 502019CA014681
+Appellant(s)
+V.
+DAVE ARONBERG, as State Attorney of Palm
+Beach County, Florida and SHARON R. BOCK, as
+Clerk and Comptroller of Palm Beach County,
+Florida,
+Appellee(s).
+BY ORDER OF THE COURT:
+CQPY
+Pursuant to the notice of voluntary dismissal filed herein, this appeal is dismissed.
+Served:
+Nina D. Boyajian
+Brigid F. Cech Samole
+Palm Beach Clerk
+Hon. Luis Delgado, Jr.
+Michael J. Grygiel
+Collin Doern
+Jessica Neer McDonald
+Stephen Arthur Mendelsohn
+Douglas Arthur Wyler
+CT
+CERTIFIE
+I HEREBY CERTIFY that the foregoing is a true copy of the court's order.
+onzes Keiscblum
+LONN WEISSBLUM, Clerk
+Fourth District Court of Appeal
+4D2024
+ST
+OF
+FLORID
+FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK 07/09/2024 2:24 PM
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e54090d17f577ce60c5ae6f423c449c7348fd825da2a1a4180ebc5d455b3f169.md b/vision-fixhub/court-01/e54090d17f577ce60c5ae6f423c449c7348fd825da2a1a4180ebc5d455b3f169.md
new file mode 100644
index 0000000000000000000000000000000000000000..f39f2facbe21050ab09e675baaa96637f01e36b5
--- /dev/null
+++ b/vision-fixhub/court-01/e54090d17f577ce60c5ae6f423c449c7348fd825da2a1a4180ebc5d455b3f169.md
@@ -0,0 +1,120 @@
+Case 9:08-cv-80119-KAM Document 567 Entered on FLSD Docket 06/14/2010 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+EPSTEIN'S REPLY TO PLAINTIFF JANE DOE'S PROTECTIVE
+RESPONSE TO DEFENDANT'S MOTION FOR RECONSIDERATION
+AND/OR REQUEST FOR RULE 4 APPEAL (DE 551)
+Defendant, JEFFREY EPSTEIN ("Epstein"), submits his Reply to Plaintiff, Jane Doe's
+Protective Response to Defendant's Motion for Reconsideration and/or Request for Rule 4
+Appeal (DE #551) and states:
+1. On May 12, 2010, Defendant filed his Consolidated Rule 4 Review and Appeal of
+Portions of Magistrate's Orders dated February 4, 2010 (Des 462, 480) and April 1, 2010 (DE
+513) with Incorporated Objections and Memorandum of Law.
+2. On May 27, 2010, Plaintiff filed her Protective Response to Defendant's Motion for
+Reconsideration and/or Request for Rule 4 Appeal.
+3. On June 11, 2010, Defendant and Plaintiffs Jane Does 2-8 filed their Joint Notice of
+
+
+Case 9:08-cv-80119-KAM Document 567 Entered on FLSD Docket 06/14/2010 Page 2 of 3
+withdrawal of their arguments related to the Rule 4 Review and Appeal as it relates to Jane Does
+2-8. However, this consolidated Appeal shall remain active as to Jane Doe (08-80893) as that
+case still remains active.
+4. Notice is hereby given that the Rule 4 Review and Appeal as it pertains only to Jane
+Doe (08-80893) is fully briefed.
+Respectfully submitted,
+By: —
+s/Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 14th day of June, 2010.
+_s/Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+2
+
+
+Case 9:08-cv-80119-KAM Document 567 Entered on FLSD Docket 06/14/2010 Page 3 of 3
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Adam D. Horowitz, Esq.
+5, Fistos &
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz/@sexabuseattorney.com
+Counsel for Plaintiffs
+i, Esq.
+, Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+badase to matic om Related Case No. 08-
+80893
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232,
+: 08-80380, 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Estein
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.L
+1, Esq.
+_ Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-
+80469
+3
diff --git a/vision-fixhub/court-01/e54090d17f577ce60c5ae6f423c449c7348fd825da2a1a4180ebc5d455b3f169.receipt.json b/vision-fixhub/court-01/e54090d17f577ce60c5ae6f423c449c7348fd825da2a1a4180ebc5d455b3f169.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c3d15d4cbc564c6c7539a9f56f870ad55c2d26b5
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/e563307ad6e33c63a503beee1c1e6727767063590dc51b70b49f3b67d5749f13.md b/vision-fixhub/court-01/e563307ad6e33c63a503beee1c1e6727767063590dc51b70b49f3b67d5749f13.md
new file mode 100644
index 0000000000000000000000000000000000000000..fa3359d36bcdc871475e9e3d9062b80be4b6978c
--- /dev/null
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@@ -0,0 +1,50 @@
+Case 1:19-cv-10577-LJL-DCF Document 32 Filed 02/18/20 Page 1 of 2
+Case 1:19-CV-10577-LJL-DCF Document 29-3 Filed 02/14/20 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+X
+Plaintiff,
+USDC SĐNY
+DOCUMENT
+ELECTRONICALLY FILED
+DOC#:.
+DATE FILED: 2/18/2020
+Index No. 1:19-cv-10577-LGS-DCF
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN in their capacities as the executors of
+the ESTATE OF JEFFREY EDWARD
+EPSTEIN,
+Defendants.
+ORDER FOR ADMISSION PRO HAC VICE
+The motion of Mary "Molly" S. DiRago for admission to practice Pro Hac Vice in the
+above captioned action is granted.
+Applicant has declared that she is a member in good standing of the bar(s) of the state(s)
+of Illinois; and that her contact information is as follows:
+Mary "Molly" S. DiRago
+Troutman Sanders LLP
+One North Wacker Drive. Suite 2905
+Chicago, 60606
+(312) 759-1926
+(312) 759-1939 (Fax)
+molly.dirago@troutman.com
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+Darren K. Indyke and Richard D. Kahn as Co-Executors of the Estate of Jeffrey E. Epstein
+(together, the "Co-Executors"), in the above entitled action;
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the
+above captioned case in the United States District Court for the Southern District of New York.
+1
+
+
+Case 1:19-CV-10577-LJL-DCF Document 32 Filed 02/18/20 Page 2 of 2
+Case 1:19-cv-10577-LJL-DCF Document 29-3 Filed 02/14/20 Page 2 of 2
+All attorneys appearing before this Court are subject to the Local Rules of this Court, including
+::=
+the Rules governing discipline of attorneys.
+Dated: 2/18/2020
+United States District/Magistrate Judge
+DEBRA FREEMAN
+UNITED STATES MAGISTRATE JUDGE
+SOUTHERN DISTRICT OF NEW YORK
+2
diff --git a/vision-fixhub/court-01/e563307ad6e33c63a503beee1c1e6727767063590dc51b70b49f3b67d5749f13.receipt.json b/vision-fixhub/court-01/e563307ad6e33c63a503beee1c1e6727767063590dc51b70b49f3b67d5749f13.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f0c2663fa0e129936de185c4ce5c0daa5169e180c81060d63ee9d57439e70fd0",
+  "output_sha256": "fd252b8875ba4232e04365889b9e27d3698fe35c208f7a8b258f95ec8ad0d5c9",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e57c19e17417588de1cd4f54f7bc992d9575e8c6d23f93dfd64a0acc1b8b79e8.md b/vision-fixhub/court-01/e57c19e17417588de1cd4f54f7bc992d9575e8c6d23f93dfd64a0acc1b8b79e8.md
new file mode 100644
index 0000000000000000000000000000000000000000..94bd843c53a4b679d425c3fc12b5c3491de997ff
--- /dev/null
+++ b/vision-fixhub/court-01/e57c19e17417588de1cd4f54f7bc992d9575e8c6d23f93dfd64a0acc1b8b79e8.md
@@ -0,0 +1,131 @@
+Case 1:20-cv-00484-JGK-DCF Document 104 Filed 04/21/21 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+X
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of
+the ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+20-cv-00484-JGK
+------
+GHISLAINE MAXWELL'S NOTICE OF TAXATION OF COSTS AND
+SUPPORTING MEMORANDUM OF LAW
+Laura A. Menninger
+Jeffrey S. Pagliuca
+HADDON,
+150 East 10" Avenue
+Denver, CO 80203
+303.831.7364
+AND
+L. P.C.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 104 Filed 04/21/21 Page 2 of 4
+On March 19, 2021, this Court dismissed plaintiff's case with prejudice, based on her
+motion for voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(2). As the prevailing party in
+this matter, Ms. Maxwell hereby requests, pursuant to Fed. R. Civ. P. 54(d)(1), an order
+awarding her taxable costs against plaintiff Jane Doe.
+Rule 54(d)(1) provides that "[u]nless a federal statute, these rules, or a court order
+provides otherwise, costs—-other than attorney's fees—should be allowed to the prevailing
+party." Fed. R. Civ. P. 54(d)(1). "Courts consistently have found defendants to be prevailing
+parties where the action against them was voluntarily dismissed with prejudice." Cir. for
+Discovery, Inc. v. D.P., No. 16-CV-3936-MKB-RER, 2018 WL 1583971, at *14 (E.D.N.Y. Mar.
+31, 2018); see Beer v. John Hancock Life Ins. Co., 211 F.R.D. 67, 70 (N.D.N.Y. 2002) ("All
+circuit courts to have directly addressed this issue have concluded that a defendant [who has
+obtained a voluntary dismissal with prejudice] is a prevailing party, or alternatively, that a
+district court has discretion to award costs to the defendant."); see also Carter v. Inc. Vill. of
+Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (disclaiming prior Second Circuit dicta which
+stated that "generally the defendant is not considered the prevailing party when, as here, there is
+a voluntary dismissal of the action by the plaintiff with prejudice." (citations omitted)). "A
+voluntary dismissal of an action with prejudice [is considered to materially alter the relationship
+of the parties], because it constitutes 'an adjudication on the merits for purposes of res
+judicata."" Carter, 759 F.3d at 165 (citation omitted); accord Feb. 12, 2021, Opinion and Order,
+DE 118; accord Jane Doe v. Darren K. Indyke et. al, Case No. 20-cv-484 (JGK), DE 98 at 5
+(addressing identical Rule 41(a)(2) motion and holding "Ms. Maxwell is correct that under
+Second Circuit law, she is the prevailing party for the purposes of Rule 54(d)").
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 104 Filed 04/21/21 Page 3 of 4
+An award of costs under Rule 54 is the "normal rule," and "the losing party has the
+burden to show that costs should not be imposed." Torcivia v. Suffolk Cty., 437 F. Supp. 3d 239,
+249 (E.D.N.Y. 2020) (quoting Harris v.
+1. No. 08-CV-1703 MKB, 2013 WL 632247, at *1
+(E.D.N.Y. Feb. 20, 2013). Once "the prevailing party demonstrates the amount of its costs and
+that they fall within an allowable category of taxable costs, see Local Rule 54.1(a), that party
+enjoys a presumption that its costs will be awarded." Equal Employment Opportunity Comm'n v.
+United Health Programs of Am., Inc., 350 F. Supp. 3d 199, 236 (E.D.N.Y. 2018) (quoting
+Patterson v. McCarron, No. 99-cv-11078 (RCC), 2005 WL 735954, at *1 (S.D.N.Y. Mar. 30,
+2005).
+Annexed hereto is Ms. Maxwell's Bill of Costs, including the Affidavit of Laura
+Menninger and exhibits, in the form required by Local Civil Rule 54.1 and including only those
+taxable costs prescribed by the rule.' As the prevailing party, Ms. Maxwell is presumptively
+entitled to an award of cost, and plaintiff is unable to meet her burden to demonstrate why costs
+should not be imposed. Accordingly, Ms. Maxwell requests that the Court order plaintiff to pay
+her costs in the amount detailed in the attached.
+WHEREFORE, Ms. Ghislaine Maxwell requests an award of costs pursuant to Fed. R.
+Civ. P. 54(d)(I) as the prevailing party in this action.
+'Ms. Maxwell seeks herein only her costs and expressly reserves her right to seek
+attorneys' fees incurred in defense of this action in future litigation either against plaintiff (e.g.,
+as claims for malicious prosecution or abuse of process), against the Estate of Epstein (under an
+indemnification theory), or both. See Opinion and Order of Feb. 10, 2021 at 5 (DE 118); accord
+Opinion and Order of Mar. 9, 2021, Jane Doe v. Darren K. Indyke et. al, 20-cv-484 (JGK), at 5
+(Dkt. 98) (striking language from proposed Rule 41(a)(2) dismissal relating to each party paying
+their own fees and costs to preserve right to seek attorneys' fees from this litigation in potential
+future litigation for claims including the torts of abuse of process and malicious prosecution).
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 104 Filed 04/21/21 Page 4 of 4
+Dated: April 21, 2021
+Respectfully submitted,
+s/ Laura A. Menninger
+Laura A. Menninger (LM-1374)
+Jeffrey S. Pagliuca (pro hac vice)
+HADDON,
+AND
+150 East 10° Avenue
+Denver, CO 80203
+Phone:
+303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+ipagliuca@hmflaw.com
+Attorneys for Ghislaine Maxwell
+P.C.
+Certificate of Service
+I hereby certify that on April 21, 2021, I electronically filed the foregoing Defendant
+hislaine Maxwell's Notice of Taxation of Costs and Supporting Memorandum of Law with the
+"lerk of Court using the CM/ECF system which will send notification of such filing to the
+following:
+Kevin Boyle
+Robert Glassman
+Panish, Shea & Boyle
+11111 Santa Monica Blvd., Ste 700
+Los Angeles, CA 90025
+boyle@psblaw.com
+glassman@psblaw.com
+Bennet J. Moskowitz
+Charles L. Glover
+Mary
+W. Metcalfe
+Troutman Pepper |
+Sanders LLP
+875 Third Avenue
+New York, NY 10022
+bennet.moskowitz@troutman.com
+charles.glover@troutman.com
+marygrace.metcalfe@troutman.com
+Molly S. DiRago
+routman Peppe
+Sanders LLP
+27 W. Monroe Street, Suite 390
+Chicago, IL 60606
+nolly.dirago@troutman.com
+s/ Nicole
+3
diff --git a/vision-fixhub/court-01/e57c19e17417588de1cd4f54f7bc992d9575e8c6d23f93dfd64a0acc1b8b79e8.receipt.json b/vision-fixhub/court-01/e57c19e17417588de1cd4f54f7bc992d9575e8c6d23f93dfd64a0acc1b8b79e8.receipt.json
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+}
diff --git a/vision-fixhub/court-01/e59bee7ba15def701bd3001484b1a23d63bc2809ab89ccbc564c70f59a543491.md b/vision-fixhub/court-01/e59bee7ba15def701bd3001484b1a23d63bc2809ab89ccbc564c70f59a543491.md
new file mode 100644
index 0000000000000000000000000000000000000000..b6e825b78128a9025ca3588db818e2b16e80ccaa
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+++ b/vision-fixhub/court-01/e59bee7ba15def701bd3001484b1a23d63bc2809ab89ccbc564c70f59a543491.md
@@ -0,0 +1,42 @@
+Case 1:19-cv-10577-LJL-DCF Document 37 Filed 03/09/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Jane Doe 1000
+-against-
+Indyke, et al.
+Plaintiff,
+Case No. 19-cv-10577-LJL
+Defendant.
+NOTICE OF CHANGE OF ADDRESS
+TO:
+ATTORNEY SERVICES CLERK AND ALL OTHER PARTIES
+I have cases pending
+I have no cases pending
+Pursuant to Local Rule 1.3 of this Court, please take notice of the following attorney information change (s) for:
+My SDNY Bar Number is: SM0926
+Sabina Mariella
+FILL IN ATTORNEY NAME
+My State Bar Number is 5530670
+1 am,
+An attorney
+•
+A Government Agency attorney
+A Pro Hac Vice attorney
+FIRM INFORMATION (Include full name of firm (OLD AND NEW), address, telephone number and fax number):
+OLD FIRM:
+FIRM NAME:
+1 & Cromwell, LLP
+FIRM ADDRESS: 125 Broad Street, New York, NY 10004
+FIRM TELEPHONE NUMBER: (212) 558-4000
+FIRM FAX NUMBER: (212) 558-3588.
+NEW FIRM:
+FIRM NAME:_Boies Schiller Flexner LLP
+FIRM ADDRESS: _55 Hudson Yards, New York, NY 10001.
+FIRM TELEPHONE NUMBER:_(212) 446-2300
+FIRM FAX NUMBER: (212) 446-2350
+V
+I will continue to be counsel of record on the above-entitled case at my new firm/agency.
+I am no longer counsel of record on the above-entitled case. An order withdrawing my appearance
+was entered on.
+by Judge
+Dated: March 9, 2020
diff --git a/vision-fixhub/court-01/e59bee7ba15def701bd3001484b1a23d63bc2809ab89ccbc564c70f59a543491.receipt.json b/vision-fixhub/court-01/e59bee7ba15def701bd3001484b1a23d63bc2809ab89ccbc564c70f59a543491.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ad3ac530731def1cfad01b588339da581f49cc00
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e5a0c126172f2f35ff9e6991e946d9263e2dbfbcbcc6b00e84d1d13ee5dab42f.md b/vision-fixhub/court-01/e5a0c126172f2f35ff9e6991e946d9263e2dbfbcbcc6b00e84d1d13ee5dab42f.md
new file mode 100644
index 0000000000000000000000000000000000000000..cfcdef4c602e43ed3b75d4beb3c71891e2e26c63
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@@ -0,0 +1,176 @@
+Case 9:08-CV-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S MOTION FOR ORDER COMPELLING CLERK TO
+ENTER DEFAULT AGAINST DEFENDANT, OR ALTERNATIVELY,
+FOR AN ENLARGEMENT OF TIME TO SERVE PROCESS,
+AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 2, by and through her undersigned counsel, and pursuant to Federal
+Rules of Civil Procedure 55(a) and 4(m), and S.D. Fla. L.R. 7.1, hereby files this Motion for Order
+Compelling Clerk to Enter Default Against Defendant, or Alternatively, for an Enlargement of Time
+to Serve Process, and Incorporated Memorandum of Law, as follows:
+This action was filed on February 6, 2008. On May 7, 2008, Defendant Jeffrey
+Epstein was served with the Summons and Complaint. A copy of the Affidavit of Service was filed
+with the Court. (D.E. 4).
+2. Pursuant to Fed.R.Civ.P. 12(a)(1), Defendant Jeffrey Epstein was required to answer
+or otherwise serve a response to the Complaint on or before May 27, 2008. Defendant failed to do
+So.
+3.
+On May 29, 2008, Plaintiff moved for entry of a Clerk's Default against Defendant
+pursuant to Fed.R.Civ.P. 55(a).
+4. On June 6, 2008, the Clerk denied Plaintiff's Motion for Entry of Default, for
+HERMAN & MERMELSTEIN, P. A.
+- 1-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 2 of 7
+improper service. (D.E. 8).'
+The Affidavit of Service filed in this case, states that the process server made five
+separate attempts at service at the Defendant's New York residence over a two week period, at
+various times of day and night; on the fifth attempt, on May 7, 2008 at 7:45 a.m., the process server
+served an "Assistant and House Staff Employee" in Defendant's residence who refused to identify
+himself.
+6.
+According to press reports, Defendant Jeffrey Epstein is a billionaire with multiple
+residences; his principal residence is a 45,000 square foot townhouse in Manhattan, where the
+above-described service was made. Mr. Epstein began receiving extensive press coverage
+approximately two years ago when allegations first surfaced that he sexually molested young girls.
+There are presently pending criminal charges against Mr. Epstein in Palm Beach County relating to
+such allegations, in which Mr. Epstein is represented by Jack A. Goldberger, Esq. (See Herman Aff.,
+Exhibit "A" hereto 19l 3-5). The Defendant's receipt of notice of this lawsuit is based on
+correspondence and communications between Plaintiff's counsel and Defendant's attorney, Mr.
+Goldberger, regarding both the criminal case and this civil case, and the extensive press coverage of
+the instant lawsuit when it was filed in February, 2008, as well as the May 7, 2008 service of process
+at his New York residence. (See Herman Aff., Exhibit "A" hereto, '9l 3, 4).
+7.
+Under Fed.R.Civ.P. 4(e)(2)(B), service of process can be made on the defendant by
+"leaving a copy ... at the individual's dwelling or usual place of abode with someone of suitable age
+'At the same time service of process was attempted in this case, it was also attempted in related
+cases in this Court against Defendant Epstein, Jane Doe 3 v. Epstein, case no. CASE NO.: 08-
+CV-80232-MARRA/
+Jane Doe No. 4 v. Epstein, case no., 08-CV-80380-
+MARRA/
+1, and Jane Doe No. 5 v. Epstein, case no. 08-80381-CIV-MARRA. Unlike the
+instant case, Clerk's defaults were entered in Jane Doe 4 and Jane Doe 5, based on affidavits of
+service identical to that filed in this case. Plaintiff filed a Motion for Entry of Default in Jane Doe
+HeRmaN & MerMElsteIN, P. A.
+- 2-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 3 of 7
+and discretion who resides there."2
+8.
+A filed Affidavit of Service constitutes prima facie evidence of valid service. Home-
+Stake Production Co. v. Talon Petroleum, C.A., 907 F.2d 1012 (10th Cir. 1990). In Home-Stake, the
+declaration of the process server stated only that the person served identified herself as the
+working for the defendant for the past twenty years. Id. at 1016. The Court held that the
+defendant's affidavit challenging the validity of that service was insufficient to overcome the
+presumption of valid service created by the process server's affidavit and return of service. Id. at
+1017. In other words, it was the defendant's burden to show that the
+did not reside in his
+home, and he failed to meet that burden.? Id. See also National Development Co. v. Triad Holding
+Corp., 930 F.2d 253, 256-58 (2d Cir. 1991) (upholding service on the defendant's housekeeper,
+where the defendant, like Defendant Jeffrey Epstein, was a wealthy individual with more than one
+residence, on the basis that, "if not the most likely method of ensuring that he received the summons
+and complaint, [the service] was reasonably calculated to provide actual notice of the action").
+9.
+"Courts have liberally construed [Rule 4] and found valid service of process when a
+defendant has actual notice of a lawsuit filed against him."
+Keevan & Son, Inc. v. Callier
+Steel Pipe & Tube, Inc., 107 F.R.D. 665, 671 (S.D. Fla. 1985) (denying motion to set aside default).
+"If the court finds that the defendant received notice of the complaint and the plaintiff made a good
+No. 3, but to date there has been no action taken on that Motion.
+* Service can also be made on the Defendant in this case under Florida law or under the law of New
+York, where the service was made. Fed.R.Civ.P. 4(2)(A). Florida law is substantially the same as
+federal law, as it allows service on a person 15 years or older who resides at the defendant's usual
+place of abode. Florida Statute $48.031(1)(a).
+3 Under Florida law, like federal law, "[a] presumption of valid service arises from evidence of a
+return of service which is regular on its face. The party challenging the service must overcome that
+presumption by clear and convincing evidence." Magazine v. Bedoya, 475 So.2d 1035 (Fla. 3d
+DCA 1985).
+Herman & MerMelsteIN, P. A.
+- 3-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 4 of 7
+faith effort to serve the defendant pursuant to the Rule, then the court will most likely find that
+service of process has been effective." Id. Here, it may fairly and reasonably be inferred that
+Defendant Epstein had actual notice of the filing of the Complaint, and the Plaintiff has exercised
+diligence and good faith in attempting to serve Defendant Epstein with process. Accordingly, entry
+of default is appropriate.
+10.
+If the Court does not agree that service on Defendant Jeffrey Epstein was valid, then
+Plaintiff requests an enlargement of time to effect service. Pursuant to Fed.R.Civ.P. 4(m), the Court
+shall extend the 120-day period' for service for an appropriate period where good cause on behalf of
+Plaintiff is shown. Here, Plaintiff was diligent in seeking service of process through numerous
+attempts, until Plaintiff reasonably believed that service had been effectuated on May 7, 2008.
+(Golub Aff., Exhibit "B" hereto (attempts at service made in February and March, 2008); Affidavit
+of Service, D.E. 4 (attempts at service made in April and May, 2008, after Defendant Epstein
+returned from Israel); see also Herman Aff. 'I9l 5-6). Within days of the expiration of time for
+Defendant to answer or respond to the Complaint based on the May 7, 2008 service date, Plaintiff
+filed a Motion for Clerk's Default. Not until June 6, 2008, when Plaintiff's counsel received the
+Clerk's denial of the Motion for Entry of Default, did a need to take further action become apparent,
+and Plaintiff then promptly filed the instant Motion. Accordingly, Plaintiff has been diligent in
+attempting to serve process on Defendant Epstein. Additionally, for a significant portion of the 120-
+day period, Defendant Epstein was out of the country, in the State of Israel, and not amenable to
+service. (Herman Aff., I 5).
+WHEREFORE, Plaintiff, JANE DOE NO. 2, respectfully requests that this Court enter an
+"This action was filed on February 6, 2008. The 120-day period to serve the Defendant with process
+ran on June 5, 2008, one day before the Clerk denied Plaintiff's Motion for Entry of Default.
+Herman & Mermelstein, P. A.
+-4-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 5 of 7
+Order compelling the Clerk to enter a default against Defendant Jeffery Epstein pursuant to
+Fed.R.Civ.P. 55(a), or in the alternative, for an enlargement of time to serve process on Defendant
+Epstein.
+Dated: June 11, 2008.
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman@hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+HERMAN & MERMELSTEIN, P. A.
+- 5-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 6 of 7
+CERTIFICATE OF SERVICE
+I hereby certify that on June 11, 2008, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+/s/ Adam D. Horowitz
+Herman & MermelsteIn, P. A.
+- 6-
+
+
+Case 9:08-cv-80119-KAM Document 9 Entered on FLSD Docket 06/11/2008 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+CASE NO.: 08-CV-80119-MARRA/,
+United States District Court, Southern District of Florida
+Jeffrey Epstein (Via Regular Mail)
+9 East 71st Street
+New York, NY 10021
+Is/ Adam D. Horowitz
+Herman & Mermelstein, P. A.
+- 7-
\ No newline at end of file
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new file mode 100644
index 0000000000000000000000000000000000000000..a5ac8e5637fc78d58095d3a5950e08c9c755917f
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@@ -0,0 +1,515 @@
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 1 of 15
+SUNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+X
+Plaintiff,
+:
+19 Civ. 8673 (KPF) (DCF)
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as the executors of
+the Estate of Jeffrey E. Epstein,
+Defendants.
+:
+------
+X
+DEFENDANTS' MEMORANDUM OF LAW IN SUPPORT OF THEIR
+MOTION TO DISMISS PLAINTIFF'S CLAIM FOR PUNITIVE DAMAGES
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Tel: 212-704-6000
+Fax: 212-704-6288
+Attorneys for Defendants Darren K. Indyke and Richard D. Kahn,
+Co-Executors of the Estate of Jeffrey E. Epstein
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20
+
+TABLE OF CONTENTS
+Page
+TABLE OF AUTHORITIES
+PRELIMINARY STATEMENT
+FACTS
+I.
+PLAINTIFF SEEKS PUNITIVE DAMAGES AGAINST AN ESTATE FOR
+ALLEGED PERSONAL INJURIES CAUSED BY A DECEDENT
+ARGUMENT.
+I.
+PLAINTIFF DOES NOT DISPUTE THAT A NEW YORK STATUTE BARS
+HER CLAIM FOR PUNITIVE DAMAGES
+II.
+NEW YORK LAW APPLIES TO THE ISSUE OF PUNITIVE DAMAGES
+BECAUSE PLAINTIFF ALLEGES THE TORTS OCCURRED IN NEW YORK.
+III.
+EVEN IF USVI LAW APPLIES - WHICH IT DOES NOT - PUNITIVE
+DAMAGES ARE STILL UNAVAILABLE
+Banks factor one: previously, USVI courts favorably cited the
+Restatement section that precludes punitive damages against
+estates.
+Banks factor two: a majority of U.S. jurisdictions do not permit an
+award of punitive damages based on the wrongful acts of a
+decedent.
+3.
+Banks factor three: Post-Banks, USVI courts have favorably
+applied Restatement Section 908 to questions regarding punitive
+damages.
+IV.
+THIS MOTION IS PROCEDURALLY PROPER
+a.
+Courts in this District routinely dismiss punitive damages claims on Rule
+12(b)(6) motions....
+b.
+Even if the Court deems this Motion a motion to strike, it should grant the
+relief requested
+CONCLUSION
+1
+2
+2
+2
+2
+3
+4
+5
+5
+6
+7
+..8
+.. 10
+-i-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 |
+
+TABLE OF AUTHORITIES
+Page(s)
+Cases
+American Buying Ins. Servs., Inc. v. S. Kornreich & Sons, Inc.,
+944 F. Supp. 240 (S.D.N.Y.
+. 1996) ...
+Bank Brussels Lambert v. Credit Lyonnais (Suisse) S.A.,
+No. 93 CIV 6876 LMM, 200 WL 1876916, at *1 (S.D.N.Y. Dec. 22, 2000)
+Banks v. Int'l Rental & Leasing Corp.,
+55 V.I. 967 (V.I. 2011).
+Blasetti v. Pietropolo,
+213 F. Supp. 2d 425 (S.D.N.Y. 2002).....
+Blissett v. Eisensmidt,
+940 F. Supp. 449 (N.D.N.Y. 1996).
+Booth v. Bowen,
+No. CIV. 2006-217, 2008 WL 220067 (D.V.I. Jan. 10, 2008)
+Brady v. Port Auth.,
+Nos. 87 CV 2702 (NG), 93 CV 1679 (NG), 95 CV 0442 (NG), 1998 U.S.
+Dist. LEXIS 16548 (E.D.N.Y. Oct. 15, 1998)
+Brandy v. Flamboyant Inv. Co., Ltd.,
+24 V.I. 249 (V.I. Terr. Ct. 1989)...
+Carmona v. Spanish Broad. System, Inc.,
+No. 08 Civ. 4475, 2009 WL 890054 (S.D.N.Y. Mar. 30, 2009)
+Cerveceria Modelo, S.A. de C.V. v. USPA Accessories LLC,
+No. 07 Civ. 7998 (HB), 2008 U.S. Dist. LEXIS 28999 (S.D.N.Y. Apr. 10,
+2008)
+Crabtree v. Estate of Crabtree,
+837 N.E.2d 135 (Ind. 2005).
+v. Christian,
+46 V.I. 557 (D.V.I. App. Div. 2005).
+Deutsch v. Novartis Pharms. Corp.,
+723 F. Supp. 2d 521 (E.D.N.Y. 2010)....
+.9
+.9
+4,5, 6
+..7
+1,2,4
+.5
+.8
+.6
+.9
+.8
+.5
+..6
+.3
+-ii-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 4 of 15
+Gemerek v. Buffalo Sewer Auth.,
+No. 99-CV-0879E(M), 2001 U.S. Dist. LEXIS 7167 (W.D.N.Y. May 21,
+2001)
+Gov't of Virgin Islands v.
+No. S. CT. CIV. 2013-0095, 2014 WL 702639 (V.I. Feb. 24, 2014)...
+Graham v.
+224 F.R.D. 59 (N.D.N.Y. 2004).
+Guidi v. Inter-Continental Hotels Corp.,
+No. 95-CV-9006, 2003 U.S. Dist. LEXIS 6390 (S.D.N.Y. Apr. 16, 2003).
+v. Dowson Holding Co.,
+51 V.I. 619 (D.V.I. 2009).
+Isaac v. Crichlow,
+63 V.I. 38, 2015 V.I. LEXIS 15 (V.I. Super. Ct. 2015).
+Kunica v. St. Jean Fin.,
+No. 97 Civ. 3804, 1998 U.S. Dist. LEXIS 11867 (S.D.N.Y. July 29, 1998)
+In re Merrill
+Auction Rate Sec. Litig.,
+851 F. Supp. 2d 512 (S.D.N.Y. 2012)....
+Ladenburg Thalmann & Co. v. Imaging Diagnostic Sys.,
+176 F. Supp. 2d 199 (S.D.N.Y. 2001).....
+Nash v. Coram Healthcare Corp.,
+No. 96 Civ. 0298, 1996 U.S. Dist. LEXIS 9101 (S.D.N.Y. June 27, 1996).
+Pappas v. Hotel on the Cay Time-Sharing Ass'n,
+69 V.I. 3 (Super. Ct. 2015).
+v. Consumers Distrib. Co.,
+648 F. Supp. 980 (S.D.N.Y. 1986) .
+SJB v. N.Y.C. Dep't of Educ.,
+No. 03 Civ. 6653, 2004 U.S. Dist. LEXIS 13227 (S.D.N.Y. July 14, 2004)
+St.
+House, Inc. v. Barrows,
+15 V.I. 435 (V.I. Terr. Ct. 1979).
+Starr Indem. & Liab. Co. v. Am. Claims Mgmt.,
+No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272 (S.D.N.Y. May 7, 2015)..
+The Cookware Co. (USA), LLC V. Austin,
+No. 15 Civ. 5796, 2016 U.S. Dist. LEXIS 177691 (S.D.N.Y. Dec. 8, 2016).
+..T
+•1,2
+.3
+.5
+.6
+...7
+.8
+.8
+.8
+.6
+....7
+..7
+.6
+.3
+..7
+- iii -
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 5 of 15
+v. Rijos,
+780 F. Supp. 2d 376 (D.V.I. 2011)
+Wine Mkts. Int'l v. Bass,
+177 F.R.D. 128 (E.D.N.Y. 1998).
+Statutes
+EPTL § 11-3.2 (a)(1).
+New York General Construction Law § 37-a
+Other Authorities
+C.I
+& A.
+, 5C Fed. Prac. & Proc. Civ. § 1380 (3d ed.)
+Fed. R. Civ. P. 12(b)(6).
+Fed. R. Civ. P. 12(f)..
+2 Linda L. Schlueter, Punitive Damages § 20.4 (7th ed. 2015)..
+Timothy R. Robicheaux and Brian H. Bornstein, Punished, Dead Or Alive: Empirical
+Perspectives on Awarding Punitive Damages Against Deceased Defendants,
+16 Psych. Pub. Pol. and L. 393, 398 2010)..
+6
+.9
+1, 2, 3, 4
+.3
+.8
+1,2,7,8
+8, 10
+..5
+5-6
+- iv -
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 6 of 15
+Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein (the "Co-Executors"), respectfully submit this memorandum of law in support of their
+motion to dismiss plaintiff Jane Doe's ("Plaintiff") claim for punitive damages pursuant to
+Federal Rule of Civil Procedure 12(b)(6).
+PRELIMINARY STATEMENT
+Plaintiff's Complaint (ECF No. 1) asserts four personal injury causes of action against the
+Co-Executors and seeks, among other things, punitive damages. However, the claim for punitive
+damages fails as a matter of law.
+New York law and public policy preclude Plaintiff's punitive damages claim. The New
+York Estates, Powers and Trusts Law unequivocally provides: "For any injury, an action may be
+brought or continued against the personal representative of the decedent, but punitive damages
+shall not be awarded nor penalties adjudged in any such action brought to recover damages
+for personal injury." NY EPTL § 11-3.2 (a)(1) (emphasis added). That is the law in most U.S.
+jurisdictions, as reflected in the Restatement (Second) of Torts. See Restat. (Second) Of Torts §
+908 cmt. a ("Punitive damages are not awarded against the representatives of a deceased
+tortfeasor."). "Also, "there is a strong policy against the assessment of punitive damages against
+an estate on account of wrongful conduct of the decedent."" Graham v.
+, 224 F.R.D.
+59, 63 (N.D.N.Y. 2004) (quoting Blissett v. Eisensmidt, 940 F. Supp. 449, 457 (N.D.N.Y. 1996)).
+Because there are no facts that would render Plaintiff's punitive damages claim proper, there is
+no reason to allow it to stand.
+Plaintiff has never disputed that New York law bars her punitive damages claim. Rather,
+she attacks this motion on erroneous procedural and choice-of-law grounds. However, as
+explained below: (1) courts in this District have routinely dismissed punitive damages claims on
+motions under Rule 12; (2) courts in this District do not hesitate to strike requests for punitive
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 7 of 15
+damages; (3) New York law applies because Plaintiff alleges the torts against her took place in
+this District; and (4) in any event, punitive damages are unavailable under the law of the United
+States Virgin Islands ("USVI"), where the estate is being administered.
+I.
+FACTS
+PLAINTIFF SEEKS PUNITIVE DAMAGES AGAINST AN ESTATE FOR
+ALLEGED PERSONAL INJURIES CAUSED BY A DECEDENT
+Plaintiff sued the Co-Executors alleging that Jefferey Epstein, now deceased, sexually
+assaulted Plaintiff in his New York City residence. (Compl. at 99l 3, 45.) Plaintiff asserts four
+personal injury causes of action based on Mr. Epstein's alleged conduct: sexual assault; sexual
+battery; intentional infliction of emotional distress; and, negligent infliction of emotional
+distress. (Id. TI 69-86.) Plaintiff seeks "actual, compensatory, statutory, consequential and
+punitive damages." (Id. 9| 88.)
+I.
+ARGUMENT
+PLAINTIFF DOES NOT DISPUTE THAT A NEW YORK STATUTE BARS HER
+CLAIM FOR PUNITIVE DAMAGES
+In her pre-motion letter, Plaintiff did not dispute that New York law precludes her from
+recovering punitive damages from the Estate. Nor could Plaintiff make such an argument.
+The New York Estates, Powers and Trusts Law provides:
+No cause of action for injury to person or property is lost because of the
+leath of the person liable for the injury. For any injury, an action may b
+rought or continued against the personal representative of the deceden
+but punitive damages shall not be awarded nor penalties adjudged in any
+such action brought to recover damages for personal injury.
+NY EPTL § 11-3.2 (a)(I) (emphasis added). "Also, 'there is a strong policy against the
+assessment of punitive damages against an estate on account of wrongful conduct of the
+decedent."" Graham, 224 F.R.D. at 63 (quoting Blissett, 940 F. Supp. at 457).
+Plaintiff's Complaint is based entirely on her alleged personal injuries. New York
+- 2-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 8 of 15
+General Construction Law § 37-a defines "personal injury" as including "an assault, battery,
+false imprisonment, or other actionable injury to the person either of the plaintiff, or of another."
+All of Plaintiff's causes of action seek damages for personal injury based on Plaintiff's core
+allegation that she "was sexually assaulted by Epstein countless times." (Compl. I 42.)
+Therefore, per NY EPTL § 11-3.2(a)(1), Plaintiff may not recover punitive damages from Mr.
+Epstein's Estate as a matter of law.
+II. NEW YORK LAW APPLIES TO THE ISSUE OF PUNITIVE DAMAGES
+BECAUSE PLAINTIFF ALLEGES THE TORTS OCCURRED IN NEW YORK
+Tacitly conceding that New York law bars her punitive damages claim, Plaintiff asserts in
+her pre-motion letter that USVI law applies to the availability of such damages merely because
+Mr. Epstein's will is being probated there. Plaintiff is wrong for two independent reasons.
+First, Plaintiff alleges the acts and omissions giving rise to her causes of action occurred
+entirely in New York. (Compl. 9 15, 22.) Therefore, New York law-including NY EPTL §
+11-3.2(a)(1)—applies to the issue of punitive damages. See Starr Indem. & Liab. Co. v. Am.
+Claims Mgmt., No. 14-cv-0463-JMF, 2015 U.S. Dist. LEXIS 60272, *7 (S.D.N. Y. May 7, 2015)
+("Because punitive damages are conduct-regulating, 'the law of the jurisdiction where the tort
+occurred will generally apply."") (quoting Deutsch v. Novartis Pharms. Corp., 723 F. Supp. 2d
+521, 524 (E.D.N.Y. 2010); Guidi v. Inter-Continental Hotels Corp., No. 95-CV-9006, 2003 U.S.
+Dist. LEXIS 6390, at *1 (S.D.N.Y. Apr. 16, 2003)).
+Second, Plaintiff is not permitted to avail herself of parts of NY EPTL § 11-3.2(a)(1)
+while disregarding others. Plaintiff is only permitted to bring her causes of action against the
+Estate because of the first sentence of NY EPTL § 11-3.2(a)(1):
+No cause of action for injury to person or property is lost because of the death of
+the person liable for the injury. For any injury, an action may be brought or
+continued against the personal representative of the decedent, but punitive damages
+shall not be awarded nor penalties adjudged in any such action brought to recover
+- 3-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 9 of 15
+damages for personal injury. This section extends to a cause of action for
+wrongfully causing death and an action therefor may be brought or continued
+against the personal representative of the person liable therefor.
+NY EPTL § 11-3.2(a)(1) (emphasis added).
+By arguing New York law does not apply to the issue of punitive damages, however,
+Plaintiff effectively asks the Court to apply the first sentence of § 11-3.2(a)(1), permitting her to
+bring this case, but to disregard the very next sentence precluding punitive damages. In Blissett,
+the Court expressly rejected such an "anomalous situation." 940 F. Supp. at 457 ("[I]t would be
+an anomalous situation indeed if plaintiff were allowed to proceed with this section 1983 action
+against the estate of
+because of section 11-3.2(a)(1), while at the same time he was
+allowed to recover relief in the form of punitive damages, which clearly is beyond the scope of
+relief which that statute authorizes.").
+III. EVEN IF USVI LAW APPLIES - WHICH IT DOES NOT - PUNITIVE
+DAMAGES ARE STILL UNAVAILABLE
+Even if USVI law applies, an award of punitive damages would not be available against
+Mr. Epstein's Estate. In 2011, the Supreme Court of the USVI effectively instructed USVI
+courts to apply what is now known as a "Banks analysis" to determine U.S.V.I. common law.
+Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967, 979 (V.I. 2011). The Banks analysis
+includes consideration of three non-dispositive factors: (1) whether any USVI courts have
+previously adopted a particular rule; (2) the position taken by a majority of courts of other
+jurisdictions; and (3) most importantly, which approach represents the soundest rule for the
+USVI. Gov't of Virgin Islands v.
+. No. S. CT. CIV. 2013-0095, 2014 WL 702639, at *1
+(V.I. Feb. 24, 2014).
+Applying the Banks factors here demonstrates that USVI courts would adopt the rule in
+the Restatement (Second) of Torts—which is also followed in the majority of United States
+- 4-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 10 of 15
+jurisdictions, including New York-and hold that punitive damages are not available against a
+deceased tortfeasor's estate.
+1.
+Banks factor one: previously, USVI courts favorably cited the
+Restatement section that precludes punitive damages against estates.
+USVI courts have favorably recited the Restatement's rule precluding punitive damages
+against a decedent tortfeasor's estate. See, e.g., l
+v. Dowson Holding Co., 51 V.I. 619,
+628 (D.V.I. 2009); Booth v. Bowen, No. CIV. 2006-217, 2008 WL 220067, at *5 (D.V.I. Jan. 10,
+2008). In these cases, the U.S. District Court of the Virgin Islands considered the inverse of the
+issue here, i.e., whether the personal representatives of an estate may obtain punitive damages in
+an action arising from the decedent's wrongful death. In determining that punitive damages
+were not available under such circumstances, the courts cited the Restatement, which provides
+that "Iplunitive damages are not awarded against the representatives of a deceased tortfeasor
+nor, ordinarily, in an action under a death statute." Restat. (Second) of Torts § 908 cmt. a
+(emphasis added). Accordingly, this Banks factor favors the Estate.
+2.
+Banks factor two: a majority of U.S. jurisdictions do not permit an
+award of punitive damages based on the wrongful acts of a decedent.
+This Banks factor overwhelmingly supports the Estate's position. The majority of U.S.
+jurisdictions do not permit an award of punitive damages against the personal representatives of
+an estate based on the actions of the deceased tortfeasor. See Crabtree v. Estate of Crabtree, 837
+N.E.2d 135, 138 (Ind. 2005) ("The majority view denies punitive damages."); 2 Linda L.
+Schlueter, Punitive Damages § 20.4 (7th ed. 2015) ("[A] majority of jurisdictions will not award
+punitive damages against a deceased tortfeasor's estate." (citing Alec A. Beech, Adding Insult to
+Death: Why Punitive Damages Should Not Be Imposed Against a Deceased Tortfeasor's Estate
+in Ohio, 49 Akron L. Rev. 553 (2016))); Timothy R. Robicheaux and Brian H. Bornstein,
+Punished, Dead Or Alive: Empirical Perspectives on Awarding Punitive Damages Against
+- 5-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 11 of 15
+Deceased Defendants, 16 Psych. Pub. Pol. and L. 393, 398 (2010) ("The Restatement (Second)
+of Torts (1965) is one authority stating that punitive damages should not follow the death of a
+wrongdoer, and the majority of courts considering the issue have provided rulings consistent
+with this position.").
+3.
+Banks factor three: Post-Banks, USVI courts have favorably applied
+Restatement Section 908 to questions regarding punitive damages.
+The third Banks factor weighs strongly in favor of the Estate as well. Post-Banks, USVI
+Courts have already found that Section 908 of the Restatement is "the soundest rule for the
+Virgin Islands with respect to the imposition of an award of punitive damages." Pappas v. Hotel
+on the Cay Time-Sharing Ass'n, 69 V.I. 3, 15 n.8 (U.S.V.I. Super. Ct. 2015) (citing
+Christian, 46 V.I. 557 (D.V.I. App. Div. 2005), Isaac v. Crichlow, 63 V.I. 38, 2015 V.I. LEXIS
+15 (V.I. Super. Ct. 2015), St.
+House, Inc. v. Barrows, 15 V.I. 435 (V.I. Terr. Ct. 1979),
+Brandy v. Flamboyant Inv. Co., Ltd., 24 V.I. 249 (V.I. Terr. Ct. 1989), and
+v. Rijos, 780
+F. Supp. 2d 376, 380 (D.V.I. 2011)); Powell v. Chi-Co's Distrib., No. ST-13-TOR-14, 2014 V.I.
+LEXIS 21, at *5 n.13 (U.S. V.I. Super. Ct. Apr. 3, 2014) ("Applying a Banks analysis, the Court
+finds that Restatement (Second) of Torts § 908(2) reflects the common law of this jurisdiction.").
+In conclusion, every Banks factor favors the Estate: (1) pre-Banks, USVI courts
+expressed approval for the general rule that punitive damages cannot be recovered against a
+wrongdoer's estate; (2) the majority of courts from other jurisdictions preclude punitive damages
+against a wrongdoer's estate; and (3) post-Banks, USVI courts have held that Section 908 of the
+Restatement of Torts (Second) represents the soundest rule for the USVI with respect to the
+availability of punitive damages.
+- 6-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 12 of 15
+IV. THIS MOTION IS PROCEDURALLY PROPER
+a.
+Courts in this District routinely dismiss punitive damages claims on Rule
+12(b)(6) motions.
+Plaintiff's pre-motion letter also argues that a motion to dismiss punitive damages is more
+properly styled a motion to strike. However, courts in this District regularly grant motions to
+dismiss punitive damages. See, e.g., The Cookware Co. (USA), LLC v. Austin, No. 15 Civ. 5796,
+2016 U.S. Dist. LEXIS 177691, at *17 (S.D.N.Y. Dec. 8, 2016) (Batts, J.) (granting motion to
+dismiss claim for punitive damages without leave to replead because allegations regarding
+defendant's bad faith conduct were conclusory and did not rise to the required level of malice);
+SJB v. N.Y.C. Dep't of Educ., No. 03 Civ. 6653, 2004 U.S. Dist. LEXIS 13227, at *25-26 (S.D.N.Y.
+July 14, 2004) (Buchwald, J.) (granting motion to dismiss punitive damages claims because
+punitive damages were not statutorily available); Kunica v. St. Jean Fin., 97 Civ. 3804, 1998 U.S.
+Dist. LEXIS 11867, at *26 (S.D.N. Y. July 29, 1998) (Sweet, J.) (granting motion to dismiss claim
+for punitive damages because even if conduct alleged in complaint was true, it did not rise to the
+level necessary to award punitive damages); (
+v. Consumers Distrib. Co., 648 F. Supp. 980,
+981, 984 (S.D.N.Y. 1986) (Cedarbaum, J.) (granting motion to dismiss claim for punitive
+damages); see also Gemerek v. Buffalo Sewer Auth., No. 99-CV-0879E(M), 2001 U.S. Dist.
+LEXIS 7167, *14 (W.D.N.Y. May 21, 2001) (granting motion to dismiss punitive damages).
+Judge Kaplan, whom Plaintiff references in her pre-motion letter, has granted a motion to dismiss
+punitive damages. See Blasetti v. Pietropolo, 213 F. Supp. 2d 425, 431-32 (S.D.N.Y. 2002) ("The
+motion
+... to dismiss the complaint is granted to the extent that plaintiff's claim for punitive
+damages ... is dismissed.").
+Fed. R. Civ. P. 12(f) provides for motions to strike "an insufficient defense or any
+redundant, immaterial, impertinent, or scandalous matter." The Estate does not contend that
+- 7-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 13 of 15
+Plaintiff's request for punitive damages is redundant, immaterial, impertinent or scandalous.
+Rather, Plaintiff's claim for punitive damages fails as a matter of law.
+b.
+Even if the Court deems this Motion a motion to strike, it should grant the
+relief requested.
+Even if the Court deems this Motion a motion to strike pursuant to Fed. R. Civ. P. 12(f),
+it should still grant the relief requested. See C. L
+& A.
+, 5C Fed. Prac. & Proc. Civ. §
+1380 (3d ed.) ("[T]he technical name given to a motion challenging a pleading is of little
+importance inasmuch as prejudice to the nonmoving party hardly can result from treating a
+motion that has been inaccurately denominated a motion to strike as a motion to dismiss the
+complaint.").
+Contrary to Plaintiff's assertions in her pre-motion letter, motions to strike punitive
+damages are not disfavored. Courts in the Second Circuit, including in this District, routinely
+grant motions to strike punitive damages at the pleadings stage. See, e.g., In re Merrill
+Auction Rate Sec. Litig., 851 F. Supp. 2d 512, 544 (S.D.N.Y. 2012) (granting defendant's motion
+to strike sections of first amended complaint asserting punitive damages); Nash v. Coram
+Healthcare Corp., No. 96 Civ. 0298 (LMM), 1996 U.S. Dist. LEXIS 9101, at *15 (S.D.N.Y.
+June 27, 1996) ("The motion to strike the punitive damages prayer from the Complaint is
+granted."); Cerveceria Modelo, S.A. de C.V. v. USPA Accessories LLC, No. 07 Civ. 7998 (HB),
+2008 U.S. Dist. LEXIS 28999, at *21-22 (S.D.N.Y. Apr. 10, 2008) ("Because Defendant has
+failed to allege that Plaintiff's conduct was egregious and directed at the public generally, its
+claim for punitive damages cannot proceed."); Ladenburg Thalmann & Co. v. Imaging
+Diagnostic Sys., 176 F. Supp. 2d 199, 207 (S.D.N.Y. 2001) (granting motion to strike punitive
+damages because plaintiff did not allege egregious conduct in complaint); see also Brady v. Port
+Auth., Nos. 87 CV 2702 (NG)(CLP), 93 CV 1679 (NG)(CLP), 95 CV 0442 (NG)(CLP), 1998
+- 8-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 14 of 15
+U.S. Dist. LEXIS 16548, at *9 (E.D.N.Y. Oct. 15, 1998) (granting Port Authority's motion to
+strike plaintiff's claims for punitive damages).
+None of the cases cited in Plaintiff's pre-motion letter held that motions to strike punitive
+damages were disfavored or "time-wasters"; in fact, none of them involved motions to strike
+punitive damages at all. Plaintiff's first case, Wine Mkts. Int'l v. Bass, 177 F.R.D. 128, 133
+(E.D.N.Y. 1998), involved a motion to strike all references to price-fixing in the complaint as
+immaterial because the price-fixing claims had been dismissed. The Wine Markets court
+observed that motions to strike "portions of a complaint" are disfavored because they are often
+sought by the movant as a dilatory tactic. Id. Notwithstanding its observation, the court granted
+the motion to strike in part. Id. at 135.
+Plaintiff's second case, Bank Brussels Lambert v. Credit Lyonnais (Suisse) S.A., No. 93
+CIV 6876 LMM, 200 WL 1876916, at *1 (S.D.N.Y. Dec. 22, 2000), involved a motion to strike
+affirmative defenses. The court summarily held that Rule 12(f) motions were disfavored, citing
+American Buying Insurance Services, Inc. v. S. Kornreich & Sons, Inc.—a case involving a
+motion to strike portions of a complaint that were deemed irrelevant. 944 F. Supp. 240, 250
+(S.D.N.Y. 1996).
+Finally, Plaintiff's third case, Carmona v. Spanish Broad. System, Inc., No. 08 Civ. 4475,
+2009 WL 890054, at *10 (S.D.N.Y. Mar. 30, 2009), involved a motion to strike an "immaterial"
+paragraph in the complaint. The court acknowledged that motions to strike are often disfavored
+but also addressed the motion on the merits, denying it because the paragraph in question had
+"possible bearing" on the allegations in the complaint and at any rate did not prejudice
+defendants.
+Here, the Estate does not seek merely to strike an insufficient defense or immaterial
+- 9-
+
+
+Case 1:19-cv-08673-KPF-DCF Document 47 Filed 01/15/20 Page 15 of 15
+portion of Plaintiff's complaint. Rather, the Estate asks this Court to strike an improper claim for
+punitive damages that is unavailable by statute and otherwise, and which thus can and should be
+disposed of on the pleadings.
+Nor is the Estate's motion a dilatory tactic. On the contrary, removing Plaintiff's
+punitive damages demand will serve to streamline the issues here. The only "time-waster"
+would be if Plaintiff were permitted to seek to conduct discovery to support a prohibited claim
+for punitive damages. Further, if Plaintiff decides not to take part in the Epstein Victims'
+Compensation Program, striking the improper punitive damages request will substantially help
+the parties appropriately value their respective positions and thus aid in settlement.
+CONCLUSION
+Based on the foregoing, the Co-Executors respectfully request that the Court grant their
+motion to dismiss Plaintiff's claim for punitive damages with prejudice or, alternatively, strike
+that claim, together with such other and further relief as the Court deems just and proper.
+Dated: New York, New York
+January 15, 2020
+Respectfully submitted,
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+By: _Is/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Attorney for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+40835487v2
+- 10-
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+Filing # 135754952 E-Filed 10/01/2021 02:16:32 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+Case No.: 50-2019-CA-014681-XXXX-MB
+Division: AG
+v.
+DAVE ARONBERG, as State Attorney of
+Beach County, Florida,
+Defendants.
+COPY
+DEFENDANT, CLERK AND COMPTROLLER
+OF PALM BEACH COUNTY'S, RESPONSE
+TO PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT
+Defendant,
+Abruzzo, as Clerk and Comptroller of Palm Beach County, Florida (the
+"Clerk"), by counsel, responds to Plaintiff, CA Florida Holdings, LLC, publisher of The Palm
+Beach Post's ("The Post"), Motion for Summary Judgment (DE # 58) (the "Motion"), and states
+as follows:
+I.
+INTRODUCTION AND BACKGROUND
+The Post sued the Clerk and Palm Beach County State Attorney! to gain access to
+"confidential" records of "secret" grand jury proceedings that are "exempt from the provisions of
+s. 119.07(1) and s. 24(a), Art. I of the State Constitution" so it can disclose them to the public. See
+§$ 905.17, 905.24, Fla. Stat.; Motion (DE # 58) at p.34. Unfortunately, the Clerk (who inherited
+"As noted in the Motion (DE # 58 at p. 2, n. I), The Post dropped the State Attorney, Dave
+Aronberg, as a party after he filed a Motion for Attorneys' Fees under Section 57.105 (DE # 35)
+and Motion for Summary Judgment (DE # 38), both of which argued that the State Attorney does
+not possess any of the records The Post seeks.
+FILED: PALM BEACH COUNTY, FL, I
+|ABRUZZO, CLERK, 10/01/2021 02:16:32 PM
+
+
+this case from his predecessor?) is the sole remaining "Defendant" in this case because his office
+is charged with the ministerial duty of keeping "stenographic records, notes, and transcriptions
+made by the court reporter or stenographer" of Palm Beach County grand jury proceedings "in a
+sealed container not subject to public inspection." See § 905.17(1), Fla. Stat.
+Several statutes enforceable through criminal penalties require grand jury secrecy and
+forbid clerks of Florida's circuit courts from releasing grand jury materials except "on request by
+a grand jury for use by the grand jury or on order of the court pursuant to s, 905.27." See
+§§ 905.17(1), 905.27(1)-(2), (4)-(5), Fla. Stat. Chapter 905 does not grant the Clerk any
+authority or discretion to release any grand jury materials to the press or public—regardless
+of the subject matter of the proceedings at issue or public sentiment about whether they
+should be released.
+Considering the Clerk's constitutional and statutory duties, lack of discretion, and role as
+a depository for grand jury materials, his defense to this lawsuit is necessarily limited to the issue
+of whether, under Florida law, clerks of the circuit courts can be sued by private parties seeking
+access to such records. The specific subject matter of the underlying grand jury proceedings is
+irrelevant to this preliminary question concerning the legality of The Post's suit against the Clerk.
+Consequently, the Clerk takes no position on most of the facts put forth in The Post's Motion.?
+If the Court decides that private litigants can sue clerks for declaratory relief to gain access
+to grand jury materials under Section 905.27(1)(c) and/or the Court's "inherent authority," only
+then would the inquiry advance to whether The Post can demonstrate to the Court that releasing
+2 Clerk Abruzzo was sworn into office as Palm Beach County's Clerk and Comptroller on
+January S, 2021.
+3 This should not, however, be construed as the Clerk's agreement with or adoption of any of the
+factual positions taken by The Post.
+2
+
+
+testimony, minutes, and other evidence related to the Jeffrey Epstein grand jury is appropriate to
+serve "the purpose of..furthering justice" and/or preserve the dignity of the judicial system.
+However, the Clerk's office is merely the statutorily designated depository for these materials and
+performs this function solely in a ministerial capacity as an arm of the Court, required comply with
+any directives from the Court concerning the materials The Post seeks. The Clerk is not aware of
+any authority or standing granted to his office to advocate for or against the release of any grand
+jury materials, including the specific materials at issue here. Accordingly, this response is limited
+to an overview of the law related to the "furthering justice" exception and the Court's inherent
+authority to help inform the Court's decision.
+Il.
+PROCEDURAL HISTORY
+The Post's operative pleading is its January 17, 2020 Amended Complaint (DE #17), which
+asserts a claim for declaratory relief (Count I) and attempted to state a private cause of action under
+section 905.27, Florida Statutes (Count II). Both counts sought the same relief: a court order
+granting The Post access to the testimony, minutes, and other evidence presented in 2006 to the
+Palm Beach County grand jury concerning Jeffrey Epstein so it can "use those materials for the
+purpose of informing the public." (DE # 17 at pp. 20-21).
+On January 24, 2020, the State Attorney and Clerk filed their respective Answerst and
+incorporated Motions to Dismiss Count II of the Amended Complaint (DE ## 22, 24); both arguing
+that Section 905.27 does not create a private cause of action. The State Attorney also argued that
+* In its Answer (DE # 24), the Clerk asserted that it was without knowledge of all the Amended
+Complaint's factual allegations regarding Epstein and the 2006 grand jury proceedings, and
+therefore denied them and "demand[ed] strict proof thereof." The Post's Motion suggests
+(DE # 58 at p.3) that the material facts are "uncontested" based in part on the Clerk's Answer, but
+that clearly is not accurate.
+3
+
+
+he was an improper party to the case because his office does not possess grand jury materials,
+which are filed with the Clerk's office under Section 905.17(1) (DE # 22 at pp.11-12).
+On June 8, 2020, the Court entered its Order Granting Defendants' Motions to Dismiss
+Count Il of Plaintiff's First Amended Complaint With Prejudice (DE # 33). In pertinent part, the
+Court ruled:
+In sum, there is nothing in the text of section 905.27 from which one
+records. Indeed, to the contrary, section 905.27 prohibits the State
+Attorney and Clerk (assuming that, as pleaded by the Post, they have
+the documents) from disclosing the documents without first being
+ordered to do so by the court. Reading section 905.27 as creating a
+private cause of action against the State Attorney and Clerk is,
+therefore, not only unsupported by the language of section 905.27,
+but is actually paradoxical to its plain language of the statute. As
+such, this Court lacks the power to construe the unambiguous
+language of section 905.27 in a way that would extend its express
+terms and create a cause of action where none exists. "To do so
+would be an abrogation of legislative power." (citation omitted).
+Shortly thereafter, the State Attorney filed his Motion for Attorneys' Fees under Section
+57.105 (DE #35) and Motion for Summary Judgment (DE # 38). On October 21, 2020, The Post
+filed its Notice of Dropping the State Attorney as a party (DE # 48).
+On April 22, 2021, without having sought reconsideration or rehearing of the June 8, 2020
+Order, The Post filed its Motion seeking summary judgment against the Clerk (DE # 58). In its
+Motion, The Post relies upon nearly 20 pages of somewhat slanted and argumentative factual
+assertions about Epstein and the 2006 grand jury proceedings (DE # 58 at pp. 1-19) to support the
+re-argument of its position that Section 905.27 creates a private right of action (DE # 58 at pp. 20-
+25), and the argument that access should be granted to the Epstein grand jury materials attendant
+4
+
+
+to The Post's claim for declaratory relief premised on Section 905.27 and the Court's "inherent
+authority" (DE # 58 at pp. 26-30).
+Il. SUMMARY JUDGMENT STANDARD
+The Post's Motion pre-dates the effective date (May 1, 2021) of the Florida Supreme
+Court's amendment of Florida Rule of Civil Procedure 1.510 and adoption of the federal summary
+judgment standard. See In re Amendments to Fla. Rule of Civil Procedure 1.510, 317 So. 3d 72,
+77-78 (Fla. 2021) ("amendment applies to pending cases and all motions filed on or after May 1,
+2021"). Although The Post has not "file[d] a renewed' summary judgment motion under the new
+rule," the Supreme Court instructed that "the new rule must govern the adjudication of any
+summary judgment motion decided on or after that date, including in pending cases." Id. (citation
+omitted). Accordingly, even though The Post's Motion was filed pre-amendment, the Clerk
+assumes the new standards governing Rule 1.510 apply to its adjudication.
+IV.
+ARGUMENT
+Once filed with clerks of the circuit courts pursuant to Section 905.17(1), grand jury
+materials are "records of the judicial branch" governed by Rule 2.420 of the Florida Rules of
+Judicial Administration and subject to its procedures governing public access. Times Pub. Co. v.
+Ake, 645 So. 2d 1003, 1005 (Fla. 2d DCA 1994), approved, 660 So. 2d 255 (Fla. 1995). Under
+the facts of this case, Rule 2.420 is the mandatory procedural mechanism through which access to
+grand jury materials must be sought. However, The Post did not follow Rule 2.420 to request or
+challenge a denial of access to these materials.
+" Florida's Supreme Court noted that, "i]n cases where a pending summary judgment motion has
+been briefed but not decided, the court should allow the parties a reasonable opportunity to amend
+their filings to comply with the new rule." 317 So. 3d at 78
+5
+
+
+Even if that were not the case, The Post still could not obtain access to grand jury materials
+to disseminate them to the public by suing the Clerk because—for many of the same reasons
+explained in the Court's June 8, 2020 Order (DE # 33)-there is no private right of action under
+Section 905.27(1)(c) and no viable claim for declaratory relief based on Section 905.27 or the
+Court's "inherent authority." Accordingly, The Post's remaining claim is procedurally and legally
+deficient, its Motion should be denied, and this entire case should be dismissed with prejudice.
+A.
+Overview of the Powers and Duties of Clerks of the Circuit Courts
+The Second DCA explained in Times Pub. Co. v. Ake, 645 So, 2d at 1005, that the offices
+of the clerks of Florida's circuit courts serve two functions:
+The office of the clerk of the circuit court derives its powers and authority from two
+articles of the Florida Constitution. Article VIII, section 1(d), of the Florida
+Constitution provides that the clerk is a county officer who shall be "ex officio clerk
+of the board of county commissioners, auditor, recorder and custodian of all county
+funds." In the exercise of these nonjudicial duties, the clerk is an autonomous
+elected county officer not subject to the direction or control of the court. Article V,
+section 16, establishes the office of clerk of the circuit court within the judicial
+framework. That section further provides that the office may be divided into two
+offices by general or special law. Absent such division, the clerk must act in a dual
+capacity. See Alachua County. Powers, 351 So.2d 32 (Fla.1977). In the
+performance of his duties as the court's record keeper, the clerk is a ministerial
+officer of the court devoid of discretion. Corbin v. State ex rel. Slaughter, 324 So.2d
+203 (Fla. Ist DCA 1975). The court has the inherent and exclusive constitutional
+authority over its agencies who act in its behalf. See The Florida Bar, 398 So.2d
+446 (Fla. 1981). The clerk, when acting in the exercise of his duties derived from
+article V is acting as an arm of the court and, as such, is immune from the
+supervisory authority of the legislature. Thus, chapter 119 does not apply to the
+clerk in such capacity and the access to judicial records under his control is
+governed exclusively by rule 2.051.
+In approving the Second DCA's decision in Times Pub. Co. v. Ake, Florida's Supreme
+Court recognized that "the clerks of the circuit courts, when acting under the authority of their
+article V powers concerning judicial records and other matters relating to the administrative
+operation of the courts, are an arm of the judicial branch and are subject to the oversight and control
+
+
+of the Supreme Court of Florida, rather than the legislative branch." 660 So.2d at 257. This is
+because the judiciary is a co-equal branch of government, not an "agency." Id.
+Among other responsibilities, clerks of the circuit courts are charged with the duty of
+maintaining certain records of the judicial branch. In performing this duty, clerks are "ministerial
+officer[s] of the court devoid of discretion." Times Pub. Co. v. Ake, 645 So. 2d at 1005.
+"Records of the judicial branch'" are "all records, regardless of physical form,
+characteristics, or means of transmission, made or received in connection with the transaction of
+official business by any judicial branch entity," and they include "court records" and
+"administrative records." See Rule 2.420(b)(1), Fla. R. Jud. Admin (emphasis added). "Court
+records...are the contents of the court file, including the progress docket and other similar records
+generated to document activity in a case, transcripts filed with the clerk, documentary exhibits in
+the custody of the clerk, and electronic records, videotapes, or stenographic tapes of depositions
+or other proceedings filed with the clerk, and electronic records, videotapes, or stenographic tapes
+of court proceedings." See Rule 2.420(b)(1)(A), Fla. R. Jud. Admin. "Administrative
+records...are all other records made or received pursuant to court rule, law, or ordinance, or in
+connection with the transaction of official business by any judicial branch entity." See Rule
+2.420(b)(1)(B), Fla. R. Jud. Admin (emphasis added).
+"The custodian of all administrative records of any court is the chief justice or chief judge
+of that court..." See Rule 2.420(b)(3), Fla. R. Jud. Admin (emphasis added). "As to all other
+records, the custodian is the official charged with the responsibility for the care, safekeeping, and
+supervision of such records." Id.
+6 "Judicial branch" is defined as including "the clerk of court when acting as an arm of the court."
+See Rule 2.420(b)(2), Fla. R. Jud. Admin; see also Times Pub. Co. v. Ake, 660 So.2d at 257.
+7
+
+
+B.
+The Framework for Keeping Confidential Grand Jury Materials
+In establishing Florida's grand jury process, the Legislature directed that "[t]he chief judge
+of each circuit court shall regularly order the convening of the grand jury for a term of 6 months"
+and "[w]hen requested, the court shall advise the grand jury about its legal duties." See §§ 905.01,
+905.18, Fla. Stat. Once the legislature established a grand jury process, its implementation became
+a "judicial administrative responsibility since the grand jury's operation is within the judicial
+branch." See State ex rel. Reichle v.
+409 So.2d 1043, 1044 (Fla. 1982),? The Court
+noted in its June 8, 2020 Order (DE # 33 at p. 1) that this case "implicate[s] records of the Palm
+Beach County grand jury, over which the Chief Judge presides."
+The Post alleges in its Amended Complaint that "in states such as Florida, where the grand
+jury is preserved, it is an important appendage of the court which impanels it...[and]... the judge
+of that court is equally important and he is generally charged with the supervision of the grand
+jury's activities..." The Post also argued in its Opposition to the Clerk's Motion to Dismiss Count
+II (DE # 27 at p. 13), and continues to argue in its Motion (DE # 58 at p. 26), that the "Grand Jury
+is Under the Court's Supervision and Jurisdiction" and "a judicial proceeding in a court of
+justice...an appendage or adjunct to the circuit court."
+Florida law requires grand jury proceedings to be kept "secret," making it "unlawful" and
+"criminal contempt of court" to "disclose, divulge, or communicate to any other person...in any
+manner whatsoever, any testimony of a witness examined before the grand jury, or the content,
+gist, or import thereof..." See §§ 905.24, 905.17(4), 905.27(2)-(5), Fla. Stat. The Legislature
+' By way of comparison, a Federal grand jury is governed by Rule 6 of the Federal Rules of
+Criminal Procedure and considered to be "an institution independent from the judicial branch."
+See Pitch v. U.S., 953 F.3d 1226, 1237 (11" Cir. 2020).
+8 See Amended Complaint (DE # 17 at 1 60) (citing State v. Clemons, 150 So.2d 231, 233-34 (Fla.
+1963); see also Plaintiff's Opposition to Clerk's Motion to Dismiss Count II (DE # 27) at p. 14.
+8
+
+
+specifically addressed the confidentiality of grand jury materials in Section 905.17(1), which
+provides:
+The stenographic records, notes, and transcriptions made by the court reporter or
+stenographer [if any] shall be filed with the clerk who shall keep them in a sealed
+container not subject to public inspection. The notes, records, and transcriptions
+are confidential and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. I
+of the State Constitution and shall be released by the clerk only on request by a
+grand jury for use by the grand jury or on order of the court pursuant to s. 905.27.
+It bears mentioning that there is no requirement that Florida grand jury proceedings be
+recorded. See Thompson v. State, 565 So.2d 1311, 1313 (Fla. 1990) (Sections 905.17 and 905.27
+do not establish a duty to record grand jury proceedings, nor is there a constitutional basis to
+impose such a duty in all cases). In contrast, Federal Rule of Criminal Procedure 6(e) requires
+grand jury proceedings to be recorded and "[u]nless the court orders otherwise," for an attorney
+for the government to "retain control of the recording, the reporter's notes, and any transcript
+prepared from those notes." See Rule 6(e)(I), Fed. R. Crim. P.
+Once a clerk of the circuit court receives grand jury materials pursuant to Section
+905.17(1), they become administrative records of the judicial branch falling under the purview
+of Florida Rule of Judicial Administration 2.420, under which they continue to maintain their
+confidentiality protections under Section 905.17. Subdivisions (c)(7) and (c)(8) of Rule 2.420
+provide that "all records made confidential under...Florida ...law" and "all records presently
+deemed to be confidential...by Florida Statutes..." shall be confidential records of the judicial
+branch.
+Rule 2.420(d)(1)(B) further provides that "[e]xcept as provided by court order, the clerk of
+the court shall maintain as confidential information subject to subdivision (c)(7) or (c)(8) of this
+rule that is currently confidential or exempt from section 119.07, Florida Statutes, and article I,
+section 24(a) of the Florida Constitution as specifically stated in any of the following
+9
+
+
+statutes:...(xvi) Grand jury records. §§ 905.17, 905.28(1), Fla. Stat." See Rule 2.420(d)(1)(B),
+Fla. R. Jud. Admin. (emphasis added). Furthermore, because both "grand jury records" and "grand
+jury notes" are administrative records of the judicial branch, the Appendix to the Florida Rules
+of Judicial Administration ("Records Retention Schedule for Administrative Records") provides
+specific minimum record retention requirements for these materials:
+GRAND JURY NOTES
+This record series consists of stenographic records, notes, and transcriptions made
+by the court reporter or stenographer during the grand jury session. These records
+are normally kept in a scaled container and are not subject to public inspection
+pursuant to Section 905.17(1), Florida Statutes. A Court order must be obtained for
+disposition.
+RETENTION: 10 years from closing of session.
+GRAND JURY RECORDS
+This record series consists of jury summons, réquests for recusal, juror payments,
+information to jurors' employers, lists of jufors, juror questionnaires, and other
+records related to a grand jury. This record series includes records related to a
+grand jury and the statewide grand jury.
+RETENTION: 2 years.
+C.
+Procedural Mechanisms for Public Access to Judicial Branch Records
+Florida Rule of Judicial Administration 2.420(m) establishes the procedure to obtain access
+to judicial branch records: "Requests for access to judicial branch records shall be in writing and
+shall be directed to the custodian. The request shall provide sufficient specificity to enable the
+custodian to identify the requested records." See Rule 2.420(m)(1), Fla. R. Jud. Admin. (emphasis
+added). Once a proper request is made, the custodian responsible for providing access to the
+records of that custodian's entity "shall determine whether the requested record is subject to this
+rule and, if so, whether the record or portions of the record are exempt from disclosure." See
+
+
+Rule 2.420(m)(2), Fla. R. Jud. Admin. If a request is denied, the custodian must respond to the
+request by stating in writing the basis for the denial. Id
+Where access to "administrative records of the judicial branch" is denied, Rule 2.420(1)
+provides that the party denied access must file an action for mandamus or other appropriate relief
+in: (1) the court having appellate jurisdiction, when a judge who has denied a request for access to
+records is the custodian; or (2) in all other cases, the circuit court of the circuit in which the denial
+of access occurs. Here, the grand jury materials The Post seeks are judicial administrative
+records, of which the Chief Judge would be the "custodian" under Rule 2.420(b)(3). Thus, The
+Post should have made a written request for these materials directed to Chief Judge under
+Rule 2.420(m) and, if that request was denied, filed an action for mandamus in the Fourth District
+Court of Appeal pursuant to Rule 2.420(D)(1).
+Rule 2.420(j) establishes the procedure for obtaining access to confidential court records.
+Under Rule 2.420(j)(2), a party seeking access to confidential court records must file a written
+motion that identifies the court record(s) to which access is sought, specifies the basis for obtaining
+access, sets forth the legal authority for obtaining access, and certifies that it is made in good faith
+and supported by a sound factual and legal basis. Rule 2.420(j)(3)-(4) specifies the requirements
+for service of the motion (on all parties and reasonably ascertainable affected non-parties) and the
+findings which must be made in any order granting access to confidential court records.
+Rule 2.420() 's requirement of filing a "motion" to obtain access to "confidential court records"
+(as opposed to filing an "action" under Rule 2.420(I) when denied access to "administrative
+records") inherently contemplates that a court case is already pending in which confidential court
+records have been filed and in which the requesting party can file a "motion" for access to those
+records. Otherwise, Rule 2.420(j) would, like subsection 2.420(I), authorize the filing of an
+
+
+"action" to seek "confidential court records." Thus, even if the grand jury materials The Post seeks
+could be considered "confidential court records," The Post would have been required to file a
+motion under Rule 2.420(j) in the grand jury proceeding or criminal case against Epstein based on
+the indictment.? If such a motion had been filed and denied, The Post could have sought appellate
+review under Florida Rule of Appellate Procedure 9.100(d) ("Orders Excluding or Granting
+Access to Press or Public").
+D.
+The Post Failed to Comply with Rule 2.420
+The Post does not allege compliance Rule 2.420 in its |
+ded Complaint and offers no
+proof of compliance in its Motion. In fact, it appears to be undisputed that The Post did not make
+a written request to the Chief Judge under Rule 2.420(m), did not file an action in the appellate
+court under Rule 2.420(l), and did not file a motion for access to "confidential court records" under
+Rule 2.420(j). Instead, The Post vaguely alleges that it requested the records from the Clerk and
+State Attorney [Amended Complaint (DE # 17) at 9| 72] and filed this civil lawsuit in the circuit
+court against the Clerk and State Atforney.
+As explained above, the grand jury materials The Post seeks are "administrative records"
+[records received "pursuant to...law..." under Rule 2.420(b)(1)(B)] of which the Chief Judge is
+the "custodian" [under Rule 2.420(b)(3)]. However, The Post offers no proof that it made a written
+request directed to the Chief Judge for the Epstein grand jury materials, nor any proof that such a
+request was denied. See Rule 2.420(m)(1), Fla. R. Jud. Admin. Moreover, even if such a request
+and denial had occurred, the only proper mechanism to challenge a Chief Judge's denial of access
+is an action for mandamus in the appellate court (which clearly did not happen). See
+Rule 2.420(I)(1), Fla. R. Jud. Admin. Likewise, The Post offers no proof that it filed a motion to
+9 See Motion (DE # 58) at 11 19, 36; Appendix (DE # 59) at 8.
+12
+
+
+obtain access to confidential court records under Rule 2.420(i), and obviously did not seek
+appellate review of the denial of any such motion under Rule 2.420(1) and Appellate Rule 9.100(d).
+Florida's Supreme Court confirmed in Times Pub. Co. v. Ake, 660 So.2d at 257, that access
+to judicial records is governed exclusively by Rule 2.420. The Post's indisputable failure to request
+and pursue access to the grand jury records it seeks through the procedures established in
+Rule 2.420 conclusively establishes that this lawsuit is procedurally and legally defective.
+Consequently, the Motion should be denied, and this entire case should be dismissed with
+prejudice.
+E.
+There is No Private Right of Action Against a Clerk to Obtain Grand Jury Records
+Even assuming arguendo that the grand jury materials at issue are not "records of the
+judicial branch" exclusively subject to Rule 2.420, The Post still has no valid legal basis to sue the
+Clerk to obtain access to them. This Court already determined in its June 8, 2020 Order (DE # 33)
+that there is no private right of action against the Clerk under Section 905.27. The Post cannot use
+an action for declaratory relief to circumvent the Court's June 8, 2020 ruling or to invoke the
+Court's "inherent authority" to try to gain public access to grand jury materials.
+The Court's June 8, 2020 Order (DE # 33 at p. 5) correctly established hat "there is nothing
+in the text of section 905.27 from which one can deduce that the Legislature contemplated a
+member of the media, or anyone else for that matter, having a private cause of action to compel
+the State Attorney and Clerk to disclose grand jury records." The Post's Motion does not raise
+any new arguments or cite any new authorities to justify the Court's reconsideration and reversal
+of this well-reasoned decision.'° There is no private right of action under Section 905.27.
+1° The Post's Motion repeats the same arguments about its alleged standing and the availability of
+a "private right of action" under Section 905.27 [Motion (DE # 58) at 19 81-90] that it alleged in
+13
+
+
+The Post cannot use a claim for declaratory relief under Chapter 86 to create substantive
+rights which the plain language of Section 905.27 clearly demonstrates do not exist. On its face,
+the Section 905.27 does not expressly or impliedly grant the public or members of the media any
+right to obtain access to grand jury materials. To the contrary, Chapter 905 explicitly denies public
+access to "secret" grand jury proceedings and prohibits access to grand jury materials.
+Nevertheless, The Post's cause of action for declaratory relief is based on a request that
+the Court declare that pursuant to Fla. Stat. Section 905.27(1), it is entitled to access the testimony,
+minutes, and other evidence presented to the 2006 Palm Beach County grand jury because such
+disclosure and access would be in the furtherance of justice" (DE # 17 at | 70). The Post "further
+seeks a declaration that disclosure of the testimony, minutes, and other evidence presented in the
+2006 Palm Beach County grand jury is appropriate pursuant to this Court's inherent authority over
+grand jury proceedings because of the exceptional public interest in this case and the compelling
+circumstances supporting transparency" (DE # 17 at 9 71).
+However, the Declaratory Judgment Act is a procedural mechanism that confers subject
+matter jurisdiction—it does not offer any substantive rights. See Gilbert v. State Farm Mut. Auto.
+Ins. Co., 95 F.Supp. 3d 1358, 1364, n. 5 (M.D. Fla. 2015). Under Section 86.011, a court only has
+jurisdiction to render declaratory judgments on the existence or nonexistence of any immunity,
+power, privilege or right, and any fact upon which the existence or nonexistence of such immunity,
+power, privilege or right may depend.
+Courts play an important "gatekeeping" role in declaratory relief actions. See Ribaya v.
+Board of Trustees of City Pension Fund for Firefighters and Police Officers in the City of Tampa,
+the Amended Complaint [DE # 17 at 1T 56-59], and which it argued in its Opposition to the Clerk's
+Motion to Dismiss Count II [DE # 27 at pp. 9-13].
+14
+
+
+162 So.3d 348, 353 (Fla. 2d DCA 2015). In particular, courts must be leery of attempts to "pervert"
+the statute by those attempting to use it as a "catch-all." Id. "To ensure that this does not occur,
+the courts have developed requirements to invoke the act that go beyond the wording of the act
+itself: that there is a "bona fide dispute' between the parties and a "bona fide...need for [a]
+declaration.'" Id. (citations omitted). Where circumstances beyond the pleadings demonstrate
+that there is not a bona fide need for declaratory relief, trial courts should exercise their authority
+to decline to adjudicate the claim. Id.
+Here, this authority should be exercised because The Post has not alleged or proven that its
+claim for declaratory relief involves a determination of the existence or non-existence of its
+substantive rights. Rather, The Post is improperly asking the Court to create a new substantive
+public right of access to grand jury materials under the guise of declaratory relief. Gilbert,
+95 F.Supp.3d at 1364. As discussed above, there is no public right of access under Section 905.27.
+Similarly, the Court's "inherent authority" does not confer any rights, privileges, or powers to The
+Post that could be adjudicated under Chapter 86. There is no "bona fide" dispute over the existence
+of the Court's "inherent authority." Rose v. Palm Beach County, 361 So.2d 135, 136 n. 3 (Fla.
+1978) (Court's powers are "inherent in the sense they exist because the court exists...." (emphasis
+added)). Instead, The Post is using its claim for declaratory relief as pretense to try to tell the Court
+how its "inherent authority" should be used.
+With respect to Section 905.27, The Post appears to be trying to use a claim for declaratory
+relief the same way it is often used in cases involving violations of the Sunshine Law and Chapter
+119. See e.g., Ribaya, 162 So.3d at 355. As noted in Ribaya, because section 286.011 does not
+contain an "express right of action...it has become common for litigants to file actions for claims
+under the Sunshine Law that allege a claim for a violation of the statute and a claim for declaratory
+
+
+relief," which "in effect...alleges a claim under 286.011 and seeks a remedy under chapter 86."
+Id. at 355. However, it is important to note that Section 286.011—unlike Sections 905.17 and
+905.27—grants the public a right to access government meetings and has provisions recognizing
+the public's right to pursue legal actions to enforce that right:
+Section 286.011 creates broad public access to governmental
+meetings. This statute implements the constitutional right of access
+created in Article I, section 24, of the Florida Constitution.
+Subsection 286.011(4) clearly contemplates legal actions by
+members of the public to enforce the Sunshine Law.
+$ 286.011(4) (providing for attorney's fees where "an action has
+been filed...to enforce the provisions of this section" and the trial
+court determines that a violation has occurred).
+See Ribaya, 162 So.3d at 355 (emphasis added).
+Similarly, Chapter 119 implements the policy "of this state that all state, county, and
+municipal records are open for personal inspection and copying by any person," thus creating a
+public right to access records "made or received pursuant to law or ordinance or in connection
+with the transaction of official business by any agency." See § 119.01(1), Fla. Stat. (agency
+records are "open for personal inspection and copying by any person"); §119.07(1)(a), Fla. Stat.
+("Every person who has custody of a public record shall permit the record to be inspected and
+copied by any person desiring to do so, at any reasonable time, under reasonable conditions, and
+under supervision by the custodian of the public records"'); see also Times Pub. Co. v. Ake, 660
+So.2d at 257, n.l. Like Section 286.011, Chapter 119 contains several provisions "clearly
+contemplating" legal actions by members of the public to enforce their rights under Chapter 119.
+See §119.07(1)(g), Fla. Stat. ("In any civil action in which an exemption to this section is asserted,
+if the exemption is alleged to exist under or by virtue of s. 119.071(1)(d) or (f), (2)(d), (e), or (f),
+or (4)(c), the public record or part thereof in question shall be submitted to the court for an
+inspection in camera...") (emphasis added); § 119.11(1), Fla. Stat. ("Whenever an action is filed
+16
+
+
+to enforce the provisions of this chapter, the court shall set an immediate hearing, giving the case
+priority over other pending case") (emphasis added); § 119.12(1), Fla. Stat. ("If a civil action is
+filed against an agency to enforce the provisions of this chapter, the court shall assess and award
+the reasonable costs of enforcement, including reasonable attorney fees, against the responsible
+agency if the court determines that...") (emphasis added).
+Conversely, Chapter 905 establishes that there is no public right to access grand jury
+proceedings or materials. In fact, Section 905.24 implements the public policy that "[g]rand jury
+proceedings are secret," and Section 905.17(1) makes records of grand jury proceedings "exempt
+from the provisions of s. 119.07(1) and s. 24(a), Art. I of the State Constitution." Moreover,
+Chapter 905 does not contain an express right of action nor any provisions "clearly
+contemplating" (or even recognizing) the public's right to pursue legal actions to obtain
+access to grand jury records. To the contrary, as this Court recognized in its June 8, 2020 Order
+(DE # 33 at p. 5): "IT]here is nothing in the text of section 905.27 from which one can deduce that
+the Legislature contemplated a member of the media, or anyone else for that matter, having a
+private cause of action to compel the State Attorney and Clerk to disclose grand jury records.
+Indeed, to the contrary, section 905.27 prohibits the State Attorney and Clerk (assuming that, as
+pleaded by the Post, they have the documents) from disclosing the documents without first being
+ordered to do so by the court. Reading section 905.27 as creating a private cause of action against
+the State Attorney and Clerk is, therefore, not only unsupported by the language of section 905.27,
+but is actually paradoxical to its plain language of the statute."
+Similarly, any argument that a substantive right of public access to grand jury materials
+can be derived from a court's "inherent authority" collapses because that authority does not grant
+any rights or powers to anyone except the courts. Moreover, even if some private right of action
+17
+
+
+could somehow emanate from courts' inherent authority, it still could only be exercised "subject
+to, or not in conflict with, valid existing laws." See Jimenez v. Bondi, 259 So. 3d 722, 725 (Fla.
+2018); L
+, 361 So.2d at 137; Weinberg v. Siemens Fin. Services, Inc., 88 So. 3d 220, 222 (Fla.
+3d DCA 2011) (A "court's inherent power does not permit a court to ignore existing law, such as
+writ of replevin statutes.").
+Given the existing laws" surrounding the secrecy of grand jury
+proceedings, the Court's inherent powers could not be used as a basis to grant the relief The Post
+seeks.
+Ultimately, The Post's declaratory relief claim is analogous to the claim asserted in
+MacNeil v. Crestview Hospital Corp., 292 So.3d 840, 843-45 (Fla, 1" DCA 2020), in which the
+First DCA affirmed the trial court's dismissal of a claim for declaratory relief where the plaintiff
+"asserted no other cause of action below that would show that a justiciable controversy exists on
+which to predicate a declaratory judgment claim." After citing Ribaya for the elements of a
+declaratory relief claim and its warning that "chapter 86 is a statute with "special objectives' that
+should not be "perverted' by permitting its use as a 'catch-all,'" the court in MacNeil recognized
+that "[a]besnt a showing of at least a colorable right which would be affected by the requested
+declaration, dismissal is required." Id. at 842, 845 (citing Webster v. Inch, 286 So.3d 847, 848
+(Fla. 1" DCA 2019) 12
+" These laws include Sections 905.17(1) (prohibiting the clerk from releasing grand jury records
+except on request by grand jury or on order of the court under s. 905.27), 905.24 (grand jury
+proceedings are "secret," and grand jurors and interpreters are prohibited from disclosing the
+nature or substance of the deliberations or vote of the grand jury), and 905.27(1) (prohibiting the
+disclosure of the testimony of a witness examined before the grand jury or other evidence received
+by it except under the enumerated exceptions).
+12 MacNeil discusses all the required elements of a claim for declaratory relief, including the
+"extrastatutory elements requiring a "bona fide dispute' between the parties and a "bona fide need'
+for the declaration [which] ensure that the proceeding is 'judicial in nature' and falls 'within the
+constitutional powers of the courts."" Id. at 843 (citing Ribaya, 162 So.3d at 353).
+18
+
+
+In MacNeil, the plaintiff attempted to bootstrap a claim for declaratory relief to an alleged
+violation of Section 627.736(5)(a) (the PIP statute), which (like Section 905.27) "lacks an express
+or implied private cause of action to enforce its provisions." Id. at 842. The Post is trying to do
+the same thing using Section 905.27 and the Court's "inherent authority." Thus, The Post's
+declaratory relief claim seeks an improper advisory opinion and must suffer the same fate as
+MacNeil's (dismissal with prejudice). MacNeil, 292 So.3d at 841, 845; see also Collier v. State,
+Dept. of Highway Safety & Motor Vehicles, 943 So. 2d 945, 946 (Fla. 4th DCA 2006) (affirming
+dismissal of action seeking declaratory relief where no private right of action existed under the
+Driver's Privacy Protection Act, 18 U.S.C. § 2721, et seq.); Kunz v. Sch. Bd. of Palm Beach
+County, 237 So. 3d 1026, 1030 (Fla. 4th DCA 2018) (affirming dismissal of action seeking
+declaratory relief where no private right of action existed under the Class-Size Amendment to the
+Florida Constitution).
+The Post's only remaining claim in this action (Count I) seeking declaratory relief based
+on Section 905.27 and the Court's "inherent authority" fails to state a claim upon which relief can
+be granted. Accordingly, The Post's Motion should be denied, and Count I should be dismissed
+with prejudice.
+Overview of the Law if the "Furthering Justice" Inquiry is Needed
+If this Court determines that The Post has the legal right to seek declaratory relief against
+the Clerk to obtain access to the Epstein grand jury materials based on Section 905.27, the Clerk
+does not believe he has the authority to advocate for or against The Post's requested relief. The
+Clerk does, however, believe that he has an obligation to apprise the Court of the relevant law
+surrounding its decision.
+19
+
+
+The Post only seeks the Epstein grand jury records under the "furthering justice" exception
+to Section 905.27. See § 905.27(1)(c), Fla. Stat. Specifically, The Post seeks these grand jury
+materials to use them "for the purpose of informing the public" (DE # 17 at p.20) and concedes
+that it "is not seeking these materials in connection with either a civil or criminal case, it seeks a
+declaration that the scope of its use of the disclosed materials is not limited" (DE # 17 at 9 70
+(emphasis added)).
+Section 905.27(2) explicitly states that, "[w]hen [a] disclosure is ordered by a court
+pursuant to subsection (1) ... the grand jury testimony afforded such persons by the court can only
+be used in the defense or prosecution of the civil or criminal case and for no other purpose
+whatsoever." See § 905.27(2), Fla. Stat. This provision seems to be at odds with The Post's
+requests for the Epstein grand jury materials to use them "for the purpose of informing the public"
+(DE # 17 at p.20) and a "declaration that the scope of its use of the disclosed materials is not
+limited" (DE # 17 at 1 70).
+The Court is certainly aware of the important reasons for grand jury secrecy. Minton v.
+State, 113 So. 2d 361, 365 (Fla, 1959) ("to protect the jurors themselves; to promote a complete
+freedom of disclosure; to prevent the escape of a person indicted before he may be arrested; to
+prevent the subornation of perjury in an effort to disprove facts there testified to; and to protect the
+reputations of persons against whom no indictment may be found").'3 While the Court has
+discretion to relax the rule of secrecy when the "purposes of the secrecy rule are accomplished and
+a disclosure becomes essential to the attainment of justice and the vindication of the truth," the
+13 Based on the facts asserted in The Post's Motion, preventing the escape of a person indicted
+before he may be arrested, preventing the subornation of perjury in an effort to disprove facts there
+testified to, and protecting the reputations of persons against whom no indictment may be found
+do not appear to be an issue in this case.
+20
+
+
+Court must be mindful of "the effect on subsequent grand jury proceedings-on jurors, on witnesses,
+on the privacy of the system itself-of indiscriminate disclosure." Id.
+Those who serve on grand juries and the witnesses appearing before them have a justifiable
+expectation that their identities will be protected. Minton, 113 So. 2d at 365. Releasing grand jury
+materials to a member of the press could set a dangerous precedent that grand jury members and
+witnesses can no longer trust the government officials who assured them that their identities would
+be protected when they participated in the grand jury process. See Grand Jury Fall Term, A.D. v.
+City of St. Petersburg, Fla., 624 So. 2d 291, 293 (Fla. 2d DCA 1993) (finding State Attorney's
+argument that disclosure of grand jury records would result in "the destruction of the grand jury
+as an investigative body if the state could no longer inform witnesses that their testimony would
+be secret" persuasive). 4
+"To obtain access to grand jury testimony, a proper predicate must be laid." Jent v. State,
+408 So. 2d 1024, 1027 (Fla. 1981), holding modified by Preston v. State, 444 So. 2d 939 (Fla.
+1984). Then, once a proper predicate is laid, the trial judge must examine the grand jury records
+sought to be disclosed to determine thé materiality of the records." Minton, 113 So. 2d at 364.
+"[!]t is crystal clear that something more than a mere surmise or speculation" about what the grand
+jury records may contain is needed to lift the veil of secrecy from the grand jury proceedings. Id.
+at 365.
+10'
+14 If disclosure of the Epstein grand jury materials is ordered, the Clerk presumes, but in an
+abundance of caution also requests, that the Clerk only be ordered to provide the materials to the
+Court for an in camera review so that the Court can determine whether records revealing the
+identifies of any grand jurors or witnesses should not be disclosed or should be redacted to protect
+these individuals' identities.
+21
+
+
+In State v. Tillett, 111 So. 2d 716, 724 (Fla. 2d DCA 1959), the Second DCA discussed the
+uncertainty surrounding the "furthering justice" exception to grand jury secrecy:
+The concept of furtherance of justice is inherently difficult of precise definition.
+The application of such principle also is difficult and is necessarily dependent upon
+the peculiar factual circumstances of each particular case. A court of competent
+jurisdiction, before granting the use of grand jury testimony upon the furtherance
+of justice doctrine, should require the satisfactory establishment of the right to its
+use. The onus must be borne by the person seeking to gain access to and use of the
+testimony.
+While there is a paucity of case law controlling the Court's inquiry on the "furthering
+justice" issue, it does appear that appellate courts have been fairly consistent in denying private
+civil litigants access to grand jury records under the "furthering justice" exception; including in
+civil actions for libel and slander based on grand jury testimony (See e.g., Tillett, 111 So. 2d 716)
+and actions for malicious prosecution (See e.g., Widener v. Crofi, 184 So. 2d 444, 445 (Fla. 4th
+DCA 1966); Dworetzky v. Monticello Smoked Fish Co., 256 A.D. 772 (App. Div. 1939)). Courts
+have also denied access to grand jury records under the "furthering justice" exception where the
+party seeking the materials fails to establish a proper predicate to obtain them. See e.g., James v.
+Wille, 480 So. 2d 253 (Fla. 4th DCA) 1985) (even where "hypothetically, discovery might affect
+the achievement of justice" a proper predicate must still be laid); State v. Meeks, 610 So. 2d 647,
+648 (Fla. 3d DCA 1992) (quashing trial court's order requiring the disclosure of grand jury records
+because the motion seeking disclosure "did not contain any facts which supported his allegations
+that the State had withheld critical facts from the grand jury").
+Overview of the Law if the "Inherent Power" Inquiry is Needed
+As explained by the Florida Supreme Court in State ex rel.
+v. City of Avon Park,
+117 Fla. 565, 158 So. 159, 164 (Fla. 1934): "Every court has inherent powers to do all things that
+are reasonably necessary for the administration of justice within the scope of its jurisdiction,
+22
+
+
+subject to, or not in conflict with, valid existing laws and constitutional provisions." See also
+Jimenez, 259 So. 3d at 725; |
+361 So.2d at 137. "Inherent powers" of courts have been
+described as "all powers reasonably required to enable a court to perform efficiently its judicial
+functions, to protect its dignity, independence and integrity, and to make its lawful actions
+effective. These powers are inherent in the sense they exist because the court exists...
+1, 361
+So.2d at 136 n. 3 (quoting CARRIGAN, INHERENT POWERS OF THE COURTS 2(1973)).
+With respect to the requirement that courts exercise their inherent authority "subject to, or
+not in conflict with, valid existing laws," courts should be mindful of the limits the Legislature
+placed on the disclosure of grand jury records. See Weinberg, 88 So. 3d at 222 (A "court's inherent
+power does not permit a court to ignore existing law, such as writ of replevin statutes."). As noted
+above, the existing laws surrounding the disclosure of grand jury proceedings and records weigh
+against any disclosure, and even where disclosure is permitted can only be "used in the defense or
+prosecution of the civil or criminal case and for no other purpose whatsoever." See § 905.27(2),
+As a rule, where the Legislatüre enacts a general prohibition and enumerates limited
+exceptions to that prohibition, courts are not at liberty to expand the enumerated exceptions by
+judicial fiat. See e.g., l
+y. State, 215 So. 3d 113, 115-16 & n.1 (Fla. Ist DCA 2017) (invoking
+the principle of expressio unius est exclusio alterius as requiring courts to respect the separation
+of powers doctrine because "where a statute enumerates the things on which it is to operate, ... it
+is ordinarily to be construed as excluding from its operation all those not expressly mentioned"")
+(quoting Thayer v. State, 335 So. 2d 815, 817 (Fla. 1976)); see also Buzzard v. Buzzard, 412 So.
+2d 388, 390-91 (Fla. 2d DCA 1982) (recognizing the general rule that "a court is not authorized
+in the construction of a statute, to create exceptions not specifically made." (quoting Ogle v. Heim,
+69 Cal.2d 7, 69 Cal.Rptr. 579, 442 P.2d 659, 660 (1968)).
+23
+
+
+The Post relies upon several federal cases in support of its argument concerning the Court's
+inherent authority to publicly disclose grand jury records (Motion (DE # 58) at pp. 27-28). In
+reviewing these cases, it is important to note the differences between Florida and Federal grand
+juries. As discussed above, Rule 6 of the Federal Rules of Criminal Procedure governs matters
+related to a federal grand jury and provides the framework for recording and disclosing
+proceedings, including the exceptions to the generally applicable rule of secrecy. See Rule 6(e),
+Fed. R. Crim. P. While Rule 6 is materially different from Section 905.27, Florida Statutes, they
+are intended to accomplish the same goal—protecting the secrecy of grand jury proceedings.
+There is a split amongst the Federal circuit courts concerning whether Federal district
+courts have the "inherent authority" to order the disclosure of grand jury records. In Pitch v. United
+States, 953 F.3d 1226 (11th Cir. 2020), cert. denied, 141 S. Ct. 624 (2020), the Eleventh Circuit
+overturned its own precedent, holding that district courts have no inherent, supervisory power to
+authorize the disclosure of grand jury records outside of the enumerated exceptions provided by
+Rule 6(e). At issue in Pitch was whether a district court could order the release of grand jury
+materials related to "Moore's Ford Lynching—a horrific event involving the murders of two
+African American couples for which no one has ever been charged" based on circumstances not
+explicitly covered by Rule 6(e). Id. at 1229. Author Anthony Pitch petitioned for the release of
+the grand jury transcripts related to the crime so he could use them to inform the public about the
+unsolved crimes. Id. Mr. Pitch's request did not meet any exception provided by Rule 6(e), but
+the district court granted the petition, relying on a previous 11" Circuit decision holding that "a
+distriet court may, pursuant to its inherent, supervisory power over the grand jury, authorized the
+disclosure of grand jury records outside of Rule 6(e)'s enumerated exceptions in certain
+"exceptional circumstances."" Id. An Eleventh Circuit panel initially affirmed the lower court's
+24
+
+
+decision, before the case was reheard en banc. Id. Considering the import of the "long-established
+policy that grand jury proceedings in federal courts should be kept secret" and the purposes of such
+secrecy, the Eleventh Circuit ultimately decided to recede from precedent, holding that Rule 6(e)
+"by its plain terms limits disclosures of grand jury materials to the circumstances enumerated
+therein." Id. at 1233-34.
+Other circuits have arrived at the same conclusion, while some continue to allow disclosure
+under the Court's inherent authority. See, e.g. McKeever v. Barr, 920 F.3d 842, 844 (D.C. Cir.
+2019), cert. denied, 140 S. Ct. 597 (2020); In re Grand Jury 89-4-72, 932 F.2d 481, 488 (6th Cir.
+1991) ("[W]ithout an unambiguous statement to the contrary from Congress, we cannot, and must
+not, breach grand jury secrecy for any purpose other than those embodied by the Rule."); United
+States v. McDougal, 559 F.3d 837, 840-41 (8th Cir. 2009) ("'Because the grand jury is an
+institution separate from the courts, over whose functioning the courts do not preside,' ... courts
+will not order disclosure absent a recognized exception to Rule 6(e) or a valid challenge to the
+original sealing order or its implementation." (alteration omitted); In re 38 Studios Grand Jury,
+225 A.3d 224, 240 (R.I. 2020) (Rhode Island courts have no inherent authority to release grand
+jury records); compare Carlson y. United States, 837 F.3d 753, 767 (7th Cir. 2016); In re Petition
+of Craig, 131 F.3d 99, 107 (2d Cir. 1997). Notably, The Post cites Carlson in its Motion (DE #
+58
+at 9195)
+25
+
+
+V.
+CONCLUSION
+For the foregoing reasons, The Post's Motion for Summary Judgment should be denied,
+and this case should be dismissed with prejudice.
+/s/ Kenneth G. Turkel
+Kenneth G. Turkel - FBN 867233
+E-mail: kturkel@bajocuva.com
+Shane B. Vogt - FBN 257620
+E-mail: svogt@bajocuva.com
+James C. Mooney - FBN 111668
+E-mail : jmooney@bajocuva.com
+BAJO | CUVAIL
+[TURKEL
+00 North Tampa Street, Suite 190(
+ampa, Florida 3360
+Telephone: (813) 443-2199
+Facsimile: (813) 443-2193
+Attorneys for Defendant,
+Abruzzo, as Clerk
+NOT A CER
+CERTIF
+and Comptroller of Palm Beach County, Florida
+26
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on the Ist day of October, 2021, I caused a true and correct
+copy of the foregoing to be served via the Florida Court's E-Filing Portal upon the following
+E-mails: mendelsohns@gtlaw.com
+smithl@gtlaw.com
+FL.Service@gtlaw.com
+Michael J. Grygiel
+Greenberg Traurig, P.A.
+54 State St., 6th Floor
+Albany, NY 12207
+E-mail:
+grygielm@gtlaw.com
+Nina D. Boyajian
+Greenberg Traurig, P.A.
+1840 Century Park East, Ste. 1900
+Los Angeles, CA 90067
+E-mails: boyajiann@gtlaw.com
+riveraal@gtlaw.com
+Attorneys for Plaintiff
+CERTIFIED
+/s/ Kenneth G.
+Turkel
+Attorney
+COPY
+NOT
+27
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+Case 9:08-cv-80119-KAM Document 89
+Entered on FLSD Docket 05/05/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE REPLY
+TO PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY
+Defendant,
+Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+file his Reply to Plaintiff's Response in Opposition to Defendant's Motion to Stay
+Complaint.
+1. On April 23, 2009 Plaintiff filed a Response [DE 82] in Opposition to Defendant's
+Motion to Stay [DE 65]. Defendant's reply would be due on May 5, 2009 (5 days to
+reply excluding weekends + mailing). Defendant is requesting a fifteen (15) day
+extension to May 20, 2009 to reply.
+2. There are several other cases filed with this Court in which Jeffrey Epstein is
+named a Defendant. In those cases, the undersigned has been handling other matters
+associated therewith.
+3. Additionally, Defendant's counsel is in the midst of preparing for a state court
+trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
+V.
+, M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+
+
+Case 9:08-cv-80119-KAM Document 89 Entered on FLSD Docket 05/05/2009 Page 2 of 3
+Jane Doe No. 2 v. Epstein
+Page 2
+through 15, 2009). Discovery in that case is ongoing with several depositions set to
+prepare for trial.
+4. The requested extension is fair and reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately reply.
+5. An extension until May 20, 2009, is fair and reasonable under the circumstances.
+The undersigned is in need of the additional time in order to fully and adequately
+prepare a response on behalf of EPSTEIN.
+6. As certified below, counsel for Defendant conferred with counsel by e-mail, and
+Plaintiff's counsel is in agreement with the requested extension.
+WHEREFORE Defendant respectfully requests that this Court enter an order
+granting an extension until May 20, 2009, to file a Reply to Plaintiff's Response in
+Opposition to Defendant's Motion to Stay Complaint.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by e-mail with counsel for the Plaintiff and
+Counsel for Plaintiff is in agreement with the requested extension until May 20, 2009 for
+Defendant to reply to Plaintiff's Response to Defendant's Motion to Stay Complaint.
+Robert D. Critton, Jr. Attorney for
+Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+day of May, 2009:
+
+
+Case 9:08-cv-80119-KAM Document 89 Entered on FLSD Docket 05/05/2009 Page 3 of 3
+Jane Doe No. 2 v. Epstein
+Page 3
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By:
+ROBERT D.
+CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
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diff --git a/vision-fixhub/court-01/e5d71ece88c2bdda3b990947981e188bc6f792eb60178335766afd50ab0cb3ce.md b/vision-fixhub/court-01/e5d71ece88c2bdda3b990947981e188bc6f792eb60178335766afd50ab0cb3ce.md
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+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 1 of 6
+0366-001
+JAPA
+55
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80804-CIV-MARRA/
+JANE DOE, a/l/a,
+JANE DOE NO. 1,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+, and SARAH KELLEN,
+Defendants.
+-
+PROPOSED ORDER
+THIS CAUSE having come before this Court upon Plaintiff Jane Doe's UNOPPOSED
+MOTION FOR ENLARGEMENT OF TIME TO FILE CIVIL RICO CASE STATEMENT
+PURSUANT TO LOCAL RULE 12.1, and this Court being fully advised, it is hereby
+ORDERED AND ADJUDGED that:
+1. The Motion is hereby granted.
+2. Plaintiffs shall have an enlargement of time to file a Civil RICO Case Statement until
+fifteen (15) days after their motion for remand is decided.
+DONE AND ORDERED this
+day of_
+_ 2008.
+HON. KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to: All counsel
+
+A
+
+
+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 2 of 6
+CM/ECF - Live Database - flsd
+Page 1 of l
+Motions
+9:08-CV-80804-KAM Doe v. Epstein et al
+U.S. District Court
+Southern Distriet of Florida
+Notice of Electronic Filing
+The following transaction was entered by Kuvin, Spencer on 8/13/2008 at 4:09 PM EDT and filed
+on 8/13/2008
+Case Name:
+Doe v. Epstein et al
+Case Number:
+2:08-CV-80804
+Filer:
+Jane Doe
+Document Number: 2
+Docket Text:
+Unopposed MOTION for Extension of Time to File CIVIL RICO CASE STATEMENT
+by Jane Doe. (Kuvin, Spencer)
+9:08-cv-80804 Notice has been electronically mailed to:
+Spencer Todd Kuvin
+skuvin@riccilaw.com
+Theodore Jon Lcopold tleopold@riccilaw.com, Icuomo@riccilaw.com
+Guy Alan
+•
+Michael.
+Tein
+tein@lewistein.com, kmeyers@lewistein.com, mcapote@lewistein.com
+9:08-cv-80804 Notice has not been delivered electronically to those listed below and will be
+provided by other means. For further assistance, please contact our Help Desk at 1-888-318-
+The following documents) are associated with this transaction:
+Document description:Main Document
+Electronic document Stamp:
+[STAMP dcecfStamp_ID=1105629215 [Date=8/13/2008] [FileNumber=5434519-0
+j [0654241630fb72965a9748afe7fde57a86ccOfa2d09487151919cfc183 dba7d366
+5f92a5ffe52e756eabfb67e114844447096e53e7ea5e345e79a5đ2abd937a]]
+https://ecf.flsd.uscourts.gov/cgi-bin/Dispatch.pl?705759404361499
+8/13/2008
+
+
+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 3 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80804-CIV-MARRA/JOHNSON
+JANE DOE, a/k/a,
+JANE DOE NO. 1,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN.
+I, and
+Defendants.
+PLAINTIFF'S UNOPPOSED MOTION FOR ENLARGEMENT OF TIME TO FILE
+CIVIL RICO CASE STATEMENT PURSUANT TO LOCAL RULE 12.1
+Plaintiff Jane Doe moves, pursuant to Rule 7.I(A) of the Local Rules of the United States
+District Court for the Southern District of Florida, for an enlargement of time to file a Civil
+RICO Case Statement under Local Rule 12.1 until fifteen days after the Court rules on her
+motion to remand, which will be filed on or about August 18, 2008.
+1. Defendants removed this action to federal court on July 21, 2008. (DE 1).
+2. Because Plaintiff has pleaded a cause of action under section 772.103, Florida
+Statutes, she is required to file a Civil RICO Case Statement within thirty days of
+removal. See S.D. Fla. L.R. 12.1.
+3.
+Plaintiff believes this action was improperly removed from state court and shall file
+a motion to remand on or about August 18, 2008. It is Plaintiff's contention that the
+Court lacks subject matter jurisdiction over this case because it does not involve a
+federal question or parties with complete diversity of citizenship.
+
+
+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 4 of 6
+4. If this action was improperly removed, Plaintiff should not be required to expend the
+time and expense necessary to create and file a Civil Rico Cast Statement, which
+would not be required in Florida state court.
+WHEREFORE, Plaintiff respectfully request the Court grant her motion for an
+enlargement of time to file a Civil RICO Case Statement until fifteen days after the Court rules
+on her motion to remand.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+On August 13, undersigned counsel conferred with counsel for the Defendants in a good
+faith effort to resolve the issues raised in this motion, and Defendants' counsel advised that
+Defendants do not oppose this motion.
+s/ Spencer I. Kuvin
+Spencer T. Kuvin (Florida Bar Number 089737)
+Certificate of Services
+1 hereby certify that on August 13, 2008, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+rved this day on all counsel of record or pro se parties identified on the attached Service List
+e manner specified, either via transmission of Notices of Electronic Filing generated
+CM/ECF or in some other authorized manner for those counsel or parties who are not authorized
+to receive electronically Notices of Electronic Filing.
+s/ Spencer I. Kuvin
+Spencer T. Kuvin (Florida Bar Number 089737)
+Attorney B-Mail Address:
+RICCI-LEOPOLD, P.A.
+2925 PGA Blvd.
+Suite 200
+Palm Beach Gardens, FL 33410
+Telephone: (561) 684-6500
+Facsimile: (561) 697-2383
+Counsel for Plaintiff Jane Doe
+2.0f4
+
+
+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 5 of 6
+SERVICE LIST
+Doe v. Epstein, et. al.
+CASE NO: 08-80804-Civ-MARRA/JOHNSON
+United States Distriet Court, Southern District of Florida
+Robert Critton, Esq.
+Burman, Critton, Luttier & Coleman, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+Counsel for Jeffrey Epstein
+Served via U.S. Mail, postage prepaid
+Guy Alan
+Esa.
+Email:
+Tein
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Phone: (305) 442-1101
+Fax: (305) 442-6744
+Counsel for Jeffrey Epstein
+Served via CM/ECP
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+Counsel for
+Served via U.S. Mail, postage prepaid
+Michael R. Tein, Esq.
+Email: tein@lewistein.com
+Tein
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Phone: (305) 442-1101
+Fax: (305) 442-6744
+Counsel for Jeffrey Epstein
+Served via CM/ECF
+3 of 4
+
+
+Case 9:08-cv-80804-KAM Document 16-1 Entered on FLSD Docket 08/29/2008 Page 6 of 6
+Douglas M. Melntosh, Esq.
+Jason A.
+1, Esq.
+Mcintosh, Sawran, Peltz & Cartaya, P.A.
+Centurion Tower, Suite 1110
+1601 Forum Place
+West Palm Beach, FL 33401
+Phone: (561) 682-3202
+Fax: (561) 682-3206
+Counsel for
+Served via U.S. Mail, postage prepaid
+4 of 4
diff --git a/vision-fixhub/court-01/e5d71ece88c2bdda3b990947981e188bc6f792eb60178335766afd50ab0cb3ce.receipt.json b/vision-fixhub/court-01/e5d71ece88c2bdda3b990947981e188bc6f792eb60178335766afd50ab0cb3ce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3f2bcbc89b89bc686159bf0492ca19e88290bd78
--- /dev/null
+++ b/vision-fixhub/court-01/e5d71ece88c2bdda3b990947981e188bc6f792eb60178335766afd50ab0cb3ce.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "d3d575a88acd9877ada1c759533d23e01990e6bb5237c1ec698d6e2f05c5f3ea",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e60684f76c198f9329366a59c7adf5d9dc3306096eaf010a33c01ffb67491152.md b/vision-fixhub/court-01/e60684f76c198f9329366a59c7adf5d9dc3306096eaf010a33c01ffb67491152.md
new file mode 100644
index 0000000000000000000000000000000000000000..2156bf20477e455c088e1a74a1b6a228c42fdc93
--- /dev/null
+++ b/vision-fixhub/court-01/e60684f76c198f9329366a59c7adf5d9dc3306096eaf010a33c01ffb67491152.md
@@ -0,0 +1,182 @@
+Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant, Jeffrey Epstein and Plaintiff,
+File This Notice of
+Agreement Relative to Defendant's Emergency Motion For Independent Medical
+Examination Of Plaintiff, Plaintiff's Response In Opposition and Defendant's Reply
+Thereto
+Defendant, JEFFREY EPSTEIN (hereinafter "EPSTEIN") and Plaintiff,
+(Plaintiff" or "CMA"), File This Notice of Agreement
+Relative to Defendant's Emergency Motion For Independent Examination Of Plaintiff, Plaintiff's
+Response In Opposition and Defendant's Reply Thereto:
+On July 29, 2009, Defendant filed the Emergency Motion for IME of
+Plaintiff (DE 245).
+2.
+On August 7, 2009, Plaintiff filed her Response In Opposition and
+Incorporated Motion for Protective Order Regarding Defendant's Emergency Motion For
+IME (DE 254).
+On August 17, 2009, Defendant filed his Reply thereto (DE 273).
+
+
+Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009 Page 2 of 4
+While several issues remain outstanding and require the court's attention
+relative to the above docket entries, the undersigned attorneys have reached an agreement
+relative to Plaintiff's specific request to have a third-party present at said IME. In
+particular, the undersigned attorneys have agreed that Plaintiff will be provided a
+television monitor in a separate room accompanied by a video feed, thereby allowing
+Plaintiff's agent to monitor the IME from a location separate and apart from where the
+IME is being performed. Such an agreement was reached as a result of Defendant's
+expert, Dr.
+, offering same in his Affidavit and the undersigned attorneys' agreement
+to same.
+The Defendant will be responsible for the costs associated with providing
+the television monitor and the video feed.
+6.
+In light of the foregoing agreement, the court is now relieved from having
+to rule on those portions of the Emergency Motion, the Response in Opposition and
+Motion for Protective Order and Reply that specifically deal with Plaintiff's request that a
+third-party be present in/at the IME of Plaintiff. That particular issue is now moot.
+MICHAEL J. PIKE, ESO
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+eing served this day on all counsel of record identified on the following Service List i
+he manner specified by CM/ECF on this 20 day of Qu
+_ 2009
+Respectfully submitted,
+
+
+Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009 Page 3 of 4
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRAÀJ
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL, 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M. I
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+
+
+Case 9:08-cv-80119-KAM Document 278 Entered on FLSD Docket 08/20/2009 Page 4 of 4
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@scarcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+Bruce Reinhart, Esq.
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
diff --git a/vision-fixhub/court-01/e60684f76c198f9329366a59c7adf5d9dc3306096eaf010a33c01ffb67491152.receipt.json b/vision-fixhub/court-01/e60684f76c198f9329366a59c7adf5d9dc3306096eaf010a33c01ffb67491152.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..57fe75ea138f31f246627e3c7a2d0e3ab112b4f8
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+}
diff --git a/vision-fixhub/court-01/e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475.md b/vision-fixhub/court-01/e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475.md
new file mode 100644
index 0000000000000000000000000000000000000000..42a4ee66820fd12f3e4da8374eec64c22746e870
--- /dev/null
+++ b/vision-fixhub/court-01/e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475.md
@@ -0,0 +1,41 @@
+Case 1:20-cv-00484-JGK-DCF Document 6-4 Filed 01/21/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+-against-
+DARREN. INDYKE and RICHARD D. KAHN, in their
+capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+Defendant.
+1:20cv_
+00484(
+ORDER FOR ADMISSION
+PRO HAC VICE
+)
+The motion of
+Robert Samuel Glassman, Esq.
+, for admission to
+practice Pro Hac Vice in the above captioned action is granted.
+Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of
+California, District of Columbia
+_; and that his/her contact information is as follows
+(please print):
+Applicant's Name:
+Robert Samuel Glassman.
+Firm Name:
+Panish Shea & Boyle LLP
+Address:
+11111 Santa Monica Blvd., Suite 700
+City / State / Zip:
+Los Angeles, CA 90025
+Telephone / Fax:
+310-477-1700 / 310-477-1699
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel for
+Plaintiff, Jane Doe
+in the above entitled action;
+IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above
+captioned case in the United States District Court for the Southern District of New York. All attorneys
+appearing before this Court are subject to the Local Rules of this Court, including the Rules governing
+discipline of attorneys.
+Dated:
+United States District / Magistrate Judge
diff --git a/vision-fixhub/court-01/e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475.receipt.json b/vision-fixhub/court-01/e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6c6a860a9660a2d34f3addcae042348d8805d1d3
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@@ -0,0 +1,14 @@
+{
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+  "doc_id": "e606fe36ec60673178b84398c3c6a04659c20ee55b8df8155de265613e05c475",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e88525ffd7fd275f59dd86e6d7b2dec6612813c93b1c2b52efc98e2b97002ba6",
+  "output_sha256": "cfcc0fe59b150603d0e320ae9d96b1c94ca3b262d0ce077afde01f87f3507d12",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e60733f8d0ab0204f4599cb3c9d87164dad7fbcd54ca87c6821204c9d87a41ae.md b/vision-fixhub/court-01/e60733f8d0ab0204f4599cb3c9d87164dad7fbcd54ca87c6821204c9d87a41ae.md
new file mode 100644
index 0000000000000000000000000000000000000000..2f2b72fab7f3772282846a2b0e9129e8b9774af5
--- /dev/null
+++ b/vision-fixhub/court-01/e60733f8d0ab0204f4599cb3c9d87164dad7fbcd54ca87c6821204c9d87a41ae.md
@@ -0,0 +1,95 @@
+Case 9:08-cv-80119-KAM Document 13 Entered on FLSD Docket 06/20/2008 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT'S MOTION FOR ENLARGEMENT OF
+TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
+Defendant Jeffrey Epstein moves, pursuant to S.D. Fla. L.R. 7.1(A), for an
+enlargement of time to answer or otherwise respond to the complaint until ten days
+after his motion for a mandatory stay, filed contemporaneously with this motion, is
+decided, and as grounds for this relief respectfully states as follows:
+This civil action is a private counterpart to two ongoing criminal
+actions, one in Palm Beach state court, the other in the Southern District of Florida.
+These cases purport to arise from the same occurrence: the alleged
+sexual assault of a minor, Jane Doe No. 2.
+3.
+On June 20, 2008, Mr. Epstein filed a motion seeking a stay of this
+action under 18 U.S.C. § 3509. Under that section, when an alleged sexual assault
+
+
+Case 9:08-cv-80119-KAM Document 13 Entered on FLSD Docket 06/20/2008 Page 2 of 4
+involving a child victim results in a "criminal proceeding," a commonly derived
+civil suit "shall be stayed until the end of all phases of the criminal action." 18
+U.S.C. § 3509(k) (emphasis added).
+4. If Mr. Epstein's stay motion is granted, he will not be required to
+respond to the Complaint or otherwise litigate this action until the two pending
+criminal matters are resolved.
+WHEREFORE, Defendant Jeffrey Epstein respectfully requests an
+enlargement of time to answer or otherwise respond to the complaint until ten days
+after his motion for a stay is decided.
+Respectfully submitted,
+ATTERBURY, GOLDBERGER &
+WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel: 561 659 8300
+Fax: 561 835 8691
+By: Is/ Jack A. Goldberger
+Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+2
+
+
+Case 9:08-cv-80119-KAM Document 13 Entered on FLSD Docket 06/20/2008 Page 3 of 4
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7
+Counsel for defendant has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+Is/ Jack A. Goldberger
+Jack A. Goldberger
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 20, 2008, I electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that
+the foregoing document is being served this day on counsel of record identified
+below by facsimile and U.S. Mail.
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+Is/ Jack A. Goldberger
+Jack A. Goldberger
+3
+
+
+Case 9:08-cv-80119-KAM Document 13 Entered on FLSD Docket 06/20/2008 Page 4 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE having come to be heard on the Defendant's Motion for An
+Enlargement of Time to Answer or Otherwise Respond to the Complaint, and this
+Court being fully advised, it is hereby:
+ORDERED AND ADJUDGED that the Motion is hereby granted.
+DONE AND ORDERED in Miami-Dade County, Florida this
+day
+of
+_, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to:
+Jack A. Goldberger, Esq.
+Jeffrey M. Herman, Esq.
diff --git a/vision-fixhub/court-01/e60733f8d0ab0204f4599cb3c9d87164dad7fbcd54ca87c6821204c9d87a41ae.receipt.json b/vision-fixhub/court-01/e60733f8d0ab0204f4599cb3c9d87164dad7fbcd54ca87c6821204c9d87a41ae.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..80d3e3396e15ff090fba67a6df4a86166fed8545
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e6139587164dc9c283d60930c1637f44128f40cb36ad924a5ac317a39eaa79be.md b/vision-fixhub/court-01/e6139587164dc9c283d60930c1637f44128f40cb36ad924a5ac317a39eaa79be.md
new file mode 100644
index 0000000000000000000000000000000000000000..dbc4d0582b4ff689b3a7cd0343015fadf6c9db34
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+++ b/vision-fixhub/court-01/e6139587164dc9c283d60930c1637f44128f40cb36ad924a5ac317a39eaa79be.md
@@ -0,0 +1,354 @@
+Case 9:08-cv-80119-KAM Document 305-8
+Entered on FLSD Docket 09/17/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CV-80119-MARRA/
+JANE DOE NO.2,
+Plaintiff,
+-VS-
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811,
+08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEPOSITION OF JANE DOE #4
+Wednesday, September 16, 2009
+1:03 - 1:08 p.m.
+250 Australian Avenue South
+Suite 115
+West Palm Beach, Florida 33401
+Reported By:
+, RPR, FPR
+Notary Public, State of Florida
+Prose Court Reporting
+
+(561) 832-7500
+Electronically signed by cynthia
+PROSE COURT REPORTING AGENCY, INC.
+(601-051-976-2934)
+
+
+Case 9:08-cv-80119-KAM Document 305-8 Entered on FLSD Docket 09/17/2009 Page 2 of 3
+Page 2
+2
+5
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+23
+24
+25
+2
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+(561) 832-7500
+Electronically signed by cynthia
+APPEARANCES:
+On behalf of the Plaintiff:
+ADAM D. HOROWITZ, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard
+Suite Z218
+Miami, Florida 33160
+Phone: 305.931.2200
+On behalf of the Defendant:
+ROBERT D. CRITTON, JR, ESQUIRE
+MARK T. LUTTIER, ESQUIRE
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Banyan Boulevard
+Suite 400
+West Palm Beach, Florida 33401
+Phone: 561.842.2820
+On behalf of Jefirey Epstein:
+JACK ALAN GOLDBERGER, ESQUIRE
+ATTERBURY, GOLDBERGER & WEISS, PA.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401-5012
+Phone: 561.659.8300
+On behalf of LM and EW:
+WILLIAM J. BERGER, ESQUIRE
+ROTHSTEIN, ROSENFELDT, ADLER
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, Florida 33301
+Phone: 954.522.3456
+[ESQUIRE
+SEARCY, DENNEY, SCAROLA
+BARNHART & SHIPLEY, P.A
+39 Palm Beach Lakes Bouleva
+est Palm Beach, Florida 334
+APPEARNCES CONTINUED...
+On behalf of BB:
+ADAM J. LANGINO, ESQUIRE
+LEOPOLD KUVIN
+2925 PGA Boulevard
+Suite 200
+Palm Beach Gardens, Florida 33410
+Phone: 561.515.1400
+Page 3
+1
+2
+3
+4
+5
+6
+7
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+PROSE COURT REPORTING AGENCY, INC.
+| (601-051-976-2934)
+Page
+4
+PROCEEDINGS
+MR. HOROWITZ: Adam Horowitz, counsel for
+Plaintiff, Jane Doe 4.
+MR. CRITTON: Cindy, what time is it?
+THE COURT REPORTER: It is 1:03.
+MR. BERGER: William J. Berger for LM and
+EW.
+MR.
+: Jack
+for CMA.
+MR. LANGINO: Adam Langino from
+Leopold Kuvin on behalf of BB.
+MR. LUTTIER: Mark Luttier on behalf of
+Burman, Critton, Luttier & Coleman for the
+Defendant.
+MR. CRITTON: Robert Critton on behalf of
+Defendant, Jeffrey Epstein.
+MR. HOROWITZ: This is Adam Horowitz.
+We're canceling today's deposition. Before
+appearing here today, we had a stipulation with
+Defense counsel that Mr. Jeffrey Epstein, the
+Defendant, would not be here. He would not
+cross paths with our client.
+And immediately as we were approaching the
+deposition room, he made face-to-face contact
+with our client. He was just feet away from
+Page 5
+her and intimidated her, and for that reason
+we're not going forward.
+MR. CRITTON: I didn't see any contact
+because I, obviously, was not out there. We
+started at about -- when you came in it was
+approximately 1:03. Mr. Epstein has an office
+here at the Florida Science Foundation. Had
+you been here at 1:00, your paths never would
+have crossed because Mr. Epstein was leaving
+the building. I instructed him to leave the
+building so that he would not be here.
+He was going to appear by way of Skype so
+that he could be on a video camera so that he
+could see this.
+(Mr. Goldberger entered the room.)
+MR. CRITTON: Had you been here on time,
+and not faulting, I am just saying had you been
+here on time at 1:00, as everyone else seemed
+to be here at least get here before you did,
+Adam, you and your client, your paths never
+would have crossed.
+I directed Mr. Epstein to leave the
+building so he would not be here so that there
+would be no way that your paths could have
+crossed. It was neither my intent nor was it
+2 (Pages 2 to 5)
+
+
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Case 9:08-cv-80119-KAM Document 305-8 Entered on FLSD Docket 09/17/2009 Page 3 of 3
+1
+2
+3
+4
+Page 6
+my client's intent specifically, because I also
+advised him that he was not to cross paths, not
+to have any contact with your client, and
+certainly by our agreement not to be here today
+for the deposition.
+MR. HOROWITZ: And at approximately 1:00
+is exactly when my client crossed paths with
+Jeffrey Epstein. And not only did he cross
+paths but he proceeded to stare her down just
+feet away from her. For that reason she became
+an emotional wreck and cannot proceed with the
+deposition. She's simply not in an emotional
+state to do so.
+And in addition Mr. Epstein violated the
+agreement between counsel that he would not
+cross paths or come into contact with our
+client. And it will be also for the criminal
+court judge to decide whether he has violated a
+no-contact order. I have nothing else to say.
+MR. CRITTON: Again I instructed
+Mr. Epstein to leave the building so absolutely
+no contact could occur between he and
+Mr. Horowitz and his client nor anyone else.
+Until the court, until either Judge Marra or
+Judge
+ruled on the issue as to whether
+Page 7
+or not he could appear at the depositions of
+not only Jane Doe 4 but any other individuals,
+so you do what you need to do.
+MR. HOROWITZ: Off the record.
+(The Deposition was concluded.)
+Page
+8
+CERTIFICATE
+2
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+1, Cynthia
+Registered Professional
+Reporter and Florida Professional Reporter, State of'
+Florida at large, certify that I was authorized to
+and did stenographically report the foregoing
+proceedings and that the transcript is a true and
+complete record of my stenographic notes.
+Dated this 16th day of September, 2009.
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Gratie J. Hopuns
+Cynthia Hopkins, RPR
+(561) 832-7500
+Electronically signed by cynthia
+PROSE COURT REPORTING AGENCY, INC.
+(601-051-976-2934)
+3
+(Pages 6 to 8)
\ No newline at end of file
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new file mode 100644
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@@ -0,0 +1,93 @@
+Case 9:08-cv-80232-KAM Document 20-1 Entered on FLSD Docket 07/18/2008 Page 1 of 3
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave. Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+NOTIFICATION OF IDENTIFIED VICTIM
+NOTICE: IN ACCORDANCE WITH TITLE 18, UNITED
+STATES CODE, SECTION 3509(d) AND FLORIDA LAW,
+THE ATTACHED DOCUMENT IS TO BE TREATED AS
+CONFIDENTIAL AND SHALL NOT BE DISCLOSED
+EXCEPT IN CONNECTION WITH
+A LEGAL
+PROCEEDING.
+
+
+
+Case 9:08-cv-80232-KAM Document 20-1 Entered on FLSD Docket 07/18/2008 Page 2 of 3
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 10, 2008
+VIA FACSIMILE AND U.S. MAIL
+Jeffrey Herman, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Re: Jeffrey Epstein/
+IDENTIFIED VICTIM
+• NOTIFICATION OF
+Dear Mr. Herman:
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client, (
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+
+
+Case 9:08-cv-80232-KAM Document 20-1 Entered on FLSD Docket 07/18/2008 Page 3 of 3
+JEFFREY HERMAN, ESQ.
+NOTIFICATION OF IDENTIFIED VICTIM
+JULY 10, 2008
+
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client, i
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401.
+Please understand that neither the U.S. Attorney's Office northe Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide written documentation of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this investigation
+and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for
+the health and well-being of
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Abid illafare
+A. M
+VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+cc:
+Jack Goldberger, Esq.
diff --git a/vision-fixhub/court-01/e633e7eb08e241af961f80d72c58001d54ccf319e39e77d4029f354dc0bce641.receipt.json b/vision-fixhub/court-01/e633e7eb08e241af961f80d72c58001d54ccf319e39e77d4029f354dc0bce641.receipt.json
new file mode 100644
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+}
diff --git a/vision-fixhub/court-01/e659a066eaffcaf3edf0d0a2600f9f1a5e36b20e9c603f53cc4563c4aea9ec3d.md b/vision-fixhub/court-01/e659a066eaffcaf3edf0d0a2600f9f1a5e36b20e9c603f53cc4563c4aea9ec3d.md
new file mode 100644
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@@ -0,0 +1,565 @@
+Ease 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 1 of 20
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:08-cv-80736-Civ-KAM
+JANE DOE 1 and JANE DOE 2
+2014 MAY 16
+FILED BY.
+V.
+UNITED STATES
+PM 4: 01
+JANE DOE 1 ANDJANE DOE 2'S RESPONSE IN OPPOSITION TO EPSTEIN'S B
+MOTION FOR A PROTECTIVE CONFIDENTIALITY ORDER
+COME NOW Jane Doe 1 and Jane Doe 2 (also referred to as "the victims"), by and
+through undersigned counsel, to file this response in opposition to Epstein's Motion for a
+Protective Confidentiality Order (DE 247). Epstein's motion is a thinly-disguised attempt to
+relitigate issues already covered by the court's earlier ruling eleven months ago (DE 188), which
+allowed the victims to file correspondence relating to Epstein's non-prosecution agreement in the
+public court file. Rather than reverse its previous ruling, this Court should reaffirm it - and
+allow the important issues presented by this case to be litigated in the light of day.
+BACKGROUND
+Because of Epstein's penchant for relitigating issues that have already been decided, it is
+necessary to recount the litigation that has already gone on in this case regarding confidentiality,
+including the Court's directive in DE 188 allowing filing of materials in the public court file.
+On March 21, 2011, the victims filed what was essentially a Motion For Summary
+Judgment in this case, explaining why (in their view) the Government had violated its
+obligations under the Crime Victims' Rights Act (CVRA) to notify them of court hearings, to
+1
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 2 of 20
+confer with them regarding plea discussions, and to treat them with fairness. DE 48. The motion
+contained 53 alleged undisputed facts. Some of those facts rested on correspondence between
+the prosecutors and Epstein's legal defense team - correspondence that the victims had received
+in 2010 as part of a civil case against Epstein (hereinafter referred to as the "2010 plea
+correspondence"). Because the victims were aware that Epstein objected to the use of this
+correspondence, they filed a redacted copy of their pleading in the open court file - i.e., a copy in
+which the quotations from the 2010 correspondence had been blacked out. They simultaneously
+filed a motion to use that correspondence in this case and to place an unredacted copy of the
+summary judgment motion and attached correspondence in the open court file. DE 51. On April
+7, 2011, the Government filed a partial opposition to the victims' motion. DE 60. On May 2,
+2011, the victims' replied to this response DE 74.
+Meanwhile, on April 7, 2011, three of Epstein's criminal defense attorneys - Roy Black,
+Jay Lefkowitz, and
+Weinberg - filed a motion to intervene in this case for the purpose of
+challenging the victims' motion to use the correspondence and to place an unredacted copy of
+the summary judgment motion and attached correspondence in the court file. DE 56 at 4
+(challenging victims" motion, DE 51). On May 2, 2011, the victims responded in opposition to
+the motion to intervene. DE 78. On May 2, 2011, the three defense attorneys replied in support
+of their intervention motion. DE 80.
+On August 12, 2011, this Court held a hearing on the various pending motions, and
+during the hearing raised various questions about whether the defense attorneys were the proper
+intervenors on issues of confidentiality. Shortly after the hearing, on September 2, 2011, Epstein
+filed a motion for limited intervention on issues relating to a protective order for the
+2
+
+
+Ease 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 3 of 20
+correspondence. DE 93. His pleading included, as Exhibit 1, a proposed motion for a protective
+order regarding the correspondence that he intended to file if granted leave to intervene. DE 93,
+Exhibit 1. On September 16, 2011, the victims filed a response in objection to Epstein's motion.
+DE 96; the Government responded as well. DE 98.
+On September 26, 2011, the Court entered an order allowing discovery to move forward
+in the case. DE 99. In September and October, further briefing continued on the intervention
+motions. DE 100, 106, 108, 115.
+On March 29, 2013, this Court granted both the motion to intervene filed by Epstein and
+the motion to intervene filed by Epstein's three defense attorneys. DE 158, DE 159.
+Accordingly, on April 17, 2012, Epstein and his three defense attorneys both filed motions for a
+protective order. DE 161, 162. The victims responded in opposition. DE 167. Epstein and his
+attorneys replied. DE 169.
+On June 18, 2013, the Court sided with the victims on all the confidentiality issues. DE
+188. The Court expressly rejected all of the arguments by Epstein and his attorneys for not
+releasing the correspondence publicly. The Court began: "At the outset, the court observes that
+the intervenors' privilege objections to public release of the correspondence in question were
+previously rejected by Magistrate Judge Linnea
+in a discovery order entered in a parallel
+civil lawsuit...." DE 188 at 3.
+The Court saw "no reason to revisit" that ruling. Id. at 4. The
+Court then rejected all of the intervenors' "privilege" arguments about why the materials were
+confidential. The Court concluded that the materials should no long be kept under seal:
+Accordingly, the court rejects the privileges asserted by intervenors as bases for
+maintaining the correspondence and related pleadings incorporating the
+correspondence under seal in this proceeding. Finding the asserted privilege
+3
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 4 of 20
+inapplicable, the court finds no legitimate compelling interest which warrants the
+continued suppression of this evidentiary material under seal in this proceeding.
+See generally United States v. Ochoa-Vasquez, 428 F.3d 1015 (11th Cir. 2005)
+(reversing order sealing document in drug trafficking conspiracy prosecution in
+order to protect cooperating defendants and confidential informants where
+unsupported by record finding to rebut presumption of openness of court
+proceedings), and shall therefore grant petitioners' motion to unseal the
+correspondence. While the court shall also grant the petitioners' motion to use the
+evidence as proof of alleged CVRA violations to the extent it shall allow
+petitioners to proffer the evidence in support of their CVRA claims, this order is
+not intended to operate as a ruling on the relevance or admissibility of any
+particular piece of correspondence, a matter expressly reserved for determination
+at the time of final disposition.
+DE 188 at 9-10. The Court then entered the language that is central to this notice: "The
+[victims] are directed to file unredacted pleadings, including attached correspondence, in the
+open court file. However, before placing the materials in the court file, petitioners are directed to
+carefully review each page of the correspondence in question and to [make appropriate
+redactions for victim names and other identifying information] .... The petitioners shall file
+unredacted pleadings in the court file in conformity with the above prescriptions within
+TWENTY (20) DAYS from the date of entry of this order. DE 188 at 10 (entered June 18, 2013)
+(emphasis added). On the same day, the Court denied the Government's motion to dismiss the
+case and directed that discovery proceed. DE 189.
+Epstein and his attorneys quickly sought a stay of the ruling from this Court. DE 193.
+They also filed notices of appeal with the Eleventh Circuit. On July 8, 2013, the Court denied
+the request for a stay, but granted a temporary stay to allow the Eleventh Circuit to review the
+issue. DE 206. On September 23, 2013, the Eleventh Circuit entered a stay pending its review
+of the matter. Following briefing and argument, on April 18, 2014, the Eleventh Circuit ruled in
+favor of the victims, affirmed this Court's decision, and simultaneously lifted its stay. Jane Doe
+4
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 5 of 20
+No. 1 v. United States, ---F.3d--, 2014 WL 1509015, No. 13-12923 at 23. The Circuit explained
+that "[a]lthough plea negotiations are vital to the functioning of the criminal justice system, a
+prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and
+trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a
+doctor and patient or attorney and client, warrants no [new] privilege . . . ."
+Slip op. at 21-22.
+On April 24, 2014, Epstein and his attorneys sought a stay of the Eleventh Circuit's order
+pending review of a petition for rehearing en banc. The next day, the Eleventh Circuit denied
+that stay.
+On May 2, 2014, the U.S. Attorney's Office provided 541 pages of correspondence
+between prosecutors and Epstein's defense attorneys that lead up to Epstein's non-prosecution
+agreement (hereinafter referred to as the "2014 correspondence").'
+That same day, Epstein filed a motion for a protective order over the correspondence. DE
+247. Epstein specifically moved the Court to restrict dissemination of the same materials that
+this Court and the Eleventh Circuit had both found to be non-confidential. Epstein asked the
+Court to enter:
+a Protective Confidentially Order which (1) limits the dissemination of certair
+Confidential Discovery Material ("CDM'") described below, to a designated list o!
+the Plaintiffs' counsel and support staff, and (2) prohibits any party from filing
+pleadings, briefs, memorandums or exhibits purporting to reproduce, quote,
+"The Government has failed to produce a significant amount of the correspondence that
+the Court had directed it to produce.
+These failures do not involve isolated pieces of
+correspondence, but rather entire substantial categories. The victims have requested this
+additional information from the Government and have been told, in essence, that it is being
+compiled. The victims are preparing an appropriate motion to bring these failures to the Court's
+attention and to request appropriate remedial action.
+5
+
+
+Ease 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 6 of 20
+paraphrase or summarize any CDM or portions thereof, absent leave of the Court
+to file the document or portion thereof under seal in accordance with Local Rules
+of the United States District Court for the Southern District of Florida.
+DE 247 at 1-2. The alleged "Confidential Discovery Material" included the same
+correspondence that was at issue in DE 188. See DE 247, Exhibit 1 (proposing that the Court
+enter a protective order regarding "all correspondence between the United States Attorney's
+Office and the Intervenors ... that was the subject of the Court's Order of June 18, 2013 (Doc.
+188) ...."). Epstein's new motion does not discuss the Court's earlier (June 18, 2013) direction
+to the victims to file unredacted pleadings (and accompanying material) in the open court file.
+That same day, Epstein's counsel sent an e-mail to victims counsel stating that Epstein
+"would ask that you await a ruling prior to any dissemination."
+On May 6, 2014, the victims filed a notice of intent to comply with Court's earlier (June
+18) direction to file unredacted copies of the pleadings in the file. The victims explained that in
+light of the lengthy procedural history just recounted, "and to avoid any confusion, the victims
+wanted to give notice that on May 8, 2014, they intend to comply with the Court's June 18, 2013,
+directive." DE 248.
+The next day, on May 7, 2014, the Court entered an order regarding the notice of intent to
+comply:
+On April 18, 2014, the Eleventh Circuit affirmed several orders of this Court, and
+lifted the stay it had imposed in relation to one of the orders. However, no
+mandate has been issued thus far. Accordingly, petitioners should not comply
+with the Order
+Granting Petitioners' Motion to Proffer Government
+Correspondence in Support of CVRA Claims & Granting Motion to Unseal
+Correspondence and Related Unredacted Pleadings of Petitioners (DE 188) until
+further order of this Court.
+DE 249 at 1.
+6
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 7 of 20
+The CAll has not yet issued its mandate.
+I.
+ARGUMENT
+IT IS ALREADY THE "LAW OF THE CASE" THAT MATERIAL RELATING
+TO THE NON-PROSECUTION AGREEMENT CAN BE PROFFERED BY THE
+VICTIMS IN PUBLIC COURT FILINGS.
+If the Court has a sense of déjà vu in reviewing Epstein's motion for a protective order, it
+is because the Court has already looked at the same arguments - and rejected them. As the
+foregoing history makes clear, the victims previously moved for leave to use the correspondence
+to prove violation of the non-prosecution agreement. And the Court agreed, subject only to the
+reservation that the Court would determine the actual relevance at the appropriate hearing:
+Accordingly, the court rejects the privileges asserted by intervenors as bases for
+maintaining the correspondence
+and related pleadings incorporating the
+correspondence under seal in this proceeding. Finding the asserted privileges
+inapplicable, the court finds no legitimate compelling interest which warrants the
+continued suppression of this evidentiary material under seal in this proceeding. .
+.. While the court shall also grant the petitioners' motion to use the evidence as
+proof of alleged CVRA violations to the extent it shall allow petitioners to proffer
+the evidence in support of their CVRA claims, this order is not intended to
+operate as a ruling on the relevance or admissibility of any particular piece of
+correspondence, a matter expressly reserved for determination at the time of final
+disposition.
+DE 188 at 9-10 (emphasis added). Accordingly, the issue has already been settled once - and the
+Court should not revisit it. See United States v. Stinson, 97 F.3d 466, 469 (11th Cir.1996)
+(discussing law of the case doctrine); see also Singh v.
+Washington Univ., 383 F.Supp.2d
+99, 101 (D.D.C. 2009) (internal quotation omitted) ("where litigants have once battled for the
+court's decision, they should neither be required, nor without good reason permitted, to battle for
+it again.").
+7
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 8 of 20
+It is the law of the case that the victims can "use the evidence as proof of alleged CVRA
+violations" and that there is "no legitimate compelling interest" supporting sealing the material.?
+Epstein does not even discuss this prior ruling. That is reason enough to reject his motion.
+Il.
+EPSTEIN'S PROPOSED PROTECTIVE ORDER WOULD PREVENT THE
+PUBLIC FROM LEARNING ABOUT MATTERS OF CONSIDERABLE PUBLIC
+CONCERN.
+Even if the Court were inclined to revisit the issue, it should reach the same conclusion it
+reached earlier: the victims pleadings in this case should generally be placed in the public court
+file. It is important to understand the breadth of the protective order that Epstein is seeking.
+Epstein pretends that his proposed order is a narrow one merely limiting the public access to
+discovery - citing various cases about whether the public can demand to have access to
+discovery produced in civil or criminal cases. DE 247 at 6-7. But the protective order Epstein
+seeks to have entered extends far more broadly and appears to be specifically designed to prevent
+the public from learning about the victims arguments in this case. In particular, Epstein's
+proposed order provides that entire "documents" must be sealed if they contain any reference to
+the plea correspondence or other alleged "confidential" material:
+In the event that [a victim] intends to file [plea correspondence] with the court in
+support of.
+super spositive or distery min (, theoring pasty shaly take mentoriny
+2 To be precise, it is actually the law of two cases that the material can be released. See
+DE 188 at 3 ("At the outset, the court observes that the intervenors' privilege objections to public
+release of the correspondence in question were previously rejected by Magistrate Judge Linnea
+The victims note that their pleadings should "generally" be placed in the public court
+file, because there are few, specialized pieces of information that should be redacted before
+public filing - such as the names of sexual assault victims, grand jury information, and private
+telephone numbers. The victims intend to perform such redactions, so those issues are not raised
+by Epstein's motion for a protective order.
+8
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 9 of 20
+action to insure that the documents receive proper protection from public
+disclosure and shall seek leave of Court to file the document under seal in
+accordance with local rules.
+DE 247-1 at 5 (emphases added).
+In light of his request for sealing of "documents," if the Court were to grant Epstein's
+motion, the net effect would be to essentially have the significant and critical parts of this
+litigation carried on in secret. For example, the public would be denied access to the victims'
+summary judgment motion - a "document" that will rely heavily on the correspondence and
+which will demonstrate (the victims believe) a carefully orchestrated plan by Epstein to keep his
+non-prosecution agreement hidden from the victims and, more broadly the public. Indeed, it
+seems clear that the majority of documents filed in this case by the victims in the future will rely
+to some extent on the underlying correspondence. If Epstein's motion is granted, the docket in
+the case will essentially become a black hole.
+It is a fundamental premise of American criminal justice that the public is entitled to
+know what happens in a criminal case. The Supreme Court has repeatedly held that "the
+knowledge that every criminal trial is subject to contemporaneous review in the forum of public
+opinion is an effective restraint on possible abuse of judicial power ...." Richmond Newspapers,
+Inc., 448 U.S. 555, 596 (1980) (internal quotation omitted). An open criminal process
+"assure[s] the public that procedural rights are respected, and that justice is afforded equally,"
+while on the other hand sentencing without the public present " breed[s] suspicion of prejudice
+and arbitrariness, which in turn spawns disrespect for law." In re Hearst Newspapers, L.L.C.,
+641 F.3d 168, 177 (5th Cir. 2011 (quoting Richmond Newspapers, Inc., 448 U.S. at 595). There
+is also a well-recognized "community therapeutic value' to having an open proceeding, because
+9
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 10 of 20
+of the concerns and emotions of members of the public who have been affected by a crime or
+crimes." Richmond Newspapers, Inc., 448 U.S. at 570.
+In light of this strong interest in public access to criminal proceedings, the Eleventh
+Circuit has instructed that the district courts must make substantial findings before sealing
+records in criminal cases before it. For instance, in United States v. Ochoa-Vasque, 428 F.3d
+1015 (11"" Cir. 2005), the Eleventh Circuit reversed an order from this Court that had sealed
+pleadings in a criminal case, emphasizing the importance of the public's historic First
+Amendment right of access to the courts. To justify sealing, "a court must articulate the
+overriding interest along with findings specific enough that a reviewing court can determine
+whether the closure order was properly entered." Id. at 1030.
+Here there is no overriding interest in keeping the pleadings secret. To the contrary, there
+is an overriding interest in having these matters exposed to public light. There is considerable
+public interest in the question of how a serial child molester could arrange such a lenient plea
+agreement with the U.S. Attorney's Office. And, more importantly, there is great public interest
+in how he could have received immunity for a multitude of sex crimes while his victims were
+under the mistaken belief that he was being prosecuted the way any other person would have
+been. There has long been suspicion that Jeffrey Epstein was receiving favorable treatment in
+the criminal investigation because of his wealth and power. See, e.g., Abby Goodnough,
+Questions of Preferential Treatment Are Raised in Florida Sex Case, N.Y. TIMES, Sept. 3,
+2006, at 19 (noting questions that the public had been left "to wonder whether the system tilted
+in favor of a wealthy, well-connected alleged perpetrator and against very young girls who are
+alleged victims of sex crimes"). Indeed, the interest in the matter is strong enough that the
+10
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 11 of 20
+widely-viewed television program Law and Order: Special Victim Unit devoted an episode to the
+case, suggesting in its plot that federal government had intervened improperly to prevent
+effective prosecution. See Law & Order Commemorates Jeffrey Epstein's Taste for Teen
+Hookers,
+http://gawker.com/#!5751094/law--order-commemorates-jeffrey-epsteins-taste-forteen-hookers.
+The public interest in this case also relates to Epstein's political and financial
+connections. For example, the Financial Times reported on July 21, 2011, that "Prince Andrew
+is to step down as Britain's special representative for trade and investment, just five months after
+being at the centre of a media firestorm over his links to Jeffrey Epstein a US businessman
+convicted of
+sex
+offences."
+http://www.ft.com/cms/s/0/78dba2c2-b383-11e0-b56c-
+00144feabdc0.html#axzz31RjGpH6l. The American media, too, has commented on these
+relations. See, e.g., Jose Lambiet, Prince's Friendship with Pedophile Causes Furor Across the
+Pond, PALM BEACH POST, Mar. 9, 2011, at 2B.
+In light of all this interest, it appears that Epstein's motivation in keeping entire
+"documents" sealed is to block the public from learning about what happened during the
+investigation of his crimes, rather than any legitimate purpose. The Court should not prevent
+public scrutiny of this case by departing from its normal rules and placing critical documents
+under seal.
+III. EPSTEIN HAS FAILED TO ESTABLISH EITHER A LEGAL BASIS OR
+FACTUAL "GOOD CAUSE" FOR A PROTECTIVE ORDER.
+Epstein claims that he can establish some sort of "good cause" for a protective order. But
+his arguments on this point lack a legal basis and are factually far-fetched.
+11
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 12 of 20
+With regard to the legal basis for his motion, Epstein cites Rule 26(c) of the Federal
+Rules of Civil Procedure. DE 247 at 1. But that rule has absolutely no bearing on the
+correspondence at issue. Rule 26(c) applies, by its plain terms, to "[a] party or any person from
+whom discovery is sought may move for a protective order ...." Fed. R. Civ. P. 26(c) (emphasis
+added). Epstein has not been asked to produce any correspondence. Rather, the victims'
+discovery request has been directed to the U.S. Attorney's Office for the Southern District of
+Florida. And it was that Office that produced the correspondence. This fact simply highlights
+the non-confidential nature of the correspondence. If Epstein did not want something revealed,
+then he should have told his attorneys to keep it out of their correspondence sent to the
+prosecutors.
+With regard to the factual basis for his motion, Epstein contends that his defense
+attorneys' "lengthy arguments may or may not have had any influence on the government's
+decision making and, therefore, their relevance is particularly remote." DE 247-7. But the
+victims have argued precisely the contrary. For example, the victims' summary judgment
+motion alleges that Epstein's defense attorneys insisted on, and obtained, a confidentiality
+provision in the non-prosecution agreement that blocked disclosure of it to the victims. DE 48 at
+10. The motion also alleges that because of pressure from Epstein's defense attorneys, the
+Government stopped making victim notifications. Id. at 13. In short, what the defense attorneys
+and prosecutors discussed and agreed to lies at the heart of this case.
+The 2014 correspondence that the victims have just received makes clear (in their view)
+that their allegations are well-founded. By way of example, here are a few excerpts from the
+12
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 13 of 20
+correspondence where Mr. Epstein's attorneys urged the United States Attorney's office against
+notifying the victims - an effort that was ultimately successful:
+Jay Lefkowitz, on behalf of Jeffrey Epstein, wrote to Alex Acosta on October 10, 2007:
+"Communication to Identified Individuals." "...Neither federal agents nor anyone from your
+Office should contact the identified victims to inform them of the resolution of the case,
+including appointment of the attorney representative and the settlement process. Not only would
+that violate the confidentiality of the Agreement, but Mr. Epstein also will have no control over
+what is communicated to the identified individuals at this most critical stage. We believe it is
+essential that we participate in crafting a mutually acceptable communication to the identified
+individuals."
+In another letter from Jay Lefkowitz to Alex Acosta, this one dated November 29, 2007,
+he writes, "More fundamentally, we don't understand the basis for your Office's belief that it is
+appropriate for any letter to be sent to these individuals at this stage - before Mr. Epstein has
+either entered a plea or been sentenced. We respectfully disagree with your view that you are
+required to notify the alleged victims pursuant to the Justice for All Act of 2004." Later in that
+same letter, Lefkowitz addresses the United States Attorney's Office's suggestion that the
+victims should have the right to be heard at any plea or sentencing, and in response he writes,
+"...encouraging these individuals to participate in the state sentencing will have the effect of
+creating a media frenzy that will surely impact the sentence Mr. Epstein received - precisely
+what your Office promised to avoid."
+Continuing to lobby the United States Attorney's Office against involving the victims in
+the process, in a December 11, 2007 letter to Acosta, Lefkowitz wrote, "C. Right of the Alleged
+13
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 14 of 20
+Victims to be Notified: As we have expressed to you previously, we do not agree with your
+Office's assertion that it is either an obligation and even appropriate for the USAO to send a
+victim notification letter to the alleged victims." He continues, "Your interpretation of §3771 is
+erroneous because the rights conferred by statute indicate that these rights are for the notification
+and appearance at public proceedings involving the crime for which the relevant individual is a
+victim. As you know, the public proceeding in this matter will be in state court for the purpose
+of the entry of a plea on state charges. Therefore, 18 U.S.C. §3771 clearly does not apply to
+"victims" who are not state "victims."*'
+On December 26, 2007, Lefkowitz sent a lengthy letter to Acosta, in relevant part,
+explaining, "The Attorney General Guidelines caution federal prosecutors from providing notice
+to potential witnesses in instances where such notice could compromise the defendant's due
+process rights. This is particularly true, as here, if the notice includes confidential information,
+including the conditions of the confidential deferred-prosecution agreement or non-prosecution
+agreement.
+In light of these concerns, we respectfully request that you reconsider sending
+notices to the alleged victims pursuant to §3771."
+In addition to providing insight into the efforts of the defense attorneys to exclude the
+victims from the process entirely, there is also extensive communication regarding the extreme
+efforts taken to prevent the public from learning of the plea as well. In fact, on September 24,
+2007, Lefkowitz sent an email to the United States Attorney's Office with a one-line message -
+"Please do whatever you can to keep this from becoming public."
+It seems Epstein's motives in his motion for protective order remain the same as they
+were during his negotiation with the Government - prevent the public from knowing what they,
+14
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 15 of 20
+in concert with the government, successfully prevented the victims and the public from knowing
+the first time. In an effort to show some sort of good cause for his order, Epstein alleges that the
+victims' counsel have made "inflammatory statements" about the case. DE 247 at 8. But the
+illustrations that Epstein provides do not show statements made to inflame, but rather statements
+made to inform.
+For example, Epstein complains about the media "quoting" the victims'
+pleadings or about victims' counsel hoping that the case will "inspire" victims to report
+sex offenses. DE 247 at 8-9. These are not improper statements. To the extent they related to
+Epstein, they simply provide information to the public about what is happening in this
+complicated proceeding - and simply summarize public record materials. Indeed, the newspaper
+articles that Epstein attaches show many quotations from Epstein's defense attorneys discussing
+the case as well. The statements made by both victims counsel and defense counsel are proper,
+because the Rules of Professional Conduct plainly allow discussion with the media about
+"information contained in a public record." ABA R. Prof. Conduct 3.6(a)(2).
+Epstein also complains about his name being "dragged through the metaphorical mud
+before a jury has made any determination of wrongdoing." DE 247 at 12 (internal quotation
+omitted). But in this case, Epstein has already admitted "wrongdoing" - by entering a plea
+agreement to state sex felonies and then securing a non-prosecution agreement to resolve his
+criminal exposure for dozens of other sex offenses (at least in this judicial district). Part of that
+plea agreement required him to register as a sex offender. He currently appears in the Florida
+sex offender registry.
+See http://offender.fdle.state.fl.us/offender/flyer.do?personld=62762.
+What Epstein is really complaining about is not the publicity associated with the victims' CVRA
+lawsuit, but rather the fact of the victims' lawsuit. Having used his vast resources to secure a
+15
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 16 of 20
+favorable plea agreement, Epstein does not want anyone to be able to publicly suggest that this
+plea agreement was unduly lenient and kept secret from victims who might have been able to
+object and block it. But that is what the victims have alleged, in detail, in their pleadings to this
+Court - and the evidence in support of their allegations is continuously mounting, as the 2014
+correspondence abundantly suggests. There is no "good cause" for keeping the victims'
+allegations - and their supporting evidence - shrouded in secrecy under a protective order.
+IV. THE PROTECTIVE ORDER THAT EPSTEIN PROPOSES WOULD PRODUCE
+CONSIDERABLE UNDERTAINTY AND FOLLOW-ON LITIGATION.
+In addition to blocking public access to information about this case, Epstein's proposed
+protective order is so ambiguously drafted that it would spawn all sorts of follow-on litigation.
+Indeed, counsel for the victims wonder whether that is Epstein's goal: to divert the time and
+attention of the victims (and the Court) away from the merits of the case and into satellite
+litigation about compliance with the protective order.
+The potential ambiguities the protective would create are legion. We list just a few of
+them here to illustrate the problems.
+For starter, the proposed protective order contains all sorts of boilerplate language about
+the "parties" to the case having to comply. See, e.g., DE 247-1 at 3, 11 5(v)(b) ("All parties and
+their respective counsel ... shall take all steps reasonably necessary to prevent disclosure of the
+[correspondence] ....") (emphasis added). And yet, Epstein is not a "party" to this case. He is a
+"limited intervenor." The extent to which the terms of the agreement apply to an intervenor is
+uncertain.
+16
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 17 of 20
+The next problem is that the proposed order applies to "correspondence between the
+United States Attorney's Office and the Intervenors." DE 247-1 at 3, 1 1. If we understand the
+the current posture of this case correctly, the "Intervenors" who would have protected
+correspondence are only three persons: Jeffrey Epstein, Roy Black, and
+Weinberg. See
+DE 247 (describing the intervenors as Epstein, Black, and Weinberg). But the vast bulk of the
+correspondence was not generated by these three people. Of course, none of the correspondence
+bears Epstein's name on it. And as for attorneys Black and Weinberg, they appear to have been
+involved in a tiny fraction of the correspondence (if any). The vast bulk of the correspondence
+was drafted by other attorneys, including Kenneth W. Starr, Jay P. Lefkowitz, Gerald P' Lefcourt,
+Alan Dershowitz, Joe D. Whitley, Stephanie D. Thacker, and Lilly Anni
+It is not clear
+whether the motion is designed to cover these persons and, if so, what standing Roy Black (for
+instance) would have to be litigating issues pertaining to, for example, correspondence written by
+Kenneth W. Starr.
+The protective order will also create delay and questions about briefing schedules. The
+protective order purports to establish a need for a court hearing every time a pleading is filed that
+touches on "confidential" material. In fact, it seems to operate to "toll" briefing on substantive
+questions. See DE 247-1 at 3, 9 12(b) (after filing of pleading with protected material, the
+"motion filing and briefing schedule shall be adjusted and tolled to provide sufficient time for
+the Court to consider and rule on the motion seeking permission to file the documents) under
+seal.").
+All these ambiguities are sure to create abundant litigation - as a just a quick perusal of
+Epstein's litigation tactics in this case in the past will attest. And to what end? Both this Court
+17
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 18 of 20
+and the 11th Circuit have rejected Epstein's arguments that the correspondence somehow
+contains any "confidential" material. See, e.g., In re Roy Black et al., No. 13-12923, slip op. at
+20 (April 18, 2014) ("The conjunctive power of three false claims of privilege [by Epstein] does
+not rescue the correspondence from disclosure."). No confidential relationship exists between
+prosecutors and defense attorneys. There is simply no reason for the Court to depart from its
+ordinary rules and the law of the case.
+To be clear, the victims are not seeking to simply release the discovery in this case to
+anyone that they want. Instead, all that the victims ask is to be able to litigate their case in the
+ordinary, public fashion that the Court follows for vast majority of its cases: by filing their
+pleadings in the open court file.
+CONCLUSION
+The Court should deny Epstein's motion for a protective order (DE 247).
+DATED: May 16, 2014
+Respectfully Submitted,
+Is/l
+ME WEING.
+_ FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+18
+
+
+Gase 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 19 of 20
+University of Utah
+332 S. 1400 B.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu*
+Attorneys for Jane Doe 1 and Jane Doe 2
+* The daytime business address indicated above is for identification purposes and does
+not imply institutional endorsement by the University of Utah of the legal positions advanced in
+this pleading.
+19
+
+
+Case 9:08-cv-80736-KAM Document 251 Entered on FLSD Docket 05/16/2014 Page 20 of 20
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on May 16, 2014, on the following using
+the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoi.gov
+E-mail:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpt, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Email: pleading@royblack.com
+(305) 37106421
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Email: lefkowitz@kirkland.com
+(212) 446-4970
+G. Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Boston,
+02116
+Email: owlmgw@att.net
+(617) 338-9538
+Criminal Defense Counsel for Jeffrey Epstein
+20
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@@ -0,0 +1,33 @@
+Filing # 192906280 E-Filed 02/28/2024 11:11:48 AM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CA FLORIDA HOLDINGS LLC,
+PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner,
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+CIRCUIT CIVIL DIVISION: AG
+VS.
+DAVE ARONBERG, as the State Attorney of Palm
+Beach County, Florida, and
+LABRUZZO,
+as the Clerk of the Circuit Court and Comptroller
+of Palm Beach County, Florida,
+Defendants/Respondents.
+AGREED ORDER GRANTING THE ASSOCIATED PRESS'
+MOTION FOR LIMITED INTERVENTION
+THIS CAUSE having come before the Court upon The Associated Press' Motion for
+Limited Intervention, filed on February 23, 2024, and the Court having considered the motion,
+being advised of the agreement of the parties, and being otherwise advised in the premises, it is
+hereby ORDERED and ADJUDGED that:
+The Motion is GRANTED.
+The Associated Press is hereby permitted to intervene in this matter and shall be
+granted access to any grand jury materials the Court orders to be disclosed.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida
+Circuit Judge
+502019CA014681XXXXMB
+02/28/2024
+Luis Delgado
+Circuit Judge
+FILED: PALM BEACH COUNTY, FL, I
+ABRUZZO, CLERK, 02/28/2024 11:11:48 AM
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@@ -0,0 +1,164 @@
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRAJ
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+
+
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 2 of 6
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-80811-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRAJ
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 3 of 6
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRAJ
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRAJ
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09-
+80656-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE is before the Court on Plaintiff,
+Emergency Motion for Protective Order Regarding the Taking of her Deposition (D.E.
+3
+
+
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 4 of 6
+#259). Due to the emergency nature of the motion, and believing there is no argument that
+can be raised by opposing counsel to justify denying the relief requested, the undersigned
+has elected to rule on the motion before waiting for a response. For the following reasons,
+Plaintiff's Motion for Protective Order is granted.
+By this Motion Plaintiff,
+"), seeks an order
+delaying the taking of her deposition until such time as she is released from the hospital,
+where she is presently recovering from, among other illnesses, thoracic surgery, and
+discharged from any hospital and/or nursing home she may be admitted to for post-surgery
+recovery. According to
+the subject deposition was unilaterally scheduled by
+Defendant's counsel to take place at 10:00 a.m. on August 14, 2009.
+meanwhile, is reportedly in the hospital at the present time recovering from serious
+illnesses, including thoracic surgery, and is not due to be released from the hospital until
+at least August 24, 2009. Counsel for
+has represented that once released, there
+is a possibility that
+will be admitted to a rehabilitative hospital or nursing home
+to convalesce from her illnesses and resulting surgery. Obviously, appearing for her
+deposition unilaterally scheduled by Defendant to take place August 14, 2009 is, for
+, a near impossibility.
+For "good cause" shown the Court may issue a protective order preventing or
+delaying a deposition. Fed. R. Civ. P. 26(c); see McCarthy v. Barnett Bank of Poly County,
+876 F.2d 89, 91 (11th Cir. 1989).
+For the reasons listed above, the Court finds good
+cause shown to postpone the subject deposition until such time as
+is discharged
+from the hospital and/or any nursing home/rehabilitation hospital she may be admitted to.
+In this regard, the Court holds Plaintiff's attorney to the assertion made in the Motion that
+4
+
+
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 5 of 6
+he will keep counsel for Defendant informed as to Plaintiff's expected discharge date in
+order to facilitate the rescheduling of her deposition.
+On the subject of deposition scheduling, the Court frowns on the unilateral
+scheduling of depositions and asks that, before any depositions are unilaterally set,
+attempts first be made to reach agreement with opposing counsel on deposition
+dates and times. Based on the Motion filed, it appears the dispute herein could have
+been amicably resolved between the parties by a simple phone call and without the
+need for court intervention. This said, the Court recognizes that a ruling has been
+made on the subject Motion without the benefit of a response by Defendant and
+allows that there may be, and often is, another side of the story. Suffice it to say that
+in this case, with its multitude of Plaintiffs and numerous claims, it is as important as
+ever that all counsel conduct themselves in a responsible and professional manner,
+mindful of the ethical obligations imposed upon all members of the Bar and attempt,
+wherever possible, to cooperate on matters of procedure and scheduling.
+In summary, all counsel are hereby put on notice that the Court can ill afford
+to waste its resources supervising the discovery process, a process that is intended
+to operate without judicial intervention. Hunter's Ridge Golf Co. v. Georgia-Pacific
+Corp., 233 F.R.D. 678, 680 (M.D. Fla. 2006)("Discovery is intended to operate with
+minimal judicial supervision unless a dispute arises and one of the parties files a
+motion requiring judicial intervention"); Nevin v. CSX Transp.., 2003 WL 22005030,
+*2 (M.D. Fla. 2003) ("discovery is intended to operate with minimal judicial
+supervision...."); U.S. v. Pepper's Steel & Alloys, Inc., 132 F.R.D. 695, 696 (S.D.
+5
+
+
+Case 9:08-cv-80119-KAM Document 261 Entered on FLSD Docket 08/11/2009 Page 6 of 6
+Fla. 1990)(reminding the parties that "discovery should be conducted
+extrajudicially"); Knight v. Docu-Fax, Inc., 838 F.Supp. 1579, 1581 (N.D. Ga.
+1993)("[the Federal Rules of Civil Procedure] contemplate that discovery be
+conducted with a minimum of judicial intervention"). The Court will, of course, issue
+appropriate rulings with regard to discovery disputes that cannot, after ardent good
+faith efforts, be resolved by the parties themselves. With the same ease, the Court
+will not hesitate to award costs or other sanctions against either party or their
+attorney if these disputes are being used to gain a tactical advantage or for other
+improper purpose. In accordance with the above and foregoing, it is hereby
+ORDERED AND ADJUDGED that Plaintiff's Emergency Motion for Protective
+Order Regarding the Taking of her Deposition (D.E. #259) is GRANTED in accordance with
+the terms hereof.
+DONE AND ORDERED this August 11, 2009, in
+at West Palm Beach,
+Florida.
+CC:
+Jenne
+Joinson
+LINNEA R. JOHNSON
+UNITED STATES MAGISTRATE JUDGE
+The Honorable Kenneth A. Marra
+All Counsel of Record
\ No newline at end of file
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+}
diff --git a/vision-fixhub/court-01/e66ee1285620f056a5569560328325fdbf45511c1d567e242bd9c2933a788fb1.md b/vision-fixhub/court-01/e66ee1285620f056a5569560328325fdbf45511c1d567e242bd9c2933a788fb1.md
new file mode 100644
index 0000000000000000000000000000000000000000..0eb94d1aedc632690ee8a380db2978d540b20e6c
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+++ b/vision-fixhub/court-01/e66ee1285620f056a5569560328325fdbf45511c1d567e242bd9c2933a788fb1.md
@@ -0,0 +1,115 @@
+Case 9:08-cv-80381-KAM Document 105 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/__
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80381-KAM Document 105 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:08-cv-80381-KAM Document 105 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:08-cv-80381-KAM Document 105 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A.
+A.
+Villafaña
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-
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new file mode 100644
index 0000000000000000000000000000000000000000..dd968aa0b2c0999a1ed87d960a50f542a4da38a2
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8d9b00a737dd3b0ff3ab483ca3e8c38477e1c086ecdab11a30e32b9bbfefed4f",
+  "output_sha256": "dfe8ead6f1e35b5adb7ab4f872f5a413e544bb434fe2b34b57b454d84a030af7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e672427784ee9efa662a8445a6c58ccfb314cad7a11ed2e801d4bdbffbd82a83.md b/vision-fixhub/court-01/e672427784ee9efa662a8445a6c58ccfb314cad7a11ed2e801d4bdbffbd82a83.md
new file mode 100644
index 0000000000000000000000000000000000000000..f6a13ca3ab7c0c432999b774d6d623df5c4bcc78
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@@ -0,0 +1,250 @@
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CV-80802-MARRA/JOHNSON
+JANE DOE NO. 8,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF JANE DOE NO. 8's MEMORANDUM OF LAW IN
+OPPOSITION TO MOTION TO DISMISS PLAINTIFF'S COMPLAINT
+Plaintiff, Jane Doe No. 8, submits this Memorandum of Law in Opposition to Motion to
+Dismiss Plaintiff's Complaint, pursuant to S.D.Fla.L.R. 7.1(C), as follows:
+INTRODUCTION
+As with the related cases in this Court against Defendant Jeffrey Epstein, Plaintiff Jane Doe
+No. 8 alleges that she was the victim of a plan and scheme by Defendant Epstein to lure her to his
+Palm Beach mansion, where he sexually molested her. The Complaint in this case sets forth state
+law claims and a federal law claim under 18 U.S.C. §$2422 and 2255. Defendant relies exclusively
+on the statute of limitations as grounds for dismissal pursuant to Fed.R.Civ.P. 12(b)(6).
+With respect to Plaintiff's state law causes of action for assault and battery, Defendant
+incorrectly applies a four-year statute of limitations. Florida Statute §95.11 is clear that a seven-year
+statute of limitations applies to the state law claims alleged by Plaintiff. As a result, the state law
+cause of action for assault and battery is timely.
+In contending that Plaintiff's federal claim should be dismissed based on the statute of
+- 1-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 2 of 10
+limitations, Defendant wrongly assumes that this claim accrued on the date when Defendant's
+wrongful conduct occurred. Defendant's argument fails to recognize that the "discovery rule" is
+applicable, which provides that an action does not accrue until the Plaintiff knew or should have
+known of both her injuries and their cause. Given the nature of the discovery rule and the factual
+inquiry it necessitates in the context of childhood sexual abuse, Plaintiff's federal claim is not
+susceptible to dismissal on statute of limitations grounds pursuant to Fed.R.Civ.P. 12(b)(6).
+Accordingly, Defendant's Motion to Dismiss should be denied in its entirety.
+ARGUMENT
+I.
+DISMISSAL IS NOT WARRANTED UNDER
+FED.R.CIV.P. 12(b)(6) AS TO ANY OF PLAINTIFF'S CLAIMS
+Defendant moves for dismissal of Counts I and Ill of the Complaint exclusively on grounds
+of statute of limitations, which is an affirmative defense. Such a dismissal "is appropriate only if its
+is apparent from the face of the complaint that the claim is time barred." Tello v
+Witter
+Inc., 410 F.3d 1275, 1288 (11th Cir. 2005) (citation omitted). "This standard for dismissal
+can be met only if the complaint shows the date on which the time-barred claim accrued." Durden v.
+Citicorp Trust Bank, 2008 WL 2098040 *3 (M.D.Fla. 2008) (citing Avco Corp. v. Precision Air
+Parts, Inc.., 676 F.2d 494, 495-96 (11th Cir. 1982)) (emphasis supplied). Accord Del Monte Fresh
+Produce Co. v. Dole Food Co., 136 F.Supp. 2d 1271, 1294 (S.D. Fla. 2001) (Gold, J.) (It]he
+absence of an indication of the date on which Del Monte discovered the alleged misappropriations
+prevents the Court from determining from the face of the complaint at what time Del Monte's
+actions accrued."). It is not apparent from the Complaint in this case that any of Plaintiff's claims
+are time barred. In particular, nowhere does the Complaint allege the date on which any of her
+claims accrued. Therefore, Defendant's Motion to Dismiss must be denied in its entirety.
+- 2-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 3 of 10
+IL.
+COUNT I OF COMPLAINT IS NOT TIME BARRED UNDER THE
+SEVEN-YEAR STATUTE OF LIMITATIONS, FLA. STAT. §95.11(7)
+Count I (assault and battery) and Count II (intentional infliction of emotional distress) allege
+claims under state law.
+. Defendant asserts that Count I should be dismissed because a four-year
+statute of limitations applies to that claim, and it is apparent from the face of the Complaint that
+Plaintiff filed her claim past this limitations period. Defendant recognizes that, for this argument to
+succeed, he must establish that Fla.Stat. §95.11(7), providing a seven-year limitations period after the
+Plaintiff reaches the age of majority for claims based on abuse, is inapplicable in this case. A review
+of the language of the Statute, however, and applying basic tenets of statutory construction, reveal
+that §95.11(7) is clearly the statute of limitations pertinent to Plaintiff's state law claims.
+Section 95.11(7) provides a seven-year limitations period, as follows:
+(7) For intentional torts based on abuse. - An action founded on
+alleged abuse, as defined in s. 39.01, ... may be commenced at any
+time within 7 years after the age of majority, or within 4 years after
+the injured person leaves the dependency of the abuser, or within 4
+years from the time of discovery by the injured party of both the
+injury and the causal relationship between the injury and the abuse.
+whichever occurs later.
+The term "abuse" is defined in Fla.Stat. §39.01(2) as follows:
+"Abuse" means any willful act or threatened act that results in any
+physical, mental or sexual injury or harm that causes or is likely to
+cause the child's physical, mental, or emotional health to be
+significantly impaired.
+The Complaint in this case alleges "abuse" under the broad definition of §39.01. Specifically, Count
+I alleges willful acts (Complaint 99l 8-13, 18-19); resulting in physical, mental or sexual injury
+(Complaint 99l 13,17); that cause or are likely to cause the child's physical, mental or emotional
+' Defendant did not move for dismissal of Count II.
+- 3-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 4 of 10
+health to be significantly impaired (Complaint 19l 14, 20). Under §95.11(7), therefore, the Plaintiff
+has until seven years after she reaches the age of majority to bring suit (i.e. until she is 25 years old),
+or within four years from the time she discovers both the injury and the causal relationship between
+the injury and abuse, whichever occurs later. Accordingly, the statute of limitations cannot expire
+before the Plaintiff's 25th birthday, and her Count I claim is timely under §95.11(7).
+Defendant nonetheless asserts that the pertinent limitations provision is §95.11(3)(o),
+providing a four-year limitation period, not §95.11(7). Section 95.11(3)(o), lists causes of action
+subject to a four-year limitations period, as follows:
+An action for assault, battery, false arrest, malicious prosecution,
+malicious interference, false imprisonment, or any other intentional
+tort, except as provided in subsections (4), (5), and (7).
+(Emphasis supplied). Section 95.11(3)(o), by its express terms, is subject to an exception, as
+provided in § 95.11(7). The plain meaning of this language is that an intentional tort claim alleging
+"abuse" against a child, as described in Fla.Stat. §39.01, is controlled by §95.11(7), which trumps
+$95.11(3)(o). The seven-year limitations period (or four years after discovery) thus applies in this
+case. See H.T.E. v. Tyler Technologies, Inc., 217 F.Supp. 2d 1255, 1259 (M.D. Fla. 2002) (where
+language of a statute is clear and unambiguous, the statute must be given its plain and obvious
+meaning).
+Defendant nonetheless seems to argue that §95.11(3)(o) applies because it expressly
+references the intentional torts of assault and battery, ignoring that the Complaint at issue alleges
+"abuse" as defined in Florida Statute $§95.11(7) and 39.01(2). This is a strained and plainly
+incorrect construction of the language in §$95.11(3)(o) and 95.11(7). Defendant essentially contends
+that only a claim of "abuse" would be controlled by §95.11(7), while other intentional torts would
+- 4-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 5 of 10
+necessarily fall under §95.11(3)(o). However, as one Court has recognized, there is no Florida cause
+of action for abuse, and §95.11(7) did not create one. Zlotogura v. Geller, 681 So.2d 778 (Fla. 3d
+DCA 1996). Accordingly, if §95.11(7) is to have any meaning, it necessarily must encompass claims
+of assault and battery and other intentional torts involving "abuse" upon a child as defined in
+$39.01(2).
+Even assuming that §§95.11(3)(o) and 95.11(7) were ambiguous, it is a basic rule of statutory
+construction that two sections are to be read in para materia, such that all sections are given effect
+and are read as a consistent whole. H.T.E., 217 F.Supp. 2d at 1259. Doing so in this case compels
+the conclusion that the seven-year limitation of §95.11(7) applies to Plaintiff's Count I claim.
+Defendant's Motion to Dismiss Count I must accordingly be denied
+IIIN THE COMPLAINT DOES NOT SHOW ON ITS FACE
+THAT PLAINTIFF'S COUNT III CLAIM IS TIME BARRED
+Count III of the Complaint alleges a claim of coercion and enticement to sexual activity
+against a minor in violation of 18 U.S.C. $2422. A victim who suffers personal injuries as a result of
+a violation of this statutory provision is granted a private right of action under 18 U.S.C. §2255. A
+limitations provision is included on this statute at subsection (b), which provides that a claim is
+barred unless it is brought "within six years after the rights of action first accrues or in the case of a
+person under a legal disability, not later than three years after disability."? The pertinent issue, then,
+for purposes of this statute of limitations, where the victim is over the age of 21, is when the action
+accrued. Defendant Epstein assumes in his Motion to Dismiss that the action accrued on the date
+" Under Florida law, a person is under a disability as a minor until age 18. See Fla. Stat. $743.07.
+- 5-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 6 of 10
+when Epstein's sexual misconduct occurred.? That assumption is incorrect under federal law and the
+allegations of the Complaint.
+A claim does not necessarily accrue when the wrongful conduct occurs. Rather, the
+"discovery rule" applies to accrual of federal causes of action. See
+v. Mercury Marine, 129
+F.3d 1428, 1435 (1 1th Cir. 1997) (noting that use of word "accrue" indicated approval of discovery
+rule in statute of limitations in accordance with federal precedents adopting discovery rule). Under
+this rule, an action accrues "when the plaintiff knew or should have known of his injury and its
+cause."* Id. (emphasis supplied). See also Lavellee v. Listi, 611 F.2d 1129, 1131 (5th Cir. 1980) (in
+a case analyzing accrual under federal law for a civil rights claims under 42 U.S.C. §1983, noting
+that the Supreme Court in United States v. Kubrick, 444 U.S. 111, 100 S.Ct. 352 (1979), "has
+rejected the standard which would allow the statute of limitations to commence running before the
+plaintiff was or should have been aware of the causal connection between his injury and the acts of
+defendants") (emphasis supplied). Accord |
+v. United States, 165 F.3d 1337, 1340 (11th Cir.
+1999) (in wrongful death case under Federal Tort Claims Act (FTCA), holding that claim accrues
+when the plaintiff knows or should have known both of the decedent's death and its causal
+connection to the government); Stoleson v. United States, 629 F.2d 1265, 1270-71(7th Cir. 1980)
+3 The Motion to Dismiss asserts that "it has been at least 8 years since the alleged conduct by
+EPSTEIN, well past the six year statute of limitations, thus requiring dismissal of Count III."
+(Motion to Dismiss, p. 4).
+4 The case of
+v. Husband, 376 F.Supp. 2d 603 (E.D. Va. 2005) is inapposite. While that case
+was brought under 18 U.S.C. §2255 for a violation of 18 U.S.C. §2251, alleging sexual exploitation
+of a minor for the purpose of producing a sexually explicit videotape, the plaintiff did not argue the
+discovery rule. Rather, the plaintiff contended that the continuing violation rule applied to toll the
+statute of limitations, which the Court rejected. As a result, the Court never considered application
+of the discovery rule.
+- 6-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 7 of 10
+(holding that claim under FTCA did not accrue until the plaintiff had knowledge of a causal
+connection "to tie together" the breach of duty and her injury); Skwira v. United States, 344 F.3d 64,
+76-83 (Ist Cir. 2003), cert. denied, 542 U.S. 903 (2004) (holding that discovery rule, requiring that
+accrual does not occur before the plaintiff knew or should have known of injury and its causal
+connection to the defendant, applies outside the medical malpractice context).
+In a case where a minor is sexually abused, or wrongfully enticed or coerced into sexual
+activity by an adult, the victim is unlikely in the exercise of reasonable diligence to be (i)
+immediately aware of her injuries given the subtle and pernicious effects of childhood sexual abuse;
+or (ii) able to connect those injuries to the defendant's misconduct. See Doe v. Paukstat, 863
+F.Supp. 884, 890-91 (E.D. Wis. 1994) (noting that application of discovery rule in case of childhood
+sexual abuse is "amorphous", and holding that when cause of action for abuse accrues is a question
+for the trier-of-fact); cf. R.L. v. Voytac, 971 A.2d 1074 (N.J. 2009) (holding that "it is necessary to
+consider all relevant facts and circumstances", including expert psychological testimony, in applying
+discovery rule to claim of childhood sexual abuse, and that the issue is "when the injured party in
+fact discovered, or when a reasonable person subjected to child sexual abuse should have discovered,
+that the claimed injury was causally related to the asserted child abuse by the defendant"). The
+determination of when the limitations period accrues under the discovery rule, in a case involving the
+defendant's sexual misconduct with a minor, therefore, requires a detailed and complex factual
+inquiry. The date of accrual certainly is not obvious nor is it otherwise alleged in the Plaintiff's
+Complaint.
+As a result, Count Ill cannot be dismissed under Fed.R.Civ.P. 12(b)(6) on the basis of
+' As discussed in §I above, dismissal under Fed.R.Civ.P. 12(b)(6) on statute of limitations grounds is
+only appropriate when the date of accrual is alleged in the complaint itself.
+- 7-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 8 of 10
+the statute of limitations.®
+CONCLUSION
+Based on the foregoing, Plaintiff respectfully requests that Defendant's Motion to Dismiss be
+denied in its entirety.
+Dated: August 12, 2009.
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff Jane Doe 8
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+"It would also be inappropriate to dismiss this case on limitations grounds because Defendant has
+argued in one of the related cases that 18 U.S.C. §2255 requires a prior federal conviction. (See Jane
+Doe 101 v. Epstein, case no. 09-CV-80591, Motion to Dismiss First Amended Complaint, p. 15,
+§I|(A), DE 29). If that argument were correct then the Plaintiff's claim in Count II has not yet
+accrued. Defendant should not be heard to whipsaw the Plaintiffs and take such inconsistent
+positions in these related cases.
+- 8-
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 9 of 10
+CERTIFICATE OF SERVICE
+I hereby certify that on August 12, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either vi a transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+- 9 -
+
+
+Case 9:09-cv-80802-KAM Document 13 Entered on FLSD Docket 08/12/2009 Page 10 of 10
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+CASE NO.: 09-CV-80802-MARRA/
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Stuart S. Mermelstein
+- 10 -
diff --git a/vision-fixhub/court-01/e672427784ee9efa662a8445a6c58ccfb314cad7a11ed2e801d4bdbffbd82a83.receipt.json b/vision-fixhub/court-01/e672427784ee9efa662a8445a6c58ccfb314cad7a11ed2e801d4bdbffbd82a83.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7f3f34eb280370a4cab5044a2f12e66a6ba53118
--- /dev/null
+++ b/vision-fixhub/court-01/e672427784ee9efa662a8445a6c58ccfb314cad7a11ed2e801d4bdbffbd82a83.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.md b/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.md
new file mode 100644
index 0000000000000000000000000000000000000000..6cf829e90c71f7588555fe0a56c57eda2ea426a4
--- /dev/null
+++ b/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.md
@@ -0,0 +1,98 @@
+Case 9:08-cv-80380-KAM Document 23
+Entered on FLSD Docket 07/08/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA-
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+EPSTEIN'S REPLY IN SUPPORT OF
+MOTION [DE 11] TO SET ASIDE CLERK'S DEFAULT
+Discovery on service of process would be extraordinary, unnecessary and a
+waste of resources.
+Mr. Barnett's affidavit is dispositive: He was the one who received the
+summons at Epstein's house, but he did not reside there. If the plaintiff had
+offered some evidence (e.g., a phone-book entry, a Google search-result, an
+affidavit, etc.) that Mr. Barnett did reside there, or that some other person, who did
+reside there, received the summons - - and if we were contesting service altogether
+' See Fed. R. Civ. P. 26(d)(1) ("A party may not seek discovery from any source before the
+parties have conferred as required by Rule 26(f), except in a proceeding exempted from initial
+disclosure under Rule 26(a)(1)(B), or when authorized by these rules, by stipulation, or by court
+order.").
+
+
+Case 9:08-cv-80380-KAM Document 23 Entered on FLSD Docket 07/08/2008 Page 2 of 5
+- - perhaps discovery would be appropriate. Instead, the plaintiff ventures a
+guess (unsupported by affidavit or other evidence) that Mr. Epstein "instructed
+[Barnett] to answer the door on May 7, 2008 and take service anonymously" (DE
+16 at 2).
+Such rank speculation is insufficient to warrant "pre-discovery discovery"
+on service of process. To conclude otherwise would create a rule that any plaintiff
+who could not identify the person who answered the door would be entitled to prediscovery discovery. Cf. Patterson v.
+No. 3:06cv476, 2008 WL 219965, at
+*8 (W.D.N.C. Jan. 24, 2008) (refusing discovery where information sought was
+irrelevant to the issue of whether service of process was valid); Centennial LLC v.
+Becker, No. Civ.A. 3:97-CV-1126, 2000 WL 35508748, at *5 n.2 (D.S.C. Nov. 14,
+2000) (stating that "Plaintiff's speculation, grounded in nothing but a 'hunch' or a
+prayer, is simply insufficient to thwart the court's finding [based on the
+defendant's uncontroverted sworn statement]," and adding that "PlaintiffI, instead
+of] provid[ing an] affidavit" to challenge the defendant's position, put forth an
+"entire argument ... grounded in nothing more substantial than idle and baseless
+speculation").
+As explained in our motion, because Mr. Barnett did not reside at Mr.
+Epstein's house, substitute service on Mr. Barnett was effective only under New
+York rules. They gave Mr. Epstein until June 23 to respond. Mr. Epstein timely
+2
+
+
+Case 9:08-cv-80380-KAM Document 23 Entered on FLSD Docket 07/08/2008 Page 3 of 5
+responded on June 20, by filing a motion to stay (DE 13). Accordingly, he is not
+in default and the clerk's default should be set aside.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By: Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By: Is/ Jack A. Goldberger
+Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+3
+
+
+Case 9:08-cv-80380-KAM Document 23 Entered on FLSD Docket 07/08/2008 Page 4 of 5
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 7, 2008, I electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that
+the foregoing document is being served this day on all counsel of record identified
+on the following service list via transmission of Notices of Electronic Filing
+generated by CM/ECF.
+/s/ Michael R. Tein
+Michael R. Tein
+4
+
+
+Case 9:08-cv-80380-KAM Document 23 Entered on FLSD Docket 07/08/2008 Page 5 of 5
+SERVICE LIST
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+HERMAN & MERMELSTEIN, P.A.
+182 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+5
diff --git a/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.receipt.json b/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..be3b6c689fbaf97a3a25ce77375e195bdfae7e32
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+++ b/vision-fixhub/court-01/e67fae9abba634f3647e7d5abaae10ffe00b60e9aa3a68a5873b31626252549a.receipt.json
@@ -0,0 +1,14 @@
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+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "7246da32d80a7d730bc9b3129cc1f79c8ed3a5e55b2a5fbb546ba0c8e45e73dc",
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+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/e68b07ab24767e18c104b0a42f07d31d7e604779ee2fa56fa0ef764c0b651f1b.md b/vision-fixhub/court-01/e68b07ab24767e18c104b0a42f07d31d7e604779ee2fa56fa0ef764c0b651f1b.md
new file mode 100644
index 0000000000000000000000000000000000000000..cd192987229a0e1ce347280063cbd0e614980fdd
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+++ b/vision-fixhub/court-01/e68b07ab24767e18c104b0a42f07d31d7e604779ee2fa56fa0ef764c0b651f1b.md
@@ -0,0 +1,121 @@
+Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT's MOTION FOR EXTENSION OF TIME IN WHICH TO RESPOND TO
+PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+respond to Plaintiff's Second Amended Complaint dated February 27, 2009. Local
+General Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P. (2009). Defendant seeks an extension
+until April 3, 2009, to file his response. As good cause in support of granting the motion,
+Defendant states:
+1. Defendant's response to the Second Amended Complaint would be due on
+March 11, 2009 (10 days to respond, not including weekend).
+2. Plaintiff's counsel also represents five (5) other Plaintiffs pursuing claims against
+Defendant, EPSTEIN. All Plaintiffs have also filed amended complaints bearing the
+same dates. In order to fully and adequately respond to this and the other complaints,
+Defendant is in need of an extension until April 3, 2009.
+3. In addition to the multiple amended complaints, good cause for the extension
+also includes that counsel has been attempting to resolve discovery issues in this and
+
+
+Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 2 of 4
+Jane Doe No. 2 v. Epstein
+Page 2
+other cases against Defendant, EPSTEIN; an associate of Defendant's undersigned
+counsel who works extensively on this case was out of the office for two weeks during
+the month February caring for two of her children who had the flu, and the associate
+herself also caught the flu; Defendant's counsel is also in the midst of preparing for two
+state court trials - one on a March trial docket and the other specially set in mid-May,
+(OLD MARSH GOLF CLUB, INC. v. OLD MARSH PARTNERS, et al, Case No. 50
+2006CA001667XXXXMBAD - set on trial docket beginning March 16, 2009;
+CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A v.
+, M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+through 15, 2009). Discovery in both of these cases is ongoing with several depositions
+set to prepare for trial.
+4. The requested extension is fair in reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately respond to this
+and the other amended complaints. In addition, this action is still at its early stages.
+5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
+Plaintiff's counsel is in agreement with the requested extension.
+WHEREFORE, Defendant requests that this Court enter an order granting an
+Defendant an extension until April 3, 2009, in which to respond to the Second Amended
+Complaint.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and
+Counsel for Plaintiff is in agreement with the requested extension until April 3, 2009 for
+
+
+Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 3 of 4
+Jane Doe No. 2 v. Epstein
+Page 3
+Defendant to respond to the Second Amended Complaint.
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+erved this day on all counsel of recorg identified on the following Service List in th
+anner specified by CM/ECF on this fEday of March, 2009
+Stuart S. Mermelstein, Esq.
+Jack Alan Goldberger
+Adam D. Horowitz, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Mermelstein & Horowitz, P.A.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Respectfully submitted,
+ROBERT D/CRITTON, JR., ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 58 Entered on FLSD Docket 03/04/2009 Page 4 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+ORDER ON DEFENDANT'S MOTION FOR EXTENSION OF TIME IN WHICH TO
+RESPOND TO SECOND AMENDED COMPLAINT
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+For Extension of Time In Which to Respond to Second Amended Complaint. Having
+considered Defendant's motion and Plaintiff's counsel being in agreement with the
+requested extension, it is HEREBY ORDERED and ADJUDGED that:
+Defendant's motion is GRANTED. Defendant shall respond to the Second
+Amended Complaint on or before April 3, 2009.
+DONE and ORDERED this
+_day of
+_. 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record
diff --git a/vision-fixhub/court-01/e68b07ab24767e18c104b0a42f07d31d7e604779ee2fa56fa0ef764c0b651f1b.receipt.json b/vision-fixhub/court-01/e68b07ab24767e18c104b0a42f07d31d7e604779ee2fa56fa0ef764c0b651f1b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2fcee778147fa23da1780e9e788b96027941f7c3
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/e6ee70b7a6b199b9bcd0160a0e8f3a2485d07dcfd433c23b663e133de1ebde9d.md b/vision-fixhub/court-01/e6ee70b7a6b199b9bcd0160a0e8f3a2485d07dcfd433c23b663e133de1ebde9d.md
new file mode 100644
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@@ -0,0 +1,216 @@
+Case 9:08-cv-80119-KAM Document 547-1 Entered on FLSD Docket 05/17/2010 Page 1 of 4
+CASE NO: 08-CV-80119-MARRA
+Notice of Supplemental Authority on Plaintiff Jane Doe's Motion for an Order to Show
+Cause and for an Order to Compel and Incorporated Memorandum of Law [DE 138]
+
+
+
+Case 9:08-cV-80119-KAM Document 547-1 Entered on FLSD Docket 05/17/2010 Page 2 of 4
+" Dificer's Name:
+For Month Ending:
+STATE OF FLORIDA
+DEPARTMENT OF CORRECTIONS
+Date/Time submitted:
+WRITTEN MONTHLY REPORT
+OUR NAME
+c#: W2575
+Jeffrey Epstein
+EMPLOYER: FSF
+SUPERVISOR'S NAME:Darren Indyke.
+YOUR RESIDENCE ADDRESS: (include Name of
+Subdivision, Apartment Complex and Number,
+Mobile Home Park and Lot Number, if applicable):
+250 5. Australian Ave Suite 1404
+West Palm Beadh, EL 33401
+358 El Brillo Way
+EMPLOYER'S TELEPHONE No. 3Ldo 0084
+Palm Beach, FL 33480
+CELLULAR TELEPHONE No..
+(Provide physical location - NOT Post Office Box)
+TELEPHONE No. 562-655-7626
+PAGER No.
+EMPLOYER EMAIL:
+CELLULAR TELEPHONE N561 6001 4569
+YOUR TOTAL MONEY EARNED MONTHLY:
+$ 10K +
+(Gross Amount)
+PAGER No.
+Full time X
+Part-time _
+Hours Worked
+Vehicle Make/Model/Year/Tag #:
+Additional (2"°) employment information:
+List full names, ages, and your relationship to all persons who resided at your residence during this month:
+26-63
+- TH-31 - VC-55, NADIO MAraMKiA-25
+R.A, Z6:
+STAH
+YES
+rave you consumed alcoholic beverages?
+Have you used or bought illegal drugs or controlled substances?
+Have you attended educational, vocational classes or mental
+health, drug, alcohol, therapy, or self-improvement programs?
+(If yes, circle which one)
+Have you been arrested or had any contact with law enforcement during the last month?
+If yes, explain what happened on separate sheet of paper, attached to report.
+If you went into debt for any reason, explain:
+If not working, give reason and source of income:
+If you have any questions or problems to discuss with your Officer, explain:_
+If monetary obligation owed, amount paid this month:
+$.
+Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL CHECKS!
+Make money order payable to the Department of Corrections.
+If monetary obligation owed and no payment made, give reason and date when payment will be made:
+Signature of Officer Receive-yon
+Date WMR Received:
+Date WMR Due:
+Comments:
+JAN 05 2010-
+15-4
+I certify the above to be true and complete:
+Your Signature:
+Mailing Address:
+City:
+State:
+E-Mail Address:
+(if applicable)
+Zip:
+ba as Gone
+
+
+Case 9:08-cv-80119-KAM Document 547-1 Entered on FLSD Docket 05/17/2010 Page 3 of 4
+Officer's Name:
+STATE OF FLORIDA
+DEPARTMENT OF CORRECTIONS
+WRITTEN MONTHLY REPORT
+For Month Ending:
+Date/Time submitted:
+YOUR RESIDENCE ADDRESS: (include Name of
+Subdivision, Apartment Complex and Number,
+obile Home Park and i Number, if applicable
+58 HAr
+Pala Bend FLORiUM
+(Provide physical location - NOT Post Office Box)
+TELEPHONE No: 561-655-7621
+CELLULAR TELEPHONE NO. 171-601-4012
+PAGER No.
+Vehicle Make/Model/Year/Tag #: -
+EMPLOYER:
+FF
+SUPERVISOR'S NAME: Is/
+EMPLOYER'S ADDRESS:
+Palm Bal 334K0:
+EMPLOYER'S TELEPHONE No. 360-0084
+CELLULAR TELEPHONE No.
+PAGER No.
+EMPLOYER EMAIL:
+YOUR TOTAL MONEY EARNED MONTHLY:
+(Gross Amount)
+Full time X
+Part-time _
+Hours Worked
+Additional (2) employment information:
+List full names, ages, and your relationship to all persons who resided at your residence during this month:
+A1: 27 24
+Have you consumed alcoholic beverages?
+Have you used or bought illegal drugs or controlled substances?
+Have you attended educational, vocational classes or mental
+health, drug, alcohol, therapy, or self-improvement programs?
+(If yes, circle which one)
+Have you been arrested or had any contact with law enforcement during the last month?
+If yes, explain what happened on separate sheet of paper, attached to report.
+If you went into debt for any reason, explain: _
+If not working, give reason and source of income: _
+If you have any questions or problems to discuss with your Officer, explain:.
+YES
+If monetary obligation owed, amount paid this month: $
+Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL CHECKS!
+Make money order payable to the Department of Corrections.
+If monetary obligation owed and no payment made, give reason and date when payment will be made:
+Official Use Only:
+Signature of Officer Receiving Report:
+Date WMR Received:
+Date WMR Due:
+Comments:
+P.
+I certify the above to be true and complete:
+Your Signature:
+Mailingddress: 30Y ce
+City: du Ben FL
+State:_FL
+_ Zip: 3748°
+EMail Address: Jeevorsgulen.
+(if applicable)
+
+
+Case 9:08-CV-80119-KAM Document 547-1 Entered on FLSD Docket 05/17/2010 Page 4,of 4
+ficer's Name: WHN
+STATE OF FLORIDA
+For Month Ending:
+DEPARTMENT OF CORRECTIONS
+Date/Time submitted:
+WRITTEN MONTHLY REPORT
+YOU
+DCH:N35755
+Jettrey Epstein
+EMPLOYER: ESE
+YOUR RESIDENCE ADDRESS: (include Name of
+SUPERVISOR'S NAME: JUDya
+Subdivision, Apartment Complex and Number,
+EMPLOYER'S ADDRESS:
+Mai Borro Nab
+k and Lot Number, if applicable):
+250S. AustralianAve. Suite 1404
+Palm Beach, FL 83485
+West Palm Beach, FL 33401
+EMPLOYER'S TELEPHONE No. 34060084
+(Provide physical location - NOT Post Office Box)
+CELLULAR TELEPHONE No..
+TELEPHONE No. 655-7626
+PAGER No.
+EMPLOYER EMAIL:
+CELLULAR TELEPHONE No. 60| -4569
+YOUR TOTAL MONEY EARNED MONTHLY:
+(Gross Amount)
+PAGER No. -
+Full time_X Part-time _
+Hours Worked
+Vehicle Make/Model/Year/Tag #:
+Additional (2) employment information:
+List full names, ages, and your relationship to all persons who resided at your residence during this month:
+SIt - 31 Front,
+ZG- Fril 22. J.LB-65, DI. Leuzu F
+YES
+NO
+lave you consumed alcoholic beverages?
+Have you used or bought illegal drugs or controlled substances?
+Have you attended educational, vocational classes or mental
+health, drug, alcohol, therapy, or self-improvement programs?
+(If yes, circle which one)
+Have you been arrested or had any contact with law enforcement during the last month?
+If yes, explain what happened on separate sheet of paper, attached to report.
+If you went into debt for any reason, explain: _
+If not working, give reason and source of income:_
+If you have any questions or problems to discuss with your Officer, explain:
+-
+If monetary obligation owed, amount paid this month: $_
+Receipts are available through your probation officer. DO NOT SUBMIT CASH OR PERSONAL CHECKS!
+Make money order payable to the Department of Corrections.
+If monetary obligation owed and no payment made, give reason and date when payment will be made:
+Official Use Only:
+Signature of Officer Receiving Report:
+Date WMR Received:
+Date WMR Due:
+Comments:
+1035AM
+3/1l10
+I certify the above to be true and complete:
+Your Signature:
+Mailing Address:
+15
+Bill
+City: PP
+State: H
+Zip: 23780
+E-Mail Address:
+(f applicable)
diff --git a/vision-fixhub/court-01/e6ee70b7a6b199b9bcd0160a0e8f3a2485d07dcfd433c23b663e133de1ebde9d.receipt.json b/vision-fixhub/court-01/e6ee70b7a6b199b9bcd0160a0e8f3a2485d07dcfd433c23b663e133de1ebde9d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..de77ca5bdfad451d24bd853e6370725cec29ab80
--- /dev/null
+++ b/vision-fixhub/court-01/e6ee70b7a6b199b9bcd0160a0e8f3a2485d07dcfd433c23b663e133de1ebde9d.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "da5454dc248554e46924471827ab086bf1b9393f28b96034ae551b645af09ff7",
+  "output_sha256": "2cee9db6b399445f2890be13a4e7963b5a113b9097b8bb021ba9d9027566a658",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.md b/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.md
new file mode 100644
index 0000000000000000000000000000000000000000..38a1000b6f10af61086def9d14a12fafb4c67605
--- /dev/null
+++ b/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.md
@@ -0,0 +1,274 @@
+Case 9:08-cv-80119-KAM Document 148-1
+Entered on FLSD Docket 06/09/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his First Amended Answer to Plaintiff's Second Amended
+Complaint [DE 56] and states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "[ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 2 of 10
+Jane Doe No. 2 V. Epstein
+Page 2
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+3. As to the allegations in paragraph 3, deny.
+4. As to the allegations in paragraph 4, deny.
+5. As to the allegations in paragraph 5, without knowledge and deny.
+6. As to the allegations in paragraphs 6, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "i]t would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+'... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 3 of 10
+Page 3
+7. As to the allegations in paragraphs 7 through 14 of Plaintiff's Second Amended
+Complaint, Defendant exercises his Fifth Amendment Privilege against selfincrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA
+1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "fit would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed. Prac. &
+Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "….. a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 15, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 16 through 21 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 4 of 10
+Page 4
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "[ilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("....court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+10. In response to the allegations of paragraph 22, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+11. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 23 through 27 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "[ilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 5 of 10
+Page 5
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "…. a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 28, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 29 through 34 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "Tilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against self-
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 6 of 10
+Page 6
+incrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+WHEREFORE, Defendant requests that this Court deny the relief sought by Plaintiff.
+Affirmative Defenses
+1. As to all counts, Plaintiff actually consented to and was a willing participant in the
+acts alleged, and therefore, her claims are barred, or her damages are required to be
+reduced accordingly.
+2. As to all counts alleged, Plaintiff actually consented to and participated in
+conduct similar and/or identical to the acts alleged with other persons which were the
+sole or contributing cause of Plaintiff's alleged damages.
+3. As to all counts, Plaintiff impliedly consented to the acts alleged by not objecting,
+and therefore, her claims are barred, or her damages are required to be reduced
+accordingly.
+4. As to all counts, Defendant reasonably believed or was told that the Plaintiff had
+attained the age of 18 years old at the time of the alleged acts.
+5. As to all counts, Plaintiff's claims are barred as she said she was 18 years or
+older at the time.
+6. As to all counts, Plaintiff's alleged damages were caused in whole or part by
+events and/or circumstances completely unrelated to the incidents) alleged in the
+complaint.
+7. Plaintiffs claims are barred by the applicable statute of limitations.
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 7 of 10
+Page 7
+8. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the limitations as set forth in §768.72, et seq., Florida Statutes.
+9. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the constitutional limitations and guideposts as set forth in BMW of North
+America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v.
+127 S.Ct. 1057
+(2007); State Farm v.
+123 S.Ct 1513 (2003);
+v. Ligget Group, Inc., 945
+So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the
+United States Constitution and Florida's Constitution, Art. I, §§2 and 9, prohibit the
+imposition of grossly excessive or arbitrary punishments
+10. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," the determination of
+whether or not Defendant is liable for punitive damages is required to be bifurcated from
+a determination of the amount to be imposed.
+11. Plaintiff has failed to state a cause of action for sexual assault and/or battery
+under Count I.
+12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and
+can not show a violation of a predicate act under 18 U.S.C. §2255 (2005).
+13.As to Count III, the version of 18 U.S.C. §2255 in effect at the time of the alleged
+conduct applies, and, thus, the presumptive minimum damages amount should Plaintiff
+prove the elements of such claim is $50,000, and not subject to any multiplier.
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 8 of 10
+Page 8
+14. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, would be in violation of the legal axiom against retroactive application of
+an amended statute, and also in violation of such constitutional principles, including but
+not limited to, the "Ex Post Facto" Clause, U.S. Const. Article I, §9, cl. 3, §10, cl. 1, and
+procedural and substantive due process, U.S. Const. 14" Amend., 5'" Amend. The
+statute in effect during the time of the alleged conduct applies.
+15. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, is prohibited pursuant to the vagueness doctrine and the Rule of Lenity.
+A criminal statute is required to give " fair warning ... in language that the common
+world will understand, of what the law intends to do if a certain line is passed. To make
+the warning fair, so far as possible the line should be clear.' " United States v. Lanier,
+520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United
+States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931)) (omission in original). The
+"three related manifestations of the fair warning requirement" are: (1) the vagueness
+doctrine bars enforcement of a statute which either forbids or requires the doing of an
+act in terms so vague that men of common intelligence must necessarily guess at its
+meaning and differ as to its application; (2) the canon of strict construction of criminal
+statutes, or rule of lenity, ensures fair warning by so resolving ambiguity in a criminal
+statute as to apply it only to conduct clearly covered; (3) due process bars courts from
+applying a novel construction of a criminal statute to conduct that neither the statute nor
+any prior judicial decision has fairly disclosed to be within its scope.
+
+
+Case 9:08-cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 9 of 10
+Page 9
+16. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+17. Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without
+subject matter jurisdiction as to all claims asserted.
+18. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+19. 18 U.S.C. §2255 violates the Equal Protection Clause of the 14" Amendment
+under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred.
+20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life, liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+
+
+Case 9:08-Cv-80119-KAM Document 148-1 Entered on FLSD Docket 06/09/2009 Page 10 of
+Page 10
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this _ day of
+_, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.receipt.json b/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..10a7bedb7e49eba31cd8743d5920066cfffb568c
--- /dev/null
+++ b/vision-fixhub/court-01/e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "e6ef534b13ad0df97fdf6a67bcdddf1fa805a1f23400f958be925feebecb3f9c",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "ac9fb7f73d6b072059ed76f892d67167ab8d262ab58305263f78140851cfdc01",
+  "output_sha256": "7c5f3c50cf7c68f663e5211f99d632d9cb609b87f18a586edb1987da734596b2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.md b/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.md
new file mode 100644
index 0000000000000000000000000000000000000000..bdf41e29619c964d7bc94314b43d81ed892a8603
--- /dev/null
+++ b/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.md
@@ -0,0 +1,118 @@
+Case 1:20-cv-00484-JGK-DCF Document 31
+Filed 03/30/20 Page 1 of 5
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+Case No. 1:20-ev-00484 (JGK) (DCF)
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the
+ESTATE OF JEFFREY EDWARD EPSTEIN and
+GHISLAINE MAXWELL, an individual,
+Defendants.
+JOINT STIPULATION FOR ORDER ON
+PLAINTIFF'S MOTION TO PROCEED BY PSEUDONYM
+Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein (together, the "Co-Executors"), jointly with Plaintiff Jane Doe ("Plaintiff"), through
+counsel for the Co-Executors, respectfully submit this stipulation (the "Stipulation") together with
+the attached Proposed Order on Plaintiff's Motion For Leave to Proceed By Pseudonym (the
+"Proposed Order") and accompanying Non-Disclosure Agreement (the "NDA").
+The parties respectfully request the Court enter the Proposed Order and NDA to resolve
+Plaintiff's Motion For Leave to Proceed By Pseudonym (ECF #5).
+
+
+Case 1:20-cv-00484-JGK-DCF Document 31 Filed 03/30/20
+
+Dated: March 30, 2020
+New York, New York
+Respectfully submitted,
+TROUTMAN SANDERS LLP
+By:/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+875 Third Avenue
+New York, NY 10022
+(212) 704-6000
+bennet.moskowitz@troutman.com
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+PANISH, SHEA & BOYLE LLP
+By:/s/ Robert S. Glassman [with permission]
+Robert S. Glassman
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+(310) 477-1700
+glassman@psblaw.com
+Attorneys for Plaintiff Jane Doe
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 31 Filed 03/30/20 Page 3 of 5
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+Case No. 1:20-ev-00484 (JGK) (DCF)
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the
+ESTATE OF JEFFREY EDWARD EPSTEIN and
+GHISLAINE MAXWELL, an individual,
+Defendants.
+ORDER ON PLAINTIFF'S ANONYMITY
+IT IS HEREBY ORDERED that any person subject to this Order, including the parties to
+this action and their respective counsel of record, shall adhere to the following terms:
+1. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose
+Plaintiff's identity to Counsel of Record for the Co-Executors, in writing.
+2. Counsel of Record for the Co-Executors may disclose Plaintiff's identity only to the Co-
+Executors and any attorneys, paralegals, and clerical or other assistants working with or
+for the Co-Executors on matters related to this action; and the recipients of such
+information shall not disclose it to any other persons.
+3. If the Co-Executors wish to disclose Plaintiff's identity to any person not otherwise
+permitted to receive such information under this Order, the Co-Executors are limited to
+doing so in connection with defending this action, and must require such person to first
+execute a non-disclosure agreement, in a form agreed to by the parties, that prevents such
+person from disclosing Plaintiff's identity to any other persons. The Co-Executors must
+maintain a list of all such persons to whom Plaintiff's identity is disclosed and copies of
+the executed non-disclosure agreements, all of which are subject to in camera inspection.
+4. All portions of pleadings, motions or other papers filed with the Court that disclose
+Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal
+until further order of the Court. The parties shall use their best efforts to minimize such
+sealing. Any party filing a motion or any other papers with the Court under seal shall also
+publicly file a redacted copy of the same, via the Court's Electronic Case Filing system,
+that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 31 Filed 03/30/20 Page 4 of 5
+5. The parties may seek to modify or amend this Order at any time upon motion to the Court
+or by stipulation.
+SO ORDERED.
+Date:
+New York, New York
+Hon. Debra C. Freeman
+United States Magistrate Judge
+Southern District of New York
+4
+
+
+Case 1:20-cv-00484-JGK-DCF Document 31 Filed 03/30/20 Page 5 of 5
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+Case No. 1:20-cv-00484 (JGK) (DCF)
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the
+ESTATE OF JEFFREY EDWARD EPSTEIN and
+GHISLAINE MAXWELL, an individual,
+Defendants.
+NON-DISCLOSURE AGREEMENT
+1,
+-, acknowledge that I understand that the identity of the
+Plaintiff in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff's identity;
+(2) I will use Plaintiff's identity only in connection with this litigation; and (3) I will take all due
+precautions to prevent the unauthorized or inadvertent disclosure of Plaintiff's identity.
+By acknowledging these obligations under this Non-Disclosure Agreement, I understand
+that I am submitting myself to the jurisdiction of the United States District Court for the Southern
+District of New York for the purpose of any issue or dispute arising hereunder, and that my willfu
+violation of any term of the Non-Disclosure Agreement could subject me to punishment for
+contempt of court.
+Dated:
+[Signature]
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.receipt.json b/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..945f677a26d7e05aa2ed700a600d93bfd6aa1b11
--- /dev/null
+++ b/vision-fixhub/court-01/e6f72b15a1645540c7355de88a92535ef4fddcc0f37030a6ab5a2b51ec0f4141.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "cad3e6f4084153ba5d76060706e9ce8bd0e97920d06294c794993c3c3f316b6f",
+  "output_sha256": "32a99923f286944b59040a97403ac1ba4f13cf57f0a48d01411a192a7c8736e6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.md b/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.md
new file mode 100644
index 0000000000000000000000000000000000000000..4f2b7085e4a1446a9ed702e2b8d5593c171e1cfb
--- /dev/null
+++ b/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.md
@@ -0,0 +1,40 @@
+OFFICE OF THE STATE ATTORNEY
+FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY
+DAVE ARONBERG
+STATE ATTORNEY
+September 27, 2019
+Via Electronic Mail: (ipacenti@pbpost.com)
+John Pacenti
+Palm Beach Post
+Ref: Response to Public Records Request - Final Letter
+Our Public Record No.: 19-373
+Thank you for contacting the Office of the State Attorney. Please accept this correspondence as
+our response to your Public Records Request received by our office on August 9, 2019, for a copy
+"1. All closeout documents generated by the Public Corruption Unit from the time of its
+inception to present".
+In response to your request, unfortunately your request is too broad and undefined to constitute a
+record request amenable to production of specific records. This request must be narrowed to case
+numbers, defendant's rames, or other more specific criteria in order to locate responsive documents.
+If you would clarify and specify the precise case or the subject of the investigation you wish to receive,
+we will make every attempt to accommodate you. Public records law does not require an agency to do
+more than provide identified records. In other words, it is this agency's obligation, as a custodian of
+public records, to respond to requests for information as to copying costs and to furnish copies of
+records "when the person requesting them identifies the portions of the record with sufficient
+specificity to permit the custodian to identify the records" and forwards the fee. Woodard v. State, 885
+So. 2d 444, 445-46 (Fla 4th DCA 2004). Florida courts have "consistently held that a defendant must
+plead with specificity the outstanding public records he seeks to obtain." Rodriguez v. State, 919 So.2d
+252, 1273 (Fla.2005); see also Thompson v. State, 759 So.2d 650, 659 (Fla. 2000); Geralds v. State
+11 So. 3d 778, 802 (Fla. 2010), as revised on denial of reh'g (Feb. 2, 2012)
+Sincerely,
+Natalie Cruz.
+Executive Assistant
+Party__JOINT
+-
+ID#. J02 EV#TOZ
+DATEADMITTED: 9/6/2022
+Case No. 2019-CA-914681
+MARIZO CERK
+CAArontar@ODOOM BEACH COUNTY, FL,58SEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
+Joint Exhibit
+J02
diff --git a/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.receipt.json b/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e228d70d9e063a4458895747bf4317864f9abcb2
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+++ b/vision-fixhub/court-01/e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "e700d068672c04e0b59b077c7f2e7edd302c20b2e4e079668c196717d41a8659",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1f0ff91983958a24826caac3290459c7a6f27fef1240412b901ac19a05c40805",
+  "output_sha256": "d2270f412b9d5916b64026dc5ca934bab818857a6ea45cbb58010df1a9ac6234",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e72729ec7ffc2799d658014b07512fb7ba43b0bd10e006a1d512ce32c94aaf2d.md b/vision-fixhub/court-01/e72729ec7ffc2799d658014b07512fb7ba43b0bd10e006a1d512ce32c94aaf2d.md
new file mode 100644
index 0000000000000000000000000000000000000000..a485c2fb0a2dc5c1d6a107e390eca37171683e6d
--- /dev/null
+++ b/vision-fixhub/court-01/e72729ec7ffc2799d658014b07512fb7ba43b0bd10e006a1d512ce32c94aaf2d.md
@@ -0,0 +1,192 @@
+Case 9:08-cv-80119-KAM Document 247-5
+Entered on FLSD Docket 08/05/2009 Page 1 of 8
+Jane Doe #5
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.
+M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+C.W. L M.D., who, being by me first duly sworn under oath deposes and says:
+1. My name is Richard C.W. || M.D. I am over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 1996.
+3. I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Deptof
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns [
+University and
+1
+"E
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #5 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #5 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12.
+She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #5.
+14. Plaintiff reports she went to three different schools in the eighth grade. (Page
+3, GK Contemp note)
+15.
+Plaintiff reports "I have had girls be mean to me and even rumor that they
+would slice my throat when I was younger." (Page 4, GK Contemp note)
+16.
+Plaintiff noted that she had caught her mother and stepfather having sex.
+(Page 7, GK Contemp note)
+3
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 4 of 8
+17.
+18.
+"I got kicked out when I was 18 (by both parents). (Page 7, GK Contemp note)
+Plaintiff noted that her mother suffers from depression/stress. (Page 7, GK
+Contemp note)
+19.
+Plaintiff noted that during her sophomore and junior years of high school she
+drank every weekend and started trying drugs. (Page 7, GK Contemp note)
+20.
+"Her problems began during adolescence." (Page 7, GK Contemp note)
+21. Family psychiatric history includes: a history of a blood relative having been
+sexually abused, plaintiff's mother was physically abused by sisters, and plaintiff's father
+"was very irresponsible as a father figure when I was growing up" and used drugs. (Pages
+7 and 8, GK Contemp note)
+22. Plaintiff noted "My stepfather hit me on a few occasions. But on one
+occasion, I lost hearing in my ear for two weeks." (Page 8, GK Contemp note)
+23. Plaintiff reported that she has been sexually active since age 13 and had 8-10
+partners. (Page 8, GK Contemp note)
+Plaintiff reported that she had been raised by her father between ages 12 to 18
+and that she found her childhood hard to remember, unhappy and painful. (Page 8, GK
+Contemp note)
+25.
+Plaintiff reports that her drug use has included marijuana and pain pills
+without prescription and that on several occasions she has drunk too much alcohol. (Page
+4
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 5 of 8
+9, GK Contemp note)
+26.
+Plaintiff reported that her mother's sisters had paid a male to rape her (the
+mother) in a closet at school. She had been raped three times, twice in childhood and once
+on a date. Also, an uncle raped the mother. (Page 1, GK Follow-up note)
+27. Plaintiff reported having suicidal thoughts in the 9th or 10" grade. (Page 4,
+GK Follow-up note) (Pre-Epstein)
+28.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+29. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+in the case.
+5
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 6 of 8
+30.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning.
+which our input is requested." We request the same.
+31. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+6
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 7 of 8
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+32.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+33. Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+34. Itis, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+and conduct. We would concur and request of the court that the same and such other
+7
+
+
+Case 9:08-cv-80119-KAM Document 247-5 Entered on FLSD Docket 08/05/2009 Page 8 of 8
+similar information be made available to us to conduct our examination.
+Respectfully submitted,
+Richard C. W.
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University ofSouth
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
+8
diff --git a/vision-fixhub/court-01/e72729ec7ffc2799d658014b07512fb7ba43b0bd10e006a1d512ce32c94aaf2d.receipt.json b/vision-fixhub/court-01/e72729ec7ffc2799d658014b07512fb7ba43b0bd10e006a1d512ce32c94aaf2d.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/e73b191d63c4102613d8593b573444048853d0ebe08647f22027d04c0ba4275d.md b/vision-fixhub/court-01/e73b191d63c4102613d8593b573444048853d0ebe08647f22027d04c0ba4275d.md
new file mode 100644
index 0000000000000000000000000000000000000000..a789b402c6f765937ca2160357eb72800610f72d
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@@ -0,0 +1,72 @@
+. Gase 9:08-cv-80232-KAM Document 18
+Entered on FLSD Docket 07/17/2008
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+08 JUL
+FILED BY
+JANE DOE NO. 3,
+Plaintiff,
+12:23
+- D.C.
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+FILED EX PARTE
+UNDER SEAL
+DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL
+
+
+, Case 9:08-cv-80232-KAM Document 18 Entered on FLSD Docket 07/17/2008 Page 2 of 4
+Pursuant to S.D. Fla. L.R. S.4, defendant Jeffrey Epstein hereby moves to
+file his Notice of Continued Pendency of Federal Criminal Action, as well as this
+motion, ex parte and under seal, stating as follows:
+1.
+In support of his motion to stay [DE 8], defendant has herewith filed a
+Notice of Continued Pendency of Federal Criminal Action.
+The Notice relates to a confidential agreement between the United
+States Attorney's Office for the Southern District of Florida and the defendant.
+3.
+The information contained in the Notice is material to this Court's
+consideration of Epstein's motion to stay.
+To avoid disclosure of confidential material, Epstein requests leave to
+file the Notice, and this motion, ex parte and under seal.
+Pending a ruling from this Court, Epstein has not served this motion
+or the Notice on counsel for plaintiff.
+2
+
+
+• Case 9:08-cv-80232-KAM Document 18 Entered on FLSD Docket 07/17/2008 Page 3 of 4
+WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this
+motion and his Notice of Continued Pendency of Federal Criminal Action, ex parte
+and under seal.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101 Fax: 305 442 6744
+By: _
+GUY A
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300 Fax. 561 835 8691
+By: JACK A. GOLDBERGER
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+3
+
+
+• Case 9:08-cv-80232-KAM Document 18 Entered on FLSD Docket 07/17/2008 Page 4 of 4
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that this motion, in accordance with S.D. Fla. L.R.
+5.4, has not been served on opposing counsel and was filed under seal on July 10,
+2008.
+Michael R. Tein
diff --git a/vision-fixhub/court-01/e73b191d63c4102613d8593b573444048853d0ebe08647f22027d04c0ba4275d.receipt.json b/vision-fixhub/court-01/e73b191d63c4102613d8593b573444048853d0ebe08647f22027d04c0ba4275d.receipt.json
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "87b51cc8427957400e3fc136c6ecbefb4568f15ac8cc94abc6d06588e68eeea6",
+  "output_sha256": "634b268cd177208d8ac9bbc8a96c20dcf4013dd576061a28458eeed939a4de62",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
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+Filing # 132529617 E-Filed 08/12/2021 10:20:22 AM
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK. as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+CASE NO.: 2019-CA-014681
+DIVISION:
+AG
+COPY
+AMENDED MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT DAVE
+ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attomey of Palm Beach County, Florida, (the
+"State Attorney"), by and through counsel below, hereby submits the following Amended
+Memorandum of Law in Support of his Amended Motion for Attorneys' Fees, as follows:
+TIMELINE & BACKGROUND
+On November 14, 2019, Plaintiff filed a Complaint against the State Attorney and
+Clerk secking to preate a private right of action under Fla. Siat. $ 905.27, in the interest of
+"furthering justice", to compel disclosure of the testimony, minutes, and other evidence presented
+in 2006 to the Palm Beach County grand jury, as to Jeffrey Epstein, (the "Requested Materials").
+[Def.Ex.A-i].
+On November 26, 2019, the State Attorney and his office received an engagement
+letter and attorney-client contract from the undersigned, which was later executed. [Def.Ex.A-2].
+*** FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK. 08/12/2021 10:20:22 AM ***
+
+
+On December 6, 2019, the State Attorney filed his Motion to Dismiss, which put
+Plaintiff on notice that "Defendant Aronberg is not in custody or control of the [Requested
+Materials] and is therefore not a proper party to this action." [Def.Ex.A-3].
+On January 17, 2020, Plaintiff filed its First Amended Complaint, which in addition
+to its original claim under § 905.27 Fla. Stat., ("Count II"), added a claim for Declaratory Relief,
+("Count I"), that sought an order declaring that the State Attorney and the Clerk disclose and
+release the Requested Materials. [Def.Ex.A-4].
+On January 24, 2020, the State Attorney filed an Answer to Count I of the First
+Amended Complaint and a Motion to Dismiss Count II, which again notified Plaintiff that:
+Defendant Aronberg and the Office of the State Auorney for the Fifteenth Judicial
+Circuit are not in custody or control of the records sought herein, and therefore
+Defendant Aronberg is not a proper party to this action. In fact, Defendant, Sharon
+R. Bock, as Clerk and Comptroller of Palm Beach County, Florida, admits that it
+is the custodian in possession of the documents that are the subject of this action.
+[Def.Ex.A-5, p. 12].
+On June 3, 2020, Chief Judge Marx held a hearing on the State Attorney's and
+Clerk's Motions to Dismiss Count II. [Def.Ex.A-6].
+On June 8, 2020, the Court entered its Order Granting Defendants' Motions to
+Dismiss Count II of Plaintiff's First Amended Complaint with Prejudice, leaving only Plaintiff's
+Count I seeking declaratory relief. [Def.Ex.A-7].
+Immediately thereafter, Plaintiff was served with a demand, pursuant to § 57.105
+Fla. Stat., to voluntarily dismiss/withdraw the First Amended Complaint and the claims against
+the State Attorney, along with a Motion for Attorneys' Fees ("§ 57.105 Demand"). [Def.Ex.A-8].
+2
+
+
+In serving his § 57.105 Demand, the State Attorney properly put Plaintiff on notice
+that he would seek sanctions by filing the § 57.105 Motion for Attorneys' Fees if Plaintiff failed
+to dismiss the remainder of the First Amended Complaint within 21 days.
+10.
+On June 23, 2020, Plaintiff's counsel sent a response to the § 57.105 Demand
+refusing to withdraw the remainder of the First Amended Complaint. [Def.Ex.A-9].
+11.
+After receiving Plaintiff's response and waiting the requisite "21 days after service
+of the motion," the State Attorney's § 57.105 Motion for Attorneys' Fees was filed with the Court
+on July I, 2020, ("First Motion for Attorneys' Fees"). [Def.Ex.A-10]/
+12. On August 18, 2020, the State Attorney filed his Motion for Summary Judgment,
+[Def.Ex.A-11], which includes an Affidavit made by the State Attorney. [Def.Ex.A-12].
+On October 21, 2020, Plaintiff filed its Notice of Dropping the State Attorney,
+pursuant to Rule 1.250(b), Fla.R.Civ.P. [Def.Ex A-13]
+14. On November 9, 2020, the State Attorney filed his Amended Motion for Attorneys'
+Fees, ("'Amended Motion"), pursuant to § 57.105, Fla. Stat.., seeking attorneys' fees in the amount
+of $19,975.00, plus a multiplier of 2. [Def.Ex.A-14].
+I.
+LEGAL STANDARD
+As follows, Florida Statutes § 57.105(1) authorizes awards of attorneys' fees as sanctions:
+(1)
+Upon the court's initiative or motion of any party, the court shall award a
+reasonable attorney's fee, including prejudgment interest, to be paid to the
+prevailing party in equal amounts by the losing party and the losing party's attorney
+on apy claim or defense at any time during a civil proceeding or action in which
+the court finds that the losing party or the losing party's attorney knew or should
+have known that a claim or defense when initially presented to the court or at any
+time before trial:
+(a)
+Was not supported by the material facts necessary to establish the
+claim or defense; or
+(b) Would not be supported by the application of then-existing law to
+those material facts.
+3
+
+
+"Section 57.105 does not require a finding of frivolousness to justify sanctions, but only a
+finding that the claim lacked a basis in fact or law" and "does not require a party to show complete
+absence of a justiciable issue of fact or law." [
+County Conservation Alliance v. |
+County, 73 So. 3d 856, 865 (Fla. Ist DCA 2011) (finding that "Courts are not at liberty to disregard
+the legislative mandate that courts shall impose sanctions in cases without foundation in material
+fact or law. The word "shall" in § 57.105, Fla. Stat., evidences the legislative intent to impose a
+mandatory penalty to discourage baseless claims, by placing a price tag on losing parties who
+engage in these activities. Section 57.105 expressly states courts "shall" assess attorney's fees for
+bringing, or failing to dismiss, baseless claims or defenses.").
+In determining an award of sanctions under § 57.105, the trial court's findings "must be
+based on substantial competent evidence" and the trial court must make an inquiry into what the
+losing party knew or should have known during the fact-establishment process, both before and
+after the suit was filed." See Trust Morig. LLC c, Ferlanti, 193 So. 3d 997 (Fla. 4th DCA 2016).
+II.
+THE STATE ATTORNEY'S AMENDED MOTION IS NEITHER IN VIOLATION
+OF THE 21-DAY SAFE HARBOR PROVISION IN FLA. STAT. § 57.105(4), NOR
+WAS THE AMENDED MOTION MOOT UPON FILING.
+"Section 57.105(4), Florida Statutes creates an opportunity to avoid the sanction of
+attorney's fees by creating a safe period for withdrawal or amendment of meritless allegations and
+claims." Davis v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Specifically, the relevant
+portion of the Statute states:
+A motion by a party seeking sanctions under this section must be served but may
+not be filed with or presented to the court unless, within 21 days after service of the
+motion, the challenged paper, claim, defense, contention, allegation, or denial is not
+withdrawn or appropriately corrected.
+Fla. Stat. § 57.105(4). Likewise, "It]he primary purpose of the safe harbor provision of §
+57.105(4), Fla. Stat., is to provide the recipient of a motion for an award of costs and attorney's
+4
+
+
+fees with notice and the opportunity to withdraw or abandon a frivolous claim before sanctions are
+sought." MC Liberty Express, Inc. v. All Points Servs., 252 So. 3d 397, 404 (Fla. 3d DCA 2018).
+Here, Plaintiff contends that the State Attorney "did not serve his Amended Motion at any
+time before filing it, and thus failed to comply with the 21-day notice provision...." [See, Plaintiff's
+Memorandum of Law in Response to Amended Motion for Attorneys' Fees, p.6.]. Plaintiff claims
+that for this reason the Amended Motion should be denied and cites in support, Lago v. Kame By
+Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013) (holding that "if a party files a subsequent
+or amended motion for sanctions under section 57.105 and raises an argument that was not raised
+in the original motion for section 57.105 sanctions, the subsequent motion must independently
+comply with the twenty-one-day 'safe harbor" provision of Section 57.105(4).").
+The instant case is distinguishable from Lago*. In Lago, because the case was still active
+when the plaintiff's amended motion for attorneys' fees was filed and was not served on the
+defendant in compliance with the 21-day safe harbor provision before it was filed with the court,
+pursuant to § 57.105, the defendant was entitled to notice and an opportunity to change its position
+and withdraw its offending motion before being subject to sanctions.
+Here, despite Plaintiff's decision to drop the State Attorney as a party, the Florida Rules of
+Civil Procedure and the courts of Florida are clear: Because Rule 1.250 specifies that a party is
+dropped "in the manner provided for voluntary dismissal in Rule 1.420(a)(I)," dropping a party
+therefore "operates as an adjudication on the merits." See, Siboni v.
+, 52 So. 3d 779, 781
+(Fla. Sth DCA 2010); Rule 1.420(a)(1) Fla. R. Civ. P. Notably, Plaintiff admits that "the entire
+'Notably, the court in Lago v. Kame By Design, LLC, 120 So. 3d 73, 75 (Fla. 4th DCA 2013),
+despite finding that the plaintiff's amended motion for attorneys' fees was improper, the trial court
+was instructed to rule as to the plaintiff's original motion for attorneys' fees as it was properly
+served and filed pursuant to § 57.105, Fla. Stat.
+5
+
+
+action, which necessarily included Count I [of the First Amended Complaint], was dismissed as to
+[the State Attorney] on October 21, 2020. [See, Plaintiff's Memorandum of Law in Response to
+Amended Motion for Attorneys' Fees, p.7.J. Nonetheless, as a result of dropping the State Attorney
+from the case, Plaintiff not only effectively made an admission that its allegations against the State
+Attorney have no basis in fact or law, but also concluded the case as to the State Attorney and
+thereby became the losing party in this action.
+Consequently, unlike the fact scenario and timeline in Lago, because Plaintiff concluded
+the instant litigation by dropping the State Attorney from the action before the filing of the
+Amended Motion, it was impossible to give Plaintiff an opportunity to respond and withdraw its
+Count I of the First Amended Complaint since Plaintiff had already done so, thus there can be no
+violation of the 21-day safe harbor provision set forth in Fla. Stat. § 57.105(4). Based on the
+foregoing, the State Attorney's Amended Motion does not violate the 21-day safe harbor provision
+because Plaintiff dropped him from the action prior to the filing of the Amended Motion, and
+therefore Plaintiff was not prejudiced by the filing of the Amended Motion. Accordingly, as further
+set forth below, Plaintiff has exposed itself to § 57.105 attorneys' fees as sanctions for failing to
+drop the State Attorney as a party within the 21-day safe harbor period.
+Additionally, there is nothing improper about the First Motion for Attorneys' Fees or the
+Amended Motion and no argument or authority has been offered by Plaintiff that would make the
+Amended Motion moot. In fact, amended motions for attorneys' fees are filed consistently as a
+matter of course to include the entirety of fees in a lawsuit. Here, the State Attorney's total legal
+fees were able to be calculated and submitted at the time of filing the Amended Motion.
+Finally, despite Plaintiff's assertion that "[a] motion for sanctions must be supported by
+the record evidence at the time it is filed" [and] "[bJecause the First Motion was not so supported,
+6
+
+
+it fails under the [S]tatute", Plaintiff has failed to provide any supporting authority and there is no
+statutory requirement or language in § 57.105 that supporting record evidence must exist to
+properly serve a § 57.105 demand and motion for attorneys' fees. [See, Plaintiff's Memorandum
+of Law in Response to Amended Motion for Attorneys' Fees, p.8.]. "The central purpose of §
+57.105, Fla. Stat., is, and always has been, to deter meritless filings and thus streamline the
+administration and procedure of the courts."
+v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th
+DCA 2019). In this vein, a § 57.105 demand and accompanying motion for attorneys' fees can be
+filed at any time after a lawsuit is initiated, even directly in response to the filing of a complaint,
+regardless of whether any record evidence exists in support of the § 57.105 demand.
+Consequently, the foregoing indicates that the State Attorney's First Motion for Attorney's
+Fees, as served and filed, is sufficient under § 57.105 to seek sanctions from Plaintiff for its failure
+to drop the State Attorney from the instant lawsuit within the 21-day safe harbor provision after
+being notified why its First Amended Complaint had no basis in fact or law. Furthermore, as set
+forth at length above, the State Attorney had no obligation to serve his Amended Motion prior to
+filing it with the Court as Plaintiff had already dropped him from the case when it was filed.
+IlL.
+THE COMPETENT SUBSTANTIAL EVIDENCE ON THE RECORD SHOWS
+THAT THERE IS NO ARGUABLE BASIS IN LAW OR FACT FOR THE ISSUES
+RAISED IN PLAINTIFF'S COUNT I, WHICH NOT ONLY LACK A GOOD
+FAITH ARGUMENT FOR THE INTERPRETATION OF EXISTING LAW OR
+ESTABLISHMENT OF A NEW LAW WITH A REASONABLE EXPECTATION
+OF SUCCESS, BUT ALSO ARE NEITHER NOVEL OR COMPLEX.
+Herę, Plaintiff relies on § 57.105(3)(a), which sets forth a scenario where sanctions are
+improper under the Statute:
+3)
+Notwithstanding subsections (I) and (2), monetary sanctions may not be
+awarded:
+(a) Under paragraph (1)(b) if the court determines that the claim or
+defense was initially presented to the court as a good faith argument for the
+extension, modification, or reversal of existing law or the establishment of
+
+
+new law, as it applied to the material facts, with a reasonable expectation
+of success.
+Notably, the § 57.105(3)(a) defense only applies to demands made under § 57.105(1)(b).
+Accordingly, Plaintiff's attempt to prevent an award of sanctions here only applies to whether
+Plaintiff or Plaintiff's attorney "knew or should have known" that the First Amended Complaint
+"when initially presented to the court or at any time before trial... (b) would not be supported by
+the application of then-existing law to those material facts necessary to establish their claim." §
+57.105(1)(b), Fla. Stat.
+Regarding the disclosure of grand jury materials, Florida Statutes § 905.17(1) makes clear
+that there is no arguable basis in law that the State Attorney provide the Requested Materials:
+The notes, records, and transcriptions are confidential and exempt from the
+provisions of s. 119.07(1) and s. 24(a), Art. Lof the State Constitution and shall be
+released by the clerk only on request by a grand jury for use by the grand jury or
+on order of the court pursuant to s. 905.27.
+Florida Statutes § 905.17(1). Based on the clear language of § 905.17(1), Fla. Stat. there can be
+no good faith reasonable expectation of success for the State Attorney to produce and disclose the
+Requested Materials as he lacks the legal authority to obtain and deliver the Requested Materials
+demanded by Plaintiff in Count I of the First Amended Complaint.
+Even if Plaintiff is shielded from § 57.105(I)(b) sanctions based on the § 57.105(3)(a)
+defense, Plaintiff is nonetheless subject to sanctions under § 57.105(1)(a), because Plaintiff or
+Plaintiff's attorneys "knew or should have known" that Count I "when initially presented to the
+court or at any time before trial ... (a) was not supported by the material facts necessary to establish
+the claim." Fla. Stat. § 57.105(1)(a). Specifically, based on Plaintiff's own research, statutory
+constructive notice, the State Attorney's affidavit, all of the pleadings and correspondence in this
+matter as well as through the State Attorney's office press release and social media accounts, and
+8
+
+
+Chief Judge Marx's statements during the June 3, 2020 hearing, Plaintiff and Plaintiff's attorneys
+knew or should have known that Count I of the Amended Complaint was not supported by the
+material facts necessary to establish the claim." See, Fla. Star. § 57.105(1)(a).
+The material facts showing that Plaintiff has no reasonable expectation of success and is
+unable to establish its claim for declaratory relief have been open, obvious, and apparent to
+everyone involved in this matter from the start. The State Attorney's position has been consistent:
+neither he nor his office has possession, custody, or control of the Requested Materials and
+therefore the declaratory relief sought by Plaintiff seeks materials that are impossible for him or
+his office to produce and he is not a proper party to this action. See, Def.Ex.A-12 11 3-4]. Again,
+these material facts negating Plaintiff's declaratory relief claim against the State Attorney were
+not only set forth in the June 8, 2020, § 57.105 Demand Letter, but have been the basis for the
+State Attorney's defense in every pleading, filing, and/or correspondence in this matter.
+Accordingly, Plaintiff knew or should have known that the First Amended Complaint was
+not supported by the material facts necessary to establish the claim for declaratory relief. At the
+very least, Plaintiff should have known that its First Amended Complaint was not supported by
+the material facts after Judge Marx's statements during the June 3, 2020 hearing on Defendant's
+Motion to Dismiss Plaintiff's Count II. During that hearing, Chief Judge Marx drew a bright line
+as to when Plaintiff knew or should have known that Count I of the Amended Complaint had no
+basis in faet or law since the relief sought thereby is impossible for the State Attorney to perform.
+Specifically, Chief Judge Marx made several unequivocal statements on the record putting Plaintiff
+on notice, if they weren't already, that the State Attorney does not have and cannot produce the
+Requested Materials. [Def.Ex.A-6, Pgs. 3:18 - 4:1; 5:17-19; 8:4-22; 10:21 - 11:1; 11:12-15; 16:12
+- 17:3; 17:6-9; 17:23 - 18:2].
+9
+
+
+Additionally, Plaintiff's argument for novelty and complexity fails as to Count I, regardless
+of Plaintiff's reliance on "Constitutional provisions and interpretive case law, along with Fla. Stat.
+§ 905.27"
+... "to propose a good faith interpretation of existing law in support of its declaratory
+relief claim in Count I." [See, Plaintiff's Memorandum of Law in Response to Amended Motion
+for Attorneys' Fees, p.10.]. The simple fact of the matter is that Count I is neither novel or complex
+because Count 1 merely seeks declaratory relief and the State Attorney's lack of possession,
+custody, or control in conjunction with § 905.17(1) creates an impossibility of performance as to
+Count I. Here, § 905.17(1) is abundantly clear that only the Clerk can release grand jury materials
+pursuant to a court order. The record is likewise clear that not only has the State Attorney never
+had possession, custody, or control of the Requested Materials, but he also lacks any legal authority
+to obtain and deliver the Requested Materials.
+Thus, there is no arguable "good faith" basis in law and/or fact as to Plaintiff's Count I.
+Likewise, under no set of facts does Plaintiff have a reasonable expectation of success against the
+State Attorney in obtaining the Requested Materials because he does not have possession, custody,
+or control over them.
+In fact,
+Plaintiff acknowledged, admitted, and acquiesced to the
+impossibility of the State Attorney providing the Requested Materials when he was dropped from
+the action. Consequently, sanctions against Plaintiff are appropriate under § 57.105, Fla. Stat.
+CONCLUSION
+Based on the foregoing, Defendant, Dave Aronberg, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an order granting his Amended Motion for
+Attorneys' Fees as well as such other and further relief as the Court deems just or proper.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+10
+
+
+Arthur I.
+Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw(@comcast.net
+Attorneys for Defendani, Dave Aronberg
+I HEREBY CERTIFY that on this 12th day of August, 2021, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+/st Douglas A. Wyler
+11
+
+
+Def.Ex.A-1
+
+
+** CASE NUMBER: 502019CA014681XXXXMB Div: AG *the
+Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM
+IN THE CIRCUIT COURT, 15th
+JUDICIAL CIRCUIT, IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CASE NO.:
+Publisher of THE PALM BEACH POST
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+'IED COP
+DEFENDANT:
+SUMMONS
+Dave Aronberg, as State Attorney of
+Palm Beach County, Florid
+401 N. Dixie Highwas
+West Palm Beach, Florida 33401
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM
+
+
+THE STATE OF FLORIDA
+TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and
+a copy of the Complaint in this lawsuit on the above named Defendant.
+DATED on November , 2019
+Nov 15 2019
+Sharon R. Bock
+As Clerk & Comptroller of the Court
+By:
+Rela
+Deputy Clerk
+DOLLY
+IMPORTANTE
+Usted ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta
+notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada
+telefonica no lo protegera. Si usted desea que el tribunal considere su defensa, debe presentar su respuesta
+por escrito, incluyendo el numero del caso y los nombres de las partes interesadas. Si usted no contesta la
+demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado
+de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted
+consultar a un abogado inmediatamente. Si no conoce a un abogado, puede llamar a una de las oficinas de
+Si desea responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante
+el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la persona denominada
+abajo como "Plaintiff/Plaintiff's Attorney" (Demandante o Abogado del Demandante).
+IMPORTANT
+Des poursuites judiciares ont eto entréprises contre vous. Vous avez 20 jours consecutifs a partir
+de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce
+tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer
+votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si
+vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse crite dans le
+relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre
+saisis par la suite, sans aucun preavis ulterieur du tribunal. Il y a d'autres obligations juridiques et vous
+pouvez, requerir les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez
+telephoner a un service de reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de
+telephones).
+Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en meme
+temps que cette formalite, faire parvenir ou expedier une copie de votre reponse ecrite au
+"Plaintiff/Plaintiff's Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
+2
+
+
+Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.:
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+COMPLAINT
+CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Complaint against
+Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his official capacity ("State
+Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach County, Florida, in her
+official capacity ("Court Clerk"), alleges as follows:
+JURISDICTION
+This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
+Fla. Stat. Section 26.012(2)(a).
+PARTIES
+2.
+The Palm Beach Post is a daily community newspaper published by Plaintiff CA
+Florida Holdings, LLC, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
+Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth
+Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
+
+
+has authority in grand jury proceedings pursuant to Fla. Stat. section 27.03. He is sued herein in
+his official capacity as his office is in possession of documents that are the subject of this action.
+4.
+Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach
+County, Florida. She is sued herein in her official capacity as her office is in possession of
+documents that are the subject of this action.
+INTRODUCTION
+In what is now widely if belatedly recognized as a colossal miscarriage of justice -
+which led to the further needless victimization of countless young girls and women - a wealthy,
+politically connected, and powerful financier was not held accountable for, nor even forced to
+confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008
+deal with the State of Florida was not consistent with the evidence gathered against him, what
+remains shrouded in mystery is how that evidence was présented - and the extent to which it was
+presented - to the grand jury that returned an indictment far more limited in scope than expected
+and deserved.
+Through this action, The Palm Beach Post seeks public access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled
+during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for
+example, in order to prevent the flight of those whose indictment may be contemplated and their
+ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an
+accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law
+expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
+including, as here, in the furtherance of justice. Fla. Stat. § 905.27(1)(c).
+It can no longer credibly be maintained that continued blanket secrecy over the
+proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.
+2
+
+
+To the contrary, transparency is required to promote public understanding of the criminal justice
+system and public confidence in the fair administration of justice. As detailed below, Epstein was
+accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
+other locations) over a period of several years while exploiting his wealth and political connections
+to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury
+proceedings will shed light on the extent to which those in our government entrusted with the
+solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties
+in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated
+like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
+who chose to give Epstein favorable - "unusual," in the words of the Town of Palm Beach Police
+Chief- treatment, are exposed and held accountable. From what limited information is now in the
+public domain, the State Attorney's referral to the grand jury - which would be out of the ordinary
+for this type of case - gives rise to a strong inference of favoritism and corresponding disregard
+for the rights of the minor victims of Epstein's sex trafficking. Access to the grand jury materials
+will allow the public to determine whether the grand jury process, and the secrecy that comes with
+it, was used to further justice or, instead, operated to shield Epstein and his co-conspirators from
+the consequences of their criminal activities. Accordingly, Fla. Stat. Section 905.27 authorizes the
+disclosure of Epstein's 2006 grand jury proceedings.
+8.
+Even in the absence of such a statutory basis, this Court is empowered to order
+public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
+Indeed, courts throughout the country in the past several decades have ordered the disclosure of
+high-profile grand jury proceedings pursuant to their inherent authority where the public's interest
+in those proceedings has outweighed the general need for secrecy. This is particularly so where,
+3
+
+
+as here, many of the details of Epstein's criminal misdeeds have already been made available in
+the public domain through extensive news reporting by, among others, The Palm Beach Post; by
+the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.
+9.
+In recognition of the sensitivity of the materials being sought, and in the interest of
+protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to
+copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County
+grand jury first being submitted to this Court for in camera review, where they may be redacted,
+as appropriate, to protect those who deserve such protection.
+FACTUAL BACKGROUND
+10.
+The following facts were gathered, in large part, from documents obtained by
+The Palm Beach Post through various Florida Public Records Law requests, documents unsealed
+or publicly available in other related judicial proceedings, and information and documents in the
+public record.
+A.
+First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:
+2005- 2008.
+11. The investigation into Epstein's sex crimes began more than fourteen years ago,
+when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that
+Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
+required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
+$300. Epstein was 52 years old at the time.
+12.
+Following this initial report in 2005, the Town of Palm Beach Police, and later, in
+2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
+seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
+disturbingly similar details, with each of the other victims.
+4
+
+
+13. Both the victim/witness interviews, as well as evidence retrieved following a search
+of Epstein's home, showed that some of the girls involved were under the age of 18. The police
+search of Epstein's residence also found two hidden cameras and, throughout the house, large
+numbers of nude photos of girls, including victims whom the police had not interviewed in the
+course of their investigation.
+14. In March 2006, a State grand jury was scheduled at which all of the victims were
+expected to testify. The proceding was postponed, however, due to meetings between the State
+Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan
+Dershowitz.
+to begin receiving evidence.
+15. Another grand jury was convened in April 2006, but canceled the day before it was
+(1) Police Chief Reiter's Letter to the State Attorney:
+16.
+stating:
+On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
+"personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer,
+I must renew my prior observation to you that I continue to find your office's
+treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to
+communicate in this manner, but my most recent telephone calls to you and those
+of the lead detective to your assigned attorneys have been unanswered and
+disqualification from the prosecution of these cases. (Emphasis supplied)
+17.
+Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach
+Police Department's probable cause affidavits charging Epstein and two of his assistants with
+multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
+
+
+that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
+against him, which would be public.
+(2) The July 2006 State Grand Jury Presentation.
+18. Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
+mandatory for capital cases but rarely used for all other crimes. According to an official
+spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
+Beach County.
+19.
+In July 2006, after State Attorney Krischer presented testimony and evidence from
+one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
+There is no mention in the indictment of the victim being a minor.
+20.
+On information and belief, a second of Epstein's victims was supposed to testify
+before the grand jury, but was unable to attend because of a school exam.
+21.
+No reasonable explanation has been provided as to why the numerous other known
+victims were not presented as witnesses and crime victims to the grand jury convened in July 2006.
+Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
+initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do
+SO.
+22.
+On information and belief, during the grand jury appearance of the single victim
+who testified, the State Attorney presented evidence that vilified the victim and attacked her
+credibility, including soliciting testimony regarding underage drinking and questionable personal
+behavior that was unrelated to the charges against Epstein. Further upon information and belief,
+this information was initially brought to the attention of the State Attorney's office by Epstein's
+defense counsel.
+6
+
+
+(3) The FBI's Investigation and Epstein's Non-Prosecution
+Agreement With Federal Authorities.
+23.
+On information and belief, following the deficient July 2006 indictment, and with
+Chief Reiter's encouragement, the FBI began its own investigation of Epstein.
+24.
+Records unsealed in 2015 revealed that the FBI compiled reports on *34 confirmed
+minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI,
+a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the
+request of Epstein's lawyers, the indictment was never presented to a federal grand jury.
+25.
+Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
+negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with
+four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
+charges.
+26.
+Throughout the remainder of 2007 and through the first half of 2008, Epstein's
+lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
+belief, Epstein's lawyers insisted that (I) the victims not be notified, (2) the deal be kept
+confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
+issued for Epstein's computers) be withdrawn.
+27.
+On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
+prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
+sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
+adjudicated as a convicted sex offender required to register twice a year in Florida.
+28.
+The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to
+receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
+7
+
+
+On information and belief, based on public records, former State Attorney Krischer communicated
+with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.
+29.
+Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
+which he was convicted. Instead, he was placed in a private wing of the Palm Beach County
+Stockade, where, after 3 12 months, he was allowed to leave the jail on "work release" for up to
+12 hours a day, 6 days a week. His private driver provided his transportation to and from "work."
+30. Epstein was released five months early.
+31.
+Upon information and belief, Epstein violated the terms of his probation, but was
+not prosecuted.
+(4) The Crime Victims' Rights Act Litigation.
+32.
+Epstein's victims only learned after the fact about his plea in State court and filed
+an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act
+(18 U.S.C. § 3771, "CVRA"), which mandates certain rights for crime victims, including the right
+to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
+Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
+Epstein's victims before allowing him to plead guilty to only the two State offenses.
+The prosecution's failure to keep the victims apprised, among other things, also
+contravenes the Florida Constitution. Article 1, § 16(b) and Fla. Stat. § 960.001.
+34.
+Following publicity exposing the extraordinary leniency of the plea deal, dozens of
+civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.
+35.
+In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense)
+sex offender in New York, a lifelong designation. In 2011, the New York County District
+Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."
+8
+
+
+36.
+Upon information and belief, during the course of the Town of Palm Beach and FBI
+investigations, Epstein retained private investigators to follow, harass, and photograph his victims
+and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated
+the case against Epstein.
+37. Upon information and belief, Epstein's victims were threatened against cooperating
+with law enforcement and told that they would be compensated only if they did not cooperate with
+law enforcement.
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
+38.
+On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
+39. Upon information and belief, the United States government's investigation of new
+allegations and charges stemmed, in part, from continued press investigations into and reporting
+on the mishandling of the 2006 charges and the civil suits that followed.
+In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
+Southern District of New York, Epstein was described as "a serial sexual predator who preyed on
+dozens of minor girls over a period of years." The letter emphasized that "the Government has real
+concerns - grounded in past experience with this defendant - that if allowed to remain out on bail,
+the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this
+case, including victims and their families, and otherwise attempt to obstruct justice." It also
+described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex
+trafficking in the form of "hundreds - and perhaps thousands - of sexually suggestive photographs
+of fully- or partially-nude females," including underage females. In a locked safe, compact discs
+were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc
+nudes 1," and "Girl pics nude."
+9
+
+
+41. On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's
+office for the Southern District of New York charged Epstein with sex trafficking and conspiracy
+to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were
+brought into Epstein's mansions for sexual encounters. A few days later, owing to public outcry
+over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
+Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump
+administration, resigned from offfice.
+42.
+Epstein was denied bail and was placed into pretrial detention at the federal
+Metropolitan Correction Center in lower Manhattan.
+43.
+On August 10, 2019, Epstein was found dead in his cell at the Metropolitan
+Correctional Center. His cause of death was determined to be suicide.
+C. The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+44.
+On account of his death, prosecutors sought to dismiss the indictment against
+Epstein, while maintaining that they would continue to investigate his co-conspirators.
+United States Senior District Judge Richard M. Berman ordered a hearing on
+August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to
+speak at the hearing.
+46.
+In the course of the hearing, more than two dozen victims delivered their personal
+stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
+violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
+47.
+While some questioned the reasoning behind the court's decision to give the victims
+voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred
+vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings
+promote transparency and they provide the court with insights and information which the court
+10
+
+
+may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that
+the court "is the institution that most people have confidence in, in these very troubled times."
+48.
+At the August 27th hearing, the girls, now women, spoke about their "exploitation
+and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme
+poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
+behalf...." One victim lamented that "as a victim, [she] never got to see what the agreement was
+or why the special treatment got approved" in the Florida case years earlier. Another noted how
+"completely different" the investigators leading to the 2019 federal indictment were from the
+prosecutors in the Florida case, both in their treatment of her and their investigation of her
+victimization by Epstein.
+49.
+A former federal judge in attendance at the August 27th hearing emphasized that
+"transparency is one of the overriding objectives in our criminal justice system."
+50.
+Nearly all of the victims expressed the conviction that the secrecy that shielded
+Epstein has caused them "irreparable harm" and that an opportunity to address his criminal
+wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
+at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts
+made to protect Epstein's name and legacy send a message to the victims that he wins and that he
+is untouchable!" Another victim expressed fear that this is a world "where there are predators in
+power, a world where people can avoid justice if their pockets run deep enough." In short, the
+"unusual" tréatment Epstein received in Florida in 2006 based on his wealth, social status, and
+connections severely eroded the public's faith in the integrity and impartiality of the criminal
+justice system.
+11
+
+
+D.
+The Palm Beach Post's Standing and the Public Interest.
+51.
+Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
+Beach County and the Treasure Coast vicinity.
+52. The Palm Beach Posr has been a Pulitzer Prize winner and nominated as a finalist
+three other times.
+53. Beginning in 2004, The Palm Beach Post has extensively investigated and reported
+on the allegations against, the law enforcement investigation of, and the crimes committed by,
+Epstein and his co-conspirators. The Newspaper's reportage has included publication of the
+following articles:
+• "The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends
+and. Investirators Say, Underage Girls.," published on August 14, 2006, reporting that:
+,, a local community college student, admitted in a sworn statement to
+police that "she had taken at least six girls to visit Epstein, all between the ages of 14
+and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;"
+"Dershowitz, the Harvard law professor, traveled to West Palm Beach with information
+about the girls," including social media discussions about "their use of alcohol and
+marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their
+decision to take the case to a grand jury;" Palm Beach Police subsequently "received
+complaints that two of the victims or their families had been harassed or threatened;"
+"relations between police and prosecutors were fraying" as the investigation continued;
+and "one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up" to testify before the grand jury.
+• "Trump Snags Gosman Estate for $41 Million" published on November 16, 2004,
+reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
+purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along
+the storied 'Raider's Row" " in Palm Beach.
+"Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that
+"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three or more times between Aug. I and Oct. 31 of last
+year, according to an indictment charging him with felony solicitation of prostitution."
+The article further reported that "Epstein's case is unusual in that suspected prostitution
+johns are usually charged with a misdemeanor, and even a felony charge is typically
+made in a criminal information - an alternative to an indictment charging a person with
+the commission of a crime."
+12
+
+
+• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006,
+reporting that "Palm Beach police thought there was probable cause to charge Epstein
+with unlawful sex acts with a minor and lewd and lascivious molestation." The article
+further reported that "Police Chief Michael Reiter was so angry with State Attorney
+Barry Krischer's handling of the case that he wrote a memo suggesting the county's
+top prosecutor disqualify himself," and identified a 20-year-old on-the-record female
+source who said "she gave Epstein a massage in the nude, then brought him six girls,
+ages 14 to 16, for massage and sex-tinged sessions at his home."
+• "Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006,
+reporting that "[flamed Harvard law professor Alan Dershowitz met with the Palm
+Beach County State Attorney's Office and provided damaging information about
+teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein,
+sexually charged massages" and that "It)he state attorney's office said it presented the
+Epstein case to a county grand jury this month rather than directly charging Epstein
+because of concerns about the girls' credibility."
+• "Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006,
+reporting that "[r)ather than file charges, the state attorney's office presented the case
+to a county grand jury" which "indicted Epstein last week on a single, less serious
+charge of felony solicitation of prostitution," and that "It]he case raised eyebrows
+because the state attorney's office rarely, if ever, kicks such charges to a grand jury."
+• "Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting
+that "[a] state attorney's spokesman would say only that the office refers cases to the
+grand jury when there are issues with the viability of the evidence or witnesses'
+credibility."
+• "Palm Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006,
+reporting that Chief Reiter "pressed for Epstein to be charged with the more serious
+crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in
+blunt language seldom used by one law enforcement official with another because of
+what he perceived as that office's mishandling of the case."
+• "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007,
+reporting that "Inlearly eight months after Palm Beach tycoon Jeffrey Epstein was
+charged with felony solicitation of prostitution, there has been no discemible progress
+in his case."
+"Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
+on October 18, 2007, reporting on a lawsuit brought in New York State court against
+Epstein "by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model."
+• "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein,
+55, pleaded guilty ... to felony solicitation of prostitution and procuring a person under
+the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex
+13
+
+
+offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their
+investigation of Epstein, which they had taken to a grand jury."
+• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on
+August 13, 2008, reporting that "[dJuring his first month of confinement" Epstein was
+visited by
+,, who allegedly escorted victims "upon their arrival at his Palm
+Beach waterfront home to an upstairs room, where she prepared the massage table and
+provided the oils for their encounters" with Epstein, and by
+"a
+young woman whom Epstein purportedly described as his Yugoslavian sex slave."
+• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July
+1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade
+six days a week on a work-release program."
+• "Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting
+that attorneys for women suing Epstein in various courts "want his [non-prosecution]
+agreement [NPA] with federal prosecutors unsealed" and were moving to unseal the
+agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces
+at least a dozen civil lawsuits in federal and state courts tiled by young women who
+said they had sex with him and now are seeking damages." On that date, The Palm
+Beach Post moved to intervene in the utter for the purpose of obtaining public access
+to the NPA, which was ordered disclosed by this Court on June 25, 2009.
+"Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on
+September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,
+"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
+pleaded guilty to prostitution-related felonies in state court" and also agreed not to
+charge any of Epstein's possible co-conspirators:
+1, Lesley
+" The article further reported that, according to an
+attorney representing three of Epstein's victims, "none of the 30 to 40 wom[e]n
+identified as victims in the federal investigation" were informed ahead of time about
+the NPA.
+• "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on
+January 27, 2010, reporting that "a judge ... gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to subpoena abortion records from
+women who are seeking millions in damages from the part-time Palm Beach resident."
+• "Epstein Journal's Findings Could Resurrect Abuse Case" published on March 20,
+2010, reporting that *[a] purloined journal that is said to contain the names of
+'hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reoper
+the investigation into the multi-millionaire's appetite for teenage girls."
+"Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published
+on October 4, 2017, reporting that, according to court documents, Epstein *shelled out
+$5.5 million to settle lawsuits with three of more than two dozen teens who sued him."
+14
+
+
+• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims'
+Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge
+Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had
+dropped plans to prosecute the billionaire on dozens of federal charges in connection
+with the girls' claims that he paid them for sex at his Palm Beach mansion."
+• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
+Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9,
+2019, reporting on Epstein's appearance in U.S. District Court for the Southern District
+of New York in which he "pleaded not guilty to charges accusing him of creating a vast
+network of girls as young as 14 that he exploited for his sexual pleasure at his homes
+in Palm Beach and Manhattan."
+A true and correct copy of the above news articles, in either the computerized format in which they
+are maintained in The Palm Beach Post's electronic archives or the news print edition in which
+originally published, is annexed hereto as Exhibit 1.
+54.
+The press has a constitutional right of access to criminal proceedings, see, e.g.,
+Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
+proceedings.
+v. Graddick, 696 F.2d 796 (1Ith Cir. 1983). Indeed, "the integrity of the
+judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
+proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ
+Co. v.
+i, 426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in
+matters concerning the closure of judicial proceedings). The press also has a First Amendment
+interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
+Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists .... the protection afforded [by
+the First Amendment] is to the communication, to its source and to its recipients both."); Pittman
+1, 267 F.3d 1269, 1283 n. 12 (11th Cit. 2001) ("The Supreme Court has recognized that the
+First Amendment offers protection to both speakers and those wishing to receive speech."); see
+also Stephens v. Cty. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff
+15
+
+
+has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing
+to convey the information to her").
+55.
+Because of the unique role performed by the press as a "public surrogate"
+426 So. 2d at 6-7) in protecting the right of access and its interest in reporting information about
+criminal proceedings, news organizations "presumptively have a right to access judicial records,"
+Comm'r, Ala Dep't of Corr. v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019),
+and "standing to question the validity of an order restricting publicity because its ability to gather
+news is directly impaired or curtailed."
+1, 426 So. 2d at 4; see also Carlson v. United States,
+837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee]
+has standing to assert [its] claim" to grand jury materials because such materials are "public records
+to which the public may seek access, even if that effort is ultimately unsuccessful").
+56.
+Here, the continued denial of access to information The Palm Beach Post seeks on
+behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury."
+Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
+Zerilli v.
+, 656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press" function as a vital
+source of information is weakened whenever the ability of journalists to gather information is
+impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand
+jury materials).
+F..
+The Court's Supervision of the Grand Jury Process and Its Authority to Order
+Public Disclosure of the Epstein Evidence.
+57.
+The Florida Supreme Court has noted that in states such as Florida, where the
+grand jury is preserved, it is an important appendage of the court which impanels it. At the same
+time it should not be forgotten that the judge of that court is equally important and he is generally
+charged with the supervision of the grand jury's activities... It is, therefore, of vital importance to
+16
+
+
+maintain the dignity and the integrity of both the grand jury and the presiding judge." State v.
+Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
+58.
+Chapter 905 of the Florida Statutes governs the empanelment and conduct of
+Florida grand juries. The court gives the grand jury its initial charge and advises the grand jury
+about its legal duties. Fla. Stat. § 905.18.
+59. Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined
+before the grand jury ... or other evidence received by it" may be disclosed "when required by a
+court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
+the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)
+Furthering justice." Fla. Stat. § 905.27(1)(a) -(c).
+60.
+Further, disclosure is appropriate pursuant to this Court's inherent authority over
+grand jury proceedings because of the exceptional public interest in this case and the compelling
+circumstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (*a district court
+has the inherent power to disclose (grand jury] materials in exceptional circumstances and ...
+historic importance can be a sufficient reason when there is little countervailing need for secrecy").
+COUNT!
+(Florida Stat. Section 905.27)
+Based on information learned by The Palm Beach Post through its Florida Public
+Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence
+and proceedings, judicial documents obtained from independent but related court proceedings, and
+documents otherwise available in the public record, the State Attorney for Palm Beach County
+presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner
+17
+
+
+that precluded his indictment for the serious crimes he committed, including sex trafficking and
+sexual assault.
+62.
+Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's
+victims and the public, and to provide public disclosure to illuminate whether Epstein received
+unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
+immediate public access to the testimony, minutes, and other evidence presented in 2006 to the
+Palm Beach County grand jury. In a case of this magnitude and importance, where the accused is
+dead and so many of his crimes, as well as the identities and crimes of his co-conspirators, and the
+identities of the victims have already been exposed, the need for grand jury secrecy is no more.
+See United States v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jury's
+functions are ended, disclosure is wholly proper where the ends of justice require it.").
+WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
+Stat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk
+of the Court to file with this Court copies of the testimony, minutes, and other evidence presented
+in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
+that, following an in camera inspection, it can be made available to The Palm Beach Post and the
+public on an expedited basis, and grant any other and further equitable or legal relief the Court
+deems just and proper.
+18
+
+
+Dated: November 14, 2019
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By:
+Is/ Stephen A. Mendelsohn
+Florida Bar No. 849324
+mendeisohns@ytlaw.com
+hasenh@gtlaw.com
+FLService@gtlaw.com
+By:
+Is/ Michael J Grugiel
+MICHAEL JGRYGIEL
+(Pro Hac Vice application forthcoming)
+54 State St., 6th Floor
+Albany, New York 12207
+NOT A CER
+Telephone: (518) 689-1400
+racsimile: (518) 689-1499
+grygielm@gtlaw.com
+Ist Vincent H. Chiefto
+VINCENT H. CHIEFFO
+Pro Hac Vice application forthcoming
+840 Century Park East, Suite 190
+Los Angeles CA 90067
+Telephone: (310) 586 7700
+Facsimile: (310 586 7800
+chicffov(@yllaw.com
+riveraal@gtlaw.com
+By: Is/ Nina D. Bosaitan
+NINA D. BOYAJIAN
+(Pro Hac Vice application forthcoming
+1840 Century Park East, Suite 1900
+Los Angeles CA 90067
+Telephone: (310) 586 7700
+Facsimile: (310) 586 7800
+bovajiann@ gtlaw.com
+riveraal/@otiaw.com
+ACTIVE 45678709v3
+
+
+
+The Newspaper's Reportage on Jeffrey Epstein
+
+
+The Man Who Had Everything: Jeffrey Epstein craved big
+homes, elite friends and underage girls
+By Andrew Marra
+Posted Jul 17, 2019 at 6:02 AM
+From the archives: When Palm Beach detectives started asking
+questions and teenage girls started talking, a wave of legal resistance
+followed.
+Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
+Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution.
+WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,
+hidden cameras trolled two rooms, while the girls came and went.
+For the police detectives who sifted through the garbage outside and kept records of visitors, it
+was the lair of a troubling target.
+Epstein, one of the most mysterious of the country's mega-rich, was known as much for his
+secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
+friendships with the world's elite.
+But at Palm Beach police headquarters, he was becoming known for something else: the
+regular arrival of teenage girls he hired to give him massages and, police say, perform sexual
+favors.
+Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
+among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
+with some of the most prominent legal, scientific and business minds in the country.
+When detectives started asking questions and teenage girls started talking, a wave of legal
+resistance followed.
+
+
+» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease
+If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
+Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
+quietly, always in the background as he navigated New York high society.
+When he first attracted notice in the early 1990s, it was on account of the woman he was
+dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
+In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British
+Mail on Sunday tabloid laid out speculative stories that the socialit's beau was a CIA spook, a
+math teacher, a concert pianist or a corporate headhunter.
+"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both
+flamboyant and intensely private."
+The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
+flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
+Africa on his private jet.
+Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
+published lengthy profiles. The New York Post listed him as one of the city's most eligible
+bachelors and began describing him in its gossip columns with adjectives such as "mysterious"
+and "reclusive."
+Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
+Building a life of extravagance
+He was born blue-collar in 1953, the son of a New York City L
+department employee, and
+raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
+but became a math teacher at the prestigious Dalton School in Manhattan.
+The story goes that the father of one of Epstein's students was so impressed with the man that
+he put him in touch with a senior partner at Bear Stearns, the global investment bank and
+securities firm.
+
+
+In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
+Epstein and Co. That is when he began making his millions in earnest.
+Little is known or said about Epstein's business except this: He manages money for the
+extremely wealthy. He is said to handle accounts only of $1 billion or greater.
+It has been estimated he has roughly 15 clients, but their identities are the subject of only
+speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a
+former Palm Beacher who is said to have been a mentor to Epstein.
+Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
+block on Manhattan's Upper East Side. It is reported to have, among its finer features, closedcircuit television and a heated sidewalk to melt away fallen snow.
+That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
+the extravagant world Epstein built over time.
+In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
+outside Santa Fe. Many believed it to be the largest home in the state.
+In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
+private island in the Virgin Islands.
+» PHOTOS: The players in the Jeffrey Epstein saga
+Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
+the highest echelons of power. This includes not only socialites but also business tycoons,
+media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
+funds.
+"Just like other people collect art, he collects scientists," said
+Nowak, who directs the
+Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
+a $30 million research donation from Epstein.
+Epstein is said to have befriended former Harvard President Larry Summers, prominent law
+Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort
+Zuckerman.
+
+
+And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
+photographed.
+"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
+and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article.
+Epstein's friendship with Clinton has attracted the most attention.
+Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
+an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
+close friends until after Clinton left the Oval Office and moved to New York.
+Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John
+Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill
+h and the
+Senate bids of Joe_
+4, Hillary Rodham Clinton, Christopher Dodd and Charles
+Schumer.
+Powerful friends and enemies
+A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he
+left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
+Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20
+million loan.
+The article suggested that one of his business mentors and previous employers was Steven
+Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million
+in one of the largest Ponzi schemes in American history."
+As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
+man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
+than $16,000 in furnishings.
+A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
+thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
+owed him nothing.
+» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
+
+
+"It's a bad memory, I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the
+retired former president of
+Electronics and Sega Corp. "Suffice it to say I have
+nothing good to say about him."
+Among the characteristics most attributed to Epstein is a penchant for women.
+He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
+and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
+model.
+"He's a lot of fun to be with," Donald Trump told New York magazine in 2002. "It is even said
+that he likes beautiful women as much as I do, and many of them are on the younger side. No
+doubt about it, Jeffrey enjoys his social life."
+Investigation leads to Epstein
+Although he was not a frequenter of the Palm Beach social scene, he made his presence felt.
+Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
+$100,000 to Ballet Florida.
+In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a l
+Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
+private chef and a small staff stood at the ready. From a window in his mansion, he could look
+out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
+who had everything.
+But extraordinary wealth can fuel extraordinary desires.
+» Epstein wants to leave jail for mansion in sex-trafficking case
+In March 2005, a worried mother contacted Palm Beach police. She said another parent had
+overheard a conversation between their children.
+Now the mother was afraid her 14-year-old daughter had been molested by a man on the
+island.
+The phone call triggered an extensive investigation, one that would lead detectives to Epstein
+but leave them frustrated.
+
+
+Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
+Beach police report detailing the criminal probe offers a window into what detectives faced as
+they sought to close in on Epstein.
+Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
+perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
+said she was paid $300 after stripping to her panties and massaging the man while he
+masturbated.
+Police interview 5 alleged victims
+The investigation began in full after the girl identified Epstein in a photo as the man who had
+paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift
+through it. They set up a video camera to record the comings and goings at his home. They
+monitored an airport hangar for signs of his private jet's arrivals and departures.
+They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
+, a Palm Beach Community College student from Loxahatchee. In a sworn
+statement at police headquarters,
+_, then 18, admitted she had taken at least six girls to
+visit Epstein, all between the ages of 14 and 16. Eg
+I paid her for each visit, she said.
+During the drive back to her house,
+told detectives, "I'm like a Heidi Fleiss."
+Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
+said they had been instructed to have sex with another woman in front of Epstein, and one said
+she had direct intercourse with him.
+In October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras were
+found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school
+transcript.
+Two of Epstein's former employees told investigators that young-looking girls showed up to
+perform massages two or three times a day when Epstein was in town.
+They said the girls were permitted many indulgences. A chef cooked for them. Workers gave
+them rides and handed out hundreds of dollars at a time.
+
+
+One employee told detectives he was told to send a dozen roses to one teenage girl after a high
+school drama performance. Others were given rental cars. One, according to police, received a
+$200 Christmas bonus.
+The cops moved to cement their case. But as they tried to tighten the noose, they encountered
+other forces at work.
+In Orlando they interviewed a possible victim who told them nothing inappropriate had
+happened between her and Epstein. They asked her whether she had spoken to anyone else.
+She said yes, a private investigator had asked her the same questions.
+» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal
+When they subpoenaed one of Epstein's former employees, he told them the same thing. He
+and a private eye had met at a restaurant days earlier to go over what the man would tell
+investigators.
+Detectives received complaints that private eyes were posing as police officers. When they told
+Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
+high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
+Kennedy
+While the private eyes were conducting a parallel investigation, Dershowitz, the Harvard law
+professor, traveled to West Palm Beach with information about the girls. From their own
+profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
+their use of alcohol and marijuana.
+He took his research to a meeting with prosecutors in early 2006, where he sought to cast
+doubt on the teens reliability.
+The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
+did some of the girls have issues with drugs or alcohol but also some had criminal records and
+other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
+told police she was younger than 18 when she started performing massages for Epstein.
+After the meeting, prosecutors postponed their decision to take the case to a grand jury.
+
+
+In the following weeks, police received complaints that two of the victims or their families had
+been harassed or threatened. Epstein's legal team maintains that its private investigators did
+nothing illegal or unethical during their research.
+By then, relations between police and prosecutors were fraying. At a key meeting with
+prosecutors and the defense, Detective
+Recarey, the lead investigator, was a no-show,
+according to Epstein's attorney.
+"The embarrassment on the prosecutor's face was evident when the police officer never
+showed up for the meeting," attorney Jack Goldberger said.
+Later in April, Recarey walked into a prosecutor's office at the state attorney's office and
+learned the case was taking an unexpected turn.
+The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein
+a plea deal that would not require him to serve jail time of receive a felony conviction.
+Recarey told her he disapproved of the plea offer,
+The deal never came to pass, however.
+Future unclear after charge
+On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
+counts of unlawful sexual activity with a minor and to charge his personal assistant,
+,, now 27, for her alleged role in arranging the visits. Police officials also wanted to
+charge
+1, the self-described Heidi Fleiss, with lewd and lascivious acts.
+By then, the department was frustrated with the way the state attorney's office had handled the
+case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
+wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
+he would not act.
+Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
+the grand jury.
+
+
+It is not known how many of the girls testified before the grand jury. But Epstein's defense
+team said one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up.
+The grand jury's indictment was handed down in July. It was not the one the police
+department had wanted.
+Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
+charged with one count of felony solicitation of prostitution, which carries a maximum penalty
+of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
+released hours later.
+Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
+he said their claims that they had sexual encounters with him lack credibility.
+"They are incapable of being believed," he said. "They had criminal records. They had
+accusations of theft made against them by their employers. There was evidence of drug use by
+some of them."
+What remains for Epstein is yet to be seen.
+The Palm Beach Police Department has asked the FBI to investigate the case. It also has
+returned the $90,000 Epstein donated in 2004.
+In New York, candidates for governor and state attorney general have vowed to return a total
+of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful
+friends have remained silent as tabloids and Internet blogs feast on the public details of the
+police investigation.
+Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
+plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
+"He will recover from this," he said.
+Staff writer Larry
+Melanie Mena contributed to this story.
+and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
+amarra@pbpost.com
+
+
+@AMarraPBPost
+
+
+273 / 278 - Tuesday, November 16, 2004
+Section: A SECTION
+Source: By PAUL OWERS Palm Beach Post Staff Writer
+Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
+Memo: Ran all editions.
+Dateline: WEST PALM BEACH
+TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
+When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
+Donald was not about to be trumped.
+"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his
+New York office.
+Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
+seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
+But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
+513 N. County Road. He wants to - what else? - sell it and make more money.
+The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
+luxury house" that would be the "finest anywhere in the United States." He might build
+another house before flipping the entire package.
+"I've known about this house for quite some time," Trump said. "It's probably the best piece
+of land in Florida - and probably the country - for luxury real estate."
+Althoush Trump said he could subdivide the property into nine lots, Palm Beach Mavor
+Lesly
+said zoning regulations allow for only two houses - and maybe a third.
+said she's not worried about Trump's plans.
+"He's been a very good property owner in the town of Palm Beach," she said. "He does his
+projects very well. He's a perfectionist."
+Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
+Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
+distribution to creditors.
+The auction began at exactly noon after Judge Steven
+dismissed an objection from
+an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
+that Trump was not a qualified bidder because his contract stipulated that he would not close
+on the sale unless title insurance was in place beforehand.
+With Trump listening via conference call, Epstein began the bidding at $37.25 million -
+$250,000 higher than Trump's initial offer.
+Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn
+came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85
+million.
+Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had
+given up his right to bid by passing the first time.
+
+
+But
+p allowed the offer to stand, and Pulte and Trump went back and forth until
+Puite dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
+$38.6 million.
+h closed the bidding 10 minutes after it started, leaving Trump with the right to buy
+the 29,000-square-foot home (a typical Palm Beach County single-family house is about
+2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
+quarters.
+The closing could take place within a week but probably won't happen until next month.
+Trustee Joe Luzinski and creditors said they were pleased with the outcome.
+"We knew we were dealing with some substantial people ... who were going to bid it up a
+bit," Luzinski said.
+"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
+"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
+The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
+former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't
+receive a commission, he said.
+Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.
+"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
+Pulte said Gosman asked him before the auction whether he would be willing to let him stay
+in the mansion after the closing until he decides where he wants to move. Trump and
+Luzinski said they have had no such discussions with Gosman.
+Gosman, 75, had the house built after paying $12.1 million for the land in 1986.
+The former health-care magnate declined interview requests before and after the auction
+Monday. He was at the courthouse but left before the auction took place.
+The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
+Beach home and guest house but falls short of the $45 million that Virginia home builder
+Dwight Schar paid for Ron Perelman's 26,000-square-foot estate, Casa Apava, a designated
+landmark.
+Schar also paid $18.6 million for a lakefront lot across the street from the main house, for a
+total of $63.6 million. Insiders say Schar spent a total of $70 million for his new property,
+making it the priciest residential sale in U.S. history.
+Gosman once had a fortune that Forbes magazine estimated at $480 million. He voluntarily
+filed for Chapter 11 bankruptcy protection in 2001, listing assets of $250 million and
+liabilities of $233.6 million.
+When a judge ruled that Gosman had to give up all of his exempt assets to creditors if he
+wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation.
+Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is
+invalid because Florida law does not recognize a Dominican Republic divorce that Lin
+Gosman tried to obtain from another man, Michael Castre.
+The judge's decision was a huge victory for creditors because it prevents Abe Gosman from
+protecting assets by claiming joint ownership with his wife. Gosman's assets, which include
+an extensive collection of artwork, could total as much as $70 million and will be sold later.
+Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's
+estate, said David Cimo, special counsel for the trustee.
+"We would have been thwarted ... or at least substantially impaired," Cimo said.
+
+
+The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
+an ownership interest in his home and other belongings only to avoid losing them in
+bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
+1999, well before he filed for bankruptcy.
+Lessen is expected to rule in the next two months whether Gosman made improper transfers,
+a decision that will affect how much money will be available to creditors.
+Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
+willing to move forward, in part because the upkeep of the estate now exceeds their means.
+"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
+said. "That's not a house you want to live in unless you're making large amounts of money
+like Donald Trump."
+paul_owers@pbpost.com
+
+
+#1/71/2013
+indictmen: sonaire socite a limes - news - ine raim deach Host - vest raim beaon, FL
+Indictment: Billionaire Solicited 3 Times
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:30 PM
+(EDITORS NOTE: This story originally published in The Palm Beach Post on July 25,
+2006)
+Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three of more times between Aug. 1 and Oct. 31
+of last year, according to an indictment charging him with felony solicitation of
+prostitution.
+Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
+was released on $3,000 bond
+Epstein's case is unusual in that suspected prostitution johns are usually charged
+with a misdemeanor, and even a felony charge is typically made in a criminal
+information - an alternative to an indictment charging a person with the
+commission of a crime.
+His attorney, Jack Goldberger, declined to discuss the charge.
+State attorney's office spokesman Mike Edmondson also had little to say.
+"Generally speaking, there is a case that has a number of different aspects to it,"
+Edmondson said of a prostitution-related charge being submitted to a grand jury.
+"We first became aware of the case months ago by Palm Beach police."
+Prosecutors and police worked together to bring the case to the grand jury, he
+said.
+htts://wwwnalmhearhonst com/news/20080701/inclictment-hillinnaira-antiriterl-?-times
+117
+
+
+Inaciment: sinonare soucieu 3 umes - News - Ine raim beach rost - vvest Faim beacn, FL
+Palm Beach police confirmed that and said the department will release a report
+today regarding its investigation.
+Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
+pool and a boat dock on the Intracoastal Waterway since 1990, according to
+property records. A man answering the door there Monday said that Epstein
+wasn't home. A Cadillac Escalade registered to him was parked in the driveway,
+which is flanked by two massive gargoyles.
+Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the
+assessment of his home exceeded its fair market value. He dismissed his lawsuit
+in December 2002.
+A profile of Epstein in Vanity Fair magazine said he owns what are believed to
+be the largest private homes in Manhattan - 51,000 square feet - and in New
+Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
+U.S. Virgin Islands and fleet of aircraft.
+Epstein's friends and admirers, according to the magazine, include prominent
+businessmen, academics and scientists and famed Harvard law professor Alan
+Dershowitz.
+httms://wwwnalmhaachnnst.com/naws/200A0701/in/lirtment_hillionaira-snliciterl-3-times
+
+
+11/T12018
+Aner long prode, Dionaire races sociaton charge - News - ine ram beach rost - vest raim seaon, rL
+After long probe, billionaire faces solicitation
+charge
+Posted Jul 27, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:11 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 26,
+2006)
+Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young
+women brought to his home, where he received massages and sometimes sex,
+according to an investigation by the Palm Beach Police Department.
+Palm Beach police spent months sifting through Epstein's trash and watching his
+waterfront home and Palm Beach International Airport to keep tabs on his
+private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
+him with one count of felony solicitation of prostitution.
+Palm Beach police thought there was probable cause to charge Epstein with
+unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
+handling of the case that he wrote a memo suggesting the county's top
+prosecutor disqualify himself.
+"I must urge you to examine the unusual course that your office's handling of this
+matter has taken and consider if good and sufficient reason exists to require your
+disqualification from the prosecution of these cases, " Reiter wrote in a May 1
+memo to Krischer.
+While not commenting specifically on the Epstein case, Mike Edmondson,
+spokesman for the state attorney, said his office presents cases other than
+murders to a grand jury when there are questions about witnesses' credibility and
+their ability to testify.
+httrs://www.nalmheac.hnnst com/naws/20060727/sffar-lonn-nrha-hillinnsira-faras-entiritation-chama
+1/5
+
+
+
+Anter fong prope, Dimonaire races solicitaton charge - News - I ne ramm beacn rost - vest raim beacn, FL
+By the nature of their jobs, police officers look at evidence from a "one-sided
+perspective," Edmondson said. "A prosecutor has to look at it in a much broader
+fashion," weighing the veracity of witnesses and how they may fare under
+defense attorneys' questioning, he said.
+Epstein's attorney, Jack Goldberger, said his client committed no crimes.
+"The reports and statements in question refer to false accusations that were not
+charged because the Palm Beach County state attorney questioned the credibility
+of the witnesses," Goldberger said. A county grand jury "found the allegations
+wholly unsubstantiated and not credible," and that's why his client was not
+charged with sexual activity with minors, he said
+Goldberger said Epstein passed a lie detector test administered by a reputable
+polygraph examiner in which he said he did not know the girls were minors.
+Also, a search warrant served on Epstein's home found no evidence to
+corroborate the girls allegations, Goldberger said.
+According to police documents:
+- A Palm Beach Community College student said she gave Epstein a massage in
+the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
+sessions at his home.
+- A 27-year-old woman who worked as Epstein's personal assistant also
+facilitated the liaisons, phoning the PBCC student to arrange for girls when
+Epstein was coming to town. And she escorted the girls upstairs when they
+arrived, putting fresh sheets on a massage table and placing massage oils nearby.
+- Police took sworn statements from five alleged victims and 17 witnesses. They
+contend that on three occasions, Epstein had sex with the girls.
+A money manager for the ultra-rich, Epstein was named one of New York's most
+eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
+the likes of former President Clinton, former Harvard University President
+Summers and Donald Trump, and has lavish homes in Manhattan,
+New Mexico and the Virgin Islands.
+httns://www.nalmhearhonst rnm/news/20060727/яftar-Ionn-nmhe-hillinnaira-faras-anlicitatinn-charnA
+
+
+Ater iong prope, dimonaire races soictaton cnarge - news - ine ram sean rost - vest ram beacn, rL
+He has contributed tens of thousands of dollars to Democratic Party candidates
+and organizations, including Sen. John Kerry's presidential bid, and the Senate
+campaigns of Joel
+1, Hillary Clinton,
+- Dodd and Charles
+Schumer.
+COPY
+Goldberger is one of five attorneys Epstein has retained since he became the
+subject of an investigation, Edmondson said. Among the others: Alan
+Dershowitz, the well-known Harvard law professor and author, who is a friend
+of Epstein. Dershowitz could not be reached for comment.
+Police said the woman who enlisted young girls for Epstein was
+20, of
+Palm Beach.
+has worked at an Olive Garden restaurant in
+Wellington and said she was a journalism major at Palm Beach Community
+College when she was questioned by police last October. She has an unlisted
+phone number and could not be reached for comment.
+said she met Epstein when, at age 17, a friend asked her if she would like
+to make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
+to a bedroom with a massage table and oils. Epstein and
+were both naked
+during the massage, she said, but when he grabbed her buttocks, she said she
+didn't want to be touched.
+httns:/www.naimheachnnet com/news/7006Л727/sftar_Innn-nenhA_hillinnaire-fares-snliritation_chame
+
+
+Maer tong prope, omionaire races socraton charge - News - Ine ram Deacn rost - vest rain beacn, FL
+Epstein said he'd pay her to bring him more girls - the younger the better,
+told police. When she tried once to bring a 23-year-old woman to him,
+Epstein said she was too old,
+said.
+1, who has not been charged in the case, said she eventually brought six
+girls to Epstein who were paid $200 each time,
+n said. "I'm like a Heidi
+Fleiss," police quoted her as saying. The girls knew what to expect when they
+were taken to Epstein's home,
+n said. Give a massage - maybe naked - and
+allow some touching.
+One 14-year-old girl
+p took to meet Epstein led police to start the
+investigation of him in March 2005. A relative of the girl called to say she
+thought the child had recently engaged in sex with a Palm Beach man. The girl
+then got into a fight with a classmate who accused her of being a prostitute, and
+she couldn't explain why she had $300 in her purse.
+The girl gave police this account of her meeting with Epstein:
+She accompanied
+and a second girl to Epstein's house on a Sunday in
+February 2005. Once there, a woman she thought was Epstein's assistant told the
+girl to follow her upstairs to a room featuring a mural of a naked woman, several
+photographs of naked women on a shelf, a hot pink and
+sofa and a massage
+table.
+She stripped to her bra and panties and gave him a massage.
+Epstein gave the 14-year-old $300 and she and the other girls left, she said. She
+said
+p told her that Epstein paid her $200 that day.
+Other girls told similar stories. In most accounts, Epstein's personal assistant at
+the time,
+,, now 27, escorted the girls to Epstein's bedroom.
+,, whose most recent known address is in North Carolina, has not been
+charged in the case.
+Palm Beach police often conducted surveillance of Epstein's home, and at Palm
+Beach International Airport to see if his private jet was there, so they would
+know when he was in town. Police also arranged repeatedly to receive his trash
+hts://www nalmhaachnnst com/news/20060727/sfer-innn-hmh/n-hillinnaire-farAs-kni-itation-charA
+4/5
+
+
+T1//2UT
+Anter long prode, cionaire races socraton charge - news - Ine ram beaon rost - vest raim beacn, FL
+from Palm Beach sanitation workers, collecting papers with names and phone
+numbers, sex toys and female hygiene products.
+One note stated that a female could not come over at 7 p.m. because of soccer.
+Another said a girl had to work Sunday - "Monday after school?" And still
+another note contained the work hours of a girl, saying she leaves school at 11:30
+a.m. and would come over the next day at 10:30 a.m.
+Only three months before the police department probe began, Epstein donated
+890,000 to the department for the purchase of a firearms simulator, said Jáne
+Struder, town finance director. The purchase was never made. The money was
+returned to Epstein on Monday, she said.
+NOT A CERTIFIED CÖ
+httns://www.natmheachnnst com/naws/20060727/after-Ionn-nmha-hillinnaire-fares-snlinitalion-chama
+F/R
+
+
+Folice say lawyer trea to discrear eenage girs - news - Fam cean waly News - ram deacn, FL
+Police say lawyer tried to discredit teenage
+girls
+Posted Jul 29, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 2:00 PM
+(EDITOR'S NOTE: This story originally was published in The Palm Beach Post on July
+29, 2006)
+Famed Harvard law professor Alan Dershowitz met with the Palm Beach County
+State Attorney's Office and provided damaging information about teenage girls
+who say they gave his client, Palm Beach billionaire Jeffrey EpH, sexually
+charged massages, according to police reports.
+The reports also state that another Epstein attorney agreed to a plea bargain that
+would have allowed Epstein to have no criminal record. His current attorney
+denies this happened.
+And the documents also reveal that the father of at least one girl complained that
+private investigators aggressively followed his car, photographed his home and
+chased off visitors.
+Police also talked to somebody who said she was offered money if she refused to
+cooperate with the Palm Beach Police Department probe of Epstein.
+The state attorney's office said it presented the Epstein case to a county grand
+jury this month rather than directly charging Epstein because of concerns about
+the girls' credibility. The grand jury indicted Epstein, 53, on a single count of
+felony solicitation of prostitution, which carries a maximum penalty of five years
+in prison.
+Police believed there was probable cause to charge Epstein with the more serious
+crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
+Krischer a memo in May suggesting he disqualify himself from the case.
+httpe://www.nalmheachrlailvnews com/article/20040720/NFWS/190917573
+1/4
+
+
+TYI2079
+roice say lawyer tea to discrear teenage gins - News - ram beach wally News - Fam Deacn, FL
+The case originally was going to be presented to the grand jury in February, but
+was postponed after Dershowitz produced information gleaned from the Web
+site myspace.com showing some of the alleged victims commenting on alcohol
+and marijuana use, according to the police report prepared by Detective JI
+Recarey.
+a 20-year-old 1 Palm Beach woman who told police she
+recruited girls for Epstein, also is profiled on myspace.com. Her page includes
+photos of her and her friends, including one using the name "Pimpin' Made EZ."
+who was not charged in the case, is a potential prosecution witness.
+According to Recarey, prosecutor Lanna Belohlavek offered Epsteín attorneys
+Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
+Epstein, accepted the deal, in which Epstein would plead guilty to one count of
+aggravated assault with intent to commit a felony, be placed on five years'
+probation and have no criminal record. The deal also called for Epstein to submit
+to a psychiatric and sexual evaluation and have no unsupervised visits with
+minors, according to Recarey's report. The plea bargain was made in connection
+with only one of the five alleged victims, the report states.
+Fronstin - who declined to comment on the case - was subsequently fired and
+veteran defense attorney Jack Goldberger was hired. He denies there was any
+agreement by any of Epstein's attorneys to a plea deal.
+"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek
+nor a state attorney's spokesman could be reached for comment.
+The parent or parents of alleged victims who complained of being harassed by
+private investigators provided license tag numbers of two of the men. Police
+found the vehicles were registered to a private eye in West Palm Beach and
+another in Jupiter, according to Recarey's report.
+"I have no knowledge of it," defense attorney Goldberger said.
+The report also says a woman connected to the Epstein case was contacted by
+somebody who was still in touch with Epstein. That person told her she would
+be compensated if she didn't cooperate with police, Recarey's report says. Those
+htine:/www nalmbeachriailunews com/artinla/200A0779/NFW/S/190917573
+
+
+Motice say lawyer tried to aiscreait teenage gins - News - raim beach ually News - ram beach, rL
+who did talk "will be dealt with," the woman said she was told. Phone records
+show the woman talked with the person who allegedly intimidated her around
+the time she said, Recarey reported.
+Phone records also show that the person said to have made the threat then
+placed a call to Epstein's personal assistant, who in turn called a New York
+corporation affiliated with Epstein, the report states.
+The issue in the Epstein case is not whether females came to his waterfront
+home, but whether he knew their ages.
+"He's never denied girls came to the house," Goldberger said. But when Ep: l
+was given a polygraph test, "he passed on knowledge of age," the attorney said.
+After the indictment against Epstein was unsealed this week, Police Chief Reiter
+referred the matter to the FBI. "We've received the referral, and we're reviewing
+it," said FBI spokeswoman Judy Orihuela in Miami.
+The chief himself has come under attack from Epi! lawyers and friends in
+New York, where he has a home. The New York Post quoted Epstein's
+prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
+only "because of the craziness of the police chief."
+Reiter has declined to comment on the case.
+Prosecutors have not presented a sex-related case like Epstein's to a grand jury
+before, said Mike Edmondson, spokesman for the state attorney's office. "That's
+what you do with á case that falls into a gray area," he said.
+The state attorney's office did not recommend a particular criminal charge on
+which to indict Epstein, Edmondson said. The grand jury was presented with a
+list of charges from highest to lowest, then deliberated with the prosecutor out of
+the room, he said
+"People are surprised at the grand jury proceeding," West Palm Beach defense
+attorney Richard Tendler said. 'It's a way for the prosecutor's office to not take
+the full responsibility for not filing the (charge), and not doing what the Palm
+Beach Police Department wanted. I think something fell apart with those
+underage witnesses."
+httre://www.halmheachrlailvnews com/article/20060729/NFW/S/190917573
+314
+
+
+Monce say lawyer tea to discrear meenage gins - news - Faim seach wary News - ram beach, FL
+Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
+must have been incredible or untrustworthy, I don't know," he said.
+Other attorneys said Epstein's case raises the issue of whether wealthy, connected
+defendants like Epstein - whose friends include former President Clinton and
+Donald Trump - are treated differently from others. Once he knew he was the
+subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
+Dershowitz and Lefcourt, who is a past president of the National Association of
+Criminal Defense Lawyers.
+Miami lawyer Roy Black - who became nationally known when he successfully
+defended William Kennedy
+• on a rape charge in Palm Beach - also was
+involved at one point.
+Said defense attorney
+* Suskauer: "I think it's unfortunate the public may
+get the perception that with power, you
+may be
+average Joe."
+CERTIFIE
+treated differently than the
+httes://www nalmhaarhrlailunews rm/artirls/2006072#/NFWS/190A17573
+4/4
+
+
+Expert: Ignorance of age isn't
+defense in sex cases
+Posted Aug 5, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 1:38 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 5, 2006)
+Even if Palm Beach money manager Jeffrey Epstein didn't
+know that girls who police say gave him sexual massages at
+his Intracoastal home were under the legal age, that alone
+wouldn't have exempted him from criminal charges of
+sexual activity with minors.
+"Ignorance is not a valid defense," said Bob Dekle, a legal
+skills professor who was a Lake City prosecutor for nearly
+30 years, half of that time specializing in sex crimes against
+children.
+"There is no knowledge element as far as the age is
+concerned," Dekle said
+After an 11-month investigation, Palm Beach police said
+there was probable cause to charge Epstein, 53, with
+unlawful sex acts with a minor and lewd and lascivious
+molestation. They contend that Epstein - friend of the rich
+and famous and financial patron of Democratic Party
+organizations and candidates - committed those acts with
+five underage girls.
+In the past week, New York Attorney General and
+gubernatorial candidate Eliot Spitzer has returned about
+$50,000 in campaign contributions he received from
+Epstein, and Mark | I, a candidate to replace Spitzer in
+
+
+his current job, has returned $10,000 to him because of the
+Palm Beach scandal, the New York Daily News has
+reported.
+Rather than file charges, the state attorney's office
+presented the case to a county grand jury. The panel
+indicted Epstein last week on a single, less serious charge of
+felony solicitation of prostitution.
+The case raised eyebrows because the state attorney's office
+rarely, if ever, kicks such charges to a grand jury. And it
+increases the difficulty of prosecuting child sex abuse cases,
+especially when the defendant is enormously wealthy and
+can hire high-priced, top-tier lawyers.
+At least one of Epstein's alleged victims told police he knew
+she was underage when the two of them got naked for
+massages and sexual activity. She was 16 years old at the
+time and said Epstein asked her questions about her high
+school, according to police reports.
+A girl who said she met Epi
+when she was 15 said he
+told her if she told anybody what happened at his house,
+bad things could happen, the police reports state.
+Epstein's youngest alleged victim was 14 when she says she
+gave him a massage that included some sexual activity. She
+is now 16. The girl's father says he doesn't know whether
+she told Epstein her age.
+"My daughter has kept a lot of what happened from me
+because of sheer embarrassment," he said. "But she very
+much looked 14. Any prudent man would have had second
+thoughts about that."
+Defense attorney Jack Goldberger maintains that not only
+did Epstein pass a polygraph test showing he did not know
+the girls were minors, but their stories weren't credible.
+The state attorney's office also implied that their credibility
+was an issue when it decided not to charge Epstein directly,
+but instead give the case to the grand jury.
+
+
+"A prosecutor has to look at it in a much broader fashion," a
+state attorney's spokesman said last week.
+Epstein hired Harvard law Professor Alan Dershowitz
+when he became aware he was under investigation, and
+Dershowitz gave prosecutors information that some of the
+alleged victims had spoke of using alcohol and marijuana on
+a popular Web site, according to a Palm Beach police
+report.
+Prosecutors typically consider two things in deciding
+whether to charge somebody with sex-related offenses
+against minors - whether there is sufficient evidence and
+whether there is a public interest in doing so, Dekle said.
+If two teens are in a sexual relationship and the boy turns
+18 before the girl, he could be charged with a sex crime if
+the sex continues. There would be no public interest in
+pursuing that, Dekle said.
+But where there is a large gap in ages - and especially in
+cases of teachers with students - there is a public interest in
+prosecuting, he said. Likewise if the accused has a track
+record of sex with minors.
+
+
+Still there is a "universal constant" in prosecuting these
+cases, Dekle said. Men who exploit underage children for
+sex often carefully choose their victims in ways that will
+minimize the risk to them, he said.
+Victims usually are from a lower social status, and they may
+suffer from psychological problems, Dekle said.
+"Lots of child sexual abuse victims have been victimized by
+multiple people over a period of time. Then the act of abuse
+produces behavior in the victims that further damages their
+credibility." Examples include promiscuous behavior and
+drug abuse.
+Some of the alleged victims in the Epstein case returned to
+his home multiple times for the massage sessions and the
+$200 to $300 he typically paid them per visit. "That would
+be a definite problem for the prosecutor," said Betty Resch,
+who prosecuted crimes against children in Palm Beach
+County for five years and now is in private practice in Lake
+Worth.
+"The victim becomes less sympathetic" to a jury, Resch said.
+"But she's a victim nevertheless. She's a kid."
+Most men charged with sex crimes against minors look
+normal, Dekle said. A jury expecting to see a monster
+seldom will. And the victims'
+ages work against them and in
+favor of the defendant in a trial, Dekle said.
+If a child and an adult tell different stories and both swear
+they're telling the truth, adult jurors are more likely to
+believe the adult, Dekle said.
+"You have all these things working against you in a child
+sex abuse case. Prosecutors normally try to be very careful
+in filing those cases because they know what they're getting
+into. There is no such thing as an iron-clad child sexual
+abuse case."
+
+
+Epstein camp calls female accusers
+liars
+Posted Aug 8, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:35 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 8, 2006)
+Attorneys and publicists for Palm Beach financier Jeffrey
+Epstein went on the offensive Monday, contending that
+teenage girls who have accused Epstein of sexual
+shenanigans at his waterfront home are liars and saying
+that the Palm Beach Police Department is "childish."
+"There never was any sex between Jeffrey Epstein and any
+underage women," his lead attorney, Jack Goldberger, said
+from Idaho where he was vacationing with his family.
+Epstein did have young women come to his house to give
+him massages, Goldberger said. "Mr. Epstein absolutely
+insisted anybody who came to his house be over the age of
+18. How he verified that, I don't know. The question is, did
+anything illegal occur. The law was not violated here."
+He had no explanation as to why Epstein would pay girls or
+women with no massage training - as the alleged victims
+said was the case - $200 to $300 for their visits. "The
+credibility of these witnesses has been seriously
+questioned," Goldberger said.
+Epstein, 53, was indicted by a county grand jury last month
+on a charge of felony solicitation of prostitution. After an
+11-month investigation that included sifting through
+Epstein's trash and surveilling his home, Palm Beach police
+concluded there was enough evidence to charge him with
+sexual activity with minors. When the grand jury indicted
+
+
+Epstein on the less serious charge, Police Chief Michael
+Reiter referred the case to the FBI to determine whether
+there were federal law violations.
+After a spate of stories about the case last week, New York
+publicist Dan Klores - whose client list has included Paris
+Hilton and Jennifer
+- said on Saturday that Epstein's
+camp was ready "to get their story out."
+They did that Monday via Goldberger and a Los Angeles
+publicist for Miami criminal defense attorney Roy Black,
+who also has represented Epstein in the case.
+"We just think there has been a distorted view of this case
+in the media presented by the Palm Beach police,"
+Reiter has consistently declined to comment on the case
+and did not respond to a request for comment Monday.
+The implication that State Attorney Barry Krischer was
+easy on Epstein by presenting the case to a grand jury
+rather than filing charges directly against him is wrong,
+
+
+The Palm Beach Police Department was "happy and
+ecstatic" that the panel was going to review the evidence. "I
+think what happened is they weren't happy with the result.
+They decided to use the press to embarrass Mr. Epstein."
+But records show that Reiter wrote Krischer on May 1 -
+well before the case went to the grand jury - suggesting that
+Krischer "consider if good and sufficient reason exists to
+require your disqualification from the prosecution of these
+cases."
+Rather than flat-out decline to charge Epstein, Krischer
+referred the case to the grand jury to "appease" the chief,
+A state attorney's spokesman would say only that the office
+refers cases to the grand jury when there are issues with the
+viability of the evidence or witnesses' credibility.
+Both the state attorney and the grand jury concluded there
+was not sufficient evidence that Epstein had sex with
+minors, according to Goldberger. "It was just a childish
+performance by the Palm Beach Police Department,"
+The defense attorney said one of the alleged victims who
+claimed she was a minor was in fact over the age of 18.
+Another alleged victim who was subpoenaed to testify to
+the grand jury failed to do so. Epstein's accusers, he added,
+have histories of drug abuse and thefts. "These women are
+liars. We've established that."
+But why would they all invent their stories about meeting
+Epstein for sexual massages?
+"I don't have an answer as to what was the motivation for
+these women to come forward and make these allegations,"
+Goldberger said,
+
+
+The Palm Beach Post (West Palm Beach, Florida) • 14 Aug 2006, Mon - Page 7
+Downloaded on Nov 11, 2019
+Palm Bearh chief focus
+, of lin: in Epstein cast
+COPY
+Reiter focus of fire in Epstein case
+Clipped By:
+reiter_m
+Sat, Apr 22, 2017
+Copynght @ 2019 Newspapors.Com. All Rights Reserved.
+NO
+
+
+Delays in Epstein case unusual,
+lawyers say
+Posted Mar 13, 2007 at 12:01 AM
+Updated Oct 3, 2019 at 3:48 PM
+(EDITORS NOTE: This story originally published in The Palm
+Beach Post March 13, 2007)
+A federal probe or a plea deal could explain the wait in the
+Palm Beacher's solicitation case.
+Neariy eight months after Palm Beach tycoon Jeffrey
+Epstein was charged with felony solicitation of prostitution,
+there has been no discernible progress in his case. No
+witnesses deposed. No trial date set. Nothing, save for
+routine court hearings reset without explanation.
+"Usually that would be unusual, said criminal defense
+attorney Glenn Mitchell, who has no involvement in the
+case.
+"As a general rule, it would be unusual for nothing to have
+happened," agreed Michael Dutko, a criminal defense
+attorney in Fort Lauderdale. He represents
+20, of
+Palm Beach, potentially a key witness in the
+case.
+A routine hearing for Epstein was pulled from the court
+docket last week and reset for May 16. The delays and
+inaction could be due to a potential federal probe of Epstein
+or because a plea deal is in the works, attorneys say.
+Unusual is the word that best describes everything about
+the case against Epstein, 54, an enigmatic money manager
+in New York City who counts Bill Clinton and Donald
+Trump among his friends.
+
+
+"Highly unusual" is how Palm Beach Police Chief Michael
+Reiter described State Attorney Barry Krischer's handling
+of the case in a bluntly critical letter to Krischer last year
+before Epstein was indicted.
+Reiter referred the matter to the FBI to determine whether
+any federal laws had been violated. Epstein's allies
+countered by attacking the chief personally and
+professionally.
+Reiter's department investigated Epstein for 11 months.
+Police sifted repeatedly through his trash and conducted
+surveillance on his five-bedroom, 7 1/2-bath, 7,234-squarefoot home on the Intracoastal Waterway.
+Police said Epstein paid women and girls as young as 14 to
+give him erotic massages at his home. Police thought there
+was probable cause to charge him with unlawful sex acts
+with a minor and lewd and lascivious molestation.
+Epstein responded by hiring a phalanx of lawyers. One of
+them, Harvard law professor and author Alan Dershowitz,
+provided the state attorney's office with information about
+alcohol and marijuana use by some of the girls who said
+they were with Epstein.
+Prosecutors then referred the case to the grand jury rather
+than file charges directly against Epstein.
+Epstein's attorneys deny he had sex with underage girls.
+The lawyers say the girls' stories are not credible. But if the
+court file is any indicator, they've made no effort to depose
+the girls.
+Neither prosecutors nor defense attorneys have sought to
+question
+1, said Dutko, her attorney. She recruited
+teenage girls to visit Epstein for massages and sexual
+activity, Palm Beach police said, and presumably would be a
+key witness.
+
+
+Epstein's attorney Jack Goldberger did not return phone
+messages.
+A source close to the case suggested it is languishing
+pending a decision by the FBI on whether to refer it to
+federal prosecutors.
+"We still have a pending case," FBI spokeswoman Judy
+Orihuela said Monday.
+State Attorney Krischer did not return a call for comment.
+His spokesman, Mike Edmondson, declined to say whether
+federal investigators are delaying the Epstein case. But, he
+added, "if another agency is looking at something, we
+wouldn't want to step on their toes."
+Attorneys say inertia in a criminal case often points to a
+pending plea deal
+"It would not surprise me if something has happened that's
+not reflected in the court file,"
+said Dutko, such as an
+agreement that will be formalized later.
+Defense attorney Marc Shiner said defense attorneys
+sometimes put off overtly conducting discovery -- deposing
+witnesses, requesting documents and the like -- because
+doing so creates more work for harried prosecutors who
+may become angry and not offer a plea deal.
+"Sometimes defense lawyers, knowing that, will try and do
+discovery without taking depositions," said Shiner, a former
+prosecutor for 13 years.
+Instead, they may conduct a below-the-radar probe such as
+having a private investigator check out leads, he said.
+Shiner and others say a plea deal for Epstein probably
+would result in pretrial intervention, in which a defendant
+may be ordered to undergo a psychological evaluation,
+counseling or other conditions in return for dropping the
+charge.
+
+
+Edmondson, spokesman for State Attorney Krischer, said
+there is no plea offer and no request for the prosecution to
+show its cards.
+"To my knowledge, it's never happened before on a filed
+case," he said.
+
+
+252 / 278 - Thursday, October 18, 2007
+Section: LOCAL
+Page: 5B
+Source: The Associated Press
+Illustration: PHOTO (B&W)
+Memo: Ran all editions.
+Dateline: NEW YORK
+WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
+A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
+prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model.
+The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein had
+the teen perform a sex act when she brought photographs of herself for him to review in his Upper
+East Side mansion sometime in 2000.
+Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
+you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
+included massages and other favors.
+When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I
+won't tell anybody," court papers say.
+Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
+indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.
+The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
+sex acts" while she was a minor, the lawsuit says.
+Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
+stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
+40s). I love girls your age.'"
+The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
+lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
+of severe mental disease and defect."
+Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
+read a newspaper and recognize the word 'rich.""
+Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly,
+and will almost certainly be dismissed.
+He refused to comment on Epstein's Florida charges.
+Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center
+of a $10 million lawsuit he filed last year against a neighbor who said he was having sex with
+underage girls. That case is pending.
+"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said
+Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve
+the case out of court.
+
+
+REAL HEWS STARTS HERE
+Palm Beacher pleads in sex case
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 3, 2019 at 1:47 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on July 1, 2008)
+Jeffrey Epstein will serve 1 1/2 years on teen solicitation
+charges.
+He lives in a Palm Beach waterfront mansion and has kept
+company with the likes of President Clinton, Prince
+Andrew and Donald Trump, but investment banker Jeffrey
+Epstein will call the Palm Beach County Jail home for the
+next 18 months.
+Epstein, 55, pleaded guilty Monday to felony solicitation of
+prostitution and procuring a person under the age of 18 for
+prostitution. After serving 18 months in jail, he will be
+under house arrest for a year. And he will have a lifelong
+obligation to register as a sex offender. He must submit to
+an HIV test within 48 hours, with the results being
+provided to his victims or their parents.
+As part of the plea deal, federal investigators agreed to drop
+their investigation of Epstein, which they had taken to a
+grand jury, two law enforcement sources said.
+Epstein was indicted two years ago after an 11-month
+investigation by Palm Beach police. They received a
+complaint from a relative of a 14-year-old girl who had
+given Epstein a naked massage at his five-bedroom, 7,234-
+square-foot, $8.5 million Intracoastal bome.
+Police concluded that there were several other girls brought
+in 2004 and 2005 to an upstairs room at the home for
+similar massages and sexual touching.
+
+
+The indictment charged Epstein only with felony
+solicitation of prostitution. The state attorney's office later
+added the charge of procuring underage girls for that
+purpose.
+Prosecutor Lanna Belohlavek said of the plea: "I took into
+consideration the length the trial would have been and
+witnesses having to testify" about sometimes embarrassing
+incidents.
+Epstein may have made a serious mistake soon after he was
+charged. He rejected an offer to plead guilty to one count of
+aggravated assault with intent to commit a felony,
+according to police documents. He would have gotten five.
+years' probation, had no criminal record and not been a
+registered sex offender, the documents indicate.
+Epstein arrived in court Monday with at least three
+attorneys. He wore a blue blazer, blue shirt, blue jeans and
+y and gray sneakers. After Circuit Judge Deborah Dale
+Pucillo accepted the plea, he was fingerprinted. Epstein
+then removed his blazer and was handcuffed for the trip to
+jail while his attorneys tried to shield him from
+photographers lenses.
+When he eventually is released to house arrest, Epstein will
+have to observe a 10 p.m. to 6 a.m. curfew, have no
+unsupervised contact with anyone younger than 18 and
+neither own nor possess pornographic or sexual materials
+"that are relevant to your deviant behavior," the judge said.
+Epstein will be allowed to leave home for work. The New
+York-based money manager told the judge he has formed
+the not-for-profit Florida Science Foundation to finance
+scientific research. "I'm there every day," Epstein said.
+The foundation was incorporated in November. Epstein
+said he already has awarded money to Harvard and MIT.
+
+
+When he is released from jail, there is a chance that Epstein
+will be forced to move. Sex offenders are not allowed to live
+within 1,000 feet of a school, park or other areas where
+children may gather. No determination has been made as to
+whether Epstein's home complies, but attorneys said it
+likely does.
+Sex offenders also typically must attend counseling sessions.
+Belohlavek said that was waived for Epstein because his
+private psychiatrist is working with him. The judge was
+skeptical but agreed to it.
+Epstein's legal woes don't end with Monday's plea. There
+are four pending federal civil lawsuits and one in state court
+related to his behavior. At least one woman has sued him in
+New York, where he owns a 51,000-square foot Manhattan
+mansion.
+"It's validation of what we're saying in the civil cases," said
+Miami attorney Jeffrey Herman, who represents the alleged
+victims in the federal lawsuits. West Palm Beach attorney
+Ted Leopold represents one alleged victim in a civil suit in
+state court. He said he anticipates amending that lawsuit to
+add "a few other clients" as well.
+In the criminal case, police went so far as to scour Epstein's
+trash and conduct surveillance at Palm Beach International
+Airport, where they watched for his private jet so they
+would know when he was in town. They concluded that
+Epstein paid girls $200 to $300 each after the massage
+sessions.
+"I'm like a Heidi Fleiss,"
+about her efforts in recruiting girls for Epstein.
+I, now 22, told police
+There was probable cause to charge Epstein with unlawful
+sex acts with a minor and lewd and lascivious molestation,
+police concluded
+
+
+The state attorney's office said questions about the girls'
+credibility led it to take the unprecedented step of
+presenting the evidence against Epstein to a grand jury,
+rather than directly charging him.
+Palm Beach Police Chief Michael Reiter was furious with
+State Attorney Barry Krischer, saying in a May 2006 letter
+that the prosecutor should disqualify himself. "I continue to
+find your office's treatment of these cases highly unusual,"
+he wrote. He then asked for and got a federal investigation.
+Epstein hired a phalanx of high-priced lawyers - including
+Harvard law professor and author Alan Dershowitz - and
+public relations people who questioned Reiter's competence
+and the victims' truthfulness.
+In addition to mansions in Palm Beach and Manhattan,
+Epstein owns homes in New Mexico and the Virgin Islands.
+He's a frequent contributor to Democratic Party candidates.
+He also donated $30 million to Harvard in 2003.
+Former New York Gov. Eliot Spitzer returned a $50,000
+campaign contribution from Epstein after his indictment,
+then resigned this year during his own sex scandal. And the
+same Palm Beach Police Department that vigorously
+investigated Epstein returned his $90,000 donation for the
+purchase of a firearms simulator.
+Staff writer Eliot Kleinberg and former staff researcher
+Michelle Quigley contributed to this story.
+
+
+Jeffrey Epstein: Scientist,
+stuntman, 'sex slave' visit jailed
+tycoon
+By LARRYL
+R / Palm Beach Post Staff Writer
+Posted Aug 13, 2008 at 12:01 AM
+Updated Jul 16, 2019 at 4:54 PM
+Tycoon Jeffrey Epstein mingled with an eclectic mix of
+people, including beautiful young women, before he got
+into trouble for paying teenage girls to give him sexual
+massages at his Palm Beach mansion.
+Not much has changed, even though he now resides in a
+dorm at the Palm Beach County Sheriff's Office's 17-acre,
+967-bed stockade near the fairgrounds.
+During his first month of confinement, Epstein was visited
+by the female assistant who, girls told police, had escorted
+them to the room at his mansion where they gave him
+naked massages.
+Also trekking to the jail was a young woman whom Epstein
+purportedly described as his Yugoslavian sex slave.
+The wealthy financier and science wonk also has been
+visited by an expert on artificial intelligence, as well as a
+man who is a mixed martial arts aficionado and sometime
+movie stuntman.
+The only other people to visit him at the jail, according to
+records, are al
+- Island man and an individual who
+listed Epstein's Palm Beach address as his own.
+Epstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,
+followed by a year of house arrest. Epstein paid teenage
+
+
+girls $200 to $300 in 2004 and 2005 for massages in his
+home that sometimes included sexual touching, Palm Beach
+police said.
+His jail visitors in July included:
+29, who some of the teen masseuses said
+phoned them when Epstein was in town and escorted them
+upon their arrival at his Palm Beach waterfront home to an
+upstairs room, where she prepared the massage table and
+provided the oils for their encounters with him.
+visited Epstein three times in July, according to a jail
+visitor's log.
+lists a Manhattan home address.
+Reached by telephone, she declined to discuss Epstein:
+Op
+23, whose family in Yugoslavia
+Epstein paid money to so that he could bring her to the
+United States to be his "sex slave," two teenage girls told
+police. One girl told police that Epstein instructed
+and her to kiss and have sex while he watched
+and masturbated. Another said she engaged in sex with
+at Epstein's urging.
+visited Epstein
+in jail four times in 13 days. She lists her address as on the
+Upper East side of Manhattan, not far from Epstein's
+enormous apartment.
+- Roger Schank, 62, founder of the Institute for Learning
+Sciences at Northwestern University and an expert on
+artificial intelligence, paid one visit to Epstein. Schank has
+written numerous books on that subject and has a doctorate
+degree from Yale University in linguistics. He was one of 19
+people who applied to be president of Florida Atlantic
+University in 2003. He became "chief learning officer" at the
+online Trump University in 2005. Schank listed his address
+as being in Stuart, and records show he also owns a home
+in Lake Worth.
+
+
+Epstein has financed a number of scientists over the years,
+including Nobel Prize winners. He gave $30 million to
+Harvard University in 2003. In November, he formed the
+not-for-profit Florida Science Foundation, which he said
+finances scientific research.
+- Igor Zinoviev, a Russian mixed martial arts fighter, who
+coaches a Chicago team in the International Fight League.
+He also has worked as a personal trainer, celebrity
+bodyguard and movie stuntman, according to the league's
+Web site. The New Jersey resident visited Epstein seven
+times in July.
+Zinoviev, Schank and I
+comment.
+could not be reached for
+Staff researcher Niels
+Heimeriks
+contributed to this story.
+
+
+Billionaire sex offender leaves jail
+six days a week for work
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 4, 2019 at 9:27 AM
+Palm Beach billionaire Jeffrey Epstein, who's serving 18
+months in jail for soliciting an underage girl for
+prostitution, is allowed to leave the Palm Beach County
+Stockade six days a week on a work-release program.
+Os
+Teri Barbera, spokeswoman for the Palm Beach County
+Sheriff's Office, confirmed that Epstein, 55, has been in the
+work-release program since Oct. 10.
+"He works six days a week: Friday through Wednesday 10
+a.m. to 10 p.m.," Barbera said vía e-mail. "(He) works at his
+local West Palm Beach office, monitored on an active GPS
+system (he wears an ankle bracelet). Mr. Epstein hires a
+permit deputy, at his expense, for his own security at his
+workplace during the time he is out."
+Miami attorney Jeffrey Herman represents six young
+women who've sued Epstein, claiming he sexually abused
+them at his Palm Beach home when they were minors.
+Herman said he received a letter about the work-release
+program from the U.S. Attorney's Office within the past
+few days. But Herman says Epstein had been out on workrelease for several weeks before the notification.
+"My clients expressed shock and disappointment," Herman
+said. "I find it incredible that he's on work-release in the
+community and my clients aren't notified of this and we get
+this letter weeks after the fact."
+Jack Goldberger, Epstein's criminal attorney, said the
+
+
+arrangement is not unusual.
+"He goes to work every single day and goes back to jail at
+night, just like everybody else (in the program),"
+Epstein pleaded guilty June 30 to two felony counts:
+soliciting prostitution and procuring a person under 18 for
+prostitution. As part of the plea agreement, Epstein must
+serve one year of house arrest and register as a lifelong sex
+offender.
+
+
+Women want Epstein sex plea deal
+unsealed
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:23 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post June 10, 2009)
+Their attorneys will ask a judge to open Jeffrey Epstein's
+records.
+When wealthy money manager Jeffrey Epstein of Palm
+Beach pleaded guilty last year to procuring teens for
+prostitution, his case detoured around local and state rules
+regarding the sealing of court documents.
+At a plea conference on the state charges, a judge, a defense
+lawyer and a prosecutor huddled at the bench and decided
+that a deal Epstein had struck with federal prosecutors to
+avoid charges should be sealed, according to a transcript of
+the hearing.
+And so it was.
+But Florida rules of judicial administration, as well as rules
+of the Palm Beach County court system, require public
+notification that a court document has been or will be
+sealed, meaning kept from public view. The rules also
+require a judge to find a significant reason to seal, such as
+protecting a trade secret or a compelling government
+interest.
+Yet no notification or reason occurred in Epstein's case,
+according to court records.
+
+
+Epstein's own attorneys, in federal filings, have referred to
+his confidential deferred prosecution agreement with the
+U.S. attorney's office, struck in September 2007, as
+"unprecedented" and "highly unusual." And it was "a
+significant inducement" for Epstein to accept the state's
+deal, observed the state judge who accepted his plea,
+County Judge Deborah Dale Pucillo.
+Epstein now faces at least a dozen civil lawsuits in federal
+and state courts filed by young women who said they had
+sex with him and now are seeking damages.
+Attorneys for some of those women want his agreement
+with federal prosecutors unsealed and will ask Circuit Judge
+Jeffrey Colbath to do so today.
+"It is against public policy for these documents to be have
+been sealed and hidden from public scrutiny. As a member
+of the public, E. W. has a right to have these documents
+unsealed," wrote former Circuit Judge Bill Berger, now in
+private practice and representing one of the women.
+The Palm Beach Post also will ask Colbath to unseal the
+agreement. Post attorney Deanna Shullman will argue that
+the public has a right to know the specifics of Epstein's deal.
+According to various media accounts, Epstein moved in
+circles that included President Clinton, Donald Trump and
+Prince Andrew. "International Moneyman of Mystery,"
+declared a 2002 New York magazine profile of Epstein.
+Epstein, 56, is in the Palm Beach County Stockade, serving
+an 18-month sentence after pleading guilty nearly a year
+ago to felony solicitation of prostitution and procuring
+teenagers for prostitution.
+He is allowed out from 7 a.m. to 11 p.m., escorted by a
+deputy, said Palm Beach County Sheriff's Office
+spokeswoman Teri Barbera.
+
+
+During a Palm Beach Police Department investigation, five
+victims and 17 witnesses gave statements. They told of
+young women brought by his assistants to Epstein's
+mansion on El Brillo Way for massages and sexual activity,
+and then being paid afterward
+At Epstein's plea conference last year, his attorney, Jack
+Goldberger, and then-Assistant State Attorney Lanna
+Belohlavek approached Pucillo in a sidebar conference.
+Pucillo, who had left the bench nine years earlier, was
+filling in temporarily as a senior judge.
+According to a transcript, Goldberger told Pucillo that
+Epstein had entered a confidential agreement with the U.S.
+attorney's office in which federal prosecutors brokered not
+pursuing charges against him if he pleaded guilty in state
+court. Pucillo then said she wanted a sealed copy of the
+agreement filed in his case, and Goldberger concurred that
+he wanted it sealed. Belohlavek later signed off on it.
+The Florida Supreme Court has expressed "serious concern"
+and launched an all-out inquiry into sealing procedures
+across the state following media reports in 2006 of entire
+cases being sealed and disappearing from court records.
+"The public's constitutional right of access to court records
+must remain inviolate, and this court is fully committed to
+safeguarding this right," justices wrote in their final report.
+Epstein's office on Tuesday referred any questions to
+Goldberger, who declined to comment. Pucillo also has
+declined to comment.
+
+
+Epstein secret pact with Feds
+reveals "highly unusual" terms
+Posted Jun 10, 2009 at 12:01 AM
+Updated Oct 4, 2019 at 9:23 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on September 19, 2009)
+A secret non-prosecution agreement multimillionaire
+financier Jeffrey Epstein struck with federal prosecutors is
+being called "highly unusual" by former federal prosecutors
+and downright outrageous by attorneys now representing
+young women who serviced him.
+The deal reveals that the FBI and the U.S, Attorney's Office
+investigated him for several federal crimes, including
+engaging minors in commercial sex. The crimes are
+punishable by anywhere from 10 years to life in prison.
+But federal prosecutors backed down and agreed to recall
+grand jury subpoenas if Epstein pleaded guilty to
+prostitution-related felonies in state court, which he
+ultimately did. He received an 18-month jail sentence, of
+which he served 13 months.
+The U.S. Attorney's Office also agreed not to charge any of
+Epstein's possible co-conspirators:
+1, Lesley Groff and
+The deal was negotiated in part by heavyweight New York
+criminal defense attorney Gerald Lefcourt.
+Unsealed on Friday after attorneys for some of Epstein's
+victims and The Palm Beach Post sought its release, it offers
+the first public look at the deal Epstein's high-powered legal
+counsel brokered on his behalf.
+
+
+Mark
+p of Stuart, a former federal prosecutor,
+described the disparity in potential sentences as unusual,
+but even more so a provision on attorney payment.
+The first draft of the agreement in September 2007
+required that Epstein pay an attorney -- tapped by the U.S.
+Attorney's Office and approved by Epstein -- to represent
+some of the victims. That attorney is prominent Miami
+lawyer Bob Josefsberg.
+But an addendum to the agreement signed the following
+month struck Epstein's duty to pay Josefsberg if he and the
+victims did not accept settlements -- capped at $150,000--
+and instead pursued lawsuits.
+said it appears the government was trying to
+balance the lesser sentence for Epstein with recovering
+$150,000 for each victim. "I've never, ever seen anything
+like that in my life," he said. "It's highly unusual."
+The deal does not say whether any victims were contacted
+or consulted before the deal was made.
+Attorney Brad Edwards of Fort Lauderdale, who represents
+three of the young women, believes that none of the 30 to
+40 woman identified as victims in the federal investigation
+were told ahead of time.
+i said his clients received
+letters from the U.S. Attorney's Office months after the deal
+was signed, assuring them Epstein would be prosecuted.
+"Never consulting the victims is probably the most
+outrageous aspect of it,"
+said. "It taught them that
+someone with money can buy his way out of anything. It's
+outrageous and embarrassing for United States Attorney's
+Office and the State Attorney's Office."
+Epstein now faces many civil lawsuits filed by the women,
+who are represented by a variety of attorneys. In many, the
+allegations are the same: that Epstein had a predilection for
+teenage girls, identified poor, vulnerable ones and used
+
+
+other young women to lure them to his Palm Beach
+mansion. They walked away with between $200 and
+$1,000.
+Former Circuit Judge Bill Berger, also representing victims,
+called the agreement a "sweetheart deal."
+"Why was it so important for the government to make this
+deal?" Berger asked rhetorically. "We have not yet had an
+honest explanation by any public official as to why it was
+made . and why the victims were sold down the river."
+Former federal prosecutor Ryon McCabe described the
+agreement as "very unorthodox." Such agreements, he said,
+are usually reserved for corporations, not individuals.
+"It's very, very rare. I've never seen or heard of the
+procedure that was set up here," said McCabe, who has no
+involvement in any Epstein litigation.
+"He's essentially avoiding federal prosécution because he
+can afford to pay that many lawyers to help those victims
+review their cases. ... If a person has no money, he couldn't
+be able to strike a deal like this and avoid federal
+prosecution."
+The backroom deal with federal prosecutors is all the more
+interesting in light of the legal powerhouses who have
+worked for Epstein, including Harvard professor Alan
+Dershowitz and Bill Clinton investigator Kenneth Starr.
+Lefcourt is a past president of the National Association of
+Criminal Defense Lawyers.
+Epstein's local defense attorney, Jack Goldberger, issued a
+statement Friday saying he had fought the release of the
+sealed agreement to protect the third parties named there.
+"Mr. Epstein has fully abided by all of its terms and
+conditions. He is looking forward to putting this difficult
+period in his life behind him. He is continuing his longstanding history of science philanthropy."
+
+
+The investigation triggered tensions between police and
+prosecutors, with then-Palm Beach Chief Michael Reiter
+saying in a May 2006 letter to then-State Attorney Barry
+Krischer that the chief prosecutor should disqualify himself.
+"I continue to find your office's treatment of these cases
+highly unusual, " Reiter wrote. He then asked for and got
+the federal investigation that ended in the sealed deal.
+"The Jeffrey Epstein matter was an experience of what a
+many-million-dollar defense can accomplish," Reiter told
+the Palm Beach Daily News upon his retirement.
+
+
+187 / 278 - Wednesday, January 27, 2010
+Section: LOCAL & BUSINESS
+Page: 3B
+Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
+Dateline: WEST PALM BEACH
+JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
+Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
+the women's claims that they suffered psychological ills after being paid to give him
+sexually-charged massages at his Palm Beach mansion when they were as young as 14.
+Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
+he said, can't be sought until the women are asked whether they have ever had an abortion,
+how many and where. Further, he said, the records would not be made public and might not
+be admissible during trial.
+But, he said, since the women claim Epstein, now 57, is responsible for their emotional
+distress, his attorneys can explore the impact of other events. Medical records, Hafele said,
+are a better source of information than a person's memory.
+Attomey Louis Silver, who represents the Presidential Women's Health Center, a West Palm
+Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky
+constitutional grounds.
+"These records are protected by our constitutional right of privacy," he said, referring to the
+Florida Constitution.
+After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the
+records.
+In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
+can't be released without a court order. The ruling came after Epstein attorney Robert Critton
+complained that a video of Epstein being asked whether he had an "egg-shaped" penis
+became a youtube.com sensation. It first appeared on The Palm Beach Post Web site.
+Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record.
+he civil suits began mounting after Epstein agreed to plead guilty to two state charge:
+rocuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18
+month sentence. As part of the deal brokered with federal prosecutors, he agreed not to
+contest the accusations in the civil lawsuits. He can argue the women don't deserve the
+millions they are seeking.
+~jane_musgrave@pbpost.com
+
+
+REAL HEWS STARTS HERE
+Epstein Journal's Findings Could
+Resurrect Case
+By Jane Musgrave
+Posted Sep 17, 2019 at 12:01 AM
+Updated Oct 1, 2019 at 10:51 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on March 20, 2010)
+"hundreds" of victims of convicted sex offender Jeffrey
+Epstein could be used to reopen the investigation into the
+multi-millionaire's appetite for teenage girls, an attorney
+representing seven of the victims said Friday.
+New details about the contents of the journal were released
+this week when Alfredo Rodriguez, who worked as a
+property manager for the Palm Beach resident, pleaded
+guilty to obstruction of justice for lying to federal agents
+when asked if he had any information about his former
+boss' criminal activity. He later tried to sell the journal he
+stole from Epstein for $50,000 to an unidentified person,
+who alerted authorities, according to court records.
+As part of the plea agreement, federal prosecutors said the
+journal "contains information material to the Epstein
+investigation, including the names of material witnesses
+and additional victims."
+"Had the items been produced in response to the inquiries
+of state or federal authorities... the materials would have
+been presented to the federal grand jury," federal
+prosecutors wrote.
+
+
+Instead, prosecutors short-circuited the grand jury
+investigation and cut a deal with Epstein. They agreed not
+to pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded
+guilty in July 2008 to procuring a minor for prostitution
+and soliciting prostitution. He served 13 months of an 18-
+month sentence.
+Attorney Adam Horowitz, who represents seven of the
+roughly 18 women who have filed civil suits against
+Epstein, said the new information could trump the socalled non-prosecution agreement.
+The multifaceted agreement, he said, deals only with a
+specific list of victims that the U.S. Attorney's Office knew
+about when it penned the deal in 2007. If additional victims
+are listed in the journal Rodriguez stole, Horowitz said
+federal prosecutors could reopen the investigation.
+"It opens the door for further prosecution," he said.
+In addition to turning over the journal to federal agents,
+Rodriguez told them he knew his former boss was having
+sex with underage gils when he worked for him in 2004
+and 2005. He had seen naked girls, who looked like minors,
+in the pool of Epstein's $8.6 million mansion. He had seen
+pornographic images of young girls on Epstein's computer,
+according to court records.
+Neither Epstein's criminal defense attorney, Jack
+Goldberger, nor attorney Robert Critton, who represents
+Epstein in the civil lawsuits, could be reached. Federal
+prosecutors have consistently declined comment.
+The wording of the controversial agreement is unclear. It
+says federal prosecutors would provide Epstein's attorneys
+"with a list of individuals whom it has identified as victims."
+Miami attorney Robert Josefsberg was appointed to
+
+
+represent any of the victims on the list who wanted to
+pursue Epstein in civil court. As part of the agreement,
+Epstein is to pay for Josefsberg to represent the women.
+Some of the women, most identified as Jane Doe in
+lawsuits, had already hired attorneys to represent them.
+Some have since settled their suits with Epstein, although
+terms were not disclosed.
+Horowitz said he has filed court papers to get the journal
+that Rodriguez stole. "It's another piece of evidence that
+shows our clients were at Epstein's mansion," he said.
+Rodriguez told prosecutors he didn't turn over the journal
+when both FBI and Palm Beach police asked for it because
+he wanted money for it. He also said he was afraid Epstein
+would make him "disappear." The information, he told
+investigators, was his "insurance policy.
+He faces a maximum 20 years in prison when he is
+sentenced on June 18.
+jane_musgrave@pbpost.com
+NOT
+
+
+Epstein paid three women $5.5 million to end underagesex lawsuits
+By Jane Musgrave
+Posted Oct 3, 2017 at 12:01 AM
+Updated Oct 4, 2017 at 12:46 AM
+Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young
+women who claimed he used them as sex toys, court documents filed last week show he shelled
+out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.
+Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the
+sex scandal, attorney
+said the politically-connected 64-year-old convicted sex
+offender paid more than $1 million to each of the three women
+§ represented.
+Identified in court papers only by their initials or pseudonyms because of the nature of the
+allegations and their youthful ages, L.M. was paid $1 million, E. W. $2 million and Jane Doe
+$2.5 million,
+said of the settlements he negotiated with Epstein to end the lawsuits.
+Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on
+the revelations, citing confidentiality agreements that were part of the settlements. For the
+same reason, he declined to say whether Epstein paid similar amounts to settle roughly two
+dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
+when some were as young as 14 years old.
+Attorney Jack Scarola, who is representing L
+, said his client was compelled to divulge
+the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move
+on their part," he said.
+Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have
+likely come out. He says the information will help him undermine Epstein's claims that
+"ginned up" the allegations to help his former law partner, imprisoned and disbarred
+Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
+
+
+•The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
+between Epstein and Rothstein, both billionaires.
+A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
+minor for prostitution, he sued Rothstein and
+claiming they trumped up the
+allegations of sexual molestation to perpetuate the Ponzi scheme.
+Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
+successful law firm by forging the names of federal judges and others to persuade investors he
+had negotiated settlements in lawsuits against high-profile people. Investors were told they
+could get a cut of the cash.
+One of the high-profile people Rothstein used to lure investors was Epstein, according to a
+Lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the
+lawsuit, Rothstein told investors Epstein, a money manager, had agri
+to settle the lawsuits
+with the teens for $200 million — a claim Critton described as "a complete fabrication."
+After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him. 1
+accused
+Epstein of filing the lawsuit maliciously to punish him for representing the young women.
+Although ]
+was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
+no evidence
+was involved in the Ponzi scheme. Federal prosecutors successfully
+charged other attorneys and members of the firm, but
+was never implicated, Scarola
+said in the malicious prosecution lawsuit.
+The revelations about the money Epstein paid to three of the young woman came last week in
+documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
+Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
+trial, in part, because she claimed she has been unable to talk to her client since his estate on his
+private island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had
+no ability to communicate with Mr. Epstein," she said.
+
+
+Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge
+Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those
+victimized by the storm that hammered the Caribbean and roared through South Florida, he
+said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
+Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
+before the case goes to trial.
+Despite Scarola's insistence that
+had nothing to do with Rothstein's Ponzi scheme,
+Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's
+well-known friends, such as now President Donald Trump, former President Bill Clinton and
+illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
+"The Epstein cases were used to fleece money and defraud investors," she said.
+Edward's malicious prosecution case has been difficult for both sides because both Epstein and
+have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
+his Fifth Amendment right against self-incrimination when questioned by Scarola.
+has claimed that much of the information Epstein is seeking is protected by attorney-client
+privilege.
+The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit
+against Epstein.
+¡ also is suing the U.S. attorney's office, claiming it violated
+the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
+Epstein.
+Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
+plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court
+records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's
+agreement to settle lawsuits filed against him by dozens of his underage victims.
+
+
+Judge rules feds' agreement with
+Jeffrey Epstein pact violated teen
+victims' rights
+By Jane Musgrave
+Posted Sep 17, 2019 at 4:02 PM
+Updated Oct 8, 2019 at 12:31 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on February 22, 2019)
+OPY
+Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims by failing to reveal they had dropped plans
+to prosecute the billionaire on dozens of federal charges in
+connection with the girls' claims that he paid them for sex
+at his Palm Beach mansion, U.S. District Judge Kenneth
+Marra ruled on Thursday.
+In a blistering 33-page ruling, Marra meticulously and
+methodically detailed the numerous steps federal
+prosecutors took to hide the agreement from more than 40
+young women who claim Epstein paid them for sex when
+they were as young as 14.
+"While the government spent untold hours negotiating the
+terns and implications of the NPA with Epstein's attorneys,
+scant information was shared with the victims," Marra
+wrote. "Instead, the victims were told to be 'patient while
+the investigation proceeded."
+By then, it was too late. A deal had already been cut with
+then-South Florida U.S. Attorney Alex Acosta and Epstein's
+attorneys to shelve a 52-page federal indictment against
+Epstein, a former math teacher turned money manager
+who counts Presidents Donald Trump and Bill Clinton
+among his friends.
+
+
+Prosecutors' failure to alert the young women about the
+deal violated the Crime Victims' Rights Act, Marra ruled.
+"At a bare minimum the (act) required the government to
+inform (the young women) that it intended to enter into an
+agreement not to prosecute Epstein," he wrote.
+Still, Marra said he wasn't second-guessing prosecutors'
+decision not to pursue Epstein on federal charges if he
+pleaded guilty to minor state prostitution charges and
+agreed to compensate his victims for the trauma he caused.
+"The court is not ruling that the decision not to prosecute
+was improper," Marra wrote. "The court is simply ruling
+that, under the facts of this case, there was a violation under
+the CVRA."
+Further, he made no decision about what, the remedy
+should be. He gave prosecutors and attorneys répresenting
+the young women 15 days to meet to decide how to unravel
+the complex legal web that has been hanging over Epstein
+and his young victims for more than a decade.
+The chances an accord will be reached are slim, said
+attorney Jack Scatola, who is representing the two Jane
+Does who challenged the prosecutors' actions.
+Further, he said, there is no road map to follow. The
+lawsuit attorney
+filed on behalf of the two
+unidentified young women, claiming prosecutors violated
+the federal act, is unique, he said.
+"We are treading on virgin ground, to use what is probably
+an inappropriate phrase in this situation," he said.
+Scarola said he and
+will ask that the nonprosecution agreement be thrown out. That would open
+the possibility that the long-shelved federal indictment
+could be dusted off and filed against the 66-year-old
+Epstein, who spends most of his time on a private island he
+owns in the U.S. Virgin Islands.
+
+
+"I don't see the government conceding to that remedy,"
+Scarola admitted. Further, he said, it is likely Epstein will be
+allowed to weigh in. Miami attorney Roy Black years ago
+filed papers asking to intervene on Epstein's behalf.
+The U.S. Attorney's Office said it wouldn't comment on
+Marra's ruling. Neither Black nor New York City attorney
+Jay Lefkowitz, who led efforts to bury the federal
+indictment, responded to emails or phone calls for
+comment. West Palm Beach attorney Jack Goldberger, who
+represents Epstein, also didn't respond.
+Scarola said it is likely Epstein's star-studded legal team will
+argue that Epstein fully complied with the terms of the
+agreement he made in 2007 with federal prosecutors and
+therefore the agreement can't be undone.
+As he promised, Epstein pleaded guilty in June 2008 to state
+charges of soliciting a minor for prostitution and soliciting
+prostitution. He served 13 months of an 18-month jail term
+in a vacant wing of the county stockade that he was allowed
+to leave 12 hours a day, six days week.
+Further, as agreed, he paid settlements to the young women
+who sued him. While the settlements were confidential,
+court records show he paid three women a total of $5.5
+million.
+In return, federal prosecutors held up their end of the
+bargain. Their investigation ceased.
+Having done all that prosecutors asked of him, Scarola said
+Epstein will make a simple argument: "You can't turn
+around and deprive me of the benefits I bargained for."
+However, Scarola said, using Marra's ruling, he will counter
+that the contract Epstein signed was illegal and therefore
+unenforceable.
+
+
+Even if Marra agrees to toss out the non-prosecution
+agreement, Scarola conceded that doesn't mean Epstein will
+face federal charges.
+'The contract can be set aside and the federal government
+can attempt to enter into the same agreement," he said.
+"Except the spotlight of public attention will be on them
+and the 40 victims will be able to explain to the court why
+this sweetheart deal should not be approved."
+Scarola said that prosecutors may have had good reason not
+to pursue Epstein. "There may be a reasonable explanation
+but we don't know what that reason may have been," he
+said.
+In court papers, federal prosecutors have said that many of
+the young women were afraid to cross the powerful,
+politically connected money manager and simply refused to
+testify against him.
+In other cases, they said, the women changed their stories.
+Jane Doe 2, who is trying to have the non-prosecution
+agreement thrown out, initially described Epstein as "an
+awesome man" and told prosecutors she hoped "nothing
+happens" to him. While she later agreed to testify against
+Epstein, prosecutors said they feared Epstein's attorneys
+would use her words to destroy her if she ever took the
+witness stand.
+Marra, however, said the young woman's comments didn't
+mean she wasn't entitled to know about the prosecutors'
+plans to drop the charges. "There is no dispute that Epstein
+sexually abused Jane Doe 2 while she was a minor," he
+wrote. "Therefore, regardless of her comments to the
+prosecutor, she was a victim."
+Before the case is finally resolved, Scarola predicted that "a
+lot of people are going to have to answer a lot of questions."
+
+
+In his ruling, Marra detailed what appeared to be a cozy
+relationship between Acosta, his line prosecutors and
+Epstein's team of lawyers. His phalanx of lawyers included
+noted Harvard law professor Alan Dershowitz and Kenneth
+Starr, the former U.S. solicitor general whose investigation
+led to the impeachment of President Clinton.
+Marra describes an October 2007 breakfast meeting
+between Acosta, who is now U.S. labor secretary, and
+Lefkowitz shortly after the non-prosecution agreement was
+inked
+After the meeting, Lefkowitz sent Acosta a note thanking
+him for "the commitment you made to me during our
+October 12 meeting in which you assured me that your
+Office would not ... contact any of the identified
+individuals, potential witnesses, or potential civil claimants
+and their respective counsel in this matter."
+Marra quoted an equally pleasant note then-Palm Beach
+County State Attorney Barfy Krischer sent to Assistant U.S.
+Attorney +
+Villafana, who was the lead prosecutor in
+Epstein's case. "Glad we could get this worked out for
+reasons I won't put in writing," Krischer wrote, shortly
+after the non-prosecution agreement was signed. "After this
+is resolved I would love to buy you a cup at Starbucks and
+have a conversation."
+Many of the notes that were exchanged dealt with
+prosecutors' and Epstein's lawyers' shared desire to keep the
+deal secret from Epstein's accusers. In a September email,
+Villafana asked Lefkowitz for guidance about what she
+should reveal. "And can we have a conference call to discuss
+what I may disclose to ... the girls regarding the
+Agreement," she asked.
+
+
+Such cooperation between prosecutors and defense
+attorneys is unusual, Marra said. "It was a deviation from
+the government's standard practice to negotiate with
+defense counsel about the extent of crime victim
+notifications," he wrote.
+Further, he noted, that when
+• and his two young
+clients asked for information, they were repeatedly misled.
+"The CRVA was designed to protect victims' right and
+ensure their involvement in the criminal justice process,"
+Marra wrote. "When the government gives information to
+victims it cannot be misleading."
+Ultimately, the terms of the non-prosecution agreement
+were revealed only after
+and attorneys for the
+press successfully sued to make
+them
+public
+
+
+76 / 278 - Tuesday, July 9, 2019
+Edition: Final
+Section: A Section
+Page: 1A
+Source: By Jane Musgrave, The Palm Beach Post
+Epstein indicted on sex charges
+Part-time Palm Beacher pleads not guilty to sex
+trafficking, conspiracy charges in federal court in
+Manhattan
+Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
+to charges accusing him of creating a vast network of girls as young as 14 that he exploited
+for his sexual pleasure at his homes in Palm Beach and Manhattan.
+The 66-year-old money manager's appearance in U.S. District Court in New York City
+capped more than a decade of recriminations by young women and their attorneys who
+claimed Epstein used his money and political influence to avoid federal prosecution.
+Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
+charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
+County Jail for 13 months more than a decade ago.
+However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
+shelve a 53-page federal indictment after Ep
+agreed to plead guilty to two state
+prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
+now U.S. labor secretary.
+"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
+Berman said at a
+morning news conference. "And while the charged conduct is from a number of years ago, it
+is still profoundly important to many of the alleged victims, now young women. They
+deserve their day in court."
+At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
+keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
+commit sex trafficking. Epstein paid dozens of young women to give him nude massages
+that, for most, led to sex, he said.
+If convicted of exploiting dozens of young women, including many Palm Beach County girls
+who were students at
+Palm Beach High School, Epstein faces a maximum 45-year
+prison sentence.
+Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin
+slands, New Mexico and Paris and his ownership of two jets, Berman said there are few
+conditions that could keep Epstein from fleeing to a foreign country to evade prosecution
+
+
+"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince
+Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former
+President Bill Clinton on his jet, dubbed the Lolita Express.
+Berman's hard-line stance was welcomed by young women who for years have been told that
+Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement,
+promising not to charge Epstein in federal court.
+Former Palm Beach County resident Virginia Guiffie, who has accused Epstein of turning
+her into his sex slave and forcing her to have sex with others, including Dershowitz and
+Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she
+told the Associated Press. Dershowitz has vehemently denied Guiffre's claims.
+New York prosecutors were able to ignore the controversial nonprosecution agreement
+because it contained some significant fine print, said former federal Judge Paul Cassell, who
+for years has fought to get the agreement thrown out. It says only that no charges could be
+filed against Epstein in South Florida, he said.
+Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
+Florida," he said. "The Southern District of New York is not bound by that agreement and
+wasn't a signatory of it."
+That means the sordid allegations that have been leveled at Epstein for years are now part of
+a federal indictment.
+Contrary to Epstein's claims, he knew the women who came to his homes in New York and
+Palm Beach were minors because they told him their ages, according to the indictment.
+Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
+prosecutors added.
+As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while
+he was in New York so they would be available for sex once he returned to Palm Beach, the
+indictment says. The employees weren't named. They were identified only as "Employee-1,"
+"Employee-2" and "Employee-3."
+To ensure he had a steady stream of young girls, Epstein would turn some victims into
+recruiters. He would pay them to bring new girls to his home on El Brillo Way along the
+Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East
+Side.
+"This allowed Epstein to create an ever-expanding web of new victims," Berman said.
+In both New York and Palm Beach, the lurid operation was similar. Unidentified employees
+of Epstein's would escort the teens into a room. They were told to take off all or most of their
+clothes before giving the naked billionaire massages, according to the indictment.
+"Epstein would also typically masturbate during these encounters, ask victims to touch him
+while he sturbated, and touch victims' genitals with his hands or with sex toys," the
+indictment says.
+As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over
+his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture
+of Epstein's house in Palm Beach.
+While heartened that Epstein now faces serious criminal charges in New York, Cassell said
+he would continue to push a West Palm Beach-based federal judge to throw out the
+nonprosecution agreement that Acosta forged with Epstein's star-studded legal team.
+
+
+U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime
+Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
+Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
+Monday, explaining what action Marra should take to redress that wrong.
+Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
+victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's
+victims with attorneys
+and Jack Scarola.
+Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
+he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
+how and why the agreement was reached.
+"There's been no explanation as to how a deal like this could have been cut and how the
+federal government could have been involved in a conspiracy to violate federal law," Scarola
+said of his interest in continuing the legal battle over the nonprosecution agreement.
+When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
+prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
+Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He
+was also forced to register as a sex offender and settle civil lawsuits more than 30 young
+women filed against him.
+U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out
+how the agreement came to be."I am especially more interested in why Epstein got the deal
+he got," Frankel said. "We need to know why he was given such an easy sentence.
+While she has asked the House Oversight Committee to investigate Acosta, Frankel said she
+is not sure that will happen. "It just seems to me it was a travesty that this guy got off the
+way he did and, without pre-judging it, let's have a proper court case," Frankel said.
+Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State
+Attorney Barry Krischer refused to charge Epstein with serious crimes. Reiter took the
+information his officers had gathered from dozens of Epstein's victims to Acosta, believing
+he would prosecute Epstein. He didn't.
+Reiter said he was heartened that 13 years later, Epstein will finally face justice.
+"Thankfully, U.S. Attorney Berman and the other authorities in New York have the good
+judgment to investigate and prosecute Epstein in the way that should have occurred in
+Florida over a decade ago," Reiter said in a statement.
+And, Scarola said, there are signals that Berman's investigation is far from over.
+Berman declined to answer questions about whether others, such as Epstein's high-powered
+friends, would be charged. He brushed off questions about the significance that the
+investigation was being handled by the Public Corruption Unit.
+While agents on Saturday were arresting Epstein aboard his private jet at the Teterboro
+Airport in New Jersey after returning from Paris. other officers were searching his New York
+City townhouse. Agents seized nude photos of young girls who appeared to be minors,
+Berman said.
+He said his focus was on finding more women who were exploited and abused by Epstein.
+Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a
+finger at a photo of the convicted sex offender who was once described as "a man of
+mystery."
+
+
+"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,"
+Berman said. A special number, 1-800-CALLFBI, will link victims of authorities.
+Bill Sweeney, assistant director of the FBI's New York office, said after years of being
+ignored by federal agents, the victims' voices will be heard.
+"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said.
+Turning to address Epstein's victims directly, he said: "Your bravery may empower others to
+speak out against crimes against them."
+
+
+Def.Ex.A-2
+
+
+= ASSOCIATES, FA
+ARTHUR I
+SCHOLZ & WYLER, LLC.
+UMITED LIABIUTY COMPANY OF PROFESSIOMAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+96I687 GATEWAY BLVD., SUITE 20I-I
+FERNANTINA BEACE, FLORIDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 281.7879
+RICHARD .d. SCHOLZ, P.A.
+RICHARD J. SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A WYLER
+November 26, 2019
+Office of the State Attorney
+15th Judicial Circuit
+Atto: Jeanne Howard
+401 North Dixie Highway
+•West Palm Beach, FL 33401
+Re:
+CA Florida Holdings, LIC v. Dave Aronberg et al.
+Case No.: 2019-CA-014681
+"OP
+COPY
+Dear Mrs. Howard:
+The purpose of this letter is to confirm that
+Scholz & Wyler, LLC will represent you regarding the
+above-referenced matter.
+Our fees will be contingent upon our success in this matter. You will not be liable or required to pay any
+monies to our office unless we are successful in our representation of you regarding the above-referenced
+litigation and receive a court order awarding attorneys' fees.
+Accordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending
+his action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senio
+artners, $425.00/hour for other partners, $375.00/hour for associate attorneys, and $125.00/hour fo
+paralegal time.
+Furthermore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates
+multiplied by the number of hours expended in defending this action or the total fee mandated and awarded
+by the court order herein, whichever is greater.
+By signing below, you agree to the terms as set forth above. Please return a signed and dated copy of thi
+letter to our office. If you have any questions or concerns, please contact our office. On behalf of th
+firm, we are proud to represent you in this matter.
+Sincerely,
+Douglas A. Wyler, Esq.
+6/4/230
+Date
+--
+
+
+Def.Ex.A-3
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida; SHARON 1
+OCK, as Clerk and Comptroller of Palt
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+MOTION TO DISMISS
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned counsel, hereby files this Motion to Dismiss Plaintiff's Complaint for failure to
+state a cause of' action, and in support thereof states^
+MOITON TO DISMISS STANDARD
+When confronted with a motion to dismiss, the Cout must determine whether the Complaint as
+phrased within its four corners sufficiently sfates a cause of action, whereby relief can be granted. Eox v.
+Professional Wrecker Operations, 801 So. 2d 175, 178 (Fla. 5th DCA 2001). A motion to dismiss tests
+whether the plaintiff has stated a cause of action. The test for a motion to dismiss under Florida Rule of
+Civil Procedure 1.140(b) is whether the pleader could prove any set of facts as alleged in the Complaint to
+support his or her claim. See, Connolly v. Sebeco, Inc.. 89 So. 2d 482, 484 (Fla. 1956); Wasua Ins. Co. v.
+Haynes, 683 So. 2d 1123 (Fla. 4th DCA 1996).
+In order to meet this test, "a complaint must allege sufficient ultimate facts to show that a pleader
+is entitled to relief." W.R. Townsend Contr., Inc. v. Jensen Civ. Constr., Inc., 728 So. 2d 297, 300 (Fla.
+1st DCA 1999) (quoting
+v. Cosgrove, 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla. R. Civ. P.
+1.110(b)). The court need not accept internally inconsistent factual claims, conchisory allegations,
+unwarranted deductions, or mere legal conclusions made by a party. Id. (citing Response Oncology, Inc.
+
+
+y. Metrahealth Insurance Co., 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Asset Mgmt. v. Jaharis,
+297 F.3d 1182, 1188 (I1th Cir. 2002) ("[Ou a motion to dismiss,] the plaintiff's factual allegations are
+accepted as true... However, legal conclusions masquerading as facts will not prevent dismissal."). To
+avoid dismissal, a pleading "must allege a cause of action recognized under law" against the defending
+party. Kislak v. Kreedian, 95 So. 2d 510, 514 (Fla. 1957).
+COUNT I
+(Florida Statutes Section 905.27)
+Plaintiff attempts to assert a cause of action, in the interest of "furthering justice", under Florida
+Statute § 905.27; however, a review of the statute in question reveals that no cause of action is provided
+for therein and consequently Plaintiff's Complaint must be dismissed as a matter of law. Despite
+Plaintiff's extensive recitation of the factual background regarding Jeffery Epstein and the testimony and
+evidence presented to the 2006 grand jury in Palm Beach County, Florida, Fla. Stat. § 905.27, merely
+explains the exceptions to the disclosure of grand jury testimony and does not set forth in any way a cause
+of action upon which to initiate a valid law suit.
+Moreover, a review of the statute at issue clearly indicates that even if § 905.27, Fla. Stat.
+provided a basis for a cause of action. Plaintiff is barred from access to the records it seeks. To wit, in
+pertinent part, Fla. Stat. § 905.27(2) states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorneys and by the latter
+to their legal associates and employees. However, the grand jury testimony afforded such
+persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Here, despite the clear statutory guidelines for disclosure of grand jury materials in a civil case.
+Plaintiff is improperly seeking the requested 2006 grand juy materials for the purposes of public
+disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [See,
+Complaint 11 8, 62]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27,
+the statute unambiguously states that grand jury testimony "can only be used in the defense or prosecution
+of the civil or criminal case and for no other purpose whatsoever", which is distinctly different from
+
+
+Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla. Stat. § 905.27(2).
+Finally, it is significant to note that despite Plaintiff's allegations to the contrary, Defendant Aronberg is
+not in custody or control of the records sought and is therefore not a proper party to this action.
+WHEREFORE, based on the foregoing argument and supporting authority, Defendant, DAVE
+ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this Honorable
+Court grant the instant Motion and dismiss Plaintiff's Complaint with prejudice, and grant Defendant
+Aronberg all other and further relief deemed just and proper, including attorney's fees and costs for
+defending this frivolous action.
+I HEREBY CERTIFY that on this 6th day of December, 2019, a copy of the foregoing has been
+electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+JACOBS SCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Arthur I.
+Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.net
+Attomney's Association
+
+
+Def.Ex.A-4
+
+
+Filing # 101840557 E-Filed 01/17/2020 12:23:06 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+Div.: AG
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+FIRST AMENDED COMPLAINT
+CA Florida Holdings, LIC, publisher of The Palm Beach Post, for its First Amended
+Complaint against Dave Aronberg, the State Attorney for Palm Beach County, Florida, in his
+official capacity ("State Attorney"), and Sharon R. Bock, the Clerk of the Court for Palm Beach
+County, Florida, in her official capacity (Court Clerk"), alleges as follows:
+JURISDICTION
+This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
+Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq
+PARTIES
+The Palm Beach Post is a daily community newspaper published by Plaintiff CA
+Florida Holdings, LL.C, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
+3.
+Defendant Dave Aronberg is the duly elected State Attorney for the Fifteenth
+Judicial Circuit in and for Palm Beach County, Florida, pursuant to Fla. Stat. Section 27.01 and
+has authority in grand jury proceedings pursuant to Fla. Stat. Section 27.03. He is sued herein in
+
+
+his official capacity as his office is in possession and/or control of documents that are the subject
+of this action.
+4.
+Defendant Sharon R. Bock is the duly elected Clerk and Comptroller of Palm Beach
+County, Florida. She is sued herein in her official capacity as her office is in possession and/or
+control of documents that are the subject of this action.
+INTRODUCTION
+In what is now widely if belatedly recognized as a colossal miscantiage of justice -
+which led to the further needless victimization of countless young girls and women - a wealthy,
+politically connected, and powerful financier was not held accountable for, nor even forced to
+confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008
+deal with the State of Florida was not consistent with the evidence gathered against him, what
+remains shrouded in mystery is how that evidence was presented - and the extent to which it was
+presented - to the grand jury that returned an indietment far more limited in scope than expected
+and deserved.
+Through this action, The Palm Beach Post seeks public access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled
+during the first Epstein sex abuse investigation. Typically, access to such materials is limited, for
+example, in order to prevent the flight of those whose indictment may be contemplated and their
+ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an
+accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law
+expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
+including, as here, in the furtherance of justice. Fla. Stat. § 905.27(1)(c).
+7.
+It can no longer credibly be maintained that continued blanket secrecy over the
+proceedings that led to the egregiously flawed 2006 Epstein indictinent is warranted under the law.
+2
+
+
+To the contrary, transparency is required to promote public understanding of the criminal justice
+systein and public confidence in the fair administration of justice. As detailed below, Epstein was
+accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
+other locations) over a period of several years while exploiting his wealth and political connections
+to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury
+proceedings will shed light on the extent to which those in our government entrusted with the
+solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties
+in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated
+like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
+who chose to give Epstein favorable - "unusual," in the words of the Town of Palm Beach Police
+Chief - treatment, are exposed and held accountable From what limited information is now in the
+public domain, the State Attorney's referral of Epstein's case to the grand jury - which would be
+out of the ordinary for this type of case - gives rise to a strong inference of favoritism and
+corresponding disregard for the rights of the minor victims of Epstein's sex trafficking. Access to
+the grand jury materials will allow the public to determine whether the grand jury process, and the
+secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and
+his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat.
+Section 905.27 authorizes the disclosure of Epstein's 2006 grand jury proceedings.
+8.
+Even in the absence of such a statutory basis, this Court is empowered to order
+public disclosure pursuant to its inherent authority and supervisory powers over the grand jury.
+Indeed, courts throughout the country in the past several decades have ordered the disclosure of
+high-profile grand jury proceedings pursuant to their inherent authority where the public's interest
+in those proceedings has outweighed the general need for secrecy. This is particularly so where,
+3
+
+
+as here, many of the details of Epstein's criminal misdeeds have already been made available in
+the public domain through extensive news reporting by, among others, The Palm Beach Post; by
+the many civil suits brought against Epstein and his co-conspirators; and by the victims themselves.
+In recognition of the sensitivity of the materials being sought, and in the interest of
+protecting any victims who wish to remain anonymous, The Palm Beach Post has no objection to
+copies of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County
+grand jury first being submitted to this Court for in camera review, where they may be redacted,
+as appropriate, to protect those who deserve such protection.
+FACTUAL BACKGROUND
+10. The following facts were gathered, in large part, from documents obtained by The
+Palm Beach Post through various Florida Public Records Law requests, documents unsealed or
+publicly available in other related judicial proceedings, and information and documents in the
+public record.
+A.
+is 2ofcin Sex Crimes Investization, Indictment, and Plea Agreement:
+11. The investigation into Epstein's sex crimes began more than fourteen years ago,
+when a 14-year-old girl's stepinother reported to police in the Town of Pahn Beach, Florida, that
+Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
+required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
+$300. Epstein was 52 years old at the time.
+12.
+Following this initial report in 2005, the Town of Palm Beach Police, and later; in
+2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
+seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
+disturbingly similar details, with each of the other victims.
+4
+
+
+13.
+Both the victim/witness interviews, as well as evidence retrieved following a search
+of Epstein's home, showed that some of the girls involved were under the age of 18. The police
+search of Epstein's residence also found two hidden cameras and, throughout the house, large
+numbers of nude photos of girls, including victims whom the police had not interviewed in the
+course of their investigation.
+14.
+In March 2006, a State grand jury was scheduled at which all of the victims were
+expected to testify. The proceeding was postponed, however, due to meetings between the State
+Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan
+Dershowitz.
+15.
+to begin receiving evidence.
+Another grand jury was convened in April 2006, but canceled the day before it was
+(1) Police Chief Reiter's Letter to the State Attorner.
+16.
+On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
+"personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer,
+stating:
+17.
+Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach
+Police Department's probable cause affidavits charging Epstein and two of his assistants with
+multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
+5
+
+
+that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
+against him, which would be public.
+(2) The July 2006 State Grand Jury Presentation.
+18.
+Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
+mandatory for capital cases but rarely used for all other crimes. According to an official
+spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
+Beach County.
+19. In July 2006, after State Attorney Krischer presented testimony and evidence from
+one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
+There is no mention in the indictment of the victim being a minor.
+On information and belief, a second of Epstein's victims was supposed to testify
+before the grand jury, but was unable to attend because of a school exam.
+21.
+No reasonable explanation has been provided as to why the numerous other known
+victims were not presented as witnesses and crime victims to the grand jury convened in July 2006.
+Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
+initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do
+SO.
+22.
+On information and belief, during the grand jury appearance of the single victim
+who testified, the State Attorney presented evidence that vilified the victim and attacked her
+credibility, including soliciting testimony regarding underage drinking and questionable personal
+behavior that was unrelated to the charges against Epstein. Further upon information and belief,
+this information was initially brought to the attention of the State Attorney's office by Epstein's
+defense counsel.
+6
+
+
+23.
+(3) The FBI's Investigation and Epstein's Non-Prosecution
+Agreement With Federal Authorities.
+On information and belief, following the deficient July 2006 indictment, and with
+Chief Reiter's encouragement, the FBI began its own investigation of Epstein.
+24.
+Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed
+minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI,
+a 53-page indietment was prepared by the U.S. Attorney's Office in June 2007. However, at the
+request of Epstein's lawyers, the indictment was never presented to a federal grand jury.
+25.
+Instead, then U.S. Attomney for the Southern District of Florida, Alexander Acosta,
+negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with
+four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
+charges.
+26.
+Throughout the remainder of 2007 and through the first half of 2008, Epstein's
+lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
+belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept
+confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
+issued for Epstein's computers) be withdrawn.
+27.
+On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
+prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
+sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
+adjudicated as a convicted sex offender required to register twice a year in Florida.
+28.
+The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to
+receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
+7
+
+
+On information and belief, based on public records, former State Attorney Krischer communicated
+with then U.S. Attomey Acosta concerning the NPA's negotiation with Epstein's lawyers.
+29. Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
+which he was convicted. Instead, he was placed in a private wing of the Palm Beach County
+Stockade, where, after 3 12 months, he was allowed to leave the jail on "work release" for up to
+12 hours a day, 6 days a week. His private driver provided his transportation to and from "work."
+30.
+Epstein was released five months early.
+31.
+Upon information and belief, Epstein violated the terms of his probation, but was
+not prosecuted.
+(4) The Crime Victims' Rights Act Litigation.
+32.
+Epstein's victims only learned after the fact about his plea in State court and filed
+an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act
+(18 U.S.C. § 3771, "CVRA"), which mandates certain rights for crime victims, including the right
+to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
+Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
+Epstein's victims before allowing him to plead guilty to only the two State offenses.
+33.
+The prosecution's failure to keep the victims apprised, among other things, also
+contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.
+34
+Following publicity exposing the extraordinary leniency of the plea deal, dozens of
+civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.
+35.
+In 2010, Epstein was registered as a "level three" (t.e., high risk of repeat offense)
+sex offender in New York, a lifelong designation. In 2011, the New York County District
+Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."
+8
+
+
+36.
+Upon information and belief, during the course of the Town of Palm Beach and FBI
+investigations, Epstein retained private investigators to follow, harass, and photograph his victims
+and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated
+the case against Epstein.
+37.
+Upon information and belief, Epstein's victims were threatened against cooperating
+with law enforcement and told that they would be compensated only if they did not cooperate with
+law enforcement.
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
+38.
+On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
+39. Upon information and belief, the United Stafes governnent's investigation of new
+allegations and charges stemmed, in part, from continued press investigations into and reporting
+on the mishandling of the 2006 charges and the civil suits that followed
+40.
+In a July 8, 2019, letter to the federal district court by the U.S. Attorey for the
+Southern District of New York, Epstein was described as "a serial sexual predator who preyed on
+dozens of minor girls over a period of years." The letter emphasized that "the Goverment has real
+concerns - grounded in past experience with this defendant - that if allowed to remain out on bail,
+the defendant could attenpt to pressure and intimidate witnesses and potential witnesses in this
+case, including victims and their families, and otherwise attempt to obstruct justice." It also
+described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex
+trafficking in the form of "hundreds - and perhaps thousands - of sexually suggestive photographs
+of fully- or partially-nude females," including underage females. In a locked safe, compact dises
+were found with handwritten labels including the descriptions: "Young [Name] + [Name]," 'Misc
+nudes 1," and "Girl pics nude."
+
+
+41.
+On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's
+office for the Southern District of New York charged Epstein with sex trafficking and conspiracy
+to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were
+brought into Epstein's mansions for sexual encounters. A few days later, owing to public outery
+over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
+Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump
+administration, resigned from office.
+42.
+Epstein was denied bail and was placed into pretrial detention at the federal
+Metropolitan Correction Center in lower Manhattan.
+43.
+On or about August 6, 2019, Florida Gov. Ron DeSantis ordered a state criminal
+probe into the actions of the Palm Beach Sheriff and forner State Attorney Krischer for their
+handling of the Epstein underage sex trafficking case.
+44.
+On August 10, 2019, Ep
+was found dead in his cell at the Metropolitan
+Correctional Center. His cause of death was determined to be suicide.
+C. The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+On account of his death, prosecutors sought to dismiss the indictment against
+Epstein, while maintaining that they would continue to investigate his co-conspirators.
+46.
+United States Senior District Judge Richard M. Berman ordered a hearing on
+August 21, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to
+speak at the hearing.
+47.
+In the course of the hearing, more than two dozen victims delivered their personal
+stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
+violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
+
+
+48.
+While some questioned the reasoning behind the court's decision to give the victims
+voice after Epstein's death, District Judge Bernan noted that "a public hearing is [the] preferred
+vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings
+promote transparency and they provide the court with insights and information which the court
+may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that
+the court "is the institution that most people have confidence in, in these very troubled times."
+49.
+At the August 27th hearing, the girls, now women, spoke about their "exploitation
+and coercion," and to the fact that many of thein "were in very vulnerable situations and in extreme
+poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
+behalf...." One victim lamented that "as a victim, [she] never got to see what the agreement was
+or why the special treatment got approved" in the Florida case years earlier. Another noted how
+"completely different" the investigators leading to the 2019 federal indictment were from the
+prosecutors in the Florida case, both in their treatment of her and their investigation of her
+victimization by Epstein.
+50.
+A former federal judge in attendance at the August 27th hearing emphasized that
+"transparency is one of the overriding objectives in our criminal justice system."
+51.
+Nearly all of the victims expressed the conviction that the secrecy that shielded
+Epstein has caused them "irreparable harm" and that an opportunity to address his criminal
+wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
+at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts
+made to protect Epstein's name and legacy send a inessage to the victims that he wins and that he
+is untouchable." Another victim expressed fear that this is a world "where there are predators in
+power, a world where people can avoid justice if their pockets run deep enough." In short, the
+11
+
+
+"unusual" treatient Epstein received in Florida in 2006 based on his wealth, social status, and
+connections severely eroded the public's faith in the integrity and impartiality of the criminal
+justice system.
+D.
+The Palm Beach Post's Standing and the Public Interest.
+The Palm Beach Post Has Reported Extensively On Epstein's
+Crimes For Nearly 15 Years.
+52. Plaintiff, The Paln Beach Post, is a community newspaper serving readers in Palm
+Beach County and the Treasure Coast vicinity.
+53.
+The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
+three other times.
+54.
+Beginning in 2004, The Palm Beach Post has extensively investigated and reported
+on the allegations against, the law enforcement investigatión of, and the crimes committed by,
+Epstein and his co-conspirators. The Newspaper's reportage has included publication of the
+following articles:
+• "The Man Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends
+and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that:
+police that "she had taken at least six girls to visit Epstein, all between the ages of 14
+and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;"
+"Dershowitz, the Harvard law professor, traveled to West Palm Beach with information
+about the girls," including social media discussions about "their use of alcohol and
+marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their
+‹decision to take the case to a grand jury;" Palın Beach Police subsequently "received
+complaints that two of the victims or their families had been harassed or threatened;"
+"relations between police and prosecutors were fraying" as the investigation continued;
+and "one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up" to testify before the grand jury.
+• "Trump Snags Gosman Estate for $41 Million" published on November 16, 2004,
+reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
+purchase of a "43,000-square-foot, seven-bedroomn estate on 6 oceanfiont acres along
+the storied Raider's Row' " in Palm Beach.
+12
+
+
+• "Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that
+"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last
+year, according to an indictment charging him with felony solicitation of prostitution."
+The article further reported that "Epstein's case is unusual in that suspected prostitution
+johns are usually charged with a misdemeanor, and even a felony charge is typically
+made in a criminal information - an alternative to an indictment charging a person with
+the commission of a crime."
+• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006,
+reporting that "Palm Beach police thought there was probable cause to charge Epstein
+with unlawful sex acts with a minor and lewd and lascivious molestation." The article
+further reported that "Police Chief Michael Reiter was so angry with State Attorney
+Barry Krischer's handling of the case that he wrote a memo suggesting the county's
+top prosecutor disqualify himself," and identified a 20-year-old on-the-record female
+source who said "she gave Epstein a massage in the nude, then brought him six girls,
+ages 14 to 16, for massage and sex-tinged sessions at his home."
+• "Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006,
+reporting that "[flamed Harvard law professor Alan Dershowitz met with the Palm
+Beach County State Attorney's Office and proyided damaging information about
+teenage girls who say they gave his client, Palm Beach billionaire Jeffiey Epstein,
+sexually charged massages" and that "ItJhe state attorney's office said it presented the
+Epstein case to a county grand jury this month rather than directly charging Epstein
+because of concerns about the girls' credibility."
+• "Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006,
+reporting that "[r]ather than file charges, the state attorney's office presented the case
+to a county grand jury" which "indicted Epstein last week on a single, less serious
+charge of felony solicitation of prostitution," and that "[t]he case raised eyebrows
+because the state attorney's office rarely, if ever, kicks such charges to a grand jury."
+• "Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting
+that "[a] state attorney's spokesman would say only that the office refers cases to the
+grand jury when there are issues with the viability of the evidence or witnesses'
+credibility."
+"Palm Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006,
+reporting that Chief Reiter "pressed for Epstein to be charged with the more serious
+crimes of sexual activity with minors" and "slammed State Attorney Bany Krischer in
+blunt language seldom used by one law enforcement official with another because of
+what he perceived as that office's mishandling of the case."
+"Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007,
+reporting that "[nearly eight months after Palm Beach tycoon Jeffrey Epstein was
+charged with felony solicitation of prostitution, there has been no discernible progress
+in his case."
+
+
+• "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
+on October 18, 2007, reporting on a lawsuit brought in New York State court against
+Epstein "by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model."
+• "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein,
+55, pleaded guilty... to felony solicitation of prostitution and procuring a person under
+the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex
+offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their
+investigation of Epstein, which they had taken to a grand jury."
+• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on
+August 13, 2008, reporting that "[d]uring his first month of confinement" Epstein was
+visited by
+, who allegedly escorted victims upon their arnival at his Palm
+Beach waterfront home to an upstairs room, where she prepared the massage table and
+provided the oils for their encounters" with Epstein, and by |
+"a
+young woman whor Epstein purportedly described as his Yugoslavian sex slave."
+• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July
+1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade
+six days a week on a work-release program
+"Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting
+that attorneys for women suing Epstein in various courts "want his [non-prosecution]
+agreement [NPA] with federal prosecutors unsealed" and were moving to unseal the
+agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces
+Beach Post moved to intervene in the matter for the purpose of obtaining public access
+to the NPA, which was ordered disclosed by this Court on June 25, 2009.
+"Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on
+September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,
+"federal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
+pleaded guilty to prostitution-related felonies in state court" and "also agreed not to
+Coney representing three of steins vie father ep of die a adi wontam
+identified as victims in the federal investigation" were informed ahead of time about
+the NPA.
+• "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on
+January 27, 2010, reporting that "a judge ... gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to subpoena abortion records from
+women who are seeking millions in damages from the part-time Palm Beach resident."
+14
+
+
+• "Epstein Joumal's Findings Could Resurrect Abuse Case" published on March 20,
+2010, reporting that "[a] purloined journal that is said to contain the names of
+'hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen
+the investigation into the multi-millionaire's appetite for teenage girls."
+• "Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published
+on October 4, 2017, reporting that, according to court documents, Epstein "shelled out
+$5.5 million to settle lawsuits with three of more than two dozen teens who sued him."
+• "Judge Rules Feds' Agreement With Jeffiey Epstein Pact Violated Teen Victims'
+Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge
+Kenneth Marra that "Federal prosecutors violated the rights of Jeffiey Epstein's
+teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had
+dropped plans to prosecute the billionaire on dozens of federal charges in connection
+with the girls' claims that he paid them for sex at his Palm Beach mansion."
+• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
+Trafficking, Conspiracy Charges In Federal Cout In Manhattan" published on July 9,
+2019, reporting on Epstein's appearance in U.S. District Court for the Southern District
+of New York in which he "pleaded not guilty to charges accusing him of creating a vast
+network of girls as young as 14 that he exploited for his sexual pleasure at his homes
+in Palm Beach and Manhattan."
+A true and correct copy of the above news articles, in either the computerized fornat in which they
+are maintained in The Palm Beach Post's electronic archives or the news print edition in which
+originally published, is annexed hereto as Exhibit 1.
+55.
+Since the filing of the initial Complaint in this matter, The Palm Beach Post- along
+with media worldwide - has continued to report on Epstein's crimes and the ongoing official
+proceedings resulting from those crimes.
+(2) The Palm Beach Post's Standing and the Public Interest.
+56.
+The press has a constitutional right of access to criminal proceedings, see, e.g.,
+Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
+proceedings.
+v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the
+judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
+proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ
+15
+
+
+Co. v.
+426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in
+matters concerning the closure of judicial proceedings). The press also has a First Amendment
+interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
+Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists ... the protection afforded [by
+the First Amendment] is to the communication, to its source and to its recipients both."); Pittman
+, 267 F.3d 1269, 1283 n. 12 (11th Cir. 2001) ("The Supreme Court has recognized that the
+First Amendment offers protection to both speakers and those wishing to receive speech."); see
+also Stephens v. Civ. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir. 2008) (providing that a plaintiff
+has "standing to assert a right to receive speech" by "show[ing] that there exists a speaker willing
+to convey the information to her").
+57. Because of the unique role performned by the press as a "public surrogate"
+426 So. 2d at 6-7) in protecting the right of aceess and its interest in reporting information about
+criminal proceedings, news organizations "presumptively have a right to access judicial records,"
+Comm'r, Ala. Dep't of Corr: v. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019),
+and "standing to question the validity of an order restricting publicity because its ability to gather
+news is directly impaired or curtailed." (
+426 So. 2d at 4; see also Carlson v. United States,
+837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee]
+has standing to assert [its] claim" to grand jury materials because such materials are "public records
+to which the public may seek access, even if that effort is ultimately unsuccessful").
+58.
+Here, the continued denial of access to information The Palm Beach Post seeks on
+behalf of its jounalists and the public it serves "unquestionably constitutes irreparable injury."
+Gainesville Woman Care, LIC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
+Zerilli v.
+656 F.2d 705, 711 (D.C. Cir: 1981) (noting that "the press' function as a vital
+16
+
+
+source of information is weakened whenever the ability of journalists to gather information is
+impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand
+jury materials).
+59.
+The Palm Beach Post has the right to maintain this private right of action because
+the furtherance of justice, an express legislative exception to grand jury secrecy, is intended for
+the public benefit, and The Palm Beach Post seeks access on behalf of the public, Fla. Stat.
+§ 905.27(1)(c). It is further express in Fla. Stat. § 905.27 that the legislature intended for a court
+to be the party to make the determination of disclosure. Fla. Stat. § 905.27(1). In other words, the
+legislature intended for recourse to the courts in considering and determining the propriety and
+scope of grand jury secrecy.
+E.
+The Court's Jurisdiction And Authority.
+(1)
+The Court's Supervision of the Grand Jury Process and Its
+Authority to Order Public Disclosure of the Epstein Evidence.
+60.
+The Florida Supreme Court has noted that in states such as Florida, where the
+grand jury is preserved, it is an important appendage of the court which impanels it. At the same
+time it should not be forgotten that the judge of that court is equally important and he is generally
+charged with the supervision of the grand jury's activities...It is, therefore, of vital importance to
+maintain the dignity and the integrity of both the grand jury and the presiding judge." State v.
+Clemons, 150 So. 2d 231, 233-34 (Fla. 1963).
+Chapter 905 of the Florida Statutes governs the empanelment and conduct of
+Florida grand juries. The cout gives the grand jury its initial charge and advises the grand jury
+about its legal duties. Fla. Stat. § 905.18.
+62.
+Florida Stat. Section 905.27(1) provides that "the testimony of a witness examined
+before the grand jury ... or other evidence received by it" may be disclosed "when required by a
+17
+
+
+court... for the purpose of: (a) Ascertaining whether it is consistent with the testimony given by
+the witness before the court; (b) Determining whether the witness is guilty of perjury; or (c)
+Furthering justice." Fla. Stat. § 905.27(1)(a)-(c).
+63.
+Further, disclosure is appropriate pursuant to this Court's inherent authority over
+grand jury proceedings because of the exceptional public interest in this case and the compelling
+circunstances supporting transparency. Carlson v. United States, 837 F.3d at 766 (a district court
+has the inherent power to disclose [grand jury] materials in exceptional circumstances and ...
+historic importance can be a sufficient reason when there is little countervailing need for secrecy").
+64.
+The Florida Supreme Court has confirmed that grand jury secrecy is not absolute
+and that any "potential harm to public officeholders" from disclosure "will be the product of their
+own conduct, and not the consequence of an unrestrained body of misguided citizens." Miami
+Herald Pub. Co. v. Marko, 352 So. 2d 518 (1977) (The benefits to be derived from this
+extraordinary exercise in citizen participation [in the grand jury] would be severely limited if the
+fruits of that activity were not available to the public on whose behalf it is undertaken. Implicit in
+the power of the grand jury to investigate and expose official misconduct is the right of the people
+to be informed of its findings. While public disclosure of grand jury findings inevitably entails the
+risk of reputational damage, the legislature has ensured that any potential harn to public
+officeholders will be the product of their own conduct, and not the consequence of an unrestrained
+body of misguided citizens.")
+The Court's Jurisdiction To Declare Rights And Construe
+Statutes.
+65.
+This Court has jurisdiction to declare rights, status, and other equitable or legal
+relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.
+18
+
+
+66.
+Florida law specifically provides that a declaration may be sought from the Court
+concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 ("Any person... whose
+rights, status, or other equitable or legal relations are affected by a statute, or any regulation made
+under statutory authority.... may have determined any question of construction or validity arising
+under such statute.... or any part thereof, and obtain a declaration of rights, status, or other equitable
+or legal relations thereunder.").
+67.
+The Court's exercise of its power to declare rights "is to be liberally administered
+and construed." Florida Stat. Section 86.101.
+COUNTI
+(Declaratory Relief - Florida Stat. Sections 86,011 et seq.)
+68.
+The allegations set forth in paragraphs ! through 67 are incorporated by reference
+as if fully set forth herein.
+69.
+This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes,
+and other supplemental relief.
+70.
+The Palm Beach Post respectfully requests that the Court declare that pursuant to
+Fla. Stat. Section 905.27(1), it is entitled access to the testimony, minutes, and other evidence
+presented in 2006 to the Palm Beach County grand jury because such disclosure and access would
+be in the furtherance of justice. Fla. Stat. § 905.27(1)(c). Because The Palm Beach Post is not
+seeking these materials in connection with either a civil or criminal case, it seeks a declaration that
+the scope of its use of the disclosed materials is not limited. See Fla. Stat. § 905.27(2)
+71.
+The Palm Beach Post further seeks a declaration that disclosure of the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury is appropriate
+19
+
+
+pursuant to this Court's inherent authority over grand jury proceedings because of the exceptional
+public interest in this case and the compelling circunstances supporting transparency.
+72. The Palm Beach Post has sought from Defendants, but Defendants have refused to
+provide, access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach
+County grand jury. Indeed, Defendants have each filed motions to dismiss the Complaint and the
+relief it sought under Fla. Stat. Section 905.27(1). Accordingly, a good-faith dispute exists between
+the parties.
+73.
+Through this Complaint, The Palm Beach Post presently has a justiciable question
+concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Section 905.27(1)
+and the Court's inherent authority.
+74.
+A bona fide, actual, present, and practical need for the declaration exists in that
+Defendants have denied to The Palm Beach Post - and to the public at large - the grand jury
+materials sought to be disclosed. The relief sought from the Court is therefore not merely the giving
+of legal advice or to answer hypothetical questions.
+WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the
+rights and obligations of the parties by declaring that pursuant to Fla. Stat. Section 905.27(1)(c)
+and the Court's inherent authority, The Palm Beach Post may gain access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury and use those
+materials for the purpose of informing the public.
+COUNT II
+(Florida Stat. Section 905.27)
+75.
+The allegations set forth in paragraphs 1 through 74 are incorporated by reference
+as if fully set forth herein.
+20
+
+
+76.
+Based on information learned by The Palm Beach Post through its Florida Public
+Records Law requests, law enforcement sources with direct knowledge of the grand jury evidence
+and proceedings, judicial documents obtained from independent but related court proceedings, and
+documents otherwise available in the public record, the State Attorney for Palm Beach County
+presented truncated evidence of Epstein's criminal wrongdoing to the 2006 grand jury in a manner
+that precluded his indictment for the serious crimes he committed, including sex trafficking and
+sexual assault.
+77.
+Pursuant to Florida Stat. Section 905.27, in order to further justice for Epstein's
+victims and the public, and to provide public disclosure to illuninate whether Epstein received
+unreasonably lenient treatment based on the available evidence, The Palm Beach Post requests
+immediate access to the testimony, minutes, and other evidence presented in 2006 to the Palm
+Beach County grand jury.
+78.
+In a case of this magnitude and importance, where the accused is dead and so many
+of his crimes, as well as the identities and crimes of his co-conspirators, and the identities of the
+victims have already been exposed, the need for grand jury secrecy is no more. See United States
+v. Socony-Vacuum Oil Co., 310 U.S. 150, 234 (1940) ("[A]fter the grand jury's functions are
+ended, disclosure is wholly proper where the ends of justice require it.").
+WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
+Stat. Section 905.27(1) and the Court's inherent authority, order the State Attorney and the Clerk
+of the Court to file with this Court copies of the testimony, minutes, and other evidence presented
+in 2006 to the Palm Beach County grand jury during the first Epstein sex abuse investigation so
+that, following an in camera inspection, it can be made available to The Palm Beach Post and the
+21
+
+
+public on an expedited basis, and grant any other and further equitable or legal relief the Court
+deems just and proper.
+Dated: January 17, 2020
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsahn
+Florida Bar No. 849324
+hasenh@gtlaw.com
+FI.Service@gtlaw.com
+By:
+As/ Michael J Grygiel
+NOT A CER
+MICHAEL J GRYGIEL
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Bovajian
+A Vice application pending)
+1840 Century Park East, Suite 1900
+Los Angeles CA 90067
+Telephone: (310) 586 -7700
+Facsimile: (310) 586 -7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+22
+
+
+I HEREBY CERTIFY that on this 17th day of January, 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+/s/ Stephen A. Mendelsohn
+23
+
+
+
+The Newspaper's Reportage on Jeffrey Epstein
+
+
+The Man Who Had Everything: Jeffrey Epstein craved big
+homes, elite friends and underage girls
+By Andrew Marra
+Posted Jul 17, 2019 at 6:02 AM
+From the archives: When Palm Beach detectives started asking
+questions and teenage girls started talking, a wave of legal resistance
+followed.
+Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
+Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution.
+WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,
+hidden cameras trolled two rooms, while the girls came and went.
+For the police detectives who sifted through the garbage outside and kept records of visitors, it
+was the lair of a troubling target.
+Epstein, one of the most mysterious of the country's mega-rich, was known as much for his
+secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
+friendships with the world's elite.
+But at Palm Beach police headquarters, he was becoming known for something else: the
+regular arrival of teenage girls he hired to give him massages and, police say, perform sexual
+favors.
+Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
+among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
+with some of the most prominent legal, scientific and business minds in the country.
+When detectives started asking questions and teenage girls started talking, a wave of legal
+resistance followed.
+
+
+» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease
+If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
+Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
+quietly, always in the background as he navigated New York high society.
+When he first attracted notice in the early 1990s, it was on account of the woman he was
+dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
+In a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love, the British
+Mail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a
+math teacher, a concert pianist or a corporate headhunter.
+"But what is the truth about him?" the newspaper wondered. "Like Maxwell, Epstein is both
+flamboyant and intensely private."
+The media frenzy did not begin in fuil until a decade later. In September 2002, Epstein was
+flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
+Africa on his private jet.
+Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
+published lengthy profiles. The New York Post listed him as one of the city's most eligible
+bachelors and began describing him in its gossip columns with adjectives such as "mysterious"
+and "reclusive."
+Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
+Building a life of extravagance
+He was born blue-collar in 1953, the son of a New York City |
+department employee, and
+raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
+but became a math teacher at the prestigious Dalton School in Manhattan.
+The story goes that the father of one of Epstein's students was so impressed with the man that
+he put him in touch with a senior partner at Bear Stearns, the global investment bank and
+securities firm.
+
+
+In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
+Epstein and Co. That is when he began making his millions in earnest.
+Little is known or said about Epstein's business except this: He manages money for the
+extremely wealthy. He is said to handle accounts only of $1 billion or greater.
+It has been estimated he has roughly 15 clients, but their identities are the subject of only
+speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a
+former Palm Beacher who is said to have been a mentor to Epstein.
+Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
+block on Manhattan's Upper East Side. It is reported to have, among its finer features, closedcircuit television and a heated sidewalk to melt away fallen snow.
+That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
+the extravagant world Epstein built over time.
+In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
+outside Santa Fe. Many believed it to be the largest home in the state.
+In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
+private island in the Virgin Islands.
+» PHOTOS: The players in the Jeffrey Epstein saga
+Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
+the highest echelons of power. This includes not only socialites but also business tycoons,
+media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
+funds.
+"Just like other people collect art, he collects scientists," said
+Nowak, who directs the
+Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
+a $30 million research donation from Epstein.
+Epstein is said to have befriended former Harvard President Larry Summers, prominent law
+Professor Alan Dershowitz, Donald Trump and New York Daily News Publisher Mort
+Zuckerman.
+
+
+And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
+photographed.
+"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
+and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article.
+Epstein's friendship with Clinton has attracted the most attention.
+Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
+an intimate fund-raising dinner in Palm Beach. But from all appearances, they did not become
+close friends until after Clinton left the Oval Office and moved to New York.
+Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John
+Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill |
+and the
+Senate bids of Joe L
+, Hillary Rodham Clinton, Christopher Dodd and Charles
+Schumer.
+Powerful friends and enemies
+A Vanity Fair profile found cracks in the veneer of Epstein's life story. The 2003 article said he
+left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
+Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20
+million loan.
+The article suggested that one of his business mentors and previous employers was Steven
+Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million
+in one of the largest Ponzi schemes in American history."
+As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
+man who in 1990 sold him his multimillion-dollar Palm Beach home over a dispute about less
+than $16,000 in furnishings.
+A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
+thousands of dollars after their failed investment in Texas oil wells. A judge decided Epstein
+owed him nothing.
+» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
+
+
+"It's a bad memory. I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the
+retired former president of
+_Electronics and Sega Corp. "Suffice it to say I have
+nothing good to say about him."
+Among the characteristics most attributed to Epstein is a penchant for women.
+He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
+and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
+model.
+"He's a lot of fun to be with," Donald Trump told New York magazine in 2002. "It is even said
+that he likes beautiful women as much as I do, and many of them are on the younger side. No
+doubt about it, Jeffrey enjoys his social life."
+Investigation leads to Epstein
+Although he was not a frequenter of the Palm Beach social scene, he made his presence felt.
+Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
+$100,000 to Ballet Florida.
+In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a l
+Harley-Davidson. His jet waited at a hangar at Palm Beach International Airport. At home, a
+private chef and a small staff stood at the ready. From a window in his mansion, he could look
+out on the Intracoastal Waterway and the West Palm Beach skyline. He seemed to be a man
+who had everything.
+But extraordinary wealth can fuel extraordinary desires.
+» Epstein wants to leave jail for mansion in sex-trafficking case
+In March 2005, a worried mother contacted Palm Beach police. She said another parent had
+overheard a conversation between their children.
+Now the mother was afraid her 14-year-old daughter had been molested by a man on the
+island.
+The phone call triggered an extensive investigation, one that would lead detectives to Epstein
+but leave them frustrated.
+
+
+Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
+Beach police report detailing the criminal probe offers a window into what detectives faced as
+they sought to close in on Epstein.
+Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
+perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
+said she was paid $300 after stripping to her panties and massaging the man while he
+masturbated.
+Police interview 5 alleged victims
+The investigation began in full after the girl identified Epstein in a photo as the man who had
+paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift
+through it. They set up a video camera to record the comings and goings at his home. They
+monitored an airport hangar for signs of his private jet's arrivals and departures.
+They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
+1, a Palm Beach Community College student from Loxahatchee. In a sworn
+statement at police headquarters,
+, then 18, admitted she had taken at least six girls to
+visit Epstein, all between the ages of 14 and 16. Epstein paid her for each visit, she said.
+During the drive back to her house,
+told detectives, "I'm like a Heidi Fleiss."
+Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
+said they had been instructed to have sex with another woman in front of Epstein, and one said
+she had direct intercourse with him.
+In October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras were
+found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school
+transcript.
+Two of Epstein's former employees told investigators that young-looking girls showed up to
+perform massages two or three times a day when Epstein was in town.
+They said the girls were permitted many indulgences. A chef cooked for them. Workers gave
+them rides and handed out hundreds of dollars at a time.
+
+
+One employee told detectives he was told to send a dozen roses to one teenage girl after a high
+school drama performance. Others were given rental cars. One, according to police, received a
+$200 Christmas bonus.
+The cops moved to cement their case. But as they tried to tighten the noose, they encountered
+other forces at work.
+In Orlando they interviewed a possible victim who told them nothing inappropriate had
+happened between her and Epstein. They asked her whether she had spoken to anyone else.
+She said yes, a private investigator had asked her the same questions.
+» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal
+When they subpoenaed one of Epstein's former employees, he told them the same thing. He
+and a private eye had met at a restaurant days earlier to go over what the man would tell
+investigators.
+Detectives received complaints that private eyes were posing as police officers. When they told
+Epstein's local attorney, Guy Fronstin, he said the inyestigators worked for Roy Black, the
+high-powered Miami lawyer who has defended the likes of Rush Limbaugh and William
+Kennedy
+While the private eyes were conducting a paraliel investigation, Dershowitz, the Harvard law
+professor, traveled to West Palm Beach with information about the girls. From their own
+profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
+their use of alcohol and marijuana.
+He took his research to a meeting with prosecutors in early 2006, where he sought to cast
+doubt on the teens' reliability.
+The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
+did some of the girls have issues with drugs or alcohol but also some had criminal records and
+other troubles, Epstein's legal team claimed. And at least one of them, they said, lied when she
+told police she was younger than 18 when she started performing massages for Epstein.
+After the meeting, prosecutors postponed their decision to take the case to a grand jury.
+
+
+In the following weeks, police received complaints that two of the victims or their families had
+been harassed or threatened. Epstein's legal team maintains that its private investigators did
+nothing illegal or unethical during their research.
+By then, relations between police and prosecutors were fraying. At a key meeting with
+prosecutors and the defense, Detective
+Recarey, the lead investigator, was a no-show,
+according to Epstein's attorney.
+"The embarrassment on the prosecutor's face was evident when the police officer never
+showed up for the meeting," attorney Jack Goldberger said.
+Later in April, Recarey walked into a prosecutor's office at the state attorney's office and
+learned the case was taking an unexpected turn.
+The prosecutor, Lanna Belohlavek, told Recarey the state attorney's office had offered Epstein
+a plea deal that would not require him to serve jail time or receive a felony conviction.
+Recarey told her he disapproved of the plea offer.
+The deal never came to pass, however.
+Future unclear after charge
+On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
+counts of unlawful sexual activity with a minor and to charge his personal assistant,
+now 27, for her alleged role in arranging the visits. Police officials also wanted to
+charge
+, the self-described Heidi Fleiss, with lewd and lascivious acts.
+By then, the department was frustrated with the way the state attorney's office had handled the
+case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
+wrote a letter to State Attorney Barry Krischer suggesting he disqualify himself from the case if
+he would not act.
+Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
+the grand jury.
+
+
+It is not known how many of the girls testified before the grand jury. But Epstein's defense
+team said one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up.
+The grand jury's indictment was handed down in July. It was not the one the police
+department had wanted.
+Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
+charged with one count of felony solicitation of prostitution, which carries a
+ximum penalty
+of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
+released hours later.
+Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
+he said their claims that they had sexual encounters with him lack credibility.
+"They are incapable of being believed," he said. "They had criminal records. They had
+accusations of theft made against them by their employers. There was evidence of drug use by
+some of them."
+What remains for Epstein is yet to be seen.
+The Palm Beach Police Department has asked the FBI to investigate the case. It also has
+returned the $90,000 Epstein donated in 2004.
+In New York, candidates for governor and state attorney general have vowed to return a total
+of at least $60,000 in campaign contributions from Epstein. Meanwhile, Epstein's powerful
+friends have remained silent as tabloids and Internet blogs feast on the public details of the
+police investigation.
+Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
+plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
+"He will recover from this," he said
+Staff writer Larry
+Melanie Mena contributed to this story.
+and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
+amarra@pbpost.com
+
+
+@AMarraPBPost
+TELLIGENT GRIE
+NOT A CERTIFIED
+NOT A CERTIFIED O
+#
+
+
+273 / 278 - Tuesday, November 16, 2004
+Section: A SECTION
+Page: 1A
+Source: By PAUL OWERS Palm Beach Post Staff Writer
+Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
+Memo: Ran all editions.
+Dateline: WEST PALM BEACH
+TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
+When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
+Donald was not about to be trumped.
+"Nobody was going to outbid me," the brash developer-turned-TV personality said from his
+New York office.
+Trump bested two other bidders with a $41.35 million offer for the 43,000-square-foot,
+seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
+But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
+513 N. County Road. He wants to - what else? - sell it and make more money.
+another house before flipping the entire package.
+"I've known about this house for quite some time," Trump said. "It's probably the best piece
+of land in Florida - and probably the country - for luxury real estate."
+Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
+Lesly
+said zoning regulations allow for only two houses - and maybe a third.
+said she's not worried about Trump's plans.
+"He's been a very good property owner in the town of Palm Beach," she said. "He does his
+projects very well. He's a perfectionist."
+Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
+Gosman's Chapter 7 bankruptcy case. Proceeds from the sale will go into escrow for eventual
+distribution to creditors.
+The auction began at exactly noon after Judge Steven
+dismissed an objection from
+an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
+that Trump was not a qualified bidder because his contract stipulated that he would not close
+on the sale unless title insurance was in place beforehand.
+With Trump listening via conference call, Epstein began the bidding at $37.25 million -
+$250,000 higher than Trump's initial offer.
+Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn
+came, letting lawyers for Trump and Esptein bid against each other until the price hit $38.85
+million.
+Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had
+given up his right to bid by passing the first time.
+
+
+But
+allowed the offer to stand, and Pulte and Trump went back and forth until
+Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
+$38.6 million.
+closed the bidding 10 minutes after it started, leaving Trump with the right to buy
+the 29,000-square-foot home (a typical Palm Beach County single-family house is about
+2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
+quarters.
+The closing could take place within a week but probably won't happen until next month.
+Trustee Joe Luzinski and creditors said they were pleased with the outcome.
+"We knew we were dealing with some substantial people ... who were going to bid it up a
+bit," Luzinski said.
+"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
+"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
+The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
+former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't
+receive a commission, he said
+Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.
+"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
+Pulte said Gosman asked him before the auction whether he would be willing to let him stay
+in the mansion after the closing until he decides where he wants to move. Trump and
+Luzinski said they have had no such discussions with Gosman.
+Gosman, 75, had the house built after paying $12,1 million for the land in 1986.
+The former health-care magnate declined interview requests before and after the auction
+Monday. He was at the courthouse but left beforé the auction took place.
+The $41.35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
+Beach home and guest house but falls short of the $45 million that Virginia home builder
+Dwight Schar paid for Ron Perelman's, 26,000-square-foot estate, Casa Apava, a designated
+landmark.
+Schar also paid $18.6 million for a lakefront lot across the street from the main house, for a
+total of $63.6 million. Insiders say Schar spent a total of $70 million for his new property,
+making it the priciest residential sale in U.S. history.
+Gosman once had a fortune that Forbes magazine estimated at $480 million. He voluntarily
+filed for Chapter 11 bankruptcy protection in 2001, listing assets of $250 million and
+liabilities of $233.6 million.
+When a judge ruled that Gosman had to give up all of his exempt assets to creditors if he
+wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation.
+Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is
+invalid because Florida law does not recognize a Dominican Republic divorce that Lin
+Gosman tried to obtain from another man, Michael Castre.
+The judge's decision was a huge victory for creditors because it prevents Abe Gosman from
+protecting assets by claiming joint ownership with his wife. Gosman's assets, which include
+an extensive collection of artwork, could total as much as $70 million and will be sold later.
+Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's
+estate, said David Cimo, special counsel for the trustee.
+"We would have been thwarted ... or at least substantially impaired," Cimo said.
+
+
+The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
+an ownership interest in his home and other belongings only to avoid losing them in
+bankruptey, Gosman has denied any wrongdoing, saying he made the property transfers in
+1999, well before he filed for bankruptcy.
+Lessen is expected to rule in the next two months whether Gosman made improper transfers,
+a decision that will affect how much money will be available to creditors.
+Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
+willing to move forward, in part because the upkeep of the estate now exceeds their means.
+"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
+said. "That's not a house you want to live in unless you're making large amounts of money
+like Donald Trump."
+paul_owers@pbpost.com
+
+
+Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL
+Indictment: Billionaire Solicited 3 Times
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:30 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 25,
+2006)
+Billionaire money manager and Palm Beach part-time resident Jeffrey Epl
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
+of last year, according to an indictment charging him with felony solicitation of
+prostitution.
+Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
+was released on $3,000 bond.
+Epstein's case is unusual in that suspected prostitution johns are usually charged
+with a misdemeanor, and even a felony charge is typically made in a criminal
+information - an alternative to an indictment charging a person with the
+commission of a crime.
+His attorney, Jack Goldberger, declined to discuss the charge.
+State attorney's office spokesman Mike Edmondson also had little to say.
+"Generally speaking, there is a case that has a number of different aspects to it,"
+Edmondson said of a prostitution-related charge being submitted to a grand jury.
+"We first became aware of the case months ago by Palm Beach police."
+Prosecutors and police worked together to bring the case to the grand jury, he
+said.
+https://www.palmbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
+1/2
+
+
+Indictment: Billionaire Solicited 3 Times - News - The Palm Beach Post - West Palm Beach, FL
+Palm Beach police confirmed that and said the department will release a report
+today regarding its investigation.
+Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
+pool and a boat dock on the Intracoastal Waterway since 1990, according to
+property records. A man answering the door there Monday said that Epstein
+wasn't home. A Cadillac Escalade registered to him was parked in the driveway,
+which is flanked by two massive gargoyles.
+Epstein sued Property Appraiser Gary Nikolits in 2001, contending that the
+assessment of his home exceeded its fair market value. He dismissed his lawsuit
+in December 2002.
+A profile of Epstein in Vanity Fair magazine said he owns what are believed to
+be the largest private homes in Manhattan - 51,000 square feet - and in New
+Mexico - a 7,500-acre ranch. Those are in addition to his 70-acre island in the
+U.S. Virgin Islands and fleet of aircraft.
+Epstein's friends and admirers, according to the magazine, include prominent
+businessmen, academics and scientists and famed Harvard law professor Alan
+Dershowitz.
+larry_keller@pbpost.com
+https://www.palmbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
+2/2
+
+
+After long probe, billionaire faces solicitation charge - News - The Patm Beach Post - West Palm Beach, FL
+After long probe, billionaire faces solicitation
+charge
+Posted Jul 27, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:11 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 26,
+2006)
+Palm Beach billionaire Jeffrey Epstein paid to have underage girls and young
+women brought to his home, where he received massages and sometimes sex,
+according to an investigation by the Palm Beach Police Department.
+Palm Beach police spent months sifting through Epstein's trash and watching his
+waterfront home and Palm Beach International Airport to keep tabs on his
+private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
+him with one count of felony solicitation of prostitution.
+Palm Beach police thought there was probable cause to charge Epstein with
+unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
+handling of the case that he wrote a memo suggesting the county's top
+prosecutor disqualify himself.
+"I must urge you to examine the unusual course that your office's handling of this
+matter has taken and consider if good and sufficient reason exists to require your
+disqualification from the prosecution of these cases," Reiter wrote in a May 1
+memo to Krischer.
+While not commenting specifically on the Epstein case, Mike Edmondson,
+spokesman for the state attorney, said his office presents cases other than
+murders to a grand jury when there are questions about witnesses credibility and
+their ability to testify.
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+1/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+By the nature of their jobs, police officers look at evidence from a "one-sided
+perspective," Edmondson said. "A prosecutor has to look at it in a much broader
+fashion," weighing the veracity of witnesses and how they may fare under
+defense attorneys' questioning, he said.
+Epstein's attorney, Jack Goldberger, said his client committed no crimes.
+"The reports and statements in question refer to false accusations that were not
+charged because the Palm Beach County state attorney questioned the credibility
+of the witnesses," Goldberger said. A county grand jury "found the allegations
+wholly unsubstantiated and not credible," and that's why his client was not
+charged with sexual activity with minors, he said.
+Goldberger said Epstein passed a lie detector test administered by a reputable
+polygraph examiner in which he said he did not know the girls were minors.
+Also, a search warrant served on Epstein's home found no evidence to
+corroborate the girls' allegations, Goldberger said.
+According to police documents:
+- A Palm Beach Community College student said she gave Epstein a massage in
+the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
+sessions at his home.
+- A 27-year-old woman who worked as Epstein's personal assistant also
+facilitated the liaisons, phoning the PBCC student to arrange for girls when
+Epstein was coming to town. And she escorted the girls upstairs when they
+arrived, putting fresh sheets on a massage table and placing massage oils nearby.
+- Police took sworn statements from five alleged victims and 17 witnesses. They
+contend that on three occasions, Epstein had sex with the girls.
+A money manager for the ultra-rich, Epstein was named one of New York's most
+eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
+the likes of former President Clinton, former Harvard University President
+Summers and Donald Trump, and has lavish homes in Manhattan,
+New Mexico and the Virgin Islands.
+https:/www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-facos-solicitation-charge
+2/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - Vest Palm Beach, FL
+He has contributed tens of thousands of dollars to Democratic Party candidates
+and organizations, including Sen. John Kerry's presidential bid, and the Senate
+campaigns of Joe
+, Hillary Clinton,
+Dodd and Charles
+Schumer.
+COPY
+Goldberger is one of five attorneys Epstein has retained since he became the
+subject of an investigation, Edmondson said. Among the others: Alan
+Dershowitz, the well-known Hafvard law professor and author, who is a friend
+of Epstein. Dershowitz could not be reached for comment.
+Police said the woman who enlisted young girls for Epstein was
+20, of
+Palm Beach.
+has worked at an Olive Garden restaurant in
+Wellington and said she was a journalism major at Palm Beach Community
+College when she was questioned by police last October. She has an unlisted
+phone number and could not be reached for comment.
+said she met Epstein when, at age 17, a friend asked her if she would like
+to make money giving him a massage. She said she was driven to his fivebedroom, 7 1/2-bath home on the Intracoastal Waterway, then escorted upstairs
+to a bedroom with a massage table and oils. Epstein and
+were both naked
+during the massage, she said, but when he grabbed her buttocks, she said she
+didn't want to be touched.
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+3/5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+Epstein said he'd pay her to bring him more girls - the younger the better,
+told police. When she tried once to bring a 23-year-old woman to him,
+Epstein said she was too old,
+said.
+, who has not been charged in the case, said she eventually brought six
+girls to Epstein who were paid $200 each time,
+said. "I'm like a Heidi
+Fleiss," police quoted her as saying. The girls knew what to expect when they
+were taken to Epstein's home,
+said. Give a massage - maybe naked - and
+allow some touching
+One 14-year-old girl
+took to meet Epstein led police to start the
+investigation of him in March 2005. A relative of the girl called to say she
+thought the child had recently engaged in sex with a Palm Beach man. The girl
+then got into a fight with a classmate who accused her of being a prostitute, and
+she couldn't explain why she had $300 in her purse.
+The girl gave police this account of her meeting with Epstein:
+She accompanied
+and a second gifl to Epstein's house on a Sunday in
+February 2005. Once there, a woman she thought was Epstein's assistant told the
+girl to follow her upstairs to a room featuring a mural of a naked woman, several
+photographs of naked women on a shelf, a hot pink and
+I sofa and a massage
+table.
+She stripped to her bra and panties and gave him a massage.
+Epstein gave the 14-yéar-old $300 and she and the other girls left, she said. She
+said Robson told her that Epstein paid her $200 that day.
+Other girls told similar stories. In most accounts, Epstein's personal assistant at
+the time,
+, now 27, escorted the girls to Epstein's bedroom.
+, whose most recent known address is in North Carolina, has not been
+charged in the case.
+Palm Beach police often conducted surveillance of Epstein's home, and at Palm
+Beach International Airport to see if his private jet was there, so they would
+know when he was in town. Police also arranged repeatedly to receive his trash
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+415
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+from Palm Beach sanitation workers, collecting papers with names and phone
+numbers, sex toys and female hygiene products.
+One note stated that a female could not come over at 7 p.m. because of soccer.
+Another said a girl had to work Sunday - "Monday after school?" And still
+another note contained the work hours of a girl, saying she leaves school at 11:30
+a.m. and would come over the next day at 10:30 a.m.
+Only three months before the police department probe began, Epstein donated
+$90,000 to the department for the purchase of a firearms simulator, said Jane
+Struder, town finance director. The purchase was never made. The money was
+returned to Epstein on Monday, she said.
+NOT A CERTIFIED CO
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+5/5
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+Police say lawyer tried to discredit teenage
+girls
+Posted Jul 29, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 2:00 PM
+(EDITOR'S NOTE: This story originally was published in The Palm Beach Post on July
+29, 2006)
+Famed Harvard law professor Alan Dershowitz met with the Palm Beach County
+State Attorney's Office and provided damaging information about teenage girls
+who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
+charged massages, according to police reports.
+The reports also state that another Epstein attorney agreed to a plea bargain that
+would have allowed Epstein to have no criminal record. His current attorney
+denies this happened.
+And the documents also reveal that the father of at least one girl complained that
+private investigators aggressively followed his car, photographed his home and
+chased off visitors.
+Police also talked to somebody who said she was offered money if she refused to
+cooperate with the Palm Beach Police Department probe of Epstein.
+The state attorney's office said it presented the Epstein case to a county grand
+jury this month rather than directly charging Epstein because of concerns about
+the girls' credibility. The grand jury indicted Epstein, 53, on a single count of
+felony solicitation of prostitution, which carries a maximum penalty of five years
+in prison.
+Police believed there was probable cause to charge Epstein with the more serious
+crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
+Krischer a memo in May suggesting he disqualify himself from the case.
+https://www.palmbeachdailynews.com/article/20060729/NEWVS/190917573
+114
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+The case originally was going to be presented to the grand jury in February, but
+was postponed after Dershowitz produced information gleaned from the Web
+site myspace.com showing some of the alleged victims commenting on alcohol
+and marijuana use, according to the police report prepared by Detective
+Recarey.
+, a 20-year-old
+Palm Beach woman who told police she
+recruited girls for Epstein, also is profiled on myspace.com. Her page includes
+photos of her and her friends, including one using the name "Pimpin' Made EZ."
+, who was not charged in the case, is a potential prosecution witness.
+According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
+Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with
+Epstein, accepted the deal, in which Epstein would plead guilty to one count of
+aggravated assault with intent to commit a felony, be placed on five years'
+probation and have no criminal record. The deal also called for Epstein to submit
+to a psychiatric and sexual evaluation and have no unsupervised visits with
+minors, according to Recarey's report. The plea bargain was made in connection
+with only one of the five alleged victims, the report states.
+Fronstin - who declined to comment on the case - was subsequently fired and
+veteran defense attorney Jack Goldberger was hired. He denies there was any
+agreement by any of Epstein's attorneys to a plea deal.
+"We absolutely did not agree to a plea in this case," he said. Neither Belohlavek
+nor a state attorney's spokesman could be reached for comment.
+The parent or parents of alleged victims who complained of being harassed by
+private investigators provided license tag numbers of two of the men. Police
+found the vehicles were registered to a private eye in West Palm Beach and
+another in Jupiter, according to Recarey's report.
+"I have no knowledge of it," defense attorney Goldberger said.
+The report also says a woman connected to the Epstein case was contacted by
+somebody who was still in touch with Epstein. That person told her she would
+be compensated if she didn't cooperate with police, Recarey's report says. Those
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+214
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Paim Beach, FL
+who did talk "will be dealt with," the woman said she was told. Phone records
+show the woman talked with the person who allegedly intimidated her around
+the time she said, Recarey reported.
+Phone records also show that the person said to have made the threat then
+placed a call to Epstein's personal assistant, who in turn called a New York
+corporation affiliated with Epstein, the report states.
+The issue in the Epstein case is not whether females came to his waterfront
+home, but whether he knew their ages.
+"He's never denied girls came to the house," Goldberger said. But when Epstein
+was given a polygraph test, "he passed on knowledge of age," the attorney said.
+After the indictment against Epstein was unsealed this week, Police Chief Reiter
+referred the matter to the FBI. "We've received the referral, and we're reviewing
+it," said FBI spokeswoman Judy Orihuela in Miami.
+The chief himself has come under attack from Epstein's lawyers and friends in
+New York, where he has a home. The New York Post quoted Epstein's
+prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
+only "because of the craziness of the police chief."
+Reiter has declined to comment on the case.
+Prosecutors have not presented a sex-related case like Epstein's to a grand jury
+before, said Mike Edmondson, spokesman for the state attorney's office. "That's
+what you do with a case that falls into a gray area," he said.
+The state attorney's office did not recommend a particular criminal charge on
+which to indict Epstein, Edmondson said. The grand jury was presented with a
+list of charges from highest to lowest, then deliberated with the prosecutor out of
+the room, he said.
+"People are surprised at the grand jury proceeding," West Palm Beach defense
+attorney Richard Tendler said. "It's a way for the prosecutor's office to not take
+the full responsibility for not filing the (charge), and not doing what the Palm
+Beach Police Department wanted. I think something fell apart with those
+underage witnesses."
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+3/4
+
+
+Police say lawyer tried to discredit teenage girls - Newg - Palm Beach Daily News - Palm Beach, FL
+Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
+must have been incredible or untrustworthy, I don't know," he said.
+Other attorneys said Epstein's case raises the issue of whether wealthy, connected
+defendants like Epstein - whose friends include former President Clinton and
+Donald Trump - are treated differently from others. Once he knew he was the
+subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
+Dershowitz and Lefcourt, who is a past president of the National Association of
+Criminal Defense Lawyers.
+Miami lawyer Roy Black - who became nationally known when he successfully
+defended William Kennedy
+on a rape charge in Palm Beach - also was
+involved at one point.
+Said defense attorney
+Suskauer: "I think it's unfortunate the public may
+get the perception that with power, you may be treated differently than the
+average Joe."
+CERTIFIE
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+4/4
+
+
+Expert: Ignorance of age isn't
+defense in sex cases
+Posted Aug 5, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 1:38 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 5, 2006)
+Even if Palm Beach money manager Jeffrey Epstein didn't
+know that girls who police say gave him sexual massages at
+his Intracoastal home were under the legal age, that alone
+wouldn't have exempted him from criminal charges of
+sexual activity with minors.
+"Ignorance is not a valid defense" said Bob Dekle, a legal
+skills professor who was a Lake City prosecutor for nearly
+30 years, half of that time speci
+zing in sex crimes against
+children.
+'There is no knowledge element as far as the age is
+concerned," Dekle said.
+After an 11-month investigation, Palm Beach police said
+there was probable cause to charge Epstein, 53, with
+unlawful sex acts with a minor and lewd and lascivious
+molestation. They contend that Epstein - friend of the rich
+and famous and financial patron of Democratic Party
+organizations and candidates - committed those acts with
+five underage girls.
+In the past week, New York Attorney General and
+gubernatorial candidate Eliot Spitzer has returned about
+$50,000 in campaign contributions he received from
+Epstein, and Mark
+, a candidate to replace Spitzer in
+
+
+his current job, has returned $10,000 to him because of the
+Palm Beach scandal, the New York Daily News has
+reported.
+Rather than file charges, the state attorney's office
+presented the case to a county grand jury. The panel
+indicted Epstein last week on a single, less serious charge of
+felony solicitation of prostitution.
+The case raised eyebrows because the state attorney's office
+rarely, if ever, kicks such charges to a grand jury. And it
+increases the difficulty of prosecuting child sex abuse cases,
+especially when the defendant is enormously wealthy and
+can hire high-priced, top-tier lawyers.
+At least one of Epstein's alleged victims told police he knew
+she was underage when the two of them got naked for
+massages and sexual activity. She was 16 years old at the
+time and said Epstein asked her questions about her high
+school, according to police reports.
+A girl who said she met Ep
+when she was 15 said he
+told her if she told anybody what happened at his house,
+bad things could happen, the police reports state.
+Epstein's youngest alleged victim was 14 when she says she
+gave him a massage that included some sexual activity. She
+is now 16. The girl's father says he doesn't know whether
+she told Epstein her age.
+"My daughter has kept a lot of what happened from me
+because of sheer embarrassment," he said. "But she very
+much looked 14. Any prudent man would have had second
+thoughts about that."
+Defense attorney Jack Goldberger maintains that not only
+did Epstein pass a polygraph test showing he did not know
+the girls were minors, but their stories weren't credible.
+The state attorney's office also implied that their credibility
+was an issue when it decided not to charge Epstein directly,
+but instead give the case to the grand jury.
+
+
+"A prosecutor has to look at it in a much broader fashion," a
+state attorney's spokesman said last week.
+LEARH MORE
+Epstein hired Harvard law Professor Alan Dershowitz
+when he became aware he was under investigation, and
+Dershowitz gave prosecutors information that some of the
+alleged victims had spoke of using alcohol and marijuana on
+a popular Web site, according to a Palm Beach police
+report.
+Prosecutors typically consider two things in deciding
+whether to charge somebody with sex-related offenses
+against minors - whether there is sufficient evidence and
+whether there is a public interest in doing so, Dekle said.
+If two teens are in a sexual relationship and the boy turns
+18 before the girl, he could be charged with a sex crime if
+the sex continues. There would be no public interest in
+pursuing that, Dekle said.
+But where there is a large gap in ages - and especially in
+cases of teachers with students - there is a public interest in
+prosecuting, he said. Likewise if the accused has a track
+record of sex with minors.
+
+
+Still there is a "universal constant" in prosecuting these
+cases, Dekle said. Men who exploit underage children for
+sex often carefully choose their victims in ways that will
+minimize the risk to them, he said.
+Victims usually are from a lower social status, and they may
+suffer from psychological problems, Dekle said.
+"Lots of child sexual abuse victims have been victimized by
+multiple people over a period of time. Then the act of abuse
+produces behavior in the victims that further damages their
+credibility." Examples include promiscuous behavior and
+drug abuse.
+Some of the alleged victims in the Epstein case returned to
+his home multiple times for the massage sessions and the
+$200 to $300 he typically paid them per visit. "That would
+be a definite problem for the prosecutor, said Betty Resch,
+who prosecuted crimes against children in Palm Beach
+County for five years and now is in private practice in Lake
+Worth.
+"The victim becomes less sympathetic" to a jury, Resch said.
+"But she's a victim nevertheless. She's a kid."
+Most men charged with sex crimes against minors look
+normal, Dekle said. A jury expecting to see a monster
+seldom will. And the victims' ages work against them and in
+favor of the defendant in a trial, Dekle said.
+If a child and an adult tell different stories and both swear
+they're telling the truth, adult jurors are more likely to
+believe the adult, Dekle said.
+"You have all these things working against you in a child
+sex abuse case. Prosecutors normally try to be very careful
+in filing those cases because they know what they're getting
+into. There is no such thing as an iron-clad child sexual
+abuse case."
+
+
+Epstein camp calls female accusers
+liars
+Posted Aug 8, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:35 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 8, 2006)
+Attorneys and publicists for Palm Beach financier Jeffrey
+Epstein went on the offensive Monday, contending that
+teenage girls who have accused Epstein of sexual
+shenanigans at his waterfront home are liars and saying
+that the Palm Beach Police Department is "childish."
+"There never was any sex between Jeffrey Epstein and any
+underage women," his lead attorney, Jack Goldberger, said
+from Idaho where he was vacationing with his family.
+Epstein did have young women come to his house to give
+him massages, Goldberger said. "Mr. Epstein absolutely
+insisted anybody who came to his house be over the age of
+18. How he verified that, I don't know. The question is, did
+anything illegal occur. The law was not violated here."
+He had no explanation as to why Epstein would pay girls or
+women with no massage training - as the alleged victims
+said was the case - $200 to $300 for their visits. "The
+credibility of these witnesses has been seriously
+questioned," Goldberger said.
+Epstein, 53, was indicted by a county grand jury last month
+on a charge of felony solicitation of prostitution. After an
+11-month investigation that included sifting through
+Epstein's trash and surveilling his home, Palm Beach police
+concluded there was enough evidence to charge him with
+sexual activity with minors. When the grand jury indicted
+
+
+Epstein on the less serious charge, Police Chief Michael
+Reiter referred the case to the FBI to determine whether
+there were federal law violations.
+After a spate of stories about the case last week, New York
+publicist Dan Klores - whose client list has included Paris
+Hilton and Jennifer
+- said on Saturday that Epstein's
+camp was ready "to get their story out."
+They did that Monday via Goldberger and a Los Angeles
+publicist for Miami criminal defense attorney Roy Black,
+who also has represented Epstein in the case.
+"We just think there has been a distorted view of this case
+in the media presented by the Palm Beach police,
+Reiter has consistently declined to comment on the case
+and did not respond to a request for comment Monday.
+The implication that State Attorney Barry Krischer was
+easy on Epstein by presenting the case to a grand jury
+rather than filing charges directly against him is wrong,
+
+
+The Palm Beach Police Department was "happy and
+ecstatic" that the panel was going to review the evidence. "I
+think what happened is they weren't happy with the result.
+They decided to use the press to embarrass Mr. Epstein."
+But records show that Reiter wrote Krischer on May 1 -
+well before the case went to the grand jury - suggesting that
+Krischer "consider if good and sufficient reason exists to
+require your disqualification from the prosecution of these
+cases."
+Rather than flat-out decline to charge Epstein, Krischer
+referred the case to the grand jury to "appease" the chief,
+A state attorney's spokesman would say only that the office
+refers cases to the grand jury when there are issues with the
+viability of the evidence or witnesses credibility.
+Both the state attorney and the grand jury concluded there
+was not sufficient evidence that Ep
+had sex with
+minors, according to Goldberger. "It was just a childish
+performance by the Palm Beach Police Department,"
+The defense attorney said one of the alleged victims who
+claimed she was a minor was in fact over the age of 18.
+Another alleged victim who was subpoenaed to testify to
+the grand jury failed to do so. Epstein's accusers, he added,
+have histories of drug abuse and thefts. "These women are
+liars. We've established that."
+But why would they all invent their stories about meeting
+Epstein for sexual massages?
+"I don't have an answer as to what was the motivation for
+these women to come forward and make these allegations,"
+
+
+Newspaper
+cancery
+The Palm Beach Post (West Palm Beach, Florida) - 14 Aug 2006, Mon - Page 7
+Downiaceo an Mav 11. 2019
+Palm Beach chief focus
+i of fire in Epstein case
+COPY
+bar bert orschaning
+Reiter focus of fire in Epstein case
+Clipped By:
+reiter_m
+Sat, Apr 22, 2017
+Copyright @2019 Newspapers.com. All Rights Reserved.
+
+
+Delays in Epstein case unusual,
+lawyers say
+Posted Mar 13, 2007 at 12:01 AM
+Updated Oct 3, 2019 at 3:48 PM
+(EDITOR'S NOTE: This story originally published in The Palm
+Beach Post March 13, 2007)
+A federal probe or a plea deal could explain the wait in the
+Palm Beacher's solicitation case.
+Nearly eight months after Palm Beach tycoon Jeffrey
+Epstein was charged with felony solicitation of prostitution,
+there has been no discernible progress in his case. No
+witnesses deposed. No trial date set. Nothing, save for
+routine court hearings reset without explanation.
+"Usually that would be unusual," said criminal defense
+attorney Glenn Mitchell, who has no involvement in the
+case.
+"As a general rule, it would be unusual for nothing to have
+happened, agl
+Michael Dutko, a criminal defense
+attorney in Fort Lauderdale. He represents
+20, of
+Palm Beach, potentially a key witness in the
+case.
+A routine hearing for Epstein was pulled from the court
+docket last week and reset for May 16. The delays and
+inaction could be due to a potential federal probe of Epstein
+or because a plea deal is in the works, attorneys say.
+Unusual is the word that best describes everything about
+the case against Epstein, 54, an enigmatic money manager
+in New York City who counts Bill Clinton and Donald
+Trump among his friends.
+
+
+"Highly unusual" is how Palm Beach Police Chief Michael
+Reiter described State Attorney Barry Krischer's handling
+of the case in a bluntly critical letter to Krischer last year
+before Epstein was indicted.
+Reiter referred the matter to the FBI to determine whether
+any federal laws had been violated. Epstein's allies
+countered by attacking the chief personally and
+professionally.
+Reiter's department investigated Epstein for 11 months.
+Police sifted repeatedly through his trash and conducted
+surveillance on his five-bedroom, 7 1/2-bath, 7,234-squarefoot home on the Intracoastal Waterway.
+Police said Epstein paid women and girls as young as 14 to
+give him erotic massages at his home. Police thought there
+was probable cause to charge him with unlawful sex acts
+with a minor and lewd and lascivious molestation.
+Epstein responded by hiring a phalanx of lawyers. One of
+them, Harvard law professor and author Alan Dershowitz,
+provided the state attorney's office with information about
+alcohol and marijuana use by some of the girls who said
+they were with Epstein.
+Prosecutors then referred the case to the grand jury rather
+than file charges directly against Epstein.
+Epstein's attorneys deny he had sex with underage girls.
+The lawyers say the girls' stories are not credible. But if the
+court file is any indicator, they've made no effort to depose
+the girls.
+Neither prosecutors nor defense attorneys have sought to
+question L
+, said Dutko, her attorney. She recruited
+teenage girls to visit Epstein for massages and sexual
+activity, Palm Beach police said, and presumably would be a
+key witness.
+
+
+Epstein's attorney Jack Goldberger did not return phone
+messages.
+A source close to the case suggested it is languishing
+pending a decision by the FBI on whether to refer it to
+federal prosecutors.
+"We still have a pending case," FBI spokeswoman Judy
+Orihuela said Monday.
+State Attorney Krischer did not return a call for comment.
+His spokesman, Mike Edmondson, declined to say whether
+federal investigators are delaying the Epstein case. But, he
+added, "if another agency is looking at something, we
+wouldn't want to step on their toes."
+Attorneys say inertia in a criminal case often points to a
+pending plea deal.
+"It would not surprise me if something has happened that's
+not reflected in the court file,"
+'said Dutko, such as an
+agreement that will be for
+Alized later.
+Defense attorney Mare Shiner said defense attorneys
+sometimes put off overtly conducting discovery -- deposing
+witnesses, requesting documents and the like -- because
+doing so creates more work for harried prosecutors who
+may become angry and not offer a plea deal.
+"Sometimes defense lawyers, knowing that, will try and do
+discovery without taking depositions," said Shiner, a former
+prosecutor for 13 years.
+Instead, they may conduct a below-the-radar probe such as
+having a private investigator check out leads, he said.
+Shiner and others say a plea deal for Epstein probably
+would result in pretrial intervention, in which a defendant
+may be ordered to undergo a psychological evaluation,
+counseling or other conditions in return for dropping the
+charge.
+
+
+Edmondson, spokesman for State Attorney Krischer, said
+there is no plea offer and no request for the prosecution to
+show its cards.
+"To my knowledge, it's never happened before on a filed
+case," he said.
+
+
+252 / 278 - Thursday, October 18, 2007
+Section: LOCAL
+Page: 5B
+Source: The Associated Press
+Illustration: PHOTO (B&W)
+Memo: Ran all editions.
+Dateline: NEW YORK
+WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
+A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
+prostitutes, is being sued by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model
+The lawsuit, filed late Tuesday in Manhattan's state Supreme Court, says financier Jeffrey Epstein hac
+the teen perform a sex act when she brought photographs of herself for him to review in his Upper
+East Side mansion sometime in 2000.
+Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
+you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
+included massages and other favors.
+When the girl told Epstein, "I am 16 years old and just want to model," he replied, "Don't worry, I
+won't tell anybody," court papers say.
+Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
+indicted in Palm Beach on charges of soliciting underage prostitutes. That case is pending.
+The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
+sex acts" while she was a minor, the lawsuit says.
+Epstein "repeatedly requested that (the girl) return with her 14, 15-, and 16-year-old girlfriends,
+stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
+40s). I love girls your age.'"
+The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
+lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
+of severe mental disease and defect."
+Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
+read a newspaper and recognize the word 'rich."
+Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly,
+and will almost certainly be dismissed.
+He refused to comment on Epstein's Florida charges.
+Weavine on lawsuit here no year agains ancient rest sad with in avinas arthe center
+underage girls. That case is pending.
+"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said
+Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve
+the case out of court.
+
+
+Palm Beacher pleads in sex case
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 3, 2019 at 1:47 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on july 1, 2008)
+Jeffrey Epstein will serve 1 1/2 years on teen solicitation
+charges.
+He lives in a Palm Beach waterfront mansion and has kept
+company with the likes of President Clinton, Prince
+Andrew and Donald Trump, but investment banker Jeffrey
+Epstein will call the Palm Beach County Jail home for the
+next 18 months.
+Epstein, 55, pleaded guilty Monday to felony solicitation of
+prostitution and procuring a person under the age of 18 for
+prostitution. After serving 18 months in jail, he will be
+under house arrest for a year. And he will have a lifelong
+obligation to register as a sex offender. He must submit to
+an HIV test within 48 hours, with the results being
+provided to his victims or their parents.
+As part of the plea deal, federal investigators agreed to drop
+their investigation of Epstein, which they had taken to a
+grand jury, two law enforcement sources said.
+Epstein was indicted two years ago after an 11-month
+investigation by Palm Beach police. They received a
+complaint from a relative of a 14-year-old girl who had
+given Epstein a naked massage at his five-bedroom, 7,234-
+square-foot, $8.5 million Intracoastal home.
+Police concluded that there were several other girls brought
+in 2004 and 2005 to an upstairs room at the home for
+similar massages and sexual touching.
+
+
+The indictment charged Epstein only with felony
+solicitation of prostitution. The state attorney's office later
+added the charge of procuring underage girls for that
+purpose.
+Prosecutor Lanna Belohlavek said of the plea: "I took into
+consideration the length the trial would have been and
+witnesses having to testify" about sometimes embarrassing
+incidents.
+Epstein may have made a serious mistake soon after he was
+charged. He rejected an offer to plead guilty to one count of
+aggravated assault with intent to commit a felony,
+according to police documents. He would have gotten five
+years' probation, had no criminal record and not been a
+registered sex offender, the documents indicate.
+Epstein arrived in court Monday with at least three
+attorneys. He wore a blue blazer, blue shirt, blue jeans and
+and gray sneakers. After Circuit Judge Deborah Dale
+Pucillo accepted the plea, he was fingerprinted. Epstein
+then removed his blazer and was handcuffed for the trip to
+jail while his attorneys tried to shield him from
+photographers lenses.
+When he eventually is released to house arrest, Epstein will
+have to observe a 10 p.m. to 6 a.m. curfew, have no
+unsupervised contact with anyone younger than 18 and
+neither own nor possess pornographic or sexual materials
+"that are relevant to your deviant behavior," the judge said.
+Epstein will be allowed to leave home for work. The New
+York-based money manager told the judge he has formed
+the not-for-profit Florida Science Foundation to finance
+scientific research. "I'm there every day," Epstein said.
+The foundation was incorporated in November. Epstein
+said he already has awarded money to Harvard and MIT.
+
+
+When he is released from jail, there is a chance that Epstein
+will be forced to move. Sex offenders are not allowed to live
+within 1,000 feet of a school, park or other areas where
+children may gather. No determination has been made as to
+whether Epstein's home complies, but attorneys said it
+likely does.
+Sex offenders also typically must attend counseling sessions.
+Belohlavek said that was waived for Epstein because his
+private psychiatrist is working with him. The judge was
+skeptical but agreed to it.
+Epstein's legal woes don't end with Monday's plea. There
+are four pending federal civil lawsuits and one in state court
+related to his behavior. At least one woman has sued him in
+New York, where he owns a 51,000-square-foot Manhattan
+mansion.
+"It's validation of what we're saying in the civil cases," said
+Miami attorney Jeffrey Herman, who represents the alleged
+victims in the federal lawsuits, West Palm Beach attorney
+Ted Leopold represents one alleged victim in a civil suit in
+state court. He said he anticipates amending that lawsuit to
+add "a few other clients" as well.
+In the criminal case, police went so far as to scour Epstein's
+trash and conduct surveillance at Palm Beach International
+Airport, where they watched for his private jet so they
+would know when he was in town. They concluded that
+Epstein paid girls $200 to $300 each after the massage
+sessions.
+"I'm like a Heidi Fleiss," [
+• now 22, told police
+about her efforts in recruiting girls for Epstein.
+There was probable cause to charge Epstein with unlawful
+sex acts with a minor and lewd and lascivious molestation,
+police concluded.
+
+
+The state attorney's office said questions about the girls'
+credibility led it to take the unprecedented step of
+presenting the evidence against Epstein to a grand jury,
+rather than directly charging him.
+Palm Beach Police Chief Michael Reiter was furious with
+State Attorney Barry Krischer, saying in a May 2006 letter
+that the prosecutor should disqualify himself. "I continue to
+find your office's treatment of these cases highly unusual,"
+he wrote. He then asked for and got a federal investigation.
+Epstein hired a phalanx of high-priced lawyers - including
+Harvard law professor and author Alan Dershowitz - and
+public relations people who questioned Reiter's competence
+and the victims' truthfulness.
+In addition to mansions in Palm Beach and Manhattan,
+Epstein owns homes in New Mexico and the Virgin Islands.
+He's a frequent contributor to Democrațic Party candidates.
+He also donated $30 million to Harvard in 2003.
+Former New York Gov. Eliot Spitzer returned a $50,000
+campaign contribution from Epstein after his indictment,
+then resigned this year during his own sex scandal. And the
+same Palm Beach Police Department that vigorously
+investigated Epstein returned his $90,000 donation for the
+purchase of a firearms simulator.
+Staff writer Eliot Kleinberg and former staff researcher
+Michelle Quigley contributed to this story.
+
+
+Jeffrey Epstein: Scientist,
+stuntman, 'sex slave' visit jailed
+tycoon
+By LARRY
+/ Palm Beach Post Staff Writer
+Posted Aug 13, 2008 at 12:01 AM
+Updated Jul 16, 2019 at 4:54 PM
+Tycoon Jeffrey Epstein mingled with an eclectic mix of
+people, including beautiful young women, before he got
+into trouble for paying teenage girls to give him sexual
+massages at his Palm Beach mansion.
+Not much has changed, even though he now resides in a
+dorm at the Palm Beach County Sheriff's Office's 17-acre,
+967-bed stockade near the fairgrounds.
+During his first month of confinement, Epstein was visited
+by the female assistant who, girls told police, had escorted
+them to the room at his mansion where they gave him
+naked massages.
+Also trekking to the jail was a young woman whom Epstein
+purportedly described as his Yugoslavian sex slave.
+The wealthy financier and science wonk also has been
+visited by an expert on artificial intelligence, as well as a
+man who is a mixed martial arts aficionado and sometime
+movie stuntman.
+The only other people to visit him at the jail, according to
+records, are a l
+Island man and an individual who
+listed Epstein's Palm Beach address as his own.
+Epstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,
+followed by a year of house arrest. Epstein paid teenage
+
+
+girls $200 to $300 in 2004 and 2005 for massages in his
+home that sometimes included sexual touching, Palm Beach
+police said.
+His jail visitors in July included:
+, 29, who some of the teen masseuses said
+phoned them when Epstein was in town and escorted them
+upon their arrival at his Palm Beach waterfront home to an
+upstairs room, where she prepared the massage table and
+provided the oils for their encounters with him.
+visited Epstein three times in July, according to a jail
+visitor's log.
+lists a Manhattan home address.
+Reached by telephone, she declined to discuss Epstein.
+23, whose family in Yugoslavia
+Epstein paid money to so that he could bring her to the
+United States to be his "sex slave," two teenage girls told
+police. One girl told police that Epstein instructed
+and her to kiss and have sex while he watched
+and masturbated. Another said she engaged in sex with
+at Epstein's urging.
+visited Epstein
+in jail four times in 13 days. She lists her address as on the
+Upper East side of Manhattan, not far from Epstein's
+enormous apartment.
+- Roger Schank, 62, founder of the Institute for Learning
+Sciences at Northwestern University and an expert on
+artificial intelligence, paid one visit to Epstein. Schank has
+written numerous books on that subject and has a doctorate
+degree from Yale University in linguistics. He was one of 19
+people who applied to be president of Florida Atlantic
+University in 2003. He became "chief learning officer" at the
+online Trump University in 2005. Schank listed his address
+as being in Stuart, and records show he also owns a home
+in Lake Worth.
+
+
+Epstein has financed a number of scientists over the years,
+including Nobel Prize winners. He gave $30 million to
+Harvard University in 2003. In November, he formed the
+not-for-profit Florida Science Foundation, which he said
+finances scientific research.
+- Igor Zinoviev, a Russian mixed martial arts fighter, who
+coaches a Chicago team in the International Fight League.
+He also has worked as a personal trainer, celebrity
+bodyguard and movie stuntman, according to the league's
+Web site. The New Jersey resident visited Epstein seven
+times in July.
+Zinoviev, Schank and
+comment.
+could not be reached for
+Staff researcher Niels
+Heimeriks
+contributed to this story.
+
+
+Billionaire sex offender leaves jail
+six days a week for work
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 4, 2019 at 9:27 AM
+Palm Beach billionaire Jeffrey Epstein, who's serving 18
+months in jail for soliciting an underage girl for
+prostitution, is allowed to leave the Palm Beach County
+Stockade six days a week on a work-release program.
+Teri Barbera, spokeswoman for the Palm Beach County
+OPY
+Sheriff's Office, confirmed that Epstein, 55, has been in the
+work-release program since Oct. 10.
+"He works six days a week: Friday through Wednesday 10
+a.m. to 10 p.m.," Barbera said via e-mail. "(He) works at his
+local West Palm Beach office, monitored on an active GPS
+system (he wears an ankle bracelet). Mr. Epstein hires a
+permit deputy, at his expense, for his own security at his
+workplace during the time he is out."
+Miami attorney Jeffrey Herman represents six young
+women who've sued Epstein, claiming he sexually abused
+them at his Palm Beach home when they were minors.
+Herman said he received a letter about the work-release
+program from the U.S. Attorney's Office within the past
+few days. But Herman says Epstein had been out on workrelease for several weeks before the notification.
+"My clients expressed shock and disappointment," Herman
+said. "I find it incredible that he's on work-release in the
+community and my clients aren't notified of this and we get
+this letter weeks after the fact."
+Jack Goldberger, Epstein's criminal attorney, said the
+
+
+arrangement is not unusual.
+"He goes to work every single day and goes back to jail at
+night, just like everybody else (in the program),"
+Epstein pleaded guilty June 30 to two felony counts:
+soliciting prostitution and procuring a person under 18 for
+prostitution. As part of the plea agreement, Epstein must
+serve one year of house arrest and register as a lifelong sex
+offender.
+
+
+Women want Epstein sex plea deal
+unsealed
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:23 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post June 10, 2009)
+Their attorneys will ask a judge to open Jeffrey Epstein's
+records.
+When wealthy money manager Jeffrey Epstein of Palm
+Beach pleaded guilty last year to procuring teens for
+prostitution, his case detoured around local and state rules
+regarding the sealing of court documents.
+At a plea conference on the state charges, a judge, a defense
+lawyer and a prosecutor huddled at the bench and decided
+that a deal Epstein had struck with federal prosecutors to
+avoid charges should be sealed, according to a transcript of
+the hearing.
+And so it was.
+But Florida rules of judicial administration, as well as rules
+of the Palm Beach County court system, require public
+notification that a court document has been or will be
+sealed, meaning kept from public view. The rules also
+require a judge to find a significant reason to seal, such as
+protecting a trade secret or a compelling government
+interest.
+Yet no notification or reason occurred in Epstein's case,
+according to court records.
+
+
+Epstein's own attorneys, in federal filings, have referred to
+his confidential deferred prosecution agreement with the
+U.S. attorney's office, struck in September 2007, as
+"unprecedented" and "highly unusual." And it was "a
+significant inducement" for Epstein to accept the state's
+deal, observed the state judge who accepted his plea,
+County Judge Deborah Dale Pucillo.
+Epstein now faces at least a dozen civil lawsuits in federal
+and state courts filed by young women who said they had
+sex with him and now are seeking damages.
+Attorneys for some of those women want his agreement
+with federal prosecutors unsealed and will ask Circuit Judge
+Jeffrey Colbath to do so today.
+"It is against public policy for these documents to be have
+been sealed and hidden from public scrutiny. As a member
+of the public, E. W. has a right to have these documents
+unsealed," wrote former Circuit Judge Bill Berger, now in
+private practice and representing one of the women.
+The Palm Beach Post also will ask Colbath to unseal the
+agreement. Post attorney Deanna Shullman will argue that
+the public has a right to know the specifics of Epstein's deal.
+According to various media accounts, Epstein moved in
+circles that included President Clinton, Donald Trump and
+Prince Andrew. "International Moneyman of Mystery,"
+declared a 2002 New York magazine profile of Epstein.
+Epstein, 56, is in the Palm Beach County Stockade, serving
+an 18-month sentence after pleading guilty nearly a year
+ago to felony solicitation of prostitution and procuring
+teenagers for prostitution.
+He is allowed out from 7 a.m. to 11 p.m., escorted by a
+deputy, said Palm Beach County Sheriff's Office
+spokeswoman Teri Barbera.
+
+
+During a Palm Beach Police Department investigation, five
+victims and 17 witnesses gave statements. They told of
+young women brought by his assistants to Epstein's
+mansion on El Brillo Way for massages and sexual activity,
+and then being paid afterward.
+At Epstein's plea conference last year, his attorney, Jack
+Goldberger, and then-Assistant State Attorney Lanna
+Belohlavek approached Pucillo in a sidebar conference.
+Pucillo, who had left the bench nine years earlier, was
+filling in temporarily as a senior judge.
+According to a transcript, Goldberger told Pucillo that
+Epstein had entered a confidential agreement with the U.S!
+attorney's office in which federal prosecutors brokered not
+pursuing charges against him if he pleaded guilty in state
+court. Pucillo then said she wanted a sealed copy of the
+agreement filed in his case, and Goldberger concurred that
+he wanted it sealed. Belohlavek later signed off on it.
+The Florida Supreme Court has expressed "serious concern"
+and launched an all-out inquiry into sealing procedures
+across the state following media reports in 2006 of entire
+cases being sealed and disappearing from court records.
+"The public's constitutional right of access to court records
+must remain inviolate, and this court is fully committed to
+safeguarding this right," justices wrote in their final report.
+Epstein's office on Tuesday referred any questions to
+Goldberger, who declined to comment. Pucillo also has
+declined to comment.
+
+
+Epstein secret pact with Feds
+reveals "highly unusual" terms
+Posted Jun 10, 2009 at 12:01 AM
+Updated Oct 4, 2019 at 9:23 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on September 19, 2009)
+A secret non-prosecution agreement multimillionaire
+financier Jeffrey Epstein struck with federal prosecutors is
+being called "highly unusual" by former federal prosecutors
+and downright outrageous by attorneys now representing
+young women who serviced him.
+The deal reveals that the FBI and the U.S. Attorney's Office
+investigated him for several federal crimes, including
+engaging minors in commercial sex. The crimes are
+punishable by anywhere from 10 years to life in prison.
+But federal prosecutors backed down and agreed to recall
+grand jury subpoenas if Epstein pleaded guilty to
+prostitution-related felonies in state court, which he
+ultimately did. He received an 18-month jail sentence, of
+which he served 13 months.
+The U.S. Attorney's Office also agreed not to charge any of
+Epstein's possible co-conspirators:
+, Lesley Groff and
+The deal was negotiated in part by heavyweight New York
+criminal defense attorney Gerald Lefcourt.
+Unsealed on Friday after attorneys for some of Epstein's
+victims and The Palm Beach Post sought its release, it offers
+the first public look at the deal Epstein's high-powered legal
+counsel brokered on his behalf.
+
+
+Mark|
+of Stuart, a former federal prosecutor,
+described the disparity in potential sentences as unusual,
+but even more so a provision on attorney payment.
+The first draft of the agreement in September 2007
+required that Epstein pay an attorney -- tapped by the U.S.
+Attorney's Office and approved by Epstein -- to represent
+some of the victims. That attorney is prominent Miami
+lawyer Bob Josefsberg.
+But an addendum to the agreement signed the following
+month struck Epstein's duty to pay Josefsberg if he and the
+victims did not accept settlements -- capped at $150,000 --
+and instead pursued lawsuits.
+said it appears the government was trying to
+balance the lesser sentence for Epstein with recovering
+$150,000 for each victim. "I've never, ever seen anything
+like that in my life," he said. "It's highly unusual."
+The deal does not say whether any victims were contacted
+or consulted before the deal was made.
+Attorney Brad Edwards of Fort Lauderdale, who represents
+three of the young women, believes that none of the 30 to
+40 woman identified as victims in the federal investigation
+were told ahead of time.
+said his clients received
+letters from the U.S. Attorney's Office months after the deal
+was signed, assuring them Epstein would be prosecuted.
+"Never consulting the victims is probably the most
+outrageous aspect of it," l
+said. "It taught them that
+someone with money can buy his way out of anything. It's
+outrageous and embarrassing for United States Attorney's
+Office and the State Attorney's Offfice."
+Epstein now faces many civil lawsuits filed by the women,
+who are represented by a variety of attorneys. In many, the
+allegations are the same: that Epstein had a predilection for
+teenage girls, identified poor, vulnerable ones and used
+
+
+other young women to lure them to his Palm Beach
+mansion. They walked away with between $200 and
+$1,000.
+Former Circuit Judge Bill Berger, also representing victims,
+called the agreement a "sweetheart deal."
+"Why was it so important for the government to make this
+deal?" Berger asked rhetorically. "We have not yet had an
+honest explanation by any public official as to why it was
+made .. and why the victims were sold down the river."
+Former federal prosecutor Ryon McCabe described the
+agreement as "very unorthodox." Such agreements, he said,
+are usually reserved for corporations, not individuals.
+"It's very, very rare. I've never seen or heard of the
+procedure that was set up here," said McCabe, who has no
+involvement in any Epstein litigation.
+"He's essentially avoiding federal prosecution because he
+can afford to pay that many lawyers to help those victims
+review their cases. /. If a person has no money, he couldn't
+be able to strike a deal like this and avoid federal
+prosecution.
+The backroom deal with federal prosecutors is all the more
+interesting in light of the legal powerhouses who have
+worked for Epstein, including Harvard professor Alan
+Dershowitz and Bill Clinton investigator Kenneth Starr.
+Lefcourt is a past president of the National Association of
+Criminal Defense Lawyers.
+Epstein's local defense attorney, Jack Goldberger, issued a
+statement Friday saying he had fought the release of the
+sealed agreement to protect the third parties named there.
+"Mr. Epstein has fully abided by all of its terms and
+conditions. He is looking forward to putting this difficult
+period in his life behind him. He is continuing his longstanding history of science philanthropy."
+
+
+The investigation triggered tensions between police and
+prosecutors, with then-Palm Beach Chief Michael Reiter
+saying in a May 2006 letter to then-State Attorney Barry
+Krischer that the chief prosecutor should disqualify himself.
+"I continue to find your office's treatment of these cases
+highly unusual," Reiter wrote. He then asked for and got
+the federal investigation that ended in the sealed deal.
+"The Jeffrey Epstein matter was an experience of what a
+many-million-dollar defense can accomplish," Reiter told
+the Palm Beach Daily News upon his retirement.
+
+
+187 / 278 - Wednesday, January 27, 2010
+Section: LOCAL & BUSINESS
+Page: 3B
+Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
+Dateline: WEST PALM BEACH
+JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
+In a decision that could spark a constitutional showdown over privacy rights, a judge
+uesday gave lawyers representing multimillionaire sex offender Jeffrey Epstein the rieht i
+ubpoena abortion records from women who are seeking millions in damages from the par
+Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
+the women's claims that they suffered psychological ills after being paid to give him
+sexually-charged massages at his Palm Beach mansion when they were as young as 14.
+Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
+he said, can't be sought until the women are asked whether they have ever had an abortion,
+how many and where. Further, he said, the records would not be made public and might not
+be admissible during trial.
+But, he said, since the women claim Epstein, now 57, is responsible for their emotional
+distress, his attorneys can explore the impact of other events. Medical records, Hafele said,
+are a better source of information than a person's memory.
+Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm
+Beach clinic where abortions are performed, warned Hafele that he was stepping on shaky
+constitutional grounds.
+"These records are protected by our constitutional right of privacy," he said, referring to the
+Florida Constitution.
+After the hearing, Silver said an appeal won't be necessary until Epstein attorneys seek the
+records.
+In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
+can't be released without a court order. The ruling came after Epstein attorney Robert Critton
+complained that a video of Epstein being asked whether he had an "egg-shaped" penis
+became a youtube.com sensation. It first appeared on The Palm Beach Post Web site.
+Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record.
+The civil suits began mounting after Epstein agreed to plead guilty to two state charges:
+procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18-
+month sentence. As part of the deal brokered with federal prosecutors, he agreed not to
+contest the accusations in the civil lawsuits. He can argue the women don't deserve the
+millions they are seeking.
+~jane_musgrave@pbpost.com
+
+
+Epstein Journal's Findings Could
+Resurrect Case
+By Jane Musgrave
+Posted Sep 17, 2019 at 12:01 AM
+Updated Oct 1, 2019 at 10:51 AM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on March 20, 2010)
+A purloined journal that is said to contain the names of
+"hundreds" of victims of convicted sex offender Jeffrey)
+Epstein could be used to reopen the investigation into the
+multi-millionaire's appetite for teenage girls, an attorney
+representing seven of the victims said Friday.
+New details about the contents of the journal were released
+this week when Alfredo Rodriguez, who worked as a
+property manager for the Palm Beach resident, pleaded
+guilty to obstruction of justice for lying to federal agents
+when asked if he had any information about his former
+boss' criminal activity. He later tried to sell the journal he
+stole from Epstein for $50,000 to an unidentified person,
+who alerted authorities, according to court records.
+As part of the plea agreement, federal prosecutors said the
+journal "contains information material to the Epstein
+investigation, including the names of material witnesses
+and additional victims."
+"Had the items been produced in response to the inquiries
+of state or federal authorities ... the materials would have
+been presented to the federal grand jury," federal
+prosecutors wrote.
+
+
+Instead, prosecutors short-circuited the grand jury
+investigation and cut a deal with Epstein. They agreed not
+to pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded
+guilty in July 2008 to procuring a minor for prostitution
+and soliciting prostitution. He served 13 months of an 18-
+month sentence.
+Attorney Adam Horowitz, who represents seven of the
+roughly 18 women who have filed civil suits against
+Epstein, said the new information could trump the socalled non-prosecution agreement.
+The multifaceted agreement, he said, deals only with a
+specific list of victims that the U.S. Attorney's Office knew
+about when it penned the deal in 2007. If additional victims
+are listed in the journal Rodriguez stole, Horowitz said
+federal prosecutors could reopen the investigation.
+"It opens the door for further prosecution," he said.
+In addition to turning over the journal to federal agents,
+Rodriguez told them he knew his former boss was having
+sex with underage girls when he worked for him in 2004
+and 2005. He had seen naked girls, who looked like minors,
+in the pool of Epstein's $8.6 million mansion. He had seen
+pornographic images of young girls on Epstein's computer,
+according to court records.
+Neither Epstein's criminal defense attorney, Jack
+Goldberger, nor attorney Robert Critton, who represents
+Epstein in the civil lawsuits, could be reached. Federal
+prosecutors have consistently declined comment.
+The wording of the controversial agreement is unclear. It
+says federal prosecutors would provide Epstein's attorneys
+"with a list of individuals whom it has identified as victims."
+Miami attorney Robert Josefsberg was appointed to
+
+
+represent any of the victims on the list who wanted to
+pursue Epstein in civil court. As part of the agreement,
+Epstein is to pay for Josefsberg to represent the women.
+Some of the women, most identified as Jane Doe in
+lawsuits, had already hired attorneys to represent them.
+Some have since settled their suits with Epstein, although
+terms were not disclosed.
+Horowitz said he has filed court papers to get the journal
+that Rodriguez stole. "It's another piece of evidence that
+shows our clients were at Epstein's mansion," he said.
+Rodriguez told prosecutors he didn't turn over the journal
+when both FBI and Palm Beach police asked for it because
+he wanted money for it. He also said he was afraid Epstein
+would make him "disappear." The information, he told
+investigators, was his "insurance policy."
+He faces a maximum 20 years in prison when he is
+sentenced on June 18.
+jane_musgrave@pbpost.com
+
+
+Epstein paid three women $5.5 million to end underagesex lawsuits
+By Jane Musgrave
+Posted Oct 3, 2017 at 12:01 AM
+Updated Oct 4, 2017 at 12:46 AM
+Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young
+women who claimed he used them as sex toys, court documents filed last week show he shelled
+out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.
+Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the
+sex scandal, attorney
+said the politically-connected 64-year-old convicted sex
+offender paid more than $1 million to each of the three women
+represented.
+Identified in court papers only by their initials or pseudonyms because of the nature of the
+allegations and their youthful ages, L.M, was paid $1 million, E. W. $2 million and Jane Doe
+$2.5 million,
+said of the settlements he negotiated with Epstein to end the lawsuits.
+Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on
+the revelations, citing confidentiality agreements that were part of the settlements. For the
+same reason, he declined to say whether Epstein paid similar amounts to settle roughly two
+dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
+when some were as young as 14 years old.
+Attorney Jack Scarola, who is representing
+I, said his client was compelled to divulge
+the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move
+on their part," he said.
+Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have
+likely come out. He says the information will help him undermine Epstein's claims that
+"ginned up" the allegations to help his former law partner, imprisoned and disbarred
+Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
+
+
+The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
+between Epstein and Rothstein, both billionaires.
+A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
+minor for prostitution, he sued Rothstein and
+claiming they trumped up the
+allegations of sexual molestation to perpetuate the Ponzi scheme.
+Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
+successful law firm by forging the names of federal judges and others to persuade investors he
+had negotiated settlements in lawsuits against high-profile people. Investors were told they
+could get a cut of the cash.
+One of the high-profile people Rothstein used to lure investors was Epstein, according to a
+lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the
+lawsuit, Rothstein told investors Epstein, a money manager, had ag
+to settle the lawsuits
+with the teens for $200 million — a claim Critton described as "a complete fabrication."
+After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him.
+accused
+Epstein of filing the lawsuit maliciously to punish him for representing the young women.
+Although
+was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
+no evidence
+was involved in the Ponzi scheme. Federal prosecutors successfully
+charged other attorneys and members of the firm, but
+was never implicated, Scarola
+said in the malicious prosecution lawsuit.
+The revelations about the money Epstein paid to three of the young woman came last week in
+documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
+Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
+trial, in part, because she claimed she has been unable to talk to her client since his estate on his
+private island in the U.S. Virgin Islands was devastated last month by Hurricane Irma. "I've had
+no ability to communicate with Mr. Epstein," she said.
+EFTA02734220R
+
+Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge
+Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those
+victimized by the storm that hammered the Caribbean and roared through South Florida, he
+said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
+Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
+before the case goes to trial.
+Despite Scarola's insistence that
+had nothing to do with Rothstein's Ponzi scheme,
+Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's
+well-known friends, such as now President Donald Trump, former President Bill Clinton and
+illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
+"The Epstein cases were used to fleece money and defraud investors," she said.
+Edward's malicious prosecution case has been difficult for both sides because both Epstein and
+have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
+his Fifth Amendment right against self-incrimination when questioned by Scarola. ]]
+has claimed that much of the information Epstein is seeking is protected by attorney-client
+privilege.
+The malicious prosecution lawsuit is one of two hotly-contested lawsuits that continue to pit
+Jagainst Epstein.
+also is suing the U.S. attorney's office, claiming it violated
+the federal Crime Victims Rights Act when it negotiated a non-prosecution agreement with
+Epstein.
+Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
+plead guilty to two prostitution charges in Palm Beach County Circuit Court. In federal court
+records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's
+agreement to settle lawsuits filed against him by dozens of his underage victims.
+
+
+Judge rules feds' agreement with
+Jeffrey Epstein pact violated teen
+victims' rights
+By Jane Musgrave
+Posted Sep 17, 2019 at 4:02 PM
+Updated Oct 8, 2019 at 12:31 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on February 22, 2019)
+Os
+Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims by failing to reveal they had dropped plans
+to prosecute the billionaire on dozens of federal charges in
+connection with the girls' claims that he paid them for sex
+at his Palm Beach mansion, U,S. District Judge Kenneth
+Marra ruled on Thursday.
+In a blistering 33-page ruling, Marra meticulously and
+methodically detailed the numerous steps federal
+prosecutors took to hide the agreement from more than 40
+young women who claim Epstein paid them for sex when
+they were as young as 14.
+"While the government spent untold hours negotiating the
+terms and implications of the NPA with Epstein's attorneys,
+scant information was shared with the victims," Marra
+wrote. Instead, the victims were told to be 'patient' while
+the investigation proceeded."
+By then, it was too late. A deal had already been cut with
+then-South Florida U.S. Attorney Alex Acosta and Epstein's
+attorneys to shelve a 52-page federal indictment against
+Epstein, a former math teacher turned money manager
+who counts Presidents Donald Trump and Bill Clinton
+among his friends.
+
+
+Prosecutors' failure to alert the young women about the
+deal violated the Crime Victims' Rights Act, Marra ruled.
+"At a bare minimum the (act) required the government to
+inform (the young women) that it intended to enter into an
+agreement not to prosecute Epstein," he wrote.
+Still, Marra said he wasn't second-guessing prosecutors'
+decision not to pursue Epstein on federal charges if he
+pleaded guilty to minor state prostitution charges and
+agreed to compensate his victims for the trauma he caused.
+"The court is not ruling that the decision not to prosecute
+was improper," Marra wrote. "The court is simply ruling
+that, under the facts of this case, there was a violation under
+the CVRA."
+Further, he made no decision about what the remedy
+should be. He gave prosecutors and attorneys representing
+the young women 15 days to meet to decide how to unravel
+the complex legal web that has been hanging over Epstein
+and his young victims for more than a decade.
+The chances an accord will be reached are slim, said
+attorney Jack Scarola, who is representing the two Jane
+Does who challenged the prosecutors actions.
+Further, he said, there is no road map to follow. The
+lawsuit attorney
+filed on behalf of the two
+unidentified young women, claiming prosecutors violated
+the federal act, is unique, he said.
+"We are treading on virgin ground, to use what is probably
+an inappropriate phrase in this situation," he said.
+Scarola said he and
+will ask that the nonprosecution agreement be thrown out. That would open
+the possibility that the long-shelved federal indictment
+could be dusted off and filed against the 66-year-old
+Epstein, who spends most of his time on a private island he
+owns in the U.S. Virgin Islands.
+
+
+"I don't see the government conceding to that remedy,"
+Scarola admitted. Further, he said, it is likely Epstein will be
+allowed to weigh in. Miami attorney Roy Black years ago
+filed papers asking to intervene on Epstein's behalf.
+The U.S. Attorney's Office said it wouldn't comment on
+Marra's ruling. Neither Black nor New York City attorney
+Jay Lefkowitz, who led efforts to bury the federal
+indictment, responded to emails or phone calls for
+comment. West Palm Beach attorney Jack Goldberger, who
+represents Epstein, also didn't respond.
+Scarola said it is likely Epstein's star-studded legal team will
+argue that Epstein fully complied with the terms of the
+agreement he made in 2007 with federal prosecutors and
+therefore the agreement can't be undone.
+As he promised, Epstein pleaded guilty in June 2008 to state
+charges of soliciting a minor for prostitution and soliciting
+prostitution. He served 13 months of an 18-month jail term
+in a vacant wing of the county stockade that he was allowed
+to leave 12 hours a day, six days week.
+Further, as agreed, he paid settlements to the young women
+who sued him. While the settlements were confidential,
+court records show he paid three women a total of $5.5
+million.
+In return, federal prosecutors held up their end of the
+bargain. Their investigation ceased.
+Having done all that prosecutors asked of him, Scarola said
+Epstein will make a simple argument: "You can't turn
+around and deprive me of the benefits I bargained for."
+However, Scarola said, using Marra's ruling, he will counter
+that the contract Epstein signed was illegal and therefore
+unenforceable.
+
+
+Even if Marra agrees to toss out the non-prosecution
+agreement, Scarola conceded that doesn't mean Epstein will
+face federal charges.
+"The contract can be set aside and the federal government
+can attempt to enter into the same agreement," he said.
+"Except the spotlight of public attention will be on them
+and the 40 victims will be able to explain to the court why
+this sweetheart deal should not be approved."
+Scarola said that prosecutors may have had good reason not
+to pursue Epstein. "There may be a reasonable explanation
+but we don't know what that reason may have been," he
+said.
+In court papers, federal prosecutors have said that many of
+the young women were afraid to cross the powerful,
+politically connected money manager and simply refused to
+testify against him.
+In other cases, they said, the women changed their stories.
+Jane Doe 2, who is trying to have the non-prosecution
+agreement thrown out, initially described Epstein as "an
+awesome
+told prosecutors she hoped "nothing
+happens" to him. While she later agreed to testify against
+Epstein, prosecutors said they feared Epstein's attorneys
+wotld use her words to destroy her if she ever took the
+witness stand.
+Marra, however, said the young woman's comments didn't
+mean she wasn't entitled to know about the prosecutors'
+plans to drop the charges. "There is no dispute that Epstein
+sexually abused Jane Doe 2 while she was a minor," he
+wrote. "Therefore, regardless of her comments to the
+prosecutor, she was a victim."
+Before the case is finally resolved, Scarola predicted that "a
+lot of people are going to have to answer a lot of questions."
+
+
+In his ruling, Marra detailed what appeared to be a cozy
+relationship between Acosta, his line prosecutors and
+Epstein's team of lawyers. His phalanx of lawyers included
+noted Harvard law professor Alan Dershowitz and Kenneth
+Starr, the former U.S. solicitor general whose investigation
+led to the impeachment of President Clinton.
+Marra describes an October 2007 breakfast meeting
+between Acosta, who is now U.S. labor secretary, and
+Lefkowitz shortly after the non-prosecution agreement was
+inked.
+After the meeting, Lefkowitz sent Acosta a note thanking
+him for "the commitment you made to me during our
+October 12 meeting in which you assured me that your
+Office would not ... contact any of the identified
+individuals, potential witnesses, or potential civil claimants
+and their respective counsel in this matter,"
+Marra quoted an equally pleasant note then-Palm Beach
+County State Attorney Barry Krischer sent to Assistant U.S.
+Attorney
+Villafana, who was the lead prosecutor in
+Epstein's case. "Glad we could get this worked out for
+reasons I won't put in writing," Krischer wrote, shortly
+after the non-prosecution agreement was signed. "After this
+is resolved 1 would love to buy you a cup at Starbucks and
+have a conversation."
+Many of the notes that were exchanged dealt with
+prosecutors' and Epstein's lawyers' shared desire to keep the
+deal secret from Epstein's accusers. In a September email,
+Villafana asked Lefkowitz for guidance about what she
+should reveal. "And can we have a conference call to discuss
+what I may disclose to ... the girls regarding the
+Agreement," she asked.
+
+
+Such cooperation between prosecutors and defense
+attorneys is unusual, Marra said. "It was a deviation from
+the government's standard practice to negotiate with
+defense counsel about the extent of crime victim
+notifications," he wrote.
+Further, he noted, that when
+and his two young
+clients asked for information, they were repeatedly misled.
+"The CRVA was designed to protect victims' right and
+ensure their involvement in the criminal justice process,"
+Marra wrote. "When the government gives information to
+victims it cannot be misleading."
+Ultimately, the terms of the non-prosecution agreement
+were revealed only after
+and attorneys for the
+press successfully sued to
+make
+them
+1 publie.
+
+
+76 / 278 - Tuesday, July 9, 2019
+Edition: Final
+Section: A Section
+Page: 1A
+Source: By Jane Musgrave, The Palm Beach Post
+Epstein indicted on sex charges
+Part-time Palm Beacher pleads not guilty to sex
+trafficking, conspiracy charges in federal court in
+Manhattan
+Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not guilty
+to charges accusing him of creating a vast network of girls as young as 14 that he exploited
+for his sexual pleasure at his homes in Palm Beach and Manhattan.
+The 66-year-old money manager's appearance in U.S. District Court in New York City
+capped more than a decade of recriminations by young women and their attorneys who
+claimed Epstein used his money and political influence to avoid federal prosecution.
+Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
+charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
+County Jail for 13 months more than a decade ago.
+However, unlike in 2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
+shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
+prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
+now U.S. labor secretary.
+"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
+Berman said at a
+morning news conference. "And while the charged conduct is from a number of years ago, it
+is still profoundly important to many of the alleged victims, now young women. They
+deserve their day in court."
+At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
+keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
+commit sex trafficking. Epstein paid dozens of young women to give him nude massages
+that, for most, led to sex, he said.
+If convicted of exploiting dozens of young women, including many Palm Beach County girls
+who were students at
+Palm Beach High School, Epstein faces a maximum 45-year
+prison sentence.
+Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin
+Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few
+conditions that could keep Epstein from fleeing to a foreign country to evade prosecution.
+
+
+"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince
+Andrew, actor Kevin Spacey, famed Harvard law professor Alan Dershowitz and former
+President Bill Clinton on his jet, dubbed the Lolita Express.
+Berman's hard-line stance was welcomed by young women who for years have been told that
+Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement,
+promising not to charge Epstein in federal court.
+Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning
+her into his sex slave and forcing her to have sex with others, including Dershowitz and
+Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she
+told the Associated Press. Dershowitz has vehemently denied Guiffre's claims. /
+New York prosecutors were able to ignore the controversial nonprosecution agreement
+because it contained some significant fine print, said former federal Judge Paul Cassell, who
+for years has fought to get the agreement thrown out. It says only that no charges could be
+filed against Epstein in South Florida, he said.
+Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
+Florida," he said. "The Southern District of New York is not bound by that agreement and
+wasn't a signatory of it."
+That means the sordid allegations that have been leveled at Epstein for years are now part of
+a federal indictment.
+Contrary to Epstein's claims, he knew the women who came to his homes in New York and
+Palm Beach were minors because they told him their ages, according to the indictment.
+Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
+prosecutors added.
+As part of a carefully orchestrated sex ring, Epstein or his associates would call girls while
+he was in New York so they would be available for sex once he returned to Palm Beach, the
+indictment says. The employees weren't named. They were identified only as "Employee-1,"
+"Employee-2" and "Employee-3."
+To ensure he had a steady stream of young girls, Epstein would turn some victims into
+recruiters. He would pay them to bring new girls to his home on El Brillo Way along the
+Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East
+Side.
+"This allowed Epstein to create an ever-expanding web of new victims," Berman said.
+In both New York and Palm Beach, the lurid operation was similar. Unidentified employees
+of Epstein's would escort the teens into a room. They were told to take off all or most of their
+clothes before giving the naked billionaire massages, according to the indictment.
+"Epstein would also typically masturbate during these encounters, ask victims to touch him
+while he masturbated, and touch victims' genitals with his hands or with sex toys," the
+indictment says.
+As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over
+his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture
+of Epstein's house in Palm Beach.
+While heartened that Epstein now faces serious criminal charges in New York, Cassell said
+he would continue to push a West Palm Beach-based federal judge to throw out the
+nonprosecution agreement that Acosta forged with Epstein's star-studded legal team.
+
+
+U.S. District Judge Kenenth Marra has already ruled that Acosta violated the federal Crime
+Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
+Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
+Monday, explaining what action Marra should take to redress that wrong.
+Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
+victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's
+victims with attorneys
+and Jack Scarola.
+Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
+he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
+how and why the agreement was reached.
+"There's been no explanation as to how a deal like this could have been cut and how the
+federal government could have been involved in a conspiracy to violate federal law," Scarola
+said of his interest in continuing the legal battle over the nonprosecution agreement.
+When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
+prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
+Palm Beach County Jail - a cell he was allowed to leave 12 hours a day, six days a week. He
+was also forced to register as a sex offender and settle civil lawsuits more than 30 young
+women filed against him.
+U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out
+how the agreement came to be."I am especially more interested in why Epstein got the deal
+he got," Frankel said. "We need to know why he was given such an easy sentence.
+While she has asked the House Oversight Committee to investigate Acosta, Frankel said she
+is not sure that will happen. "It just seems to me it was a travesty that this guy got off the
+way he did and, without pre-judging it, let's have a proper court case," Frankel said.
+Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State
+Attorney Barry Krischer refused to charge Epstein with serious crimes. Reiter took the
+information his officers had gathered from dozens of Epstein's victims to Acosta, believing
+he would prosecute Epstein. He didn't.
+Reiter said he was heartened that 13 years later, Epstein will finally face justice.
+"Thankfully, U.S. Attorney Berman and the other authorities in New York have the good
+judgment to investigate and prosecute Epstein in the way that should have occurred in
+Florida over a decade ago," Reiter said in a statement.
+And, Scarola said, there are signals that Berman's investigation is far from over.
+Berman declined to answer questions about whether others, such as Epstein's high-powered
+friends, would be charged. He brushed off questions about the significance that the
+investigation was being handled by the Public Corruption Unit.
+While agents on Saturday were arresting Epstein aboard his private jet at the Teterboro
+Airport in New Jersey after returning from Paris, other offcers were searching his New York
+City townhouse. Agents seized nude photos of young girls who appeared to be minors,
+Berman said.
+He said his focus was on finding more women who were exploited and abused by Epstein.
+Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a
+finger at a photo of the convicted sex offender who was once described as "a man of
+mystery."
+
+
+"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,"
+Berman said. A special number, 1-800-CALLFBI, will link victims of authorities.
+Bill Sweeney, assistant director of the FBI's New York office, said after years of being
+ignored by federal agents, the victims' voices will be heard.
+"The Jeffrey Epstein matter is No. I on the major case list in the country," Sweeney said.
+Turning to address Epstein's victims directly, he said: "Your bravery may empower others to
+speak out against crimes against them."
+NOT A CERTIFIED COPI
+
+
+Def.Ex.A-5
+
+
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R. BOCK
+as Clerk & Comptroller, Palm Beach County,
+Florida,
+Defendants.
+CASE NO: 2019-CA-014681
+COPY
+DEFENDANT, DAVE ARONBERG, AS STATE ATTORNEY OF PALM BEACH COUNTY,
+FLORIDA'S ANSWER TO FIRST AMENDED COMPLAINT
+AND MOTION TO DISMISS COUNT I|
+Defendant, DAVE ARONBERG, as State Afforncy of Palm Beach County, Florida, ("SAO"),
+by and through the undersigned attorney, heroby answers Count I of the First Amended Complaint of
+Plaintiff, CA Florida Holdings, LLC, Publisher of The Palm Bcach Post ("Post"), and files a Motion
+to Dismiss Count II, as follows:
+1.
+Admitted for jurisdictional purposes.
+JURISDICTION
+PARTIES
+2.
+Admitted.
+Denied that Defendant Aronberg or the Office of the State Attorney for the Fiftcenth
+Judicial Circuit is in possession and/or control of documents that are the subjoct of this action.
+Otherwise admitted
+4.
+Admitted.
+INTRODUCTION
+Paragraph 5 contains the Post's statement of the case and Iegal arguments to which no
+
+
+response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belicf as to the truth of any factual allegations contained in paragraph
+5, and therefore denics the allegations and demands strict proof thereof.
+6.
+Paragraph 6 contains the Post's statement of the case and legal arguments to which no
+response is required. To the extent that a response is required, the SAO admits only that section
+905.27(1)(c), Florida Statute authorizes the disclosure of grand jury proceedings under certain
+circumstances.
+Paragraph 7 contains the Palm Beach Post's statement of the case and legal arguments
+to which no response is required. To the extent that a response is requirod, the SAO is without
+knowledge or information sufficient to form a belief as to the truth of any factual allegations contained
+in paragraph 7, and therefore denics the allegations and demands strict proof thercof
+8.
+Paragraph 8 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in paragraph
+8, and therefore denies the allegations and demands strict proof thereof.
+Paragraph 8 scts forth the Post's statement of the case and Iegal arguments to which
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in paragraph
+9, and therofore denics the allegations and demands strict proof thercof
+FACTUAL BACKGROUND
+10.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 10, and therefore denics the allegations and demands
+A.
+First Epstein Sex Crimes Investigation, Indietment, and Plea Agreement: 2005-2008.
+11.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+2
+
+
+of any factual allegations contained in paragraph 11, and therefore denics the allegations and demands
+12.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 12, and therefore denics the allegations and demands
+13.
+The SAO is without knowledge or information sufficient to form a belicf as to the truth
+of any factual allegations contained in paragraph 13, and therefore denics the allegations and demands
+strict proof thercof
+14.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 14, and therefore denies the allegations and demands
+15.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 15, and therefore denies the allegations and demands
+strict proof thercof
+(1)
+Police Chief Reiter's Letter to the State Attorney
+16. The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 16, and therefore denics the allegations and demands
+17K
+The SAO is without knowledge or information sufficient to forn a belief as to the truth
+of any factual allegations contained in paragraph 17, and therefore denics the allegations and demands
+(2)
+The July 2006 State Grand Jury Presentation
+18.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 18, and therefore denics the allegations and demands
+3
+
+
+19.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 19, and therefore denics the allegations and demands
+20.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 20, and therefore denics the allegations and demands
+21.
+The SAO is without knowledge or information sufficient to form a belicf as to the truth
+of any factual allegations contained in paragraph 21, and therefore denics the allegations and demands
+22.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 22, and thercfore denics the allegations and demands
+(3)
+The FBI's Investigation and Epstein's Non-Prosecution Agreement with Federal
+Authorities.
+23.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 23, and therefore denics the allegations and demands
+24.
+The SAO is without knowledge or information sufficient to form a belicf as to the truth
+of any factual allegations contained in paragraph 24, and therefore denies the allegations and demands
+25. Y The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 25, and therefore denies the allegations and demands
+26.
+The SAO is without knowledge or information sufficient to for a belief as to the truth
+of any factual allegations contained in paragraph 26, and therefore denics the allegations and demands
+4
+
+
+27.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 27, and therefore denies the allegations and demands
+28.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 28, and therefore denics the allegations and demands
+29.
+The SAO is without knowledge or information sufficient to forn a belief as to the truth
+of any factual allegations contained in paragraph 29, and therefore denics the allegations and demands
+30.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 30, and therefore denies the allegations and demands
+31.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 31, and therefore denies the allegations and demands
+(4)
+32.
+The Crime Victims' Rights Act Litigation.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 32, and therefore denics the allegations and demands
+33.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 33, and therefore denies the allegations and demands
+34.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 34, and therefore denics the allegations and demands
+5
+
+
+35.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 35, and therefore denies the allegations and demands
+36.
+The SAO is without knowledge or information sufficient to form a belicf as to the truth
+of any factual allegations contained in paragraph 36, and therefore denies the allegations and demands
+37.
+The SAO is without knowledge or information sufficient to forn a belief as to the truth
+of any factual allegations contained in paragraph 37, and therefore denics the allegations and demands
+strict proof thercof
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019
+38.
+Admitted.
+39.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 39, and therefore denies the allegations and demands
+strict proof thercof
+40.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 40, and therefore denics the allegations and demands
+41,4
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 41, and therefore denies the allegations and demands
+strict proof thereof.
+42.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 42, and therefore denics the allegations and demands
+43.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+6
+
+
+of any factual allegations contained in paragraph 43, and therefore denies the allegations and demands
+C.
+44.
+Admitted.
+The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+45.
+The SAO is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 44, and therefore denies the allegations and
+demands strict proof thercof.
+46.
+Admitted that United States Senior Judge Richard M. Berman ordered a hearing on
+August 27, 2019, but the SAO is without knowledge or information sufficient to form a belief as to the
+truth of any remaining factual allegations contained in paragraph 43, and therefore denics the
+allegations and demands strict proof thercof
+47.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 47, and therefore denies the allegations and demands
+strict proof thercof
+48.
+The SAO is without knowlodge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 48, and therefore denics the allegations and demands
+49.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 49, and therefore denies the allegations and demands
+50.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations paragraph 50, and therefore denies the allegations and demands strict proof
+thercof.
+51.
+The SAO is without knowledge or information sufficient to form a belief as to the truth
+of any factual allegations contained in paragraph 51, and therefore denics the allegations and demands
+7
+
+
+D.
+The Palm Beach Post's Standing and the Public Interest.
+(1)
+The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly
+15 Years.
+52.
+Admitted.
+53. Admitted.
+54.
+Admitted that the Post has extensively investigated and reported on the allegations
+against, the law enforcement investigation of, and the crimes committed by Epstein, but lacks sufficient
+knowledge to admit or deny any factual allegations remaining in paragraph 54, and therefore denics
+the allegations and demands strict proof thereof.
+55.
+The SAO is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 55, and therefore denies the allegations and
+demands strict proof thercof
+(2)
+The Palm Beach Post's Standing and the Public Interest.
+56.
+Paragraph 56 of tho First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the SAO admits the press has a constitutional right of access to criminal
+proceedings, but is without knowledge or information sufficient to formn a belief as to the truth of any
+remaining factual allegations contained in paragraph 56, and therefore denics the allegations and
+demands strict proof thercof
+Paragraph 57 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belicf as to the truth of any factual allegations contained in paragraph
+57, and therefore denics the allegations and demands strict proof thercof.
+58.
+Paragraph 58 sets forth the Post's statement of the case and legal arguments to which
+8
+
+
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belicf as to the truth of any factual allegations contained in paragraph
+57, and therefore denics the allegations and demands strict proof thereof.
+59.
+Paragraph 59 of the First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the SAO admits that Fla. Stat. 905.27 allows a court to make the determination
+of disclosure but is without knowledge or information sufficient to form a belief as to the truth of any
+remaining factual allegations contained in paragraph 59, and therefore denics the allegations and
+demands strict proof thercof
+E.
+The Court's Jurisdiction and Authority
+(1)
+The Court's Supervision of the Grand Aury Process and Its Authority to Order
+Public Disclosure of the Epstein Evidence.
+60.
+Paragraph 60 of the First
+ded Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the SAO admits the press has a constitutional right of access to criminal
+proceedings, but is without knowledge or information sufficient to for a belief as to the truth of any
+remaining factual allegations contained in paragraph 60, and therefore denies the allegations and
+demands strict proof thercof.
+61.
+Admitted.
+62.
+Admitted.
+63.
+Paragraph 63 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belicf as to the truth of any factual allegations contained in paragraph
+63, and therefore denics the allegations and demands strict proof thercof.
+64.
+Paragraph 64 of the First Amended Complaint contains the Palm Beach Post's
+9
+
+
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the SAO is without knowledge or information sufficient to form a belief as to the
+truth of any remaining factual allegations contained in paragraph 64, and therefore denies the
+allegations and demands strict proof thercof.
+(2)
+The Court's Jurisdiction To Declare Rights And Construe Statutes.
+65.
+Admitted.
+66.
+Admitted.
+67.
+Admitted.
+COPY
+COUNT!
+(Declaratory Relief - Florida Stat. Sections 86.011 et seq.)
+The SAO reincorporates and re-alleges its prior answers to paragraphs 1 through
+68.
+67 above.
+69. Admitted.
+70. Paragraph 70 contains the Post's statement of the case and Iegal arguments to which
+no response is required. To the extent that a response is required, the SAO is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in paragraph
+70, and therefore denics the allegations and demands strict proof thercof
+71.
+Admitted that The Palm Beach Post is secking a declaration from this Court but
+denies the remainder of Paragraph 71.
+72.
+Admitted
+73. Y Denied.
+74.
+Paragraph 74 contains the Post's Iegal arguments to which no response is required.
+To the extent that a response is required, the SAO is without knowledge or information sufficient to
+form a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denics
+the allegations and demands strict proof thereof.
+10
+
+
+MOTION TO DISMISS COUNT LI
+(Florida Stat. Section 905.27)
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, pursuant
+to the Florida Rules of Civil Procedure 1.420, hercby files this Motion to Dismiss Count II of Plaintiff's
+First Amended Complaint for failure to state a cause of action, and in support thercof states:
+L.
+Standard of Review
+When confronted with a motion to dismiss, the Court must determine whether the Complaint
+as phrased within its four corners sufficiently states a cause of action, whereby relief can be granted.
+Fox v. Professional Wrecker Opcrations, 801 So. 2d 175, 178 (Fla. 5th DCA 2001). A motion to
+dismiss tests whether the plaintiff has stated a cause of action. The test for a motion to dismiss under
+Florida Rule of Civil Procedure 1.140(b) is whether the pleader could prove any set of facts as alleged
+in the Complaint to support his or her claim. Scc, Connolly v. Scbcco, Inc., 89 So. 2d 482, 484 (Fla.
+1956); Wasua Ins. Co. v. Haynes. 683 So. 2d 1123 (Fla. 4th DCA 1996).
+In order to meet this test,
+"a complaint must allege sufficient ultimate facts to show that a
+pleader is entitled to relief." W.R. Townsend Contr., Inc. v. Jensen Civ. Constr., Inc., 728 So. 2d 297,
+300 (Fla. Ist DCA 1999) (quoting
+v. Cosgrove, 464 So. 2d 664, 665 (Fla. 2d DCA 1985); Fla.
+R. Civ. P. 1.110(b)). The court need not accept internally inconsistent factual claims, conclusory
+allegations, unwarranted deductions, or mere legal conclusions made by a party. Id. (citing Response
+Oncology. Inc. v. Mctrahcalth Insurance Co., 978 F. Supp. 1052, 1058 (S.D. Fla. 1997)); Oxford Assct
+Mgınt. y. Jaharis, 297 F.3d 1182, 1188 (11th Cir. 2002) ("[On a motion to dismiss,] the plaintiff's
+factual allegations are accepted as true.. However, legal conclusions masquerading as facts will not
+prevent dismissal."). To avoid dismissal, a pleading "must allege a cause of action recognized under
+law" against the defending party. Kislak v. Krecdian, 95 So. 2d 510, 514 (Fla. 1957).
+Il.
+Argument
+a.
+Neither Defendant Aronberg, nor the Office of the State Attorney for the
+Fifteenth Judicial Circuit is in possession and/or control of documents that
+11
+
+
+are the subject of this action.
+It is significant to emphasize that despite Plaintiff's allegations to the contrary, Defendant
+Aronberg and the Office of the State Attorney for the Fifteenth Judicial Circuit are not in custody or
+control of the records sought herein, and therefore Defendant Aronberg is not a proper party to this
+action. In fact, Defendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida,
+admits that it is the custodian in possession of the documents that are the subject of this action.
+b.
+Plaintiff Fails to State a Cause of Action
+Plaintiff attempts to assert a cause of action, in the interest of "furthering justice", under Florida
+Statute § 905.27; however, a review of the statute in question revcals that no cause of action is provided
+for therein and consequently Count II of Plaintiff's First Amended Complaint must be dismissed as a
+matter of law. Despite Plaintiff's extensive recitation of the factual background regarding Jeffery
+Epstein and the testimony and evidence presented to the 2006 grand jury in Palm Beach County,
+Florida, Fla. Stat. § 905.27, merely explains the exceptions to the disclosure of grand jury testimony
+and does not set forth in any way a cause of action upon which to initiate a valid law suit.
+Morcover, a review of the statute at issue clcarly indicates that even if § 905.27, Fla. Stat.
+provided a basis for a cause of action, Plaintiff is barred from access to the records it secks. To wit, in
+pertinent part, Fla. Stat. § 905.27(2) states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorncys and by the latter
+to their legal associates and employecs. However, the grand jury testimony afforded
+such persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Here, despite the clear statutory guidclines for disclosure of grand jury materials in a civil case,
+Plaintiff is improperly seeking the requested 2006 grand jury materials for the purposes of public
+disclosure pursuant to the court's inherent authority and supervisory powers over the grand jury. [Sec,
+Complaint 11 8, 63]. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat. 905.27,
+the statute unambiguously states that grand jury testimony "can only be used in the defense or
+12
+
+
+prosccution of the civil or criminal casc and for no other purpose whatsoever", which is distinctly
+different from Plaintiff's intended purpose for public disclosure of the grand jury evidenco. Fla. Stat.
+$ 905.27(2).
+WHEREFORE, based on the forgoing argument and supporting authority, Defendant, DAVE
+ARONBERG, as State Attorney of Palm Beach County, Florida, respectfully requests that this
+Honorable Court grant the instant Motion and dismiss Count Il of Plaintiff's First Amended Complaint
+with prejudice, and grant Defendant Aronberg all other and further relief deemed just and proper,
+including attorney's fees and costs for defending this frivolous action.
+I HEREBY CERTIFY that on this 24th day of January, 2020, a copy of the foregoing has been
+clectronically filed with the Florida E-File Portal for c-scrvice on all partics of record hercin.
+JACOBS SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I.
+, Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.net
+13
+
+
+Def.Ex.A-6
+
+
+COPY
+In the Matter Of:
+50-2019-CA-014681
+CQPY
+June 02, 2020
+NOT A CERTIF
+→ ESQUIRE
+- DEPOSITION SOLUTIONS
+800.211. DEPO (3376)
+
+
+
+
+June 03, 2020
+IN THE CIRCUIT COURT
+ASE NO.
+50-2019-CA-014681
+'IRCUIT CIVIL DIVISION: "AG
+OF THE PREME PUBLTSHER
+-vS-
+NOT
+BEFORE THE HONORABLE KRISTA MARX
+(ZOOM CONFERENCE)
+Wednesday,
+June 3,
+2020
+10:08 a.m. - 10:28 a.m.
+REMOTE ZOOM CONFERENCE
+Port Saint Lucie, Florida
+Stenographically Reported By:
+SONJA M.
+Court Reporter
+ESQUIRE
+
+
+June 03, 2020
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+APPEARANCES:
+On behalf of the Plaintiff/Petitioner:
+GREENBERG TRAURIG, P.A.
+1840 Century Park East
+Suite 1900
+Los Angeles,
+California 90067
+310.586.7700
+boyajian@gtlaw.com
+BY: NINA D. BOYAJIAN, ESQUIRE
+On behalf of the Defendant/Respondent:
+JACOB, SCHOLZ & WYLER, LLO
+61687 Gateway Boulevar‹
+Suite 2011
+COPY
+Fernandina Beach, Florida 32034
+904.261.3693
+doug.wyler@concast.net
+BY: DOUGLAS A. WYLER, ESQUIRE
+On behalf of the Defendant/Respondent:
+CLERK & COMPTROLLER,
+PALM BEACH COUNTY
+P.O. Box 229
+West Palm Beach, Florida 33401
+561.355.2983
+nfingerhut@mypalmbeachclerk.com
+BY: NICOLE R.
+FINGERHUT, ESQUIRE
+NOT
+→ ESQUIRE
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+June 03, 2020
+PROCEEDINGS
+*****
+THE COURT: We are here today for a very
+limited purpose. I'm sure the attorneys are aware of
+that, but I just don't want there to be any
+confusion. We are here on Defendant Dave Aronberg
+and Defendant Sharon Bock for the Comptroller and the
+State Attorney's motion to dismiss Count II.
+You're all acutely aware as the lawyers that
+this is a question of law. So we're not going to be
+diving into facts and the Court will not be deciding
+the merits of this motion this morning. We are
+simply here for the sole purpose of that motion to
+dismiss. So I just wanted to make sure that we all
+stay on track and we're all on that same page.
+So, Ms. Boyagian, I'll send it to you first,
+• I -- of course, we all know that the Law 101,
+I must look at the four corners of the motion, which
+alleges that the State Attorney, David Aronberg, and
+the clerk and comptroller, Sharon Bock, actually have
+custody and control of these grand jury proceeding.
+Whether that is true or not is not for this
+court to determine because I'm looking simply at the
+four corners of the complaint. But, not for nothing,
+I think we all know that they don't have control and
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+June 03, 2020
+custody of the records. But I'm going to assume that
+it's correct because that's what has been alleged.
+So what I first want to hear from is the
+attorney for Florida Holdings with regard to,
+assuming arguendo, that Florida Statute 905.27 does
+create a cause of action, what relief is it that
+you're seeking from -- in Count II, specifically.
+Not the dec action. We're not here on that today --
+what is it you hope to get, a judgment?
+MS. BOYAGIAN: Thank you, your Honor. Good
+morning, and thank you for the privilege of appearing
+before this court.
+The relief we are seeking is disclosure of the
+grand jury records, pursuant to the Furtherance of
+Justice Exception to 905.27. And under the First
+Amendment.
+The press, as your Honor is aware, has a right
+of access under the First Amendment as a surrogate of
+the public --
+THÉ COURT: Let me just stop you for a minute.
+I'dylike you to answer my specific question.
+So I am not particularly convinced -- and I'd
+like for you to address that. So we're not going to
+dive into facts or the press's standing because
+that's not something we're here to discuss today.
+2 ESQUIRE
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+800.211. DEPO (3376)
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+And I have read the voluminous paperwork --
+I've received paperwork as -- and -- five-minute ago
+from some of the other parties. But I deeply
+appreciate the fact that you sent this to me so much
+in advance and I have been able to spend some time
+with, as I said, the voluminous paperwork that was
+provided.
+But as you know,
+1, we are here for such an
+extremely limited issue today, and that their motion
+to dismiss where they state "you're suing the wrong
+people"; that the court has these records.
+And so, more importantly, I want you to address
+whether Section 905.27 gives you a private cause of
+action against the state attorney and the clerk.
+Again, I'm going to assume the facts are true
+that are asserted in the motion. Whether they are or
+not -- because I think we can all agree we're not for
+sure if they ever -- that the state attorney doesn't
+have these records. So what is it you're seeking in
+Count II -- not the dec action. I know you want the
+recórds. I've got that. But in Count II,
+specifically, what do you -- what's the relief you're
+seeking and, more importantly, how under this statute
+do you get to assert a private action -- a private
+cause of action against the state attorney and the
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+clerk?
+MS. BOYAGIAN: Your Honor, we are aware, of
+course, that there is no expressed private right of
+action, 905.27. But that does not end the inquiry.
+As the Florida Supreme Court stated:
+"Where a statute like 905.27
+forbids an act which is to Plaintiff's
+injury, the party injured should have
+an action."
+And that's the
+Piezo case in the volume
+of materials that we sent you,
+There's no question here that the denial of the
+FIRST AMENDMENT right to the press is an injury which
+gives rise to a right of action.
+Stated another way, looking at the analysis
+that the Fischer Metcalf Court looked at, there are
+three factors in determining whether there is a
+private fight) of action where a statute does not
+expressly provide for one.
+One is whether the Plaintiff is part of the
+class for which the statute is intended to protect;
+second is a legislative history; and the third is the
+underlying purposes of the statutory scheme.
+The first factor I already addressed, that the
+press is part of the class that the statute is
+2 ESQUIRE
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+June 03, 2020
+intended to benefit, being the surrogate of the
+public and exercising its first amendment right.
+The second issue of legislative history and the
+purpose -- statutory purpose are somewhat related.
+We were unable to find much legislative history on
+this issue of a private right of action under the
+statute.
+There is nothing that says we intend to create
+a private action, but there's certainly nothing that
+says we do not want to create a private right of
+action.
+What we do have is that in 1994, the same time
+that 905.27 was reenacted, a statute that pertains to
+the secrecy of State Grand Jury -- statewide grand
+juries was also enacted. That provision, which is
+905.395, has no exceptions for -- for revealing these
+records. By contrast, the legislature intentionally
+enacted 905.27 with the Furtherance of Justice
+Exception.
+If the public through the press can't bring a
+private right of action to enforce that exception or
+to seek relief under that exception, that
+intentionally placed exception of furthering justice
+is essentially rendered hollow --
+(Speaking simultaneously.)
+2 ESQUIRE
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+THE COURT: Okay. Pause for a minute.
+I don't think anybody is saying that there
+isn't a cause of action or that the press doesn't
+have standing. That's not what I'm asking you. I'm
+asking you, how are the clerk and the state attorney
+the proper defendants?
+So, you know, nowhere have I said there isn't a
+cause of action. Clearly there is.
+-'m puzzled by
+the procedural posturing of this case naming the
+state attorney.
+And, you know, I'm further stymied by the fact
+that you allege in your complaint that they have --
+particularly David Aronberg, the State Attorney --
+that he has these records.
+But I'm going to assume that's true. So I'm
+not telling you, you don't have a cause of action.
+I'm just saying, okay, let's run this all the way
+out. Let's say you win and you get a judgment
+against the State Attorney Dave Aronberg.
+What's he supposed to do with it? He can't
+release the grand jury testimony. He has no
+authority whatsoever to do that.
+MS. BOYAGIAN:
+Well, your Honor, as you stated,
+this is a motion to dismiss stage, and we are
+entitled to discovery on the issue of possession,
+→ ESQUIRE
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+custody, and control. My understanding is that the
+state attorney has asserted that he does not have
+possession. It's not my understanding that the clerk
+has taken that position.
+So the clerk may indeed be
+the -- someone who does have possession, custody, and
+control.
+In any event, we would submit that the state
+attorney, even it does not have actual possession at
+this time, it might be able to have the power to
+control or direct the entity or persons who do have
+control and possession to release those -- to effect
+the judgment.
+THE COURT: So let
+me ask you this: so the
+clerk is the keeper of the record. But even if you
+got a judgment against her -- let's say you asserted
+this cause of action and let's say you win and you
+get a judgment against the clerk. The clerk cannot
+release grand jury testimony to you. Only the court
+can.
+So really -- all I'm saying to you is I do not
+understand the way this case was filed or why these
+are the defendants because it's impossible for them
+to perform.
+I mean, I'm going to assume, based on your
+motion, again, that they do have the records. But we
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+CAAORIDA HOLDINGS US DAVE ARONBERG
+June 03, 2020
+10
+all know -- everyone in the room knows they do not --
+that only the court -- they're -- they're with a
+court interpreting. And only the court can release
+the records.
+So if you get a judgment against either the
+state attorney or the clerk, they cannot -- I mean, I
+guess what you're saying to me is, well, we want to
+do discovery and we want them to say unequiyocally "I
+have these records" or "I don't have them."
+And -- I mean, the law is abundantly clear.
+You cannot do it without a court determining whether,
+in the furtherance of justice, the release is
+appropriate.
+MS. BOYAGIAN: And that is a determination
+we're asking your Honor to make, and we're asking for
+an order from your court.
+THE COURT: When we get to the merits of the
+case, sure it is. But, again, you're asking me to
+make that determination and for me to make a
+determination of whether the grand jury records
+should be released. And the only thing we're here
+today about is why should the clerk and the state
+attorney have to defend a civil action when it's a
+possibility of performance? They -- even if you were
+to win and get a judgment against them, they cannot
+→ ESQUIRE
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+June 03, 2020
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+give you what they don't have.
+So -- I mean, it's as simply as this: Are
+you -- you just want to engage in some discovery for
+them to absolutely assert, particularly, the state
+attorney, "I don't have these records"; look to the
+rules that say the moment the grand jury's over,
+they're sealed and they're turned over and they
+cannot be released without court order?
+So I'm not addressing the merits or whether you
+have an exception or you're able to argue that
+there's an exception in the furtherance of justice.
+We're not getting there today. I'm simply saying why
+should these two entities have to defend this lawsuit
+when even down the road if they win they can't give
+you what they don't have?
+MS. BOYAGIAN: As your Honor stated, I'm not
+sure that's the case with the clerk. That was not in
+their --
+that issue was not stated in their papers.
+THE COURT: Let me ask you this, then: Do you
+think, if you got a judgment and I or the court
+doesn't make the determination that the grand jury
+records should be released, that the clerk would be
+able to perform?
+Would they be able to say "here you go"? I
+mean, could the clerk just make that unilateral
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+June 03, 2020
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+decision "I'm going to release the records, sealed
+confidential records"?
+Does she have any authority to do that?
+MS. BOYAGIAN: My understanding, your Honor, is
+that 905.27 requires a court order before the records
+are unsealed.
+THE COURT: Exactly. Exactly.
+All right. Let me hear from Mr. Aronberg's
+attorney, Mr. Wyler.
+MR. WYLER: Thank you, your Honor. May it
+please the Court --
+THE COURT: Good morning, sir.
+MR. WYLER: Good morning.
+Your Honor, I just wanted to let you know that
+I spoke with counsel for the clerk, Ms. Fingerhut, a
+couple of days before this hearing, and we decided
+that I would just make the presentation for both of
+of us, being that our arguments overlap except for
+the fact of who this claim -- whether they have the
+records or not, which, of course, we've said we don't
+have custody of the records.
+But, nonetheless, our arguments overlap. The
+Plaintiff is attempting to assert a cause of action
+under Section 905.27. That statute settled testimony
+not to be disclosed exceptions. So it's just
+→ ESQUIRE
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+June 03, 2020
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+explaining exceptions to the disclosure of the grand
+jury testimony.
+Our position is that it doesn't set forth a
+cause of action and that it's impossible for us to
+perform what they're asking.
+I know you said you didn't really want to get
+into the Furthering Justice Exception, but I know
+that's what they're using as their basis to get to
+these. But it's our position that the clear
+unambiguous statutory language, it shows that this
+disclosure only applies to a Civil or criminal case,
+and that within that civil or criminal --
+(Speaking simultaneously.)
+THE COURT: Again, sir -- I'm sorry. As I told
+Plaintiff's counsel y
+MR. WYLER:
+can only be used in the defense
+for --
+THE COURT: Okay. We're not there. We're not
+discussing the merits of the case, and -- I'm not
+ready to cross that bridge. I'm here for a very,
+very limited hearing today.
+So just as I stopped Plaintiff's counsel from
+arguing the merits of the case and whether or not the
+Furtherance of Justice Exception will apply in this
+instance, we're not even there yet.
+C ESQUIRE
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+June 03, 2020
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+I'm only here for the purpose of determining
+whether or not the clerk and state attorney should be
+dismissed. And I am bound by the four corners of the
+document, which assert that you do have control and
+custody over it.
+So if you'll fashion your argument with regard
+to that limited purpose, I would appreciate
+it.
+MR. WYLER: No problem, your Honor. I
+apologize.
+Within the four corners of their complaint, our
+position is that they failed to state a cause of
+action under 905.27. It does not provide for -- it
+doesn't list that there's no element that they have
+adequately pled to assert a cause of action under
+that. There's -- and the only thing they're asking
+for is records that we don't have.
+There's really not much more to it, your Honor.
+And we would ask that you would grant our motion to
+dismiss for failure to state a cause of action.
+THE COURT: Okay. Ms. Fingerhut, are you still
+on the phone?
+MS. FINGERHUT: Yes, your Honor.
+THE COURT: Is there anything you wish to add?
+MS. FINGERHUT: We agree with the state
+→ ESQUIRE
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+June 03, 2020
+15
+attorney's position, and we also agree with what the
+Court has said, that the plain language of the
+statute, a cause of action doesn't exist. And we
+really cannot -- we'll be defending something without
+the four corners. We're simply involved in this
+action because the clerk is the custodian of the
+records.
+THE COURT: Okay. Thank you,
+. Boyagian, back to you.
+MS. BOYAGIAN: Your Honor, I'd like to note
+that in the Butterworth case in which the Supreme
+Court limited the application 905.27 by saying that a
+witness can reveal her own testimony and prohibiting
+that they violate the First Amendment --
+THE COURT:
+Say that again, please.
+MS. BOYAGIAN:
+In the Supreme Court case, the
+Butterworth case, in which the Supreme Court ruled
+that 905.27 can't restrict a Grand Jury witness from
+revealing her own testimony, that would be a
+violation of First Amendment, in that case, the state
+attorney was, in fact, a party.
+THE COURT: Well, I assume the state attorney
+that was present -- I mean, I don't find that that's
+close to what we're talking about here, and that's
+whether or not -- I mean, as we know, this was in
+ESQUIRE
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+June 03, 2020
+16
+2006. Certainly Dave Aronberg wasn't even the state
+attorney then. But this is about the release of
+records.
+I want to give you ample opportunity -- and
+again, I sincerely appreciate that all of the case
+law and the way that it was presented to the Court in
+such a timely fashion. I really do. And I did spend
+some time with it. But I want to give you whatever
+opportunity you want to take to convince me that it
+is in -- as to Count 2, again. Not the dec action --
+whether these would be the appropriate defendants.
+And, you know, really I want you to boil it
+down for me as to this & let's take it all the way
+down the road. You win.
+You get a judgment against
+the clerk and the state attorney.
+I know there's other reasons why you might have
+filed it this way. But I'm just simply puzzled
+because I do hear what the clerk and the state
+attorney are saying, and that is, performance is
+impossible. They don't have the records and
+cannot -- absolutely. There's not even an inch of
+wiggle room -- that they could release the records
+even if you got a judgment. It is solely a
+determination for the court.
+I, frankly, think, you know, there's ways to
+→ ESQUIRE
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+June 03, 2020
+17
+get to your records. There's ways to get
+confidential records. But it isn't by suing the
+state attorney and the clerk.
+So I just want to hear your last final argument
+on how Count II, the appropriate defendants are the
+clerk and the state attorney. Even assuming arguendo
+they have the records -- we know they don't
+-- you
+were to get a judgment against them, how would you
+expect them to perform?
+MS. BOYAGIAN: Iwo points, Your Honor: One is
+that, again, the clerk did not assert in her papers
+that she does not have control. That is a position
+that the State Attorney's Office has asserted. It is
+our allegation, and as your Honor noted, allegations
+must be accepted as true -- as true at this stage of
+the proceedings.
+Second,
+it is also our understanding that the
+state attorney and the clerk intend to block access
+to these records. So our allegation is that they do
+have possession, custody, or control, which the clerk
+has not denied; and second, that they are trying to
+block access to the records --
+THE COURT: What do you mean? What do you
+mean? They're not trying to block it. They're
+saying that despite the fact -- let's just talk about
+ESQUIRE
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+June 03, 2020
+18
+the clerk, because we all know the state attorney
+doesn't have it.
+So the clerk is the custodian of records.
+That's her main job.
+There's no doubt about it. We
+all know that. But we also know, unequivocally --
+unequivocally, only the court can make the
+determination of whether the moving party has
+satisfied that there is an exception that these
+should be released.
+So, again, I ask you -- she is, in fact, the
+custodian of the records -- is it your opinion that
+if you got a judgment saying clerk and comptroller
+gets a judgment against them, that she can release
+the records without the court -- without the court
+weighing in, without the court making that
+determination as required by law?
+MS. BOYAGIAN: No, your Honor. We are asking
+your Honor to order the clerk to do that under your
+discretion.
+THE COURT: All right.
+Mr.
+-- Ms. Fingerhut, you wish to be heard on
+that?
+MS. FINGERHUT: Your Honor, our position is
+that we're not trying to block access to the
+records --
+2 ESQUIRE
+
+
+(Speaking simultaneously.)
+THE COURT: Can you hear? Can the attorneys
+June 03, 2020
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+hear?
+MS. FINGERHUT: -- custodian the records and
+that he cannot release the records without court --
+THE COURT: Exactly.
+Okay. All right. Anything further,
+Mr.
+wyler?
+MR. WYLER: No, your Honor. I concur with the
+attorneys for the clerk's office that it's impossible
+for us to release these records.
+There's no intent
+to hide them or block anything from the Plaintiff.
+THE COURT: Okay. Anything further,
+Ms. Fingerhut?
+MS. FINGERHUT:
+THE COURT:
+No, your Honor.
+And, Ms. Boyagian, anything
+further,
+. BOYAGIAN: Nothing further, your Honor.
+THE COURT: Okay. I will get an order out
+quickly
+Thank you, folks so much. And I'll see you
+on the next round. Thanks a lot.
+MS. BOYAGIAN: Thank you, your Honor.
+MR. WYLER: Thank you, your Honor.
+(The proceedings concluded at 10:28 a.m.)
+ESQUIRE
+POSITION SOLUTIONS
+
+
+CERTIFICATE OF REPORTER
+June 03, 2020
+20
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+I, Sonja M.
+Court Reporter, certify that
+I was authorized to and did stenographically report the
+foregoing proceedings and that the transcript, pages 1
+through 19, is a true and complete record of my
+stenographic notes.
+NOT
+Sonja M.
+Court
+Reporter
+→ ESQUIRE
+
+
+Def.Ex.A-7
+
+
+CIRCUIT CIVIL DIVISION AG
+CASE NO. 50-2019-CA-014681-XXXХ-MB
+CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner
+VS.
+DAVE ARONBERG,
+SHARON R BOCK,
+Defendant/Respondents.
+ORDER GRANTING DEFENDANTS MOTIONS TO DISMISS COUNT IL OF
+PLAINTIFE'S FIRST AMENDED COMPLAINT WITH PREJUDICE
+THIS CAUSE came before the Court on Dave Aronberg, as State Attomey of Palm
+Beach County's ("State Attorney") and Sharon R. Bock, as Clerk & Comptroller of Palm Beach
+County's, ("Clerk") respective Motions to Dismiss Cout Il of CA Florida Holdings, LLC,
+Publisher of the Palm Beach Post's ("The Post") First Amended Complaint (DE## 22, 24). This
+case is assigned to Division AG, which is currently presided over by the Honorable Donald
+Hafele. However, the undersigned, as Chief Judge of the Fifteenth Judicial Circuit, presided
+over the June 3, 2020 hearing on the State Attorney and Clerk's Motions as the Motions
+implicate records of the Palm Beach County grand jury, over which the Chief Judge presides.
+See § 905.01, Fla. Stat. (2019)., After careful consideration of the pleadings and the arguments
+presented at the hearing, the Court grants the Motions for the following reasons.
+Background
+The Post is a media outlet which has heavily reported on the 2006 Palm Beach County criminal
+prosecution of Jeffrey Epstein. Through the instant civil lawsuit, The Post seeks "immediate
+access to the testimony, minutes, and other evidence presented in 2006 to the Palm Beach
+County grand jury" in Mr. Epstein's case and alleges that both the State Attorney and Clerk are
+"in possession and/or control of [those] documents." (DE # 17, First Amended Complaint at 91
+3,4, and 77). Specifically, The Post seeks declaratory judgment as to its rights to obtain the
+grand jury testimony in Mr. Epstein's case from the State Attorney and Clerk (Count I) as well as
+
+
+
+judgment against the State Attorney and the Clerk pursuant to section 905.27, Florida Statutes,
+which sets forth the parameters of grand jury secrecy in Florida. (Count II. Both the State
+Attorney and the Clerk move to dismiss Count Il of The Post's First Amended Complaint,
+arguing that that section 905.27 does not create a private cause of action (DE## 22, 24). The
+Court agrees.
+Analysis
+"In reviewing a motion to dismiss for failure to state a cause of action, the court must accept the
+allegations of the complaint as true and construe them in the light most favorable to the plaintiff."
+Almarante v. Art Institute of Fort Lauderdale, Inc., 921 So. 2d 703, 704-05 (Fla, 4th DCA
+2006). The motion should only be granted if the moving party demonstrates that the plaintiff
+cannot provide any facts that would support a cause of action. Id. It follows that if the cause of
+action alleged is nonexistent under Florida law, dismissal is warranted. Cummings v. Dawson,
+444 So. 2d 565, 566 (Fla. Ist DCA 1984) (affirming dismissal of cause of action not recognized
+by Florida law).
+Section 90527, Florida Statutes (2019), is tifled "Testimony not to be disclosed, exceptions,"
+and states:
+(1) A grand juror, state attorney, assistant state attomey, reporter, stenographer,
+interpreter, or any other person appearing before the grand jury shall not disclose the
+testimony of a witness examined before the grand jury or other evidence received by it
+except when required by a court to disclose the testimony for the purpose of:
+a. Ascertaining whether it is consistent with the testimony given by the witness before
+the court;
+bo Deternining whether the witness is guilty of perjury; or
+c. Furthering justice.
+(2) It is unlawful for any person knowingly to publish, broadcast, disclose, divulge, or
+communicate to any other person, or knowingly to cause or pennit to be published,
+broadcast, disclosed, divulged, or communicated to any other person, in any manner
+whatsoever, any testimony of a witness examined before the grand jury, or the content,
+gist, or import thereof, except when such testimony is or has been disclosed in a court
+proceeding. When a court orders the disclosure of such testimony pursuant to subsection
+(1) for use in a criminal case, it may be disclosed to the prosecuting attomey of the court
+in which such criminal case is pending, and by the prosecuting attorney to his or her
+assistants, legal associates, and employees, and to the defendant and the defendant's
+
+
+
+attorey, and by the latter to his or her legal associates and employees. When such
+disclosure is ordered by a court pursuant to subsection (1) for use in a civil case, it may be
+disclosed to all parties to the case and to their attorneys and by the latter to their legal
+associates and employees. However, the grand jury testimony afforded such persons by
+the court can only be used in the defense or prosecution of the civil or criminal case and
+for no other purpose whatsoever.
+(3) Nothing in this section shall affect the attorney-client relationship. A client shall have
+the right to communicate to his or her attorney any testimony given by the client to the
+grand jury, any matters involving the client discussed in the client's presence before the
+grand jury, and any evidence involving the client received by or proffered to the grand jury
+in the client's presence.
+(4) Persons convicted of violating this section shall be guilty of a misdemeanor of the first
+degree, punishable as provided in s. 775.083, or by fine not exceeding $5,000, or both.
+(5) A violation of this section shall constitute criminal contempt of court.
+§ 905.27, Fla. Stat. (20 19).
+As the State Attorney and Clerk argue and The Post concedes, section 905.27
+makes no express provision for a civil suit or civil liability. Nonetheless, The Post maintains that
+it is entitled to seek the grand jury records via a private cause of action pursuant to the "furthering
+justice" exception to grand jury secrecy contained in subsection 905.27(1)(c). Therefore, the
+limited question for this Court's consideration is whether a cause of action under section 905.27
+should be judicially implied. See Murthy v. N. Sinha Corp., 644 So. 2d 983, 985 (Fla. 1994).
+In advocating that it may maintain a cause of action against the State Attorney and Clerk
+under section 90527, The Post urges the Court to examine three factors "(1) whether the
+plaintiff is one of the class for whose special benefit the statute was enacted; (2) whether there
+is any indication, either explicit or implicit, of a legislative intent to create or deny such a
+remedy; and (3) whether judicial implication is consistent with the underlying purposes of the
+legislative scheme." (Plaintiff's Opposition to Defendant, Dave Aronberg, As State Attorney of
+Palm Beach County, Florida's Motion to Dismiss Count II of the First Amended Complaint at
+page 13 (citing Fischer v. Metcalf, 543 So. 2d 785 (Fla. 3d DCA 1989)). Within these three
+factors, The Post recognizes that there is no indication of legislative intent to create a cause of
+action, but leans heavily on the benefit factor, arguing that the "furthering justice" exception to
+
+
+
+grand jury secrecy outlined in section 905.27(1)(c) was meant to benefit the public at large, for
+which the press acts as a surogate. The Post's arguments are unpersuasive as to the discrete
+issue of whether a private cause of action lies in section 905.27.
+To begin with, The Post's reliance on the benefit factor is misplaced. Per the Florida
+Supreme Court's 1994 opinion in Murthy, "the question of whether a statute establishes a duty to
+take precautions to protect or benefit a particular class of persons is no longer determinative on
+the question of whether a cause of action should be recognized." Sorenson v. Profl
+Compounding Pharmacists of W. Pa., Inc., 191 So. 3d 929 (Fla. 2d DCA 2016) (citing Murthy,
+644 So. 2d at 985). Instead, "whether a statutory cause of action should be judicially implied is a
+question of legislative intent." Horowitz v. Plantation Gen. Hosp. Ltd. P'ship, 959 So. 2d 176,
+182 (Fla. 2007). See also QBE Ins. Corp. v. Chalfonte Condo. Apartment Ass'n, Inc., 94 So. 3d
+541, 551 (Fla. 2012) ("Since Murthy, we have reaffirmed the principle that whe the r a statutory
+cause of action should be judicially implied is a question of legislative intent."); Universal Prop.
+& Cas. Ins. Co. v. Loftus, 276 So. 3d 849, 851 (Fla. 4th DCA 2019).
+As is always the case when a court undertakes a legislative intent analysis, the plain
+language of the statute is the starting, and often ending, point. See Horowitz, 959 So. 2d at 182.
+"When the statute is clear and unambiguous, courts will not look behind the statute's plain
+language for legislative intent or resort to rules of statutory construction to ascertain intent."
+Loftus, 276 So. 3d at 851 (Fla. 4th DCA 2019)) (quoting Daniels v. Fla. Dep't of Health, 898 So.
+2d 61, 64 (Fla. 2005)). "However, a single part of a statute should not be read in isolation." Id.
+"Instead, 'all parts of a statute must be read together in order to achieve a consistent whole."" Id.
+(quoting Forsythe v. Longboat Key Beach Erosion Control Dist., 604 So. 2d 452, 455 (Fla.
+1992)).
+As The Post acknowledges, "there is a dearth of legislative history surrounding Section
+90527 and the The Palm Beach Post was unable to locate any documents capturing any
+legislative intent regarding the possibility of a private right of action." (Plaintiff's Opposition to
+Defendant, Dave Aronberg, As State Attorney of Palm Beach County, Florida's Motion to
+Dismiss Count Il of the First Amended Complaint at page 14). While the lack of any legislative
+
+
+
+history indicating an intent to create a private right of action is telling, it is not dispositive as the
+plain language of the section 905.27 is clear an unambiguous and, therefore, controls. Horowitz,
+959 So, 2d at 182.
+Examining the plain language of section 905.27 in its entirety, which requires the Court to
+look at more than just the "furthering justice" provision of section 905.27(1)(c) relied on by The
+Post, it is clear that the intent of the Legislature in passing section 905.27 was to limit, not
+facilitate, disclosure of grand jury records. In no uncertain terns, the Legislature provided that
+no "person appearing before the grand jury" may "disclose" testimony or evidence presented
+except when "required by a court" under certain limited circumstances. § 905.27(1), Fla. Stat. In
+solidifying that its intent was to prohibit disclosure without court permission, the Legislature
+provided that disclosure without a court order is a criminal offense, § 90527(4), Fla. Stat.
+Therefore, to the extent section 905.27 could be read as inposing a duty on the State Attorney
+and Clerk, the duty imposed is one of secrecy, not disclosure,
+In sum, there is nothing in the text of section 905.27 from which one can deduce that the
+Legislature contemplated a member of the media, or anyone else for that matter, having a private
+cause of action to compel the State Attorney and Clerk to disclose grand jury records. Indeed,
+to the contrary, section 905.27 prohibits the State Attorney and the Clerk (assuming that, as
+pleaded by The Post, they have the documents) from disclosing the documents without first
+being ordered to do so by the court.[l Reading section 905.27 as creating a private cause of
+action against the State Attomey and Clerk is, therefore, not only unsupported by the language of
+section 905.27, but is actually paradoxical to its plain language of the statute. As such, this Court
+lacks the power to construe the unambiguous language of section 905.27 in a way that would
+extend its express terms and create a cause of action where none exists. "To do so would be an
+abrogation of legislative power." Horowitz, 959 So. 2d 176, 182 (quoting Holly v. Auld, 450 So.
+2d 217, 219 (Fla. 1984)).
+Conclusion
+Based on the foregoing, the Court finds CountIl of The Post's First Amended Complaint
+must be dismissed with prejudice as it pursues a nonexistent cause of action under section
+
+
+
+905.27. In arriving at this conclusion, the Court does not suggest The Post has no available
+mechanism to obtain a court order granting it access to the grand jury proceedings. The Court
+also does not render any opinion as to whether releasing these records is appropriate for the
+purpose of "furthering justice" within the meaning of section 905.27. Rather, the Court's
+dismissal of Count Il is necessitated by precedent and the simple fact that a civil lawsuit against
+the State Attorey and Clerk under section 905.27 is not the proper mechanism for The Post to
+pursue its goal.
+Therefore, it is hereby
+ORDERED AND ADJUDGED that Dave Aronberg, as State Attorney of Palm Beach
+County's and Sharon R. Bock, as Clerk & Comptroller of Palm Beach County's, respective
+Motions to Dismiss Count Il of CA Florida Holdings, LLC, Publisher of the Palm Beach Post's
+First Amended Complaint are GRANTED and Count Il of Plaintiff's first Amended Complaint is
+hereby DISMISSED with prejudice.
+DONE AND ORDERED, in West Palm Beach, Palm Beach County, Florida this 8th day
+of June, 2020.
+Krista Marx Chief Jydge
+06/08/2020
+50-2019-CA-014681-XXXX-MB
+Krista Marx
+Chief Judge
+[!] The Court notes that, if there was a court order directing the State Attorney or the Clerk to
+disclose records and the State Attorney or the Clerk refused, the remedy for disobeying a court order
+is contempt or, in some instances, a mandamus proceedings - not a civil lawsuit.
+COPIES TO:
+DOUGLAS A. WYLER
+No Address Available
+961687 GATEWAY BLVD
+SUITE 201-1
+FERNANDINA BEACH, FL
+
+No E-mail Address Available
+doug.wyler@comcast.net
+
+
+MICHAEL GRYGIEL
+MICHAELJ. GRYGIEL
+NICOLE R. FINGERHUT
+NINA D. BOYAJIAN
+NINA D. BOYAJIAN
+STEPHEN A.
+MENDELSOHN, ESQ
+32034
+54 STATE STREET
+6TH FLOOR
+ALBANY, NY 12207
+No Address Available
+POST OFFICE BOX 229
+WEST PALM BEACH, FL
+33401
+GRYGIELM(@GTLAW.COM
+grygielm@gtlaw.com
+CLERK E-
+SERVICE@MYPALMBEACH
+CLERK.COM
+nfingerhut@ mypalmbeachclerk.
+com
+No Address Available
+boyajiarn@gtlaw.com
+riveraal@gtlaw.com
+1840 CENTURY PARK
+No E-mail Address Available
+EAST
+SUITE 1900
+LOS ANGELES, CA 90067
+5100 TOWN CENTER CIR
+SUITE 400
+BOCA RATON, FL33486 flservice@gtlaw.com
+NOT A CERTIF
+
+
+
+Def.Ex.A-8
+
+
+HE LAW OFFICES C
+« ASSOCIATES, PA
+ARTHUR 1
+SCHOLZ & WYLER, LLC.
+A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+9EI887 GATEWAY BLVD. SUITE 201-1
+FERNANDINA BEACH, FLORIDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 261.7879
+RICHARD J. SCHOLZ, P.A.
+RICHARD J, SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A. WYLER
+June 8, 2020
+VIA ELECTRONIC & U.S. MAIL
+Stephen A. Mendelsohn, Esq.
+Greenburg Traurig, P.A.
+5100 Town Center Circle, Suite 400
+Boca Raton, FL. 33486
+COPY
+RE: CA Florida Holdings, LL.C v. Dave Aronberg et al.
+Palm Beach County, Case No.: 2019-CA-014681
+Dear Mr. Mendelsohn:
+As you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach
+County, Florida, in the above referenced ter. The purpose of this letter is to demand the voluntary
+dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand
+is made pursuant to section 57.105, Florida Statutés.
+As you know, Section 57.105 provides:
+reasonable attorney's fee, including prejudgment interest, to be paid to the
+prevailing party in equal amounts by the losing party and the losing party's attorney
+on any claim or defense at any time during a civil proceeding or action in which
+the court finds that the losing party or the losing party's attorney knew or should
+have known that a claim or defense when initially presented to the court or at any
+time before trial:
+a. Was not supported by the material facts necessary to establish the claim or
+detense; or
+b. Would not be supported by the application of then-existing law to those
+material facts.
+Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count Il of the
+Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action
+consists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein
+and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to
+establish the claims asserted, and that your claims are not supported by the application of current law
+
+
+First and foremost, the Complaint is not supported by the material facts necessary to establish the
+claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the
+Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.
+Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are
+impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to
+this action because no matter what, he and his office do not have possession, custody, or control of the
+requested materials.
+In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims
+are also not supported by the application of current law. Specifically, your action for declaratory relief
+fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes,
+which states:
+When such disclosure is ordered by a court pursuant to subsection (J) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorneys and by the latter
+to their legal associates and employees. However, the grand jury testimony afforded
+such persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable
+to comply with any court order granting disclosure of the requested documents because neither Mr.
+Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession,
+custody, or control of the 2006 Epstein grand jury records.
+Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter,
+the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client
+and your firm, recovery of the legal expenses incurred in defending this frivolous action.
+Please govern yourself accordingly
+Douglas A. Wyler, Esq.
+Encl.: Defendant's Motion for Attorneys' Fees
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+I hereby certify that on this
+_day
+, 2020, the foregoing was electronically filed
+via the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Ärthur I. L
+Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+NOTACE
+jacobsscholzlaw@comcast.net
+
+
+Def.Ex.A-9
+
+
+GT GreenbergTraurig
+Stephen A. Mendelsohn
+Tel 561.955.7629
+Fax 561.659.9119
+mendelschns@gtlaw.com
+Douglas A. Wyler
+Jacob Scholz & Wyler, LLC
+961687 Gateway Blvd.
+Suite 201-1
+Fernandina Beach, Fl. 32034
+Re:
+CA Florida Holdings, LLC v. Dave Aronberg et al.
+Case No. 2019-CA-014681
+COPY
+Dear Mr. Wyler:
+We are in receipt of your letter of June 8, 2020 with your proposed Fla. Stat. section 57.105 motion.
+In your letter and your proposed motion, you assert that CA Florida Holdings, LIC and the law
+firm of Greenberg Traurig, P.A. should be liable for the attorneys' fees to be incurred by State
+Attorney Aronberg after the date of your letter, Your letter cites to Fla. Stat. sections 57.105(1)
+(a) and (b) for support. As shown below, there is no basis for a Fla. Stat. section 57.105 motion,
+and we expect that if the State Attorney were to make such a motion, the court should deny it.
+Your letter omits a citation to section 57, 105(3). Subsection 57.105(3)(a) provides that sanctions
+may not be awarded where there is a "good faith argument for the extension, modification or
+reversal of existing law or the establishment of new law, as it is applied to the matenal facts, with
+a reasonable expectation of success." We have such a good faith argument.
+Contrary to your analysis of Fla. Stat. section 905.27, there are actually three instances where a
+court may order the release of grand jury materials. As we argue, the court may order release "in
+futherance of justice." There are few cases in Florida reviewing this provision and its scope. It is
+an open and valid question as to whether the court may order release of grand jury transcripts to
+the media, under both the statute and the First Amendment to the US Constitution in furtherance
+of justice. The statutory language you cite refers to instances where a person is seeking grand jury
+materials for use in a civil or in a criminal case. In these limited situations, the statute allows for
+such uses and for no other reason. However, the statute does not state, as you assert, that where
+the media seeks grand jury materials based upon its constitutional standing, which the Circuit
+Court acknowledged at the June 2, 2020 hearing includes The Palm Beach Post, that the statutory
+5100 Town Center Circle | Suite 400 | Boca Raton, Florida 33486 | T +1 561.955.7600 | F +1 561.338.7099
+Albany, Amsterdam. Atlanta. Austin. Berlin' Boca Raton. Boston. Chicago. Dallas. Delaware, Denver. Fort Lauderdale. Houston. Las Vegas, London' Los Angeles.
+Mexico City" Miami. Milan: Minneapolis. Nashville. New Jersey, New Tork, Northern Virginia. Orange County, Orlando. Philadelphia. Phoenix. Sacramento.
+San Francisco, Seoul. Shanghai. Silicon Valley. Tallahassee. Tampa. Tel Aviv: Tokyo: Warsaw. Washington, D.C. West Palm Beach. Westchester County: (
+
+
+Page 2
+use limitation you cite applies. No reported Florida case has addressed this issue and there is a
+good faith basis for our view of Fla. Stat. section 905.27
+Your letter also argues that sanctions are applicable because the State Attorney has alleged that it
+does not possess the Jeffiey Epstein grand jury transcripts. This allegation is also contained in the
+State Attorney's Answer. Assuming that the State Attorney does not currently have physical
+possession of the Epstein grand jury materials, which has yet to be demonstrated, this does not end
+the matter. The State Attorney was named as a party not simply as a custodian of grand jury
+records. The State Attorney was named in his official capacity as his office has as its primary
+interest the protection of its grand jury system." [Italics in original.] In re Grand Jury Proceedings.
+832 F. 3d 554, 559 (11" Circuit 1987). In that case, the US petitioned a state judge to order the
+State Attorney to turn over grand jury transcripts. The State Attorney argued against their release
+citing to Fla. Stat. section 905.27. Later, a federal grand jury subpoenaed the Broward County
+State Attorney for delivery of state grand jury testimony. The Broward State Attorney advised the
+federal court that it would produce the transcripts, thereby demonstrating that while it may not
+have physical possession of the materials, he had legal authority fo obtain and deliver them. It
+should also be noted that the State Attorney moved to quash the subpoena arguing that it was
+unlawful under Florida law and Fla. Stat. section 905.27. This case indicates that where one seeks
+grand jury materials, the relevant State Attorney is a necessary party in order to protect the grand
+jury that the Office of State Attorney supervised and to make arguments, if need be, against release
+of the grand jury materials. These are some of the same reasons why the State Attorney was named
+in this case.
+Also, assuming the State Attorney does not have physical possession of the grand jury materials,
+there is nothing in Florida law that prohibits the State Attorney from requesting that the Clerk
+provide copies to the State Attorney. Chapter 905, Fla. Stats. does not contain a prohibition against
+a State Attorney demand that the Clerk grant his office access to grand jury materials, even after a
+criminal case has concluded. Upon information and belief, the Clerk's office maintains a log that
+tracks release of grand jury materials to the State Attorney upon its request. Please confirm
+whether the State Attorney has accessed grand jury materials from the Clerk's office in other
+instances or that it has never done so. If the Clerk has such a log, then its contents should be
+discoverable, or subject to Florida Public records laws.
+Greenberg Traurig, P.A. | Attorners at Law
+
+
+Page 3
+For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed
+against the Office of the State Attorney. We expect that your demand will be withdrawn.
+Thank you,
+Very truly yours,
+/s/Stephen Mendelsohn
+Stephen Mendelsohn
+SAM:Is
+ACTIVE
+
+
+
+Def.Ex.A-10
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida; SHARON F
+OCK. as Clerk and Comptroller of Palr
+Beach County, Florida.
+Defendants.
+COPY
+CASE NO.: 19-CA-014681
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+I hereby certify that on this Ist day July, 2020, the foregoing was electronically filed via
+the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I.
+1. Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 002126Y
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+NOT A CERTAIN
+
+
+Def.Ex.A-11
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Bcach County, Florida; SHARON R
+sack Conly, Ford Comptroller of Palm
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+DEFENDANT DAVE ARONBERG'S MOTION FOR SUMMARY FINAL JUDGMENT
+AND MEMORANDUM OF LAW IN SUPPORT THEREOF
+Defendant
+DAVE ARONBERG, as State Attorncy of Palm Beach County, Florida,
+(hereinafter "Aronberg"), by and through counsel below and pursuant to Rule 1.510 Florida Rules of'
+Civil Proceduro, moves for entry of summary final judgment in his favor as to the remaining claim for
+Declaratory Relief in Plaintiff's First Amended Complaint', and in support thereof states as follows:
+STATEMENT OF THE UNDISPUTED FACTS
+The following is a statement of facts material to this motion for summary judgment as to which
+there is no genuine issuc:
+Count I of Plaintiff's First Amended Complaint, (hereinafter "Complaint"), filed
+January I7, 2020, secks Declaratory Relief pursuant to Section 86.011, Florida Statutes.
+Specifically, Plaintiff's Count I secks a court order "declaring that pursuant to Fla. Stat.
+Section 905.27(1)(c) and the Court's inherent authority, The Palm Beach Post may gain access to the
+testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury" that
+- On June 8, 2020, this Court entered its Order Granting Defendants Motion to Dismiss Count Il of the Plaintiff's First
+Amended Complaint with Prejudice
+
+
+was empancled during the first Jeffrcy Epstein, (hercinafter "Epstein"), sex abuse investigation,
+(hereinafter "Requested Materials"). Complaint pg. 20
+3.
+Plaintiff secks to use the Requested Materials "for the purpose of informing the public."
+Id.
+Plaintiff sceks the above-referenced declaratory relief, including copies of the
+Requested Materials, from both Aronberg, as State Attorney of Palm Beach County, Florida, and
+Defendant, Sharon R. Bock, as Clerk and Comptroller of Palm Beach County, Florida, (hercinafter the
+"Clerk").
+5.
+Neither Aronberg nor the Office of the Statc Attorncy for the Fificenth Judicial Circuit,
+("SAO"), is in control, custody, or possession of the Requested Materials. Aronberg Aff. 1 3, attached
+as Exhibit "A".
+6.
+The doclaratory relicf sought by the Plaintiff socks matcrials that are impossible for
+Aronberg or the SAO to produce. Exhibit "A/14
+Neither Aronberg nor the SAO has the legal authority to obtain and/or deliver the
+Roquestod Materials. Exhibit "A" 1|5.
+The undisputed facts set forth above in paragraphs 6-7 have been repcatedly made
+evident by Aronberg to the Plaintiff and the public through not only the pleadings and correspondence
+in this matter, but also through an office press releasc and Aronberg's public social media accounts.
+
+Neither Aronberg nor the SAO has the authority to demand that the Clerk grant the
+SAO access to grand jury materials after a criminal case has concluded. Exhibit "A" 17.
+10.
+During Aronberg's administration, neither he nor his office has accessed grand jury
+matcrials from the Clerk's office in this or any other instance. Exhibit "A" 98.
+2
+
+
+11.
+As provided in scetion 905.17(1), Florida Statutes (2020), the Clerk has sole custody
+and possession of the Requested Matcrials, which can only be released by the Clerk pursuant to an
+order of the Court. Exhibit "A" 99.
+MEMORANDUM OF LAW
+Legal Standard Governing Motions For Summary Judgment
+"The judgment sought shall be rendered forthwith if the pleadings, depositions, answers to
+interrogatorics, and admissions on file together with the affidavits, if any, show that there is no genuine
+issuc of material fact and that the moving party is entitled to a judgment as a matter of law." Rule
+1.510, Fla. R. Civ. P. It is appropriate to resolve a declaratory action on summary judgment when, as
+here, the decree secks a legal interpretation of a statute. Rahimi v Global Discoveries, Lid., LLC, 252
+So. 3d 804 (Fla. 5th DCA 2018).
+Il.
+The Requested Materials Can Only Be Released By The Clerk Pursuant To A Court
+Order
+Notably, ncither Aronberg nor the SAO is in control, custody, or possession of the Requested
+Materials. Exhibit "A" 9| 3. Nonetheless, pursuant to Section 905.27(1)(c), Florida Statutes and the
+Court's inherent authority, Plaintiff secks a court order declaring that Aronberg provide copies of the
+Requested Materials to The Palm Beach Post for the purpose of informing the public. Complaint pg
+20-21. Plaintiff is sceking declaratory relief alleging its entitlement to the Requested Materials
+pursuant to the "furthering justice" excoption to grand jury secrocy. § 905.27, Fla. Stat. (2020).
+Despite bringing its declaratory relief claim pursuant to Section 905.27, Florida Statutes, "a
+single part of a statute should not be read in isolation." Universal Prop. & Cas. Ins. Co. v. Loftus, 276
+So. 3d 849, 851 (Fla. 4th DCA 2019). 'Instcad, "all parts of a statute must be read together in order to
+achieve a consistent whole."" Id. (quoting Forsythe v. Longboat Key Beach Erosion Control Dist.,
+604 So. 2d 452, 455 (Fla. 1992).
+3
+
+
+Section 905.17(1), Florida Statutes makes clcar that grand jury records, like the Requested
+Materials in this matter, arc to be maintained with the Clerk, and can only be released by the Clerk
+pursuant to a court order. To wit:
+The stenographic records, notes, and transcriptions made by the court reporter or
+stenographer shall be filed with the clerk who shall keep them in a scaled container not
+subject to public inspection. The notes, records, and transcriptions are confidential
+and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. I of the State
+Constitution and shall be released by the clerk only on request by a grand jury for use
+by the grand jury or on order of the court pursuant to s. 905.27.
+Soction 905.17(1), Florida Statutes (2020). (Emphasis added.)
+Text, context, and purpose are the ordinary tools used for discerning statutory meaning, with
+the overarching principle being "that judges lack the power to construc an unambiguous statute in a
+way which would extend, modify, or limit its express terms or its reasonable and obvious implications.
+To do so would be an abrogation of legislative power." Id. Here, the plain language of section 905.17
+is clear and unambiguous and, therefore, controls. See Horowitz v. Plantation Gen. Hosp. Ltd. P'ship,
+959 So. 2d 176, 182 (Fla. 2007).
+Accordingly, based on the clcar, unambiguous statutory language set forth in section 905.17(1),
+only the Clerk, not the State Attorncy, may release grand jury materials pursuant to an order of the
+court. Thus, it is apparent that Aronberg and the SAO lack the legal authority to obtain and deliver the
+Requested Materials. Exhibit "A" 9| 5. Likewise, the declaratory relicf sought by the Plaintiff sceks
+materials that are impossible for Aronberg or the SAO to produce. Exhibit "A" 11 4. Again, the Clerk
+has sole custody and possession of the Requested Materials. These facts have been repcatedly made
+evident by Aronberg to the Plaintiff and the public through not only the pleadings and correspondence
+in this matter, but also through an office press release and Aronberg's public social modia accounts.
+
+Although the above-referenced statutory authority illuminates the fact that only the Clerk may
+release grand jury records like the Requested Materials hercin, it remains significant to note that neither
+4
+
+
+Aronberg nor the SAO has the authority to demand that the Clerk grant the SAO access to grand jury
+materials after a criminal case has concluded. Exhibit "A" 9 7.
+Hence, during Aronberg's
+administration, neither he nor his office has accessed grand jury materials from the Clerk's office in
+this or any other instance. Exhibit "A" 9|8.
+Ill.
+Conclusion
+The ultimate facts underlying the lawsuit are not in dispute. The Court is fully cmpowered to
+dispose of this matter based on application of the undisputed facts to the plain language of Section
+905.17, Florida Statutes, which renders the Plaintiff's action for declaratory L
+fan impossibility for
+Aronberg to perform and that must be denied as a matter of law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorncy of Palm Beach County,
+Florida, respectfully requests that this motion be granted and that summary final judgment be entered
+in his favor consistent with this motion, and hereby respectfully roquests that this Court dismiss the
+Complaint with prejudice and grant such other folicf, including attorney's fees and costs, as this Court
+deems fit and proper under the circumstances.
+I HEREBY CERTIFY that on this 18th day of August, 2020, a copy of the foregoing has been
+clectronically filed with the Florida E-File Portal for c-scrvice on all parties of record hercin.
+NOT
+]SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur 1. L
+Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.nct
+5
+
+
+6
+
+
+
+
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Defendants.
+..!
+AFFIDAVIT OF DAVID ARONBERG
+CASE NO.: 19-CA-014681
+COPY
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Before me, the undersigned authority personally appeared DAYID ARONBERG, being first duly sworn,
+states:
+My name is David (Dave) Aronberg, and I am the State Attorney for the Fifteenth Judicial
+Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter.
+Plaintiff is seeking declaratory relief, pursuant to Fla. Stat. 905.2 1(1)(c) and the Court's
+inherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006
+to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the
+purpose of informing the public.
+Despite Plaintiff's above-described action for declaratory relief, neither myself nor the
+Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession
+of the Requested Materials.
+As such, the declaratory relief sought by the Plaintiff seeks materials that are impossible
+for me or my office to produce.
+S.
+To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the
+Requested Materials.
+6.
+I have repeatedly made these facts evident to the Plaintiff and the public through not only
+the pleadings and correspondence in this matter, but also through an office press release and my public
+social media accounts.
+
+
+7.
+Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to
+demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded.
+8.
+Moreover, during my administration, neither myself nor my office has accessed grand jury
+materials from the Clerk's office in this or any other instance.
+9.
+As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and
+possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the
+Court.
+FURTHER AFFIANT SAYETH NAUGHT.
+„Cog
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Sworn to and subscribed before me this 30 day of July, 2020, by DAVID ARONBERG, who is
+personally known'to me or has shown.
+as personal identification.
+NOT A CER
+Notary's Stamp or Seglymu
+LATOSHA LOME-GOODE
+Consmission # GG 967813
+Expines May 28, 2024
+Fended Then Budpa Mary Borden
+
+
+Def.Ex.A-12
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Defendants.
+..!
+AFFIDAVIT OF DAVID ARONBERG
+CASE NO.: 19-CA-014681
+COPY
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Before me, the undersigned authority personally appeared DAYID ARONBERG, being first duly sworn,
+states:
+My name is David (Dave) Aronberg, and I am the State Attorney for the Fifteenth Judicial
+Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter.
+Plaintiff is seeking declaratory relief, pursuant to Fla. Stat. 905.2 1(1)(c) and the Court's
+inherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006
+to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the
+purpose of informing the public.
+Despite Plaintiff's above-described action for declaratory relief, neither myself nor the
+Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession
+of the Requested Materials.
+As such, the declaratory relief sought by the Plaintiff seeks materials that are impossible
+for me or my office to produce.
+S.
+To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the
+Requested Materials.
+6.
+I have repeatedly made these facts evident to the Plaintiff and the public through not only
+the pleadings and correspondence in this matter, but also through an office press release and my public
+social media accounts.
+
+
+7.
+Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to
+demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded.
+8.
+Moreover, during my administration, neither myself nor my office has accessed grand jury
+materials from the Clerk's office in this or any other instance.
+9.
+As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and
+possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the
+Court.
+FURTHER AFFIANT SAYETH NAUGHT.
+„Cog
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Sworn to and subscribed before me this 30 day of July, 2020, by DAVID ARONBERG, who is
+personally known'to me or has shown.
+as personal identification.
+NOT A CER
+Notary's Stamp or Seglymu
+LATOSHA LOME-GOODE
+Consmission # GG 967813
+Expines May 28, 2024
+Fended Then Budpa Mary Borden
+
+
+Def.Ex.A-13
+
+
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+COPY
+Defendants.
+PLAINTIFF CA HOLDINGS, LLC'S
+NOTICE OF DROPPING STATE ATTORNEY, DAVE ARONBERG
+Plaintiff, CA HOLDINGS, LL.C, pursuant to Fla. R. Cix. P. /250(b), hereby notifies the parties that
+it has dropped State Attorney, Dave Aronberg from the above case.
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Autore pator eAtinda Holdings, LLC. Publisher
+Stephen A. Mendelsohn, Esq.
+401 East Las Olas Boulevard Suite 2000
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+Florida Bar No. 849324
+FL.Service@gtlaw.com
+
+
+By: Is/ Michael J Grygiel
+MICHAELJ GRYGIEL
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Boyajian
+NINA D. BOYAJIAN
+1840 Century Park East, Suite 1900
+Los Angeles California 90067
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+bovaiiann/@stlaw.com
+v.com
+I HEREBY CERTIFY that on this 21" day of October, 2020, a true and correct copy of the
+foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which
+will send a notice of electronic service for all parties of record herein
+ACTIVE
+53317341v1
+/s/ Stephen A. Mendelsohn
+2
+
+
+Def.Ex.A-14
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida; SHARON F
+OCK. as Clerk and Comptroller of Palt
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+DEFENDANT DAVE ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned counsel, hereby moves this Honorable Court, pursuant to Rule 1.525, Fla.
+R. Civ. P. to enter an award of attorneys' fees in his favor against Plaintiff, CA FLORIDA
+HOLDINGS, LLC, publisher of the PALM BEACH POST, and in support thereof states the
+following:
+BASIS FOR AWARDING ATTORNEYS' FEES
+On November 14, 2019, CA FLORIDA HOLDINGS, LLC, publisher of the PALM
+BEACH POST ("Plaintiff") filed a complaint against DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida (the "State Attorney" or "Defendant Aronberg") and SHARON R.
+BOCK, as Clerk and Comptroller of Palm Beach County, Florida (the "Clerk"). The basis of the
+action was asking the Court to order the State Attorney and the Clerk to disclose the 2006 Jeffrey
+Epstein grand jury materials, (the "Requested Materials"), pursuant to § 905.27(1) Fla. Stat.
+
+
+On December 6, 2019, the State Attorney filed his Motion to Dismiss, then on
+December 13, 2019, the Clerk also filed a Motion to Dismiss. In response, Plaintiff filed its First
+Amended Complaint on January 17, 2020, which in addition to its original claim under § 905.27
+Fla. Stat. (Count II) added a claim for Declaratory Relief (Count I) that sought an order declaring
+that the State Attorney and the Clerk disclose the Requested Materials to Plaintiff for the purpose
+of informing the public.
+On January 24, 2019, both the State Attorney and the Clerk filed their Answer to
+the First Amended Complaint and Motion to Dismiss Count I| ("Answer/Motion to Dismiss).
+Notably, the State Attorney's Answer/Motion to Dismiss asserted its right to attorneys' fees for
+defending the action and requested such relief from the Court.
+On June 8, 2020, the Court entered its Order Granting Defendants Motions to
+Dismiss Count Il of Plaintiff's First Amended Complaint with Prejudice ("Order").
+Immediately following the Court's Order, on June 8, 2020, the State Attorney,
+through the undersigned counsel, served Plaintiff with a demand pursuant to § 57.105 Fla. Stat..,
+to voluntary dismiss/withdraw the First Amended Complaint and the claims against the State
+Attorney, along with a Motion for Attorneys' Fees ("57.105 Demand"). See, Exhibit "A".
+Specifically, because of the Court's Order only Count I of Plaintiff's Amended Complaint
+remained, which sought Declaratory Relief under § 86.011, Fla. Stat.
+Here, in properly serving his 57.105 Demand on Plaintiff, the State Attorney also
+properly put Plaintiff on notice that he would seek sanctions by filing the 57.105 Motion for
+Attorneys' Fees if Plaintiff failed to dismiss the remainder of its First Amended Complaint within
+21 days of service of the 57.105 Demand and Motion for Attorneys' Fees.
+2
+
+
+On June 23, 2020, Plaintiff's counsel sent a response to the 57.105 Demand
+refusing to withdraw the remainder of the First Amended Complaint. See, Exhibit "B".
+8.
+§ 57.105, Florida Statutes states the following:
+A motion by a party seeking sanctions under this section must be served but may
+not be filed with or presented to the court unless, within 21 days after service of the
+motion, the challenged paper, claim, defense, contention, allegation, or denial is not
+withdrawn or appropriately corrected.
+9.
+Accordingly, after receiving Plaintiff's June 23, 2020, response refusing to
+withdraw the remainder of the First Amended Complaint and waiting the prerequisite "21 days
+after service of the motion" the State Attorney's Motion for Attorneys' Fees was filed with this
+Court on July 1, 2020. See, Exhibit "C".
+10. Thereafter, on August 18, 2020, the State Attorney filed his Motion for Summary
+Judgment ("Motion") and proceeded, on October 21, 2020, to file a Motion to Set Hearing on the
+State Attorney's Motion ("Motion to Set") after it became clear that there would be no resolution
+of this matter without the Court's intervention.
+11. Nonetheless, later the same day, rather than setting and participating in a hearing
+on the merits as to State Attorney's Motion, Plaintiff filed its Notice of Dropping the State Attorney
+("Notice") from the instant case. See, Exhibit "D". As a consequence of filing its Notice, Plaintiff
+has effectively made an admission that its allegations against the State Attorney have no basis in
+fact or law.
+12.y
+"An essential distinction between a notice of dropping a party and a voluntary
+dismissal is that the former concludes the action as to the dropped party while the latter is generally
+utilized to conclude the action in its entirety." Carter v. Lake County, 840 So. 2d 1153, 1155 (Fla.
+5th DCA 2003).
+3
+
+
+13.
+Specifically, Plaintiff's Notice states: "Plaintiff, [sic], pursuant to Fla. R. Civ. P.
+1.250(b), hereby notifies the parties that it has dropped State Attorney, Dave Aronberg from the
+above case."
+14.
+Rule 1.250(b), Fla. R. Civ. P. states:
+(b) Dropping Parties. Parties may be dropped by an adverse party in the manner
+provided for voluntary dismissal in rule 1.420(a)(1) subject to the exception stated
+in that rule. If notice of lis pendens has been filed in the action against a party so
+dropped, the notice of dismissal shall be recorded and cancels the notice of lis
+pendens without the necessity of a court order. Parties may be dropped by order of
+court on its own initiative or the motion of any party at any stage of the action on
+15. Rule 1.420(a)(1), Fla. R. Civ. P., Voluntary Dismissal states:
+(1) By Parties. Except in actions in which property has been seized or is in the
+custody of the court, an action, a claim, or any part of an action or claim may be
+dismissed by plaintiff without order of court (A) before trial by serving, or during
+trial by stating on the record, a notice of dismissal at any time before a hearing on
+motion for summary judgment, or if none is served or if the motion is denied, before
+retirement of the jury in a case tried before a jury or before submission of a nonjury
+case to the court for decision, or (B) by filing a stipulation of dismissal signed by
+all current parties to the action. Unless otherwise stated in the notice or stipulation,
+the dismissal is without prejudice, except that a notice of dismissal operates as an
+adjudication on the merits when served by a plaintiff who has once dismissed in
+any court an action based on or including the same claim.
+16. Notably, "[RJule 1.250(b) expressly incorporates the procedural aspects of Florida
+Rule of Civil Procedure 1.420(a)(1) governing voluntary dismissal by providing that parties may
+be dropped in the manner provided for voluntary dismissal in rule 1.420(a)(1) subject to the
+exception stated in that rule.** Siboni v. |
+52 So. 3d 779, 780 (Fla. 5th DCA 2010).
+Likewise, because Rule 1.250(b) specifies that a party is dropped "in the manner
+provided for voluntary dismissal in Rule 1.420(a)(I), the Siboni court concluded that "the manner"
+includes the same entitlement to costs and attorney's fees which would have been enjoyed had the
+dismissal occurred entirely under Rule 1.420(a)(1). Id. at 781.
+4
+
+
+18.
+Accordingly, the Siboni court held that a "party dropped from litigation under rule
+1.250(b) is subject to the time limitation contained in rule 1.525 governing service of a motion
+seeking a judgment for costs and attorney's fees." Id.
+19.
+Although Plaintiff filed its Notice the claims asserted by Plaintiff have been, since
+the filing of its initial complaint, completely without support of the facts or the law. At their very
+core, all of Plaintiff's claims are based on the presumption that the State Attorney has the authority
+to disclose the Requested Materials. Nonetheless, Section 905.1 7(1), Florida Statutes makes clear
+that Plaintiff's Requested Materials can only be released by the Clerk pursuant to a court order.
+The stenographic records, notes, and transcriptions made by the court reporter or
+stenographer shall be filed with the clerk who shall keep them in a sealed container
+not subject to public inspection. The notes, records, and transcriptions are
+confidential and exempt from the provisions of s. 119.02(1) and s. 24(a), Art. I of
+the State Constitution and shall be released by the clerk only on request by a grand
+jury for use by the grand jury or on order of the court pursuant to s. 905.27.
+Section 905.17(I), Florida Statutes (2020). ‹
+20.
+The State Attorney has no objection to the Clerk producing and disclosing the
+Requested Materials should the Court grant an order to that effect, however, it is impossible for
+the State Attorney to comply with the relief sought by Plaintiff in its remaining claim for
+declaratory relief as he does not possess or control the Requested Materials and is statutorily barred
+from any disclosure.
+21K
+Although the State Attorney was prepared to make his argument to the Court,
+Plaintiff decided instead to drop him as a party. Despite Plaintiff's decision, the Florida Rules of
+Civil Procedure and the above authorities make clear that because Rule 1.250 specifies that a party
+is dropped "in the manner provided for voluntary dismissal in Rule 1.420(a)(I)," it therefore
+"operates as an adjudication on the merits." See, Siboni v.
+52 So. 3d 779, 781 (Fla. 5th
+DCA 2010); Rule 1.420(a)(1) Fla. R. Civ. P.
+5
+
+
+22.
+Consequently, the filing of Plaintiff's Notice triggered Rule 1.525, Fla. R. Civ. P.
+and therefore:
+Under [§ 57.105], the legislature has expressed its unequivocal intent that where a
+party files a meritless claim, sut or appeal, the party who is wrongtully required to
+expend funds for attorneys' fees is entitled to recoup those fees.
+County Conservation Alliance v. I
+County, 73 So. 3d 856, 857 (Fla. Ist DCA 2011)
+(finding that "Courts are not at liberty to disregard the legislative mandate that courts shall impose
+sanctions in cases without foundation in material fact or law. The word "shall" in § 57.105, Fla.
+Stat., evidences the legislative intent to impose a mandatory penalty to discourage baseless claims,
+by placing a price tag on losing parties who engage in these activities. Section 57.105 expressly
+states courts "shall" assess attorney's fees for bringing, or failing to dismiss, baseless claims or
+defenses.").
+23.
+In fact, "Section 57.105(1) clearly and explicitly confers upon the trial court the
+authority to award attorney's fees to the prevailing party upon the court's initiative, if 'the court
+finds that the losing party ... knew or should have known that a claim or defense when initially
+presented to the court or at any time before trial
+... [wlas not supported by the material facts
+necessary to establish the claim or defense."
+. 47 So. 3d 320, 324 (Fla. 2d DCA
+2010).
+24.
+The simple fact of the matter is that Plaintiff failed to withdraw its Amended
+Complaint against the State Attorney within the 21-day period provided for in section 57.105(4),
+and therefore the State Attorney was permitted to file his 57.105 Motion for Attorneys' Fees as
+sanctions.
+25.
+Furthermore, based on the impossible nature of Plaintiff's demand of the State
+Attorney, it was proper to demand withdrawal of Plaintiff's remaining claim for declaratory relief
+6
+
+
+and serve the 57.105 Motion for Attorneys' Fees due to Plaintiff's claim lacking any basis in fact
+or law. Again, neither the State Attorney nor his office has possession, custody or control of the
+Requested Materials. Likewise, the State Attorney has no objection, and never has had any
+objection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the Requested
+Materials sought by Plaintiff lies solely within the providence of the Clerk pursuant to an order of
+the Court.
+26.
+Consequently, the State Attorney is entitled to recover all of his reasonable
+attorneys' fees in defending this suit by virtue of 57.105, Florida Statutes.
+REASONABLENESS AND AMOUNT OF ATTORNEYS' FEES
+27. From the service of the 57.105 Demand to the date of this motion, the attorneys for
+the State Attorney have rendered 42.2 hours of legal services for a total amount of $18,275.00 in
+defending this action. See time sheets detailing: the amount of hours by each timekeeper, the
+timekeeper's hourly rate, and a description of the tasks done during those times, on attached
+Exhibit "E". Of that amount, the undersigned has been paid $0.00 as the engagement with the
+State Attorney is on a pure contingency fee basis. The undersigned expects to incur an additional
+4.0 hours at $425.00 an hour in preparing for and attending the hearing on attorneys' fees. Thus,
+the total amount of hourly attorneys" fees the State Attorney is seeking is 46.2 hours for a total of
+$19,975.00.
+As further set forth below, the State Attorney also seeks a multiplier of 2.0, which
+when applied makes the grand total attorneys' fees as sanctions sought herein $39,950.00.
+An Affidavit of Attorneys' Fees is attached hereto as Exhibit "F", which details
+and breaks down the attorneys' fees sought herein.
+7
+
+
+29.
+The State Attorney would offer the following facts and arguments as they relate to
+the factors promulgated in Rule 4-1.5 of the Rules Regulating the Florida Bar and Florida Patient's
+Compensation Fund v.
+, 472 So. 2d 1145 (Fla. 1985):
+Factor
+(A) the time and labor
+omplexity, and difficult
+f the questions involved
+and the skill requisite to
+perform the legal service
+properly
+(B) the likelihood that the
+acceptance of the
+particular employment
+will preclude other
+employment by the lawyer
+the litigation, due to time required in the instant matter.
+(C) the fee, or rate of fee,
+The base fees consisting of $425.00/hour for Mr. Wyler's services
+customarily charged in the
+and $475.00/hour for Mr.
+services are reasonable for
+locality for legal services
+lawyers in their respective communities possessing equal
+of a comparable or similar
+nature
+experience and skill.
+(D) the significance of, or
+amount involved in, the
+subject matter of the
+representation, and the
+results obtained
+(E) the time limitations
+imposed by the client or
+by the circumstances and,
+as between attorney and
+The outcome of' this case is of great public significance to the State
+of Florida as it pertains to the disclosure of grand jury records and
+the role of the State Attorney concerning such disclosure. Here,
+the results obtained were the maximum sought by Defendant
+Aronberg as he was dismissed from the case, albeit not within the
+time constraints of the safe-harbor provision within § 57.105, Fla.
+Stat.
+There were not any extraordinary limitations imposed by the client,
+however, Defendant Aronberg expected and received zealous
+repres fittion, with the desire that the case be dispensed of quickly
+(F) the nature and length
+As general counsel for the FPAA the undersigned counsel has
+of the professional
+represented Defendant Aronberg since the beginning of his tenure
+relationship with the client
+as State Attorney in civil matters throughout the State of Florida as
+well as matters before the Florida Legislature.
+8
+
+
+(G) the experience,
+reputation, diligence, and
+ability of the lawyer or
+lawyers performing the
+service and the skill,
+expertise, or efficiency of
+effort reflected in the
+This representation required experience in a field available to few
+lawyers, which included defending the State Attorney from claims
+of a media entity and lawyers from multiple states regarding the
+release of information with a nationwide interest. Accordingly, the
+undersigned counsel conducted the representation with skill and
+efficiency wherein Defendant Aronberg was dismissed from the
+action prior to any hearing on the merits before the court.
+actual providing of such
+services
+(H) whether the fee is
+The fee arrangement herein was entirely contingent, wherein
+fixed or contingent, and, if
+obtaining a fee was conditioned upon prevailing and obtaining an
+fixed as to the amount or
+order awarding fees.
+rate, then whether the
+client's ability to pay
+ested to any significan
+legree on the outcome of
+the representation.
+JUSTIFICATION FOR MULTIPLIER
+30.
+Defendant Aronberg was able to proceed with this litigation only if counsel would
+receive a court order awarding contingency based attorneys' fees upon achievement of a successful
+outcome in this case. See, Exhibit "G". Given this and the fact that counsel risked a total of 74.8
+hours of work for no pay, of which 39.4 hours is subject to the 57.105 Demand, Defendant
+Aronberg submits that multiplier of 2.0 would be appropriate in this case. Based upon the hours
+expended, the hourly rates and a 2.0 multiplier, Defendant Aronberg respectfully requests an award
+of attorneys' fees as sanctions as stated herein.
+31.
+With regard to the application of a multiplier, the court must analyze the three
+factors set forth in Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828 (Fla. 1990):
+(1) whether the relevant market requires a contingency fee multiplier to obtain
+competent counsel; (2) whether the attorney was able to mitigate the risk of
+nonpayment in any way; and (3) whether any of the factors set forth in
+_ are
+applicable, especially the amount involved, the results obtained, and the type of fee
+arrangement between the attorney and his client.
+See, Citizens Prop. Ins. Corp. v. Pulloquinga, 183 So. 3d 1134 (Fla. 3d DCA 2015).
+9
+
+
+32.
+Here, as to the first factor there was no other counsel in the relevant market who
+would agree to represent Defendant Aronberg under the contingency fee agreement needed due to
+the financial situation of the Office of the State Attorney as a public entity funded entirely by the
+taxpayers of the State of Florida. Although "Risk Mitigation" within the Florida Department of
+Financial Services and the Office of the Attorney General indeed represent the State Attorney in
+some instances, this case was not picked up by either and Defendant Aronberg was left needing
+representation by other, private counsel. Although the undersigned counsel and his law firm are
+General Counsel for the Florida Prosecuting Attorneys' Association, Inc., "FPAA") the instant
+matter did not fall within the scope of representation for the FPAA and required a separate
+engagement between Defendant Aronberg and the undersigned counsel. Accordingly, the
+undersigned counsel and his law firm agreed to represent Defendant Aronberg on a contingency
+fee basis and to try the case to final judgment considering that there was no other counsel willing
+to represent Defendant Aronberg on such terms.
+With respect to the other factors to be considered in applying a multiplier as set
+forth in Quanstrom, here Defendant Aronberg was unable to mitigate against non-payment of fees
+because as a purely taxpayer funded entity, the Office of State Attorney had no other means by
+which to pay the undersigned counsel. Additionally, Defendant Aronberg meets each of the
+individual Rowe factors as set forth in the table located above on pages 8-9. Accordingly, based
+on the foregoing the application of a multiplier herein is proper. In this vein, the
+court set
+guidelines for the size of a multiplier, as follows:
+Based on our review of the decisions of other jurisdictions and commentaries on
+the subject, we conclude that in contingent fee cases, the lodestar figure calculated
+by the court is entitled to enhancement by an appropriate contingency risk
+multiplier in the range from 1.5 to 3. When the trial court determines that success
+was more likely than not at the outset, the multiplier should be 1.5; when the
+likelihood of success was approximately even at the outset, the multiplier should
+10
+
+
+be 2; and, when success was unlikely at the time the case was initiated, the
+multiplier should be in the range of 2.5 to 3.
+Florida Patient's Compensation Fund v.
+, 472 So. 2d 1145 (Fla. 1985).
+34.
+Additionally, the Quanstrom court confirmed and modified the
+approach, as
+follows:
+However, we find that the multiplier in
+should be modified as follows: If the
+trial court determines that success was more likely than not at the outset, it may
+apply a multiplier of 1 to 1.5; if the trial court determines that the likelihood of
+uccess was approximately even at the outset, the trial judge may apply a multiplie
+f 1.5 to 2.0; and if the trial court determines that success was unlikely at the outse
+of the case, it may apply a multiplier of 2.0 to 2.5. Accordingly, our Rowe decision
+is modified to allow a multiplier from 1 to 2.5.
+Standard Guaranty Insurance Co. v. Quanstrom, 555 So. 2d 828, 834 (Fla. 1990). Thus, based
+upon all of the foregoing factors, Defendant Aronberg respectfully submits that a multiplier of 2.0
+is appropriate for this representation.
+CERTIFICATION OF GOOD FAITH EFFORT TO RESOLVE
+The undersigned certifies that a good faith effort was made to resolve the issues raised in
+this motion by agreement of the parties. The parties were unable to resolve by agreement the
+issues of entitlement to fees or the amount of fees.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, prays that this Honorable Court will enter an Order awarding Defendant Aronberg
+his reasonable attorneys' fees with a multiplier of 2.0 against the Plaintiff, CA FLORIDA
+HOLDINGS, LLC, publisher of the PALM BEACH POST, in the amount of $39,950.00.
+I HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing
+Defendant, Dave Aronberg's Amended Motion for Attorneys' Fees has been electronically filed
+with the Florida E-File Portal for e-service on all parties of record herein.
+
+
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur i|
+1 Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-J
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlawi@comcast.net
+Attorneys for Defendant,
+NOT A CERTIFIED CO
+Dave
+Aronberg
+12
+
+
+
+
+
+
+Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time
+Subject:
+SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V.
+DAVE ARONBERG ET AL.
+Date:
+From:
+To:
+Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time
+Douglas Wyler
+'mendelsohns@gtlaw.com', smithl@gtlaw.com, flservice@gtlaw.com, BoyajianN@gtlaw.com,
+riveraal@gtlaw.com, GRYGIELM@gtlaw.com
+Attachments: 2020-06-08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf
+Please see attached and below in this matter.
+Court:
+Case No:
+Plaintiff:
+Defendant:
+Title of Documents
+Served:
+Sender's Name and
+Telephone Number:
+Circuit Court of the Fifteenth Judicial Circuit, in and for Palm Beach County,
+Florida
+Case No. 2020-CA-014681
+CA Florida Holdings, LLC
+Dave Aronberg
+• Fla. Stat. § 57.105 Demand Letter
+• Defendant, Dave Aronberg's Motion for Attorneys' Fees
+Douglas Wyler
+(904) 261-3693
+Sincerely,
+Doug Wyler, Esq.
+1. Scholz & Wyler, LLC
+961687 Gateway Blvd., STE 201-1
+Fernandina Beach, FL 32034
+904-261-3693
+904-261-7879 (fax)
+doug.wyler@comcast.net
+Please be advised that this e-mail and any files transmitted with it are confidential attorney-client
+communication or may otherwise bé privileged or confidential and are intended solely for the individual or
+entity to whom they are addressed. If you are not the intended recipient, please do not read, copy or
+retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or
+copying of this communication is strictly prohibited.
+
+
+
+HE LAW OFFICES C
+« ASSOCIATES, PA
+ARTHUR 1
+SCHOLZ & WYLER, LLC.
+A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+9EI887 GATEWAY BLVD. SUITE 201-1
+FERNANDINA BEACH, FLORIDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 261.7879
+RICHARD J. SCHOLZ, P.A.
+RICHARD J, SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A. WYLER
+June 8, 2020
+VIA ELECTRONIC & U.S. MAIL
+Stephen A. Mendelsohn, Esq.
+Greenburg Traurig, P.A.
+5100 Town Center Circle, Suite 400
+Boca Raton, FL. 33486
+COPY
+RE: CA Florida Holdings, LL.C v. Dave Aronberg et al.
+Palm Beach County, Case No.: 2019-CA-014681
+Dear Mr. Mendelsohn:
+As you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach
+County, Florida, in the above referenced ter. The purpose of this letter is to demand the voluntary
+dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand
+is made pursuant to section 57.105, Florida Statutés.
+As you know, Section 57.105 provides:
+reasonable attorney's fee, including prejudgment interest, to be paid to the
+prevailing party in equal amounts by the losing party and the losing party's attorney
+on any claim or defense at any time during a civil proceeding or action in which
+the court finds that the losing party or the losing party's attorney knew or should
+have known that a claim or defense when initially presented to the court or at any
+time before trial:
+a. Was not supported by the material facts necessary to establish the claim or
+detense; or
+b. Would not be supported by the application of then-existing law to those
+material facts.
+Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count Il of the
+Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action
+consists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein
+and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to
+establish the claims asserted, and that your claims are not supported by the application of current law
+
+
+First and foremost, the Complaint is not supported by the material facts necessary to establish the
+claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the
+Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.
+Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are
+impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to
+this action because no matter what, he and his office do not have possession, custody, or control of the
+requested materials.
+In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims
+are also not supported by the application of current law. Specifically, your action for declaratory relief
+fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes,
+which states:
+When such disclosure is ordered by a court pursuant to subsection (J) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorneys and by the latter
+to their legal associates and employees. However, the grand jury testimony afforded
+such persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable
+to comply with any court order granting disclosure of the requested documents because neither Mr.
+Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession,
+custody, or control of the 2006 Epstein grand jury records.
+Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter,
+the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client
+and your firm, recovery of the legal expenses incurred in defending this frivolous action.
+Please govern yourself accordingly
+Douglas A. Wyler, Esq.
+Encl.: Defendant's Motion for Attorneys' Fees
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+I hereby certify that on this
+_day
+, 2020, the foregoing was electronically filed
+via the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Ärthur I. L
+Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+NOTACE
+jacobsscholzlaw@comcast.net
+
+
+
+
+
+
+GT GreenbergTraurig
+Stephen A. Mendelsohn
+Tel 561.955.7629
+Fax 561.659.9119
+mendelschns@gtlaw.com
+Douglas A. Wyler
+Jacob Scholz & Wyler, LLC
+961687 Gateway Blvd.
+Suite 201-1
+Fernandina Beach, Fl. 32034
+Re:
+CA Florida Holdings, LLC v. Dave Aronberg et al.
+Case No. 2019-CA-014681
+COPY
+Dear Mr. Wyler:
+We are in receipt of your letter of June 8, 2020 with your proposed Fla. Stat. section 57.105 motion.
+In your letter and your proposed motion, you assert that CA Florida Holdings, LIC and the law
+firm of Greenberg Traurig, P.A. should be liable for the attorneys' fees to be incurred by State
+Attorney Aronberg after the date of your letter, Your letter cites to Fla. Stat. sections 57.105(1)
+(a) and (b) for support. As shown below, there is no basis for a Fla. Stat. section 57.105 motion,
+and we expect that if the State Attorney were to make such a motion, the court should deny it.
+Your letter omits a citation to section 57, 105(3). Subsection 57.105(3)(a) provides that sanctions
+may not be awarded where there is a "good faith argument for the extension, modification or
+reversal of existing law or the establishment of new law, as it is applied to the matenal facts, with
+a reasonable expectation of success." We have such a good faith argument.
+Contrary to your analysis of Fla. Stat. section 905.27, there are actually three instances where a
+court may order the release of grand jury materials. As we argue, the court may order release "in
+futherance of justice." There are few cases in Florida reviewing this provision and its scope. It is
+an open and valid question as to whether the court may order release of grand jury transcripts to
+the media, under both the statute and the First Amendment to the US Constitution in furtherance
+of justice. The statutory language you cite refers to instances where a person is seeking grand jury
+materials for use in a civil or in a criminal case. In these limited situations, the statute allows for
+such uses and for no other reason. However, the statute does not state, as you assert, that where
+the media seeks grand jury materials based upon its constitutional standing, which the Circuit
+Court acknowledged at the June 2, 2020 hearing includes The Palm Beach Post, that the statutory
+5100 Town Center Circle | Suite 400 | Boca Raton, Florida 33486 | T +1 561.955.7600 | F +1 561.338.7099
+Albany, Amsterdam. Atlanta. Austin. Berlin' Boca Raton. Boston. Chicago. Dallas. Delaware, Denver. Fort Lauderdale. Houston. Las Vegas, London' Los Angeles.
+Mexico City" Miami. Milan: Minneapolis. Nashville. New Jersey, New Tork, Northern Virginia. Orange County, Orlando. Philadelphia. Phoenix. Sacramento.
+San Francisco, Seoul. Shanghai. Silicon Valley. Tallahassee. Tampa. Tel Aviv: Tokyo: Warsaw. Washington, D.C. West Palm Beach. Westchester County: (
+
+
+Page 2
+use limitation you cite applies. No reported Florida case has addressed this issue and there is a
+good faith basis for our view of Fla. Stat. section 905.27
+Your letter also argues that sanctions are applicable because the State Attorney has alleged that it
+does not possess the Jeffiey Epstein grand jury transcripts. This allegation is also contained in the
+State Attorney's Answer. Assuming that the State Attorney does not currently have physical
+possession of the Epstein grand jury materials, which has yet to be demonstrated, this does not end
+the matter. The State Attorney was named as a party not simply as a custodian of grand jury
+records. The State Attorney was named in his official capacity as his office has as its primary
+interest the protection of its grand jury system." [Italics in original.] In re Grand Jury Proceedings.
+832 F. 3d 554, 559 (11" Circuit 1987). In that case, the US petitioned a state judge to order the
+State Attorney to turn over grand jury transcripts. The State Attorney argued against their release
+citing to Fla. Stat. section 905.27. Later, a federal grand jury subpoenaed the Broward County
+State Attorney for delivery of state grand jury testimony. The Broward State Attorney advised the
+federal court that it would produce the transcripts, thereby demonstrating that while it may not
+have physical possession of the materials, he had legal authority fo obtain and deliver them. It
+should also be noted that the State Attorney moved to quash the subpoena arguing that it was
+unlawful under Florida law and Fla. Stat. section 905.27. This case indicates that where one seeks
+grand jury materials, the relevant State Attorney is a necessary party in order to protect the grand
+jury that the Office of State Attorney supervised and to make arguments, if need be, against release
+of the grand jury materials. These are some of the same reasons why the State Attorney was named
+in this case.
+Also, assuming the State Attorney does not have physical possession of the grand jury materials,
+there is nothing in Florida law that prohibits the State Attorney from requesting that the Clerk
+provide copies to the State Attorney. Chapter 905, Fla. Stats. does not contain a prohibition against
+a State Attorney demand that the Clerk grant his office access to grand jury materials, even after a
+criminal case has concluded. Upon information and belief, the Clerk's office maintains a log that
+tracks release of grand jury materials to the State Attorney upon its request. Please confirm
+whether the State Attorney has accessed grand jury materials from the Clerk's office in other
+instances or that it has never done so. If the Clerk has such a log, then its contents should be
+discoverable, or subject to Florida Public records laws.
+
+
+Page 3
+For these reasons, we decline your Fla. Stat. section 57.105 demand that the case be dismissed
+against the Office of the State Attorney. We expect that your demand will be withdrawn.
+Thank you,
+Very truly yours,
+/s/Stephen Mendelsohn
+Stephen Mendelsohn
+SAM:Is
+ACTIVE
+
+
+
+
+
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida; SHARON F
+OCK. as Clerk and Comptroller of Palr
+Beach County, Florida.
+Defendants.
+COPY
+CASE NO.: 19-CA-014681
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+I hereby certify that on this Ist day July, 2020, the foregoing was electronically filed via
+the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I.
+1. Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 002126Y
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+NOT A CERTAIN
+
+
+
+
+
+
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+COPY
+Defendants.
+PLAINTIFF CA HOLDINGS, LLC'S
+NOTICE OF DROPPING STATE ATTORNEY, DAVE ARONBERG
+Plaintiff, CA HOLDINGS, LL.C, pursuant to Fla. R. Cix. P. /250(b), hereby notifies the parties that
+it has dropped State Attorney, Dave Aronberg from the above case.
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Autore pator eAtinda Holdings, LLC. Publisher
+Stephen A. Mendelsohn, Esq.
+401 East Las Olas Boulevard Suite 2000
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+Florida Bar No. 849324
+FL.Service@gtlaw.com
+
+
+By: Is/ Michael J Grygiel
+MICHAELJ GRYGIEL
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Boyajian
+NINA D. BOYAJIAN
+1840 Century Park East, Suite 1900
+Los Angeles California 90067
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+bovaiiann/@stlaw.com
+v.com
+I HEREBY CERTIFY that on this 21" day of October, 2020, a true and correct copy of the
+foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which
+will send a notice of electronic service for all parties of record herein
+ACTIVE
+53317341v1
+/s/ Stephen A. Mendelsohn
+2
+
+
+
+
+
+
+: Scholz & Wyler, LLC
+961687 Gateway Blvd., Suite 2011
+Fernandina Beach, FL 32034
+United States
+904-261-3693
+Scholz & Wyler, LLC
+Dave Aronberg
+Balance
+Invoice#
+Invoice Date
+Payment Terms
+Due Date
+00307
+November 6, 2020
+Aronberg (SAO15) adv. CA Florida Holdings, LLC
+Time Entries
+Date
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+11/26/2019
+12/02/2019
+12/02/2019
+12/02/2019
+12/02/2019
+12/02/2019
+12/03/2019
+12/03/2019
+EE
+DW
+DW
+DW
+DW
+DW
+AIJ
+AIJ
+DW
+AIJ
+DW
+DW
+DW
+AIJ
+AIJ
+AIJ
+DW
+DW
+DW
+Activity
+Review
+Review
+Teleconference
+Draft
+Review
+Review
+Meeting
+Meeting
+Teleconference
+Research &
+Preparation
+Draft
+Teleconference
+Review
+Teleconference
+Meeting
+Meeting
+Draft
+Description
+Initial review of summons and complaint.
+Reviewed motion for pro hac vice and Judge
+Hafele' order granting
+Teleconference w/ Client, re: response to lawsuit
+Drafted engagement letter and sent to client
+Reviewed 15th circuit local rules
+Initial review of complaint
+Meeting w/ DAW to discuss lawsuit and strategy
+Meeting w/ AlJ to discuss lawsuit and strategy
+Teleconference w/ Client, re: response to lawsuit
+Research and prep for Motion to dismiss
+1st Draft motion to dismiss
+Teleconference w/ Client, re: draft motion to
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+Reviewed 1st Draft MTDismiss
+Teleconference w/ client, re: draft motion to
+dismiss
+Meeting w/ DAW, re: motion to dismiss
+Meeting w/ AlJ, re: MTDismiss
+Completed final draft of motion to dismiss; filed with
+Court
+Teleconference
+Spoke w/ client, re: final draft of motion to dismiss
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+$425.00
+$425.00
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+0.5
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+1.0
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+0.5
+2.0
+1.0
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+$425.00
+$475.00
+$237.50
+$237.50
+$850.00
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+$142.50
+$237.50
+$297.50
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+01/16/2020
+01/16/2020
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+01/17/2020
+01/17/2020
+01/20/2020
+01/21/2020
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+Review
+Review
+Review
+Review
+Teleconference
+Meeting
+Meeting
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+Research & Draft
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+Draft
+Review
+Review
+Review
+Teleconference
+Review
+Review
+Teleconference
+Review
+E-mail
+E-mail
+Review
+Spoke with Clerk's attomey, re: response
+Reviewed final draft MTDismiss
+Reviewed Clerk's MTDismiss
+Reviewed Clerk's Motion to Dismiss
+Reviewed Order Setting Hearing on Defendants'
+MTDismiss
+Reviewed motion for pro hac vice
+Reviewed PI's Amended Complaint
+Spoke with client, re: Amended Complaint
+Reviewed PI's notice of filing
+Reviewed PI's Am. Compl
+Reviewed Judge Marx's Order Cancelling
+MTDismiss Hearing
+Reviewed Pl's Objection to Defendants' MTDismiss
+Spoke with client, re: Amended complaint
+Meeting w/ DAW, re: response 1o Am. Compl.
+Meeting w/ Ald, re: response to Am. Compl.
+Reviewed Order granting pro hac vice admission
+Researched and drafted response. to Amended
+Complaint
+Spoke with Clerk's altomey, re; response to
+amended complaint
+Completed Answer/MTDismiss Amended
+Complaint; filed with Court; sent copy to Client
+Drafted and filed Notice of Unavailability
+Reviewed final Answer/MTDismiss
+Reviewed Clerk's Answer/MTDismiss
+Reviewed Order setting hearing on Defs'
+MTDismiss
+Spoke w/ client, re: order setting MTDismiss
+hearing for March 24, 2020
+Reviewed Pl's Opposition to Aronberg MTDismiss
+& Clerk's MTDismiss
+Reviewed Pl's Opposition to Aronberg MTDismiss
+& Clerk's MTDismiss
+Reviewed email from Pt's counsel, re: motion to
+continue hearing
+Reviewed Pl's unopposed motion for continuance
+Emails w/ Clerk's counsel, re: Pl's request to
+continue hearing
+Reviewed email from Pl, re: agreed order &
+responded
+Reviewed Court's agreed order continuing hearing
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+05/28/2020
+05/29/2020
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+06/02/2020
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+06/08/2020
+06/08/2020
+06/08/2020
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+06/10/2020
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+DW
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+DW
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+DW
+DW
+DW
+DW
+DW
+DW
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+AIJ
+DW
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+Review
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+Teleconference
+E-mail
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+E-mail
+E-mail
+Altend Hearing
+Review
+Review
+Various
+Various
+Meeting
+Meeting
+Review
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+Various
+Reviewed order rescheduling hearing on Defs'
+MTDismiss
+Spoke w/ client, re: order rescheduling MTDismiss
+hearing for June 3, 2020
+Reviewed Order rescheduling MTDismiss hearing
+Reviewed order setting Zoom hearing, re:
+MTDismiss
+Spoke w/ client, re: hearing will be via Zoom
+Reviewed Clerk's filing: change of atty of record
+Spoke with Clerk's new counsel, Nicole Fingerhut
+Reviewed Pl's email, re: cases and authorities for
+MDismiss hearing; responded
+Began oral argument prep for 6/8 MTDismiss
+hearing
+Reviewed email from Judge Marx's JA and
+responded
+Reviewed PI's 500+ page binder, re: MTDismiss &
+prepped for hearing
+Drafted and sent email to client, re: MTD hearing
+Prepped for and attended MTDismiss hearing via
+Spoke w/ Client, re: debrief MTDismiss hearing
+Emailed courtesy copies of Aronberg's Answer and
+MTDismiss to Judge Marx
+Reviewed response from Client and replied
+Attended MTDismiss hearing via Zoom
+Reviewed order granting MTDismiss w/ prejudice
+Reviewed Court's Order Granting Defendants
+MTDismiss Count II w/ Prejudice
+Shared order w/ Client and spoke wi, re: result and
+plan going forward, re: 57.105
+Researched § 57.105 Fla. Stat.; drafted 57.105
+demand letter and proposed motion for attorneys'
+fees/sanctions; Served Pr's counsel with demand
+letter and proposed motion.
+Meeting w/ DAW, re: Order & 57.105
+Meeting w/ All, re: Order & 57.105
+Reviewed 57.105 demand and proposed motion for
+sanction
+Reviewed notice of change of attorney, re: Clerk:
+called and spoke w/ new counsel Cynthia Guerra
+Reviewed Pl's letter refusing to voluntarily dismiss
+amended complaint despite 57.105 demand; called
+and spoke w/ client, re: Pl's refusal & next steps
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+07/02/2020
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+07/10/2020
+07/10/2020
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+DW
+DW
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+DW
+DW
+DW
+DW
+DW
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+DW
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+DW
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+Teleconference
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+Review
+Teleconference
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+Draft
+Research &
+Preparation
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+Draft
+Draft
+Review
+E-mail
+Meeting
+Various
+Draft
+Teleconference
+Various
+Review
+Teleconference
+Sent client copy of Pl's letter refusing to dismiss
+complaint
+Romewed P's letter refusing to dismiss Count VAm.
+Spoke w/ client, re: tiling of 57.105 motion for
+fees/sanctions; filed motion for attorneys' fees
+based on Pl's failure to voluntarily dismiss
+amended complaint count 1
+Email to client, re: affidavit and summary judgment
+Discussed w/ Client drafting and filing Motion for
+Summary Judgment and MSJ evidence
+Discussed w/ Client drafting and filing Motion for
+Summary Judgment and MSJ evidence
+Created Ist draft of Aronberg Affidavit; shared w/
+client
+Reviewed draft affidavit and discussed w/DAW
+Discussed draft affidavit w/ AIJ
+Reviewed PI's Request to Produce, re: Clerk
+Spoke w/ Clerk's counsel, re: Request to Produce
+Reviewed PI's Amended Request to Produce, re:
+Spoke w/ Clerk's counsel, re: Amended Request to
+Produce
+Revised Aronberg affidavit
+Finalized Aronberg Affidavit and sent to client
+Research and prep for Motion for Summary
+Judgment
+Received executed Aronberg Affidavit
+Began drafting Motion for Summary Judgment
+Continued drafting Motion for Summary Judgment
+Reviewed email from Plaintiff attempting to set
+hearing on 57.105 motion for fees/sanctions
+Sent responsive email to Pl's counsel
+Discussed drait MSJ w/ Ald
+Reviewed draft MSJ and met w/ DAW to discuss
+Finalized Motion for Summary Judgment; filed w/
+court along with Aronberg affidavit
+Spoke w/ Clerk's counsel, re: request to produce
+Reviewed Pl's email and accepted conference call
+invite for 9/2/20
+Reviewed Clerk's response to request for
+production
+Spoke w/ Pl's counsel, re: dispute as to whether
+MSJ should be heard before 57.105 fee motion or
+vis versa - call was unsuccessful
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+10/14/2020
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+DW
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+DW
+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+DW
+DW
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+Meeting
+E-mail
+Meeting
+Meeting
+Various
+E-mail
+E-mail
+E-mail
+E-mail
+Various
+Review
+Review
+Review
+Review
+Research
+Research &
+Analyze
+Draft
+Meeting
+Various
+Draft
+Telephone
+Telephone
+Attend Hearing
+Various
+Discussed w/ DAW phone call w/ Pl's counsel
+Discussed w/ All phone call w/ Pl's counsel
+Reviewed email from Pl's counsel requested
+Aronberg to withdraw sanctions motion w/o
+prejudice
+Discussed w/ Ald filing motion for CMC
+Discussed w/ DAW filing motion for CMC
+rafted and filed motion to set case managemer
+onference; re: MSJ 1st or Fee hearing 1s
+Responded to PI's 9/16/20 email and refused to
+withdraw 57.105 motion; provided copy of motion to
+set CMC and available dates for hearing
+Reviewed Pl's email insisting that 57.105 motion be
+withdrawn
+Replied to PI's counsel that the 57.105 motion for
+sanctions will not be withdrawn and asking for
+response, re: CMC
+Sent client copy of email exchange w/ PI's counsel;
+called and spoke w/ Client
+Drafted and filed Notice of Hearing on 10/15/20; set
+up Court Call; spoke w/ client, re: hearing date
+Reviewed PI's Memo of Law opposing Aronberg's
+57.105 motion for fees/sanctions,
+Reviewed Pl's Response to Aronberg's request to
+schedule 57.105 motion for fees after MSJ
+Reviewed PI's Memo of Law opposing 57.105
+motion
+Reviewed Pl's Response to Aronberg's request to
+schedule 57.105 motion after MSJ
+Research caselaw & statutes, re: response to PI's
+Memo of Law
+Continued researching caselaw, re: response to
+Pl's memo of law
+Created 1st draft of Response to Pl's Memo of Law
+and shared w/ Client
+Miscussed wi Al caselaw and drait response 1o
+Casieved drat MS, discussed ralt w DAW and
+Finalized and filed Response to Pl's Memo of Law
+Spoke w/ client, re: memo of law
+Spoke w/ client again, re: response to memo of law
+Attended hearing, re: Motion to Set CMC; called
+client to discuss
+Reviewed email and letter from Pl, re: settlement.
+Sent copy to Client and called to discuss.
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+
+
+10/16/2020
+10/16/2020
+10/16/2020
+10/16/2020
+10/16/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/21/2020
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+10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/22/2020
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+DW
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+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+AlJ
+DW
+DW
+Telephone
+Telephone
+Various
+Various
+Meeting
+Various
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+Telephone
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+Review
+Telephone
+Telephone
+Telephone
+Telephone
+Telephone
+E-mail
+Meeting
+Meeting
+Various
+Spoke w/ Pl's counsel, re: settlement
+Spoke w/ client, re: Pl's settlement proposal
+Attended hearing, re: motion to set CMC;
+discussed w/ client
+Discussed Pl's settlement proposal w/ DAW and
+then w/ Client
+Discussed Pl's settlement proposal w/ Al
+Drafted and shared proposed order w/ Pl's counsel
+Spoke w/ Pl's counsel, re: settlement
+Spoke w/ client, re: PI's settlement proposal
+Discussed Pl's settlement proposal w/ Al
+Discussed PI's settlement proposal w/ DAW
+Uploaded proposed order, re: CMC for Judge
+Hafele
+Spoke w/ client, re: PI's settlement proposal
+Spoke w/ Pl's counsel, re: settlement
+Discussed Pl's settlement proposal w/ DAW
+Discussed PI's settlement proposal wAlJ
+Reviewed email from Pl, re: settlement; sent copy
+to Client and called to discuss
+Spoke w/ client, re: settlement
+Spoke w/ PI's counsel, re: settlement
+Spoke w/ client, re: settlement
+Discussed Pr's settlement proposal w/ AL
+Discussed Pls settlement proposal w/ DAW
+Drafted and filed Motion to Set Hearing on
+Aronberg MS; drafted proposed order granting
+motion to set; checked court availability; emailed
+Pl's counsel, re: choose date for hearing
+Reviewed Order, re: CMC unnecessary
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Sent email w/ Aronberg statement to media
+Discussed media response w/ DAW
+Discussed media response w/ Al
+Reviewed Pl's Notice of Dropping Aronberg as
+party; spoke w/ Client and ALl, re: notice and next
+steps
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+$190.00
+$170.00
+$425.00
+$142.50
+
+
+10/22/2020
+AIJ
+Various
+Reviewed Pl's Notice of Dropping Aronberg as
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+steps
+$475.00
+0.5
+Totals:
+74.8
+Time Entry Sub-Total:
+Sub-Total:
+Total:
+Amount Paid:
+Balance Due:
+$237.50
+$0.00
+
+
+
+
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+BICk, as erk any Compriser of Pain.
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+AFFIDAVIT OF ATTORNEYS' FEES
+STATE OF FLORIDA
+COUNTY OF NASSAU
+BEFORE ME, the undersigned authority appeared Douglas A. Wyler, Esq., who, after
+being first duly sworn, deposes and says:
+Affiant is a partner of JACOBS, SCHOLZ & WYLER, LLC, counsel for
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, ("Aronberg").
+as well as general counsel to the Florida Prosecuting Attorneys Association, ("FPAA"), and makes
+this Affidavit of his own personal knowledge.
+2.
+Affiant is licensed to practice law in the State of Florida, is an active member of
+the Florida Barín good standing and has engaged in the practice of law in the State of Florida since
+2015.
+3.
+As detailed herein, the services rendered by Affiant and his firm pertain to Affiant's
+demand letter and motion for attorneys' fees sent to Plaintiff's counsel pursuant to § 57.105,
+Florida Statutes, on June 8, 2020, in defending against Count I of Plaintiff's Amended Complaint
+
+
+and Plaintiff's October 21, 2020 Notice of Dropping State Attorney, Dave Aronberg from the
+above-captioned lawsuit. See, Exhibits "A" and "B" attached hereto.
+4.
+The total time Affiant's law firm has expended services rendered to date is 74.8
+hours, however, from the date of Defendant Aronberg's 57.105 demand, Affiant's law firm has
+expended a total of 42.2 hours. Of the 42.2 hours expended since Defendant Aronberg's 57.105
+demand was served, the Affiant
+5. Of the 42.2 hours expended since Defendant Aronberg's 57,105 demand was
+served, the total time Affiant has expended services rendered to date is 35.4 hours at the rate of
+$425.00 per hour. Likewise, the total time Affiant's law partner, Arthur l.
+services rendered to date is 6.8 hours at the rate of $475.00 per hour.
+, has expended
+Accordingly, since Defendant Aronberg's 57.105 demand was served, Defendant
+, SCHOLZ & WYLER, LLC, has rendered services in the amount
+Aronberg's counsel,
+of $18,275.00, in conjunetion with the defense of the instant action pursuant to § 57.105, Florida
+Statutes. See, Exhibit "C" attached hereto.
+Affiant expects to incur an additional 4.0 hours at $425.00 an hour in preparing for
+and attending the hearing on attorneys' fees. Thus, the total amount of hourly attorneys' fees the
+State Attorney is seeking is 46.2 hours for a total of $19,975.00. Additionally, the State Attorney
+seeks a multiplier of 2.0, which when applied makes the grand total attorneys' fees sought herein
+$39,950.00.
+Dated this 9th day of November, 2020.
+FURTHER AFFIANT SAYETH NOT.
+Dat
+-ALL
+Douglas A Wyler, Esq.. Fla. Bar No. 119979
+
+
+STATE OF FLORIDA
+COUNTY OF NASSAU
+The foregoing instrument was acknowledged before me this 9th day of November, 2020,
+by Douglas
+• Wyler, Esquire, who is personally known to me and who did take an oath.
+TARAN R
+Notary Public - State of Florida
+Commission # GG 3548*1
+My Comm. Expires Aug 17, 2023
+Bonded through Nationa! Notary Assn.
+Taran R.
+. Jackson
+Name typed, printed or stamped
+I HEREBY CERTIFY that on this 9th day of November, 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+JACOBS SCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Arthur I.
+6, Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz. Esq.
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.net
+Altorneys for Defendant, Dave Aronberg
+
+
+
+
+
+
+Friday, September 18, 2020 at 11:09:24 Eastern Daylight Time
+Subject:
+SERVICE OF COURT DOCUMENT; CASE NO. 2019-CA-014681; CA FLORIDA HOLDINGS, LLC V.
+DAVE ARONBERG ET AL.
+Date:
+From:
+To:
+Monday, June 8, 2020 at 3:58:58 PM Eastern Daylight Time
+Douglas Wyler
+'mendelsohns@gtlaw.com', smithl@gtlaw.com, fservice@gtlaw.com, BoyajianN@gtlaw.com,
+riveraal@gtlaw.com, GRYGIELM@gtlaw.com
+Attachments: 2020-06-08 Aronberg 57.105 Demand and Motion for Attorneys' Fees.pdf
+Court:
+Case No:
+Plaintiff:
+Defendant:
+Title of Documents
+Served:
+Sender's Name and
+Telephone Number:
+Sincerely,
+Doug Wyler, Esq.
+• Scholz & Wyler, LLC
+961687 Gateway Blvd., STE 201-1
+Fernandina Beach, FL 32034
+904-261-3693
+904-261-7879 (fax)
+Circuit Court of the Fifteenth Judicial Circuit, in and for Palm Beach County,
+Florida
+Case No. 2020-CA-014681
+CA Florida Holdings, LLC
+Dave Aronberg
+• Fla. Stat. § 57.105 Demand Letter
+• Defendant, Dave Aronberg's Motion for Attorneys' Fees
+Douglas Wyler
+(904) 261-3693
+Please be advised that this e-mail and any files transmitted with it are confidential attorney-client
+communication or may otherwise be privileged or confidential and are intended solely for the individual or
+entty to whom they are addressed. If you are not the intended recipient, please do not read, copy or
+retransmit this communication but destroy it immediately. Any unauthorized dissemination, distribution or
+
+
+
+JACOBS & ASSOCIATES, P.A.
+ARTHUR I C
+• ScHoLz. & WYLER, LLC.
+A LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+98I6B7 GATEWAY BLVD.. SUITE 2OI-I
+FEENANDINA BEACH, FLORDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 261-7879
+RICHARD J. SCHOLZ, P.A.
+RICHARD J. SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A. WYLER
+June 8, 2020
+VIA ELECTRONIC & U.S. MAIL
+Stephen A. Mendelsohn, Esq.
+Greenburg Traurig, P.A.
+5100 Town Center Circle, Suite 400
+Boca Raton, FL 33486
+RE:
+COPY
+CA Florida Holdings, LLC v. Dave Aronberg et al.
+Palm Beach County, Case No.: 2019-CA-014681
+Dear Mr. Mendelsohn:
+As you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach
+County, Florida, in the above referenced matter. The purpose of this letter is to demand the voluntary
+dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand
+is made pursuant to section 57.105, Florida Statutes.
+As you know, Section 57.105 provides:
+(1) Upon the court's initiative or motion of any party, the court shall award a
+reasonable attorney's fee. including prejudgment interest, to be paid to the
+prevailing party in equal amounts by the losing party and the losing party's attorney
+on any claim or defense at any time during a civil proceeding or action in which
+the court finds that the losing party or the losing party's attorney knew or should
+have known that a claim or defense when initially presented to the court or at any
+time before trial:
+a. Was not supported by the material facts necessary to establish the claim or
+defense; or
+b. Would not be supported by the application of then-existing law to those
+material facts.
+Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count Il of the
+Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action
+consists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein
+and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to
+establish the claims asserted, and that your claims are not supported by the application of current law
+
+
+First and foremost, the Complaint is not supported by the material facts necessary to establish the
+claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the
+Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.
+Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are
+impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to
+this action because no matter what, he and his office do not have possession, custody, or control of the
+requested materials.
+In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims
+are also not supported by the application of current law. Specifically, your action for declaratory relief
+fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes,
+which states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorneys and by the latter
+to their legal associates and employees. However, the grand jury testimony afforded
+such persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable
+to comply with any court order granting disclosure of the requested documents because neither Mr.
+Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession,
+custody, or control of the 2006 Epstein grand jury records.
+Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter,
+the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client
+and your firm, recovery of the legal expenses incurred in defending this frivolous action.
+Please gover yourself accordingly
+Douglas A. Wyler, Esq.
+NOT
+Encl.: Defendant's Motion for Attorneys" Fees
+
+
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+I hereby certify that on this _.
+day
+, 2020, the foregoing was electronically filed
+via the Florida E-File Portal for electronic service on the parties of record herein.
+MISCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Arthur I. I Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blyd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+jacobsscholzlaw(@comcast.net
+Attorneys for Defendant
+NOT A CER
+
+
+
+
+
+
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASENO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+COPY
+Defendants.
+PLAINTIFF CA HOLDINGS, LIC'S
+NOTICE OF DROPPING STATE ATTORNEY, DAVE ARONBERG
+Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ, P. 1250(b), hereby notifies the parties that
+it has dropped State Attorney, Dave Aronberg from the above case.
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Antorneys for CA Florida Holdings. LLC. Publisher
+of The Palm Beach Post
+Stephen A. Mendelsohn. Esq.
+401 East Las Olas Boulevard Suite 2000
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By: Is/ Stephen A. Mendelsohn
+Florida Bar No. 849324
+smitht@gtlaw.com
+EL.Servicer@gtlaw.com
+
+
+By: (s/ Michael J Grugiel
+MICHAEL J GRYGIEL
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: [s/ Nina D. Boyajian
+NINA D. BOYAJIAN
+1840 Century Park East, Suite 1900
+Los Angeles California 90067
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+I HEREBY CERTIFY that on this 21" day of October, 2020, a true and correct copy of the
+foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which
+will send a notice of electronic service for all parties of record herein
+ACTIVE
+53317341v1
+/s/ Stephen d. Mendelsohn.
+2
+
+
+
+
+
+
+Scholz & Wyler, LLC
+961687 Gateway Blvd., Suite 201/
+Fernandina Beach, FL 32034
+United States
+904-261-3693
+Scholz & Wyler, LLC
+Dave Aronberg
+Balance
+Invoice#
+Invoice Date
+Payment Terms
+Due Date
+00307
+November 6, 2020
+Aronberg (SAO15) adv. CA Florida Holdings, LLC
+Time Entries
+Date
+EE
+11/26/2019
+DW
+11/26/2019
+DW
+11/26/2019
+DW
+11/26/2019
+DW
+11/26/2019
+DW
+11/26/2019
+11/26/2019
+AlJ
+11/26/2019
+DW
+11/26/2019
+12/02/2019
+DW
+12/022019
+DW
+12/02/2019 DW
+12/02/2019
+AU
+12/02/2019
+Al
+12/03/2019
+12/03/2019
+DW
+ow
+DW
+Activity
+Review
+Review
+Teleconference
+Draft
+Review
+Review
+Meeting
+Meeting
+Teleconference
+esearch
+reparatio
+Draft
+Teleconference
+Review
+Teleconference
+Meeting
+Meeting
+Draft
+Teleconference
+Description
+Initial review of summons and complaint.
+eviewed motion for pro hac vice and Judg
+alele' order grantir
+Teleconterenco w/ Client, re: response to lawsuit
+Drafted engagement letter and sent to client
+Reviewed 15th circuit local rules
+Initial review of complaint
+Meeting w/ DAW to discuss lawsuit and strategy
+Meeting w/ AlJ to discuss lawsuit and strategy
+| Teleconference w/ Client, re: response to lawsuit
+Research and prep for Motion to dismiss
+1st Draft motion to dismiss
+Teleconference wi Client, re: draft motion to
+dismiss
+Reviewed Ist Draft MTDismiss
+Teleconference w/ client, re: draft motion to
+dismiss
+Meeting wi DAW, re: motion to dismiss
+Meeting w/ Ald, re: MTDismiss
+Completed final draft of motion to dismiss; filed with
+Court
+Spoke wi client, re: final draft of motion to dismiss
+Rate
+$425.00
+$425.00
+$425.00
+$125.00
+$425.00
+$475.00
+$475.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$475.00
+$475.00
+$475.00
+$425.00
+$425.00
+$425.00
+Hours
+1.5
+02
+0.5
+1.0
+0.5
+0.5
+0.5
+2.0
+0.5
+0.3
+0.51
+0.2
+0.2
+0.7
+0,5
+Line Total
+$637.50
+$425.00
+$475.00
+$237.50
+$237.50
+$850.00
+$425.00
+$142.50
+$237.50
+$297.50
+
+
+12/13/2019
+01/16/2020
+01/16/2020
+01/17/2020
+01/17/2020
+01/17/2020
+01/20/2020
+01/21/2020
+01/21/2020
+01/21/2020
+01/21/2020
+01/21/2020
+01/22/2020
+01/22/2020
+01/23/2020
+01/24/2020
+01/24/2020
+01/24/2020
+01/27/2020
+02/03/2020
+02/03/2020
+03/13/2020
+03/13/2020
+03/18/2020
+03/18/2020
+03/18/2020
+03/19/2020
+03/20/2020
+DW
+AIJ
+ALJ
+DW
+DW
+DW
+DW
+DW
+ALJ
+DW
+DW
+DW
+ALJ
+DW
+DW
+DW
+DW
+DW
+DW
+AL
+DW
+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+DW
+Teleconference
+Review
+Review
+Review
+Review
+Review
+Review
+Teleconference
+Review
+Review
+Review
+Review
+Teleconference
+Meeting
+Meeting
+Review
+Research & Draft
+Teleconference
+Various
+Draft
+Review
+Review
+Review
+Teleconference
+Review
+• Review
+Teleconference
+Review
+E-mail
+E-mail
+Review
+Spoke with Clerk's attorney, re: response
+Reviewed final draft MTDismiss
+Reviewed Clerk's MTDismiss
+Reviewed Clerk's Mation to Dismiss
+Reviewed Order Setting Hearing on Defendants'
+MiDismiss
+Reviewed motion for pro hac vice
+Reviewed Pt's Amended Complaint
+Spoke with client, re: Amended Complaint
+Reviewed Pl's notice of filing
+Reviewed PI's Am. Compl
+Reviewed Judge Marx's Order Cancelling
+MTDismiss Hearing
+Reviewed Pl's Objection to Defendants' MT Dismiss
+Spoke with client, re: Amended complaint
+Meeting w/ DAW, re: response to Am. Compl
+Meeting w/ All, re: response to Am. Compl
+Reviewed Order granting pro hac vice admission
+Compared and crald rasponse to Amended
+Spoke with Clerk's altorney, re: response to
+amended complaint
+Completed Answer/MTDismiss Amended
+Complaint, filed with Court; sent copy to Client
+Drafted and filed Notice of Unavailability
+Reviewed final Answer/MTDismiss
+Reviewed Clerk's Answer/MTDismiss
+Reviewed Order setting hearing on Dets'
+MT Dismiss
+Spoke wi client, re: order setting MTDismiss
+hearing for March 24, 2020
+Reviewed Pl's Opposition to Aronberg MTDismiss
+& Clerk's MTDismiss
+Reviewed PI's Opposition to Aranberg MT Dismiss
+& Clerk's MT Dismiss
+Reviewed email from Pi's counsel, re: motion to
+continue hearing
+Reviewed Pl's unopposed motion for continuance
+Emails w/ Clerk's counsel, re: Pl's request to
+continue hearing
+Reviewed email from Pl, re: agreed order &
+responded
+Reviewed Court's agreed order continuing hearing
+$425.00
+$475.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$125.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+0.5
+02
+02
+0.5
+0.1
+0.1
+1.0
+0.5
+0.1
+0.3
+0.1
+0.2
+0.5
+02
+0.2
+0.1
+1.D
+0.2
+1.0
+0.4
+02
+0.1
+0.5
+1.5
+0.7
+0.1
+0.1
+02
+0.1
+0.1
+$425.00
+$142.50
+$95.00-
+$425.00
+$425.00
+$170.00
+
+
+05/22/2020
+05/22/2020
+05/27/2020
+05/27/2020
+05/28/2020
+05/29/2020
+06/01/2020
+06/02/2020
+06/02/2020
+06/03/2020
+06/03/2020
+06/03/2020
+06/03/2020
+06/03/2020
+06/03/2020
+06/08/2020
+06/08/2020
+06/08/2020
+06/08/2020
+06/08/2020
+06/08/2020
+06/10/2020
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+ALJ
+DW
+DW
+DW
+ALJ
+DW
+DW
+DW
+Review
+Teleconference
+Review
+Review
+Teleconference
+Review
+Teleconference
+E-mail
+Preparation
+E-mail
+Various
+E-mail
+Attend Hearing
+Teleconference
+E-mail
+E-mail
+Attend Hearing
+Review
+Review
+Various
+Meeting
+Meeting
+Review
+Variaus
+Various
+Reviewed order rescheduling hearing on Defs'
+MT Dismiss
+Spoke w/ client, re: order rescheduling MTDismiss
+hearing for June 3, 2020
+Reviewed Order rescheduling MTDismiss hearing
+Nosed order selling zoom hearing, re:
+Spoke w/ client, re: hearing will be via Zoom
+Reviewed Clark's fling: change of ally of record
+Spoke with Clerk's new counsel, Nicale Fingerhut
+Reviewed Pi's email, re: cases and authorities for
+MTDismiss hearing: responded
+Began oral argument prep for 6/8 Dismiss
+hearing
+Reviewed email from Judge Marx's JA and
+responded
+Reviewed Pl's 500+ page binder, re: MTDismiss &
+prepped for hearing
+Dratted and sent email to client, re: MTD hearing
+tomorrow
+Peened for and attended MT mies, hearing via.
+Spoke w/ Client, re: debriet MDismiss hearing
+Emailed courtesy copies of Aronberg's Answer and
+MTDismiss to Judge Marx
+Reviewed response from Client and replied
+Attended MTDismiss hearing via Zoom
+Reviewed order granting MTDismiss wi prejudice
+reviewed Court's Order Granting Defendant
+Dismiss Count il w/ Prejudic
+shared order w/ Client and spoke wi, re: result an
+lan going forward, re: 57.104
+Researched $ 57.105 Fla. Stat; drafted 57.105
+demand letter and proposed motion for attorneys'
+ces/sanctions; Served Pls counsel with deman
+after and proposed motior
+Meeting w/ DAW. re: Order & 57.105
+Meeting w/ All, re: Order & 57.105
+Sancined 57.105 demand and proposed matin for
+Reviewed notice of change of attorney, re: Clerk;
+called and spoke w/ new counsel Cynthia Guerra
+Reviewed Pl's letter refusing to voluntarily dismiss
+amended complaint despite 57.105 demand; called
+and spoke wi client, re: Pis refusal & next steps
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$475.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$475.00
+$425.00
+$425.00
+0.1
+0.3
+0.1
+0.1
+0.2
+0.1
+0.2
+1.0
+0.1
+3.0
+0.1
+1.5
+0.5
+0.1
+0.1
+1.0
+03
+0.5
+0.5
+$47.50
+$425.00
+$1,275.00
+$637.50
+$475.00
+$142.50
+2.0
+03
+0.3
+0.2
+0.3
+1.0
+$850.00
+$142.50
+$425.00
+
+
+07/01/2020
+07/02/2020
+07/08/2020
+07/08/2020
+07/10/2020
+07/10/2020
+07/10/2020
+07/13/2020
+07/13/2020
+07/27/2020
+07/27/2020
+07/28/2020
+07/29/2020
+07/29/2020
+07/30/2020
+07/30/2020
+08/05/2020
+08/07/2020
+08/10/2020
+08/17/2020
+/ 08/17/2020
+08/18/2020
+| 08/27/2020
+09/01/2020
+DW
+DW
+DW
+DW
+AiJ
+DW
+ALJ
+OW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW(
+oW
+DW
+DW
+DW
+DW
+E-mail
+Review
+Various
+E-mail
+¡ Teleconference
+Teleconference
+Draft
+Various
+Meeting
+Review
+/Teleconference
+Review
+Teleconference
+Draft
+Draft
+Research &
+Preparation
+Various
+Draft
+Draft
+Review
+E-mail
+Meeting
+Various
+Draft
+Teleconference
+Various
+Review
+Teleconference
+Sent client copy of Pr's letter refusing to dismiss
+complaint
+Comped P's lter refusing to dismis Count lAm.
+Spoke wi client, re: filing of 57.105 motion for
+fees/sanctions; filed motion for attorneys' fees
+based on P's failure to voluntarily dismiss
+amended complaint count 1
+Email to client, re: aflidavit and summary judgment
+Discussed w/ Client drafting and fling Mation for
+Summary Judgment and MSJ evidence
+Discussed w: Client drafting and filing Mation for
+Summary Judgment and MSJ evidence
+Created Ist draft of Aronberg Affidavit: shared wi
+Reviewed draft affidavit and discussed w/ DAW
+/Discussed draft affidavit w/ AIJ
+Reviewed P's Request to Produce, re: Clerk
+Spoke w/ Clerk's counsel, re: Request to Produce
+Reviewed Pts Amended Request to Produce, re:
+Spoke w/ Clerk's counsel, re: Amended Request to
+Revised Aronberg affidavit
+Finalized Aronberg Affidavit and sent to client
+Research and prep for Motion for Summary
+Judgment.
+Received executed Aronberg Affidavit
+Began drafting Motion for Summary Judgment
+Continued drafting Motion for Summary Judgment
+Reviewed email from Plaintift attempting to set
+hearing on 57.105 motion for lees/sanctions
+Sent responsive email to Pl's counsel
+Discussed draft MSJ W/ AlJ
+Reviewed draft MSJ and met w/ DAW to discuss
+Finalized Motion for Summary Judgment; filed wi
+court along with Aronberg affidavit
+Spoke w/ Clerk's counsel, re: request lo produce
+Reviewed Pl's email and accepted conference call
+invite for 9/2/20
+Reviewed Clerk's response to request for
+production
+Spoke w/ Pl's counsel, re: dispute as to whether
+MSJ should be heard betore 57.105 lee motion of
+vis versa - call was unsuccessful
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$175.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
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+$47.50
+$297.50
+$332.50
+$425.00
+$142.50
+$425.00
+. $42.50
+$850.00
+$425.00
+$237.50
+$850.00
+
+
+09/16/2020
+09/17/2020
+09/17/2020
+09/18/2020
+09/18/2020
+09/18/2020
+09/18/2020
+09/18/2020
+09/22/2020
+10/02/2020
+10/02/2020
+10/02/2020
+10/02/2020
+10/12/2020
+10/13/2020
+10/13/2020
+10/13/2020
+10/13/2020
+10/14/2020
+10/14/2020
+10/14/2020
+AI
+DW
+DW
+DW
+AU
+DW
+DW
+DW
+DW
+OW
+DW
+DW
+AlJ
+AIJ
+DW
+DW
+DW
+DW
+AU
+DW
+DW
+DW
+oW
+E-mail
+Meeting
+Meeting
+Various
+E-mail
+E-mail
+_E-mail
+E-mail
+Various
+Review
+Research &
+Analyze
+Draft
+Various
+Draft
+Telephone
+Telephone
+Attend Hearing
+Various
+Discussed w/ DAW phone call w/ Pr's counsel
+Discussed w! All phone call wi PI's counsel
+eviewed email from Pis counsel requeste
+ronberg to withdraw sanctions motion wi
+prejucice
+Discussed w/ All filing motion for CMC
+Discussed w/ DAW filing motion for CMC
+Drafted and filed motion to set case management
+conference; re: MSJ 1st or Fee hearing 1st
+Responded to Pr's 9/16/20 email and relused to
+withdraw 57.105 motion; provided copy of motion to
+set CMC and available dates for hearing
+Reviewed Pl's email insisting that 57.105 motion be
+withdrawn
+Replied to Pi's counsel that the 57.105 motion for
+sanctions will not be withdrawn and asking for
+response, re: CMC
+Sent client copy of email exchange w: Pl's counsel:
+called and spoke w/ Client
+Drafted and filed Notice of Hearing on T0/15/20; set
+up Court Call; spoke w/ client, re: hearing date
+Reviewed Pt's Memo of Law opposing Arenberg's
+57.105 motion for fees/sanctions.
+Revlewed Pl's Response to Aronberg's request to
+schedule 57.105 motion for fees after MSJ
+Reviewed Pl's Memo of Law opposing 57.105
+motion
+Reviewed PT's Response to Aronberg's request to
+schedule 57.105 motion after MSJ
+Rescarch caselaw & statutes, re: response to Pl's
+Memo of Law
+Continued researching caselaw, re: response to
+Pl's memo of law
+Created 1st draft of Response to Pl's Memo of Law
+and shared w/ Client
+Discussed w: All caselaw and draft response to
+memo
+Reviewed draft MSJ, discussed draft w/ DAW and
+caselaw
+Finalized and filed Response to P's Memo of Law
+Spoke w/ client, re: memo of law
+Spoke wi client again, re: response to memo of law
+Altended hearing, re: Motion to Set CMC; called
+client to discuss
+Reviewed email and letter from Pl, re: settlement.
+Sent copy to Client and called to discuss.
+$475.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
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+0.7
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+0.5
+0.4
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+1.0
+4.0
+0.5
+0.7
+05
+$47.50
+$297.50
+$297.50
+$237.50
+$190.00
+$425.00
+$425.00
+$1,700.00
+$332.50
+$425.00
+$637.50
+
+
+10/16/2020
+10/16/2020
+10/16/2020
+10/16/2020
+10/16/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/19/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/20/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+| 10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/21/2020
+10/22/2020
+DW
+DW
+Telephone
+Telephone
+AlJ
+DW
+DW
+DW
+DW
+DW
+AIJ
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+DW
+AlJ
+DW
+DW
+DW
+DW
+oW
+DW
+DW
+AN
+DW
+/ Various
+Various
+Meeting
+Various
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+[Telephone
+Telephone
+Telephone
+Meeting
+Meeting
+Various
+Review
+Telephone
+Telephone
+(Telephone
+Telephone
+Telephone
+E-mail
+Meeting
+Meeting
+DW
+Various
+Spoke w/ Pls counsel, re: settlement
+Spoke w/ client, re: PI's settlement proposal
+Attended hearing, re: motion to set CMC;
+discussed w/ client
+Discussed Pl's settlement proposal w/ DAW and
+then w/ Client
+Discussed Pr's settlement proposal w/ AlJ
+Drafted and shared proposed order w/ Pl's counsel
+Spoke w/ Pl's counsel, re: settlement
+Spoke w/ client, re: PI's settlement proposal
+Discussed Pi's seltlement proposal wi AlJ
+Discussed Pl's settlement proposal w/ DAW
+Uploaded proposed order, re: CMC for Judge
+Hafele
+Spoke wi client, re: P's settlement proposal
+Spoke w/ Pl's counsel, re: settlement
+Discussed Pl's settlement proposal w/ DAW
+Discussed Pl's settlement proposal wi Ald
+Reviewed email from Pl, re: settlement; sent copy
+to Client and called to discuss
+Spoke w/ client, re: settlement
+Spoke w/ Pl's counsel, re: settlement
+Spoke w/ client. re: settlement
+Discussed Pl's settlement proposal w/ AL
+Discussed Pl's settlement proposal w/ DAW
+Drafted and filed Motion to Set Hearing on
+Aronberg MSJ; drafted proposed order granting
+molion to set; checked court availability; emailed
+Pt's counsel, re: choose date for hearing
+Reviewed Order, re: CMC unnecessary
+Spoke w/ client, re: media response
+Spoke wi client, re: media response
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Spoke w/ client, re: media response
+Sent email wi Aronberg statement to media
+Discussed media response wi DAW
+Discussed media respanse wi AIJ
+Reviewed Pl's Notice of Dropping Aronberg as
+Sany spoke wi Client and Al, ro: notice and next
+$425.00
+$425.00
+$475.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$425.00
+$475.00
+$425.00
+$425.00
+$425.00
+0.1
+021
+1.0
+0.4
+02
+0.5
+0.2
+0.5
+0,2
+02
+0.1
+0.2
+0.1
+0.2
+0.2
+0.5
+0.4
+0.1
+0.1
+0.2
+0.2
+1.0
+0.1
+0.2
+0.1
+0.1
+0.1
+0.1
+03
+0.3
+0.5
+$475.00
+$190.00
+$85.00|
+$12.50
+$170.00
+$425.00
+$42.50|
+$142.50
+
+
+10/22/2020
+AU
+Various
+Reviewed P's Notice of Dropping Aronberg as
+party; spoke w/ Client and DAW, re: notice and next
+steps
+$475.00
+0.5
+Totals:
+74.8
+Time Entry Sub-Total:
+Sub-Total:
+Total:
+Amount Paid:
+Balance Due:
+$237.50
+$0.00
+
+
+
+
+
+
+= ASSOCIATES, FA
+ARTHUR I
+SCHOLZ & WYLER, LLC.
+UMITED LIABIUTY COMPANY OF PROFESSIOMAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+96I687 GATEWAY BLVD., SUITE 20I-I
+FERNANTINA BEACE, FLORIDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 281.7879
+RICHARD .d. SCHOLZ, P.A.
+RICHARD J. SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A WYLER
+November 26, 2019
+Office of the State Attorney
+15th Judicial Circuit
+Atto: Jeanne Howard
+401 North Dixie Highway
+•West Palm Beach, FL 33401
+Re:
+CA Florida Holdings, LIC v. Dave Aronberg et al.
+Case No.: 2019-CA-014681
+"OP
+COPY
+Dear Mrs. Howard:
+The purpose of this letter is to confirm that
+Scholz & Wyler, LLC will represent you regarding the
+above-referenced matter.
+Our fees will be contingent upon our success in this matter. You will not be liable or required to pay any
+monies to our office unless we are successful in our representation of you regarding the above-referenced
+litigation and receive a court order awarding attorneys' fees.
+Accordingly, should we be successful in this matter, you agree to be billed for the time incurred in defending
+his action at our current hourly rates. At this time, our current hourly rates are: $475.00/hour for senic
+artners, $425.00/hour for other partners, $375.00/hour for associate attorneys, and $125.00/hour fo
+paralegal time.
+Furthermore, the attorneys' fees paid to our firm shall be calculated by the above listed hourly rates
+multiplied by the number of hours expended in defending this action or the total fee mandated and awarded
+by the court order herein, whichever is greater.
+By signing below, you agree to the terms as set forth above. Please return a signed and dated copy of thi
+letter to our office. If you have any questions or concerns, please contact our office. On behalf of th
+firm, we are proud to represent you in this matter.
+Sincerely,
+Douglas A. Wyler, Esq.
+6/4/230
+Date
+--
\ No newline at end of file
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+  "engine": "marble-apple-vision",
+  "event_count": 402,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
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+  "text_format": "markdown"
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diff --git a/vision-fixhub/court-01/e75b9faeba28c0804d126a4a640d5bc757539ba07c4cbacca70731ff346d27ca.md b/vision-fixhub/court-01/e75b9faeba28c0804d126a4a640d5bc757539ba07c4cbacca70731ff346d27ca.md
new file mode 100644
index 0000000000000000000000000000000000000000..94b3d8126c0e9fb05988757b9be1217c406fbac3
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+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 1 of 8
+Aug 0485059388-CV-8@1ch9rlKAMHaldøDment 247-7 Entered on FLSD D'8ZK8P08/85/2009 Pag84 of 8
+Jane Doe #7
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W..
+| M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+c.w.L
+,M.D., who, being by me first duly sworn under oath deposes and says:
+1.
+My name is Richard C.W.
+M.D. Iam over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 1996.
+3.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns University and
+1
+F
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 2 of 8
+Aug 04Cas@19C0B-cv-80KI4@-KAMHD06Qment 247-7 Entered on FLSD D$ZK8P08/85/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+5.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+• 9.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #7 against Jeffrey Epstein makes
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 3 of 8
+Aug 040285053108-CV-80xf-19xKAMHaDd8üment247-7 Entered on FLSD D86RE7 68985/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #7 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer,
+severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12.
+She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13.
+Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director.
+14.
+While all pertinent medical history has been withheld, on October 4, 2005,
+Plaintiff did provide a statement to the police, which directly conflicts with the allegations
+in her complaint. Medical records would assist with the veracity (or lack thereof) of her
+statements and the allegations in the complaint. Plaintiff told the police on October 4, 2005
+that she was introduced to Epstein by
+when she was approximately 17.
+(Police Statement, page 1)
+allegedly told her that the first time you go it's
+3
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 4 of 8
+Aug 040260t830B-CV-80k18rKAMHaD06Dment247-7 Entered on FLSD D8ZR8f88985/2009 Page 4 of 8
+just like a massage and she said "well, like, well the more you go supposedly, the more
+like, he expects, and like flirting with girls and that's what kind of scared her." (Police
+Statement, page 2) She also states that the second time she went to Epstein's, she gave him
+a massage and that she had her clothes on. (Police Report, pages 2 & 4) Plaintiff claims she
+thought Epstein might be leaning towards wanting her to take her clothes off, or touching
+her but Epstein never did because she was so shy. (Police Statement, pages 2 & 3) She also
+told police that when she massaged Epstein, he was not naked (Police Statement, page 3),
+he never removed his towel (Police Statement, page 3), she did not take her clothes off
+(Police Statement, page 4), Epstein did not touch her inappropriately (Police Statement,
+page 3), he did not masturbate (Police Statement, page 5), and they did not touch each
+other's private areas (Police Statement, page 3). Further, she claims in the report not to
+have returned to Epstein's home after the second visit. (Police Report, page 3)
+15. Her allegations in the complaint are in complete opposite when compared to
+the police report. For instance, the complaint alleges: (a) during the first massage, Epstein
+sexually assaulted her and masturbated (Complaint, Paragraph 13); and (b) Plaintiff
+returned on many occasions to the Palm Beach mansion to provide Epstein with massages
+for money. On those occasions, Epstein engaged in sexual contact and activity with
+Plaintiff, which included, among other things, Epstein touching Jane's breasts, placing a
+vibrator on her vagina and masturbating himself. This sexual abuse continued over a
+4
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 5 of 8
+Aug 040885859308CV-8010tgrAMHabdEment 247-7 Entered on FLSD 86k3788985/2009 Page 5 of 8
+period of approximately 18 to 24 months (Complaint, Paragraph 14). In stark contrast to
+the statement she gave to the police, she now claims in her answers to interrogatories that
+she went to Epstein's home between 8-10 times (Interrogatory, #15) and that she brought
+friends on two separate occasions and was paid $200 per friend (Interrogatory, #17). In
+fact, she denies in her answers to interrogatories that she even provided a recorded
+statement to the police (Interrogatory, #22). In addition, on Tape 2, pages 11, 12 &20, she
+claims that Epstein was aggressive, grabbed her butt, tried to feel parts of her, masturbated
+under the towel and pulled her bra and exposed her nipples and touched her breasts,
+which is totally inconsistent with her statement to the police.
+16.
+For further elaboration of Jane Doe #7's history and background, access to all
+available records is crucial if one is to fully understand the impact of any of these events on
+her subsequent behavior and proportion the impact of specific events, if any, or her current
+and future level of function.
+17. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 6 of 8
+Aus 0086889:08-CV-804995KMadlEment 247-7 Entered on FLSD Dockef 83885/2009 Page 6 of 8
+in the case.
+18.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attomey, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning,
+which our input is requested." We request the same.
+19. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+6
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 7 of 8
+aur 048389308-cv-80749kmoment 247-7 Entered on FLSD DOCkeR 08/85/2009 Page of 8
+behavior that may have placed them at increased risk. It is important to know if there had
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+20.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+21.
+Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+22. Itis, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+•
+7
+
+
+Case 9:08-cv-80119-KAM Document 362-6 Entered on FLSD Docket 10/21/2009 Page 8 of 8
+Aus Gase 9:08-cv-80719-KAM Document 247-7 Entered on FLSD Docket 08/05/2009 Page 8 of 8
+and conduct. We would concur and request of the court that the same and such other
+similar information be made available to us to conduct our examination.
+Respectfully submitted,
+Richard C. W. Hall, Vil
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+BEFORE ME, the undersigned authority, personally appeared RICHARD C.W.
+M.D., who is (V) personally known to me or (
+) who has produced
+- as identification, and who did take an oath, deposes and says that
+the attached Affidavit is true and correct to the best of his knowledge and belief.
+SWORN TO AND SUBSCRIBED before me on this 4th day of August
+2009.
+MARCIA CHAPMAN******
+Expires B/6/2010
+Narcia 1 Usman
+Printed Name: MARcIA I CHAPMAN
+My Commission Expires:
+8
diff --git a/vision-fixhub/court-01/e75b9faeba28c0804d126a4a640d5bc757539ba07c4cbacca70731ff346d27ca.receipt.json b/vision-fixhub/court-01/e75b9faeba28c0804d126a4a640d5bc757539ba07c4cbacca70731ff346d27ca.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/e75d0fd48d9a0415bd6ec42660a3e4a7410cafba3ec54e10a0ec0c7c7d2649fc.md b/vision-fixhub/court-01/e75d0fd48d9a0415bd6ec42660a3e4a7410cafba3ec54e10a0ec0c7c7d2649fc.md
new file mode 100644
index 0000000000000000000000000000000000000000..5c674d9a6d0d15f318de4698db78660a6933a806
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@@ -0,0 +1,69 @@
+Case 1:20-cv-00484-JGK-DCF Document 63 Filed 08/12/20 Page 1 of 2
+PANISH
+SHEA &
+BOYLE
+LLP
+August 12, 2020
+VIA ECE
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl Street
+New York, NY 10007
+Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF
+Status Update Following 8/5/20 Scheduling Conference
+Dear Judge Freeman:
+We are writing on behalf of our client, plaintiff Jane Doe, in the above-referenced
+litigation and to update the Court on some discovery issues in our case following the August 5,
+2020 scheduling conference.
+First, on August 5, 2020, this Court ordered defendant Ghislaine Maxwell to serve her
+initial disclosures no later than August 10, 2020. The Court's specific order was that: "It is
+hereby ORDERED that: 1. Defendant Ghislaine Maxwell ("Maxwell") shall serve her initial
+disclosures no later than August 10, 2020." As of the time of submitting this letter, however,
+Ms. Maxwell has not served her initial disclosures on the parties. Moreover, Ms. Maxwell has
+not sought any relief from the Court to excuse her of complying with the order of the Court.
+Accordingly, as it stands, Ms. Maxwell has violated the Court's order.
+Second, it has now been over 4 months since Plaintiff served the Epstein Estate with
+document requests and she has still failed to receive a single substantive response nor a single
+page of evidence from the Epstein Estate to date. Indeed, even after providing counsel for the
+Epstein Estate with her proposed edits to their draft confidentiality order and non-disclosure
+agreement they have insisted all Epstein victims sign before producing any information to them,
+Plaintiff received no response and no documents have been released.
+And third, despite Plaintiff's multiple attempts at getting available deposition dates for
+defendant Richard Kahn, the co-executor of the Epstein Estate, his attorneys simply just refuse to
+provide them. Instead, they are insisting that Plaintiff's counsel first tell them what Mr. Kahn is
+to be questioned about and essentially prove why he—a defendant in this action—ought to be
+required to testify at deposition.
+11111 Santa Monica Boulevard, Suite 700 - Los Angeles, California 90025 - 310.477.1700 phone - 310.477.1699 fax - www.psblaw.com
+
+
+Case 1:20-cv-00484-JGK-DCF Document 63 Filed 08/12/20
+PARISH
+SHEA &
+BOYLEL
+Hon. Debra C. Freeman
+Daniel T
+Moynihan
+United States Courthouse
+August 12, 2020
+Page 2
+It has become incredibly obvious that there is a concerted and coordinated effort by the
+Epstein Estate and its attorneys to not only deprive the victims of information in these cases that
+they are entitled to by law but also deny them of having their day in court. Indeed, the Epstein
+Estate repeatedly reminds Plaintiff how she is the only victim who continues to pursue her case
+against them while the other victims have all agreed to stay their cases in hopes of resolving
+them through the victim compensation fund. And despite the Epstein Estate's ongoing selfserving statements that they have not formally requested a stay as to any of the proceedings
+themselves, that is form over substance. To the contrary, they have done everything they can to
+make these cases as difficult as possible for the victims so the victims feel like they have no real
+choice but to submit to the fund and postpone the proceedings indefinitely. As a consequence, in
+this case, the Epstein Estate has resorted to belittling Plaintiff and threatening her lawyers with
+sanctions and accusations of impropriety simply because she is exercising her constitutional right
+to pursue a legal claim against those responsible for causing her unimaginable harm. In short,
+since Plaintiff has not agreed to stay her case and walk away, she is being punished by the
+Epstein Estate for doing what she has a basic right to do. That is simply unacceptable and
+Plaintiff is not walking away.
+Respectfully submitted,
+PANISH SHEA & BOYLE
+/s/ Robert Glassman
+Robert Glassman
diff --git a/vision-fixhub/court-01/e75d0fd48d9a0415bd6ec42660a3e4a7410cafba3ec54e10a0ec0c7c7d2649fc.receipt.json b/vision-fixhub/court-01/e75d0fd48d9a0415bd6ec42660a3e4a7410cafba3ec54e10a0ec0c7c7d2649fc.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/e78f14176dd5ce0e8ad25f4aad3ad2f94789d4bc5f08a7a162458c0f65580b6a.md b/vision-fixhub/court-01/e78f14176dd5ce0e8ad25f4aad3ad2f94789d4bc5f08a7a162458c0f65580b6a.md
new file mode 100644
index 0000000000000000000000000000000000000000..f7f1903c5bb228f09ec7d050845c24519465b3d4
--- /dev/null
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@@ -0,0 +1,52 @@
+Case 9:08-cv-80069-KAM Document 8 Entered on FLSD Docket 02/15/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80069-CIV-MARRA/JOHNSON
+JANE DOE NO. 1, by and through
+JANE DOE's FATHER as parent and natural
+guardian, and JANE DOE's FATHER, and
+JANE DOE's STEPMOTHER, individually,
+Plaintiffs,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' NOTICE OF NON-OPPOSITION TO MOTION
+TO INTERVENE FILED BY JANE DOE'S MOTHER
+Plaintiff, Jane Doe No. 1, by and through Jane Doe's Father as parent and natural guardian,
+and Jane Doe's Father and Jane Doe's Stepmother individually, hereby advise the Court that, upon
+review of the Motion to Intervene and Supporting Memorandum of Law filed by Jane Doe's Mother,
+and the Intervenor's Complaint attached thereto as Exhibit "A", Plaintiffs have no opposition to
+Jane Doe's Mother's intervention for the purpose of asserting the claims set forth in the Intervenor's
+Complaint attached to her Motion.
+Dated: February 14, 2008
+Respectfully submitted,
+By:
+HERMAN & MERMELSTEIN, P. A.
+s/ Jeffrey M. Herman
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman@hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+smermelstein@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe et al.
+18205 Biscayne Blvd., Suite 2218
+www.hermanlaw.com
+- 1 -
+
+
+Case 9:08-cv-80069-KAM Document 8 Entered on FLSD Docket 02/15/2008 Page 2 of 2
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on February 14, 2008, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on the following, via transmission of Notices of Electronic Filing generated by CM/ECF:
+Theodore Jon Leopold
+tleopold@riccilaw.com
+Is/ Jeffrey M. Herman
+HERMAN & MERMELSTEIN, P. A.
+www.hermanlaw.com
+- 2-
diff --git a/vision-fixhub/court-01/e78f14176dd5ce0e8ad25f4aad3ad2f94789d4bc5f08a7a162458c0f65580b6a.receipt.json b/vision-fixhub/court-01/e78f14176dd5ce0e8ad25f4aad3ad2f94789d4bc5f08a7a162458c0f65580b6a.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "doc_id": "e78f14176dd5ce0e8ad25f4aad3ad2f94789d4bc5f08a7a162458c0f65580b6a",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.md b/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.md
new file mode 100644
index 0000000000000000000000000000000000000000..bd0c1cf211c889000cf3dbce03637f67ed3b4bf6
--- /dev/null
+++ b/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.md
@@ -0,0 +1,276 @@
+Case 9:08-cv-80380-KAM Document 132-1
+Entered on FLSD Docket 06/09/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA-
+JANE DOE NO. 4
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his First Amended Answer to the Second Amended
+Complaint [DE 62] and states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "it would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 2 of 10
+Page 2
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+3. As to the allegations in paragraph 3, deny.
+4. As to the allegations in paragraph 4, deny.
+5. As to the allegations in paragraph 5, without knowledge and deny.
+6. As to the allegations in paragraphs 6, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "fit would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed. Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 3 of 10
+Page 3
+7. As to the allegations in paragraphs 7 through 15 of Plaintiff's Second Amended
+Complaint, Defendant exercises his Fifth Amendment Privilege against selfincrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA
+1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "[ilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. &
+Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "…. a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 16, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 17 through 22 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4'" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 4 of 10
+Page 4
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "lift would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+10. In response to the allegations of paragraph 23, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+11. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 24 through 28 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "lilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 5 of 10
+Page 5
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination (...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 29, Defendant realleges and adopts
+his responses to paragraphs 1 through 15 of the Second Amended Complaint set forth
+in paragraphs 1 through 7 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 30 through 35 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4* DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "Tilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against self-
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 6 of 10
+Jane Doe No. 4 V. Epstein
+Page 6
+incrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief' which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+WHEREFORE, Defendant requests that this Court deny the relief sought by Plaintiff.
+Affirmative Defenses
+1. As to all counts, Plaintiff actually consented to and was a willing participant in the
+acts alleged, and therefore, her claims are barred, or her damages are required to be
+reduced accordingly.
+2. As to all counts alleged, Plaintiff actually consented to and participated in
+conduct similar and/or identical to the acts alleged with other persons which were the
+sole or contributing cause of Plaintiff's alleged damages.
+3. As to all counts, Plaintiff impliedly consented to the acts alleged by not objecting
+and by going to Defendant's home with other females and/or by bringing other females
+to Defendant's home for which Plaintiff received money, and therefore, her claims are
+barred, or her damages are required to be reduced accordingly.
+4. As to all counts, Defendant reasonably believed or was told that the Plaintiff had
+attained the age of 18 years old at the time of the alleged acts.
+5. As to all counts, Plaintiff's claims are barred as she said she was 18 years or
+older at the time.
+6. As to all counts, Plaintiff's alleged damages were caused in whole or part by
+events and/or circumstances completely unrelated to the incidents) alleged in the
+complaint.
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 7 of 10
+Page 7
+7. Plaintiff's claims are barred by the applicable statute of limitations.
+8. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the limitations as set forth in §768.72, et seq., Florida Statutes.
+9. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count |I - "Intentional Infliction of Emotional Distress," such claims are
+subject to the constitutional limitations and guideposts as set forth in BMW of North
+America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v.
+123 S.Ct 1513 (2003);
+127 S.Ct. 1057
+v. Ligget Group, Inc., 945
+(2007); State Farm v.
+So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the
+United States Constitution and Florida's Constitution, Art. I, §§2 and 9, prohibit the
+imposition of grossly excessive or arbitrary punishments
+10. As to Plaintiff's claims for punitive damages in Count I - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," the determination of
+whether or not Defendant is liable for punitive damages is required to be bifurcated from
+a determination of the amount to be imposed.
+11. Plaintiff has failed to state a cause of action for sexual assault and/or battery
+under Count I.
+12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and
+can not show a violation of a predicate act under 18 U.S.C. §2255 (2005).
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 8 of 10
+Page 8
+13. As to Count III, the version of 18 U.S.C. §2255 in effect at the time of the alleged
+conduct applies, and, thus, the presumptive minimum damages amount should Plaintiff
+prove the elements of such claim is $50,000, and not subject to any multiplier.
+14. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, would be in violation of the legal axiom against retroactive application of
+an amended statute, and also in violation of such constitutional principles, including but
+not limited to, the "Ex Post Facto" Clause, U.S. Const. Article I, §9, cl. 3, §10, cl. 1, and
+procedural and substantive due process, U.S. Const. 14* Amend., 5" Amend. The
+statute in effect during the time of the alleged conduct applies.
+15. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, is prohibited pursuant to the vagueness doctrine and the Rule of Lenity.
+A criminal statute is required to give " 'fair warning ... in language that the common
+world will understand, of what the law intends to do if a certain line is passed. To make
+the warning fair, so far as possible the line should be clear.' " United States v. Lanier,
+520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United
+States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931)) (omission in original). The
+"three related manifestations of the fair warning requirement" are: (1) the vagueness
+doctrine bars enforcement of a statute which either forbids or requires the doing of an
+act in terms so vague that men of common intelligence must necessarily guess at its
+meaning and differ as to its application; (2) the canon of strict construction of criminal
+statutes, or rule of lenity, ensures fair warning by so resolving ambiguity in a criminal
+statute as to apply it only to conduct clearly covered; (3) due process bars courts from
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 9 of 10
+Page 9
+applying a novel construction of a criminal statute to conduct that neither the statute nor
+any prior judicial decision has fairly disclosed to be within its scope.
+16. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+17. Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without
+subject matter jurisdiction as to all claims asserted.
+18. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+19. 18 U.S.C. §2255 violates the Equal Protection Clause of the 14* Amendment
+under the U.S. Constitution, and thus Plaintiffs claim thereunder is barred.
+20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life, liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by
+Plaintiff.
+
+
+Case 9:08-cv-80380-KAM Document 132-1 Entered on FLSD Docket 06/09/2009 Page 10 of
+Page 10
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this _ day of _
+, 2009:
+Stuart S. Mermelstein, Esq.
+Jack Alan Goldberger
+Adam D. Horowitz, Esq.
+Atterbury Goldberger & Weiss, P.A.
+Mermelstein & Horowitz, P.A.
+250 Australian Avenue South
+18205 Biscayne Boulevard
+Suite 1400
+Suite 2218
+West Palm Beach, FL 33401-5012
+Miami, FL 33160
+561-659-8300
+305-931-2200
+Fax: 561-835-8691
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #4
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.receipt.json b/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.receipt.json
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--- /dev/null
+++ b/vision-fixhub/court-01/e790e6ff03c714129843182498749a2ee216f2f602f2cde29a29e450398639f7.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.md b/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.md
new file mode 100644
index 0000000000000000000000000000000000000000..8be2a105329cec3e23efee8f838c0f9279215b6f
--- /dev/null
+++ b/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.md
@@ -0,0 +1,89 @@
+Case 9:08-cv-80232-KAM Document 102-1 Entered on FLSD Docket 05/27/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80232-KAM Document 102-1 Entered on FLSD Docket 05/27/2009 Page 2 of 3
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/_
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRAJ
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al.,
+Defendant.
+CASE NO.: 08-CV- 80469-MARRA/_
+
+
+Case 9:08-cv-80232-KAM Document 102-1 Entered on FLSD Docket 05/27/2009 Page 3 of 3
+JANE DOE NO. 101,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80591-MARRA/
+JANE DOE NO. 102,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA/
+ORDER
+Upon Plaintiffs' Motion for Enlargement of Time to Respond to Defendant's Motion to
+Compel and/or Identify Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third
+Party Subpoenas for Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and
+good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+twenty (20) days until June 11, 2009, to respond to the Defendant's Motions to Compel and/or
+Identify Jane Doe in the Style, et al..
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this
+day of
+• 2009.
+DISTRICT COURT JUDGE
diff --git a/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.receipt.json b/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c0157007cacc2e14b4f617a3b872496fb9a75286
--- /dev/null
+++ b/vision-fixhub/court-01/e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb.receipt.json
@@ -0,0 +1,14 @@
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+  "doc_id": "e7aa1a43abd64714148e0a0cffa8806055aba34102fc8b7d6d0945b640c0e9eb",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f14cbc065ef37b7f3b48efc5d9f203ebebdc35c5322c45a7c3eb59b46ae6f487",
+  "output_sha256": "0f1d602be89097ae77c6a994d55567f0d4f2599cf1840262d24e902333dc7073",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.md b/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.md
new file mode 100644
index 0000000000000000000000000000000000000000..0d21ed1ca05d35384ce627be93663d2a2d57b42b
--- /dev/null
+++ b/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.md
@@ -0,0 +1,116 @@
+Case 9:08-cv-80994-KAM Document 58 |
+Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/C
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80994-KAM Document 58 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:08-cv-80994-KAM Document 58 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:08-cv-80994-KAM Document 58 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A
+A.
+Villafaña
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-
diff --git a/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.receipt.json b/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c1185deb5309deb062ba7bd5ffdd1ddc5a298c5e
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+++ b/vision-fixhub/court-01/e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "e7bfd6472091af9b3df8f80896b7dfe0a4c9d991e50a2083055d86522451777e",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e48c7e66100d619edaf23ccd79cf25a5f78d54a385ba606210d05ac3c5cb70ee",
+  "output_sha256": "7dca324774cf9747f121bbc2d4903369c478c355566f714b066bbf4e5055f967",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b.md b/vision-fixhub/court-01/e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b.md
new file mode 100644
index 0000000000000000000000000000000000000000..930e38ed75c29552d206f586191a40c46bffbc49
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+++ b/vision-fixhub/court-01/e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b.md
@@ -0,0 +1,177 @@
+Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT'S NOTICE OF INDEPENDENT MEDICAL EXAMINATION OF
+PLAINTIFF, JANE DOE (80893)
+Defendant, JEFFREY E. EPSTEIN, pursuant to Rule 35, Fed. R. Civ. P., notices
+the Plaintiff for an independent/psychological medical examination and states:
+An appointment for examination of the Plaintiff has been made with Ryan
+•. M.D. of C.W.
+M.D., P.A. at 9:00 a.m. on October 13, 2009 at the law firm of
+Burman, Critton, Luttier and Coleman, LLP, located at 303 Banyan Boulevard, Ste. 400,
+West Palm Beach, FL, 33401. The Plaintiff is to wear comfortable clothing and bring a
+sweater. The examination shall consist of an interview and testing and will likely last
+until 5:30 p.m. See infra and Motion attached at DE (301) for scope, time and place of
+IME. See Exhibits attached as well.
+
+
+Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009 Page 2 of 4
+2.
+Plaintiff has not agreed to this date; however, unless a timely and valid
+objection to this Notice is made, the Plaintiff is required by this Rule to be in attendance
+at the above-scheduled examination.
+Pursuant to Rule 35, if the psychiatrist performing the examination is
+called as a witness, the psychiatrist shall not be identified as one appointed by the Court.
+The cost of the examination will be originally borne by the Defendant but
+is subject to taxation by the Court upon proper motion.
+5.
+The interview will be videotaped.
+6.
+Dr. Halls' specialties and qualifications are attached to the Motion
+to Compel the IME at DE (301). The time, place, manner, conditions and scope
+of the examination are attached to the Motion to Compel the IME at DE (301).
+See Affidavit attached thereto. All of the above documents have been provided
+to the Plaintiff's counsel and, therefore, sufficient notice has been made.
+By:.
+MICHAELS. PIKE, ESQ.
+Florida Bar #617296
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List ir
+he manner specified by CM/ECF on this /< day of September, 2005
+Respectily subopted,
+By: _
+ROBERT D! CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcfit@bclclaw.com
+
+
+Case 9:08-cV-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009 Page 3 of 4
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10** Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Jack Scarola, Esq.
+Jack P.
+• Esq.
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+
+
+Case 9:08-cv-80119-KAM Document 302 Entered on FLSD Docket 09/15/2009 Page 4 of 4
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Nos. 09-80591 and 09-80656
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant !!
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+jagesq@bellsouth.net
+Spencer T. Kuvin, Esq.
+Counsel for Defendant Jeffrey Epstein
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
diff --git a/vision-fixhub/court-01/e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b.receipt.json b/vision-fixhub/court-01/e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b7b093825babc08900a06218ff78462bae34c831
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@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
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+  "doc_id": "e7c2bd908638e42ff1c128765fb16d8c04fb22436c1e2b44f1c9d68107ff5d3b",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "01e09c76bdc94d6b9cf78c8db2947e6e0e406f6ad82938175d4e638b489b284a",
+  "output_sha256": "7d190c215272be69862f002f45220f4511b5d6cc527ad3bb71528ffd83af8dcb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e7da04d9b3f5101e75fc5353f6c6d807cbd3494f0b14bfca29f6f2dfed441a81.md b/vision-fixhub/court-01/e7da04d9b3f5101e75fc5353f6c6d807cbd3494f0b14bfca29f6f2dfed441a81.md
new file mode 100644
index 0000000000000000000000000000000000000000..4e6908c1920b17992598ee379001b95bec7faa35
--- /dev/null
+++ b/vision-fixhub/court-01/e7da04d9b3f5101e75fc5353f6c6d807cbd3494f0b14bfca29f6f2dfed441a81.md
@@ -0,0 +1,192 @@
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80119-CIV-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+/
+MOTION TO DISMISS
+Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of
+Civil Procedure and Rule 7.1(A) of the Local Rules for the Southern District of
+Florida, moves to dismiss Count I of plaintiff's complaint,' and states as follows:
+-
+' The time to answer the remaining allegations of the complaint is tolled pending the Court's
+ruling on the present motion.
+See Beaulieu v. Bd. of Trustees of Univ. of W. Fla., No.
+3:07cv30/RV/EMT, 2007 WL 2020161, * 2 (N.D. Fla. July 9, 2007) (holding that defendant's
+partial motion to dismiss "automatically extends its time to answer ... until after the court has
+ruled on [its] motion to dismiss"); Finnegan v. Univ. of Rochester Med. Ctr., 180 F.R.D. 247,
+249 (W.D.N.Y. 1998) (concluding "that the filing of a motion that only addresses part of a
+complaint suspends the time to respond to the entire complaint, not just to the claims that are the
+subject of the motion");
+v. Berry College, Inc., No. Civ.A. 4:96CV338-HLM, 1997 WL
+579166, *1 (N.D. Ga. July 3, 1997) (noting that there is significant case law to support the
+position that "when a defendant files a Rule 12(b) motion to dismiss, addressing only some of
+the claims contained in the plaintiff's complaint, the defendant is not required to file an answer
+until the court rules on the motion to dismiss").
+
+
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 2 of 8
+CASE NO.: 08-80119-CIV-MARRA/.
+ALLEGATIONS IN PLAINTIFF'S COMPLAINT
+This action arises out of the alleged assault of the plaintiff. According to the
+allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him
+"a massage for monetary compensation" (Compl. 1 12), where Mr. Epstein
+allegedly assaulted her "in violation of Chapter 800 of the Florida Statutes."
+(Compl. 1 18).
+The plaintiff tries to assert a claim for sexual assault (Compl. 11 15-19.)
+This theory of liability, however, cannot be supported by the allegations in the
+complaint. In fact, even if everything in the complaint were true, recovery against
+Jeffrey Epstein, for Count I, under any formulation, is impossible under Florida
+law. Accordingly, this count must be dismissed.
+ARGUMENT
+A motion to dismiss under Fed. R. Civ. P. 12(b)(6) should be granted when a
+court cannot identify "each of the material elements necessary to sustain a
+recovery under some viable legal theory." Snow v. DirectTV, Inc., 450 F.3d 1314,
+1320 (11th Cir. 2006) (quoting Roe v. Aware Woman Ctr. For Choice, Inc., 253
+F.3d 678, 684 (11th Cir. 2001)). Moreover, a court should dismiss a complaint
+"when, on the basis of a dispositive issue of law, no construction of the factual
+allegations will support a cause of action." Marshall County Bd. of Educ. v.
+Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "ITlo survive a
+2
+
+
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 3 of 8
+motion to dismiss, plaintiffs must do more than merely state legal conclusions;
+they are required to allege some specific factual bases for those conclusions . .…."
+Holt v. Crist, No. 06-14617, 2007 WL 1156938, *2 (11th Cir. Apr. 19, 2007). As
+such, "conclusory allegations, unwarranted deductions of facts or legal conclusions
+masquerading as facts will not prevent dismissal." Snow, 450 F.3d at 1320.
+Count I Fails to State a Cause of Action For Assault Recognized by
+Florida Law.
+The plaintiff attempts to plead a cause of action against Mr. Epstein for
+"sexual assault" based on a "violation of Chapter 800 of the Florida Statutes'? for
+the "lewd and lascivious acts committed by Epstein upon Jane Doe." (Compl. 1
+18.) Plaintiff cannot assert a cause of action for "violation of Chapter 800, Florida
+Statutes" because there is no private right of action under that Chapter. See
+generally Am. Home Assurance Co. v. Plaza Materials Corp.., 908 So. 2d 360, 374
+(Fla. 2005) (observing that "not every statutory violation carries a civil remedy"
+(citing Villazon v. Prudential Health Care Plan, Inc., 843 So. 2d 842, 852 (Fla.
+2003)). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Supp. 970 (S.D.
+Fla. 1985) (
+C.J.) (holding that violation of Florida's criminal extortion
+statute does not give rise to a civil cause of action for damages).
+2 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure."
+3
+
+
+Case 9:08-cV-80119-KAM Document 40 • Entered on FLSD Docket 09/04/2008 Page 4 of 8
+Where a plaintiff brings a civil action pursuant to a criminal statute that
+provides no civil remedy, her complaint is properly dismissed for failure to state a
+cause of action. See Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA
+1990) (per curiam) (affirming dismissal of plaintiff's claim for parental kidnapping
+where "the mentioned statutes concern only criminal violations and do not afford
+a civil remedy") (citation omitted) (emphasis added).
+Even if Chapter 800 provided a civil remedy (which it does not) the statute
+does not apply to the plaintiff. The statute prohibits sexual activity with or lewd or
+lascivious offenses against "a person ... less than 16 years of age." § 800.04, Fla.
+Stat. (2008) (emphasis added). By her own admission, the plaintiff was
+"approximately 16 years old." (Compl. 9| 8) (emphasis added). Plainly, the
+plaintiff falls outside of the scope of the statute's protection. Accordingly, the
+plaintiff's claim for sexual assault against Mr. Epstein, pursuant to a violation of
+Chapter 800, Florida Statutes, must be dismissed.
+Should the Court look beyond the plain language of the plaintiff's complaint
+and construe Count I as a claim for common-law assault, that claim would also
+fail. As the court explained in Lay v. Kremer, 411 So. 2d 1347, 1349 (Fla. Ist
+DCA 1982), an assault is "an intentional, unlawful offer of corporal injury to
+another by force, or force unlawfully directed toward another under such
+circumstances as to create a fear of imminent peril, coupled with the apparent
+4
+
+
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 5 of 8
+present ability to effectuate the attempt." An assault thus requires "an affirmative
+act—a threat to use force, or the actual exertion of force."
+v. Atl. Fed.
+Sav. & Loan Assoc., 454 So. 2d 52, 54 (Fla. 4th DCA 1984) (affirming dismissal of
+assault claim where there was no affirmative act).
+In this case, there is no such affirmative act. The only thing that Mr. Epstein
+is alleged to have said to the plaintiff is "to take off her clothes" and "to give him a
+massage." (Compl. 9| 12.) These allegations fall far short of an "offer of corporal
+injury by force." There are no allegations that Jane Doe was placed in any fear of
+imminent peril. See Gatto v. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla.
+3d DCA 1980) (holding that where there was no evidence to show that Gatto was
+placed in fear of imminent peril, there was no assault). In fact, the plaintiff does
+not even allege that Mr. Epstein touched her. Thus, there was no assault.
+Accordingly, because the plaintiff has failed to plead a cause of action for
+assault recognized in Florida, Count I against Mr. Epstein must be dismissed.
+Conclusion
+For the reasons set forth herein, Defendant Jeffrey Epstein respectfully
+requests that Count I of the plaintiff's complaint be dismissed.
+5
+
+
+Case 9:08-cV-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 6 of 8
+CASE NO.: 08-80119-CIV-MARRA/
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By: Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER &
+WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, Florida 33401
+Tel. 561 842 2820
+Fax. 561 515 3148
+6
+
+
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 7 of 8
+By: Robert D. Critton, Esq.
+Fla. Bar No. 224162
+rcritton@bclclaw.com
+Michael J. Pike, Esq.
+Fla. Bar No. 617296
+mpike@bclclaw.com
+Attorneys for Defendant Jeffrey Epstein
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Undersigned counsel has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+/s/ Michael R. Tein
+Michael R. Tein
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on September 4, 2008, I electronically filed the
+foregoing document with the Clerk of Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all individuals on the following
+service list via transmission of Notices of Electronic Filing generated by CM/ECF.
+/s/ Michael R. Tein
+Michael R. Tein
+7
+
+
+Case 9:08-cv-80119-KAM Document 40 Entered on FLSD Docket 09/04/2008 Page 8 of 8
+CASE NO.: 08-80119-CIV-MARRA/
+Service List
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+8
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e7da04d9b3f5101e75fc5353f6c6d807cbd3494f0b14bfca29f6f2dfed441a81.receipt.json b/vision-fixhub/court-01/e7da04d9b3f5101e75fc5353f6c6d807cbd3494f0b14bfca29f6f2dfed441a81.receipt.json
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 9,
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+}
diff --git a/vision-fixhub/court-01/e7f5bdbc8fff32f12d0ea33cb2b8b240ef6450f84d71e63cf126011ce77d4a6d.md b/vision-fixhub/court-01/e7f5bdbc8fff32f12d0ea33cb2b8b240ef6450f84d71e63cf126011ce77d4a6d.md
new file mode 100644
index 0000000000000000000000000000000000000000..1179e19b120b9e35b7dbb3fad2ad86e0d6cbd559
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+++ b/vision-fixhub/court-01/e7f5bdbc8fff32f12d0ea33cb2b8b240ef6450f84d71e63cf126011ce77d4a6d.md
@@ -0,0 +1,62 @@
+Case 1:19-cv-09610-PAE-DCF Document 41
+Filed 03/06/20 Page 1 of 2
+B BUZIN
+LAW p.c
+111 Broadway, Suite 1204
+New York, NY 10006
+Tel: (646) 470-4878
+Fax: (347) 736-9490
+www.buzinlaw.com
+Andrew S. Buzin*
+abuzin@buzinlaw.com
+*Admitted in NY, FL
+March 6, 2020
+Via ECE
+Hon. Debra C. Freeman
+Daniel
+Moynihan United States Courthouse
+500 Pearl Street
+New York, NY 10007
+Re:
+Index No.:
+File No.:
+Jane Doe 17 v. Indyke and Kahn, et al.
+1:19-cv-09610-PAE-DCF
+19-6711
+Dear Judge Freeman:
+for Jane Doe 17 in the above-referenced matter. We recently received correspondence from the
+elen indicating er desire to dischard us as heral, nam, sy Daid H. Bodie be are at or
+Weisman, Brodie, Starr & Margolies, P.A., and Alan Goldfarb and David Appleby of Alan
+Goldfarb, P.A. The case is presently stayed per Hon. Paul A. Engelmayer's order of January 9
+2020, which permitted the stay pending potential participation in the Epstein Victims
+Compensation Program.
+Based on the above, we respectfully request that Your Honor enter an order, pursuant to
+Naive and thelvis relieving myril and retailing orcha representation of Jane Doe 17. We
+This letter motion is being served upon Jane Doe 17 through counsel and upon all other
+parties.
+
+
+Case 1:19-cv-09610-PAE-DCF Document 41 Filed 03/06/20 Page 2 of 2
+We appreciate your consideration and, as always, please feel free to contact me with any
+questions or concerns.
+Very truly yours,
+ASB/me
+To:
+Jane Doe 17
+c/o David H. Brodie and Laura Starr
+Weisman, Brodie, Starr & Margolies, P.A.
+1301 N. Federal Highway
+Lake Worth, FL 33460
+David H. Brodie and Laura Starr
+Weisman, Brodie, Starr & Margolies, P.A.
+1301 N. Federal Highway
+Lake Worth, FL 33460
+Alan Goldfarb and David Appleby
+Alan Goldfarb, P.A.
+100 S.E. 2nd Street
+Miami Tower, 45th Floor
+Miami, FL 33131
+Bennet J. Moskowitz
+Troutman Sanders
+875 Third Avenue
+New York, NY 10022
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "059c7629a112c0af41a5afbe11f48317abf88ffcb2ff2084bc40e032555c6c99",
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e7fa06c19bebf588978d81c1c59a71c7f2fe18e3df25c1512be1dfc8a6da51e9.md b/vision-fixhub/court-01/e7fa06c19bebf588978d81c1c59a71c7f2fe18e3df25c1512be1dfc8a6da51e9.md
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@@ -0,0 +1,303 @@
+Case 9:08-cV-80381-KAM Document 15-1 Entered on FLSD Docket 07/01/2008 Page 1 of 4
+
+
+
+Case 9:08-CV-80381-KAM Document 15-1 Entered on FLSD Docket 07/01/2008 Page 2.of 4
+CASE
+80 :
+5020060FD09454AXXX. ET CF TE, V$.
+JEFFREY E. EPSTEIN
+241
+Chazges
+SE CONNET PROBTITUNDO
+ARTEST 9
+
+3730708.60
+13006
+W/WO Def. Co.
+
+5. 32000.09
+DATES
+ASA
+Deft---Pres Not Pres.:
+GotT
+22901
+Esq./ PD.
+-Pres / Not Pres,
+Before the Court for
+• Denied • With / Without Prejudice
+• Withdrawn
+O Ordered
+• Recalled
+• Bond Forf
+DOR: Disch/Revoked/Reinstated
+[ Bond: Disch/Revoked"
+• Bond Forf Vacated
+• Previous Bond Reinstated, if Bondsman agrées
+• Deft _ Indigent
+• PD Appt
+• Hig only
+. PD Pres
+• Court Reserves Ruling
+• Written Order to Follow
+• See Below
+•Also Covers. Sp Cond
+OSOR: Disch/Revoked/Reinstated
+• State failed to file charges • - Released O.R. / S.O.R.
+• Court Appts
+Evaluation for:
+• Drug Farm
+• DOC Non-Secure Bed by
+• PSI ordered by/within
+w/input from DIJ / Staffing
+Referred to: PTI / SAAP /PADD
+• Case placed on the absentee docket
+DEFT ENTERED A PLEA OF:
+• NOT GUILTY
+$ GUILTY
+• NO CONTEST O BEST INTEREST. O TO THE COURT
+As Charged-Cts
+Lesser Charge
+a Ady of Rts
+& Waived PSI
+Lesser Cts
+Lesser Charge
+ADJ GUILTY as Charged as to Cts.
+FOUND GUILTY as Charged as to Cts
+ADJ W/HELD as to Cts
+• SENT W/HELD as to Cts
+FOUND AND ADJUDICATED DELINQUENT as to Cts
+•Dispo Onderto follow /Filed
+FOUND & ADJ NOT GUILTY as to Cts
+• Dismiss
+• Revoked
+• Reinstat
+• Modified
+SENTENCE: (PiC) abill: 775.084
+Successfully / Unsuccessfully
+Sexua Offent Sexual Predator
+• Stip/Found: P.R.R.
+SENTENCE:
+lays /-Mes:+YTS.
+A Deft Remanded O Deft to remain on same rel. status pending sent.
+'onc / Consec / Co-Term w/cases
+• Execution of Sentence Stayed
+• Sentence Suspended • Time served as to Cts
+• Youthful Off • Habitual Off. • Min/ Mand:
+- as to Cts
+• ABOVE SENTENCE TO BE FOLLOWED By: O Probation
+• Drug / Sex Off Prob • Comm. Control DI
+- See Pg. 2
+DRIVERS LICENSE TO BE SUSPENDED / REVOKED FOR
+YEARS AS A RESULT OF THIS PLEA.
+DUA SWAB
+Set / Remains Set / Reset
+Div.
+Rm
+at -
+AM/PM
+Set / Remains Set / Reset:
+Div..
+Rm.
+at
+AM/PM
+• Deft sign
+• Def Co
+• ASA —
+• Bondsman
+• Prob
+• Jail
+• DIJ O GAL
+Notified by mail by:-
+- оП
+• County Courthouse
+Courtroom, Criminal Justice Bldg-
+Courtroom, Criminal Justice Complex
+205 N. Dixie, West Palm Beach
+38844 State Road 80, Belle Glade
+3228 Gun Club Rd., West Palm Beach
+IF YOU ARE A PERSON WITH A DISABILITY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS PROCEEDING YOU ARE ENTITLED, AT NO COST TO YOU, TO THE PROVISION OF
+CERTAIN ASSISTANCE. PLEASE CONTACT MARY JAFFE, ADA COORDINATOR IN THE ADMINISTRATIVE OFFICE OF THE COURT, PALM BEACH COUNTY COURTHOUSE, 205 N. DIE HWY, RM 5.2500,
+WEST PALM BEACH, FL 33401; TELEPHONE (561) 355-4380, WTTHIN 2 WORKING DAYS OF YOUR RECEIPT OF THIS NOTICE. IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 1-800-955-8771.
+Form 611 EDP Rev 12/06
+
+
+Case 9:08-CV-80381-KAM Document 15-1. Entered on FLSD Docket 07/01/2008 Page 3 of 4
+Case No.:
+2008CP009381AXX
+Charges:
+PROCURE PERSON
+UNDER
+ST of FL vs.
+AGE OF
+18 FOR PROSTITOTION
+JEPFREY SPOTEIN
+(ARISZS PROM
+2006CP0094543XX)
+Arrest# -
+Bond#
+Type
+\A/C
+Date
+Judge
+Crt. Rep.
+ASA
+-Defi... Pres/ Not Pres.
+Pre a 0 4 1.06
+EDBERGER
+Int
+Esq (PD--Pres/ Not Pres.
+Before the Court for:
+• Granted
+• Denied With / Without Prejudice
+• Withdrawn
+• Court Reserves Ruling
+• Written Order to Follow
+• Warrant
+• Ordered
+• Recalled
+• Bond Set at $
+D. See Below
+• Also Covers O Sp Cond
+D. Bond Forf
+OOR: Disch / Revoked / Reinstated
+• Bond: Disch / Revoked
+• SOR: Disch / Revoked / Reinstated
+O Bond Forf Vacated • Previous Bond Reinstated, if Bondsman agrees. 7 State failed to file charges • O Released O.R. /S.O.R.
+• Deft _ Indigent O PD Appt
+• Hrg only PD Pres
+• Court Appts
+Evaluation for: O Drug Farm
+• DOC Non-Secure Bed by
+• Pre-Plea
+O PSI ordered by/within
+days.
+• w/input from DJJ / Staffing
+• Referred to: PTI / SAAP/PADD l
+• Case placed on the absentee docket
+DEFT ENTERED A PLEA QF:
+• NOT GUILTY. I
+O'GULTY O NO CONTEST: O BEST INTEREST TO TO THE COURT
+As Charged-Cts
+Lesser Cts
+| Sw & Test JJ Adr of Ris
+T. Lesser Charge
+C Waived PSI
+Lesser Cts
+- Lésser Charge
+Q ADI GUILTY as Charged as to Cts .
+CLAY
+Lesser Cts
+• FOUND GUILTY as Charged as to Cts
+Lesser Cts
+• ADJ W/HELD as to Cts
+• SENT W/HELD as to Cts
+O FOUND AND ADJUDICATED DELINQUENT as to Cts :
+• Dispo Order to follow / Filed
+• FOUND & ADJ NOT GUILTY as to Cts
+• Dismiss : • Nolle Prosse Cts
+Prob / Comm Control:
+.• Reinstated
+• Modified.
+• Term: Successfully / Unsuccessfully • *
+• Deft. to pay fine or complete
+hrs. Community Service or Serve
+• Stip/Found: (violent) Habitua] Off. 775.084
+• Stip/Found: Sexual Offender / Sexual Predator
+• Stip/Found: P.R.R:
+PBCJL2127
+4 W/Credit for
+Days / Mos. / Yrs.
+Conc /Consecy Co-Term w/cases Yets. 1221:1.
+granded: • Deft to remain on same rel: status pending sent.
+• Execution of Sentence Stayed
+• Sentence Suspended • Time served as to Cts
+• Youthful Off • Habitual Off • Min/ Mand:
+L ABOVE SENTENCE TO BE FOLLOWED By: • Probation: • Drug Off Prob
+Comm. Control 1 O 1- See Page 2)
+- Set / Remains Set / Reset.
+. Div
+- Rm
+•at
+- AM/PM
+Set / Remains Set / Reset
+Div_
+Rm.
+al
+AM/PM
+• Deft sign
+• Def Co
+O ASA
+] Bondsman
+• Prob
+• Jail O DJI. • GAL Notified by mail by:
+on
+• County Courthouse
+• Courtroom, Criminal Justice Bldg.
+Courtroom, Criminal Justice Complex
+205 N. Dixie, West Palm Beach
+: 38844 State Road 80, Belle Glade
+3228 Gun Club Rd., West Palm Beach
+IF YOU ARE A PERSON WITH A DISABILTY WHO NEEDS ANY ACCOMMODATION IN ORDER TO PARTICIPATE IN THIS PROCEEDING, YOU ARE ENTITLED, AT NO COST TO YOU, TO THE PROVISION OF
+CERTAIN ASSISTANCE. PLEASE CONTACT ROBIN SHEPETT, ADA, COORDINATOR IN THE ADMINSTRATIVE OFFICE OF THE COURT, PALM BEACH COUNTY COURTHOUSE, 205 N. DIXIE HWY, RM 5,2500,
+WEST PALM BEACH, FL 33401; TELEPHONE (561) 355-4380, WITHIN 2 WORKING DAYS OF YOUR RECEIPT OF THIS NOTICE. IF YOU ARE HEARING OR VOICE IMPAIRED, CALL 1-800-955-8771.
+Form 611-snap 1ev-3/02--
+
+
+Case 9:08-CV-80381-KAM Document 15-1 Entered on FLSD Docket 07/01/2008 Page 4 of 4
+DATE:
+6/30/08
+CASE NO.
+0080= 1831xxy
+-Page 2
+TERM OF Prob / Sex Off / Drug Off Prob// C.C. I) C.C. II:
+• conc w/ • consec. w/
+NAME
+mos / yrs-as tó Cts.
+• Probation transferred to:
+SPECIAL CONDITIONS:
+• Complete Originally Ordered Conditions
+• Curfew:
+p.m., with the following exception:
+Deft. to report to Prob. Dept. immediately upon release
+•. Deft. not țo have in care, custody, or control any unlawful of illegal material, subst., device, or object.
+Deft. to immediately notify Prob. Officer if place of residence or job changes.
+Restitution CRO filed
+• Subject to all ordinary and special conditions of Probation
+• Substance Abuse Eval. / Psychological Eval: / Psychosexual Eval. within / by:
+and deft. to successfully complete recommended treatment
+Random Drug/Alcohol Testing
+• At Deft's Expense
+• Costs Waived
+No Consumption/Possession of Alcohol or Drugs or Intoxicants without a Prescription.
+Attend
+AA and/or NA Meetings per. Week:
+• Deft. not to frequent any place of business whose primary purpose is the sale of alcohol. "
+Complete -
+_Hrs. of Community Service to be done at the rate of
+Hrs. per Wk / Mo.(Min.)
+License Revoked / Suspended for
+_ mos / yrs
+Attend and successfully complete DUl school and 1 session of Victim Impact Panel
+• No Contact / No Violent Contact / No Direct or Indirect contact w/Victim(s) or others listed: -
+• No Contact w/Minor Children w/o Adult Supervision aware of this case and the disposition:
+• Cost of Supervision: $
+_ per month
+• Waived by Court.
+• Enter and Successfully Complete DOC Non-Secure Bed Program and Any Recommended Aftercare.
+• Hold in Custody, release only to DOC Non-Secure Bed Program Officer.
+• Enter and Successfully Complete PBSO Long / Short Track Drug Farm and Any Rec: Aftercare.
+• Forfeit Weapon / Money seized at the time of arrest to:
+Enter and Complete:
+• Anger Management Program
+• Theft Abatement Program:
+Defendant may apply for Early Termination after
+Serve
+days / months in PBCJ, with credit for
+Batterers Intervention Program
+Other:
+; provided all conds. are satisfied
+days / months.
+* See all Aliched, Documents
+* Dori mst mminens: Seria Offerine.
+FORM 373 rev 3/02
diff --git a/vision-fixhub/court-01/e7fa06c19bebf588978d81c1c59a71c7f2fe18e3df25c1512be1dfc8a6da51e9.receipt.json b/vision-fixhub/court-01/e7fa06c19bebf588978d81c1c59a71c7f2fe18e3df25c1512be1dfc8a6da51e9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..87f1528e7ecc50833b5d0717dfe8b18d17fd13ee
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+++ b/vision-fixhub/court-01/e7fa06c19bebf588978d81c1c59a71c7f2fe18e3df25c1512be1dfc8a6da51e9.receipt.json
@@ -0,0 +1,14 @@
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+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
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diff --git a/vision-fixhub/court-01/e80c8430f89106ceb354d9df79c93663d2cb26b936985d9fabbcf77205b2943c.md b/vision-fixhub/court-01/e80c8430f89106ceb354d9df79c93663d2cb26b936985d9fabbcf77205b2943c.md
new file mode 100644
index 0000000000000000000000000000000000000000..cb64c11b57ab7f822b157ead3a23acb8d183af7d
--- /dev/null
+++ b/vision-fixhub/court-01/e80c8430f89106ceb354d9df79c93663d2cb26b936985d9fabbcf77205b2943c.md
@@ -0,0 +1,22 @@
+Case 9:08-cv-80736-KAM Document 70 Entered on FLSD Docket 04/18/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/JOHNSON
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER GRANTING MOTION FOr JAY LEFKOWITZ TO
+APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST
+To ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING
+THIS CAUSE came before the Court on the motion for attorney Jay Lefkowitz to appear
+Pro Hac Vice and to receive electronic notices of filing. For good cause shown, it is
+ORDERED AND ADJUDGED that the motion is GRANTED. Jay Lefkowitz, Esq. is
+granted admission to appear and participate in this action on behalf of the proposed intervenors.
+The Clerk shall provide electronic notification of all electronic filings to Jay Lefkowitz, Esq. at
+lefkowitz@kirkland.com
+DONE AND ORDERED in West Palm Beach, Florida on April 18, 2011
+KENNETH MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to all counsel of record
diff --git a/vision-fixhub/court-01/e80c8430f89106ceb354d9df79c93663d2cb26b936985d9fabbcf77205b2943c.receipt.json b/vision-fixhub/court-01/e80c8430f89106ceb354d9df79c93663d2cb26b936985d9fabbcf77205b2943c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b2f19dce807943beac6caddc47109703eaed9ca4
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee.md b/vision-fixhub/court-01/e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..f694703eb1e10b5666d1807e7e497393704ec77a
--- /dev/null
+++ b/vision-fixhub/court-01/e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee.md
@@ -0,0 +1,39 @@
+Case 9:08-cv-80119-KAM Document 494 Entered on FLSD Docket 03/19/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON JOINT MOTION FOR AN EXTENSION OF TIME
+TO COMPLETE DISCOVERY DEADLINES AND SHORTEN EXPERT
+DISCLOSURES
+This matter came before the Court on a Joint Motion for Extension of Time to
+Complete Discovery Deadlines and Shorten Expert Disclosures. Having considered the
+Joint Motion it is HEREBY ORDERED and ADJUDGED that the motion is GRANTED
+as follows:
+1.
+Jane Does 2-4 discovery cutoff is extended to April 30, 2010 and the parties will
+exchange their expert reports on or before May 14, 2010.
+2.
+Jane Does 5-7 discovery cutoff is extended to June 6, 2010 and the parties will
+exchanges their expert reports on or before June 6, 2010.
+DONE and ORDERED this 18 day of mAeCH
+_ 2010.
+Kenneth A. Marra
+United States District Judge
+
+
+Case 9:08-cv-80119-KAM Document 494 Entered on FLSD Docket 03/19/2010 Page 2 of 2
+08-CIV-80119-Marra
+Related cases 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+Page 2
+Courtesy Copies:
+Counsel of Record
diff --git a/vision-fixhub/court-01/e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee.receipt.json b/vision-fixhub/court-01/e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..079b02eba663b7638e78d25b2a70f1c4f56b2ba3
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@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
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+  "doc_id": "e82138f1ad4df06872a267a1b2fc68dcd5fe0f3f65d2c6c9e819fd58465ec9ee",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8fca225f2e866ef34fd68e21966d9ac96cb372d6f21875ec4f365eed4e966066",
+  "output_sha256": "2c7fad75396128ec1087f9df47d150bb11f20efa87937c46133b968e737dade0",
+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e8294f7ea424a462f7e498821f2744b41ed476d67f52d2da74d0df23a889d3b9.md b/vision-fixhub/court-01/e8294f7ea424a462f7e498821f2744b41ed476d67f52d2da74d0df23a889d3b9.md
new file mode 100644
index 0000000000000000000000000000000000000000..0cc1a3fb821f9797a879d8833bbf9acc4999b800
--- /dev/null
+++ b/vision-fixhub/court-01/e8294f7ea424a462f7e498821f2744b41ed476d67f52d2da74d0df23a889d3b9.md
@@ -0,0 +1,40 @@
+Case 1:20-cv-00484-JGK-DCF Document 6 k
+Filed 01/21/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+-against-
+DARREN | INDYKE and RICHARD D. KAHN, in their
+capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+Defendant.
+1:20 Civ.
+00484(
+MOTION FOR ADMISSION
+PRO HAC VICE
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern and Eastern
+Robert Samuel Glassman, Esq.
+hereby move this Court
+Districts of New York,
+for an Order for admission to practice Pro Hac Vice to appear as counsel for
+Plaintiff, Jane Doe
+_in the above-captioned action.
+I am in good standing of the bar(s) of the state(s) of_
+California, District of Columbia
+_and
+there are no pending disciplinary proceedings against me in any state or federal court. I have
+never been convicted of a felony. I have never been censured, suspended, disbarred or denied
+admission or readmission by any court. I have attached the affidavit pursuant to Local Rule 1.3.
+Dated: January 16, 2020
+Respectfully Submitted,
+Robert Samuel Glassman
+Applicant Signature: R-Ola
+Applicant's Name:
+Robert Samuel Glassman
+Firm Name:__Panish Shea & Boyle LLP
+Address:_
+11111 Santa Monica Blvd., Suite 700
+City/State/Zip:_ Los Angeles, CA 90025
+Telephone/Fax: 310-477-1700 / 310-477-1699
+Email:_glassman@psblaw.com
diff --git a/vision-fixhub/court-01/e8294f7ea424a462f7e498821f2744b41ed476d67f52d2da74d0df23a889d3b9.receipt.json b/vision-fixhub/court-01/e8294f7ea424a462f7e498821f2744b41ed476d67f52d2da74d0df23a889d3b9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..34914167af09334d353ae6144875da9a45f45681
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "1ce861287052766705654fcd908ecc79f5b86c6c2c4317ae4661e27031471cf3",
+  "output_sha256": "578d5f455078ca346c599e2a124ebee9c9da12c9a2d36a6ca92e6d2210ddbd3e",
+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.md b/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.md
new file mode 100644
index 0000000000000000000000000000000000000000..3de7161731e9a27241da0de78ee0467420a6d3fb
--- /dev/null
+++ b/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.md
@@ -0,0 +1,120 @@
+Case 9:08-cv-80381-KAM Document 38 Entered on FLSD Docket 08/05/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER DENYING MOTION TO STAY
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Stay
+(DE 11), filed June 20, 2008. The motion is now fully briefed and is ripe for review. The Court
+has carefully considered the motion and is otherwise fully advised in the premises.
+Defendant Jeffrey Epstein ("Defendant") seeks a stay of this civil action under a federal
+statute which reads, in pertinent part, as follows:
+damage or injury to the person of a child exists, a criminal action is
+sending which arises out of the same occurrence and in which the child is
+the victim, the civil action shall be stayed until the end of all phases of the
+criminal action and any mention of the civil action during the criminal
+proceeding is prohibited. As used in this subsection, a criminal action is
+pending until its final adjudication in the trial court.
+18 U.S.C. § 3509 (k). In his motion, Defendant cites a state case, Florida v. Epstein, No. 2006
+1
+
+
+Case 9:08-cv-80381-KAM Document 38 Entered on FLSD Docket 08/05/2008 Page 2 of 5
+CF 09454AXX (Fla. Cir. Ct. 2008)' and a federal case, In re Grand Jury, No. FGJ 07-103(WPB)
+(S.D. Fla.), that arise out of the same occurrences and are pending and thus require a stay of this
+civil case. The federal "case," according to Defendant, involves a "deferred-prosecution"
+agreement whereby the U.S. Attorney agreed to suspend its investigation of Defendant while
+"retaining the right to reactivate the grand jury." (DE 28.) Defendant essentially reasons,
+because the U.S. Attorney could bring criminal charges against Defendant, that a criminal action
+is "pending." The Court rejects this definition of a "pending criminal action."
+When interpreting the text of a statute, the Court begins with the plain meaning of the
+text. In re
+524 F.3d 1175, 1186 (11" Cir. 2008). If the plain meaning of a statute is
+clear, the Court should not deviate from that interpretation. Id. Pending is defined as "remaining
+undecided" and "awaiting decision." Blacks Law Dictionary (8"' ed. 2004).- Likewise, an
+'As Defendant recognizes, the state court case was "finally adjudicated" and thus no
+longer pending as of June 30, 2008. (See DE 19.)
+"Defendant attempts to argue that the fact that grand jury subpoenas are still
+"outstanding" and "not withdrawn" and that the grand jury will not be dismissed until Defendant
+completes his obligations under the state plea agreement means that a "criminal action" is
+"pending." (Def. Reply 4.) Defendant misunderstands the purpose of a grand jury. A grand
+jury's sole purpose is to inquire into whether there is probable cause to bring an individual before
+a tribunal to determine his guilt or innocence of an alleged crime. Id. The grand jury is simply
+an investigative body. See U.S. v. Alred, 144, F.3d 1405, 1413 (11" Cir. 1998). A "criminal
+action" is not instigated by the calling of a grand jury, because a grand jury is convened "to
+determine whether a crime has been committed and whether criminal proceedings should be
+instituted against any person." U.S. v. Calandra, 414 U.S. 338, 344 (1974). An "action" is
+commenced against a person after the grand jury actually finds probable cause to make an
+individual answer specific charges and renders a bill of indictment against that individual. Until
+a grand jury's investigation is complete and there has been a determination by a lawful authority
+that probable cause exists, there can be no criminal action.
+2
+
+
+Case 9:08-cv-80381-KAM Document 38 Entered on FLSD Docket 08/05/2008 Page 3 of 5
+"action" is defined as a "criminal judicial proceeding." Id. Because the U.S. Attorney has not
+filed an indictment or an information against Defendant, the Court fails to see how there is an
+undecided judicial proceeding in federal court against Defendant.
+Defendant argues that this statute should be read to include the definition of "criminal
+action" used in 18 U.S.C. § 1595(b)(2), which reads as follows: "In this subsection, a 'criminal
+action' includes investigation and prosecution and is pending until final adjudication in the trial
+court." Defendant argues that "Congress specifically intended that the term "criminal action'
+would be applied extremely broadly" under § 1595, so Congress "took pains to ensure that courts
+would give it the broadest possible construction" and defined "criminal action" as including
+investigatory stages. (Def. Reply 4.) Defendants argue that the Court should borrow this
+definition.
+The Court disagrees. The Court believes that Congress's inclusion of this broader
+definition under § 1595 evinces Congressional intent to depart from the normal meaning of the
+term "criminal action.". This addition to the text suggests that Congress knows the plain
+meaning of the term "criminal action" and that Congress decided, under § 1595, that the
+definition of "criminal action" should be broader. In contrast, Congress could have made such an
+addition to § 3509 had it intended the mandatory stay provision to apply to pre-indictment
+investigations, but it did not. In other words, by not broadening the definition of "criminal
+action" § 3509, Congress intended that the term should only have its ordinary meaning: that an
+indictment or information has been filed naming a specific defendant. Instead, it seems clear that
+'In fact, Congress made this intent clear by stating that this broader definition of a
+"criminal action" applied only "in this subsection."
+3
+
+
+Case 9:08-cv-80381-KAM Document 38 Entered on FLSD Docket 08/05/2008 Page 4 of 5
+Congress intended that these two statutory provisions should each have a different scope.
+Defendant's argument of statutory construction fails.
+The single case cited by Defendant in support of his motion is not on point. In Doe 1 v.
+Francis, No. 5:03CV260/MCR/WCS, 2005 WL 517847 (N.D. Fla. Feb. 10, 2005), the stay was
+entered because criminal charges had been filed against the defendant in a state court several
+months earlier (i.e., the defendants had been indicted by the state attorney). See Memorandum in
+Support of Motion to Stay Proceedings Pending Outcome of Parallel Criminal Proceedings at 3,
+Doe 1 v. Francis, No. 5:03CV260/MCR/WCS (N.D. Fla. Dec. 2, 2003). The Court agrees with
+Defendant that a stay under § 3509(k) is mandatory when a criminal action is pending; the Court
+simply disagrees that the "deferred-prosecution agreement" constitutes a pending criminal action.
+The Court also does not believe a discretionary stay is warranted. Defendant did not seek
+this relief in his motion; including such a request in the reply brief is inappropriate. Further, the
+Court sees no reason to delay this litigation for the next thirty-three months. After all, Defendant
+is in control of his own destiny - it is up to him (and him alone) whether the plea agreement
+reached with the State of Florida is breached. If Defendant does not breach the agreement, then
+he should have no concerns regarding his Fifth Amendment right against self-incrimination. The
+fact that the U.S. Attorney (or other law enforcement officials) may object to some discovery in
+these civil cases is not, in an of itself, a reason to stay the civil action. Any such issues shall be
+resolved as they arise in the course of this litigation.
+Accordingly, it is ORDERED AND ADJUDGED as follows:
+1. Defendant's Motion to Stay (DE 11) is DENIED.
+2. Defendant's Motion for Hearing (DE 31) is DENIED AS MOOT.
+4
+
+
+Case 9:08-cv-80381-KAM Document 38 Entered on FLSD Docket 08/05/2008 Page 5 of 5
+3. Plaintiff's Motion for an Extension of Time to File Response (DE 22) is GRANTED NUNC
+PRO TUNC.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 4" day of August, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+5
diff --git a/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.receipt.json b/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..43ad5b6be6f7fef591009dd5068dbc9200afcf73
--- /dev/null
+++ b/vision-fixhub/court-01/e8430826f1902d204deeb81d045a26a824793071282698e671cd923799dcba8a.receipt.json
@@ -0,0 +1,14 @@
+{
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+}
diff --git a/vision-fixhub/court-01/e86d372acf4727758f12f601b1c64d9fc7875d4ce36bc68488293ab31d366e94.md b/vision-fixhub/court-01/e86d372acf4727758f12f601b1c64d9fc7875d4ce36bc68488293ab31d366e94.md
new file mode 100644
index 0000000000000000000000000000000000000000..e540f2b8a6f646f1e57a56b15662952e8cd7b764
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@@ -0,0 +1,162 @@
+Filing # 98941846 E-Filed 11/15/2019 11:18:53 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.:
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+COPY
+Defendants.
+VERIFIED MOTION FOR ADMISSION TO APPEAR PRO HAC VICE PURSUANT TO
+FLORIDA RULE OF JUDICIAL ADMINISTRATION 2.510
+COMES NOW Michael Grygiel, Moyant herein, and respectfully represents the following:
+Movant resides in Saratoga County, State of New York.
+2.
+Movant is an attorney and a Shareholder of the law firm of Greenberg Traurig, LLP,
+with offices at 54 State Street, 6th Floor, Albany, New York 12207, telephone number (518) 689-
+1406.
+3.
+Movant has been retained personally or as a member of the above-named law firm
+on or about August 28, 2019, by plaintiff CA Florida Holdings, LLC, publisher of the Palm Beach
+Post to provide legal representation in connection with matters related to the above-styled action
+now pending before the above-named court of the State of Florida.
+4.
+Movant is an active member in good standing and currently eligible to practice law
+in the following jurisdiction(s):
+-.-
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/15/2019 11:18:53 AM
+
+
+Court
+Bar Number
+State of New York
+
+District of Columbia
+
+State of Vermont
+3154
+United States Supreme Court
+
+Admitted
+8/28/1989.
+3/7/1990
+4/8/1996
+5/13/2019
+There have been no disciplinary, suspension, disbarment, or contempt proceedings
+initiated against Movant in the preceding 5 years.
+6.
+Movant, either by resignation, withdrawal, or otherwise, never has terminated or
+attempted to terminate Movant's office as an attorney in order to avoid administrative, disciplinary,
+disbarment, or suspension proceedings.
+Movant is not an active member of The Florida Bar.
+8.
+Movant is not now a member of The Florida Bar.
+9.
+Movant is not a suspended member of The Florida Bar.
+Movant is not a disbarred member of The Florida Bar nor has Movant received a
+disciplinary resignation from The Florida Bar.
+11.
+Movant has not previously been disciplined or held in contempt by reason of
+misconduct committed while engaged in representation pursuant to Florida Rule of Judicial
+Administration 2.510.
+12.
+Movant has not filed a motion to appear as counsel in Florida state courts during
+the past five years.
+13.
+Local counsel of record associated with Movant in this matter is Stephen A.
+Mendelsohn who is an active member in good standing of The Florida Bar and has offices at
+Greenberg Traurig, P.A., 51 Town Center Circle, Suite 400, Boca Raton, Florida 33486, telephone
+number (561) 955-7600.
+2
+--
+
+
+Movant has read the applicable provisions of Florida Rule of Judicial
+Administration 2.510 and Rule 1-3.10 of the Rules Regulating The Florida Bar and certifies that
+this verified motion complies with those rules.
+Movant agrees to comply with the provisions of the Florida Rules of Professional
+Conduct and consents to the jurisdiction of the courts and the Bar of the State of Florida.
+WHEREFORE, Movant respectfully requests permission to appear in this court for this
+cause only.
+DATED this 12 day of November, 2019.
+54 State Street, 6' Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+Email: grygielm@gtlaw.com
+STATE OF NEW YORK
+) ss:
+COUNTY OF ALBANY
+I, Michael J. Grygiel, do hereby swear or affirm under penalty of perjury that I am the
+Movant in the above-styled matter; that I have read the foregoing Motion and know the contents
+thereof, and the contents are true of my own knowledge and belief.
+Michel J. Grygie
+Sworn to belore me
+This | 2-day of November, 2019.
+Coolin
+Noinry Public
+AUTUMN
+Notary Paiblic, Stata of Now York
+Qubiified in Saratoga County:
+No: 01WH60G6256
+Commission Expiras Nov: 13, 20.21
+3
+
+
+CERTITICATE OF LOCAL COUNSEL
+I hereby consent to be associated as local counsel of record in this cause pursuant to Florid
+Rule of Judicial Administration 2.510
+DATED November 12, 2019.
+Is Stephen 1. Mendelsohn
+Florida Bar Number: 849324
+reenberg Traurig, P.A
+5100 Town Center Circle, Suite 40(
+Boca Raton, FL 33486
+Telephone: (561) 955-7600
+Facsimile: (561-338-7099
+Email: sanchezfo@gtlaw.com
+NOT A CERTIFIE®
+4
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on November 12, 2019, a true and correct copy of the foregoing
+Is/ Stephen A. Mendelsohn
+Stephen A. Mendelsohn
+ACTIVE
+47104667v1
+NOT A CERTIFIED CO
+5
+-.-
+
+
+SUPREME COURT OF
+THE STATE OF NEW YORK
+APPELLATE DIVISION, FOURTH DEPARTMENT
+ROCHESTER, NEW YORK
+I, ALAN L.
+1, Deputy Clerk of the Appellate Division of
+the Supreme Court in the Fourth Judicial Department, State of
+New York, do hereby certify that
+Michael J. Grygiel
+was duly admitted to practice as an attorney and counselor at
+law in all courts of this state by this Court on August 28, 1989,
+and appears in good standing upon the roll of attorneys and
+counselors, and other records, in this office and has registered
+with the administrative office of the Courts as required by
+Judiciary Law §468-a.
+COURT APPELLATE
+AR
+TMENT
+IN WITNESS WHEREOF, I have
+hereunto set my hand and affixed the
+seal of this Court, at the City of
+Rochester, November 12, 2019
+- Aila 2 on
+Deputy Clerk of the Court
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e86d372acf4727758f12f601b1c64d9fc7875d4ce36bc68488293ab31d366e94.receipt.json b/vision-fixhub/court-01/e86d372acf4727758f12f601b1c64d9fc7875d4ce36bc68488293ab31d366e94.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..46ae2449d2e53863dad61fd16f39fededed3d567
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+++ b/vision-fixhub/court-01/e86d372acf4727758f12f601b1c64d9fc7875d4ce36bc68488293ab31d366e94.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "eee4e30a6a41a253b68005c459e99c20b1d98d8663c909ed98d6b81e26be68f4",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e876a2cd9ad1220a2b9e20244da1d4741dd7c9259427109d1fdc3369bc270bff.md b/vision-fixhub/court-01/e876a2cd9ad1220a2b9e20244da1d4741dd7c9259427109d1fdc3369bc270bff.md
new file mode 100644
index 0000000000000000000000000000000000000000..da50236b786fc5f72e87859bab0aa54cbe3819ea
--- /dev/null
+++ b/vision-fixhub/court-01/e876a2cd9ad1220a2b9e20244da1d4741dd7c9259427109d1fdc3369bc270bff.md
@@ -0,0 +1,150 @@
+Entered on FLSD Docket 04/05/2011 Page 1 of 5
+FILING FEE
+IPAO $7510
+(Pro hac
+Vice.
+16719
+steven M. Larimore. Clerk
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+APR 0 4 2011
+STEVEN M. LARIMORE
+CLERK U.S. DIST. CT.
+S. D. of FLA. - MIAMI
+v.
+UNITED STATES OF AMERICA,
+Defendant.
+MOTION TO APPEAR PRO HAC VICE,
+CONSENT TO DESIGNATION, AND REQUEST TO
+ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING
+In accordance with Local Rule 4(b) of the Special Rules Governing the Admission and
+Practice of Attorneys of the United States District Court for the Southern District of Florida, the
+undersigned Roy Black, of Black, Srebnick, Kornspan & Stumpf, P.A.., respectfully moves for the
+admission pro hac vice of attorney
+Weinberg of
+G. Weinberg P.C., 20 Park Plaza,
+Suite 1000, Boston,
+02116, Telephone: (617) 227-3700, for purposes appearing as counsel on
+behalf of proposed intervenors in this case. Pursuant to Rule 2B of the CM/ECF Administrative
+Procedures, undersigned also requests that the Court permit attorney Weinberg to receive electronic
+filings in this case. In support, undersigned states:
+Weinberg is a member in good standing of the Massachuset State Bar and of the
+United States District Court of the District of Massachusetts.
+2. Movant, Roy Black, is a member in good standing of The Florida Bar and of the Bar of
+this Court. He maintains an office in Miami for the practice of law, and is authorized to file
+pleadings through the Court's electronic filing system. Movant consents to be designated as a
+
+
+Case 9:08-cv-80736-KAM Document 55 Entered on FLSD Docket 04/05/2011 Page 2 of 5
+member of the Bar of this Court with whom the Court and opposing counsel may readily
+communicate regarding the conduct of the case, upon whom filings shall be served, who shall be
+required to electronically file all documents and things that may be filed electronically, and who shall
+be responsible for filing documents in compliance with CM/ECF Administrative Procedures.
+3. Attorney Weinberg has paid the $75 admission fee. A certification in accordance with
+Rule 4(b) is attached, as well as a Certificate of Good Standing from the Massachusetts Bar.
+4. Mr. Weinberg, by and through designated counsel and pursuant to Section 2B of this
+Court's CM/ECF Administrative Procedures, requests that the Court provide Notices of Electronic
+Filings to Mr. Weinberg at the following email address: owlmgw@att.net.
+5. Accordingly, the undersigned moves this Court to enter an Order permitting
+Weinberg, Esquire to appear before this Court on behalf of the proposed intervenors and directing
+the Clerk of Court to provide Notices of Electronic Filing to Mr. Weinberg. A proposed order is
+attached for the Court's consideration.
+I certily that on 7-$"- 1L my office filed the foregoing document with the Clerk af
+Court and served a copy by mail and by email to all counsel of record.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office. (305) 37176421
+- Kade
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+2
+
+
+Entered on FLSD Docket 04/05/2011 Page 3 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/!
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+CERTIFICATION OF 1
+WEINBERG
+Pursuant to Rule 4(b) of the Special Rules Governing the Admission and Practice of
+Attorneys, I certify that I have studied the Local Rules of the United States District Court for the
+Souther District of Florida and that I am a member in good standing of the Massachuset Bar and
+the Bar of the United States District Court for the District of Massachusetts.
+Dated
+4.4.2011.
+Respectfully submitted,
+|G. WEINBERG, P.C.
+20 Park Plaza
+Suite 1000
+Boston, 02116
+Office: (617) 227-3700
+Fax: (617) 338-9538
+By Darela
+MARTIN G. WEINBERG, ESQ.
+Massachusetts Bar No. 519480
+
+
+Entered on FLSD Docket 04/05/2011 Page 4 of 5
+COMMONWEALTH OF MASSACHUSETTS
+SUFFOLK, SS.
+BE IT REMEMBERED, that at the Supreme Judicial Court holden at Boston
+within and for said County of Suffolk, on the
+twenty-fourth
+day of
+April
+A.D. 1972
+, said Court being the highest
+Court of Record in said Commonwealth:
+G. Weinberg
+being found duly qualified in that behalf, and having taken and subscribed
+the oaths required by law, was admitted to practice as an Attorney, and, by
+virtue thereof, as a Counsellor at Law, in any of the Courts of the said
+Commonwealth: that said Attorney is at present a member of the Bar, and
+is in good standing according to the records of this Court*.
+In testimony whereof, I have hereunto set my hand and affixed the
+seal of said Court, this thirtieth day of March
+in the year of our Lord two thousand and eleven
+Tamal Dale
+MAURAS.
+ClerkR
+* Records of private discipline, if aary, such as a private reprimand imposed by the Board of Bar Overseers or by any court, are not covered by this certification.
+X3116
+
+
+Entered on FLSD Docket 04/05/2011 Page 5 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER GRANTING MOTION FOR
+WEINBERG TO
+APPEAR PRO HAC VICE, CONSENT TO DESIGNATION, AND REQUEST
+To ELECTRONICALLY RECEIVE NOTICES OF ELECTRONIC FILING
+THIS CAUSE came before the Court on the motion for attorney
+Weinberg to appear
+Pro Hac Vice and to receive electronic notices of filing. For good cause shown, it is
+ORDERED AND ADJUDGED that the motion is GRANTED.
+Weinberg, Esq. is
+granted admission to appear and participate in this action on behalf of the proposed intervenors. The
+Clerk shall provide electronic notification of all electronic filings to
+Weinberg, Esq. at
+owlmgw@att.net.
+DONE AND ORDERED in West Palm Beach, Florida on
+KENNETH MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to all counsel of record
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e876a2cd9ad1220a2b9e20244da1d4741dd7c9259427109d1fdc3369bc270bff.receipt.json b/vision-fixhub/court-01/e876a2cd9ad1220a2b9e20244da1d4741dd7c9259427109d1fdc3369bc270bff.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..be2b0c241419f82a4c6c6b05190f9aa13cb867b3
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+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "15c374d413c7798d7e056c58748ba0d3b2ebb23b198444c2dcacf1d72a266029",
+  "output_sha256": "c8f0c777144ff5ca9aaf393286ae58d597c91df0e57ebc58595d42cc66079d04",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e87da7a1088202b3421d83bc2bb19fd462140044538810bc9a670952c5c25553.md b/vision-fixhub/court-01/e87da7a1088202b3421d83bc2bb19fd462140044538810bc9a670952c5c25553.md
new file mode 100644
index 0000000000000000000000000000000000000000..0720136befba79646a573f6edd94155da56c5185
--- /dev/null
+++ b/vision-fixhub/court-01/e87da7a1088202b3421d83bc2bb19fd462140044538810bc9a670952c5c25553.md
@@ -0,0 +1,8155 @@
+4
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+J8RsEPS1
+relatively straightforward. In my view, a public hearing
+clearly is nevertheless the preferred vehicle for its
+resolution.
+Incidentally, while I'm on this subject, I got some
+help today from the New York Law Journal from two professors
+who write that a hearing is -- let me tell you exactly what
+they said. They say, in part, that this is an odd moment for
+transparency in a criminal case. I think that
+an odd
+sentence to hear about, transparency in a criminal case.
+They go on to say that normally, if a prosecutor seeks
+to dismiss an indictment for such an obviously worthy reason,
+the court would simply grant the request. As to that
+statement, I respectfully say it is incorrect as a matter of
+law.
+They go on to say the judge would not schedule a
+hearing and he definitely would not allow the victims to speak.
+If he did hold a hearing, whatever informational interests the
+victims may have would be served by affording them a chance to
+attend the hearing, not by giving them a speaking role.
+I read it.
+It was incredulous. I'm still
+incredulous. I don't quite understand at all. There is a
+suggestion in the article that the reason they are making these
+suggestions has to do with minimization of drama in this case.
+In the Jeffrey Epstein case, there has not been much a
+minimization of drama, and what little drama might happen
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000923
+
+
+5
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+J8RsEPS1
+today, I don't think it would be very significaht.
+On a somewhat more serious note, don't quote me on
+this, but it 1s my understanding that one of the authors of
+that article is himself counsel in one of the Epstein-related
+cases. I was surprised to learn that very recently. I'm
+certain it is true. I was also surprised that that aspect was
+not disclosed in the Law Journal.
+But in any event, I think you know where I'm heading.
+I respectfully disagree with the Law Journal piece.
+I was
+saying that the government's motion is relatively
+straightforward, and in my view, a public hearing is clearly,
+nevertheless, the preferred vehicle for its resolution. I'm
+still convinced of that.
+A few may differ on this, but public hearings are
+exactly what judges do.
+Hearings promote transparency and they
+provide the court with insights and information which the court
+may not otherwise be aware of.
+The victims have been included in the proceeding today
+both because of their relevant experiences and because they
+shoald always be involved before rather than after the fact.
+Indictment 19 CR 490 charges Jeffrey Epstein with sex
+trafficking and with conspiracy to commit sex trafficking.
+The
+U.S. Attorney, on August 19, 2019, requested that the court
+approve the government's proposed order of nolle prosequi.
+think that's a rough justice. That means nolle prosequi,
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000924
+
+
+6
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+J8RsEPS1
+discontinuance by the prosecutor of all or of a part of the
+case that he or she has commenced.
+The government in its motion concludesi that Epstein's
+death abates these proceedings.
+In accordance with Federal
+Rule of Criminal Procedure 57(b), I determined to hold a public
+hearing and I notified the victims that they would be given the
+opportunity to be heard before any final action on the motion.
+That is the purpose also of today's proceeding.
+I would do
+that every time.
+Also, recognized that Epstein, Mr.
+Epstein died before
+any judgment of conviction against him had been obtained, and
+that the government's proposed order appears, in form and
+substance, to be appropriate.
+Federal Rule of Criminal Procedure 48(a) codifies the
+nolle prosequi process.
+It is entitled dismissal, and it
+states in relevant part that the government may, with leave of
+the court, dismiss an indictment, information, or complaint,
+and that leave of the court proviso, you should know, was added
+as an amendment to the original draft of Rule 48, which had
+originally provided for automatic dismissal upon the motion of
+the government.
+This proviso, in my judgment, is clearly directed
+toward an independent judicial assessment of the public
+interest in dismissing the indictment. Thus, even whereas, in
+this case, the standard of court review is deferential, the
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000925
+
+
+7
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+J8RsEPS1
+court must still make its own independent determination. A
+conclusory statement from the government that dismissal is
+appropriate does not satisfy the court's obligations.
+It is also, in my view, required that the court
+consider the views of the victims in the case at the hearing
+and before deciding whether to grant the motion. This is being
+done here both as a matter of law and as a measure of respect
+that we have for the victims' difficult decisions to
+Come
+forward in this matter.
+In a case called United States vol
+H-e-a-t-o-n-, the government filed a Rule 48 motion for leave
+to dismiss a charge against a defendant who allegedly committed
+a sexual offense against a young victim. Although I should
+point out, very importantlyn that that defendant was still
+alive, which distinguishes it from our case.
+Nevertheless,
+I think it is irrelevant because in
+evaluating the Rule 48 motion, then district Judge Paul G.
+Cassell -- who is now a law professor at the University of Utah
+and is fegarded to be a noted expert in victims' rights --
+concluded that under the Crime Victims' Rights Act, victims
+have broad rights that extend to a court's decision whether to
+grant a government motion to dismiss under Rule 48.
+I completely share that viewpoint in these
+circumstances, even though the facts of our case, as I said,
+are somewhat different from those in
+I believe it is
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000926
+
+
+8
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+J8RsEPS1
+the court's responsibility, and manifestly within its purview,
+to ensure that the victims in this case are treated fairly and
+with dignity.
+The fundamental substantive principle which applies in
+considering the government's motion is termed the rule of
+abatement. This principle originated in the English common
+law. It was adopted by most U.S. federal courts, but more
+recently, it has faced some appropriate criticism.
+The rule of
+abatement is best explained in the second Circuit casé of
+U.S. V.
+In that
+•case, two defendants had pled guilty to
+embezzlement and tax evasion. Both defendants appealed, but
+one of the defendants died while his appeal was pending in the
+Second Circuit. The Court of Appeals rule that under the rule
+of abatement, the judgment of conviction against the deceased
+defendant was required to be vacated and the indictment was to
+be dismissed. The Wright court held that when a convicted
+defendant dies while his direct appeal as of right is pending,
+his death abates not only the appeal, but also proceedings had
+during the course of the prosecution.
+The Second Circuit incidentally has also held that
+when a criminal conviction abates upon the death of a
+defendant, any restitution ordered as a result of that
+conviction must also abate, and it is also ruled the same with
+respect to associated forfeiture orders.
+SOUTHERN DISTRICT REPORTERS, P.Ç.
+(212) 805-0300
+CA/Aronberg-000927
+
+
+9
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+This latter application of the rule of abatement
+regarding forfeiture has not been universally accepted among
+federal courts, but it certainly is the law in this circuit.
+Some of you may be interested to know that some United States
+courts, state courts, have criticized the rule of abatement,
+particularly in the face of growing recognition of victims'
+rights in the criminal justice system, including the
+Crime
+Victims' Rights Act.
+* rooklyn Law
+It has been written and contended in the Brooklyn Law
+Review -- I can give you the cite later
+that when courts
+abate criminal convictions, they reimpose a burden on victims
+that legislatures intended to alleviate through these victim
+rights statutes. The state Supreme Court has even concluded
+that the expansion and codification of victims' rights provides
+the changed conditions needed for overruling the rule of
+abatement. It
+also been stated that Alaska's statute and
+its constitution now require the criminal justice system to
+accommodate the rights of crime victims. Further, that the
+abatement of criminal convictions has important implications
+for these rights.
+But coming back to our case, which is what you are
+concerned about and I am as well, it is appropriate to conclude
+that if the rule of abatement applies to a convicted defendant
+as in the Wright case, it should also apply a fortiori in the
+Epstein case, which was still in the pretrial phase when
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+!
+CA/Aronberg-000928
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+Mr. Epstein died, when there had been no conviction.
+So that's just some background I wanted to share with
+you. At this point in time, I would like to turn to the
+government prosecutors to hear
+from them in support of their
+Rule 48 application to dismiss the Epstein indictment.
+MS. COMEY: Thank you, your Honor.
+Would you like me
+to address the court from the
+podium?
+THE COURT: If you wouldn't mind.
+MS. COMEY: Thank you, your Honor
+I believe your Honor has accurately summarized the
+state of the law, as set forth in our papers, in light of the
+clear Second Circuit law, that upon the death of a defendant
+before a final entry of a judgment of conviction, all
+proceedings must be abated.
+In light of that clear law, the government is legally
+obligated to seek dismissal of the pending indictment against
+Jeffrey Epstein, and we respectfully submit, likewise, that the
+entry
+of the proposed order is similarly required by law.
+A few notes to make about that, though, your Honor.
+Ta
+be very clear, dismissal of this indictment as to Jeffrey
+in no way prohibits or inhibits the government's
+ongoing investigation into other potential coconspirators, nor
+does it prevent the bringing of a new case in the future or the
+prosecution of new defendants.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000929
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+It also does nothing to prevent the government from
+continuing to explore the possibility of seeking civil
+forfeiture of any assets that were used to facilitate the
+crimes charged in this indictment. Indeed, as has been stated
+publicly, investigations into those matters have been ongoing,
+remain ongoing, and will continue following dismissal of the
+indictment here.
+I would also like to note that, as the
+government has
+previously mentioned, this dismissal in no way lessens the
+government's resolve to stand up for the victims in this case,
+both those who have come forward and those who have yet to do
+so. We agree with your Honor's sentiment that those victims
+should be respected, and we appreciate your Honor's recognition
+of that.
+One housekeeping matter that I did want to reference
+for your Honor.
+The protective order in this case requires
+destruction or return of any and all discovery material upon
+conclusion of the case. We have been in communication with
+defense counsel, who have confirmed that they have returned all
+physical copies that they have of discovery that the government
+has produced to date, and they are in the process of deleting
+any copies that they may have made. So the parties are in
+compliance with the protective order.
+Finally, I just wanted to say a word about the victims
+in this case, and particularly those who are here in court
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000930
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+today. I'll note that in light of the court's order indicating
+that the victims and their counsel would be permitted to be
+heard in court here today, the government has endeavored to
+provide notice to all known victims of today's proceeding. We
+did so either directly where a victim was not represented by
+counsel or through counsel where a victim is represented by an
+attorney.
+The government does not know exactly how many victims
+or their attorneys are here today and we do not know how many
+of them or their counsel would like to speak. To the extent
+any individuals do wish to speak, we do not know the substance
+of what they would like to say. We have left that entirely up
+to the individual decisions of the victims and their attorneys.
+I will note, though, that throughout this case, the
+government has endeavored and done our utmost to fulfill our
+obligations under the Crimes Victims' Rights Act. We have done
+so by trying to keep as many victims as we are aware of up to
+date about the ongoing case and about any developments in the
+case.
+Wé will continue to provide services and offer
+services to any of the victims in this case, even after the
+Indictment is dismissed. Both the U.S. Attorney's office and
+the FBI have been in touch with all known victims or have
+attempted to be in touch with all known victims, either again
+directly where victims are not represented by counsel or
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000931
+FILED: PALM BEACH COUNTY, FL, |
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+through counsel where they have attorneys. We have expressed
+to them that services are available for those who wish to take
+advantage of them.
+Unless the court has any questions for me, the
+government will otherwise rest on its papers.
+THE COURT: I just have one question.
+The protective order,
+is that self-executing or do I
+need to do something?
+MS. COMEY: It is self-executing, your Honor.
+THE COURT: Thanks very much, Ms. Comey.
+MS. COMEY: Thank you, your Honor.
+THE COURT: Yes.
+I'll turn to counsel for the defense at this time.
+Mr. Weingarten, I'm happy to hear from you.
+MR. WEINGARTEN:
+Thank you.
+Your Honor, I think it is an understatement of the
+year to say the world looks and feels differently today than it
+the room is what happened to our client. I would like to tell
+you how we see the world and where we are on that subject.
+We start with the Attorney General's statements,
+public statements, that there were very serious improprieties
+in the jail. We obviously read the press. We see that the
+warden has been taken out. We see that the guards on duty at
+the time have been put on leave. We understand guards are
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000932
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+refusing to cooperate with the investigation.
+We have heard
+allegations that people at the time who had responsibility for
+protecting our client falsified information. We understand
+that there were orders out there that Jeffrey Epstein was never
+to be left alone and that the orders were ignored by many of
+the employees of the prison.
+In a word, yikes. In addition, obviously we)
+followed
+the medical examiner's report, or we haven't followed the
+report, we haven't seen it, but heard conclusions, initially
+not enough evidence to come to a conclusion, wanted to see
+more. We assumed she was talking about the videotapes, but
+then came to the conclusion that it was suicide.
+We report to the court that --
+THE COURT: Suicide by hanging -
+MR. WEINGARTEN: Yes.
+• was her conclusion?
+THE COURT:
+MR. WEINGARTEN: Yes.
+And we report to the court that we had a doctor there
+at the time, and we also have been in receipt of a tremendous
+amount of medical and scientific evidence volunteered to us
+opining that the injuries suffered, as reported, were far more
+consistent with assault than with suicide, and we are happy to
+supply the court with all the information that we have.
+Now, in addition, as the court noted, we were underway
+with our pretrial motions, and as the court obviously
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000933
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+understands, the NPA and the role of the NPA was going to be
+critically important. And I would simply like to report that
+- -
+we went pretty far along.
+We interviewed all of the relevant lawyers on the
+defense side who participated in the NPA, and we were satisfied
+that we had a very strong argument that every one of those
+lawyers believed with an objective basis that the deal was
+global. That is, at the time --
+THE COURT: I'm sorry, that?
+MR. WEINGARTEN: The deal of the NPA was global. That
+is, more specifically, at the time, the Elorida prosecutors and
+agents knew of conduct in New York, and that no competent
+defense counsel negotiating in good faith with the prosecutors
+would have ever agreed to a deal back then that allowed New
+York prosecutors to indict for precisely the same conduct in
+the future, which, of course, is what happened.
+In addition, we have come up with very powerful
+evidence, we believe, that Florida prosecutors, who
+participated in the deal, steered the victims and the alleged
+victims to New York on more than one occasion because they did
+not want to suffer the sleights of attacks against them. So we
+have advanced the ball on this very subject and we are prepared
+to completely report to the court as to where we are and what
+we've done.
+Another point.
+We obviously had contact with our
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000934
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+client at or around the time of his death, and obviously the
+attorney-client privilege survives death and we are not going
+to forfeit the privilege, but we will report to the court, with
+as much specificity as the court may want, that at or around
+the time of his death, we did not see a despairing, despondent
+suicidal person. Details to follow, if the court wishes.
+The 800-pound gorilla, for us, of course, are the
+video surveillance tapes. Obviously we assume there
+Is a tape
+that leads directly to the door where Jeffrey Epstein was
+housed. If that tape reports for 12 hours before his death
+that no one went in and out of that foom, then the suggestion
+that there was something other than a suicide seems
+preposterous.
+But there is no such evidence that has surfaced to
+date. Just the opposite!
+We have heard, and we actually read
+in the press, that the tapes were either corrupted or not
+functioning. Talk about a yikes. If, in fact, the system was
+broken for six months before Jeffrey Epstein was housed, I
+mean,
+that would be stunning incompetence. If it was allowed
+to continué to be inoperative when Jeffrey Epstein was housed,
+would be incompetence times ten. But what if the tapes only
+broke down or were inoperative or were corrupted on the day he
+was killed or the day he died? Then we're in a completely
+different situation.
+So where does this lead? I think where it leads,
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000935
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+Judge, is there are incredibly important questions that remain
+open. The public interest
+in this matter is obvious from this
+courtroom. There are conspiracy theories galore. We are all
+for finding the truth. We believe
+this court has an
+indispensable role to play.
+Whether or not this indictment is dismissed, I think
+this court has the inherent authority to find out what happened
+on its watch. Obviously, when the court detained Jeffrey
+Epstein, the court did not anticipate that weeks later he would
+be dead in his cell. I think given the inherent authority of
+the court, the court should make inquiry.
+This could come in many forms.
+Obviously the court
+made inquiry as to what happened in the first incident. When
+there was an allegation of an attempted suicide, the court made
+inquiry. The court obviously was interested.
+I recall youf language. You talked about that being
+one of the several open questions indicating an interest on the
+court for the others as well. Obviously, the ultimate question
+is what happened to the client.
+THE COURT: You're talking about the July 23, 2019
+Incident?
+MR. WEINGARTEN: Yes.
+The court obviously could hold hearings. The court
+could assign a lawyer to help the court. I think this is an
+area where there is intense public interest. We have complete
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000936
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+J8RsEPS1
+confidence in the prosecutors in the Southern District and the
+FBI to do a competent investigation. But these are allegations
+against serious components of the United Statesi Department of
+Justice. Sometimes the appearance of justice is just as
+important as justice itself.
+I think the court supervising, or at least keeping an
+interest in this proceeding, is incredibly important for the
+public to have confidence in the ultimate findings,
+certainly for us to have confidence in the ultimate findings.
+One more issue, Judge. The conditions of the jail, in
+a word, they were dreadful. Not just for deffrey Epstein, but
+for many of the prisoners over there.
+This is a prison within
+the shadows of this courthouse. The situation is rife with
+vermin. The abuse and the conditions in that prison, in a
+word, are a disgrace and everybody knows it.
+A person with authority told us, someone with
+knowledge, that
+the prisoners in Guantanamo -- and he spoke
+with personal knowledge -- are treated better than the
+prisoners right across the way. The feds certainly know how to
+run a disciplined, clean prison. I've been in 20 of them.
+They know how to do it just fine. And the question is, why in
+the world does it not happen down the road? I think that is a
+perfectly legitimate subject for the court to make inquiry.
+In a word, we want the court to help us find out what
+happened. The court has a role to play. It is the institution
+SOUTHERN DISTRICT REPORTERS, P.Ç.
+(212) 805-0300
+CA/Aronberg-000937
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+that most people have confidence in in these very troubled
+times.
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+So whether or not you dismiss the indictment, to us,
+is beside the point. We want you to stay on the case, we want
+you to conduct an investigation, and we want to know what
+happened here.
+Thank you, your Honor.
+THE COURT: Just so it is clear, so your view on the
+motion directly on its merits of the nolle prosequi order and
+application by the U.S. Attorney, do you have a view on that?
+MR. WEINGARTEN: I think if the court felt that the
+case had to stay alive for the court to continue, we would
+oppose it. I think --
+THE COURT: I'm sorry, if what?
+MR. WEINGARTEN:
+If the issue, if you took the
+position for you to conduct the investigation or lead the
+investigation or participate in the investigation, then we
+want, the role we want you to play, if the indictment has to be
+alive,
+we
+would oppose the motion.
+'don't think you need to do that. I think you can
+dismiss the indictment.
+THE COURT: So you're suggesting that you support the
+government's motion, just viewed in the context of -
+MR. WEINGARTEN:
+Yes, of course.
+THE COURT: Great.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000938
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+MR. WEINBERG: Judge, if I can just supplement?
+THE COURT: Absolutely.
+MR. WEINBERG: Thank you, sir.
+Thank you, as an out-of-town lawyer for the privilege
+to appear in front of you, your Honor.
+THE COURT: It's my pleasure.
+MR. WEINBERG: First, as to the conditions, we think
+your Honor trusted the government, the Bureau of Prisons, to
+keep our client safe and keep him in civilized conditions. The
+government will again ask, as to other defendants, that they be
+detained at the MCC, some subset of them will end up in the SHU
+unit.
+It is a horrific. I've called it medieval. There's
+vermin on the floor.
+There is wet from the plumbing. There is
+no sunlight. There is limited exercise. It is simply
+conditions that no pretrial detainee -- and I would go farther
+as a criminal defense lawyer -- no United States defendant
+should be subjected to.
+Certain judges have taken views of the conditions. We
+would urge your Honor, the government talks about and we talk
+about transparency, to see what kind of conditions there exist
+within 50 or 100 yards of one of the great United States
+district courts.
+Second, in terms, we have a profound problem with the
+conclusions of the medical examiner. There are for three
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000939
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+J8RsEPS1
+reasons, your Honor.
+One is the timing of Mr. Epstein's demise. It was on
+August 10. On August 12, a bail pending appeal motion was
+being filed in the Second Circuit. On August 12 or 13, the
+United States Attorneys were going to respond to our request
+for the preservation and production of documents that would
+have facilitated and furthered our efforts to demonstrate
+communications between the Southern District of Florida, the
+Northern District of Georgia, which was standing in the shoes
+of the Southern District of Florida main justice and the
+Southern District.
+In other words, we were beginning the process
+discharging our responsibilities
+There had been no new
+evidence that Mr. Epstein had committed any offense against a
+minor after 2005. The subject matter of the New York
+prosecution was
+squarely within the heartland of the Florida
+NPA.
+We had a significant motion to dismiss. This was not a
+futile, you know, defeatist attitude.
+Third, we had all the discovery motions that your
+Honor had scheduled. So the timing for a pretrial detainee to
+commit suicide on August 10, when his bail pending appeal
+motion is being filed on August 12, strikes us as implausible.
+Second, we had an independent doctor who was present
+at the autopsy which occurred on August 11. On August 11, the
+city medical examiner's findings were inconclusive. We are
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000940
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+told by a very experienced forensic pathologist that the broken
+bones in Mi. Epstein's neck, in his larynx, are more consistent
+with external pressure, with strangulation, with homicide, if
+you will, than with suicide.
+It doesn't exclude suicide, but
+the pure medical forensic evidence creates profound issues
+about what happened to him.
+Also the time of death. Our medical examiner's
+opinion is it occurred at least 45 minutes and probably hours
+before 6:30 a.m. on August 10, when he was first found, if you
+will, according to the reports. Yet he was moved, something
+that is not ordinary in these circumstances.
+I would also
+--
+THE COURT: Excuse me. He was moved?
+MR. WEINBERG: Instead of having the cell in the
+condition it was found,
+if he had been dead for 45 minutes or
+two hours or four hours, there were efforts to move him and,
+therefore, make
+it more difficult to reconstruct whether or not
+he died of suicide or some other cause.
+I spoke to Stacey Richmond, who is a responsible
+member of this court who represents the family of Mr. Epstein.
+She spoke to the medical examiner on the Friday after
+MI. Epstein's death and asked why, if the conclusion was made
+late in the afternoon on Friday that week. She specifically
+asked about what extrinsic nonmedical evidence caused the
+medical examiner to go from uncertain to suicide, and she was
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000941
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+told that the medical examiner had seen nine mihutes of one
+video which was on a stairwell between floors at the MCC. She
+was told that the principal video that would have showed the
+whole
+was corrupted. It was in DC with the FBI to see if
+they can reconstruct it.
+And I asked the same questions that my co-counsel did,
+you know, was the dysfunction of the critical pivotal video, in
+the most secure prison east of Florence, out in Colorado known
+to the MCC before August 10, or was this corruption occurring
+on August 10, which would again cause us to be skeptical of the
+servitude of the medical examiner's conclusions that this was
+suicide rather than some other cause.
+So with my co-counsel, we ask your Honor, it is not a
+question of trust or not trust. They ask you to detain people
+and you trust the Bureau of Prisons. And it is within your
+inherit authority, your Honor, to find out what happened to our
+client.
+We are angry about the conditions he was held in. And
+we're also angry, quite frankly, your Honor, that the only
+source of information that we get as to what happened to him is
+through the media rather than through the United States
+Attorney's office. We've made requests informal. We have
+made Touhy requests.
+We've been told there is a pending
+investigation.
+But we trust your Honor and the judiciary, and with
+SOUTHERN DISTRICT REPORTERS, P.Ç.
+(212) 805-0300
+CA/Aronberg-000942
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+all due respect, we believe there is an inherent and central
+role, a pivotal role in your Honor to find out what happened to
+a defendant in a case before the court, whether or not the
+court grants the nolle pros today or whether it holds it
+pending an investigation into Mr. Epstein's death.
+We're not here without significant doubts regarding
+the conclusion of suicide.
+We are not here to say what
+happened. We don't know what happened. But
+we
+deeply want to
+know what happened to our client.
+Thank you, sir.
+THE COURT: And you, as Mr Weingarten, have the same
+view of the nolle prosequi motion?
+MR. WEINBERG: Yes, your Honor.
+THE COURT: OK. 1
+YOur HO
+I respond to some of those
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+points?
+THE COURT: Sure.
+MS. COMEY: Thank you, your Honor.
+'Just) briefly. With the exception of the noting that
+the defensé does not have an objection to the government's
+motion, virtually everything else that defense counsel just
+argued, respectfully is completely irrelevant to the purposes
+of today's proceeding and to the motion that is pending before
+your Honor.
+As an initial matter, the question -
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000943
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+THE COURT: Well, it may be. Well, I don't know. You
+say irrelevant.
+It is a public hearing, and I think it, is fair game
+for defense counsel to raise its
+concerns.
+MS. COMEY: Certainly, your Honor. But it is
+irrelevant to whether or not the motion should be granted.
+THE COURT: Right. I get that.
+MS. COMEY: I would also note that the question of
+Mr. Epstein's death is the subject of an ongoing and active
+investigation,
+as has been publicly noted, by a separate team
+of Assistant United States Attorneys from the Southern District
+of New York, separate from the team who is handling this
+prosecution, as well as a separate team of FBI agents.
+There is an ongoing and active grand jury
+investigation into the circumstances surrounding Mr. Epstein's
+death. It is the function of a grand jury and of the Federal
+Bureau of Investigation to investigate crimes in the federal
+court system.
+It is not the purview, respectfully, of the
+court
+• conduct an investigation into uncharged matters.
+So respectfully, we disagree with defense counsel's
+suggestion that the court has some authority to conduct an
+Independent investigation. Io the extent any other defendants
+who are detained in the MCC have concerns about the conditions
+or believe that the conditions are relevant to a future or
+current bail determination, it is for those defendants and
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CAVAronberg-000944
+
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+their counsel to raise those arguments and for the judges
+hearing those arguments to evaluate those claims. It is not
+relevant to today's proceedings.
+Thank you, your Honor.
+THE COURT: In those other cases, Ms. Comey, judges do
+have authority to investigate, but don't here?
+MS. COMEY: Not to investigate, your Honor
+but to
+hear arguments about the conditions of confinement in the MCC
+as they may relate to any bail determination.
+I believe that
+was the argument that was made.
+The bigger picture here, your Honor, is that the focus
+of today's proceeding, as we understand it, is to allow the
+victims who have gathered here today to be heard and to comment
+upon the case and to comment upon the motion that is pending,
+and to bring this case to a close.
+THE COURT:
+Got it.
+MR. WEINGARTEN: May I?
+THE COURT: Sure.
+MR. WEINGARTEN: We obviously saw this as, perhaps,
+the last opportunity to be before you, and we wanted to take
+advantage of the opportunity to say our peace and thank you for
+allowing us.
+There is precedent here. Ted Stevens, the Senator
+from Alaska case in Washington, DC, Judge Emmet
+ordered an independent investigation by a private lawyer when
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000945
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+he was deeply troubled by the alleged Brady violations. I
+represented the prosecutors in that case, so I'm very, very
+familiar with it.
+It is analogous. It is a situation where there was
+tremendous controversy over what happened in the case and
+whether or not the prosecutors went off the reservation.
+Judge
+- and there were three or four independent - not
+independent, DOJ inquiries
+Judge
+into the very same matter./ But
+wanted his own opportunity to make a judgment
+with his own independent investigation.
+THE COURT: OK.
+MR. WEINBERG: If I could just add one precedent, your
+Honor.
+The Chief judge in the District of Massachusetts or
+the Chief Judge at the time, Judge
+in a case called
+U.S. V. Eleming, when the conditions at Walpole, which is a
+state prison where federal prisoners were being held -- we
+don't have a federal MCC in Boston -- went to the prison,
+stayed an the prison to determine whether or not the complaints
+about the conditions were authentic.
+I think your Honor has the inherent authority to go to
+the ninth floor and see how the MCC houses pretrial detainees.
+Thank you.
+THE COURT: Are you saying that whether or not the
+motion is granted that is pending before us?
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+• -
+CA/Aronberg-000946
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+MR. WEINBERG: Yes, your Honor.
+I think, like when appeals are taken, bail issues
+remain before the district court. Jurisdiction is not
+completely divested. Your Honor
+issued a pretrial detention
+order and your Honor has the power, the inherent authority,
+they are not going to refuse to allow you to go look at the
+ninth floor. They are going to count on you to make decisions
+in the future.
+I just trust that the executive branch is not going to
+prevent the judicial branch from looking into the death of
+Jeffrey Epstein or the conditions in the SHU unit at the MCC,
+sir.
+THE COURT: Great.
+Thank you.
+I, your Honor?
+Just very briefly, your Honor. I would note that upon
+the dismissal of the indictment, which I believe the parties
+agree is appropriate in this case, there would be no case.
+There would be no jurisdiction for the court to conduct any
+sort of inquiry, even if the court had such authority.
+THE COURT: Right.
+OK. I think we've heard enough.
+It is at this point in the hearing that I would like
+to call upon victims' counsel, plural, for any remarks they may
+have and they may wish to make. Also, to introduce their
+clients, those of them who wish to be heard.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000947
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+It would be helpful if, in doing that, if counsel -
+and I see and I see Mr. Boise as well -- I know
+Mr.
+they are counsel to several, at least several of the victims.
+It would be helpful if whoever is speaking, both Mr.
+and Mr. Boise, would indicate to the court whether or not they
+have discussed the pending motion with their clients,
+that is
+to say and the rule of abatement, etc., etc. with them prior to
+today's hearing.
+Are we going to hear from Mr. Edwards first, is that
+right?
+MR.
+Thank you, your Honor.
+THE COURT: You bet.
+It would be helpful/ Mr.
+if you would state
+and spell your name for the court reporter.
+If you are going to introduce someone else, which I
+trust that you are,
+if you could state and spell their name as
+well.
+MR. EDWARDS: Yes, your Honor.
+May It please the court.
+Brad
+B-r-a-d
+E-d-w-a-ryd-s, with the law firm of |
+Pottinger.
+I have in the courtroom today 15 victims that I
+represent and have represented over the years. There are at
+least 20 more who didn't make this hearing today for a
+multitude of reasons, some out of fear of public exposure,
+others because the way in which this case ended will never
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000948
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+bring full justice, and they decided it was best for them not
+to talk today.
+Some of my clients are going to address the court that
+are here today. Others are not. Some are going to use their
+names, and have in the past, and others wish to remain
+anonymous. And I have instructed each of them to inform the
+court reporter that they will be proceeding as Jane Doe so that
+the court reporter can take them down.
+THE COURT: For those who wish to remain anonymous?
+MR.
+: Exactly, your Honor.
+THE COURT: And that is satísfactory, as far as I am
+concerned.
+MR.
+: Before we do that, I would like to
+address a couple of the things that have occurred this morning.
+First of all, whether relevant or not, I personally,
+and on behalf of my clients, do appreciate the presentation
+that Mr. Weingarten made and Mr. Marty Weinberg made.
+I have tremendous respect for Mr. Weinberg. I've
+worked with him through this and related cases for years, and I
+understand the reason why they made the presentation that they
+made.
+There is two things of interest to our clients in that
+respect. One is, because of the tragic ending, that none of my
+clients wanted, nor did I, nor did anyone else, if there is
+some civil rights violation and there is some civil remedy for
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000949
+
+
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+Mr. Epstein that goes to the estate, certainly the victims are
+interested in that as they might help to repair the damage
+done.
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+Second, Mr. Epstein's untimely death, the timing is
+curious to us. But more so, it makes it absolutely impossible
+for the victims to ever get the day in court that they wanted
+in court and to get full justice. That now can never happen.
+I know that Mr. Epstein's attorneys say he wanted
+it, and they
+know, we did too. And there are a lot of people here today
+that are very sad by the way that this ended for both
+Mr. Epstein and the fact that full justice was robbed from
+them, once again.
+The second issue I wanted to address was the Law
+Review or the Law Journal article that your Honor referenced,
+which is troubling because the opinion seems to say that
+transparency is not appropriate in the criminal system and is
+not appropriate
+at this point in time.
+That's tough to swallow, especially in this case,
+given the long history of this case. Personally, it is tough
+to swallow, and on behalf of my clients, I can say that is very
+concerning. Iransparency is the only way that the justice
+system works. We know this because there was a similar
+investigation of Mr. Epstein many years ago, from 2005 to 2008.
+My personal involvement in this case was because a
+young female came into my office named
+and she
+SOUTHERN DISTRICT REPORTERS, P.¢.
+(212) 805-0300
+CA/Aronberg-000950
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+came to me not asking to file a lawsuit against Jeffrey
+Epstein, but simply asking for the government to talk to her.
+She was cooperating in an FBI investigation and wanted the
+government to speak with her,
+and I thought that was going to
+be an easy task.
+It was only a few months later that we learned that
+this investigation that was represented to my client in written
+form, that it would be a long investigation, and to be patient.
+Basically, to hang tight. It was resolved by way of a secret
+deal that never allowed any of the more than 30 victims who had
+been identified of Mr. Epstein's abuse in Florida to ever
+participate in a single hearing..
+There was a hearing. They
+were never notified.
+I then went on to represent many of them in civil
+cases and also in extensive pro bono work. And I can tell your
+Honor that while Jeffrey Epstein's abuse of them hurt them and
+harmed them for many years, the feelings they had was
+aggravated exponentially by the facts that they had no rights
+in the criminal justice system, by the fact that they were
+treated as if they didn't matter. They were not allowed their
+rights under the Crime Victims' Rights Act to meaningfully
+confer with prosecutors, to be treated with fairness, to be
+treated with dignity. That is what this is supposed to be
+about, and to have notice of hearings.
+So I do want to thank your Honor, and 'especially the
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000951
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+J8RsEPS1
+prosecutors who have worked this investigation and this case,
+which is very different in experience for all of my clients and
+the other Epstein victims in this case, because they were
+allowed to be a part of the process.
+While some of them
+elected not to be here today, that opportunity should always be
+allowed for them.
+In 2008, we filed that case under the Crime Victims'
+Rights Act because our clients' rights were violated, /and as
+your Honor knows, a federal judge has ruled in our clients'
+favor that their rights were violated. So this hearing today
+means a lot to them. The fact that they may never get their
+chance to speak in court, they may never get complete closure,
+and all of us have to wonder/ if their rights had been afforded
+them the first time, would any of us be here right now. Or
+wouldn't it more likely be the case that everyone, including
+Jeffrey Epstein,
+would have turned out better for it?
+Today,
+I have not only represented, but met and become
+very close with many of these victims. Many of these
+survivors.
+They are very strong people. They are people who
+have persevered through a lot of adversity. It's been a roller
+coaster of emotions that has led us to where we are today. And
+while they have all been cast over the years because of the
+secrecy of the first investigation, in the shadow as victims,
+you can't put them all in one bucket and say one size fits all.
+They are each individual people who were harmed differently and
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000952
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+distinctly through not only the abuse, but the system.
+And on behalf of all of them, I would like to thank
+your Honor for the fairness with which they've been treated,
+and the United States Attorney's office for the way in which
+you have handled this investigation, and especially how you
+have treated the victims in this case.
+Like I said, I have many who want to speak.
+→ Some that
+can't. This is a very difficult day for them.
+But we
+appreciate the opportunity and the invitation.
+The first client that I have that is going to address
+your Honor is the one who walked into my office in 2008 asking
+just to be heard,
+THE COURT: Hold on one second. Did you all want to
+be seated?
+You don't need to be standing. Whatever is more
+comfortable until you're ready to give some comments. It's up
+to you.
+Ms. Wild, if you could spell your name for the court
+reporters, please.
+MS.
+C-o-u-т-t-n-e-y, last name
+(Continued on next page)
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000953
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+My name is
+and I'm a victim
+of Jeffrey Epstein. Jeffrey Epstein sexually abused me for
+years, robbing me of my innocence and mental health. Jeffrey
+Epstein has done nothing but manipulate our justice system,
+where he has never been held accountable for his actions, even
+to this day.
+Jeffrey Epstein robbed myself and all the other
+victims of our day in court to confront him one by one, and for
+that he is a coward.
+I want to thank the U.S. Attorney's for seeking
+justice that has been long over due,and most importantly,
+given us, the victims, our day in court to speak our peace and
+find some sort of closure. I feel very angry and sad that
+justice has never been seved in this case. Thank you.
+THE COURT:
+Thanks very much.
+MR. EDWARDS I believe my next client who is going to
+speak is probably going to speak as Jane Doe.
+JANE DOE NO. 1: Yes, Jane Doe.
+THE COURT: We'll say Jane Doe No. 1, just for the
+•
+record.
+JANE DOE NO. 1: Okay. Thank you for allowing us to
+speak today. I've shifted what I want to say in hearing
+what's already been said, and just about the question of
+Jeffrey's death. I don't know what the relevance is to this
+hearing, but I do know that it is profoundly relevant to my
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000954
+
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+life, as a victim. I don't like that word, but! I still feel
+like I am learning the ways that he's impacted me as a complex
+situation, but he was also a major part of my life. As
+destructive as that relationship was and as much of a villain
+as we have created him to be -- based on facts we've created
+him to be a villain -- he's a complex villain and actually all
+of that is irrelevant. Anybody deserves -- an investigation is
+the right thing to do. Like, we do need to know how he died.
+It felt like a whole new trauma all over again, and I
+don't know why, you know, because I -- I'm trying to defend
+myself against him at this point in my life, but it still does
+not feel good. It didn't feel good to wake up that morning and
+find out that he had allegedly committed suicide. Okay. But I
+also wanted to say to the press, I'm reading -- I read my story
+in the paper. I read so many other girls' stories that are so
+similar to my own, and everything that's been focused on is not
+the most important part of it.
+There was -- the problem with focusing on these, the
+facts of the situation, that were out of the ordinary and like
+because he was such a grand person, and it was just a unique
+situation. I know that that's the more interesting side of the
+story, but I don't want to be used as entertainment. And the
+problem, the fundamental problem of the whole situation is the
+element of exploitation and coercion, and these are things that
+so many girls can relate to.
+SOUTHERN DISTRICT REPORTERS,
+P.C.
+(212) 805-0300
+CA/Aronberg-000955
+
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+And even though this Jeffrey Epstein brought it to a
+grand scale, on some level,
+a lot of girls could relate to the
+trauma that we are talking about, and even though this whole
+situation sucks, I would like to think that it may be possibly
+a catalyst for change because, obviously, as we're seeing with
+the "Me Too" movement, change needs to happen and it's.
+what
+I'm seeing in the papers is not a common story, but it's so
+much more common than you realize. That's all.
+Thank you.
+THE COURT: Thank you very much.
+MR.
+I believe that the next client is going
+to also be a Jane Doe; so I think fof the purposes of the
+record it will be Jane Doe
+2.
+THE COURT: Yes.
+JANE DOE NO. 2: (Good morning, your Honor.
+THE COURT:
+Good morning. How are you?
+JANE DOE NO 2:
+'Doing okay. I hadn't prepared any
+words to speak today, but there is something that was on my
+mind this morning when I got here. It's been on my mind in
+reading through the press and through the people that I've
+spoken toyabout it, friends, family. It's something that's
+bathered me because I think it has a lot of blame in it, as
+well, a little bit of what my friend, who was up here, was
+speaking about.
+I think that a lot of people asked why we spent so
+much time, why we stayed. It's an experience that's really
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000956
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+hard to explain to people who haven't gone through it. I think
+there's a writer,
+Nagel, who wrote an essay called "What
+is it like to be a bat?" And I think that he touches on it
+pretty strongly and if you haven't experienced something, it's
+very hard to fully understand why someone makes the decisions
+they do and what the circumstances were.
+I don't want to speak for all of the victims.
+I think
+each of us has a different story and different circumstances
+for why we stayed in it, but for me, I think he was really
+strategic in how he approached each of us.
+Things happened
+slowly over time. We didn't -- it almost was like, putting it
+like that analogy of a frog being in a pan of water and slowly
+turning the flame up. You didn't realize it was happening, and
+it just -- I don't think anyone can fully understand the
+experience, but I just
+the blame feels very strong.
+There's a lot of support as well, but I just want
+people to try and understand that we aren't bad people. We
+weren't trying to -- it wasn't a situation where we were trying
+to extort money from someone. A lot of us were in very
+vulnerable situations and in extreme poverty, circumstances
+where we didn't have anyone on our side, to speak on our
+behalf, and that's really scary.
+You start to blame yourself because, at first, you
+don't tell anyone what's happening, and it becomes your deep,
+dark secret that you tried to keep from everyone. And I didn't
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000957
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+even know I was a victim until I spoke with my lawyers. I had
+no idea. I had so much self-hatred and doubt and just guilt
+for everything. I still do. I still don't feel like I deserve
+to say I'm a victim, and I think that's a big problem with our
+society right now, that people are still blaming victims, and I
+think that does need to change.
+I hope that today people understand that
+each of us
+has a story, has a past, has a family and just give us
+a chance
+to - you know, that's basically all I just wanted to say.
+THE COURT: Thank you so much.
+JANE DOE NO. 2: Thank you so much.
+THE COURT: Okay.
+MR.
+Okay.AI think that the next person who
+is going to speak is also going to be speaking as Jane Doe; so
+for the purpose of the record, Jane Doe No. 3.
+JANE DOE NO. 3)
+Thank you for allowing us to speak
+today. I came to New York City 15 years ago to pursue modeling
+from a small town. I signed on with an agency and was excited
+to pursue my passion and my dream. Several months later, I met
+a female who told me about Mr. Epstein. She portrayed him as
+an amazing man who genuinely cared for people and that he was
+going to be able to help me in a modeling career.
+I was excited to meet him, after hearing her talk
+about him. He sounded like an amazing person. An introduction
+was made at his New York home, and it is there that I was
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000958
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+sexually assaulted. I left his home, after he threw me,
+basically put money on the table, and I was ashamed. I was
+embarrassed. This was not the way I was brought up, and I
+couldn't believe this had happened to me.
+I left and my world kind of spiraled after that.
+stopped going on modeling castings. I gained weight. i became
+depressed. I stopped going out with my friends, and only five
+months after I had been in New York City to pursue my dream, I
+left. I left the modeling industry, and I left New York City,
+and I totally switched my career paths.
+I buried this deep within me, and all of the new
+occurrences that have come up in the media is what brought it
+back up for me. And I feel sickened and saddened that it took
+so many years, and God knows how many victims, for this to
+finally come out, but
+I'm thankful it did. And I'm just angry
+that he's not
+ve anymore to have to pay the price for his
+actions. So I thank you for your time.
+THE COURT: You're very welcome.
+MR.
+Your Honor, Jane Doe No. 4, I believe,
+is going to speak now.
+JANE DOE NO. 4: Good morning, your Honor.
+THE COURT: Good morning.
+JANE DOE NO. 4: I just have something very short to
+say. I met Jeffrey Epstein at a very vulnerable place in my
+life, and whatever the outcome is with everything, I just
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000959
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+wanted to express that we, the victims, we will always carry
+irreparable damage and pain throughout our lives after this.
+It's something that's never going to go away.
+You know, whoever we marry in our life, whatever
+future we have in our life, it's always going to be something
+that's always there for us.
+And I'm very nervous right now.
+And Jeffrey Epstein, he took away the chance I had at having
+the future I had envisioned for myself as a young girl, and I
+think many of us here today will never fully heal from that
+pain and the heartache that we'll continue carrying with us.
+So I just wanted to say that.
+It's something that
+it's irreparable. I can't even really use a better word to
+describe that. So thank you for hearing us today.
+THE COURT: You'fe very welcome.
+MR.
+Your Honor, Jane Doe No. 5 would like to
+speak.
+JANE DOE NO. 5: This is a letter that I wrote; so
+it's going to be: Dear Jeffrey, I think you are a mentally
+disturbed human being. You used your power to make me believe
+at a young age that I could have my dreams of being a model.
+You paid for your freedom. You violated my rights. You should
+have to pay for them, just as anyone else. You got a plea deal
+that no one else would have been able to get. You used your
+money to get out of paying the price for your actions.
+Also, as a victim, I never got to see what the
+SOUTHERN DISTRICT REPORTERS, P.Ç.
+(212) 805-0300
+CA/Aronberg-000960
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+agreement was or why the special treatment got approved. I
+think you should have been
+in jail for several years in
+population and live like everyone else that is mentally
+disturbed like you. You paid for yourself to get special
+treatment while you were in jail. I don't even think you spent
+a day in a jail as a normal human being.
+You had investigators come to my house and also went
+to my friend's house to question them.
+I will never
+be able to
+over -- I will never be able to get over the overwhelming
+emotions and embarrassment I experienced from that trauma. I
+needed therapy several times a week and had high stress and
+anxiety levels.
+You paid your way to make the public think that the
+girls had nothing in life going on for them. You wanted to try
+and blame that we were lower class and that was the problem
+with the girls.
+I was from a middle class family and did well
+in school. I lived the American girl dream -- or the American
+girl life. I went on family vacations around the world, grew
+up in
+good city, and my parents are still married to this
+day. Basically, everything you said that we didn't have in our
+Infe, I did.
+It all came down to I was told I was making $200 in an
+hour. Being young, that was a lot of money, and I didn't know
+any better. Sadly, you were the one with an illness that you
+should have to go and see a doctor and also have a mentor group
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000961
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+for the sickness you have. I will continue with writing my
+book about that secret life, with all the newspaper articles of
+the case, my high school agenda book of official dates. I'm
+basing that proof that I deposited cash after leaving
+Jeffrey's. I still have all of the information, articles that
+I collected over the years.
+You mentally and physically traumatized me
+I went to
+therapy, and it was the best thing I did for myself,
+If anyone
+only learns one thing from this case, I hope is that money
+should not let you buy your way free. A crime is a crime and a
+victim is a victim. Thank you.
+THE COURT: Thank you. Thank you very much.
+MR.
+Your Honor, my next client is Chauntae
+C-h-a-u-n-t-a-e, Davies, D-a-v-i-e-s.
+I met Jeffrey Epstein through my first
+massage teacher,
+a man who took me in as his apprentice to
+teach me a practice I wanted to learn while in desperate search
+to find a cure for a debilitating neurological disorder that I
+have, which manifests into violent vomiting attacks, largely
+triggered by stress. It's called Cyclic Vomiting Syndrome.
+I was recruited by Ghislaine Maxwell. Upon my first
+meeting of her, I wouldn't know I had been recruited until many
+years later, when I would read it in a headline. Ghislaine and
+Jeffrey took me in. They sent me to school. They gave me a
+job. They flew me around the world, introduced me to a world I
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000962
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+had only dreamt of and made me feel as though I! had become a
+part of their family, another thing I was desperately searching
+for.
+But on my third or fourth time meeting them, they
+brought me to Jeffrey's island for the first time, and on the
+first night there,
+came tapping on my door late at
+night to inform me Jeffrey was ready for another massage. My
+instincts told me this didn't feel right, but I(
+yup and
+followed her to a villa I hadn't yet seen.
+Jeffrey and
+Ghislaine's villa.
+I began my massage, trying hot to let him smell my
+fear and obvious discomfort, but before I knew what was
+happening, he grabbed onto my wrist and tugged me towards the
+bed. I tried to pull away, but he was unbuttoning my shorts
+and pulling my body onto his already naked body faster than I
+could think. I was searching for words but all I could say was
+meek, "No, please stop, " but that just seemed to excite him
+more.
+'He continued to rape me, and when he was finished, he
+hopped off and went to the shower. I pulled my shorts up, and
+Iran as fast as I could back to my own villa, my feet bloodied
+from the rocks. I cried myself to sleep that night.
+I spent two weeks vomiting, almost to death, in a
+Los Angeles hospital after that first encounter. Jeffrey's
+abuse would continue for the next three years, and I allowed it
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000963
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+to continue because I had been taken advantage of my entire
+life and had been conditioned to just accept it:
+It took me a long time to come forward, too long
+maybe, and all it took to bring - and all that it took to
+bring this man to justice has been robbed by his death. Every
+day, every week I've spent in the hospital since, I've suffered
+and he has won. Every job offer that's been offered to me and
+then retracted because of my connection to this
+case, I have
+suffered and he has won. Every public humiliation I have
+endured, I have suffered and he has won Every relationship
+that I've had to end because of the abuse that I have endured
+by the hands of this man, I have suffered and he has won.
+Every woman sitting in this room today, and all of the
+women who have yet come forward and who have not yet to come
+forward and whose lives have been affected by Jeffrey Epstein's
+sick abuse of young girls, we have all suffered, and he is
+still winning in death.
+I refuse to let this man win in death. I couldn't
+fight back when Jeffrey Epstein sexually abused me because I
+hadn't yet found my voice. Well, I have found my voice now,
+and while Jeffrey may no longer be here to hear it, I will not
+stop fighting, and I will not be silenced anymore. I needed
+him to hear the pain he's caused, what I've gone through
+because of him. I wrote a 350-page book of all the pain that I
+have endured at the hands of this man that I really needed him
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000964
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+to hear. His death has robbed me of that justice.
+Please don't rob us of justice again. Thank you.
+THE COURT: Thank you.
+MR. L
+Your Honor, I think I have one more
+client that is going to speak today,
+THE COURT: Would you spell that?
+Good morning, your Honor
+THE COURT: Good morning.
+My name is spelled A-p-o-u-s-k-a,
+D-e, space, G-e-o-r-g-i-o-u.
+Thank you, your Honor, for giving us the opportunity
+to be heard this morning.
+THE COURT: Sure.
+When I was introduced to Jeffrey
+Epstein, I was young and full of hope and the foolishness of a
+teenager. I was idealistic, and I saw the good in people.
+Jeffrey Epstein manipúlated me, coerced me and sexually abused
+me.
+Somet
+I think is very important to communicate is
+that loss of innocence, trust and joy is not recoverable. The
+abuse, spanning several years, was devaluing beyond measure and
+affected my ability to form and maintain healthy relationships,
+both in my work and my personal life. He could not begin to
+fathom what he took from us, and I say "us" because I am every
+girl he did this to, and they're all me. And today we stand
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000965
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+together, those that are present and those that aren't.
+I was a victim, and it has taken me many, many years
+to stand here and say, yes, it was me.
+I was a victim, but I
+will not remain a victim and be silent for one more day.
+Although I think it's tragic when anybody dies before their
+time, I'm extremely relieved that Jeffrey Epstein will not be
+in a position to hurt anymore children or anymore women, and
+I'm glad to be part of a group of women who are
+now bonded
+forever in the trauma that we endured at the hands of this man.
+Thank you.
+THE COURT: Thank you.
+MR.
+Your Honor,
+we had one client who was
+not able to be here but sent a message through a letter. Her
+name is
+• M-i-C-h-e-1-1-e; last name,
+L-i-c-a-t-a. And Brittany Henderson, of my office, is going to
+read her letter as instructed.
+THE COURT:) Sure.
+MS. HENDERSON: Thank you, your Honor.
+THE COURT: Yup.
+MS.
+1 What happened to me occurred many
+years ago when I was in high school, but it still effects my
+Life. I was told then that Jeffrey Epstein was going to be
+held accountable, but he was not. In fact, the government
+worked out a secret deal and didn't tell me about it. The case
+ended without me knowing what was going on, without him being
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000966
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+held responsible, without any explanation and without a chance
+for my voice to be heard. I was treated like I did not matter.
+Many years later, he was arrested again. These
+investigators and attorneys representing the United States have
+been completely different.
+I am still mad, concerned and
+confused about how he committed suicide and escaped
+responsibility again, but I know it is not the fault of the
+judge or the government attorneys.
+I was allowed to be a part of the process this time.
+My attorney was able to tell me what was going on at every
+stage because they kept him informed. Thank you for inviting
+me. It means more to me than you can ever know. I was not
+able to be here this time, but Iknow that I was allowed to be
+and I had the chance to attend this hearing, which is helping
+me in my healing process!
+The fact that I mattered this time
+and the other victims mattered is what counts. For that, I am
+grateful.
+THE COURT: Thank you.
+MR.
+: Your Honor, finally, in 2008 when I
+filed the case under the Crime Victims Rights Act, it wasn't me
+alone
+I did it with Paul Cassell and Jay Howell.
+Paul Cassell is here today, and I think your Honor
+even cited to a piece of -- an opinion of his from when he was
+on the bench, and he has some remarks to make.
+Once again, your Honor, I really do believe that this
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000967
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+is a model for how victims should be treated in a criminal
+process, and we really do appreciate it. Thank you.
+THE COURT: Thank you.
+MR. CASSELL: I'll be very brief because I know there
+are others that want to speak here. I'm Paul Cassell,
+C-a-s-s-e-1-1, previously served as a federal judge at the
+District of Utah, currently a law professor, where I teach
+crime victims rights at the University of Utah,
+College of Law.
+I just wanted to take one minute to address some
+suggestion that there would be no need for a hearing this
+morning. I think, having heard already from these powerful
+victims and recognizing how important giving those statements
+will be in the trajectory of their lives, makes clear that your
+Honor has followed exactly the right path. Legally, there is
+one precedent, which is u.s. v.
+a case that you cited
+that I wrote about a decade ago, and as explained in that
+opinion, victims have important interests in the criminal
+justice system that can only be recognized if they're given
+their
+day in court.
+With all due respect to other law professors that have
+recently written an article, I think transparency is one of the
+overriding objectives in our criminal justice system, and the
+one substantive action that I would urge your Honor to take
+today is to publish your remarks as a published opinion. The
+case is, to my knowledge, the only reported decision on
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000968
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+this particular issue, even though it's more than a decade old
+and, yet, we can see today that these problems recur in many
+other cases. Your remarks today, I think, should be published
+so that they can serve as a guide for other judges around the
+country.
+I would encourage you to add into your remarks
+la
+reference to the Crime Victims Rights Act. The Crime Victims
+Right Act promises victims
+the right to be treated
+with
+fairness, dignity and respect, and the process that we see
+unfolding this morning is a clear example of how victims can be
+treated with fairness, dignity and respect.
+So I know that your Honor is wondering what is the
+appropriate action here. Unfortunately, it seems like there
+are no other legal options, but there was a legal option for
+you to decide to exercise, which was to allow these victims to
+come forward. And if there's been one positive thing that has
+come out of the tragedies, the abuse, the other events of this
+case, it's been your decision to allow these victims to be
+heard this morning, and I encourage you to publish your
+decision and to encourage other judges to follow what is
+Clearly a model for crime victims rights and is clearly an
+example that should be followed in other cases down the road.
+THE COURT: Thank you very much. I appreciate your
+being here. I had no idea that you would be here when I wrote
+the remarks, but it was clear from the literature that you are
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000969
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+the leading expert formerly of the District Court of Utah,
+believe, and it's a pleasure to have you here today.
+MR. CASSELL: Thank you, your Honor.
+THE COURT: Thanks.
+Mr. Boies?
+MR. BOIES: Thank you, your Honor. David Boies
+of
+Boies Schiller Flexner. We have with us today five of the
+victims that we represent.
+There are a number
+of additional
+victims who either were unable to attend or are still unwilling
+to come forward publicly. This has been an enormously
+traumatic aspect of their lives, something that, as you've
+already heard and will hear more today is something that they
+can never entirely escape from.
+I want to, as prior counsel have, commend both the
+Court and counsel for the Department of Justice for the
+consideration and respect and attention that they have paid to
+the victims.
+We believe that that is not only right, as a
+matter of human dignity, but we think that is exactly what the
+law requires land intends.
+I will be more blunt than the Court has been, or
+Professor Cassell has been about Professor
+article.
+That is an article that cites no authority, and I believe there
+is no authority for his proposition. I entirely respect his
+right to advocate on behalf of his client Alan Dershowitz, who
+has retained him in connection with litigation that we've
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000970
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+brought against Mr. Dershowitz, but I would have expected that
+the Law Journal or Professor
+] himself would have disclosed
+that connection, which I think is a conflict.
+But regardless of the appropriateness of his
+disclosure, or lack of disclosure, I think that his article
+opposing allowing the victims to have a voice in this/
+proceeding is inconsistent not only with the policy that
+underlies the Crime Victim Rights Act and the very statute that
+Mr. Epstein is being prosecuted under, but it ignores the
+actual language of those statutes, and many other statutes, in
+which Congress has made clear that the purpose of the criminal
+law is no longer
+simply to punish the individual defendant, but
+it is to find some way of trying to mitigate the damage that
+has been done to the victims through restitution and economic
+mitigation, but also through the ability to confront and to
+have the court system and the justice system and the
+prosecutors treat these victims as they are victims, as they
+are human beings, and they are entitled to the respect that our
+society
+needs to give every human being. So I think that this
+is not only commendable, but I think it is what the law
+requires.
+In response to the question the Court asked, I have
+discussed this hearing with my clients. I have told them that,
+under the applicable law, the government has no alternative but
+to move to dismiss this case, and I believe under the
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000971
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+applicable law in this circuit, the Court has no alternative
+but to grant that motion.
+I think the current law is outdated, as the Court
+suggested in some of its remarks. I think there will come a
+time when either an Appellate court or the Congress will make
+clear that, just as it's possible to continue civil cases
+against someone after they have deceased, it is possible, at
+least for purposes of things like restitution, to continue
+criminal cases, but we are not there now. And, fortunately, in
+this case, there are other ways and perhaps even more efficient
+ways to vindicate the interests of the victims here.
+We greatly appreciate the remarks of the
+representative of the Department of Justice today, and we, too,
+on behalf of the victims, (are not going to stop when we walk
+out of this courtroom.
+We are going to continue to seek
+vindication against MF. )Epstein's estate and, in some senses,
+perhaps even more important, against the people who worked with
+him and enabled him.
+As you have already heard, and will hear more,
+Mr Epl
+did not act alone.
+He could not have done what he
+did, on the scope and the scale of what he did, for as many
+years as he did it without the activities and support and the
+co-conspirator activity of a number of other key individuals,
+and those individuals also need to bear their share of
+responsibility, and those people need to have a reckoning as
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000972
+
+
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+My partner Sig McCawley, who's been working with me
+for more than five years on this case, is going to, with the
+Court's permission, introduce five of our clients who will
+speak briefly to your Court. Thank you very much.
+THE COURT: Thank you very much, Mr. Boies.
+Pleasure
+to have you here.
+MS. MCCAWLEY: Thank you, your Honor, the first victim
+that would like to speak today is
+THE COURT: Can we have the spelling of your name?
+MS. MCCAWLEY: Sure.
+Sigrid, S-i-g-r-i-d, and the
+last name is M-C-C-a-w-l-e-y/and I'm a partner at Boies
+Schiller Flexner.
+THE COURT:
+Thank you.
+MS. HELM:
+Good morning.
+THE COURT: Good morning.
+Thank you, prosecutors and Judge, and the
+Court.
+My name is
+I note today I do feel
+respected and listened to; so I appreciate that, and I have to
+say that I commend the boldness of the New York prosecutors for
+pursuing a man that has, you know -- and others, that have
+clearly taken a lot from a lot of people.
+17 years ago I knew him only as "Jeffrey." I was
+recruited and brought from California to New York, and that
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000973
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+experience for the last 17 years has been a dark corner in my
+story, in my life, in my life story and that has been
+definitely made worse by my own self-shame and that -- and
+anger for normalizing all of the red flags. I feel like we are
+conditioned to do that, and that's something that needs to
+change.
+So I'm here today, you know, I'm coming forward
+because it is time to bring light to that darkness,
+and it's
+time to replace that darkness with light. And I am a survivor
+of this, and I do aim to progress further from being a
+survivor, you know. I feel I've worked hard, quite hard, to
+get to where I'm at now, and I'm definitely at a place in my
+life where I will no longer dover up. I'll no longer cover up
+what needs to be brought to light.
+Jeffrey is no longer here, and the women that helped
+him are, Ghislaine Maxwell. My experience is with Ghislaine
+Maxwell and Sarah Kelien, and they definitely need to be held
+accountable for helping him, helping themselves, helping one
+another
+carry/on this huge, almost like a system. So they need
+to be held accountable, all of them, and I would like to see
+that, certainly on behalf of myself and for everyone here.
+Thank you.
+THE COURT: Thanks so much.
+MS. MCCAWLEY: Our next client, who is going to speak
+this morning, is
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000974
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+Good morning, your Honor.
+THE COURT: Good morning. How are you?
+Okay. Thank you. My name is -
+that's V-i-r-g-i-n-i-a,
+R-o-b-e-i-t-s,
+• G-i-u, double E, for Fred, -I-e.
+I am a victim of Jeffrey Epstein and Ghislaine Maxwell
+in the dark and cruel and criminal acts they committed against
+me and hundreds of other girls and young women
+for
+• years and
+years and years, unstopped.
+Thank you for allowing me to address the Court and
+speak the truth. I commend the prosecutors from the Southern
+District of New York for the ongoing investigation and its
+pursuit of justice for us victims.
+It has given me hope, and I
+will not let go of that hope.
+When I was recruited by Ghislaine Maxwell at
+Mar-a-Lago, just before I was 17, I thought I was given a big
+break, and I'd be able to reset my life and become an actual
+real massage therapist. My hopes were quickly dashed, and my
+dreams wère stolen. Jeffrey Epstein is no longer alive, but
+this is not about how he died. This is about how he lived.
+He will not have his day in court, but the reckoning
+af accountability has begun, supported by the voices of these
+brave and beautiful women in this courtroom today. The
+reckoning must not end.
+It must continue. He did not act
+alone and we, the victims, know that. We trust the government
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000975
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+is listening and that the others will be brought to justice.
+Thank you, your Honor.
+THE COURT: Thank you very much.
+MS. McCAWLEY: The next client of ours that will be
+speaking this morning is !
+Thank you, your Honor. My name is
+R-a-n-s-o-m-e. I'm a victim of Jeffrey Epstein and
+Ghislaine Maxwell's international sex trafficking
+ring.
+I would like to thank the Court for the dignity and
+the respect you are showing me here today, as well as the other
+victims. I would also like to acknowledge and extend my
+gratitude to the prosecutors from the Southern District of
+New York for pursuing justice on behalf of the victims.
+Please, please finish what you have started. I struggled to
+find the words to adequately say how important your work is to
+us.
+For a very long time Jeffrey Epstein gamed the system
+at every level, and when he realized he couldn't do that any
+longer,
+he showed the world what a depraved and cowardly human
+being he is by taking his own life. But we, the victims, are
+still here, prepared to tell the truth, and we all know he did
+not act alone. We are survivors, and the pursuit of justice
+should not abate. Thank you, your Honor.
+THE COURT: You're very welcome.
+MS. MCCAWLEY: Our next client who is going to be
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000976
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+speaking this morning is 1
+Good morning, your Honor.
+THE COURT: Good morning.
+A-n-n-i-e,
+F-a-r-m-e-r.
+I had the opportunity to speak at Jeffrey Epstein's
+bail hearing, and I really appreciate that you heard me and
+listened to me that day. I am so sorry that others will not
+have the opportunity to stand before him the way that I did.
+But I'm here today to speak on behalf of my sister,
+who could not be here.
+Jeffrey Epstein, Ghislaine Maxwell not only assaulted
+her, but as we're hearing from so many of these brave women
+here today, they stole her dreams and her livelihood. She
+risked her safety in 1996, so many years ago, to report them,
+to no avail, and it is heartbreaking to her and to me that all
+this destruction has been wrought since that time.
+We were deeply disappointed and disturbed by Epstein's
+death and the fact that that was allowed to happen while he was
+in the government's custody, and I'm encouraged to hear that
+there will be a full investigation as to how that was allowed
+to happen.
+But it is extremely important, as others are saying,
+that he did not act alone and that the other people that were a
+part of what he did are held accountable and that that
+investigation continues.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000977
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+I believe that we have a real problem in this country
+with perpetrators of sexual abuse and sexual assault being held
+accountable. There are so many roadblocks to victims being
+heard, to cases being investigated thoroughly, and then to
+those cases being prosecuted. And so I think this is a really
+important signal to send a message to victims out there that
+people will take you seriously, people will follow through, and
+that even those in power, as we have unfortunately seen, that
+has not been often are able to escape that,
+that even those in
+power will be held accountable.
+Thank you.
+THE COURT: Thanks so much/
+MS. MCCAWLEY: Our nextaclient,
+who's going to address
+the Court is Marijke Chartouni. She says it much more
+beautifully than I do; so Ill let her say it.
+MS. CHARTOUNI:
+My first name is spelled,
+M-a-i-i-j-k-e; last name is C-h-a-r-t-o-u-n-i.
+My name is Marijke
+and I am a victim of
+Jeffrey Epstein and the sophisticated sex trafficking operation
+he ran,
+where/ he allegedly was to be a financier.
+I was 20 and previously modeled and was living in the
+west Village. I met a young woman named Rena through a mutual
+friend. We were friends for a few months. She was an amazing
+artist and liked to party. One day she called me and asked if
+I was interested in meeting a friend of hers. She told me he
+wanted to meet me and really liked blonds, and I thought he was
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000978
+
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+our age and liked to do the same things we did at that age; so
+I agreed.
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+On a sunny, crisp day, we took the train together to
+the Upper East Side. She then began to talk a little bit about
+him on our way to his house. I was at his house. I was
+sexually assaulted by both Rena and Jeffrey Epstein in his
+mansion. It left me feeling both disgusted and betrayed.!
+As we walked home
+to the subway afterwards,
+she
+continued to tell me about the man who had just abused me with
+her participation. She seemed exhilarated from the horrific
+experience. I was shocked and in a daze.
+This is a few things
+that she had told me. She told me he went to !
+Union. He
+was a mathematical genius. That he had favorite girls that he
+would take to Chanel for 15-minute, all-you-can-buy shopping
+trips. She told me his right-hand person had connection to the
+arts and the fashion world, and she could help me.
+This is not my complete story. I'll stop here. I'm
+in a good, stable place in my life, and I had decided to come
+forward to bera voice to the victims who may not be able to
+tell their story, or at least not yet. I feel like I am a
+SurvivoI.
+Thank you, Judge Berman, for inviting victims to speak
+today before you. We hope the government is listening very
+closely to the words we are saying.
+THE COURT: Thank you very much.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000979
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+MR. BOIES: Your Honor, just very briefly.
+THE COURT: Sure.
+MR. BOIES: I would like to express to the Court how
+proud I am of all of these women who have come forward. It's
+taken an enormous amount of strength and courage for them to do
+so. Thank you.
+THE COURT: Thanks, Mr. Boies. Hold on one second.
+(Pause)
+MS. LERNER: Thank you, your Honor.
+My name is
+Kimberly Lerner, of Lerner and Lerner, and your Honor, with
+your permission, I would like my client, Jennifer Aroz, to
+stand next to me.
+THE COURT: Sure.
+MS. LERNER: Would that be okay?
+THE COURT: Absolutely.
+MS. LERNER: Your Honor, I would like to begin by
+saying that I am in awe of all of these beautiful women. I
+just want to let you know,
+on behalf of Jennifer and myself, we
+admire you, we respect you, and we applaud you, and you are
+brave suryivors. And Jennifer's heart is with all of you, and
+we
+thank you so much for coming forward.
+Jennifer, when she went public, she thought she was
+one of the only ones, and to see all of these faces is, I know,
+amazing for her.
+Jeffrey Epstein was a predator, a pedophile and a sick
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000980
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+individual. However, he was also a thief. He stole Jennifer's
+childhood dreams, her innocence and her self-confidence.
+She
+was 14 years old. What he could not buy, he forcibly took.
+Why? Because he surrounded himself with a network of powerful
+people who not only looked the other way, but also actively
+facilitated and participated in his sexual abuse of children.
+Jeffrey Epstein thought he was above the law,
+and
+essentially he was until now.
+The system let Jennifer and the
+other victims down, but it does not have to end here. We ask
+the U.S. Attorney's Office and the FBI to bring all of
+Epstein's enablers and co-conspiratofs to justice.
+It has taken Jennifer 18 years to find her voice, and
+again, Jeffrey Epstein has tried to silence her. While she
+will never have her chance to face him in court, he no longer
+has any power over her
+Today, this brave survivor will be
+heard.
+MS. AROZ: Thank you for allowing me to be able to
+have my chance in court today, to be able to tell you what this
+horrific man did to my life. You can't even imagine how much
+it affected my childhood, all the way through my adult life.
+He robbed me of my dreams. He robbed me of my chance to pursue
+a career I always adored. He stole my chance at really feeling
+love because I was so scared to trust anyone for so many years
+that I had such severe anxiety. I didn't want to leave my
+house let alone my bed.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000981
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+The fact that he felt entitled to take away my
+innocence, the fact that he felt that he could do whatever he
+wanted, regardless of the laws, hurts me so very much. It took
+me years to tell anyone what Epstein did to me because I was so
+ashamed and embarrassed at what people would say or think of me
+until I found out there were other victims, girls just like me.
+I knew I could no longer keep my silence no matter how
+ruthless
+and powerful Epstein was, and still is even after
+his death.
+The fact I will never have a chance to face my
+predator in court eats away at my soul.
+Even in death, Epstein
+is trying to hurt me. I had hoped to at last get an apology,
+but this evil man had no remorse or caring for what he did to
+anyone. I felt let down by the people who were supposed to
+watch him in prison. They let this man kill himself and kill
+the chance of justice for so many others in the process, taking
+away our ability to speak.
+Out of all the damages and side effects that Epstein
+caused by his heartless and selfish acts, it's very hard to put
+my feelings and emotions into words, trying to let his
+horrendous actions go and attempting to forgive him, has been
+so difficult for me. Yet, as hard as it's been to come so
+publicly forward, I refuse to let Epstein take me as a victim
+anymore.
+I am a survivor. The many that stand before me here
+today that have shared the horrific experiences with this
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+:
+CA/Aronberg-000982
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+deplorable human being, because even though this weak, evil
+coward tried to steal all of our childhoods, tried to steal all
+of our innocence and tried to steal all of our means of
+justice, he will never steal our inner strength, and he will
+never, ever, ever steal our voice. Thank you so much.
+THE COURT: You're welcome.
+MS. GIBBS: Good morning, your Honor. Teri Gibbs,
+I-e-r-i, G-i-b-b-s. For the record, I am a California
+attorney. I'm not admitted to the New York State bar. I am
+here to make a statement on behalf of New York attorney, Lisa
+Bloom. I work for her firm, The Bloom Firm.
+Lisa Bloom represents four of Jeffrey Epstein's
+victims, Jane Doe 6, for the record, Jane Doe 7 and Jane Doa 8.
+I am so proud of all of you victims who are here today and are
+able to voice yourselves today. I will not and cannot comment
+on the criminal case, or Ms. Bloom's communications with her
+clients.
+Ms. the record. Here are the statements.
+of sane Doé 6.
+Io the Honorable Richard M. Berman. Jeffrey Epstein
+stole my innocence. He gave me a life sentence of guilt and
+shame. I do not consider myself a victim. I see myself a
+survivor. The abuse that I endured cannot continue. Let's
+stop this before it happens to other young women. Jane Doe.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000983
+FILED: PALM BEACH COUNTY, FL, |
+
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+Statement of Jane Doe 7. To the Honorable Richard M.
+Berman. I used to be relatively carefree, inquisitive, hopeful
+and excited about life, but my life changed because of Jeffrey
+Epstein. My perspective on life became very dark when I was
+unknowingly recruited by one of his agents. Jeffrey Epstein
+ruined me. His recruiter ruined me. The far-reaching
+consequences of that day ruined my family's lives.
+I've chosen to remain anonymous in order to protect my
+family from unwanted media attention.
+I was just trying to figure out my path in life when I
+encountered Jeffrey Epstein in his New York City mansion. I
+cannot even begin to summarize the many detriments this
+experience of sexual assault has had on my life. Immediately
+following the incident, I(was unable to function and be around
+other people. My parents had to rescue me and bring me home,
+where I became a recluse for years.
+I was changed forever and buried my assault deep down,
+where the darkness couldn't hurt me anymore, but of course, it
+has always been here, lingering and affecting me unconsciously.
+At the timé, I was mired in shame, guilt and humiliation. I
+had somehow tricked myself into thinking that I had allowed the
+assault to happen, that I did it to myself, that I don't
+deserve to be alive or to be loved. I believed that I was a
+disgusting, shameful person who does not deserve to ever be
+happy. These are the thoughts I've lived with on a daily
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000984
+
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+Furthermore, because
+I couldn't tell anyone, out of
+fear of judgment, blame or retaliation, keeping this secret
+completely hindered my ability to uncover why these issues
+existed for me, which could have led to a path of healing over
+the years.
+It is time for those of power to do the right thing.
+It is time for compassion toward our fellow human
+beings to
+reign over money, power and greed. We need to protect our most
+vulnerable to allow them a chance at a normal life, and nothing
+should come in the way of that. I believe that for future
+generations, including my own children, this case will set a
+precedent that victims must no longer suffer in silence on our
+own or be shamed for coming forward to seek protection.
+This case should demonstrate to those who want to harm
+others that there will be a reckoning, and they will pay dearly
+for the harm they infíict on innocent people. Judge Berman, I
+thank you for from the bottom of my heart for this forum and
+opportunity.
+To all of those survivors who came before me, I
+commend your bravery. There is no way I could have done this
+without you.
+Thank you to the public following this story, for your
+outrage and desire for answers, which will hopefully move this
+case forward so that victims can stop having to relive their
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000985
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+experiences every day and move on to begin to heal.
+God bless the victims, their families, the
+investigators and public servants working so diligently to find
+those answers and to right all these wrongs. Jane Doe 7.
+(Continued on next page)
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+THE COURT: Thanks very much.
+MS. GIBBS: One more. Statement of Jane Doe 8.
+In the past few weeks, I have had to reflect on my
+interaction with Jeffrey Epstein and realized that, though I
+have yet to put it all behind me, I am still a victim. I say
+this because I have to come to terms with it in an effort to
+truly get past the abuse I suffered at the hands of
+Ep
+Pursuing criminal
+penalties against him
+and
+having an
+opportunity to address the egregious crimes he committed
+against me and other young woman would have helped my recovery
+process. This all came to an abrupt halt when he took his own
+life. This point
+of disclosure is lost.
+I cannot say that I am pleased he committed suicide,
+bút I am at peace knowing he will not be able to hurt anyone
+else. However, a sad truthremains. I, along with other
+people, will never have an answer as to why. I will never have
+an apology for the wrongdoing. And most importantly, Epstein
+will not be justly sentenced for his crimes. Now I sit in my
+home questioning the well-being of those girls like myself. In
+choosing death, Epstein denied everyone justice.
+Any efforts made to protect Epstein's name and legacy
+send a message to the victims that he wins and that he is
+untouchable. I understand his case may be dismissed or closed,
+but this makes me feel as though I, and anyone else who fell
+pry to his hands, simply do not matter.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000987
+
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+I ask that you very seriously consider the final
+decision, because it will undoubtedly affect all other facets
+of this case, including any future charges brought against the
+recruiters or third parties to his crimes. I do not want the
+narrative to be, Those poor girls. I want to send a message to
+anyone who would consider engaging in similar acts to think
+twice beforehand. I want some sort of closure for those of us
+who relive those horrible moments where we were
+assaulted,
+abused, and taken advantage of by Epstein.
+You have the opportunity to help us seek that closure.
+I appreciate your time and consideration and ask for your
+continued support in dealing with this case to illustrate that
+we, Epstein's victims, do matter,
+Sincerely, Jane Doe 8.
+On behalf of Disa Bloom and The Bloom Firm, thank you,
+your Honor.
+THE COURT: Thank you, Ms. Gibbs.
+Did we have any other victim's counsel or victims?
+Ms. Allred.
+MS. ALLRED:
+Good morning, your Honor.
+THE COURT: Good morning. How are you?
+MS. ALLRED: Fine. Thank you.
+Allred, Maroko & Goldberg by Gloria Allred,
+G-1-o-r-i-a A-1-1-r-e-d.
+Your Honor, thank you so much for this opportunity to
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000988
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+afford the victims their voice, because many of them have never
+spoken before. They never spoke in Florida. They never spoke
+anywhere. They never told their mother. They never told their
+father. They never told their family members. This is an
+opportunity for them to be heard. We thank you for that.
+Your Honor, for 43 years my firm has been the leading
+women's rights private law firm in the United States.
+We have
+helped thousands of victims. And I, as an officer of the
+court, and as a believer in the system, have tried to encourage
+the victims to have confidence in the system that should
+provide them access to justice that should help them to assert
+and vindicate their rights in a court of law. It has been
+increasingly difficult in this case for me to say to my clients
+that they should have confidence in the system of justice given
+what has occurred in this case, People v. Jeffrey Epstein.
+Having
+said that, I am encouraged by the fact that
+this court, essentially, in an unprecedented situation where
+the defendant is deceased, is still affording these victims an
+opportunity to be heard. So we thank you for that. It is some
+encouragement.
+Your Honor, you also asked do our clients wish to be
+heard in reference to some of the issues that have been raised
+this morning, including what should happen into this case.
+Your Honor, there has been a suggestion that the court should
+investigate the circumstances of the death of Mr. Epstein. I'm
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000989
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+JÅRSEPS3
+not going to repeat the arguments made by counsel, but I would
+say that if there is jurisdiction, and I know that is a legal
+issue which has been previously argued, that certainly it would
+increase the confidence of my clients. Not just my clients,
+but victims all over, and some are, by the way, located in
+other parts of the world, to have the court oversee the
+investigation.
+We are encouraged by the sensitivity of the attorneys
+for the United States Attorney's office for the Southern
+District of New York and the investigation that is going on
+with the separate team. However, and, of course, the defense
+is also conducting its own investigation. But I do think the
+greatest confidence would befif the court in some way would be
+able to oversee an investigation because the court is a neutral
+party. And although the court certainly has a stake in finding
+out what happened to defendants who are in the custody of the
+federal system and who should be there to face the prosecutors
+and the charges against them, but now are not because clearly
+the system has failed.
+And the United States Attorney has admitted that, and
+even before he admitted that, everybody knows the system
+failed. Failed the victims, failed the court, failed everyone.
+In any event, your Honor, having seen so many
+thousands of victims of gender violence, sex harassment, sexual
+assault, I've dealt with child sex trafficking, child
+SOUTHERN DISTRICT REPORTERS, P.Ç.
+(212) 805-0300
+CA/Aronberg-000990
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+molesters, I mean, this is a unique case because there are so
+many victims and so many failures of the system. At this
+point, what we would really ask for is not just words, but
+words have been helpful, but deeds, and that is very important.
+In addition, I would like to say, throughout this case
+is the running theme of the betrayal of trust. Betrayal of
+trust by Jeffrey Epstein. Betrayal of trust by the system.
+And betrayal of trust to the victims who had a fight
+to
+justice. And the Crime Victims' Act should not just be words,
+it should have meaning and it should be enforced.
+In essence, we are asking, although you may need to,
+of course, grant this motion to dismiss, I think because the
+court has shown sensitivity to victims and victims' needs, if
+there is a way to at least keep the record open so that victims
+who have not been able to be physically present in the
+courtroom today
+and who have not been able to submit to the
+court any letters, victim impact, and who have not been able to
+secure attorneys or speak to attorneys yet -- so, for example,
+I'll still hearing from victims who I have not been able to
+meet with yet because they just recently are now contacting
+so if they could submit, at least for the record, their
+victim impact statements, that, I think, would be a very
+important assistance to them. So that would be, at least they
+would know that what they are sharing is on the record.
+So, in summary, I would say that they are looking
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000991
+
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+forward to the very serious investigation by the United States
+Attorney of who may have conspired in this case, and that is
+very hopeful, and we're hoping that everyone who may have a
+role to this criminal prosecution will submit that evidence.
+This is about power. This is about many victims
+having lived in fear -- fear of the rich, the powerful, the
+famous, fear that the system will not afford them Justice.
+So
+fear of not coming forward. And fear, of course,
+is a weapon
+that the rich, powerful, famous, and sexual predators used to
+silence the victims. But that is gone for a lot of victims
+because they refuse to suffer in silence.
+Finally, it does take courage to speak truth to power.
+We thank this honorable court for giving these victims a voice.
+We thank them, even after the death of the defendant, for
+showing respect for the victims, allowing them dignity,
+allowing them a voice. We do want truth, we do want justice,
+we do want accountability, and we do want those conspirators to
+face the justice system.
+Your Honor, right now we have two of our clients who
+would like to address the court.
+THE COURT: Sure.
+MS. ALLRED: Then I have a couple of statements on
+victims who do not wish to address the court.
+As they come up, we'll give them the opportunity to
+say either their name or Jane Doe.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000992
+
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+By the way, thank you, your Honor, for allowing some
+of these victims to be called Jane Doe. What number the court
+affords to them, we'll accept whatever that is.
+Thank you.
+THE COURT: We're up to nine.
+MS. ALLRED: Thank you.
+Hello. My name is
+That is
+T-e-a-1-a D-a-v-i-e-s.
+I was going to start this statement by saying that I
+was à victim of Jeffrey Epstein. But that's not the case. I'm
+still a victim of Jeffrey Epstein. I'm still a victim because
+the fear of not being heard stopped me from telling my story
+for so many years. This Lingering fear almost stopped me from
+attending this monumental movement of strength and power.
+I'm still a victim because I am fearful for my
+daughters and everyone's daughters. I'm fearful for their
+future in this world, where there are predators in power, a
+world where people can avoid justice if their pockets run deep
+enough
+I'm still a victim because the 17-year-old Teala was
+manipulated into thinking she had found someone who cared,
+someone who wanted to help. Jeffrey knew I had nowhere to go.
+He knew I was vulnerable, and he took advantage of that poor
+girl, who will never be the same.
+I cannot eat at the thought that Jeffrey Epstein -- I
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000993
+
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+cannot eat at the thought of Jeffrey Epstein not serving the
+time he needed to realize the pain and suffering he caused so
+many vulnerable young girls. He thought he was untouchable,
+and honestly, so did I. I thought he was the most powerful
+person I would ever meet.
+But the end is here and here I stand becoming more
+powerful than he will ever be. Thank you.
+THE COURT: Thank you.
+JANE DOE: Jane Doe.
+Um, in 2004, when I was 15 years old, I flew on
+Jeffrey Epstein's plane to Zorro Ranch,
+where I was sexual
+molested by him for many hours. What ) remember most vividly
+was him explaining to me how beneficial the experience was for
+me and how much he was helping me to grow. Yikes.
+I remember feeling so small and powerless, especially
+after he positioned me by laying me on his floor so that I was
+confronted by all the framed photographs on his dresser of him
+smiling with wealthy celebrities and politicians.
+After he finished with me, he told me to describe in
+detail how good my first sexual experience felt. That was the
+first of many lies I was forced to carry for him, the weight of
+which proliferated my trauma.
+I felt powerless not merely
+because one man wanted to strip me of my innocence, but because
+I was the victim of a system that just enfranchises human
+beings, making them vulnerable to pedophilic exploitation.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000994
+
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+As unjust as what happened to me was, I believe that
+experience to be a symptom of insidious and pathological
+violence that extreme wealth yields, a violence which
+ultimately stays hidden through channels of extreme power that
+serve it.
+I first identified with this feeling the night after I
+was molested by Epstein, when another girl and I took out two
+of his ATVs and raised them across the mesa.
+I crashed mine
+and expressed my concern to the other girl of getting in
+trouble, which she replied to me, Don't worry, no one gets in
+trouble for anything here.
+Even as a child, I understood/
+in a sad and precocious
+way, what I hoped we have the ability of changing now. Even
+though Epstein is dead, there is still justice to be brought
+for the crimes we felt powerless against concealing for him and
+the system that supported him for all these years.
+Thank you.
+THE COURT: You're very welcome.
+MS. ALLRED: Thank you.
+Your Honor, may it please the court. I would like to
+read a statement for Jane Doe, my client, who is present in
+court, but requested that I read it.
+We only have one opportunity at childhood. One
+opportunity to develop. One opportunity to find direction for
+our lives.
+Jeffrey Epstein robbed and denied me at each
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000995
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+opportunity he had.
+I came from a small Texas town, not far from the New
+Mexico border. My mother died when I was 11, after suffering
+from cancer for many years. My father was devastated, as were
+my siblings and I. My father was saddled with debt. My only
+hope for college was to get a scholarship.
+When I was 15, I was a blossoming freshman
+In high
+school and was trying to carry on my mother's dream.
+She
+wanted me to
+I the violin. After school, I would often go
+to a mall in a nearby city. A lady approached me and saw I had
+a violin case with me and asked if I was any good. We talked
+about the violin, my family, and why Ihad clothes that looked
+like hand-me-downs.
+The lady told me she works for a very rich man who had
+a home close by and that he would pay to hear me play. I was
+told that if I could get away, she could arrange for
+transportation to and from his place and have me back before
+anyone knew I was gone. After some hesitation, I agreed. This
+decision was the beginning of the end of my childhood.
+The man who only identified himself as J or Jeff had
+asked if I would give him a massage, and over four visits,
+eventually progressed to forced oral copulation. The money he
+gave me further placed my young soul into a perverse sense of
+hell.
+I was so utterly disgusted with myself and what he did
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000996
+
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+to me that I stopped going
+to see him. I had documented the
+events with a Texas rape crisis center about the man I know now
+as Jeffrey Epstein.
+Epstein targeted and took advantage of me, a young
+girl, whose mother had recently died a horrific death and whose
+family structure had deteriorated. His actions placed me, a
+young girl, into a downward spiral to the point where
+I
+purchased a gun and drove myself to an isolated place to end my
+suffering.
+A voice that could only have been from my mother told
+me, quote, I am not the victim, I am the victor, and I dare not
+pull the trigger." I returned the gun days later.
+Epstein is a coward/
+He lived his life leaching off
+the souls of inspiring, young girls due to the fact that he
+could never know how it feels inspired to live. Like a leach,
+once Epstein had his fill, he would unlatch and seek out
+another victim.
+The only sense of justice I had hoped to see was
+Epstein being sentenced. However, Epstein died as he lived,
+taking the easy way out without any responsibility.
+Your Honor, the next statement is also a statement of
+a Jane Doe. May it please the court.
+I was a 16-year-old virgin when Jeffrey Epstein first
+raped me. I was naive and gullable. He was a pillar of
+finance and a giant, in the world that I was an insignificant
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+!.
+CA/Aronberg-000997
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+J8RSEPS3
+part of. I was so impressed that this great man would even
+talk to me and impart any of his wisdom on me.
+I gladly jumped
+at the chance to meet him again, when he told me how impressed
+he was with my personal story and maturity for my age.
+When I was in his presence, he made an effort to call
+celebrities and influential people on speakerphone, like
+Academy Award-winning actresses and super models,
+who
+always
+answered his calls. Sadly, I was impressed.
+He was friends with former and future heads of states
+and every other fixture in the New York social scene and
+beyond. He knew important people in my own world that I looked
+up to and revered, but he spoke about them like they were sweet
+distractions far beneath his/stature. He could easily reach
+down from his position and influence the people directly
+involved with my daily life and future prosperity. I was the
+perfect victim.
+My whole lifé was extremely turbulent. But one of my
+mother's greatest wishes was
+that all her children would
+graduate from respectable universities. He promised me that he
+would writé me a letter of recommendation for Harvard if I got
+the grades and scores needed for admission. His word was worth
+¿ lot, he assured me, as he was in the midst of funding and
+leading Harvard's studies on the human brain, and the president
+was his friend.
+The fact that all of you already know these next
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000998
+
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+details, which I'll share, should ignite fire instead of induce
+the complacency they did in the past, when heard repeatedly
+over the years, but yes, an innocent massage turned sexual
+almost immediately.
+"Here, come. Come help me with a kink in my shoulder
+while we finish our discussion."
+A large vibrator and a couple
+of hundred dollars, disgust and dirty secret, more praise and
+imparted wisdom from a godlike figure, a deliberate diabolical
+depression of grooming and submission for his pleasure and
+release.
+Even if I resisted, I was no match for him. I felt
+powerless, ashamed, and embarrassed,
+I wanted to vomit
+remembering these moments.
+What I learned in those depraved sessions, staring up
+at the dome ceiling in his private massage room, tore a violent
+hole through any normal sexual awakening. I'm haunted forever,
+having learned everything there is to know about sex through a
+vile criminal.
+Every time a new molestation would bring a new
+lesson, the progressive and constant unwinding. I was nothing
+more than a teenage prostitute. I was his slave.
+I had never even kissed a boy before I met him, and
+never throughout the horrific abuse did Jeffrey Epstein kiss me
+even once.
+When he stole my virginity, he washed my entire
+body compulsively in the shower and then told me, "If you're
+not a virgin, I will kill you." And then I wasn't a virgin
+anymore.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-000999
+
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+He forcefully penetrated me. I was numb.
+There was
+pain, but his use of the vibrator and his fingers in previous
+sessions with me had left a black hole-like void between my
+legs. I protested, but he forced my face into the bed to
+stifle my cries. That was my first time.
+I got a few hundred dollars, as usual, as he led me
+out of his mansion with assurances that I was on the right path
+guided by him. I lied to myself and tried to believe him. I
+became a hollow shell. If I missed an appointment, he
+threatened me and let me know who was in charge. "Do you know
+how important my time is? I'll bury you.
+I owe this -- I
+won't say the word -- F'ing town." He would hang up.
+I would stand there frozen in the street, terrified
+that his assistant would call to reschedule. I made sure to
+stay in line and not disobey him. I was in complete denial.
+Being paid after every scheduled meeting felt routine and
+disgusting. He was the [
+of the universe and the world
+bent to his will,
+He would eventually brag to his assistants about my
+ability to please him sexually right in front of me, leaving me
+feeling grotesque and worthless. Everything in my outside life
+was falling apart. I distanced myself from friends and grew
+further away from my family. I felt less human after each
+ordeal. My psyche broke down completely and wouldn't let me
+continue.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001000
+
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+One day I walked out of his residence and passed a
+girl similar to myself. When
+I turned around, she was entering
+Jeffrey's residence. He no longer even tried to schedule his
+appointments with other girls in secrecy from me. Maybe he
+never did. I was too stupid to see.
+My world shattered.
+I had been so naive. I had an
+epiphany in a calvary of desperation. I realized
+I
+was just
+one of many young girls he had in rotation come
+to perform for
+him for money. I went into a deep depression and never lifted
+completely. I wanted to inflict pain on myself. I was
+humiliated, angry, and suicidal. I Iocked myself away from
+everything. I cut myself off forever from the world I had
+known.
+I endured the dadly agony of knowing my life would
+never be the same.
+I could never go back to New York City and
+the wonderful life I had taken for granted before I met this
+demon named Jeffrey Epstein.
+This creature had manipulated and outwitted the whole
+system,
+including some of the most intelligent scientists,
+political people, prosecutors, and power players. How easy was
+It
+to manipulate a 16-year-old virgin who never had a boyfriend
+and came from a background of hardship with no parental
+guidance or support.
+I went to therapy and was given antidepressants for
+severe anxiety and depression. My only solace, years later,
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001001
+
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+was my desire to succeed on my own terms. I emersed myself
+into my studies and was accepted to every college I applied to,
+graduating from a top university. To this day, there is still
+an ache in my being that I did not apply to Harvard in fear of
+his influence there.
+They say you never forget your first. I'm in a
+never-ending nightmare trying to do just that. I'm forever
+suffering because everything reminds me of that
+horror. This
+new wave of worldwide publicity only worsens my despair.
+It was only many years later that I was finally
+intimate with a man again, and those moments were marred by my
+actions as a child with Jeffrey Epstein.
+Even now is
+impossible to separate his treachery from any care of a good
+man.
+For one brief moment there was elation when he was
+recently arrested, I would finally get my chance to see him
+again face to face and show him what I had become, that I had
+succeeded on my own, that
+I was worth something in spite of his
+abuse, and that I had surmounted the monumental obstacles he
+laid before me throughout my entire life since falling prey to
+nim.
+I had hoped humanity would prevail, but it seems to me
+that he outsmarted everyone so far, and his ghost is still
+laughing at us. I appeal to all of those just and true that
+his evil legacy and his death not stand in the way of
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001002
+
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+resolution and justice for all of his underagedi victims.
+Thank you, your Honor.
+And then just one last one, and this is much shorter.
+Statement of Jane
+Doe, also my client.
+I was a model in another country when I came to the
+United States. I was told by a booker that I needed to meet
+with a man named Jeffrey Epstein, who was the owner
+of
+Victoria's Secret. The booker told me that Mr.
+Epstein could
+help me get into Victoria Secret's world.
+It was my childhood dream to be a Victoria's Secret
+model. So I went one day in the afternoon and I met
+Mr. Epstein in his office in his mansion in New York. A woman
+introduced herself and suggested to me that I should be
+extremely nice to Mr. Epstein, because if he liked me, he would
+probably have photographers shooting photos of me right away.
+The told me to go upstairs and directed me to Jeffrey
+Epstein's office.
+Mr. Epstein had a
+robe on and we
+chatted very briefly. I had my portfolio of photos, but he
+didn't even look at it. Suddenly, he took his robe off and got
+close to me.
+I didn t know what was going on.
+I got up to leave, but the door was locked.
+I didn't know what was going on. It was my first
+afficial meeting to be cast in the United States. I was a
+young girl and confused. He got very close to me, and I had a
+skirt on. He started to touch my genitals. I refused him.
+Then he went to the massage table and showed me the vibrator.
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001003
+
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+I took it and threw it at him.
+At that point, I ran to the door again and figured out
+how to get out of there. A girl outside asked me where I was
+going and she said to be careful. She said that Mr. Epstein
+knew a lot of powerful people, including Bill Clinton, and that
+if I didn't do what Mr. Epstein wanted, I would not be able to
+have any job in the industry.
+I was so scared. I couldn't wait to get out of there,
+as os my
+and I left. I took the train home. I had spent all of my
+savings getting Victoria's Secret lingerie to prepare for what
+I thought would be my audition. But instead, it seemed like a
+casting call for prostitution.
+I
+felt like I was in hell.
+Thank you, your Honor.
+Thank you.
+THE COURT: Thank you, Ms. Allred.
+was there anybody else, any victim's counsel or any of
+the other victims who have not been heard and wish to be heard?
+Wel1, OK then. All I have to say, really, is thank
+you, all of you, for your participation in today's remarkable
+hearing.
+YI think everybody has benefited greatly from your
+input, and especially from the testimony of victims here today
+and who have had the courage to come forward.
+We have also benefited throughout these proceedings,
+however brief altogether,
+from the attorneys' legal advocacy
+and their written and oral submissions. I'm grateful to them
+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001004
+
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+as well, both for the government and the defense and those
+representing the victims.
+Finally, we're also grateful to the press for their
+very diligent coverage of seemingly every detail of this case.
+That concludes our work for today and we stand
+adjourned.
+Thanks.
+(Adjourned)
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+SOUTHERN DISTRICT REPORTERS, P.C.
+(212) 805-0300
+CA/Aronberg-001005
+FILED: PALM BEACH COUNTY, FL, [
+
+
+Appendix 12
+NOT A CERTIFIED COPY
+CA/Aronberg-001006
+FILED: PALM BEACH COUNTY, FL, •
+
+
+The Man Who Had Everything: Jeffrey Epstein craved big
+homes, elite friends and underage girls
+By Andrew Marra
+Posted Jul 17, 2019. at 6:02 AM
+From the archives: When Palm Beach detectives started asking
+questions and teenage girls started talking, a wave of legal resistance
+followed.
+Editor's Note: This article appeared in The Palm Beach Post on August 14, 2006, three weeks after
+Jeffrey Epstein's arrest in Palm Beach County on a charge of felony solicitation of prostitution.
+WINGED GARGOYLES guarded the gate at Jeffrey Epstein's Palm Beach mansion. Inside,
+hidden cameras trolled two rooms, while the girls came and went.
+For the police detectives who sifted through the garbage outside and kept records of visitors, it
+was the lair of a troubling target.
+Epstein, one of the most mysterious of the country's mega-rich, was known as much for his
+secrecy as for his love of fine things: magnificent homes, private jets, beautiful women,
+friendships with the world's elite.
+But at Palm Beach police headquarters, he was becoming known for something else: the
+regular arrival of teenage girls he hired to give him massages and, police say, perform sexual
+favors.
+Epstein was different from most sexual abuse suspects; he was far more powerful. He counted
+among his friends former President Bill Clinton, Donald Trump and Prince Andrew, along
+with some of the most prominent legal, scientific and business minds in the country.
+When detectives started asking questions and teenage girls started talking, a wave of legal
+resistance followed
+CA/Aronberg-001007
+
+
+» NEW: Jeffrey Epstein: Lawyer said financier had sex with woman during workrelease
+If Palm Beach police didn't know quite who Jeffrey Epstein was, they found out soon enough.
+Epstein, now 53, was a quintessential man of mystery. He amassed his fortune and friends
+quietly, always in the background as he navigated New York high society.
+When he first attracted notice in the early 1990s, it was on account of the woman he was
+dating: Ghislaine Maxwell, daughter of the late British media tycoon Robert Maxwell.
+Iri a lengthy article, headlined "The Mystery of Ghislaine Maxwell's Secret Love," the British
+Mail on Sunday tabloid laid out speculative stories that the socialite's beau was a CIA spook, a
+math teacher, a concert pianist or a corporate headhunter.
+"But what is the truth about him?" the newspaper wondered, "Like Maxwell, Epstein is both
+flamboyant and intensely private."
+The media frenzy did not begin in full until a decade later. In September 2002, Epstein was
+flung into the limelight when he flew Clinton and actors Kevin Spacey and Chris Tucker to
+Africa on his private jet.
+Suddenly everyone wanted to know who Epstein was. New York magazine and Vanity Fair
+published lengthy profiles. The New York Post listed him as one of the city's most eligible
+bachelors and began describing him in its gossip columns with adjectives such as "mysterious"
+and "reclusive."
+Although Epstein gave no interviews, the broad strokes of his past started to come into focus.
+Building a life of extravagance
+He was born blue-collar in 1953, the son of a New York City
+department employee, and
+raised in Brooklyn's Coney Island neighborhood. He left college without a bachelor's degree
+but became a math teacher at the prestigious Dalton School in Manhattan.
+The story goes that the father of one of Epstein's students was so impressed with the man that
+he put him in touch with a senior partner at Bear Stearns, the global investment bank and
+securities firm.
+CA/Aronberg-001008
+
+
+In 1976, Epstein left Dalton for a job at Bear Stearns. By the early 1980s, he had started J.
+Epstein and Co. That is when he began making his millions in earnest.
+Little is known or said about Epstein's business except this: He manages money for the
+extremely wealthy. He is said to handle accounts only of $1 billion or greater.
+It has been estimated he has roughly 15 clients, but their identities are the subject of only
+speculation, All except for one: Leslie Wexner, founder of The Limited retail chain and a
+former Palm Beacher who is said to have been a mentor to Epstein:
+Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a
+block on Manhattan's Upper East Side. It is reported to have, among its finer features, closedcircuit television and a heated sidewalk to melt away fallen snow.
+That townhouse, thought to be the largest private residence in Manhattan, is only a piece of
+the extravagant world Epstein built over time.
+In New Mexico, he constructed a 27,000-square-foot hilltop mansion on a 10,000-acre ranch
+outside Santa Fe. Many believed it to be the largest home in the state.
+In Palm Beach, he bought a waterfront home on El Brillo Way. And he owns a 100-acre
+private island in the Virgin Islands,
+» PHOTOS: The players in the Jeffrey Epstein saga
+Perhaps as remarkable as his lavish homes is his extensive network of friends and associates at
+the highest echelons of power. This includes not only socialites but also business tycoons,
+media moguls, politicians, royalty and Nobel Prize-winning scientists whose research he often
+funds.
+"Just like other people collect art, he collects scientists," said
+Nowak, who directs the
+Program for Evolutionary Dynamics at Harvard University and was reportedly the recipient of
+a $30 million research donation from Epstein.
+Epstein is said to havę befriended former Harvard, President Larry Summers, prominent law
+Professor Alan Dershowitz, Donald Trump and. New York Daily News Publisher Mort
+Zuckerman.
+CA/Aronberg-001009
+
+
+And yet he managed for decades to maintain a low profile. He avoids eating out and was rarely
+photographed.
+"The odd thing is I never met him," said Dominick Dunne, the famous chronicler of the trials
+and tribulations of the very rich. "I wasn't even aware of him," except for a Vanity Fair article.
+Epstein's friendship with Clinton has attracted the most attention.
+Epstein met Clinton as early as 1995, when he paid tens of thousands of dollars to join him at
+an intimate fund-raising dinner in Palm. Beach. But from all appearances, they did not become
+close friends until after Clinton left the Oval Office and moved to New York.
+Epstein has donated more than $100,000 to Democratic candidates' campaigns, including John
+Kerry's presidential bid, the reelection campaign of New Mexico Gov. Bill Richardson and the
+Senate bids of Joe
+,, Hillary Rödham Clinton, Christopher. Dodd and Charles
+Schumer.
+Powerful friends and enemies
+A Vanity Fair profile found cracks in the veneer of Epl
+life story. The 2003 article said he
+left Bear Stearns in the wake of a federal probe and a possible Securities and Exchange
+Commission violation. It also pointed out that Citibank once sued him for defaulting on a $20
+million loan.
+The article suggested that one of his business mentors and previous employers was Steven
+Hoffenberg, now serving a prison term after "bilking investors out of more than $450 million
+in one of the largest Ponzi schemes in American history."
+As he amassed his wealth, Epstein made enemies in disputes both large and small. He sued the
+man who in 1990 sold him his multimillion-dollar Palm Beach home over a disputé about less
+than $16,000 in furnishings.
+A former friend claimed Epstein backed out of a promise to reimburse him hundreds of
+thousands of dollars after their failed investment in Texas oil wells: A judge decided Epstein
+owed him nothing.
+» Jeffrey Epstein: Model prisoner who swept, mopped floors, official says
+CA/Aronberg-001010
+
+
+"It's a bad memory, I would rather not have ever met Jeffrey Epstein," said Michael Stroll, the
+retired former president of
+| Electronics and. Sega Corp. "Suffice it to say T have
+nothing good to say about him."
+Among the chäracteristics most attributed to Epstein is a penchant for women.
+He has been linked to Maxwell, a fixture on the high-society party circuits in both New York
+and London. Previous girlfriends are said to include a former Ms. Sweden and a Romanian
+model.
+"He's a lot of fun to be with," Donald Trump told New York magazine in 2002, "It is even said
+that he likes beautiful women as much as I do, and many of them are on the younger side. No.
+doubt about it, Jeffrey enjoys his social life."
+Investigation leads to Epstein
+Although he was not a frequenter of the Palm. Beach sócial scene, he made his presence felt.
+Among his charitable donations, he gave $90,000 to the Palm Beach Police Department and
+$100,000 to Ballet Florida.
+In Palm Beach, he lived in luxury. Three black Mercedes sat in his garage, alongside a
+Harley-Davidson, His jet waited at a hangar at Palm Beach International Airport. At home, a
+private chef and a small staff stood at the ready. From a window in his mansion, he could look
+out on the Intracoastal Waterway and the West Palm. Beach skyline. He seemed to be a man
+who had everything.
+But extraordinary wealth can fuel extraordinary desires,
+» Epstein wants to leave jail for mansion in sex-trafficking case
+In March 2005, a worried mother contacted Palm Beach police. She said another parent had
+overheard a conversation between their children.
+Now the mother was afraid her 14-year-old daughter had been molested by a man on the
+island
+The phone call triggered an extensive investigation, one that would lead detectives to Epstein
+but leave them frustrated.
+CA/Aronberg-001011
+
+
+Palm Beach police and the state attorney's office have declined to discuss the case. But a Palm
+Beach police report detailing the criminal probe offers a window into what detectives faced as
+they sought to close in on Epstein.
+Detectives interviewed the girl, who told them a friend had invited her to a rich man's house to
+perform a massage. She said the friend told her to say she was 18 if asked. At the house, she
+said she was paid $300 after stripping to her panties and massaging the man while he
+masturbated
+Police interview 5 alleged victims
+The investigation began. in full after the girl identified Epstein in a photo as the man who had
+paid her. Police arranged for garbage trucks to set aside Epstein's trash so police could sift
+through it. They set up a video camera to record the comings and goings at his home. They
+monitored an airport hangar for signs of his private jet's artivals and departures.
+They quickly learned that the woman who took the 14-year-old girl to Epstein's house was
+, a Palm Beach Community College student from Loxahatchee. In a sworn
+statement at police headquarters, |
+,, then 18, admitted she had taken at least six girls to
+visit Epstein, all between the ages of 14 and 16. Epl
+paid her for each visit, she said.
+During the drive back to her house, Robson told detectives, "I'm like a Heidi Fleiss."
+Police interviewed five alleged victims and 17 witnesses. Their report shows some of the girls
+said they had been instructed to have sex with another woman in front of Epstein, and one said
+she had direct intercourse with him.
+In October, police searched the Palm Beach mansion. They discovered photos of naked, younglooking females, just as several of the girls had described in interviews. Hidden cameras, were
+found in the garage area and inside a clock on Epstein's desk, alongside a girl's high school
+transcript.
+Two of Epstein's former employees told investigators that young-looking girls showed up to
+perform massages two or three times a day when Epstein: was in towin.
+They said the girls were permitted many indulgences. A chef cooked for them. Workers gave
+them rides and handed out hundreds of dollars at a time.
+CA/Aronberg-001012
+
+
+One employee told detectives he was told to send a dozen roses to one teenage girl after a high
+school drama performance. Others were given rental cars. One, according to police, received a
+$200 Christmas bonus.
+The cops moved to cement their case. But as they tried to tighten the noose, they encountered
+other forces at work.
+In Orlando they interviewed a possible victim who told them nothing inappropriate had
+happened. between her and Epstein. They asked her whether she had spoken to anyone else.
+She said yes, a private investigator had asked her the same questions.
+» Jeffrey Epstein: Acosta, Krischer trade barbs over sweetheart deal
+When they subpoenaed one of Epstein's former employees, he told them the same thing. He
+and a, private eye had met at a restaurant days earlier to go over what the man would tell
+investigators.
+Detectives received complaints that private eyes were posing as police officers. When they told
+Epstein's local attorney, Guy Fronstin, he said the investigators worked for Roy Black, the
+high-powered Miami lawyer whọ has defended the likes of Rush Limbaugh and William
+Kennedy L
+While the private eyes were conductíng a parallel investigation, Dershowitz, the Harvard law
+professor, traveled to West. Palm Beach with information about the girls. From their own
+profiles on the popular Web site MySpace.com, he obtained copies of their discussions about
+their use of alcohol and, marijuana.
+He took his research to a meeting with prosecutors in early 2006, where he sought to cast
+doubt on the teens' reliability.
+The private eyes had dug up enough dirt on the girls to make prosecutors skeptical. Not only
+did some of the girls have issues with drugs or alcohol but also some had criminal records and
+other troubles, Epstein's legal team claimed. And at least one of them; they said, lied when she
+told police she was younger than 18 when she started performing massages for Epstein.
+After the meeting, prosecutors postponed their decision to take the case to a grand jury.
+:
+CA/Aronberg-001013
+
+
+In the following weeks, police received complaints that two of the victims or their families had
+been harassed or threatened. Epstein's legal team maintains that its private investigators did
+nothing illegal or unethical during their research.
+By then, relations between police and prosecutors were fraying. At a key meeting with
+prosecutors and the defense, Detective
+Recarey, the lead investigator, was a no-show,
+according to Epstein's attorney.
+"The embarrassment on the prosecutor's face was evident when the police officer never
+showed up for the meeting," attorney Jack Goldberger said,
+Later in April, Recarey walked into a prosecutor's office at the state attorney's office and
+learned the case was taking an unexpected turn.
+The prosecutor, Lanna Belohlavek, told. Recarey the state attorney's office had offered Epstein
+a plea deal that would not require him to serve jail time or rèceive a felony conviction.
+Recarey told her he disapproved of the plea offer.
+The deal never came to pass, however.
+Füture unclear after charge
+On May 1, the department asked prosecutors to approve warrants to arrest Epstein on four
+counts of unlawful sexual activity with a minor and to charge his personal assistant,
+| now 27, for her alleged role in arranging the visits. Police officials also wanted to
+charge
+the self-described Heidi Fleiss, with lewd and lascivious acts.
+By then, the department was frustrated with the way the state attorney's office had handled the
+case. On the same day the warrants were requested, Palm Beach Police Chief Michael Reiter
+wrote a letter, to State Attorney Barry Krischer suggesting he disqualify himself from the case if
+he would not act.
+Two weeks later, Recarey was told that prosecutors had decided once again to take the case to
+the grand jury.
+CA/Aronberg-001014
+
+
+It is not known how many of the girls testified before the grand jury. But Epstein's defense
+team said one girl who was subpoeriaed - the one who said she had sexual intercourse with
+Epstein - never showed up.
+The grand jury's indictment was handed down in July. It was not the one the police
+department had wanted.
+Instead of being slapped with a charge of unlawful sexual activity with a minor, Epstein was
+charged with one count of felony solicitation of prostitution, which carries a maximum penalty
+of five years in prison. He was booked into the Palm Beach County Jail early July 23 and
+released hours later:
+Epstein's legal team "doesn't dispute that he had girls over for massages," Goldberger said. But
+he said their claims that they had sexual encounters with him lack credibility.
+"They are incapable of being believed," he said. "They had criminal records. They had
+accusations of theft made against them by their employers. There was evidence of drug use by
+some of them."
+What remains for Epstein is yet to be seen,
+The Palm Beach Police Department has asked the FBI to investigate the case. It also has
+returned the $90,000 Epstein donated in 2004.
+In New York, candidates for governor and state attorney general have vowed to return a total
+of at least $60,000 in campaign contributions from Epstein, Meanwhile, Epstein's powerful
+friends have remained silent as tabloids and Internet blogs feast on the public details of the
+police investigation,
+Goldberger maintains Epstein's innocence but says the legal team has not ruled out a future
+plea deal. He insists Epstein will emerge in the end with his reputation untarnished.
+"He will recover from this," he said.
+Staff writer Larry
+Melanie Mena contributed to this story.
+and staff researchers Bridget Bulger, Angelica Cortez, Amy Hanaway and
+amarra@pbpost.com
+CA/Aronberg-001015
+
+
+@AMarraPBPost
+TRIF MOST
+INTELLIGENT GRID
+JAMARCAL
+NOT A CERTIFIED S
+CA/Aronberg-001016
+FILED: PALM BEACH COUNTY, FL, M
+
+
+273 / 278 - Tuesday, November 16, 2004
+Section: A SECTION
+Source: By PAUL OWERS Palm Beach Post Staff Writer
+Illustration: PHOTO (C & 2 B&W) & MAP (B&W)
+Dateline: WEST PALM BEACH
+TRUMP SNAGS GOSMAN ESTATE FOR $41 MILLION
+R
+When it came time to bid Monday for the palatial Palm Beach digs of Abe Gosman, The
+Donald was not about to be trumped.
+"Nobody was going to outbid me," the brash developer-turned-TV-personality said from his
+New York office,
+Trump bested two other bidders with a $41.35 million offer for the 43,000-squaré-foot,
+seven-bedroom estate on 6 oceanfront acres along the storied "Raider's Row."
+But Trump, 58, proud possessor of Mar-a-Lago, has no plans to live in the Gosman home at
+513 N. County Road, He wants to - what else? - sell it and make more money.
+The star of the mega-hit The Apprentice said he intends to redevelop the site into a "super
+Juxury house" that would be the "finest anywhere in the United States:" He might build
+another house before flipping the entire package.
+"T've known about this house for quite some time," Trump said. "It's probably the best piece
+of land in Florida - and probably the country - for luxury real estate."
+Although Trump said he could subdivide the property into nine lots, Palm Beach Mayor
+Lesly
+said zoning regulations allow for only two houses - and maybe a third.
+said she's not worried about Trump's plans.
+"He's been a very good property owner in the town of Palm Beach," she said. "He does his
+projects very well. He's a perfectionist."
+Monday's auction took place at U.S. Bankruptcy Court in West Palm Beach as part of
+Gosman's Chapter 7 bankruptcy case. Proceeds from the sale: will go into escrow for eventual
+distribution to creditors.
+The auction began at exactly noon after Judge Steven
+dismissed an objection from
+an attorney representing money manager Jeffrey Epstein. The lawyer argued unsuccessfully
+that Trump was not a qualified bidder because his contract stipulated that he would not close
+on the sale unless title insurance was in place beforehand.
+With Trump listening via conference call, Epstein began the bidding at $37.25 million.-
+$250,000 higher than Trump's initial offer.
+Mark Pulte, son of the founder of home-building giant Pulte Homes, passed when his turn
+came, letting lawyers for Trump: and Esptein bid against each other until the price hit $38.85
+million.
+Pulte then bid $39.1 million, briefly raising the ire of Trump, who believed that Pulte had
+given up his right to bid by passing the first time.
+CA/Aronberg-001017
+
+
+But
+allowed the offer to stand, and Pulte and Trump went back and forth until
+Pulte dropped out at $41.1 million. Epstein, a part-time Palm Beach resident, bowed out at
+$38.6 million.
+closed the bidding 10 minutes after it started, leaving Trump with the right to buy
+the 29,000-square-foot home (a typical Palm Beach County single-family house is about
+2,200 square feet). The property also has a tennis house, a pool house and 1930s-era service
+quarters.
+The closing could take place within a week but probably won't happen until next month.
+Trustee Joe Luzinski and creditors said they were pleased with the outcome.
+"We knew we were dealing with some substantial people ..» who were going to bid it up a
+bit," Luzinski said.
+"The system worked," said Charles Tatelbaum, a lawyer for creditor JPMorgan Chase Bank.
+"In bankruptcy court, the idea is to get the most for creditors, and that's what happened."
+The auction proved to be a bonanza for creditors, Luzinski said, noting that the highest offer
+former listing agent Sotheby's International Realty received was $32 million. Sotheby's won't
+receive a commission, he said.
+Pulte, 42, of Boca Raton, said he figured Trump wouldn't back down Monday.
+"I got the feeling he was willing to go a lot higher, and I didn't want to chase it," Pulte said.
+Pulte said Goşman asked him before the auction whether he would be willing to let him stay
+in the mansion after the closing until he decides. where he wants to move. Trump and
+Luzinski said they have had no such discussions with Gosman.
+Gosman, 75, had the house. built after paying $12.I million for the land in 1986.
+The former health-care magnate declined interview requests before and after the auction
+Monday. He was at the courthouse but left before the auction took place.
+The $41,35 million price tag eclipses the $30.35 million sale of Lowell "Bud" Paxson's Palm
+Beach home and guest house but falls short of the $45 million that Virginia home builder
+Dwight Schar paid for Ron Perelman's 26,000-square-foot estate, Casa, Apava, a designated
+landmark.
+Schar also paid $18.6 million for a lakefront lot across the street from the main house; for a
+total of $63.6 million. Insiders say Schar spent a total of $70 million for his new property,
+making it the priciest residential sale in U.S. history.
+Gosman once had a fortúne that Forbes magazine estimated at $480 million. He voluntarily
+filed for Chapter 11 bankruptcy protection in 2001, listing assets of $250 million and
+liabilities of $233.6 million.
+When a judge riled that Gosman had to give up all of his exempt assets to creditors if he
+wanted to reorganize under Chapter 11, Gosman converted the case to Chapter 7 liquidation.
+Last year, U.S. Bankruptcy Judge Larry Lessen ruled that Abe and Lin Gosman's marriage is
+invalid because Florida law does not recognize a Dominican Republic divorce that Lin
+Gosman tried to obtain from another man, Michael Castre.
+The judge's decision was a huge victory for creditors because it prevents: Abe Gosman from
+protecting assets by claiming joint ownership with his wife. Gosman's assets, which include
+an extensive collection of artwork, could total as much as $70 million and will be sold later,
+Without Lessen's ruling, Luzinski would have had a much harder time selling Gosman's
+estate, said David Cimo, special counsel for the trustee.
+"We would have been thwarted... or at least substantially impaired," Cimo said.
+CA/Aronberg-001018
+
+
+The trustee alleged during a weeklong trial in May that Gosman fraudulently gave his wife
+an ownership interest in his home and other belongings only to avoid losing them in
+bankruptcy. Gosman has denied any wrongdoing, saying he made the property transfers in
+1999, well before he filed for bankruptcy.
+Lessen is expected to rule in the next two months whether Gosman made improper transfers,
+a decision that will affect how much money will be available to creditors.
+Cimo acknowledged that Monday wasn't the best of days for the Gosmans but said they were
+willing to move forward, in part because the upkeep of the estate now exceeds their means.
+"This is not a happy occasion for them, but at least we're moving to the next level," Cimo
+said. "That's not a house you want to live in unless you're making large amounts of money
+like Donald Trump."
+paul_owers@pbpost.com
+NOT A CERTIFIED COP
+CA/Aronberg-001019
+
+
+Indicument: Billionaite Solicited 3 Times. - News - The Palm Beach Post - West Palm Beach, FL
+Indictment: Billionaire Solicited 3 Times
+Posted Jul 1, 2008 at 12:01 AM
+Updated. Oct 2, 2019 at 2:30 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 25,
+2006)
+Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31
+of last year, according to an indictment charging him with felony solicitation of
+prostitution.
+Epstein, 53, was booked at the Palm Beach County jail at 1:45 a.m. Sunday. He
+was released on $3,000 bond.
+Epstein's case is unusual in that suspected prostitution johns are usually charged
+with a misdemeanor, and even a felony charge is typically made in a criminal
+information - an alternative to an indictment charging a person with the
+commission of a crime.
+His attorney, Jack Goldberger, declined to discuss the charge.
+State attorney's office spokesman Mike Edmondson also had little to say..
+"Generally speaking, there is a case that has a number of different aspects to it,"
+Edmondson said of a prostitution-related charge being submitted to a grand jury.
+"We first became aware of the case months ago by Palm Beach police."
+Prosecutors and police worked together to bring the case to the grand jury, he
+said.
+https://www.paimbeachpost.com/news/20080701/indictment-billionaire-solicited-3-times
+CA/Aronberg-001020
+1/2
+
+
+Indictment: Billionaire Solicited 3 Times - Néws - The Palm Beach Post- West Palm Beach, FL.
+Palm Beach police confirmed that and said the department will release a report
+today regarding its investigation.
+Epstein has owned a five-bedroom, 7 1/2-bath, 7,234-square-foot home with a
+pool and a boat dock on the Intracoastal Waterway since 1990, according to
+property records. A man answering the door there Monday said that Epstein
+wasn't home. A Cadillac Escalade registered to him was parked in the driveway,
+which is flanked by two massive gargoyles.
+Epstein sued Property Appraiser Gary Nikolits in 2001, contending thạt the
+assessment of his home exceeded its fair market value. He dismissed his lawsuit
+in December 2002.
+A profile of Epstein in Vanity Fair magazine said he owns what are believed to
+be the largest private homes in Manhattan - 51,000 square feet - and in.New
+Mexico - a 7,500-acre ranch, Those are in addition to his 70-acre island in the
+U.S. Virgin Islands and fleet of aircraft.
+Epstein's friends and admirers, according to the magazine; include prominent
+, academics and scientists and famed Harvard law professor Alan
+business
+Dershowitz,
+Járry_keller@pbpost.com
+https://www.palmbeachpost.com/news/20080701/indictmenl-billionaire-solicited-3-times
+CA/Aronberg-001021
+2/2
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+After long probe, billionaire faces solicitation
+charge
+Posted Jül 27, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:11 PM
+(EDITOR'S NOTE: This story originally published in The Palm Beach Post on July 26,
+Palm Beach billionaire Jeffrey Epstein paid to have underage gils and young
+women brought to his home, where he received massages and sometimes sex,
+according to an investigation by the Palim Beach Police Department.
+Palm Beach police spent months sifting through Epstein's trash and watching his
+waterfront home and Palm Beach International: Airport to keep tabs-on his
+private jet. An indictment charging Epstein, 53, was unsealed Monday, charging
+him with one count of felony solicitation of prostitution.
+Palm Beach police thought there was probable cause to charge Epstein with
+unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry with State Attorney Barry Krischer's
+handling of the case that he wrote a memo suggesting the county's top
+prosecutor disqualify himself.
+"I must urge you to examine the unusual course that your office's handling of this
+matter has taken and consider if good and sufficient reason exists to require your
+disqualification from the prosecution of these cases," Reiter wrote in a May 1
+memo to Krischer.
+While not commenting specifically on the Epstein case, Mike Edmondson,
+spokesman for the state attorney, said his office presents cases other than
+murders to a grand jury when there are questions about witnesses credibility and
+their ability to testify.
+https://www.palmbeachpost.com/news/20050727/after-long-probe-billionaire-faces-solicitation-charge
+CA/Aronberg-001022
+1/5
+
+
+After-long prode, bilionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+By the nature of their jobs, police officers look at evidence from a Tone-sided
+perspective," Edmondson said. "A prosecutor has to look at it in a much broader
+fashion," weighing the veracity of witnesses and how they may fare under
+defense attorneys' questioning, he said.
+Epstein's attorney, Jack Goldberger, said his client committed no crimes.
+"The reports and statements in question refer to false accusations that were not
+charged because the Palm Beach County state attorney questioned the credibility
+of the witnesses," Goldberger said. A county grand jury "found the allegations
+wholly unsubstantiated and not credible," and that's why his client: was not
+charged with sexual activity with minors, he said.
+Goldberger said Epstein passed a lie detector test administered by a teputable
+polygraph examiner in which he said he did not know the girls were minors.
+Also, a search warrant served on Epstein's home found no evidence to
+corroborate the girls' allegations, Goldberger said.
+According to police documents:
+- A Palm Beach Community College student said she gave Epstein a massage in
+the nude, then brought him six girls, ages 14 to 16, for massage and sex-tinged
+sessions at his home.
+- A 27-year-old woman who worked as Epstein's personal assistant also
+facilitated the liaisons, phoning the PBCC student to arrange for girls when
+Epstein was coming to town. And she escorted the girls upstairs when they
+arrived, putting fresh sheets on a massage table and placing massage oils nearby.
+- Police took sworn statements from five alleged victims and 17 witnesses. They
+contend that on three occasions, Epstein had sex with the girls.
+A money manager for the ultra-rich, Epstein was named one of New York's most
+eligible bachelors in 2003 by The New York Post. He reportedly hobnobs with
+the likes of former President Clinton, former Harvard University President
+Summers and Donald Trump, and has lavish homes in Manhattan,
+New Mexico and the Virgin Islands.
+https://www.palmbeachpost.com/news/20060727/aftor-long-probe-billionaire-faces-solicitation-charge
+CA/Aronberg-001023
+2i5
+
+
+After long probe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+He has contributed tens of thousands of dollars to Democratic Party candidates
+and organizations, including Sen. John Kerry's presidential bid, and the Senate
+campaigns of Joe
+, Hillary Clinton,
+Dodd. and Charles
+Schumer.
+COPY
+Goldberger is one of five attorneys Epstein has retained since he became the
+subject of an investigation, Edmondson said. Among the others: Alan
+Dershowitz, the well-known Harvard law professor and author, who is a friend
+of Epstein. Dershowitz could not be reached for comment.
+Police said the woman who enlisted young girls for Epstein was
+20, ofl
+Palm Beạch. Robson has worked at an Olive Garden restaurant in
+Wellington and said she was a journalism major at Palm Beach Community
+College when she was questioned by police last October. She has an unlisted
+phone number and could not be reached for comment.
+Robson said she met Epstein when, at age 17, a friend asked her if she would like
+to make money giving him a massage. She said she was driven to his fivebedroom; 7 1/2-bath home on the Intracoastal. Waterway; then escorted upstairs
+to a bedroom with a massage table and oils. Epstein and
+wère both naked
+during the massage, she said, but when he grabbed her buttocks, she said she
+didn't want to be touched.
+hittps://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+CA/Aronberg-001024
+3/5
+
+
+After long prude, bilionaire-faces solicitation charge : News - The Palm Beuch Post - West Palm Beach, FL
+Epstein said he'd pay her to bring him more girls - the younger the better,
+told police. When she tried once to bring a 23-year-old woman to him,
+Epstein said she was too old,
+said.
+who has not been charged in the case, said she eventually brought six
+girls to Epstein who were paid $200 each time,
+said. "I'm like a Heidi
+Fleiss," police quoted her as saying. The girls knew what to expect when they
+were taken to Epstein's home,
+said. Give a massage - maybe naked - and
+allow some touching-
+One 14-year-old girl.]
+took to meet Epstein led police to start the
+investigation of him in March 2005. A relative of the girl called to say she
+thought the child had recently engaged in sex with a Palm Beach man. The girl
+then got into a fight with a classmate who accused her of being a prostitute, and
+she couldn't explain why she had $300 in her purse.
+The girl gave police this account of her meeting with Epstein:
+She accompanied.
+and a second girl to Epstein's house on a Sunday in
+February 2005. Once there, a woman she thought was Epstein's assistant told the
+girl to follow her upstairs to a room featuring a mural of a naked woman, several
+photographs of naked women on a shelf, a hot pink and
+sofa and a massage
+table.
+She stripped to her bra and parties and gave him a massage.
+Epstein gave the 14-year-old $300 and she and the other girls left, she said. She
+said Robson told her that Epstein paid her $200 that day.
+Other girls told similar stories. In most accounts, Epstein's personal assistant at
+the time, Sarah
+now 27, escorted the girls to Epstein's bedroom.
+Kellen, whose most recent known address is in North Carolina, has not been
+charged in the case.
+Palm Beach police often conducted surveillance of Epstein's home, and at Palm
+Beach International Airport to see if his private jet was there, so they would
+know when he was in town. Police also arranged repeatedly to receive his trash
+https:/www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+CA/Aronberg-001025
+4/5
+
+
+After long plobe, billionaire faces solicitation charge - News - The Palm Beach Post - West Palm Beach, FL
+from Palm Beach sanitation workers, collecting papers with names and phone
+numbers, sex toys and female hygiene products.
+One note stated that a female could not come over at 7 p.m. because of soccer.
+Another said a girl had to work Sunday - "Monday after school?" And still
+another note contained the work hours of a girl, saying she leaves school at 11:30
+a,m. and would come over the next day at 10:30 a.m.
+Only three months before the police department probe began, Epstein donated
+$90,000 to the department for the purchase of a firearms simulator, said Jane
+Struder, town finance director, The purchase was never made. The money was
+returned to Epstein on Monday, she said.
+NOT A CERTIFIED CO
+https://www.palmbeachpost.com/news/20060727/after-long-probe-billionaire-faces-solicitation-charge
+CA/Aronberg-001026
+5/5
+
+
+Police
+Lawyer tried to discredit teenage girls - News : Palm Beach Daily News - Palm Beach, FL
+Palm Beach Daily News
+Police say lawyer tried to discredit teenage
+girls
+Posted Jul 29, 2006.at 12:01 AM
+Updated Oct 3, 2019 at 2:00 PM
+(EDITOR'S NOTE: This story originally was published in The Palmi Beach Post on Jubl
+29, 2006)
+Famed Hal
+law professor Alan Dershowitz met with the Palm. Beach County
+State Attorney's Office and provided damaging information about teenage girls
+who say they gave his client, Palm Beach billionaire Jeffrey Epstein, sexually
+charged, massages, according to police reports.
+The reports also state that another Epstein attorney agreed to a plea bargain that
+would have allowed Epstein to have no criminal record. His current attorney
+denies this happened.
+And the documents also reveal that the father of at least one girl complained that
+private investigators aggressively followed his car, photographed his home and
+chased off visitors.
+Police also talked to somebody who said she was offered money if she refused to
+cooperate with the Palm Beach Police Department probe of Epstein.
+The state attorney's office said it presented the Epstein case to a county grand
+jury this month rather than directly charging Epstein because of concerns about
+the girls credibility. The grand jury indicted Epstein; 53, on a single count of
+felony solicitation of prostitution, which carries a maximum penalty of five years
+in prison.
+Police believed there was probable cause to charge Epstein with the more serious
+crimes of unlawful sex acts with a minor and lewd and lascivious molestation.
+Police Chief Michael Reiter was so angry that he wrote State Attorney Barry
+Krischer a memo in May suggesting he disqualify himself, from the case.
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+CA/Aronberg-001027
+1/4.
+
+
+Police say lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL.
+The case originally was going to be presented to the grand jury in February, but
+was postponed after Dershowitz produced information gleaned from the Web
+site myspace.com showing some of the alleged victims commenting on alcohol
+and marijuana use, according to the police report prepared by Detective
+Recarey.
+a 20-year-old
+Palm Beach woman who told police she
+recruited girls for Epstein, also is profiled on myspace.com. Her page includes
+photos of her and her friends, including one using the name "Pimpin' Made EZ"
+, who was not charged in the case, is a potential prosecution witness.
+According to Recarey, prosecutor Lanna Belohlavek offered Epstein attorneys
+Dershowitz and Guy Fronstin a plea deal in April. Fronstin, after speaking with.
+Epstein, accepted the deal, in which Epstein would plead guilty to one count of
+aggravated assault with intent to commit a felony, be placed on five years'
+probation and have no criminal record. The deal also called for Epstein to submit
+to a psychiatric and sexual evaluation and have no unsupervised visits with
+minors, according to Recarey's report. The plea bargain was made in connection
+with only one of the five alleged victims, the report states.
+Fronstin - who declined to comment on the case - was subsequently fired and
+veteran defense attorney Jack Goldberger was hired. He denies there was any
+agreement by any of Epstein's attorneys to a plea deal.
+"We absolutely did not agree to a plea in this case," he said. Neither Belohlävek
+nor a state attorney's spokesmän could be reached for comment.
+The parent or parents of alleged victims who complained of being harassed by
+private investigators provided license tag numbers of two of the men. Police
+found the vehicles were registered to a private eye in West Palm. Beach and
+another in Jupiter, according to Recareys report.
+"T have no knowledge of it," defense attorney Goldberger said.
+The report also says a woman connected to the Epstein case was contacted by
+somebody who was still in touch with Epstein. That person told her she would
+be compensated if she didn't cooperate with police, Recarey's report says. Those
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+CA/Aronberg-001028
+214
+
+
+Police suy lawyer tried to discredit teenage girls - News - Palm Beach Daily News - Palm Beach, FL
+who did talk "will be dealt with," the woman said she was told. Phone records
+show the woman talked with the person who allegedly intimidated her around
+the time she said, Recarey reported.
+Phone records also show that the person said to have made the threat then
+placed a call to Epstein's personal assistant, who in turn called a New York
+corporation affiliated with Epstein, the report states.
+The issue in the Epstein case is not whether females came to his waterfront!
+home, but whether he knew their ages.
+"He's never denied girls came to the house," Goldberger said. But when Epl
+was given a polygraph test, "he passed on knowledge of age," the attorney said.
+After the indictment against Epstein was unsealed this week, Police Chief Reiter
+referred the matter to the FBI. "We've received the referral, and we're reviewing
+it," said FBI spokeswoman Judy Orihuela in Miami.
+The chief himself has come under attack from Epl
+lawyers and friends in
+New York, where he has a home. The New York Post quoted Epstein's
+prominent New York lawyer, Gerald Lefcourt, as saying his client was indicted
+only "because of the craziness of the police chief."
+Reiter has declined to comment on the case.
+Prosecutors have not presented a sex-related case like Epstein's to a grand jury
+before, said Mike Edmondson, spokesman for the state attorney's office. "That's
+what you do with a case that falls into a gray area," he said.
+The state attorney's office did not recommend a particular criminal charge on
+which to indict Epstein, Edmondson said. The grand jury was presented with a
+list of charges from highest to lowest, then deliberated with the prosecutor out of
+the room, he said.
+"People are surprised at the grand jury proceeding," West Palm Beach defense
+attorney Richard Tendler said. "It's a way for the prosecutor's office to not take
+the full responsibility for not filing the (charge), and not doing what the Palm
+Beach Police Department wanted. I think something fell apart with those
+underage witnesses."
+https:/www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+CA/Aronberg-001029
+3/4
+
+
+Police Say lawyer tried to discredit teenage girls - News - Palm.Beach Daily News - Palm Beach, FL
+Defense attorney Robert Gershman was a prosecutor for six years. "Those girls
+must have been incredible or untrustworthy, I don't know," he said
+Other attorneys said Epstein's case raises the issue of whether wealthy, connected
+defendants like Epstein - whose friends include former President Clinton and
+Donald Trump - are treated differently from others. Once he knew he was the
+subject of a criminal probe, Epstein hired a phalanx of powerful attorneys such as
+Dershowitz and Lefcourt, who is a past president of the National Association of
+Criminal Defense Lawyers.
+Miami lawyer Roy Black - who became nationally known when he successfully
+defended William
+on a rape charge in Palm Beach - also was
+involved at one point.
+Said defense attorney
+get the perception that with power,
+average Joe."
+Suskauer: "L
+think it's unfortunate the public may
+be treated differently than
+the
+CERTIFIE
+NOT A
+https://www.palmbeachdailynews.com/article/20060729/NEWS/190917573
+CA/Aronberg-001030
+FILED: PALM BEACH COUNTY, FL, •
+4/4
+
+
+Expert: Ignorance of age isn't
+defense in sex cases
+Posted Aug 5, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 1:38 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on Aug. 5, 2006).
+know that girls who police say gave him sexual •
+his Intracoastal home were under the legal age, that alone
+wouldn't have exempted him from criminal chärges of
+sexual activity with minors.
+"Ignorance is not a valid defense," said Bob Dekle, a legal
+skills professor who was a Lake City prosecutor for nearly
+30 years, half of that time specializing in sex crimes against
+children.
+"There is no knowledge element as far as the age is
+concerned," Dekle said.
+After an 11-month investigation, Palm Beach police said
+there was probable cause to charge Epstein, 53, with
+unlawful sex acts with a minor and lewd and lascivious
+molestation. They contend that Epstein - friend of the rich
+/ and famous and financial patron of Democratic Party
+organizations and candidates - committed those acts with
+five underage girls.
+In the past week, New York Attorney General ánd
+gubernatorial candidate Eliot Spitzer, has returned about
+$50,000 in campaign contributions he received from
+Epstein, and Mark
+a candidate to replace Spitzer in
+. -
+CA/Aronberg-001031
+
+
+his current job, has returned $10,000 to him because of the
+Palm Beach scandal, the New York Daily News has
+reported.
+Rather than file charges, the state attorney's office
+presented the case to a county grand, jury. The panel
+indicted Epstein last week on a single, less serious charge of
+felony solicitation of prostitution.
+The case raised eyebrows because the state attorney's office
+rarely, if ever, kicks such charges to a grand jury. And it
+increases the difficulty of prosecuting child sex abuse cases,
+especially when the defendant is enormously wealthy and
+can hire high-priced, top-tier lawyers.
+At least one of Epstein's alleged victims told police he knew
+she was underage when the two of them got naked for
+massages and sexual activity. She was 16 years old at the
+time and said Epstein asked her questions about her high
+school, according to police reports.
+A girl who said she met Epstein when she was 15 said he
+told her if she told anybody what happened at his house,
+bad things could happen, the police reports state.
+Epstein's youngest alleged victim was 14 when she says she
+gave him a massage that included some sexual activity. She
+is now 16. The girl's father says he doesn't know whether
+she told Epstein her age.
+"My daughter has kept a lot of what happened from me
+beçause of sheer embarrassment," he said. "But she very
+much looked 14. Any prudent, man would have had second
+thoughts about that."
+Defense attorney Jack Goldberger maintains that not only
+did Epstein pass a polygraph test showing he did not know
+the girls were minors, but their stories weren't credible.
+The state attorney's office also implied that their credibility
+was an issue when it decided not to charge Epstein directly,
+but instead give the case to the grand jury.
+CA/Aronberg-001032
+
+
+"A prosecutor has to look at it in a much broader fashion," a
+state attorney's spokesman said last week.
+INTELLIGENT GRID
+Epstein hired Harvard law Professor Alan Dershowitz
+when he became aware he was under investigation, and
+Dershowitz gave prosecutors information that some of the
+alleged victims had spoke of using alcohol and marijuana on
+a popular Web site, according to a Palm Beach police
+report.
+Prosecutors typically consider two things in deciding
+whether to charge somebody with sex-related offenses
+against minors - whether there is sufficient evidence and
+whether there is a public interest in doing so, Dekle said.
+If two téens are in a sexual relationship and the boy turns
+18 before the girl, he could be charged with a sex crime if
+the sex continues. There would be no public interest in
+pursuing that, Dekle said.
+But where there is a large gap in ages - and especially in
+cases of teachers with students - there is a public interest in
+prosecuting, he said. Likewise if the accused has a track
+record of sex with minors.
+CA/Aronberg-00.1033
+
+
+Still there is a "universal constant" in prosecuting these
+cases, Dekle said. Men who exploit underage children for
+sex often carefully choose their victims in ways that will'
+minimize the risk to them, he said
+Victims usually are from a lower social status, and they may
+suffer from psychological problems, Dekle said.
+"Lots of child sexual abuse victims have been victimized by
+multiple people over a period of time. Then the act of abuse
+produces behavior in the victims that further damages their
+credibility." Examples include promiscuous behavior and
+drug abuse.
+Os
+Some of the alleged victims in the Epstein case returned to
+his home multiple times for the massage sessions and the
+$200 to $300 he typically paid them per visit. "That would
+be a definite problem for the prosecutor," said Betty Resch,
+who prosecuted crimes against children in Palm Beach
+County for five years and now is in private practice in Lake
+Worth.
+"The victim becomes less sympathetic" to a jury, Resch said:
+"But she's a victim nevertheless. She's a kid."
+Most men charged with sex crimes against minors look
+normal, Dekle said. A jury expecting to see a monster.
+seldom will. And the victims' ages work against them and in
+favor of the defendant in a trial, Dekle said.
+) If a child and an adult tell different stories and both swear
+they're telling the truth, adult jurors are more likely to
+believe the adult, Dekle said.
+"You have all these things working against you in a child
+sex abuse case. Prosecutors normally try to be very careful
+in filing those cases because they know what they re getting
+into. There is no such thing as an iron-clad child sexual
+abuse case."
+CA/Aronberg-001034
+
+
+Epstein camp calls female accusers
+liars
+Posted Aug 8, 2006 at 12:01 AM
+Updated Oct 3, 2019 at 3:35 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post.ori Aug. 8, 2006)
+Epstein went on the offensive Monday, contending that
+teenage girls who have accused Epstein of sexual
+shenanigans at his waterfront home are liars and saying
+that the Palm Beach Police Department is "childish."
+"There never was any sex between Jeffrey Epl
+and any
+underage women," his lead attorney, Jack Goldberger, said
+from Idaho where he was vacationing with his family.
+Epstein did have young women come to his house to give
+him massages, Goldberger said. "Mr. Epstein absolutely
+insisted anybody who came to his house be over the age of
+18. How he verified that, I don't.know. The question is, did
+anything illegal occur. The law was not violated here."
+He had no explanation as to why Epstein would pay girls or
+said was the case - 3200 to 5300 or their visits. "The
+credibility of these witnesses has been seriously
+questioned," Goldberger said
+Epstein, 53, was indicted by a county grand jury last month
+on a charge of felony solicitation of prostitution, After an
+11-month investigation that included sifting through
+Epstein's trash and surveilling his home, Palm Beach police
+concluded there was enough evidence to charge him with
+sexual activity with minors. When the grand jury indicted
+:
+CA/Aronberg-001035
+
+
+Epstein on the less serious charge, Police Chief Michael
+Reiter referred the case to the FBI to determine whether
+there were federal law violations.
+After a spate of stories about the case last week, New York
+publicist Dan Klores - whose client list has included Paris
+Hilton and Jennifer:
+- said on Saturday that Epstein's
+camp was ready "to get their story out."
+They did that Monday via Goldberger and a Los Angeles
+publicist for Miami criminal defense attorney Roy Black,
+who also has represented Epstein in the case.
+"We just think there has been a distorted view of this case
+in the media presented by the Palm Beach police,"
+Goldberger
+Reiter has consistently declined to comment on the case
+and did
+not respond to a request for comment Monday:
+NOT A CERTIF
+The implication that State Attorney Barry Krischer was
+easy on Epstein by presenting the case to a grand jury
+rather than filing charges directly against him is wrong;
+Goldberger said.
+CA/Aronberg-001036
+
+
+The Palm Beach Police Department was "happy and
+ecstatic" that the panel was going to review the evidence. *I
+think what happened is they weren't happy with the result.
+They decided to use the press to embarrass Mr. Epstein."
+But records show that Reiter wrote Krischer on May 1 -
+well before the case went to the grand jury - suggesting that
+Krischer "consider if good and sufficient reason exists to
+require your disqualification from the prosecution of these
+Rather than flat-out decline to charge Epstein, Krischer
+Goldberger said.
+A state attorney's spokesman would say only that the office
+refers cases to the grand jury when there are issues with the
+viability of the evidence or witnesses credibility.
+Both the state attorney and the grand jury concluded there
+was not sufficient evidence that Epstein had sex with
+minors, according to Goldberger. "It was just a childish
+performance by the Palm Beach Police Department,"
+Goldberger said.
+The defense attorney said one of the alleged victims-who
+claimed she was a minor was in fact over the age of 18.
+Another alleged victim who was subpoenaed to testify to
+the grand jury failed to do so. Epstein's accusers, he added,
+have histories of drug abuse and thefts. "These women are
+liars, We've established that."
+But why would they all invent their stories about meeting
+Epstein for sexual massages?
+"I don't have an answer as to what was the motivation for
+these women to come forward and make these allegations,"
+Goldberger said.
+CA/Aronberg-001037
+
+
+Newspapers
+iy sancestry
+The Palm Beach Post (West Palm Beach, Florida) • 14 Aug 2005, Mon • Page 7.
+Downipaded on Nov. 11. 2018
+Palm Beach chief focus
+of fire in Epstein case
+COPY
+Reiter focus of fire in Epstein case
+Clipped By:
+reiter_m
+Sat, Apr 22, 2017
+Copyright @ 2019 Newspapers com. All Fights Reserved.
+Newspapers"
+CA/Aronberg-001038
+
+
+Delays in Epstein case unusual,
+lawyers say
+Posted Mar 13, 2007 at 12:01 AM
+Updated Oct 3, 2019 at 3:48 PM
+(EDITOR'S NOTE: This story originally published in The Palm
+Beach Post March 13, 2007)
+Palin Beacher's solicitation case:
+Nearly eight months after Palm Beach tycoon Jeffrey
+Epstein was charged with felony solicitation of prostitution,
+there has been no discernible progress in his case. No
+witnesses deposed. No trial date set. Nothing, save for
+routine court hearings reset without explanation.
+"Usually that would be unusual," said criminal defense
+attorney Glenn
+chell, who has no involvement in the
+case.
+"As a general rule, it would be unusual for nothing to have
+happened," agreed Michael Dutko, a criminal defense
+attorney in Fort Lauderdale. He represents
+20, of RJ
+Palm Beach, potentially a key witness in the
+case.
+A routine hearing for Epstein was pulled from the court
+docket last week and reset for May 16. The delays and
+inaction could be due to a potential federal probe of Epstein
+or because a plea deal is in the works, attorneys say.
+Unusual is the word that best describes everything about
+the case against Epstein, 54, an enigmatic money manager
+in New York. City who counts Bill Clinton and Donald
+Trump among his friends.
+CA/Aronberg-001039
+
+
+"Highly unusual" is how Palm Beach Police Chief Michael
+Reiter described State Attorney Barry Krischer's handling
+of the case in a bluntly critical letter to Krischer last year
+before Epstein was indicted.
+Reiter referred the matter to the FBI to determine whether
+any federal laws had been violated. Epstein's allies
+countered by attacking the chief personally and
+professionally.
+Reiter's department investigated Epstein for 11 months:
+Police sifted repeatedly through his trash and conducted
+surveillance on his five-bedroom, 7 1/2-bath, 7;234-squáre-.
+foot home on the Intracoastal Waterway.
+Police said Epstein paid women and girls as young as 14 to
+give him erotic massages at his home. Police thought there
+was probable cause to charge him with unlawful sex acts
+with a minor and lewd and lascivious molestation.
+Epstein responded by hiring a phalanx of lawyers. One of
+them, Harvard law professor and author Alan Dershowitz,
+provided the state attorney's office with information about
+alcohol and marijuana use by some of the girls who said
+they were with Epstein.
+Prosecutors then referred the case to the grand jury rather
+than file charges directly against Epstein:
+Epstein's attorneys deny he had sex with underage girls;
+) The lawyers say the girls' stories are not credible. But if the
+court file is any indicator, they've made no effort to depose
+the girls.
+Neither prosecutors nor defense attorneys have sought to
+question
+, said Dutko, her attorney. She recruited
+teenage girls to visit Epstein for massages and sexual
+activity, Palm Beach police said, and presumably would be a
+key witness.
+CA/Aronberg-001040
+
+
+Epstein's attorney Jack Goldberger did not return phone
+messages.
+A source close to the case suggested it is languishing
+pending a decision by the FBI on whether to refer it. to
+federal prosecutors.
+"We still have a pending case," FBI spokeswoman Judy
+Orihuela said Monday.
+State Attorney Krischer did not return a call for comment.
+His spokesman, Mike Edmondson, declined to say whether
+added, "if another agency is looking at something, wel
+wouldn't want to step on their toes."
+Attorneys say inertia in a criminal case often points to a
+pending plea deal.
+"It would not surprise me if something has happened that's
+not reflected in the court file," said Dutko, such as an
+agreement that will be formalized later.
+Defense attorney Mare Shiner said defense attorneys
+sometimes put off overtly conducting discovery -- deposing
+witnesses, requesting documents and the like -- because
+doing so creates more work for harried prosecutors who
+may become angry and not offer a plea deal.
+"Sometimes defense lawyers, knowing that, will try and do
+discovery without taking depositions," said Shiner, a former
+prosecutor for 13 years.
+Instead, they may conduct a below-the-radar probe such as
+having a private investigator check out leads, he said.
+Shiner and others say a plea deal for Epstein probably
+would result in pretrial intervention, in which a defendant
+may be ordered to undergo a psychological evaluation,
+counseling or other conditions in return for dropping the
+charge.
+CA/Aronberg-00.1041
+
+
+Edmondson, spokesman for State Attorney Krischer, said
+there is no plea offer and no request for the prosecution to
+show its cards.
+"To my knowledge, it's never happened before on a filed
+case," he said.
+NOT A CERTIFIED COPY
+CA/Aronberg-00.1042
+| ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
+
+
+252 / 278 - Thursday, October 18; 2007
+Section: LOCAL
+Page: 5B
+Source: The Associated Press
+Illustration: PHOTO (B&W)
+Memo: Ran all editions.
+Dateline: NEW YORK
+WOMAN SUES BILLIONAIRE INVESTOR, SAYS THEY HAD SEX WHEN SHE WAS 16
+A billionaire investor, already facing jail in Palm Beach County on charges of soliciting underage
+East Side mansion sometime in 2000.
+Epstein, 54, a money manager, told the teen he managed finances for Victoria's Secret and "could get
+you into the catalog" if she were "nice" to him, court papers say. The papers say being "nice"
+included massages and other favors.
+When the girl told: Epstein, 'I am 16 years old and just want to model," he replied, "Don't worry, I
+won't tell anybody," court papers say.
+Epstein, said by London's Mail on Sunday to be a close friend of England's Prince Andrew, has been
+indicted in Palin. Beach on charges of soliciting underage prostitutes. That case is pending
+The girl visited Epstein "several times over the several months and engaged in bizarre and unnatural
+sex acts" while she was a minor, the lawsuit says.
+Epstein "repeatedly requested that (the girl) return with her 14-, 15-, and 16-year-old girlfriends,
+stating, 'Come by with your friends your age next time. Don't bring Sherrie (a mutual friend in her
+40s). I love girls your age.'"
+The young woman, now 23, kept returning to Epstein because she has "mental issues," said her
+lawyer, William J. Unroch. He refused to elaborate, but court papers say she was "disabled as a result
+of severé mental disease and defect."
+Epstein's lawyer in New York, Gerald Lefcourt, said, "The girl has admitted she is insane, but she can
+read a newspaper and recognize the word 'rich."
+Lefcourt also said the statute of limitations has expired for the woman's case criminally and civilly,
+and will almost certainly be dismissed
+He refused to comment on Epstein's Florida charges.
+Meanwhile, Unroch, 57, also acknowledged that his client was living with him and was at the center
+of'a $10 million lawsuit he filed last year against a neighbor who said he was having sex with
+underage girls. That case is pending.
+"What she was doing at 22 is irrelevant to what happened to her when she was 16," Unroch said
+Wednesday. He went on the say he hoped Epstein would agree to "do right" by his client and resolve
+the case out of court.
+CA/Aronberg-00.1043
+
+
+Palm Beacher pleads in sex case
+Posted Jul. 1, 2008 at 12:01 AM
+Updated Oct 3, 2019 at 1:47 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on July 1, 2008)
+Jeffrey Epstein will serve 1 1/2 years on teen solicitation
+He lives in a Palm Beach waterfront mansion and has kept
+OPY
+company with the likes of President Clinton, Prince
+Andrew and Donald Trump, but investment banker Jeffrey
+Epstein will call the Palm Beach County Jail home for the
+next 18 months.
+Epstein, 55, pleaded guilty Monday to felony solicitation of
+prostitution and procuring a person under the age of 18 for
+prostitution. After serving 18 months in jail, he will be:
+under house arrest for a year. And he will have a lifelong
+obligation to register as a sex offender. He must submit to
+an HIV test within 48 hours, with the results being
+provided to his victims or their parents.
+As part of the plea deal, federal investigators agreed to drop
+their investigation of Epstein, which they had taken to a
+) grand jury, two law enforcement sources said.
+Epstein was indicted two years ago after an 11-month
+investigation by Palm Beach police. They received a
+complaint from a relative of a 14-year-old girl who had
+given Epstein a naked massage at his five-bedroom, 7,234-
+square-foot, $8.5 million Intracoastal home.
+Police concluded that there were sevéral other girls brought
+in 2004 and 2005 to an upstairs room at the home for
+similar massages and sexual touching.
+CA/Aronberg-001044
+
+
+The indictment charged Epstein only with felony
+solicitation of prostitution. The state attorney's office later
+added the charge of procuring underage girls for that
+purpose.
+Prosecutor Lanna Belohlavek said of the plea: "I took into
+consideration the length the trial would have been and
+witnesses having to testify™ about sometimes embarrassing
+incidents.
+Epstein may have made a serious mistake soon after he was
+charged. He rejected an offer to plead guilty to one count of
+aggravated assault with intent to commit a felony,
+according to police documents. He would have gotten five
+years probation, had no criminal record and not been a
+registered sex offender, the documents indicate..
+Epstein arrived in court Monday with at least three
+attorneys. He wore a blue blazer, blue shirt, blue jeans and
+and gray sneakers. After Circuit Judge Deborah Dale
+Pucillo accepted the plea, he was fingerprinted. Epstein
+then removed his blazer and was handcuffed for the trip to
+jail while his attorneys tried to shield him from
+photographers lenses.)
+When he eventually is released to house arrest, Epstein will
+have to observe a 10 p.m. to 6 a.m. curfew, have, no
+unsupervised contact with anyone younger than 18 and
+neither own nor possess pornographic or sexual materials
+"that are relevant to your deviant behavior," the judge said.
+Epstein will be allowed to leave home for work. The New
+York-based money manager told the judge he has formed
+the not-for-profit Florida Science Foundation to finance
+scientific research. "I'm there every day," Epstein said.
+The foundation was incorporated in November. Epstein
+said he already has awarded money to Harvard and MIT:
+CA/Aronberg-001045
+
+
+When he is released from jail, there is a chance that Epstein
+will be forced to move. Sex offenders are not allowed to live
+within 1,000 feet of a school, park or other areas where
+children may gather. No determination has been made as to
+whether Epstein's home complies, but attorneys said it
+likely does.
+Sex offenders also typically must attend counseling sessions.
+Belohlavek said that was waived for Epstein because his
+private psychiatrist is working with him. The judge was
+skeptical but agreed to it.
+Epstein's legal woes don't end with Monday's plea, There
+are four pending federal civil lawsuits and one in state court
+related to his behavior. At least one woman has sued him in
+New York, where he owns a 51,000-square-foot Manhattan
+mansion.
+"Iť's validation of what we're saying in the civil cases," said
+Miami attorney Jeffrey Herman, who represents the alleged
+victims in the federal lawsuits. West Palm, Beach attorney
+Ted Leopold represents one alleged victim in a civil suit in
+state court. He said he anticipates amending that lawsuit to
+add "a few other clients" as well.
+In the criminal case, police went so far as to scour Epstein's
+trash and conduct surveillance at Palm Beach, International
+Airport, where they watched for his private jet so they
+would know when he was in town. They concluded that
+Epstein paid girls $200 to $300 each after the massage.
+sessions.
+"I'm like a Heidi Fleiss,"
+about her efforts in recruiting girls for Epstein.
+1 now 22, told police
+There was probable cause to charge Epstein with unlawful
+sex acts with a minor and lewd and lascivious molestation,
+police concluded.
+CA/Aronberg-001046
+
+
+The state attorney's office said questions about the girls"
+credibility led it to take the unprecedented step of
+presenting the evidence against Epstein to a grand jury,,
+rather than directly charging him:
+Palm Beach Police Chief Michael Reiter was furious with
+State Attorney Barry Krischer, saying in a May 2006 letter
+that the prosecutor should disqualify himself. "I continue to
+find your office's treatment of these cases highly unusual,"
+he wrote. He then asked for and got a. federal investigation.
+Epstein hired a phalanx of high-priced lawyers - including
+Harvard law professor and author Alan Dershowitz - and
+public relations people who questioned Reiter's competence
+and the victims truthfulness.
+In addition to mansions in Palm Beach and Manhattan,
+Epstein owns homes in New Mexico and the Virgin Islands..
+He's a frequent contributor to Democratic Party candidates.
+He also donated $30 million to Harvard in 2003.
+Former New York Gov. Eliot Spitzer returned a $50,000
+campaign contribution from Epstein after his indictment,
+then resigned this year during his own sex scandal. And the
+same Palm Beach Police Department that vigorously
+investigated Epstein returned his $90,000 donation for the
+purchase of a firearms. simulator:
+Staff writer Eliot Kleinberg and former staff researcher
+NO
+Michelle Quigley contributed to this story.
+CA/Aronberg-001047
+
+
+REAL NEWS STARTS HERE.
+Jeffrey Epstein: Scientist,
+stuntman, 'sex slave' visit jailed
+tycoon
+/ Palm Beach Post Staff Writer
+Updated Jul 16, 2019 at 4:54 PM
+Tycoon Jeffrey Epstein mingled with an eclectic mix of
+into trouble for paying teenage girls to give him sexual
+massages at his Palm Beach mansion.
+Not much has changed, even though he now resides in a
+dorm at the Palm Beach County Sheriff's Office's 17-acre,
+967-bed stockade near the fairgrounds.
+During his first month of confinement, Epstein was visited
+by the female assistant who, girls told police, häd escorted
+them to the room at his mansion where they gave him
+naked massages.
+Also trekking to the jail was a young woman whom Epstein
+purportedly described as his Yugoslavian sex slave.
+The wealthy financier and science wonk also has been
+visited by an expert on artificial intelligence, as well as a
+/ man who is a mixéd martial arts aficionado and sometime
+movie stuntman.
+The only other people to visit him at the jail, according to
+records, are al
+Island man and an individual who
+listed Epstein's Palm Beach address as his own.
+Epstein, 55, pleaded guilty on June 30 to two prostitutionrelated charges and was sentenced to 18 months in jail,
+followed by a year of house arrest. Epstein paid teenage
+CA/Aronberg-001048
+
+
+girls $200 to $300 in 2004 and 2005 for massages in his
+home that sometimes included sexual touching, Palm Beach
+police said.
+His jail visitors in July included:
+29, who some of the teen masseuses said
+phoned them when Epstein was in town and escorted them
+upon their arrival at his Palm Beach waterfront hometo an
+upstairs room, where she prepared the massage table and
+provided the oils for their encounters with him:
+visited Epstein three times in July, according to a jail
+visitor's log. L
+lists a Manhattan home address.
+Reached by telephone, she declined to discuss Epstein.
+OPY
+, 23, whose family in Yugoslavia
+Epstein paid money to so that he could bring her to the
+United States to be his "sex slave," two teenage girls told
+police. One girl, told police that Epstein instructed
+and her to kiss and have sex while he watched
+and masturbated. Another said she engaged in sex with
+at Epstein's urging.
+visited Epstein
+in jail four times in 13 days: She lists her address as on the
+Upper East side of Manhattan, not far from Epstein's
+enormous apartment.
+- Roger Schank, 62, founder of the Institute for Learning
+Sciences at Northwestern University and an expert on
+artificial intelligence, paid one visit to Epstein. Schank has
+written numerous books on that subject and has a doctorate
+degree from Yale University in linguistics. He was one of 19
+people who applied to be president of Florida Atlantic
+University in 2003. He became "chief learning officer" at, the
+online Trump University in 2005. Schank listed his address
+as being in Stuart, and records show he also owns a home
+in Lake Worth.
+CA/Aronberg-001049
+
+
+Epstein has financed a number of scientists over the yeats,
+including Nobel Prize winners. He gave $30 million to
+Harvard University in 2003. In November, he formed the
+not-for-profit Florida Science Foundation, which he said
+finances scientific research.
+- Igor Zinoviev, a Russian mixed martial arts fighter, who
+coaches a Chicago team in the International Fight League.
+He also has worked as a personal trainer, celebrity
+bodyguard and movie stuntman, according to the league's
+Web site. The New Jersey resident visited Epstein seven
+times in July.
+Zinoviev, Schark and Marcinkova could not be reached for
+OP
+comment.
+Staff researcher Nids Heimeriks contribured to this story
+Staff
+research
+NOT A CERTIFIE
+CA/Aronberg-001050
+| ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
+
+
+Palm Beach Daily News
+Billionaire sex offender leaves jail
+six days a week for work
+Posted Jul 1, 2008 at 12:01 AM
+Updated Oct 4, 2019 at 9:27 AM
+Palm Beach billionaire Jeffrey Epstein, who's serving 18
+months in jail for soliciting an underage girl for
+prostitution, is allowed to leave the Palm Beach County
+Stockade six days a week on a work-release program.
+OPY
+Teri Barbera, spokeswoman for the Palm Beach County
+Sheriffs Office, confirmed that Epstein, 55, has been in the
+work-release program since Oct. 10.
+"He works six days a week: Friday through Wednesday 10
+a,m. to 10 p.m.," Barbera said via e-mail."(He) works at his
+local. West Palm Beach office, monitored on an active GPS
+system (he wears an ankle bracelet). Mr. Epstein hires a
+permit deputy, at his expense, for his own security at his
+workplace during the time he is out."
+Miami attorney Jeffrey Herman represents six young
+women who've sued Epstein, claiming he sexually abused
+them at his Palm Beach home when they were minors.
+Herman said he received a letter about the work-release
+) program from the U.S. Attorney's Office within the past
+few days. But Herman says Epstein had been out on workrelease for several weeks before the notification.
+"My clients expressed shock and disappointment," Herman
+said. "I find it incredible that he's on work-release in the
+community and my clients aren't notified of this and we get
+this letter weeks after the fact."
+Jack Goldberger, Epstein's criminal attorney, said the
+CA/Aronberg-001051
+
+
+arrangement is not unusual.
+"He goes to work every single day and goes back to jail at
+night, just like everybody else (in the program),"
+Goldberger said.
+Epstein pleaded guilty June 30 to two felony counts:
+soliciting prostitution and procuring a person, under 18 for
+prostitution. As part of the plea agreement, Epstein must
+serve one year of house arrest and register as a lifelong sex
+offender.
+NOT A C
+NOT A CERTIFIED COPY
+CA/Aronberg-001052
+
+
+Women want Epstein sex plea deal
+unsealed
+Posted Jül 1, 2008 at 12:01 AM
+Updated Oct 2, 2019 at 2:23 PM
+(EDITOR'S NOTE: This story originally published in The
+Palim Beach Post June 10, 2009)
+When wealthy money manager Jeffrey Epstein of Palm
+Beach pleaded guilty last year to procuring teens for
+prostitution, his case detoured around local and state rules.
+regarding the sealing of court documents.
+At a plea conference on the state charges, a judge, a defense
+lawyer and a prosecutor huddled at the bench and decided
+that a deal Epstein had struck with federal prosecutors to
+avoid charges should, be séaled, according to a transcript of
+the hearing
+And so it was.
+But Florida rules of judicial administration, as well as rules
+of the Palm Beach County court system, require public
+•horification that a our document has been or wil be
+sealed, meaning kept from public view. The rules also
+require a judge to find a significant reason to scal, such as
+protecting a trade secret or a compelling government
+interest.
+'Yet no notification or reason occurred in Epstein's case,
+according to court records.
+...
+CA/Aronberg-001053
+
+
+Epstein's own attorneys, in federal filings, have referred to
+his confidential deferred prosecution agreement with the
+U.S. attorney's office, struck in September 2007, as
+"unprecedented" and "highly unusual." And it was "a
+significant inducement" for Epstein to accept the state's !
+deal, observed the state judge who accepted his plea,
+County Judge Deborah Dale Pucillo.
+Epstein now faces at least a dozen civil lawsuits in federal
+and state courts filed by young women who said they had
+sex with him and now are seeking damages.
+Attorneys for some of those women want his agreement
+with federal prosecutors unsealed and will ask Circuit Judge
+Jeffrey Colbath to do so today.
+"It is against public policy for these documents to be have
+been sealed and hidden from public scrutiny. As a member
+of the public, E. W. has a right to have these documents
+unsealed," wrote former Circuit Judge Bill Berger, now in
+private practice and representing one of the women.
+The Palm Beach Post also will ask Colbath to unseal the
+agreement. Post attorney Deanna Shullman will argue that
+the public has a right to know the specifics of Epstein's deal:
+According to various media accounts, Epstein moved in
+circles that included President Clinton, Donald Trump and
+Prince Andrew. "International Moneyman of Mystery,"
+declared a 2002 New York magazine profile of Epstein,
+Epstein, 56, is in the Palm Beach County Stockade, serving
+an 18-month sentence after pleading guilty nearly a year.
+ago to felony solicitation of prostitution and procuring
+teenagers for prostitution.
+He is allowed out from 7 a.m: to 11 p.m., escorted by a
+deputy, said Palm Beach County Sheriff's Office
+spokeswoman Teri Barbera.
+1
+CA/Aronberg-001054
+
+
+During a Palm Beach Police Department investigation, five
+victims and 17 witnesses gave statements. They told of
+young women brought by his assistants to Epstein's
+mansion on El Brillo Way for massages and sexual activity,
+and then being paid afterward.
+At Epstein's plea conference last year, his attorney, Jack:
+Goldberger, and then-Assistant State Attorney Lanna
+Belohlavek approached Pucillo in a sidebar conference.
+Pucillo, who had left the bench nine years earlier, was
+filling in temporarily as a senior judge.
+According to a transcript, Goldberger told Pucillo that
+Epstein had entered a confidential agreement with the U.S.
+attorney's office in which federal prosecutors brokered not
+pursuing charges against him if he pleaded guilty in state
+court. Pucillo then said she wanted a sealed copy of the
+agreement filed in his case, and Goldberger concurred that
+he wanted it sealed, Belohlavek later signed off on it.
+The Florida Supreme Couft has expressed "serious concern"
+and launched an all-out inquiry into sealing procedures
+across the state following media reports in 2006 of ențire
+cases being sealed and disappearing from court records.
+"The public's constitutional right of access to court records
+must remain inviolate, and this court is fully committed to
+safeguarding this right," justices wrote in their final report.
+Goldberger, who declined to comment. Pucillo also has
+declined. to comment.
+CA/Aronberg-001055
+
+
+Epstein secret pact with Feds
+reveals "highly unusual" terms
+Posted Jun 10, 2009. at 12:01 AM.
+Updated Oct 4, 2019 at 9:23 AM
+(EDITOR'S NOTE: This story originally published' in The
+Palm Beach Post ori September 19, 2009)
+A secret non-prosecution agreement multimillionaire
+financier Jeffrey Epstein struck with federal prosecutors is
+OPY
+being called "highly unusual" by former federal prosecutors
+and downright outrageous by attorneys now reptesenting
+young women who serviced him.
+The deal reveals that the FBI and the U,S. Attorney's Office
+investigated him for several. federal crimes, including
+engaging minors in commercial sex. The crimes are
+punishable by anywhere from 10 years to life in prison..
+But federal prosecutors backed down and agreed to recall
+grand jury subpoenas if Epstein pleaded guilty to
+prostitution-related. felonies in state court, which he
+ultimately did. He received an 18-month jail sentence, of
+which he served 13 months.
+The U.S. Attorney's Office also agreed not to charge any of
+Epstein's possible co-conspirators:
+Lesley Groff and
+The deal was negotiated in part by heavyweight New York
+criminal defense attorney Gerald Lefcourt.
+Unsealed on Friday after attorneys for some of Epstein's
+victims and The Palm Beach Post sought its release, it offers
+the first public look at the deal Epstein's high-powered. legal
+counsel brokered on his behalf.
+CA/Aronberg-001056
+
+
+Mark Johnson of Stuart, a former federal prosecutor,
+described the disparity in potential sentences as unusual,
+but ever more so a provision on attorney payment.
+The first draft of the agreement in September 2007
+required that Epstein pay an attorney -- tapped by the U.S.
+Attorney's Office and approved by Epstein -- to represent
+some of the victims. That attorney is prominent Miami
+lawyer Bob Josefsberg.
+But an addendum to the agreement signed the following
+month struck Epstein's duty to pay Josefsberg if he and the
+victims did not accept settlements-- capped at $150,000 -
+and instead pursued lawsuits.
+said it appears the government was trying to
+balance the lesser sentence for Epstein with recovering
+$150,000 for each victim. "I've never, ever seen anything
+like that in my life," he said. "It's bighly unusual."
+The deal does not say whether any victims were contacted
+or consulted before the deal was made.
+Attorney Brad Edwards of Fort Lauderdale, who represents
+three of the young women, believes that none of the 30 to
+40 woman identified as victims in the federal investigation
+were told ahead of time.
+said his clients received
+letters from the U.S. Attorney's Office months after the deal
+was signed, assuring them Epstein would be prosecuted.
+"Never consulting the victims is probably the most
+outrageous aspect of it,"
+said. "It taught them that
+someone with money can buy his way out of anything: It's
+outrageous and embarrassing for United States Attorney's
+Office and the State Attorney's Office.™
+Epstein now faces many civil lawsuits filed by the women,
+who are represented by a variety of attorneys. In many, the
+allegations are the same: that Epstein had a predilection for
+teenage girls, identified poor, vulnerable ones and used
+CA/Aronberg-001057
+
+
+other young women to lure them to his Palm Beach
+mansion. They walked away with between $200 and
+$1,000.
+Former Circuit Judge Bill Berger, also representing victims;
+called the agreement a "sweetheart deal."
+"Why was it so important for the government to make this
+deal?" Berger asked rhetorically. "We have not yet had an
+honest explanation by any public official as to why it was
+made.. and why the victims' were sold down the river."
+Former federal prosecutor Ryon McCabe described the
+agreement as "very unorthodox." Such agreements, hè said,
+are usually reserved for corporations, not individuals.
+"It's very, very rare. I've never seen or heard of the
+procedure that was set up here," said McCabe, who has no
+involvement in any Epstein litigation.
+"He's essentially avoiding federal prosecution because he
+can afford to pay that many lawyers to help those victims
+review their cases. AIf a person has no money, he couldn't
+be able to strike a deal like this and avoid federal
+prosecution/
+The backroom deal with federal prosecutors is all the more
+interesting in light of the legal powerhouses who have
+worked for Epstein, including Harvard professor Alan
+Dershowitz and Bill Clinton investigator Kenneth Starr.
+Lefcourt is a past president of the National Association of
+Criminal Defense Lawyers.
+Epstein's local defense attorney, Jack Goldberger, issued a
+statement Friday saying he had fought the release of the
+sealed agreement to protect the third parties named there.
+"Mr. Epstein has fully abided by all of its terms and
+conditions. He is looking forward to putting this difficult
+period in his life behind him. He is continuing his longstanding history of science philanthropy."
+CA/Aronberg-001058
+
+
+The investigation triggered tensions between police and
+'prosecutors, with then-Palm Beach Chief Michael Reiter
+saying in a May 2006 letter to then-State Attorney Barry
+Krischer that the chief prosecutor should disqualify himself.-
+"I continue to find your office's treatment of these cases
+highly unusual," Reiter wrote. He then asked for and got
+the federal investigation that ended in the sealed deal.
+"The Jeffrey Epstein matter was an experience of what a
+many-million-dollar defense can accomplish," Reiter told
+the Palm Beach Daily News upon his retirement.
+NOT A CERTIFIED COPY
+CA/Aronberg-001059
+FILED: PALM BEACH COUNTY, FL, I
+
+
+187 / 278 - Wednesday, January 27, 2010
+Section: LOCAL & BUSINESS
+Page: 3B
+Source: By JANE MUSGRAVE Palm Beach Post Staff Writer
+Dateline: WEST PALM BEACH
+JUDGE RULES EPSTEIN ATTORNEYS CAN SUBPOENA ABORTION RECORDS
+In a decision that could spark a constitutional showdown over privacy rights, a judge
+uesday gave lawyers representing multimillionaire sex offender Jettrey opstein the rignt
+ibpoena abortion records from women who are, seeking millions in damages from the par
+time Palm Beach resident.
+Palm Beach County Circuit Judge Donald Hafele said the records could help Epstein rebut
+the women's claims that they suffered psychological ills after being paid to give him
+sexually-charged massages at his Palm Beach mansion when they were as young as 14.
+Hafele told Epstein's attorneys they couldn't go on a fishing expedition. The medical records,
+he said, can't be sought until the women are asked whether they have ever had an abortion,
+how many and where. Further, he said, the records would not be made public and might not
+be admissible during trial.
+But, he said, since the women claim Epstein, now 57, is responsible for their emotional
+distress, his attorneys can explore the impact of other events. Medical records, Hatele said,
+are a better source of information than a person's memory.
+Attorney Louis Silver, who represents the Presidential Women's Health Center, a West Palm
+Beach clinic where abortions are performed, warned Hafele that.he was stepping on shaky
+constitutional grounds.
+"These records are protected by our constitutional right of privacy," he said, referring to the
+Florida Constitution.
+After the hearing; Silver said an appeal won't be necessary until Epstein attorneys seek the
+records.
+In another ruling Wednesday, Hafele also said that videos from depositions in the state cases
+can't be released without a court order. The ruling came after Epstein attorney Robert Critton.
+complained that a video of Epstein being asked whether he had an "egg-shaped" penis
+became a yourube.com.sénsation: It first appeared on The Palm Beach Post Web site.
+Critton blamed attorney Spencer Kuvin for releasing it. Kuvin said it was public record.
+The civil suits began mounting after Epstein agreed to plead guilty to two state charges:
+procuring a minor for prostitution and soliciting prostitution. He served 13 months of an 18-
+month sentence. As part of the deal brokered with federal prosecutors, he agreed not to
+contest the accusations in the civil lawsuits. He can argue the women don't deserve the
+millions they are seeking.
+~jane_musgrave@pbpost.com
+CA/Aronberg-001060
+
+
+Epstein Journal's Findings Could
+Resurrect Case
+By Jane Musgrave
+Posted Sep 17, 2019 at 12:01 AM
+Updated Oct 1, 2019 at 10:51 AM.
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on March 20, 2010)
+"hundreds" of victims of convicted sex offender Jeffrey
+Epstein could be used to reopen the investigation into the
+multi-millionaire's appetite for teenage girls, an attorney
+representing seven of the victims said Friday.)
+New details about the contents of the journal were released
+this week when Alfredo Rodriguez, who worked as a
+property manager for the Palm Beach resident, pleaded
+guilty to obstruction of justice for lying to federal agents
+when asked if he had any information about his former
+boss' criminal activity. He later tried to sell the journal he
+stole from Epstein for $50,000 to an unidentified person,
+who alerted authorities, according to court records.
+As part of the plea agreement, federal prosecutors said the
+ournal contains in formation material to the Epstein
+investigation, including the names of material witnesses
+and additional victims."
+"Had the items been produced in response to the inquiries
+of state or federal authorities... the materials would have
+been presented to the federal grand jury," federal
+prosecutors wrote.
+CA/Aronberg-001061
+
+
+Instead, prosecutors short-circuited the grand jury
+investigation and cut a deal with Epstein. They agreed not
+to pursue federal charges if he didn't contest prostitutionrelated felonies in state court. The money manager pleaded
+guilty in July 2008 to procuring' a minor for prostitution
+and soliciting prostitution. He served 13 months of an 18-
+month sentence.
+Attorney Adam Horowitz, who represents seven of the
+roughly 18 women who have filed civil suits against:
+Epstein, said the new information could trump the socalled non-prosecution agreement.
+The multifaceted agreement, he said, deals only with a
+OPYR
+specific list of victims that the U.S. Attorriey's Office knew
+about when it penned the deal in 2007. If additional victims
+are listed in the journal Rodriguez stole, Horowitz said
+federal prosecutors could reopen the investigation.
+"It opens the door for further prosecution," he said.
+In addition to turning over the journal to federal agents,
+Rodriguez told them he knew his former boss was having
+sex with underage girls when he worked for him in 2004
+and 2005. He had seen naked girls, who looked like minors,
+in the pool of Epstein's $8.6 million mansion. He had seen
+pornographic images of young girls on Epstein's computer,
+according to court records.
+) Neither Epstein's criminal defense attorney, Jack
+Goldberger, nor attorney Robert Critton, who represents
+Epstein in the civil lawsuits, could be reached. Federal
+prosecutors have consistently declined comment.
+The wording of the controversial agreement is unclear. It
+says federal prosecutors would provide Epstein's attorneys
+"with a list of individuals whom it has identified as victims."
+Miami attorney Robert Josefsberg was appointed to
+CA/Aronberg-001062
+
+
+represent any of the victims on the list who wanted to
+pursue Epstein in civil court. As part of the agreement,
+Epstein is to pay for Josefsberg to represent the women.
+Some of the women, most identified as Jane Doe in
+lawsuits, had already hired attorneys to represent them.
+Some have since settled their suits with Epstein, although
+terms were not disclosed.
+Horowitz said he has filed court papers to get the journal
+that Rodriguez stole. "It's another piece of evidence that
+shows our clients were at Epstein's mansion, "he said.
+Rodriguez told prosecutors he didn't turn over the journal
+when both FBI and Palm Beach police asked for it because
+he wanted money for it. He also said he was afraid Epstein
+would make him "disappear." The information, he told
+investigators, was his "insurance policy."
+He faces a maximum 20 years in prison when he is
+sentenced on June 18.
+jane_musgrave@pbpost.com
+@phpcourts
+NOT A
+CA/Aronberg-001063
+
+
+Epstein paid three women $5.5 million to end underagesex lawsuits
+By Jane Musgrave
+Posted Oct 3, 2017 at 12:01.AM
+Updated Oct:4, 2017 at 12:46 AM
+Ending years of speculation about how much Palm Beach billionaire Jeffrey Epstein paid young
+women who claimed he used them as sex toys, court documents filed, last week show he shelled
+out $5.5 million to settle lawsuits with three of more than two dozen teens who sued him.
+Responding to requests from Epstein's attorneys in a complex lawsuit that was spawned by the
+sex scandal, attorney
+said the politically connected 64-year-old convicted sex
+offender paid more than $1 million to cach of the three women |
+represented.
+Identified in court papers only by their initials or pseudonyms because of the nature of the
+allegations and their youthful ages, L.M. was paid $1 million, E. W. S2 million and Jane. Doe
+$2.5 million,
+said of the settlements he negotiated with Epstein to end the lawsuits.
+Jack Goldberger, one of Epstein's criminal defense attorneys, on Tuesday declined comment on
+the revelations, citing confidentiality agreements that were part of the settlements. For the
+same reason, he declined to say whether Epstein. paid similar amounts to settle roughly two
+dozen lawsuits filed by other young women against Epstein, claiming he paid them for sex
+when some were as young as 14 years old.
+Attorney Jack Scarola, who is
+, said his client was compelled to divulge
+the confidential settlements to answer questions posed by Epstein's attorneys. "Brilliant move
+on their part," he said.
+Even if Epstein's attorneys hadn't opened the door, Scarola said the information would have
+likely come out. He says the information will help him undermine Epstein's claims that
+"ginned up" the allegations to help his former law partner, imprisoned and disbarred
+Fort Lauderdale lawyer Scott Rothstein, perpetuate a $1.2 billion Ponzi scheme.
+CA/Aronberg-001064
+
+
+The revelations of the settlements came as part of an ongoing lawsuit that started as a dispute
+between Epstein and Rothstein, both billionaires.
+A year after Epstein in 2008 pleaded guilty to solicitation of prostitution and procuring a
+minor for prostitution, he sued Rothstein and Edwards, claiming they trumped up the
+allegations of sexual molestation to perpetuate the Ponzi scheme..
+Rothstein was sentenced to 50 years in prison in 2010 after admitting he had built his wildly
+successful law firm by forging the names of federal judges and others to persuade investors he
+had negotiated settlements in lawsuits against high-profile people. Investors were told they
+could get a cut of the cash.
+One of the high-profile people Rothstein used to lure investors was Epstein, according to a
+lawsuit West Palm Beach attorney Robert Critton filed on Epstein's behalf. According to the
+lawsuit, Rothstein told investors Epstein, a money manager, had agreed to settle the lawsuits
+with the teens for $200 million — a claim Critton described as "a complete fabrication."
+After Epstein dropped the lawsuit in 2012, Edwards turned the tables on him.
+accused
+Epstein of filing the lawsuit maliciously to punish him for representing the young women.
+Although
+was a partner in Rothstein's now defunct firm, Scarola claims Epstein had
+no evidence
+was involved in the Ponzi scheme. Federal prosecutors successfully
+charged other attorneys and members of the firm, but
+was never implicated, Scarola
+said in the malicious prosecution lawsuit.
+The revelations about the money Epstein paid to three of the young woman came last week in
+documents filed for a hearing Tuesday in preparation for a December trial on the lawsuit.
+Attorney Tonja Haddad Coleman, who represents Epstein, on Tuesday sought a delay of the
+trial, in part, because she claimed she has been unable to talk to her client since his estate on his
+private island in the U:S. Virgin Islands was devastated last month by Hurricane Irma. "I've had
+no ability to communicate: with Mr. Epstein," she said.
+CA/Aronberg-001065
+
+
+Pointing out Epstein's enormous wealth and his private jet, Palm Beach County Circuit Judge
+Donald Hafele rejected her request. While saying he didn't want to appear insensitive to those
+victimized by the storm that hammered. the Caribbean and roared through South Florida, he
+said Coleman offered no proof, such as an affidavit from Epstein, to shore up her claims.
+Still, Hafele gave Coleman extra time to respond to various motions that he will have to decide
+before the case goes to trial.
+Despite Scarola's insistence that|
+had nothing to do with Rothstein's Ponzi scheme,
+Coleman said the evidence indicates otherwise. Why else would he try to depose Epstein's
+well-known friends, such as now President Donald Trump, former President Bill Clinton and
+illusionist David Copperfield, she asked. He used the celebrities as a draw, she said.
+"The Epstein cases were used to fleece money and defraud investors," she-said.
+Edward's malicious prosecution case has: been difficult for both sides because both Epstein and
+have refused to answer questions. As he did in the civil lawsuits, Epstein has invoked
+his Fifth Amendment right against self-incrimination when questioned by Scarola.
+has claimed that much of the information Epstein is seeking is protected by attorney-client
+privilege
+The malicious prosecution lawsuit is one oftwo hotly-contested lawsuits that continue to pit
+against Epstein. Edwards also is suing the U.S. attorney's office, claiming it violated
+the federal Crime Victims Rights Aet when it negotiated a non-prosecution agreement with
+Epstein.
+Only after federal prosecutors agreed to drop their investigation of Epstein, did he agree to
+plead guilty to-two prostitution charges in Palm Beach County Circuit Court. In federal court
+records, prosecutors claim one of the key reasons they agreed to drop their case was Epstein's
+agreement to settle lawsuits filed against him by dozens of his underage victims.
+CA/Aronberg-001066
+
+
+Palm Beach Daily News
+Judge rules feds' agreement with
+Jeffrey Epstein pact violated teen
+victims' rights
+By Jane Musgrave
+Posted Sep 17, 2019 at 4:02 PM
+Updated Oct 8, 2019 at 12:31 PM
+(EDITOR'S NOTE: This story originally published in The
+Palm Beach Post on February 22, 2019)
+ODy
+Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims by failing to reveal they had dropped plans
+to prosecute the billionaire on dozens of federal charges in
+connection with the girls' claims that he paid them for sex
+at his Palm Beach mansion, U.S. District Judge Kenneth
+Marra ruled on Thursday.
+In a blistering 33-page ruling, Marra meticulously and
+methodically detailed the numerous steps federal
+prosecutors took to hide the agreement from more than 40
+young women who claim Epstein paid them for sex when
+they were as young as 14.
+"While the government spent untold hours negotiating the
+terms and implications of the NPA with Epstein's attorneys,
+) scant information was shared with the victims," Marra
+wrote. "Instead, the victims were told to be 'patient' while
+the investigation proceeded."
+By then, it was too late. A deal häd already been cut with
+then-South Florida U.S. Attorney Alex Acosta and. Epstein's
+attorneys to shelve a 52-page federal indictment against
+Epstein, a former math teacher turned money manager
+who counts Presidents Donald Trump and Bill Clinton
+among his friends.
+CA/Aronberg-001067
+..:
+
+
+Prosecutors' failure to alert the young women about the
+deal violated the Crime Victims' Rights Act, Marra ruled.
+"At a bare minimum the (act) required the government to
+inform. (the young women) that it intended to enter into an
+agreement not to prosecute Epstein," he wrote.
+Still, Marra said he wasn't second-guessing prosecutors'
+decision not to pursue Epstein on federal charges if he
+pleaded guilty to minor state prostitution charges and
+agreed to compensate his victims for the trauma he caused.
+"The court is not ruling that the decision not to prosecute
+was improper," Marra wrote. "The court is simply ruling
+that, under the facts of this case, there was a violation under
+the CVRA."
+Further, he made no decision about what the remedy
+should be. He gave prosecutors and attorneys representing
+the young womer 15 days to meet to decide how to unravel
+the complex legal web that has been hanging over Epstein
+and his young victims for more than a decade.
+The chances an accord will be reached are slim, said
+attorney Jack Scarola, who is representing the two Jane
+Does who challenged the prosecutors' actions.
+Further, he said, there is no road map to follow. The
+lawsuit attorney
+filed on behalf of the two
+unidentified young women, claiming prosecutors violated
+the federal act, is unique, he said.
+"We are treading on virgin ground, to use what is probably
+an inappropriate phrase in this situation," he said.
+Scarola said he and
+will ask that the nonprosecution agreement be thrown out. That would open
+the possibility that the long-shelved federal indictment
+could be dusted off and filed against the 66-year-old
+Epstein, who spends most of his time on a private island he
+owns in the U.S. Virgin Islands.
+CA/Aronberg-001068
+
+
+"I don't see the government conceding to that remedy,"
+Scarola admitted. Further, he said, it is likely Epstein will be
+allowed to weigh in. Miami attorney Roy Black years ago
+filed papers asking to intervene on Epstein's behalf.
+The U.S. Attorney's Office said it wouldn't comment on
+Marra's ruling. Neither Black nor New York City attorney
+Jay Lefkowitz, who led efforts to bury the federal
+indictment, responded to emails or phone calls for
+comment. West Palm Beach attorney Jack Goldberger, who
+represents Epstein, also didn't respond.
+Scarola said it is likely Epstein's star-studded legal team will
+argue that. Epstein fully complied with the terms of the
+agreement he made in 2007 with federal prosecutors and
+therefore the agreement can't be undone.
+As he promised, Epstein pleaded guilty in June 2008 to state
+charges of soliciting a minor for prostitution. and soliciting
+prostitution. He served 13 months ofan 18-month jail term
+in a vacant wing of the county stockade that he was allowed
+to leave 12 hours a day, six days week.
+Further, as agreed, he paid settlements to the young women
+who sued him. While the settlements were confidential,
+court records show he paid three women a total of $5.5
+million.
+In return, federal prosecutors held up their end of the
+bargain. Their investigation ceased.
+Having done all that prosecutors asked of him, Scarola said
+Epstein will make a simple argument: "You can't turn
+around and deprive me of the benefits I bargained for."
+However, Scarola said, using Marra's ruling, he will counter
+that the contract Epstein signed was illegal and therefore
+unenforceable.
+CA/Aronberg-001069
+
+
+Even if Marra agrees to toss out the non-prosecution
+agreement, Scarola conceded that doesn't mean Epstein will
+face federal charges.
+"The contract can be set aside and the federal government
+can attempt to enter into the same agreement," he said.
+"Except the spotlight of public attention will be on them
+and the 40 victims will be able to explain to the court why
+this sweetheart deal should not be approved."
+Scarola said that prosecutors may have had good reason not
+to pursue Epstein. "There may be a reasonable explanation
+but we don't know what that reason may have been," he
+said.
+Op
+In court papers, federal prosecutors have said that many of
+the young women were afraid to cross the powerful,
+politically connected, money manager and simply refused to
+testify against him.
+In other cases, they said, the women changed their stories.
+Jane Doe 2, who is trying to have the non-prosecution
+agreement thrown out, initially described Epstein as "an
+awesome man" and told prosecutors she hoped "nothing
+happens" to him. While she later agreed to testify against
+Epstein, prosecutors said they feared Epstein's attorneys
+would use her words to destroy her if she ever took the
+witness stand.
+Marra, however, said the young woman's comments didn't
+mean she wasn't entitled to know about the prosecutors'
+plars to drop the charges. "There is ho dispute that Epstein
+sexually abused Jane Doe 2 while she was a minor," he
+wrote. "Therefore, regardless of her comments to the
+prosecutor, she was a victim."
+Before the case is finally resolved, Scarola predicted that "a
+lot of people are going to have to answer a lot of questions."
+CA/Aronberg-001070
+
+
+In his ruling, Marra detailed what appeared to be a cozy
+relationship between Acosta, his line prosecutors and
+Epstein's team of lawyers. His phalanx of lawyers included
+noted Harvard law professor Alan Dershowitz and Kenneth
+Starr, the former U.S. solicitor general whose investigation
+led to the impeachment of President Clinton.
+Marra describes an October: 2007 breakfast meeting
+between Acosta, who is now U.S. labor secretary, and
+Lefkowitz shortly after the non-prosecution agreement was
+him for "the commitment you made to me during our
+October 12 meeting in which you assured me that your
+Office would not ... contact any of the identified
+individuals, potential witnesses, or potential civil claimants
+and their respective counsel in this matter.
+Marra quoted an equally pleasánt note then-Palm Beach
+County State Attorney Barry Krischer sent to Assistant U.S.
+Attorney
+Villafana, who was the lead prosecutor in
+Epstein's case. "Glad we could get this worked out for
+reasons I won't put in writing," Krischer wrote, shortly
+after the non-prosecution agreement was signed. "After this
+is resolved I would love to buy you a cup at Starbucks and
+have a conversation."
+Many of the notes that were exchanged dealt with
+prosecutors' and Epstein's lawyers' shared desire to keep the
+deal secret from Epstein's accusers. In a September email,
+Villafana asked Lefkowitz for guidance about what she
+should reveal. "And can we have a conference call to discuss
+what I may disclose to... the girls regarding the
+Agreement," she asked.
+CA/Aronberg-001071
+
+
+Such cooperation between prosecutors and defense
+attorneys is unusual, Marra said. "It was a deviation from
+the government's standard practice to negotiate with
+defense counsel about the extent of crime victim
+notifications," he wrote.
+Further, he noted, that when
+and his two young
+clients asked for information, they were repeatedly misled
+"The CRVA was designed to protect victims' right and
+ensure their involvement in the criminal justice process,"
+Marra wrote. "When the government gives information to
+victims it cannot be misleading."
+Ultimately, the terms of the non-prosecution agreement
+OP
+were revealed only after
+and attorneys for the
+press successfully sued to
+make
+them
+public.
+jmusgrave@pbpost.com
+:@pbpcourts
+NOT A CERTIFIE
+CA/Aronberg-001072
+•ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
+
+
+76 / 278 - Tuesday, July 9, 2019
+Edition: Final
+Section: A Sectior
+Page: 1A
+Source: By Jane Musgrave, The Palm Beach Post
+Epstein indicted on sex charges
+Part-time Palm Beacher pleads not guilty to sex
+trafficking, conspiracy charges in federal court in
+Manhattan
+Dressed in a blue prison jumpsuit, billionaire Jeffrey Epstein on Monday pleaded not. guilty
+to charges accusing him of creating a vast network of girls as young as 14 that he exploited
+for his sexual pleasure at his homes in Palm Beach and Manhattan,
+The 66-year-old money manager's appearance in U.S. District Court in New York City
+capped more than a decade of recriminations by young women and their attorneys. who
+claimed Epstein used his money and political influence to avoid federal prosecution.
+Epstein's attorney Reid Weingarten dismissed the two-count indictment on sex trafficking
+charges as "essentially a do-over" of allegations that landed Epstein in the Palm Beach
+County Jail for 13 months more than a decade ago.
+However, unlike in.2007 when then-South Florida U.S. Attorney Alex Acosta agreed to
+shelve a 53-page federal indictment after Epstein agreed to plead guilty to two state
+prostitution charges, prosecutors in New York indicated they aren't willing to deal. Acosta is
+now U.S: labor secretary.
+"The alleged behavior shocks the conscience," New York City U.S. Attorney Geoffrey
+Berman said at a
+morning news conference. "And while the charged conduct is from a number of years ago, it
+is still profoundly important to many of the alleged victims, now young women. They
+deserve their day in court."
+At a detention hearing scheduled for Monday, Berman said he will ask a federal judge to
+keep Epstein behind bars until he is tried on charges of sex trafficking and conspiracy to
+commit sex trafficking: Epstein paid dozens of young women to give him-nude massages
+that, for most, led to sex, he said.
+If convicted of exploiting dozens of young women, including many Palm. Beach County girls
+who were students at
+Palm Beach High School, Epstein faces a maximum 45-year
+prison sentence.
+Citing Epstein's enormous wealth, his homes in New York, Palm Beach, the U.S. Virgin
+Islands, New Mexico and Paris and his ownership of two jets, Berman said there are few
+conditions that could keep Epstein from fleeing to a foreign country to evade prosecution.
+CA/Aronberg-001073
+
+
+"We think he's a significant flight risk," Berman said of the man who ferried Britain's Prince
+Andrew, actor Kevin Spacey, famed Harvard. law professor Alan Dershowitz and former
+President Bill Clinton-on his jet, dubbed the Lolita Express.
+Berman's hard-line stance was welcomed by young women who for years have been told that
+Epstein couldn't be touched because Acosta signed off on the nonprosecution agreement,
+promising not to charge Epstein in federal court.
+Former Palm Beach County resident Virginia Guiffre, who has accused Epstein of turning
+her into his sex slave and forcing her to have sex with others, including Dershowitz and
+Prince Andrew, praised Berman. He showed the case is "being taken in a serious way," she
+fold the Associated Press. Dershowitz has vehemently denied Guiffre's claims.
+New York prosecutors were able to ignore the controversial nonprosecution agreement
+because it contained some significant fine print, said former federal Judge Paul Cassell, who
+for years has fought to get the agreement thrown.out. It says only that no charges could be
+filed against Epstein in South Florida, he said.
+Berman agreed. "That agreement only binds, by its terms, only binds the Southern District of
+Florida," he said. "The Southern District of New York is not bound by that agreement and
+wasn't a signatory of it."
+That means the sordid allegations that have been leveled at Epstein for years are now part of
+a federal indictment.
+Contrary to Epstein's claims, he knew the women who came to his homes in New York and
+Palm Beach were minors because they told him their ages, according to the indictment.
+Epstein preyed on young girls because he knew they were "vulnerable to exploitation,"
+prosecutors added.
+As part of a carefully orchestrated sex ring, Epsteih or his associates would call girls while
+he was in New York so they would be available for sex once he returned to Palm Beach, the
+indictment says. The employees weren't named. They were identified only as. "Employee-1,"
+"Employee-2" and "Employee-3."
+To ensure he had a steady stream of young girls, Epstein would turn some victims into
+recruiters, He would pay them to bring new girls to his home on El Brillo Way along the
+Intracoastal Waterway in Palm Beach or to his palatial townhouse on New York's Upper East
+Side.
+"This allowed Epstein to create an ever-expanding web of new' victims," Berman said.
+In both New York and Palm Beach, the lurid operation was similar. Unidentified employees
+of Epstein's would escort the teens into a room. They were told to take off all or most of their
+clothes before giving the naked billionaire massages, according to the indictment.
+"Epstein would also typically masturbate during these encounters, ask victims to touch him
+while he masturbated, and touch victims' genitals with his hands or with sex toys," the
+indictment says.
+As part of the criminal complaint, prosecutors are asking that Epstein be forced to turn over
+his multimillion-dollar townhouse on East 71st Street. The complaint does not seek forfeiture.
+of Epstein's house in Palm Beach.
+While heartened that Epstein now faces serious criminal charges in New York, Cassell said
+he would continue to push a West Palm Beach-based federal judge to throw out the
+nonprosecution agreement that Acosta forged with Epstein's star-studded legal team.
+CA/Aronberg-001074
+
+
+U.S. District Judge Kenenth Marra has already ruled that Acosta violatedi the federal Crime
+Victims' Rights Act by not telling Epstein's victims about the agreement before it was inked.
+Coincidentally, Cassell and Epstein attorney Roy Black had to file papers by midnight
+Monday, explaining what action Marra should take to redress that wrong.
+Cassell insisted Epstein should face charges in federal court in West Palm Beach. "Florida
+victims deserve justice in Florida," said Cassell, who is working on behalf of Epstein's
+victims with attorneys
+and Jack Scarola.
+Since it's likely Florida women will get to testify against Epstein in New York, Scarola said
+he's not focused on whether Epstein will face charges here. Instead, he said he wants to know
+how and why the agreement was reached.
+"There's been no explanation as to how a deal like this could have been cut and how the
+federal government could have been involved in a conspiracy to violate federal law;" Scarola
+said of his interest in continuing the legal battle over thè nonprosecution agreement.
+When Acosta agreed to drop the federal investigation, Epstein in 2008 pleaded guilty to two
+prostitution charges and served 13 months of an 18-month sentence in a vacant wing of the
+Palm Beach County Jail. - a cell he was allowed to leave 12 hours a day, six days a week. He
+was also forced to register as a sex offender and settle civil lawsuits more than 30 young
+women filed against him.
+U.S. Rep. Lois Frankel, D-West Palm Beach, said she shares Scarola's interest in finding out
+how the agreement came to be."I am especially more interested in why Epstein got the deal
+is not sure that will happen. "It just seems to me it was a travesty that this guy got off the
+Former Palm Beach Police Chief Michael Reiter was inflamed in 2006 when then-State
+Attorney Barry Krischer refused to charge Epl
+with serious crimes. Reiter took the
+information his officers had gathered from dozens of Epstein's victims to Acosta, believing
+he would prosecute Epstein. He didn't.
+Reiter said he was heartened that 13 years later, Epstein will finally face justice.
+"Thankfully, U.S. Attorney Berman and the other authorities. in New York have the good
+judgment to investigate and prosecute Epstein in, the way that should have occurred in
+Florida over a decade ago," Reiter said in a statement.
+And, Scarola said, there are signals that Berman's investigation is far from over.
+Berman declined to answer questions about whether others, such as Epstein's high-powered
+friends, would be charged. He brushed off questions about the significance that the
+investigation was being handled by the Public Corruption Unit.
+While agents on Saturday were arresting Epstein aboard his private jet at the Teterboro
+Airpor, in New Jersey after returning from Paris, other officers were searching his New York.
+City townhouse. Agents seized nude photos of' young girls who appeared to be minors,
+Berman said.
+He said his focus was on finding more women who were exploited and abused by Epstein.
+Turning to a poster, detailing the charges that had been filed against Epstein, he pointed a
+finger at a photo of the convicted sex offender who was once described as "a man of
+mystery."
+CA/Aronberg-001075
+
+
+"If you believe you are a victim of this man, Jeffrey Epstein, we want to hear from you,"
+Berman said. A special number, 1-800-CALLFBI, will, Jink victims of authorities.
+Bill Sweeney, assistant director of the FBI's New York office, said, after years of being
+ignored by federal agents, the victims' voices will be heard.
+"The Jeffrey Epstein matter is No. 1 on the major case list in the country," Sweeney said.
+Turning to address Epstein's victims directly, he said; "Your bravery may empower others to
+speak out against crimes against them."
+jmusgrave@pbpost.com
+NOT A CERTIFIED COPY
+CA/Aronberg-00.1076
+
+
+Appendix 13
+NOT A CERTIFIED COPY
+CA/Aronberg-001077
+FILED: PALM BEACH COUNTY, FL, E
+• ABRUZZO, CLERK. 3/28/2023 2:27:00 PM
+
+
+IN THE CIRCUIT COURT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+50-2019-CA-014681
+IVIL DIVISION: AG
+CA FLORIDA HOLDINGS LLC PUBLISHER
+OF THE PALM BEACH POST,
+Plaintiff/Petitioner
+-VS-
+DAVE ARONBERG,
+SHARON R. BOCK,
+Defendant/Respondents.
+XED COPY
+HEARING BEFORE THE HONORABLE KRISTA MARX
+(ZOOM CONFERENCE)
+Wednesday:
+2020
+10:08 a.m.
+-1e:28 a.m.
+NOT
+REMOTE ZOOM CONFERENCE
+Port Saint Lucie, Florida
+Stenographically Reported By:
+SONJA M.
+Court Reporter
+→ ESQUIRE
+DEPOSITION SOLUTI
+CA/Aronberg-001078
+
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+APPEARANCES :
+On behalf of the Plaințiff/Petitioner:
+GREENBERG TRAURIG,
+P.A.
+1840 Century Park East
+Los Angeles, California 90067
+310.586.7700
+boyajian@gtlaw.com
+BY: NINA D. BOYAJIAN, ESQUIRE
+On behalf of the Defendant/Respondent:
+JACOB, SCHOLZ & WYLER, LLC
+961687 Gateway Boulevard
+Suite 2011
+Fernandina Beach, Florida 32034
+COPY
+904.261.3693
+doug.wyler@comcast.net
+BY: DOUGLAS A. WYLER, ESQUIRE
+On behalf of the Defendant/Respondent:
+CLERK & COMPTROLLER,
+PALM BEACH
+COUNTY
+P.O. Box 229
+West Palm Beach,
+Florida 33401
+561.355.2983
+nfingerhut@mypalmbeachclerk.com
+BY: NICOLE R. FINGERHUT,
+ESQUIRE
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+→ ESQUIRE
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+PROCEEDINGS
+*****
+THE COURT: We are here today for a very
+limited purpose. I'm sure the attorneys are aware of
+that, but I just don't want there to be any
+confusion. We are here on Defendant Dave Aronberg
+and Defendant Sharon Bock for the Comptroller and the
+State Attorney's motion to dismiss Count II.
+You're all acutely aware as the lawyers that
+this is a question of law. So weire not going to be
+diving into facts and the Court will not be deciding
+the merits of this motion this morning. We are
+simply here for the sole purpose of that motion to
+dismiss. So I just wanted to make sure that we all
+stay on track and we're all on that same page.
+So, Ms. Boyagian, I'll send it to you first,
+\ I -- of course, we all know that the Law 101,
+: must look at the four corners of the motion, which
+alleges that the State Attorney, David Aronberg, and
+the clerk and comptroller, Sharon Bock, açtually have
+custody and control of these grand jury proceeding.
+Whether that is true or not is not for this
+court to determine because I'm looking simply at the
+four corners of the complaint. But, not for nothing,
+I think we all know that they don't have control and
+→ ESQUIRE
+OEPOSITION SOLUTIONS
+CA/Aronberg-001080
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+custody of the records. But I'm going to assume that
+it's correct because that's what has been alleged.
+So what I first want to hear from is the
+attorney for Florida Holdings with regard to,
+assuming arguendo, that Florida Statute 905.27 does
+create a cause of action, what relief is it that
+you're seeking from -- in Count II, specifically.
+Not the dec action. We're not here on that today --
+what is it you hope to get, a judgment?
+MS. BOYAGIAN: Thank you, your Honor. Good
+morning, and thank you for the privilege of appearing
+before this court.
+The relief we are seeking is disclosure of the
+grand jury records, pursuant to the Furtherance of
+Justice Exception to 905.27. And under the First
+Amendment.
+The press, as your Honor is aware, has a right
+of access under the First Amendment as a surrogate of
+the public
+THE COURT: Let me just stop you for a minute.
+Ild like you to answer my specific question.
+So I am not particularly convinced -- and I'd
+like for you to address that. So we're not going to
+dive into facts or the press's standing because
+that's not something we're here to discuss today.
+→ ESQUIRE
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+CA/Aronberg-001081
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+And I have read the voluminous paperwork --
+I've received paperwork as -- and -- five-minute ago
+from some of the other parties. But I deeply
+appreciate the fact that you sent this to me so much
+in advance and I have been able to spend some time
+with, as I said, the voluminous paperwork that
+was,
+provided.
+But as you know,
+we are here for such an
+extremely limited issue today. and that their motion
+to dismiss where they state "you're suing the wrong
+people"; that the court has these records.
+And so, more importantly, I want. you to address
+whether Section 905.27 gives you a private cause of
+action against the state attorney and the clerk.
+Again, I'm going to assume the facts are true
+that are asserted in the motion. Whether they are or
+not -- beçause I think we can all agree we're not for
+sure if they ever -- that the state attorney doesn't
+have these records. So what is it you're seeking in
+Count II -- not the dec action. I know you want the
+records.
+I've got that. But in Count II,
+specifically, what do you -- what's the relief you're
+seeking and, more importantly, how under this statute
+do you get to assert a private action -. a private
+cause of action against the state attorney and the
+→ ESQUIRE
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+clerk?
+MS. BOYAGIAN: Your Honor, we are aware, of
+course, that there is no expressed private right of
+action, 905.27. But that does not end the inquiry.
+As the Florida Supreme Court stated:
+"Where a statute like 905.27
+forbids an act which is to Plaintiff's
+injury, the party injured should have
+an action."
+And that's the
+Piezo case
+in the volume
+of materials that we sent you.
+There's no question here that the denial of the
+FIRST AMENDMENT right to the press is an injury which
+gives rise to a right of action.
+Stated another way, looking at the analysis
+that the Fischer Metcalf Court looked at, there are
+three factors in determining whether there is a
+private right of action where a statute does not
+expressly provide for one.
+One is whether the Plaintiff is part of the
+class for which the statute is intended to protect;
+second is a legislative history; and the third is the
+underlying purposes of the statutory scheme.
+The first factor I already addressed, that the
+press is part of the class that the statute is
+→ ESQUIRE
+DEPOSITION SOLUTIONS
+CA/Aronberg-001083
+
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+intended to benefit, being the surrogate of the
+public and exercising its first amendment right.
+The second issue of legislative history and the
+purpose -- statutory purpose are somewhat related.
+We were unable to find much legislative history on
+this issue of a private right of action under the
+statute.
+There is nothing that says we intend to create
+a private action, but there's certainly nothing that
+says we do not want to create a private right of
+action.
+What we do have is that in 1994, the same time
+that 905.27 was reenacted, a statute that pertains to
+the secrecy of State Grand Jury -- statewide grand
+juries was also enacted.
+That, provision, which is
+905.395, has no exceptions for -- for revealing these
+records. By contrast, the legislature intentionally
+enacted 905,27 with the Furtherance of Justice
+Exception:
+If the public through the press can't bring a
+private right of action to enforce that exception or
+to seek relief under that exception, that
+intentionally placed exception of furthering justice
+is essentially rendered hollow --
+(Speaking simultaneously.)
+→ ESQUIRE
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+CA/Aronberg-001084
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+THE COURT: Okay. Pause for a minute.
+I don't think anybody is saying that there
+isn't a cause of action or that the press doesn't
+have standing. That's not what I'm asking you.
+I'm
+asking you, how are the clerk and the state attorney
+the proper defendants?
+So, you know, nowhere have I said there isn't a
+cause of action. Clearly there is.
+I'm puzzled by
+the procedural posturing of this case naming the
+state attorney.
+And, you know, I'm further stymied by the fact
+that you allege in your complaint that they have
+particularly David Aronberg the State Attorney --
+that he has these records.
+But I'm going to assume that's true. So I'm
+not telling you, you don't have a cause of action.
+I'm just saying okay, let's run this all the way
+out. Let's say you win and you get a judgment
+against
+the State Attorney Dave Aronberg.
+What's he supposed to do with it? He çan't
+release the grand jury testimony. He has no
+authority whatsoever to do that.
+MS. BOYAGIAN: Well, your Honor, as you stated,
+this is a motion to dismiss stage, and we are
+entitled to discovery on the issue of possession,
+→ ESQUIRE
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+custody, and control.
+My understanding is that the
+state attorney has asserted that he does not have
+possession. It's not my understanding that the clerk
+has taken that position. So the clerk may indeed be
+the -- someone who does have possession, custody. and
+control.
+In any event, we would submit that the state
+attorney, even it does not have actual possession at
+this time, it might be able to have the power to
+control or direct the entity or persons who do have
+control and possession to release those -- to effect
+the judgment:
+THE COURT: So let me ask you this: So the
+clerk is the keeper of the record. But even if you
+got a judgment against her -- let's say you asserted
+this cause of action and let's say you win and you
+get a judgment against the clerk. The clerk cannot
+release grand jury testimony to you. Only the court
+can.
+So really -- all I'm saying to you is I do not
+understand the way this case was filed or why these
+are the defendants because it's impossible for them
+to perform.
+I mean, I'm going to assume, based on your
+motion, again, that they do have the records. But we
+→ ESQUIRE
+POSITION SOLUTIONS
+:
+CA/Aronberg-001086
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+all know -- everyone in the room knows they do not --
+that only the court -- they're -- they're with a
+court interpreting. And only the court can release
+the records.
+So if you get a judgment against either the
+state attorney or the clerk, they cannot -- I mean, I
+guess what you're saying to me is, well, we want to
+do discovery and we want them to say unequivocally "I
+have these records" or "I don't have them."
+And -- I mean, the law is abundantly clear.
+You cannot do it without a court determining whether,
+in the furtherance of justice, the release is
+appropriate.
+MȘ. BOYAGIAN: And that is a determination
+we're asking your Honor to make, and we're asking for
+an order from your court.
+THE COURT: When we get to the merits of the
+case, sure it, is. But, again, you're asking me to
+make that determination and for me to make a
+determination of whether the grand jury records
+should be released. And the only thing we're here
+today about is why should the clerk and the state
+attorney have to defend a civil action when it's a
+possibility of performance? They -- ever if you were
+to win and get a judgment against them, they cannot
+→ ESQUIRE
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+give you what they don't have.
+So. -- I mean, it's as simply as this: Are
+you -- you just want to engage in some discovery for
+them to absolutely assert, particularly, the state
+attorney, "I don't have these records"; look to the
+rules that say the moment the grand jury's over,
+they're sealed and they're turned over and they
+cannot be released without court order?
+So I'm not addressing the merits or whether you
+have an exception or you're able to argue that
+there's an exception in the furtherance of justice.
+We're not getting there today:
+I'm simply saying why
+should these two entities have to defend this lawsuit
+when even down the road if they win they can't give
+you what they don't have?
+MS. BOYAGIAN:
+As your Honor stated, I'm not
+sure that's the case with the clerk. That was not in
+their -- that, issue was not stated in their papers.
+THE COURT: Let me ask you this, then: Do you
+think,
+if you got a judgment and I or the court
+doesn't make the determination that the grand jury
+records should be released, that the clerk would be
+able to perform?
+Would they be able to say "here you go"? I
+mean, could the clerk just make that unilateral
+→ ESQUIRE
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+CA/Aronberg-001088
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+decișion "I'm going to release the records, sealed
+confidential records"?
+Does she have any authority to do that?
+M$. BOYAGIAN: My understanding, your Honor, is
+that 905.27 requires a court order before the records
+are unsealed.
+THE COURT: Exactly. Exactly.
+All right, Let me hear from Mr. Aronberg's
+attorney, Mr. Wyler.
+MR. WYLER: Thank you, your Honor. May it
+please the Court --
+THE COURT: Good morning, Sir.
+MR. WYLER: Good morning.
+Your Honor, I just wanted to let you know that
+I spoke with counsel for the clerk, Ms. Fingerhut, a
+couple of days before this hearing, and we decided
+that I would just make the presentation for both of
+of us, being that our arguments overlap except for
+the fact of
+who this claim -- whether they have the
+records or not, which, of course, we've said we don't
+have custody of the records.
+But, nonetheless, our arguments overlap. The
+Plaintiff is attempting to assert a cause of action
+under Section 905.27. That statute settled testimony
+not to be disclosed exceptions. So it's just
+• ESQUIRE
+POSITION SOLUTION:
+CA/Aronberg-001089
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+explaining exceptions to the disclosure of the grand
+jury testimony.
+Our position is that it doesn't set forth a
+cause of action and that it's impossible for us to
+perform what they're asking.
+I know you said you didn't really want to get
+into the Furthering Justice Exception, but I know
+that's what they're using as their basis to get to
+these. But it's our position that the clear
+unambiguous statutory language, it shows that this
+disclosure only applies to a civil or criminal case,
+and that within that civil or criminal --
+(Speaking simultaneously.)
+THE COURT: Again,
+sir -- I'm sorry. As I told
+Plaintiff's counsel
+MR. WYLER.
+can only be used in the defense
+for --
+THE COURT:
+Okay. We're not there. We're not
+discussing the merits of the case, and -- I'm not
+ready to cross that bridge. I'm here for a very,
+very limited hearing today.
+So just as I stopped Plaintiff's counsel from
+arguing the merits of the case and whether or not the
+Furtherance of Justice Exception will apply in this
+instance, we're not even there yet.
+ESQUIRE
+POSITION 501 UTION:
+:
+CA/Aronberg-00.1090
+
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+I'm only here for the purpose of determining
+whether or not the clerk and state attorney should be
+dismissed. And I am bound by the four corners of the
+document, which assert that you do have control and
+custody over it.
+So if you'll fashion your argument with
+• regard
+to that limited purpose, I would appreciate it
+MR. WYLER: No problem, your HonorA
+apologize.
+Within the four corners of their
+complaint, our
+position is that they failed to state a cause of
+action under 905.27. It does not provide for -- it
+doesn't list that there's no element that they have
+adequately pled to assert a cause of action under
+that. There's -- and the only thing they're asking
+for is records that we don't have.
+There's really not much more to it, your Honor.
+And we would ask that you would grant our motion to
+dismiss for failure to state a cause of action.
+THE COURT:
+Okay: Ms. Fingerhut, are you still
+on the phone?
+MS. FINGERHUT: Yes, your Honor.
+THE COURT: Is there anything you wish to add?
+MS. FINGERHUT: We agree with the state
+→ ESQUIRE
+iDLUTION
+CA/Aronberg-001091
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+attorney's position, and we also agree with what the
+Court has said, that the plain language of the
+statute, a cause of action doesn't exist. And we
+really cannot -- we'll be defending something without
+the four corners. We're simply involved in this
+action because the clerk is the custodian of the
+records.
+THE COURT: Okay. Thank you, Ma'am.
+Ms. Boyagian, back to you.
+MS. BOYAGIAN: Your Honor, Ild like to note
+that in the Butterworth case in which the Supreme
+Court limited the application 905.27 by saying that a
+witness can reveal her own testimony and prohibiting
+that they violate the First Amerdment --
+THE COURT: say that again, please.
+MS. BOYAGIAN: In the supreme court case, the
+Butterworth case, in which the Supreme Court ruled
+that 905.27 can't restrict a Grand Jury witness from
+revealing her own testimony, that would be a
+violation of First Amendment, in that case, the state
+attorney was, in fact, a party.
+THE COURT: Well, I assume the state attorney
+that was 'present -- I mean, I don't find that that's
+close to what we're talking about here, and that's
+whether or not -- I mean, as we know, this was in
+ESQUIRE
+DEPOSITION SOLUTIONS
+CA/Aronberg-001092
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+2006. Certainly Dave Aronberg wasn't even the state
+attorney then. But this is about the release of
+records.
+I want to give you ample opportunity -- and
+again, I sincerely appreciate that all of the case
+law and the way that it was presented to the Court in
+such a timely fashion. I really do. And I did spend
+some time with it. But I want to give you whatever
+opportunity you want to take to convince me that it
+is in -- as to Count 2, again. Not the dec action -*
+whether these would be the appropriate defendants.
+And, you know, really,
+I want you to boil it
+down for me as to this - letys take it all the way
+down the road. You win, You get a judgment against
+the clerk and the state attorney.
+I know there's other reasons why you might have
+filed it this way. But I'm just simply puzzled
+because I do hear what the clerk and the state
+attorney are saying, and that is, performance is
+impossible. They don't have the records and
+cannot -- absolutely. There's not even an inch of
+wiggle room -- that they could release the records
+even if you got a judgment. It is solely a
+determination for the court.
+I, frankly, think, you know, there's ways to
+→ ESQUIRE
+TION SOLUTIONS
+CA/Aronberg-00.1093
+
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+get to your records. There's ways to get
+confidential records. But it isn't by suing the
+state attorney and the clerk.
+So I just want to hear your last final argument
+on how Count II, the appropriate defendants are the
+clerk and the state attorney. Even assuming arguendo
+they have the records -- we know they don't
+= you
+were to get a judgment against them, how would you
+expect them to perform?
+MS. BOYAGIAN: Iwo points, your Honor: One is
+that, again, the clerk did not assert in her papers
+that she does not have control. That is a position
+that the State Attorney's Office has asserted. It is
+our allegation, änd as your Honor noted, allegations
+must be accepted as true -- as true at this stage of
+the proceedings.
+Second, it is also our understanding that the
+state attorney and the clerk intend to block access
+to these records. So our allegation is that they do
+have possession, custody, or control, which the clerk
+has not denied; and second, that they are trying to
+block access to the records --
+THE COURT: What do you mean? What do you
+mean? They're not trying to block it. They're
+saying that despite the fact -- let's just talk about
+ESQUIRE
+EPOSITION SOLUTIONS
+CA/Aronberg-00.1094
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+the clerk, because we all know the state attorney
+doesn't have it.
+So the clerk is the custodian of records.
+That's her main job. There's no doubt about it.
+We
+all know that. But we also know, unequivocally
+--
+'unequivocally, only the court can make the
+determination of whether the moving party has
+satisfied that there is an exception that these
+should be released.
+So, again, I ask you -- she is, in fact, the
+custodian of the records -- is it your opinion that
+if you got a judgment saying clerk and comptroller
+gets a judgment against them, that she can release
+the records without the court -- without the court
+weighing in, without the court making that
+determination as required by law?
+MS. BOYAGIAN: No, your Honor. We are asking
+your Honor to order the clerk to do that under your
+discretion.
+THE COURT: All right.
+Mr.
+-- Ms. Fingerhut, you wish to be heard on
+that?
+MS. FINGERHUT: Your Honor, our position is
+that we're not trying to block access to the
+records --
+→ ESQUIRE
+DEPOSITION SLUTIONS
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+(Speaking simultaneously.)
+THE COURT: Can you hear? Can the attorneys
+hear?
+MS. FINGERHUT: -- custodian the records and
+that he cannot release the records without court
+1--
+THE COURT: Exactly.
+Okay. All right. Anything further,
+Mr.
+Wyler?
+MR. WYLER: No, your Honor. I concur with the
+attorneys for the clerk's office that it's impossible
+for us to release these records.
+There's no intent
+to hide them or block anything from the Plaintiff.
+THE COURT: Okay. Anything further,
+Ms. Fingerhut?
+MŞ. FINGERHUT: No, your Honor.
+THE COURT: And,
+Ms. Boyagian, anything
+further,
+BOYAGIAN
+Nothing further, your Honor.
+THE COURT: Okay. I will get an order out
+quickly.
+Thank you, folks so much. And I'1l see you
+on the next round. Thanks a lot.
+MS. BOYAGIAN: Thank you, your Honor.
+MR. WYLER: Thank you, your Honor.
+(The proceedings concluded at 10:28
+a.m.)
+ESQUIRE
+CA/Aronberg-001096
+
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+CERTIFICATE OF REPORTER
+I, Sonja M. L
+• Court Reporter, certify that
+I was authorized to and did stenographically report the
+foregoing proceedings and that the transcript, pages 1
+through 19, is a true and complete record of
+stenographic notes.
+Dated this 3rd day
+June
+TIP|
+2020.
+15
+16
+17
+Sangine
+18
+19
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+21
+22
+NOT A
+Sonja
+Reed
+Court Reporter
+23
+24
+25
+→ ESQUIRE
+POSITION SOLUTION
+:
+CA/Aronberg-001097
\ No newline at end of file
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+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 2 of 6
+JANE DOE NO. 6
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRAJ,
+CASE NO.: 08-CV-80993-MARRAI,
+C.M.A.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80811-MARRAJ
+CASE NO.: 08-CV-80893-MARRA/
+2
+
+
+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 3 of 6
+DOE II
+CASE NO.: 09-CV-80469-MARRA/.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/.
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRAI.
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S NOTICE OF FILING WITHDRAWAL OF PREVIOUSLY RAISED
+OBJECTIONS TO DEFENDANT, JEFFREY EPSTEIN'S, MOTION TO COMPEL
+AND/OR IDENTIFY C.M.A. IN THE STYLE OF THIS CASE AND MOTION TO
+IDENTIFY C.M.A. IN THIRD-PARTY SUBPOENAS FOR PURPOSES OF
+DISCOVERY, OR, ALTERNATIVELY, MOTION TO DISMISS SUA SPONTE, WITH
+INCORPORATED MEMORANDUM OF LAW
+Plaintiff, C.M.A., by and through her undersigned attorneys, hereby files notice of
+withdrawal of previously raised objections to Defendant, JEFRREY EPSTEIN'S, Motion
+3
+
+
+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 4 of 6
+to Compel and/or Identify C.M.A. in the Style of This Case and Motion to Identify C.M.A.
+in Third-Party Subpoenas For Purposes of Discovery, or, Alternatively, Motion to
+Dismiss Sua Sponte, With Incorporated Memorandum of Law, and further states as
+follows:
+1.
+Defendant, JEFFREY EPSTEIN, filed a Motion to Compel and/or Identify
+C.M.A. in the Style of This Case and Motion to Identify C.M.A. in Third-Party Subpoenas
+For Purposes of Discovery, or, Alternatively, Motion to Dismiss Sua Sponte, With
+Incorporated Memorandum of Law (D.E. 67) on April 29, 2009.
+2.
+EPSTEIN's Motion seeks the following relief (taken verbatim from the
+conclusion of his Motion):
+a) "That C.M.A. be identified by her legal name in the style of this case;
+b) That Epstein be granted leave to identify C.M.A. by her legal name in
+Third-Party Subpoenas (but not file them in Court, or, if required, in a
+redacted form); and
+c) That on an alternative basis, this court dismiss this action Sua Sponte
+until such time as C.M.A. identifies herself in the style of this matter.
+Doe v. Rostker, 89 F.R.D at 163."
+3.
+Plaintiff withdraws her objection to a) and b) requested above. The
+request to have C.M.A.'s case dismissed is rendered moot given C.M.A.'s acquiescence
+to a) and b). To the extent that it is not, however, C.M.A. continues to object to c)
+above.
+4
+
+
+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 5 of 6
+4.
+Counsel for EPSTEIN is free to prepare a proposed agreed order
+reflecting the above for the Court's consideration following the undersigned's review of
+same.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Counsel for the movant conferred via telephone with counsel for the Defendant
+regarding the filing of the instance Notice and he has no objection to Plaintiff filing
+same.
+s/ Jack P.|
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on the 20th day of May, 2009, I electronically filed the
+foregoing with the Clerk of the Court by using CM/ECF system, which will send a notice
+of electronic filing to all counsel of record on the attached service list.
+Is/Jack P.
+Jack Scarola
+Florida Bar No.: 169440
+Jack P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+(561) 383-9424
+Attorneys for Plainti, C.M.A.
+5
+
+
+Case 9:09-cv-80469-KAM Document 18 Entered on FLSD Docket 05/20/2009 Page 6 of 6
+COUNSEL LIST
+Richard H. Willits, Esquire
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Phone:
+(561) 582-7600
+Fax:
+(561) 588-8819
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Phone:
+(561) 842-2820
+(561) 844-6929
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Phone:
+(561) 863-9100
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Phone:
+(561) 202-6360
+Fax:
+(561) 828-0983
+6
diff --git a/vision-fixhub/court-01/e88bbcee8c00776f8a90a149e961b03873955ee398f64613e20ad3fb77be4fcd.receipt.json b/vision-fixhub/court-01/e88bbcee8c00776f8a90a149e961b03873955ee398f64613e20ad3fb77be4fcd.receipt.json
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diff --git a/vision-fixhub/court-01/e89a53dba98dbda8bd7721f90f7654de5dded82ce7520abf289263c616a4cb85.md b/vision-fixhub/court-01/e89a53dba98dbda8bd7721f90f7654de5dded82ce7520abf289263c616a4cb85.md
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@@ -0,0 +1,65 @@
+Case 1:20-cv-00484-JGK-DCF Document 6-1 Filed 01/21/20 Page 1 of 1
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Case No. 1:20-cv-00484
+DECLARATION OF ROBERT
+SAMUEL GLASSMAN IN SUPPORT
+OF APPLICATION FOR
+ADMISSION PRO HAC VICE
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, California 90025
+310.477.1700 phone
+•
+310.477.1699 fax
+I, Robert Samuel Glassman, hereby declare as follows:
+1. I have never been convicted of a felony.
+2. I have never been censured, suspended, disbarred or denied admission or readmission by
+any court.
+3. There is no pending disciplinary proceedings against me in any state or federal court.
+4. I am a member in good standing of the bars of the State of California and Washington D.C.
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+Respectfully submitted,
+Dated: January 21, 2020
+Robert S. Glassman
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, CA 90025
+Telephone: (310) 477-1700
+casinie at 477.169
+tornevs for Plainti
+1
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@@ -0,0 +1,365 @@
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+petitioners,
+VS.
+JUN 1 8 2013
+STEVEN M. LARIMORE
+CLERK U. S. DIST. CT
+S. D. of FLA - WP.B.
+UNITED STATES OF AMERICA,
+respondent.
+ORDER DENYING GOVERNMENT'S MOTION TO DISMISS
+FOR LACK OF SUBJECT MATTER JURISDICTION &
+ORDER LIFTING STAY OF DISCOVERY
+THIS CAUSE is before the court on the government's motion to dismiss for lack of subject
+matter jurisdiction [DE 119], the petitioners' response in opposition [DE 127] and the government's
+reply [DE 147]. For reasons stated below, the court has determined to deny the motion.
+I. Preface
+The petitioners in this action seek to vacate a "non-prosecution agreement" ("the agreement")
+between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and
+Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C.
+§3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pending state court
+charges, solicitation of prostitution and solicitation of minors to engage in prostitution (a charge
+requiring him to register as a sex offender), in violation of Fla. Stat. §§796.07 and 796.03 and
+(2) make a binding recommendation for an eighteen-month sentence in county jail followed by
+twelve months of community control. In exchange for Epstein's performance, the USAO/SDFL
+agreed to (1) defer prosecution of related federal offenses against Epstein which had been
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 2 of 14
+investigated by the Federal Bureau of Investigation (FBI) ' in favor of prosecution by the State of
+Florida and (2) refrain from instituting criminal charges against certain alleged co-conspirators
+of Epstein. Further, the USAO/SDFL and Epstein expressed their "anticipation]" that the
+"agreement will not be made part of any public record. " Additionally, the USAO/SDFL promised
+to provide Epstein advance notice before disclosing the agreement in response to a Freedom of
+Information Act request or compulsory process commanding disclosure [DE 48-5, PP. 2-15].
+I. Factual Background
+As outlined in their CVRA petition and supplemental pleadings filed in this action,
+petitioners allege the following sequence of events, which the court assumes to be true at the motion
+to dismiss stage:?
+1. In 2006, the Federal Bureau of Investigation opened an investigation into allegations that
+Epstein had been inducing minor females to engage in commercial sexual activity over the preceding
+five year period of time. The United States Attorney's Office for the Southern District of Florida
+accepted the case for prosecution, and in June, 2007 and August, 2007, the FBI issued standard
+The agreement enumerated certain federal offenses which the FBI and the United States
+Attorney's Office determined may have been committed by Epstein between 2001 through 2007,
+including conspiracy to use and the use of facilities of interstate commerce to persuade, induce or
+entice minor females to engage in prostitution in violation of 18 U.S.C. §2422(b); conspiracy to
+travel and travel in interstate commerce for purpose of engaging in illicit sexual conduct with minor
+emales in violation of 18 U.S.C. § 2423(b); knowingly recruiting, enticing and obtaining persons
+under the age of eighteen years to engage in commercial sex acts in violation of 18 U.S.O
+§1591(a)(1).
+Tv. United States, 755 F.2d 873 (11" Cir. 1985)(in reviewing motion to dismiss for lack
+of subject matter jurisdiction under Fed. R. Civ. P. 12(b), reviewing court must assume as true all
+"factual" allegations in the complaint).
+2
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 3 of 14
+victim notification letters to the petitioners Jane Doe No. 1 and Jane Doe No. 2.
+2. On September 24, 2007, the USAO/SDFL entered into the above-described nonprosecution agreement with Epstein without first conferring with petitioners, and without alerting
+them to the existence of the agreement either before or promptly after the fact.? Petitioners claim
+they were kept in the dark about the agreement for roughly nine months - with no mention of the
+federal deal made in intervening correspondence and verbal communications between petitioners,
+the FBI and the local United States Attorney's Office.*
+3. On June 27, 2008, the Assistant United States Attorney assigned to the Epstein case
+contacted petitioners' counsel to advise that Epstein was scheduled to plead guilty to certain state
+court charges on June 30, 2008, without mentioning that the anticipated plea in the state court was
+a term of the pre-existing non-prosecution agreement with the federal authorities.
+4. On July 3, 2008, petitioners' counsel sent a letter to the USAO/SDFL advising that Jane
+'The government appears to concede the non-conferral, stating in its reply brief:
+While it may be true that the USAO-SDFL did not inform Petitioners and confer with
+them about the Non-Prosecution Agreement before it signed that agreement, the
+USAO-SDFL had conferred with both of the Petitioners about the potential
+prosecution of Epstein and was aware that Jane Doe #1 wished to see Epstein
+prosecuted and that, at that time, Jane Doe #2 had expressed open hostility toward
+[DE 147, page 31].
+4
+The post-agreement communications are alleged to include a May 30, 2008 letter from the
+3
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 4 of 14
+Doe No. I wished to see federal charges brought against Epstein.
+III. Procedural History
+5. On July 7, 2008, Jane Doe No. 1 filed an "emergency" petition under the CVRA,
+contending that Epstein was currently involved in plea negotiations with the USAO/SDFL, which
+"may likely result in a disposition of the charges in the next several days." [CVRA Petition, DE 1,
+13]. Claiming to be wrongfully excluded from those discussions, Jane Doe 1 asserted the violation
+of her CVRA rights to confer with federal prosecutors; to be treated with fairness; to receive
+timely notice of relevant court proceedings and to receive information about her right to restitution.
+As relief, she requested entry of an injunction directing the United States Attorney's Office to
+"comply with the provisions of the CVRA prior to and including any plea or other agreement with
+[Epstein] and any attendant proceedings."
+6. On July 9, 2008, the government filed its response, disclaiming application of the CVRA
+to pre-charge negotiations with prospective defendants. Alternatively, the government contended
+it did use its "best efforts" to comply with CVRA notice and conferral requirements in its dealings
+with Jane Doe 1.
+7. On July 11, 2008, the court entertained a hearing on the initial petition. During the course
+of that proceeding, the court allowed an amendment of the petition to include Jane Doe No. 2 as a
+complainant. The government acknowledged at that time that both petitioners met the definition
+of "crime victims" under the CVRA.
+4
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 5 of 14
+8. Over the course of the next eighteen months, the CVRA case stalled as petitioners
+pursued collateral civil claims against Epstein. The CVRA case was administratively closed on
+September 9, 2010, and then re-opened at petitioners' request on October 28, 2010. Since then,
+petitioners have submitted a "Motion for Finding of Violations of the CVRA" and a supporting
+statement of facts [DE 48].
+9. On September 26, 2011, the court entered its order partially granting the petitioners'
+motion for a finding of violations of the CVRA, recognizing that the CVRA can apply before
+formal charges are filed against an accused. The court deferred ruling on the merits of the motion
+pending development of a full factual record, and authorized petitioners to conduct limited
+discovery in the form of requests for production of documents and requests for admissions directed
+to the U.S. Attorney's Office, with leave for either party to request additional discovery as
+appropriate [DE 99].
+10. On November 8, 2011, the government moved to dismiss the entire CVRA proceeding
+for lack of subject matter jurisdiction [DE 119], and successfully sought a stay of discovery pending
+resolution of that motion [DE 121, 123]. In its current motion to dismiss, the government first
+contends that "even assuming that the CVRA was violated as petitioners claim, petitioners lack
+standing to seek redress for those violations" because the remedy petitioners seek- - a vacating or
+re-opening of the non-prosecution agreement - is not a legally viable option at this juncture.
+Alternatively, the government argues that petitioners' CVRA claims are not "constitutionally ripe"
+because petitioners
+have a present ability to confer with prosecutorial authorities in other
+jurisdictions, namely the United States Attorney's Offices of the District of New Jersey and New
+York, which share jurisdiction and venue over the federal offenses potentially chargeable against
+5
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 6 of 14
+Epstein for crimes committed in this District. Thus, the government asserts that it is premature and
+speculative for petitioners to bring a claim for the prospective denial of CVRA conferral rights,
+rendering their current claims constitutionally unripe. These arguments are addressed, in turn, in the
+discussion which follows.
+IV. Discussion
+"[T]he core component of standing is an essential and unchanging part of the case-orcontroversy requirement of Article III." Lujan v. Defenders of Wildlife, 504 U.S. 555, 560, 112 S.
+Ct. 2130, 119 L.Ed.2d 351 (1992). To satisfy Article III's minimum standing requirements, a
+plaintiff must generally show (1) it has suffered an injury in fact - i.e. the invasion of a legally
+protected interest that is concrete and particularized, as well as actual or imminent; (2) the injury
+is fairly traceable to the challenged action of the defendant, and (3) it is likely, as opposed to merely
+speculative, that the injury will be redressed by a favorable decision. Id. at 560-561.
+Here, the government contends petitioners are unable to satisfy the third prong of this test
+on the theory it is legally impossible for petitioners to obtain the relief which they seek - the
+vacating of the non-prosecution agreement as a predicate to the full and unfettered exercise of their
+CVRA conferral rights - and that they are therefore unable to show a likelihood that the CVRA
+injury alleged will be redressed by a favorable decision in the case. More specifically, the
+government contends that rescission of an otherwise valid plea or non-prosecution agreement (i.e.
+an agreement containing no illegal terms or conditions) is prohibited by constitutional Due Process
+guarantees - even if entered in violation of the CVRA. Alternatively, the government argues that
+even if the court could set the agreement aside and order the government to confer with petitioners
+before arriving at a final prosecutorial decision regarding Epstein, the gesture would be futile. The
+6
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 7 of 14
+government claims that the United States Attorney's Office for the Southern District of Florida
+would still be legally bound to abide by the terms of the September 24, 2007 agreement,
+eliminating the possibility that exercise of petitioners' conferral rights under the CVRA might lead
+to a different federal charging outcome.
+The court disagrees. As a threshold matter, the court finds that the CVRA is properly
+interpreted to authorize the rescission or "re-opening" of a prosecutorial agreement - including a
+non-prosecution arrangement - reached in violation of a prosecutor's conferral obligations under
+the statute. Clearly, the statute contemplates such a result where, under the "enforcement and
+limitations" provision, § 3771(d)(5), the conditions under which "[a] victim may make a motion to
+re-open a plea or sentence" in order to remedy a failure to afford a right provided under the CVRA
+are specifically prescribed. If the government's theory was correct, i.e. that no otherwise valid plea
+may be disturbed, notwithstanding a CVRA violation, as a matter of constitutional due process
+guarantees -- the statutory prescriptions for "re-opening" a plea or sentence reached in violation
+of the CVRA would effectively be nullified. The court will not embrace such a strained construction
+of the statute.
+The government acknowledges that the USAO/SDFL has been recused by the Department of
+Justice for prospective responsibility of any further criminal investigation or potential prosecution
+of Epstein relating to his alleged sexual activities with minor females in the Southern District of
+Florida, and that responsibility for any future prosecutorial action arising out of Epstein's alleged
+criminal activity in this district has now been assigned to the United States Attorney's Office for the
+Middle District of Florida [Government Motion to Dismiss, page 8, n. 8][DE 119]. However, it
+contends, without explanation, that the September 24, 2007 non-prosecution agreement would still
+constrain the Middle District of Florida United States Attorney's Office "due to that office's recusalbased derivative prosecutorial responsibilities in the Southern District of Florida" [Government
+Motion to Dismiss, page 12, n. 13][DE 119].
+7
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 8 of 14
+Although this particular statutory enforcement provision expressly refers to the re-opening
+of a "plea" or "sentence" - events falling in the post-charge stage of criminal proceedings - the court
+concludes that the statute is properly interpreted impliedly to authorize a "re-opening" or setting
+aside of pre-charge prosecutorial agreements made in derogation of the government's CVRA
+conferral obligations as well.
+First, the court concludes that the "reasonable right to confer... in the case " guaranteed by
+the CVRA at §3771(a)(5) is properly read to extend to the pre-charge stage of criminal
+investigations and proceedings, certainly where -- as here-- the relevant prosecuting authority has
+formally accepted a case for prosecution. The case law and legislative history of the statute support
+such an expansive reading of the statutory mandate. See United States v. BP Products North
+America, Inc., 2008 WL 501321 at * 11-15 (S.D. Tex. 2008)(unpub), citing 150 Cong. Rec. S2460,
+S4268 (daily ed. Apr 22, 2004)(statement of Senator Feinstein)(explaining that the right to confer
+was "intended to be expansive," applying to "any critical state or disposition of the case") and United
+States v.
+458 F. Supp. 2d 1272 (D. Utah 2006)(government motion to dismiss charge of
+using facility of interstate commerce to entice minors to engage in unlawful sexual activity would
+not be granted until government consulted with victim); United States v. Ingrassia, 2005 WL
+2875220 at *17 n. 11 (Senate Debate supports view that contemplated mechanism for victims to
+obtain information on which to base their input was conferral with prosecutor concerning any critical
+stage or disposition of the case), and United States Department of Justice, Attorney General
+Guidelines for Victim and Witness Assistance 30 (2005)("Responsible officials should make
+reasonable efforts to notify identified victims of, and consider victims' views about, prospective
+plea negotiations.")
+8
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 9 of 14
+In short, there is no logical reason to treat a "non-prosecution agreement" which the
+government employs to dispose of contemplated federal charges any differently from a "plea
+agreement" employed to dispose of charged offenses in interpreting remedies available under the
+CVRA. Where the statute expressly contemplates that a "plea" may be set aside if entered in
+violation of CVRA conferral rights, it necessarily contemplates that a "non-prosecution" agreement
+may be set aside if entered in violation of the government's conferral obligations.
+Thus, in their petition and supplemental pleadings, Jane Doe 1 and 2 have identified a
+remedy which is likely to redress the injury complained of - the setting aside of the non-prosecution
+agreement as a prelude to the full unfettered exercise of their conferral rights at a time that will
+enable the victims to exercise those rights meaningfully. See BP Products North America, supra
+at *14 ("Section 3771(c)(1) requires government officials to use best efforts to give victims notice
+of their rights under subsection (1), including the right to confer, at a time that will enable the
+victims to exercise these rights meaningfully"). Thus, petitioners do not lack constitutional standing
+because of an inability to identify a remedy for their alleged injury.
+Nor is the court persuaded by the government's "futility" argument, derived from its stated
+perception that the United States Attorney's Office for the Southern District of Florida (and
+derivatively the United States Attorney's Office for the Middle District of Florida) would be
+constrained to honor the terms of the September 24, 2007 agreement even if the court were to set it
+aside and order the government to confer with the victims before reaching a final charging decision.
+9
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 10 of 14
+The fallacy with this strand of the government's standing argument derives from its misidentification
+of the alleged injury sought to be remedied in the case: The victims' CVRA injury is not the
+government's failure to prosecute Epstein federally - an end within the sole control of the
+government. Rather, it is the government's failure to confer with the victims before disposing of
+contemplated federal charges. This injury can be redressed by setting aside the agreement and
+requiring the government to handle its disposition of the Epstein case in keeping with the mandates
+of the CVRA, including the pre-charge conferral obligations of the government.
+The court rejects the notion that a victim must show the likelihood or at least a possibility
+of a prosecution as a pre- requisite to demonstrating standing for redress of conferral rights under
+the CVRA - which is the fundamental premise of the government's futility argument. What the
+government chooses to do after a conferral with the victims is a matter outside the reach of the
+CVRA, which reserves absolute prosecutorial discretion to the government. 18 U.S.C. §3771
+(d)(6)("Nothing in this chapter shall be construed to impair the prosecutorial discretion of the
+Attorney General or any officer under his direction").
+While the law of standing does require, as a general proposition, that a federal plaintiff show
+some logical nexus between the asserted injury and the claim sought to be adjudicated (i. e. a
+likelihood that the relief sought is likely to vindicate the injury), Linda R.S. v. Richard D., 410 U.S.
+614, 93 S. Ct. 1146, 35 L.Ed. 2d 536 (1973), these requirements apply only in the absence of a
+statute expressly conferring standing. Id. at 617 n. 3 ("I] Congress may enact statutes creating leal
+rights, the invasion of which creates standing, even though no injury would exist without the
+statute"), citing Trafficante v. Metropolitan Life Ins. Co., 409 U.S. 205, 212, 93 S. Ct. 364, 368, 34
+L.Ed. 2d 415 (1972). It is apparent, through the passage of the CVRA, that Congress has enacted
+10
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 11 of 14
+a statute expressly conferring certain legal rights upon "crime victims," the invasion of which
+creates standing to seek relief under the CVRA, even though no cognizable injury would exist
+without the statute. It is also apparent that the petitioners in this case meet the definition of "crime
+victims" conferred with standing to assert the subject CVRA claims.
+The CVRA at §3771(e) defines a "crime victim" as " a person directly and proximately
+harmed as a result of the commission of a Federal offense." In the Eleventh Circuit, a two-part test
+is employed to determine whether an individual qualifies as a crime victim under this statute: First,
+the court must identify the behavior constituting the "commission of a Federal offense." Second,
+the court must identify the direct and proximate effects of that behavior on parties other than the
+United States. In re Stewart, 552 F.3d 1285 (11" Cir. 2008). If the criminal behavior causes a party
+direct and proximate harmful effect, the party is considered a victim under the CVRA. Id at 1288.
+The non-prosecution agreement at issue refers to five distinct federal sex offense crimes
+involving minors contemplated against Epstein, the direct and proximate harmful effects of which
+were allegedly visited upon the petitioners, plainly qualifying them as crime victims within the
+meaning of the CVRA. As such, they have standing to assert rights under the CVRA, as they have
+done in this case. See e.g. United States v. Thetford, _
+_F. Supp. 2d
+_, 2013 WL 1309851
+(N.D. Ala. 2013). Presented with these claims, the court is obligated to decide whether, as crime
+victims, petitioners have asserted valid reasons why the court should vacate or re-open the nonprosecution agreement reached between Epstein and the USAO/SDFL. Whether the evidentiary
+proofs will entitle them to that relief is a question properly reserved for determination upon a fully
+11
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 12 of 14
+developed evidentiary record.
+In sum, the petitioners' standing is expressly conferred by the CVRA, which limits its
+protections to "crime victims)," defined as "person[s] directly and proximately harmed as a result
+of the commission of a Federal offense ..." 18 U.S.C. §3771(e). The court finds and the government
+does not dispute that petitioners are persons "directly and proximately harmed" as the result of
+federal offenses allegedly committed by Epstein. This concludes the proper confines of the standing
+inquiry.
+6
+Recognizing the need for a developed evidentiary record, the court accordingly rejects the
+government's related "estoppel" argument as an independent attack on petitioners' constitutional
+standing to sue. In this vein, the government argues that the petitioners are legally precluded from
+seeking rescission of the non-prosecution agreement under any scenario because they had, but
+forfeited, an opportunity to press for rescission at an early stage in these CVRA proceedings--
+before Epstein performed his part of the bargain (i.e. before he served jail time on the two state
+charges). Due to petitioners' counsel's initial "indecision" on whether to seek rescission, as
+expressed at an earlier hearing held in August 2008, the government argues that "[e]ven assuming
+arguendo that the CVRA would allow a victim to seek rescission of a non- prosecution agreement
+between the government and an uncharged individual, petitioners' action would legally preclude
+them from obtaining such a remedy in these proceedings."
+Whether petitioners are estopped from seeking vindication of their CVRA conferral rights
+via the vehicle of rescission or a "re-opening" of the non-prosecution agreement due to an earlier
+litigation posture assumed in this case-- as the government contends -- implicates a fact-sensitive
+equitable defense which must be considered in the historical factual context of the entire interface
+between Epstein, the relevant prosecutorial authorities and the federal offense victims - including
+an assessment of the allegation of a deliberate conspiracy between Epstein and federal prosecutors
+to keep the victims in the dark on the pendency of negotiations between Epstein and federal
+authorities until well after the fact and presentation of the non-prosecution agreement to them as a
+fait accompli. As with threshold questions going to the existence of the alleged CVRA violations
+uestions pertaining to this equitable defense are properly left for resolution after development o
+a full evidentiary record
+12
+
+
+Case 9:08-cv-80736-KAM Document 189 Entered on FLSD Docket 06/19/2013 Page 13 of 14
+B. Ripeness
+The "ripeness doctrine," under which a plaintiff lacks standing if his claim is not ripe, aims
+to prevent the courts, through avoidance of premature adjudication, from entangling themselves in
+abstract disagreements over administrative policies. Pashby v. Delia, 709 F.3d 307 (4" Cir. 2013);
+v. Roman Catholic Diocese of Syracuse New York, Inc., 322 Fed. Appx. 852, 2009 WL
+941765 (11" Cir. 2009)(unpub).
+In this case, the government contends that the petitioners' CVRA conferral claims are not
+constitutionally ripe because petitioners do not allege they have sought and have been denied
+conferral with all federal prosecutorial authorities having potential jurisdiction over Epstein's
+federal sex crimes in the Southern District of Florida. Specifically, the government argues that the
+United States Attorney's Office of the Districts of New Jersey and New York share jurisdiction with
+the United States Attorney's Office for the Southern District of Florida over federal sex offenses
+allegedly committed by Epstein in the Southern District of Florida, and that petitioners' CVRA
+conferral claims are not ripe unless and until all other relevant prosecutorial authorities refuse or fail
+to confer with them regarding federal offenses chargeable against Epstein.
+The court summarily rejects this argument. Petitioners have alleged a violation of their
+CVRA conferral rights against a federal prosecutorial authority which formally accepted the case
+against Epstein for prosecution. Whether conferral rights do or do not exist with prosecutorial
+authorities in some other jurisdiction does not detract from the ripeness of this claim against a local
+federal prosecutorial authority which did actively investigate potential charges against Epstein in
+this district and formally resolved those charges with the challenged non-prosecution agreement at
+13
+
+
+Case 9:08-cv-80736-KAM Document 189
+Entered on FLSD Docket 06/19/2013 Page 14 of 14
+issue in this action.
+III. Conclusion
+Based on the foregoing, it is ORDERED AND ADJUDGED:
+1. The government's motion to dismiss for lack of subject matter jurisdiction [DE 119] is
+DENIED.
+2. The stay of discovery pending ruling on the government's motion to dismiss entered
+November 8, 2011 [DE# 123] is LIFTED.
+DONE AND ORDERED in
+at West Palm Beach, Florida this 18" day of June,
+2013.
+Kenneth A. Marra
+United States District Judge
+cc. All counsel
+_SEALED
+KNOT SEALED
+14
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@@ -0,0 +1,197 @@
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3,
+v.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+AFFIDAVIT OF MICHAEL J. PIKE, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+BEFORE ME, the undersigned authority, personally appeared
+Michael J. Pike, Esq., having personal knowledge and being duly sworn,
+deposes and says:
+1. I, Michael J. Pike, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida, and I
+am one of the main attorneys in charge of litigating this matter.
+2.
+I have read Plaintiff, Jane Doe, No. 3's Motion For Sanctions.
+Plaintiff's IME was set to occur on November 24, 2009 at 250
+Australian Avenue S., West Palm Beach Florida ("One Clearlake Centre").
+On that same date, Mr. Epstein had a prescheduled attorney-client
+conference/meeting with the undersigned and Robert D. Critton, Jr., Esq., at our
+offices located at 303 Banyan Boulevard, West Palm Beach, FL.
+
+
+
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 2 of 6
+5.
+On November 24, 2009, at or around 4:40 p.m., I was contacted by
+Dr. | (Defendant's IME Examiner) who stated that Plaintiff's counsel
+terminated the IME because Plaintiff and her lawyer, while on a smoking break,
+had seen Epstein exiting One Clearlake Centre through the lobby area, which
+occurred towards the end of the work day. At that time, I contacted Mr. Horowitz,
+who was not in attendance at the IME, to discuss the circumstances. I explained
+to Mr. Horowitz that Epstein's office was still located in One Clearlake Centre,
+that Epstein was leaving the building at the end of the day to meet with the
+undersigned and Robert D. Critton, Jr., Esq. for an attorney-client meeting and
+that no one from Mr. Horowitz's office had contacted the undersigned to let him
+know that Plaintiff and her lawyer had exited the building to have a cigarette or
+otherwise. I also advised Mr. Horowitz that it was improper to unilaterally cancel
+or terminate the IME.
+6. Had Plaintiff's counsel contacted the undersigned as required by
+the Order (DE 369) this alleged event could have been avoided altogether.
+The attorney-client meeting with Mr. Epstein lasted approximately 2
+hours. During that time, Mr. Epstein made no mention whatsoever of seeing
+Jane Doe No. 3 or her attorney, and Mr. Critton and I did not bring up the subject
+until the end of said meeting. At the end of the meeting, Mr. Critton and I advised
+Mr. Epstein of what Dr.
+| and Mr. Horowitz advised us of earlier that afternoon
+(i.e., that Jane Doe No.3 and her attorney had seen Epstein exit the building
+and, as a result, Plaintiff's counsel unilaterally cancelled the IME). As stated in
+his Affidavit, Mr. Epstein did not recall seeing anyone, including Jane Doe No.3
+Page - 2 -
+
+
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 3 of 6
+or her attorney when he exited One Clearlake Centre and immediately entered
+his vehicle to arrive at my office for the above meeting.
+8.
+Much effort went into the scheduling of the Plaintiffs' IMEs
+including, but not limited to, attorney and paralegal resources. Plaintiff's counsel
+should not have unilaterally terminated the IME.
+9. The costs associated with the court reporter and videographer
+currently totals $1,260.00 for Visual Evidence and $2,207.65 for Prose Court
+Reporting for a total amount of $3,467.65. See Exhibit's "A" and "B" hereto.
+Also, the undersigned should be entitled to recover his reasonable attorneys'
+fees for having to defend Plaintiff's Motion for Sanctions.
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer
+and take
+acknowledgments, personally appeared
+Michael J. Pike, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+xecuted the same, that I relied upon the following form of identification of the
+bove named person: Derboall know-
+, and that an oath was/was
+not taken.
+day of Junnary
+_ 2010.
+Page - 3 -
+
+
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 4 of 6
+JESSICA CADWELL
+MY COMMISSION # DD 853529
+EXPIRES: April 19, 2013
+Bonded Thru Notary Public Underwri
+(SEAL)
+COMMISSION NO.: 30 853529
+MY COMMISSION EXPIRES: 04/19/2013
+Page - 4 -
+
+
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 5 of 6
+VISUAL
+EVIDENCE
+P.O. Box 6967
+West Palm Beach, FL 33405
+Invoice
+Date
+Number
+12/8/2009
+29091
+Terms
+Due on receipt
+BURMAN, CRITTON & LUTTIER
+ROBERT CRITTON
+303 BANYAN BLVD
+SUITE 400
+WEST PALM BEACH, FL 33401
+Case / Reference:
+Services Rendered
+Date
+11/23/2009 | VIDEOTAPED EXAMINATION OF: JANE DOE #6
+Tech Time - 1ST 2 Hours
+Additional Tech Time
+Digital Tape
+Digital Video encoded to Mpeg2 format: per hour per original video source
+11/24/2009 VIDEOTAPED EXAMINATION OF: JANE DOE#2
+Tech Time - 1ST 2 Hours
+Additional Tech Time
+Digital Tape I
+Digital Video encoded to Mpeg2 format: per hour per original video source
+11/30/2009 Delivery
+JANE DOE #2 VS EPSTEIN
+ety
+Amount
+275.00
+800.00
+60.00
+400.00
+4
+6.5
+275.00
+600.00
+60.00
+325.00
+ONE CALL SERVICE FOR VIDEOCONFERENCING. We make all
+other arrangements for you.
+TOTAL:
+$2,795.00
+Remit to:
+P.O. Box 6967
+West Palm Beach, FL 33405
+Tax ID # 59-2476529
+Fax: (561) 655-2896 office@visualevidence.org
+Phone: (561) 655-2855
+"A"
+
+
+Case 9:08-cv-80119-KAM Document 450-2 Entered on FLSD Docket 01/13/2010 Page 6 of 6
+Prose Court Reporting Agency, Inc
+One Clearlake Centre
+250 South Australian Avenue, Suite 1500
+West Palm Beach, Florida 33401
+(561) 832-7500 Phone (561) 832-7506 Fax
+Tax ID: 26-3892897
+www.prosecra.com
+November 30, 2009
+Robert Critton, Esquire
+Burman, Critton, Luttier & Coleman - WPB
+303 Banyan Boulevard
+Suite 400
+West Palm Beach, FL 33401
+Invoice Number
+CH 772
+Re: Jane Doe Il vs. Jeffrey Epstein, et al.
+11-24-09 CME of Jane Doe No. 3
+Description of Services
+CME App - 1st Hr
+CME App - Addl Hr
+Other Tran CC - Exp 3
+E-Transcript Emailed
+ETran, Mini, Exbs Pkg
+S & H - Local
+Appearance 1st Hr
+Appearance Add'l 6.5 Hrs
+Transcript Pages - 195
+Complimentary
+Total:
+Paid:
+Invoice total:
+150.00
+585.00
+1456.65
+10.00
+6.00
+$2,207.65
+-2,207.65
+$0.00
+Thank you for choosing Prose Court Reporting Agency, Inc. Payment is due upon receipt.
+"B"
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diff --git a/vision-fixhub/court-01/e8cb0c1edefd1fdce23fd05a274654848c9642e7578a36faa2b4437da8d04228.md b/vision-fixhub/court-01/e8cb0c1edefd1fdce23fd05a274654848c9642e7578a36faa2b4437da8d04228.md
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@@ -0,0 +1,543 @@
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+CASE NO: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 2 of 16
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+2
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 3 of 16
+CASE NO: 08-CV-80811-MARRA/
+C.M.A.,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/_
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/
+Plaintiff
+VS.
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 4 of 16
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST
+REQUEST FOR PRODUCTION
+Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant,
+Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove
+that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests
+production of a privilege log.
+Jane Doe has propounded 16 requests for production, including such
+straightforward requests as requests for production of:
+4
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 5 of 16
+Request No. 1: Copies of all telephone records;
+Request No. 2: Photos of the inside of your home located at 358 El Brillo Way,
+Palm Beach, Florida, that depict the rooms) where massages took place (including
+massage table).
+Request No. 10: Correspondence between Epstein and federal prosecutors;
+Request No. 12: Personal tax returns;
+Request No. 13: Photocopies of Epstein's passport;
+Request No. 14: A statement of net worth; and
+Request No. 16: Medical records.
+In response to each and every one of these requests, Epstein has given the
+following response (with only minor variations here and there):
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+This Court should order Epstein to provide all of the requested information or, in
+the alternative, prove that his Fifth Amendment invocations are valid. It is for the court,
+not the claimant, to determine whether the hazard of incrimination is justified. United
+States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a
+particularized inquiry, deciding, in connection with each specific area that the
+5
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 6 of 16
+questioning party wishes to explore, whether or not the privilege is well-founded." Id.
+Typically this is done in an in camera proceeding wherein the person asserting the
+privilege is given the opportunity "to substantiate his claims of the privilege and the
+district court is able to consider the questions asked and the documents requested by
+the summons." Id.
+Here Epstein has made boilerplate invocation of the Fifth Amendment to each
+and every request propounded by Jane Doe, including for example the request for
+correspondence with federal prosecutors and for production of federal tax returns. This
+obviously is not a request with Fifth Amendment implications, as the information has
+already been fully disclosed to the Government.
+For all these reasons, the Court should compel Epstein to answer the requests or
+provide a particularized justification for his Fifth Amendment invocation with regard to
+each request.
+Epstein's "cut and paste" response to the request for production also blatantly
+disregards the requirements for invoking privilege under the Court's local rules. Local
+rule 26.1.G very specifically requires the preparation of a privilege log with respect to all
+documents and oral communications (among other things) that are withheld on the
+basis of privilege. Epstein has failed to prepare such a log, making it impossible for
+Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few
+requests, Epstein has stated: "Further, the request may include information subject to
+work product or an attorney-client privilege." Of course, the whole purpose of forcing a
+defendant to prepare a privilege log is to force the defendant to decide whether or not
+6
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 7 of 16
+information is privileged. An assertion that something "may" be privileged is obviously
+woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a
+minimum) promptly required to produce a privilege log.
+For all these reasons, the Court should compel Epstein to provide a privilege log
+and to answer the interrogatories or provide a particularized justification for his Fifth
+Amendment invocation with regard to each request.
+It should be noted that (with minor exceptions) the only grounds on which Epstein
+can refuse to answer the request for production is proof of a valid Fifth Amendment
+privilege. This the only objection Epstein has asserted (with minor exceptions). As a
+result, any other objections to production are deemed waived. See Local Rule
+26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within the time
+provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be
+waived.").
+SPECIFIC REQUESTS FOR PRODUCTION
+For the convenience of the court - and in compliance with Local Rule 26.1 H
+(party filing motion to compel shall list specific requests in succession) - Jane Doe's
+requests for production and Epstein's objections are as follows:
+Request No. 1: Copies of all telephone records in your or your attorney's possession
+from 2002 through 2005 that in any way relate to you (including all phone lines owned
+by you or that were used to contact girls for the purposes of scheduling massages for
+you.)
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+7
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 8 of 16
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 2: All massage appointment books, diaries, computer calendars or
+scheduling entities, scheduling books or any other writing or correspondence that
+contains the names of any of the girls that were called, contacted, scheduled or who
+otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the
+purpose of giving you a massage.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 3: Any and all documentation in your possession that contains Plaintiff's
+name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message
+pads, diaries, appointment books, computer print outs).
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Filth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 4: Any and all photos, videos, downloaded digital prints or any other visual
+depiction of Plaintiff, or of any other known or suspected minor females introduced to
+you, directly or indirectly, by Plaintiff.
+8
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 9 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm
+Beach, Florida, that depict the rooms) where the massages too place (including
+massage table).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 6: Any and all documentation of cancelled checks or evidence of payment
+to Plaintiff of any kind and for any reason whatsoever.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+9
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 10 of 16
+Request No. 7: All discovery information obtained by you or your attorneys as a result
+of the exchange of discovery in the State criminal case against you or the Federal
+investigation against you.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse
+inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible to the terms of the deferred prosecution agreement, Federal
+Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.'
+Further, the
+request may including information subject to work product or an attorneyclient privilege.
+Request No. 8: All financial documents evidencing asset transfers from 2005 to present
+for you personally or any company or corporation owned by you.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+"Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this
+10
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 11 of 16
+Request No. 9: Any documents or other evidentiary materials provided to local, state,
+or federal law enforcement investigators or local, state or federal prosecutors
+investigating your sexual activities with minors.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 2
+Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 10: All correspondence between you and your attorneys and state or
+federal law enforcement or prosecutors (includes, but not limited to, letters to and from
+the States Attorney's office or any agents thereof).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing
+an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information
+sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+7 act of Diea discussins, nd to the horse me protes here materials are cooler a re
+fact of plea discussions, but rather for other purposes.
+discovery of other admissible evidence.
+To the extent that Epstein relies on the non-prosecution
+agreement, nothing in that agreement bars discovery of information relevant to this lawsuit.
+11
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 12 of 16
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 11: Any and all documents reflecting your current net worth.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 12: Personal tax returns for all years from 2002 through the present.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 13: A photocopy of your passport, including any supplemental pages
+reflecting travel to locations outside the 50 United States between 2002 and 2008,
+including any documents or records regarding plane tickets, hotel receipts, or
+transportation arrangements.
+" Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of correspondence in connection with plea discussions, but rather for other purposes. These
+naterials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein
+relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant
+to this lawsuit.
+12
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 13 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, 1 assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution. In addition to and without waiving his constitutional
+protections and privileges, the scope of information is so overbroad that it
+seeks information that is neither relevant nor reasonably calculated to lead
+to the discovery of admissible evidence; compiling such information over a
+six year period would be unduly burdensome and time consuming.4
+Request No. 14: A sworn statement of your net worth (including a detailed financial
+statement depicting all current assets and liabilities).
+Defendant is asserting his U.S. constitutional privileges. I intend to respond to all
+relevant questions regarding this lawsuit, however, my attorneys have counseled me
+that at the present time I cannot select authenticate, and produce documents relevant to
+this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution.
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution.
+Request No. 15: All financial statements or affidavits produced by you for any reason,
+to any person, company, entity or corporation since 2005.
+Defendant is asserting his U.S. constitutional privileges. 1 intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+* Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual
+purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is
+hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent
+or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from
+such intermediaries.
+13
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 14 of 16
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+CONCLUSION
+For all these reasons, the Court should compel Epstein to answer the request for
+production, or provide a particularized justification for his Fifth Amendment invocation
+with regard to each request. Epstein should also be required to provide a privilege log.
+Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this
+motion, and no resolution was possible.
+DATED July 10, 2009
+Respectfully Submitted,
+J.l
+J.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 54207:
+E-mail: bedwards@rra-law.com
+14
+
+
+Case 9:08-cv-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 15 of 16
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 10, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+S/
+J.
+J.
+15
+
+
+Case 9:08-cV-80381-KAM Document 121 Entered on FLSD Docket 07/10/2009 Page 16 of 16
+SERVICE LIST
+Jane Doe v. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+16
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e8cb0c1edefd1fdce23fd05a274654848c9642e7578a36faa2b4437da8d04228.receipt.json b/vision-fixhub/court-01/e8cb0c1edefd1fdce23fd05a274654848c9642e7578a36faa2b4437da8d04228.receipt.json
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-01/e8cc76f47cc6222f12465fc357cf3b53aa95d808d35c6c7d965aecbfcdcc9a74.md b/vision-fixhub/court-01/e8cc76f47cc6222f12465fc357cf3b53aa95d808d35c6c7d965aecbfcdcc9a74.md
new file mode 100644
index 0000000000000000000000000000000000000000..cfccdb22afe152b49ba06931d1c60410807a16d0
--- /dev/null
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@@ -0,0 +1,120 @@
+Case 9:08-cv-80380-KAM Document 105 Entered on FLSD Docket 05/14/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+
+
+Case 9:08-cv-80380-KAM Document 105 Entered on FLSD Docket 05/14/2009 Page 2 of 5
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/_
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:08-cv-80380-KAM Document 105 Entered on FLSD Docket 05/14/2009 Page 3 of 5
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA
+Plaintift,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09- 80656-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+ORDER CONSOLIDATING CASES FOR PURPOSES OF DISCOVERY AND
+PROCEDURAL MOTIONS THAT RELATE TO MULTIPLE CASES
+THIS CAUSE is before the Court sua sponte.
+In the interests of judicial economy and
+3
+
+
+Case 9:08-cv-80380-KAM Document 105 Entered on FLSD Docket 05/14/2009 Page 4 of 5
+efficiency, it is hereby ORDERED AND ADJUDGED as follows:
+1. The above-styled cases are hereby CONSOLIDATED for purposes of discovery and
+for procedural motions that relate to multiple cases.
+2. Hereinafter, all motions and other court filings that relate to discovery and all
+procedural motions that relate to multiple cases shall be styled with all of the case names and
+numbers, consistent with the styling of this Order, and shall be FILED ONLY IN Jane Doe No.
+2 v. Epstein, case no. 08-80119, which is the lowest-numbered pending case. Any motions styled
+incorrectly or filed in multiple cases will be stricken from the docket for failure to follow the
+Court's Order.
+3. The parties may file separate motions to dismiss, answers to the complaint, summary
+judgment motions, motions in limine and other substantive motions that pertain to their
+individual cases and their individual trials under their individual case styles.
+4. Production of documents by any party or non-party that relate to multiple cases need
+be produced only once.
+5. Defendant is limited to a single deposition of each Plaintiff, during which Defendant
+may depose the Plaintiff as both a party and a witness.
+6. Defendant(s) may be deposed only once.
+7. Any other witnesses common to multiple cases may be deposed only once.
+8. For depositions, Local Rule 26.1 K (limiting deposition time to one day of seven
+hours) is waived so as to allow each party an adequate opportunity to develop fully the record as
+it may relate to that party. However, this waiver shall not be construed as authority for any party
+to take unnecessarily long depositions, or abuse the process. Any abuses of this waiver
+4
+
+
+Case 9:08-cv-80380-KAM Document 105 Entered on FLSD Docket 05/14/2009 Page 5 of 5
+shall result in the imposition of appropriate sanctions against the offending party.
+DONE AND ORDERED in
+Florida, this 14" day of May, 2009
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+Magistrate Judge Linnea R.
+5
diff --git a/vision-fixhub/court-01/e8cc76f47cc6222f12465fc357cf3b53aa95d808d35c6c7d965aecbfcdcc9a74.receipt.json b/vision-fixhub/court-01/e8cc76f47cc6222f12465fc357cf3b53aa95d808d35c6c7d965aecbfcdcc9a74.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8e3aefa1c759d9a3505b6a43843e8c89abd62b4f7225ef28089602c176babb15",
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diff --git a/vision-fixhub/court-01/e8ce51e4e8baad53a67408e03cbdc0cfbf5b57a159ecf24b125672759804135e.md b/vision-fixhub/court-01/e8ce51e4e8baad53a67408e03cbdc0cfbf5b57a159ecf24b125672759804135e.md
new file mode 100644
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@@ -0,0 +1,64 @@
+Case 1:20-cv-00484-JGK-DCF Document 7-1 Filed 01/21/20 Page 1 of 1
+1
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+JANE DOE,
+Plaintiff,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+Case No. 1:20-cv-00484
+DECLARATION OF KEVIN R.
+BOYLE IN SUPPORT OF
+APPLICATION FOR ADMISSION
+PRO HAC VICE
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, California 90025
+I, Kevin R. Boyle, hereby declare as follows:
+1. I have never been convicted of a felony.
+2. I have never been censured, suspended, disbarred or denied admission or readmission
+by any court.
+3. There is no pending disciplinary proceedings against me in any state or federal court.
+4. I am a member in good standing of the bars of the State of California and Washington D.C.
+18 I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+Respectfully submitted,
+Dated: _January 21, 2020
+28
+Kevin Boyle
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, CA 90025
+Telephone: (310) 477-1700
+Facsimile: (310) 477-1699
+boyle@psblaw.com
+Attorneys for Plaintiff
+1
diff --git a/vision-fixhub/court-01/e8ce51e4e8baad53a67408e03cbdc0cfbf5b57a159ecf24b125672759804135e.receipt.json b/vision-fixhub/court-01/e8ce51e4e8baad53a67408e03cbdc0cfbf5b57a159ecf24b125672759804135e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..22c1b4b96c034a22d0551570f5fb59cc2f03dff0
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+}
diff --git a/vision-fixhub/court-01/e8d21abddf8bfeb4add6bf65daa922cf10d29064fd06b32f9ed424414a99fb42.md b/vision-fixhub/court-01/e8d21abddf8bfeb4add6bf65daa922cf10d29064fd06b32f9ed424414a99fb42.md
new file mode 100644
index 0000000000000000000000000000000000000000..356c033eb176cf4d6158c6918738448e8e512ccc
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@@ -0,0 +1,202 @@
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAJ
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+1
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 2 of 7
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRAI
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRAJ
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA/
+2
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 3 of 7
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA1
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+PLAINTIFFS JANE DOES' 2- 7 NOTICE OF JOINDER IN PLAINTIFFS'
+JANE DOES 101 AND 102'S MOTION FOR NO-CONTACT ORDER
+Plaintiffs Jane Does 2-7 join in Plaintiffs Jane Does 101 and 102's Motion for No-
+Contact Order, filed May 22, 2009, and state as follows:
+Plaintiffs Jane Does 2-7 incorporate and adopt the facts set forth in the pending
+Motion for No-Contact Order. Additionally, Plaintiffs offer additional facts in support of the
+Motion for a No-Contact Order, as set forth below.
+2.
+Upon information and belief, Plaintiffs Jane Does 2-7 were all identified on the
+victims list provided to Defendant Epstein's counsel in connection with the Non-prosecution
+Agreement, and each has been identified as victims to Defendant Epstein in their pending
+3
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 4 of 7
+actions. In June 2008, Palm Beach Circuit Court Judge Pucillo ordered Defendant Epstein "not
+to have any contact, direct or indirect," with any of his victims. Judge Pucillo clarified that
+forbidden "indirect" contact included, but was not limited to, text messages, emails, telephone
+calls, or messages through third parties. As detailed herein, Jane Does 4 and 7 have been
+contacted on multiple occasions by at least one person representing that she is cooperating with
+and communicating on behalf of Defendant Epstein. In these contacts, the Plaintiffs/victims
+were threatened and harassed.
+3.
+As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant
+Epstein by Hayley
+, who was a high school friend.'
+4.
+had had contact with these Plaintiffs on several occasions in which she
+represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defendant Epstein's
+attorneys and that she is being financially supported by Defendant Epstein. Moreover,
+has told these Plaintiffs specifically that she is communicating on behalf of Defendant Epstein.
+5.
+During these contacts,
+made disparaging comments to the Plaintiffs and
+also sent disturbing text messages to Jane Doe No. 4. In one text,
+specifically stated, "I
+just met with my lawyer today and I'm finally done with the Epstein case. LOL. I knew you were
+suing Jeffrey all along and I've learned so much about you in the meantime. LOL." Jane Doe 4
+understood this to mean that
+had exchanged private information about Jane Doe 4 with
+Defendant Epstein and his attorneys. Since February, 2009, Jane Doe 4 has continued to receive
+text messages from
+that are sometimes harassing and other times seek information about
+Jane Doe 4's private life, her lawsuit against Defendant Epstein, and/or her lawyer's strategy.
+was named in at least one civil case against Mr. Epstein as a co-defendant. See
+Jane Doe v. Epstein, case no. 50-2008-CA-0065996, Palm Beach County Circuit Court.
+brought multiple underage girls to Epstein in addition to Jane Does 4 and 7.
+4
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 5 of 7
+6.
+On one occasion,
+approached Jane Doe 7 and disclosed that she was
+cooperating with Defendant Epstein's defense, and that she (
+agreed that she would
+testify against Jane Doe 7 and the other plaintiffs to make sure that none of the Plaintiffs ever
+received any money from Defendant Epstein, making clear that her testimony would not be
+truthful to achieve this end. She also made disparaging comments to Jane Doe 7, accusing her of
+ruining Defendant Epstein's reputation.
+7.
+The very possibility of any contact with Epstein or his agents, including |
+causes anxiety and distress particularly to Jane Doe 4 and 7, as well as the other Plaintiffs. A nocontact order should prevent further harassment of the Plaintiffs by Epstein and his agents,
+including, but not limited to, Hayley
+WHEREFORE, Plaintiffs Jane Does 2-7, respectfully join Plaintiffs Jane Does 101 and
+102 in moving this Court to enter an order granting Plaintiffs' Motion for a No Contact Order
+prohibiting the Defendant, Jeffrey Epstein, from any contact or communication with Plaintiffs,
+either directly or indirectly, except through Plaintiffs' attorneys of record for the duration of the
+Order.
+Dated: June 8, 2009
+Respectfully submitted,
+By:_
+_s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+5
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 6 of 7
+CERTIFICATE OF SERVICE
+THEREBY CERTIFY that on June 8, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Adam D. Horowitz
+6
+
+
+Case 9:08-cv-80119-KAM Document 145 Entered on FLSD Docket 06/08/2009 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Adam D. Horowitz
+7
diff --git a/vision-fixhub/court-01/e8d21abddf8bfeb4add6bf65daa922cf10d29064fd06b32f9ed424414a99fb42.receipt.json b/vision-fixhub/court-01/e8d21abddf8bfeb4add6bf65daa922cf10d29064fd06b32f9ed424414a99fb42.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e1a6b86be1b865efb279709cf560183c310e8220
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+++ b/vision-fixhub/court-01/e8d21abddf8bfeb4add6bf65daa922cf10d29064fd06b32f9ed424414a99fb42.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "7aed1b10a578071e52d8beed0470f6802a97e371ce03cb0add516863348e87ac",
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+}
diff --git a/vision-fixhub/court-01/e8d3b8d40a9e894d51afa883c67b89577302351cff66e1ab64c56524bf5c3311.md b/vision-fixhub/court-01/e8d3b8d40a9e894d51afa883c67b89577302351cff66e1ab64c56524bf5c3311.md
new file mode 100644
index 0000000000000000000000000000000000000000..474cda9a5c5dd945600bf9af4e39a9e4dce8fb76
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@@ -0,0 +1,207 @@
+Case 9:08-cv-80119-KAM Document 277 Entered on FLSD Docket 08/20/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant's Motion To Strike Declarations Attached And Cited In Plaintiffs'
+Reply In Support Of Their Motion For Protective Order (DE 266), And
+Incorporated Memorandum Of Law
+Defendant, Jeffrey Epstein (hereinafter "Epstein" or Defendant), by and
+through his undersigned attorneys, respectfully moves this Court for an order
+Striking The Declarations attached to and cited in Plaintiffs' Reply in Support of
+their Motion for Protective Order (DE 266). Local Rule 12 allows for this court to
+strike same. As good cause in support of granting the motion, Defendant states:
+1. On July 29, 2009, Plaintiffs filed their Motion for Protective Order seeking
+to prevent any investigation of the Plaintiffs and/or the claims they assert against
+Jeffrey Epstein in their respective Complaints.(DE 226) Plaintiffs Motion for
+Protective Order attached the Affidavits of Dr. Kliman - Ex. "A," the Declaration of
+Jane Doe 4 - Ex. "B," and the Declaration of Jane Doe 6 - Ex. "C".
+
+
+Case 9:08-cv-80119-KAM Document 277 Entered on FLSD Docket 08/20/2009 Page 2 of 5
+2. On August 11, 2009, Defendant filed his Response In Opposition to the
+above Motion for Protective Order. (DE 262)
+3. On August 14, 2009, Plaintiffs filed their Reply Memorandum in Support of
+Motion for Protective Order (DE 266), and attached and cited newly filed
+declarations for which Defendant does not have an opportunity to respond to
+under the rules. Therefore, the declarations delineated below are outside the
+scope of Plaintiffs' initial Motion for Protective Order and the Defendants'
+Response in Opposition. Moreover, the declarations are untimely.
+4. In particular, Plaintiffs attach to or cite in their Reply the declaration of
+Jane Doe 4 (dated August 14, 2009 - a newly filed declaration - DE 267-2), the
+declaration of Jane Doe 6 (a declaration not attached to the Reply or linked to
+any other motion by docket entry citation), the declaration of Jane Doe 7 (a
+declaration not attached to the Reply and referenced as a new August 14, 2009
+declaration) and the declaration of Jane Doe 4's sister (Y.B.'s newly filed
+declaration dated August 18, 2009 - DE 267-3).
+5. Based upon the foregoing, the Defendant does not have an opportunity to
+respond to the newly filed declarations or those declarations cited in the Reply
+but not attached or linked to any other motion. To the extent Plaintiffs" intention
+was to link the missing declarations to another motion, response or reply
+previously filed by Plaintiffs, same has not been specified in their Reply.
+6. Note, Defendant is not moving to strike the declaration of Jane Doe 4
+dated July 17, 2009 because that declaration is attached to Plaintiffs' initial
+motion.
+
+
+Case 9:08-cv-80119-KAM Document 277 Entered on FLSD Docket 08/20/2009 Page 3 of 5
+Memorandum of Law
+7. Ivory v. Holme, 2009 WL 513720 (M.D. Fla. 2009)(striking affidavits as
+untimely).
+Wherefore, Defendant respectfully requests that this court enter an order:
+a.
+b.
+c.
+d.
+e.
+f.
+striking the declaration of Jane Doe 4 (dated August 14, 2009 - a
+newly filed declaration - DE 267-2);
+striking the declaration of Jane Doe 6 (a declaration not attached to the
+Reply or linked to any other motion by docket entry citation);
+striking the declaration of Jane Doe 7 (a declaration not attached to the
+Reply and referenced as a new August 14, 2009 declaration);
+the declaration of Jane Doe 4's sister (Y.B.'s newly filed declaration
+dated August 18, 2009 - DE 267-3); or, alternatively;
+require Plaintiffs to file the missing declarations and allow Defendant
+10 days within which to file a Supplemental Brief addressing same;
+for such other and further relief as this court deems just and proper.
+By:
+ell
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically
+filed with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+Respectfully submitted,
+By:
+
+
+Case 9:08-cv-80119-KAM Document 277 Entered on FLSD Docket 08/20/2009 Page 4 of 5
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+I. Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case
+No. 08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-
+80119, 08-80232, 08-80380, 08-80381, Paul G. Cassell, Esq.
+08-80993, 08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10t Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+1. Esq.
+Counsel for Plaintiff in Related Case No.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+
+
+Case 9:08-cv-80119-KAM Document 277 Entered on FLSD Docket 08/20/2009 Page 5 of 5
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P. L| Esq.
+Counsel for Plaintiff in Related Case
+Searcy Denney Scarola Barnhart & No. 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+Jack Alan Goldberger, Esq.
+West Palm Beach, FL 33401
+Atterbury Goldberger & Weiss, P.A.
+561-202-6360
+250 Australian Avenue South
+Fax: 561-828-0983
+Suite 1400
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+jagesg@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
diff --git a/vision-fixhub/court-01/e8d3b8d40a9e894d51afa883c67b89577302351cff66e1ab64c56524bf5c3311.receipt.json b/vision-fixhub/court-01/e8d3b8d40a9e894d51afa883c67b89577302351cff66e1ab64c56524bf5c3311.receipt.json
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/e8d961254371cfae9bddfae515f07060248e853d7ffe5bc97845e279bb3a49d3.md b/vision-fixhub/court-01/e8d961254371cfae9bddfae515f07060248e853d7ffe5bc97845e279bb3a49d3.md
new file mode 100644
index 0000000000000000000000000000000000000000..f295634aeda58a28e69cd69506568bb17a7addb1
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@@ -0,0 +1,215 @@
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-cv-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/L
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/T
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 2 of 6
+CASE NO.: 08-CV-80381-MARRAL
+JANE DOE NO. 5,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+/
+CASE NO.: 08-80994-CIV-MARRAL|
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80993-CIV-MARRAJT I
+JANE DOE NO. 7,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+J
+
+
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 3 of 6
+JANE DOE,
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRACI
+/
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 09-80591-CIV-MARRA-
+JANE DOE NO. 102,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-80656-CIV-MARRA/L
+DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
+OF TIME IN WHICH TO REPLY TO PLAINTIFES JANE DOES 2-7
+RESPONSE TO DEFENDANT'S MOTION TO COMPEL IDENTITY
+IN THE STYLE OF THE CASE AND IN THIRD PARTY SUBPOENAS (DE 144)
+
+
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 4 of 6
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves
+this Court for an extension of time until August 5, 2009, to file a Reply to Plaintiffs Jane
+Does 2-7 Response to Defendant's Motion to Compel Identity in the Style of the Case
+and in Third Party Subpoenas, pursuant to Local Rule 7.1 A.1(i) (S.D. Fla. 2008). As
+good cause for the requested extension, Defendant states:
+1. Counsel for Defendant communicated with Counsel for the Plaintiff, and
+Plaintiff's Counsel agrees to the requested extension of August 5, 2009, to file a Reply to
+Reply to Plaintiffs Jane Does 2-7 Response to Defendant's Motion to Compel Identity in
+the Style of the Case and Third Party Subpoenas.
+Rule 7.1 A. 3. Certification of Pre-Filing Conference
+Counsel for Defendant conferred with Counsel for Plaintiff's counsel, by
+telephone, and Counsel for Plaintiff is in agreement with the requested extension.
+
+
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 5 of 6
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S.
+Mail and facsimile to the following addressees this 31°' day of July, 2009.
+Stuart S. Mermelstein, Esq.
+Brad
+1, Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+horowitz@sexabuseattorney.con
+08-80893
+'ounsel for Plaintiff
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Isidro M. WHIL. Esq.
+|| Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P. , Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+isx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+
+
+Case 9:08-cv-80119-KAM Document 235 Entered on FLSD Docket 07/31/2009 Page 6 of 6
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submited,
+BOBERT D. CRITTON, JR., ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+Fax: 561-515-3148
+(Co-counsel for Defendant Jeffrey Epstein)
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diff --git a/vision-fixhub/court-01/e8eb58def43c4dc6fea7a84b32235a4abca3af95e5a999089b88cd7a129532d3.md b/vision-fixhub/court-01/e8eb58def43c4dc6fea7a84b32235a4abca3af95e5a999089b88cd7a129532d3.md
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@@ -0,0 +1,18 @@
+Case 9:08-cv-80232-KAM Document 126-3 l
+Entered on FLSD Docket 07/29/2009 Page 1 of 1
+DECLARATION OF JANE DOE NO. 6
+state as follows:
+I am the Plaintiff identified as Jane Doe No. 6 in this lawsuit.
+2.
+On July 9, 2009, an investigator came to the office of my former employer, A
+Affordable Auto Insurance, in Lake Worth, Florida.
+After the investigator left, I was contacted by my former employer and told that
+the investigator was asking personal questions about me.
+I am worried that Jeffrey Epstein will continue to send investigators to speak with
+other people I know who do not know that I am a Plaintiff in this lawsuit. I am concerned that
+the investigators will ask these people very personal questions about my life and disclose that I
+am a Plaintiff in a sexual abuse lawsuit against Jeffrey Epstein.
+I declare under penalty of perjury the foregoing to be true and correct.
+Dated this 22 day of July
+→ 2009
+mika line Doc Nigo
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@@ -0,0 +1,254 @@
+Case 9:08-cv-80119-KAM Document 308-9
+Entered on FLSD Docket 09/17/2009 Page 1 of 10
+Entered on FLSD D87R8708/85/2009 Pager of 10
+Jane Doe #6
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.
+M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+c.W. I M.D., who, being by me first duly sworn under oath deposes and says:
+1.
+My name is Richard CW.
+, M.D. Iam over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 1996.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns
+University and
+1
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 2 of 10
+Aug Cast 94886V-801RRHAM. H@paament 247-7 Entered on FLSD 507R87 98995/2009 Page 2 of 10
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+1, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+10.
+Lat the University of Tennessee College of Medicine, Memphis.
+The amended complaint filed by Jane Doe #6 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 3 of 10
+Aug Gase BiQ.BefV-801 KREANC. Hapnent 247-7 Entered on FLSD B8ZR8768995/2009 Page 3 of 10
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #6 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer,
+severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12.
+She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #6.
+14. Plaintiff's interrogatories note a diagnosis of PTSD following an auto accident
+in 2003. (Pre-Epstein) (Page 5, Plaintiff's Answers to Defendant's First Interrogatories)
+15. Plaintiff noted "nervous about driving here. Hit by a semi June 2003.I wasn't
+hurt but Mom was." (Page 1, GK Contemp notes, Interview Part 1)
+16. "Seroquel ... for bad dreams after the car accident... longest therapy six
+months court ordered. I am on probation for stupid stuff I did 2-3 years ago... really
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 4 of 10
+Aug 0a509048$v-801 18cKaAM. Hamament 247-7 Entered on FLSD D0748208485/2009 Page 4 of 10
+dumb, I got in trouble, arrested." (Page 2, GK Contemp notes)
+17.
+A Petition for Involuntary Assessment for Substance Abuse, dated July 19,
+2006, noted a domestic disturbance at plaintiff's home with "threats to several family
+members as well as threats of suicide... appeared to be under the influence of Zanax [sic]
+bars... She found her grandmother dead three weeks ago, may have pushed her over the
+edge." (Page 1, Petition for Involuntary Assessment for Substance Abuse, Circuit Court of
+the 15th Judicial Circuit in and for Palm Beach County, Florida). On January 31, 2007,
+Plaintiff pled guilty to grand theft and burglary, and was sentenced to a 30-day substance
+abuse program, 9 months community control, and 2 years probation. On February 25,
+2007, Plaintiff cutoff her monitoring bracelet and fled her residence violating probation.
+She was arrested on March 9, 2007 and April 2, 2007 and was ordered to undergo a mental
+health evaluation. On August 8, 2007, she was arrested for possession of drug
+paraphernalia and violated her probation again. She was in jail for a period of 30 days until
+September 6, 2007 when she was found guilty of the violation of probation and sentenced
+to remain in jail for evaluation and treatment and then outpatient treatment as well as
+parenting classes.
+18.
+A Notice of Related Case reports an incident of the plaintiff being charged
+with possession of a weapon on school property in November 2004. (Page 2, Notice of
+Related Case, Circuit Court of the 15% Judicial Circuit in and for Palm Beach County,
+4
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 5 of 10
+Case 9:08-cv-80119-KAM S
+Document 247-7 Entered on FLSD Docket 08/05/2009 Page 5 of 10
+Florida)
+On 4/13/06, in response to a call of child abuse, an officer received a report
+from DCF noting that "since the age of 13, Plaintiff has been smoking marijuana with her
+father every other day... Mom is aware of (blacked out) smoking marijuana with dad. ..
+She placed her daughter in Growing Together Treatment Center on 3/10/06. Then Baker
+Acted her on 4/ 7/06 to (blacked out)." (Police Offense Report)
+20. On 4/12/05, police responded to a domestic violence call, which involved
+plaintiff and her brother kicking and hitting each other at their residence. (Police Offense
+Report)
+21. A police report of 5/24/04 notes that police responded to a delayed battery
+charge, in which the plaintiff was involved in a verbal argument with a friend who then
+punched the plaintiff with a closed fist to the forehead area. (Police Offense Report)
+22. A police report of 11/22/03 noted a physical altercation involving the plaintiff
+and another individual, which resulted in the plaintiff being struck in her left eye with a
+closed fist. (Police Offense Report)
+23.
+On 3/02/03, police responded to a call of a suspicious person at the plaintiff's
+residence. The plaintiff reported that when she entered her shed to do her laundry, she
+came in contact with an unknown male, who had some of her underwear inside his mouth.
+She reported that the male took the underwear out of his mouth, put them in the dryer, and
+5
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 6 of 10
+Aug Case 8086V-801 kRAM. Happent 247-7 Entered on FLSD D49ZK8898995/2009 Pag₴6 of 10
+then ran away. (Police Offense Report)
+24.
+A police report notes an incident of 8/27/02 in which plaintiff was followed
+home from school by four girls and allegedly battered by two of the girls subsequent to a
+verbal conflict at school. (Police Offense Report)
+25.
+"I met Mir. Jeffrey August 2004... I was between repeating sixth grade... I
+was not yet 14.
+came to my house to get me to go and we called a cab to go to
+Jeffrey's. She told me I had to tell him a different age, 16 or over because I wouldn't get
+paid." (Page 1, GK notes)
+26. Plaintiff reported, "I wasn't a virgin. I might have had sex with one person. I
+was around 13 or 14 that I lost my virginity with a little kid, a childhood friend." (Page 2,
+GK notes)
+27. "I smoked some weed during the Xanax... drank a little but not into it." (Page
+2, Vl
+wi GK III, 12/6/08)
+28. Plaintiff reported "Cause I don't like the way it made me feel and I'd fall
+asleep on it and yea ... that's a little bit after I got into that car accident, that's 2006. I
+started getting bad dreams and they started taking me to therapists and I started getting
+like anxiety attacks in the car... It was bad... that's the longest therapist I've ever seen and
+that was because it was court ordered." "I went to her like six months." (Page 9, Tape 1)
+29.
+Question: "Have you been more irritable since this happened to you?"
+6
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 7 of 10
+AugCase09048spv-801 18cKaAMc. HathMtent 247-7 Entered on FLSD DØZke208R5/2009 Page of 10
+Plaintiff response, "I don'tknow."(Page 12, Tape 3).
+30.
+Plaintiff failed to report to Dr. Kliman that on April 10, 2005 she witnessed a
+friend get electrocuted. On December 22, 2006, Plaintiff got into a fight with her thenboyfriend, who had been out all night, and the boyfriend went out in the street in front of
+their house and put a gun to his head and killed himself.
+31.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+32. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical, clinical, school, and work records known to the attorney
+in the case.
+33.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+7
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 8 of 10
+Aug Cases 90686pv-801 folkaAC. HEldEhent 247-7 Entered on FLSD D87R 08995/2009 Pağe 8 of 10
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning,
+which our input is requested." We request the same.
+34.
+It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+8
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 9 of 10
+Case 9:08-0v-80119-KAM _ Document 247-7 — Entered on FLØD Doeket 08/05/2009 — Page 9 of to
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+35.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+
+
+Case 9:08-cv-80119-KAM Document 308-9 Entered on FLSD Docket 09/17/2009 Page 10 of
+Eftered on FLSD D60ke708188/2009
+
+Respectfully submitted,
+Richard C. W.
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+BEFORE ME, the undersigned authority, personally appeared RICHARD C.W.
+| M.D., who is (X) personally known to me or ( ) who has produced
+_ as identification, and who did take an oath, deposes and says that
+the attached Affidavit is true and correct to the best of his knowledge and belief.
+SWORN TO AND SUBSCRIBED before me on this 4th day of Augost
+2009.
+"MARCIA CHAPMAN***
+Expires 6/8/2010
+Florida Notary Assa. Inc
+I pucia f Ungman
+Notary Public
+Printed Name: MARCIA CHAPnAN
+My Commission Expires:
+10
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+}
diff --git a/vision-fixhub/court-01/e8f122adbbdf25f15885ae1a1d7d45119b946d8c5887e092796b549a3efe8a12.md b/vision-fixhub/court-01/e8f122adbbdf25f15885ae1a1d7d45119b946d8c5887e092796b549a3efe8a12.md
new file mode 100644
index 0000000000000000000000000000000000000000..4105f22b4be3cba753d319331a69d368ff02ce7c
--- /dev/null
+++ b/vision-fixhub/court-01/e8f122adbbdf25f15885ae1a1d7d45119b946d8c5887e092796b549a3efe8a12.md
@@ -0,0 +1,210 @@
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. S,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 2 of 7
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/R
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 3 of 7
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 08-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF JANE DOE 101'S RESPONSE TO COURT'S ORDER
+TO SHOW CAUSE REGARDING CONSOLIDATION FOR DISCOVERY
+Plaintiff JANE DOE 101, by and through her undersigned counsel, responds to the Court's
+Order to Show cause why cases 08-80119, 08-80232, 08-80380, 08-80993, 08-80381, 08-80994, 08-
+80811, 08-80893, 09-80469 and 09-80591 should not be consolidated for discovery purposes:
+Plaintiff Jane Doe 101 (Case NO. 09-80591) agrees that all of the ten cases listed above
+should be consolidated for discovery purposes.
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 4 of 7
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By: s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 5 of 7
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this 1" day of May, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 6 of 7
+SERVICE LIST
+JANE DOE NO. 101 v. JEFFREY EPSTEIN
+Case No. 08-CV-80591-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+rcrit@bcldlaw.com
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+jagesg@bellsouth.net
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Co-counsel for Defendant, Jeffrey Epstein
+Jack Scarola, Esq.
+Jack P.L
+1, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+jsx@searcylaw.com
+iph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Herman & Mermelstein
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+
+
+Case 9:09-cv-80591-KAM Document 8 Entered on FLSD Docket 05/01/2009 Page 7 of 7
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10* Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+Esq.
+Law Office of Brad
+& Associates, LLO
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+hedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+, Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
diff --git a/vision-fixhub/court-01/e8f122adbbdf25f15885ae1a1d7d45119b946d8c5887e092796b549a3efe8a12.receipt.json b/vision-fixhub/court-01/e8f122adbbdf25f15885ae1a1d7d45119b946d8c5887e092796b549a3efe8a12.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/e929be5703a398f7846630b0661eb553e99b957f5851db9a1c2d50943c90ef28.md b/vision-fixhub/court-01/e929be5703a398f7846630b0661eb553e99b957f5851db9a1c2d50943c90ef28.md
new file mode 100644
index 0000000000000000000000000000000000000000..5b3771ef4c8010a938dfc11e4953c096b95d263e
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+++ b/vision-fixhub/court-01/e929be5703a398f7846630b0661eb553e99b957f5851db9a1c2d50943c90ef28.md
@@ -0,0 +1,25 @@
+Case 9:08-CV-80736-KAM Document 28-1 Entered on FLSD Docket 09/25/2008 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80736-CIV-MARRA/.
+JANE DOE #1 AND JANE DOE #2,
+Petitioners,
+V.
+UNITED STATES OF AMERICA,
+Respondent.
+ORDER TO UNSEAL NON-PROSECUTION AGREEMENT
+THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-
+Prosecution Agreement between the United States Attorney's Office for the Southern District of
+Florida and Jeffrey Epstein. After consideration of the Motion and the record, it is
+ORDERED AND ADJUDGED that the Petitioners' Motion is GRANTED and the Non-
+Prosecution Agreement between the United States Attorney's Office for the Southern District of
+Florida and Jeffrey Epstein is hereby ordered to be unsealed.
+DONE AND ORDERED in
+in West Palm Beach, Palm Beach County,
+Florida, this
+day of
+, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT COURT
+Copies furnished to:
+all counsel of record
diff --git a/vision-fixhub/court-01/e929be5703a398f7846630b0661eb553e99b957f5851db9a1c2d50943c90ef28.receipt.json b/vision-fixhub/court-01/e929be5703a398f7846630b0661eb553e99b957f5851db9a1c2d50943c90ef28.receipt.json
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/e92e73e527a40fa7cd8f6f7ff89bbdea5e631f38c755fd7b456985412992c85f.md b/vision-fixhub/court-01/e92e73e527a40fa7cd8f6f7ff89bbdea5e631f38c755fd7b456985412992c85f.md
new file mode 100644
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@@ -0,0 +1,683 @@
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 1 of 20
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman™
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz(@troutman.com
+June 1, 2020
+ECF
+Hon. Debra C. Freeman
+Thurgood Marshall
+United States Courthouse
+500 Pearl Street
+New York, NY 10007
+Re: VE, 1:19-cv-07625-AJN-DCF; Katlyn Doe, 1:19-cv-07771-PKC-DCF; Priscilla Doe,
+1:19-cV-07772-ALC-DCF; Lisa Doe, 1:19-cv-07773-ER-DCF; Anastasia Doe, 1:19-CV-
+11869-MKV-DCF
+Dear Judge Freeman:
+We represent Defendants in the above-referenced actions. We write on behalf of all parties to
+update the Court regarding settlement and discovery.
+As the Court is aware, there have been no settlement discussions in any of the individual
+above-referenced cases. The parties' efforts regarding settlement have been singularly focused
+on the establishment of a voluntary, independent claims resolution program, the Epstein
+Victims' Compensation Program. We are pleased to report that, this past weekend, the Co-
+Executors entered into a tripartite agreement with claimants' counsel (specifically, counsel for
+Plaintiffs in the above-referenced actions, Brad
+actions pending before Your Honor, David Boies) and the Attorney General of the United States
+Virgin Islands pursuant to which the Program may now move forward. Earlier today, the Co-
+Executors of the Estate of Jeffrey E. Epstein filed in the Superior Court of the Virgin Islands the
+status report attached hereto as Exhibit A. As stated therein, the Co-Executors, with the
+support of claimants' counsel and the USVI Attorney General, intend to authorize
+commencement of the Program on Monday, June 15, 2020. Most, if not all, of the Plaintiffs in
+the above-referenced actions intend to participate in the Program.
+Meanwhile, the parties continue to meet and confer in efforts to resolve various discovery
+disputes.
+Thank you for your attention to this matter.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 2 of 20
+June 1, 2020
+Page 2
+troutman™
+sanders
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+
+
+Case 1:19-CV-11869-MKV-DCF Document 30 Filed 06/01/20 Page 3 of 20
+
+
+
+Filed 06/01/20
+
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+& ST. JOHN
+***************************
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+Deceased.
+PROBATE NO. ST-19-PB-80
+ACTION FOR TESTATE
+ADMINISTRATION
+: VIRGIN ISLANDS
+CO-EXECUTORS' STATUS REPORT ON VOLUNTARY COMPENSATION
+PROGRAM AND PRESENTATION OF PROGRAM PROTOCOL
+On November 14, 2019, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Co-
+Executors") filed their Expedited Motion for Establishment of a Voluntary Claims Resolution
+Program (the "Expedited Motion"') seeking to establish an independent and voluntary claims
+resolution program (the "Program") for purposes of resolving sexual abuse claims against Jeffrey
+E. Epstein, deceased. As promised in the Expedited Motion, the Co-Executors now submit to the
+Court the detailed Program protocol (the "Protocol," copy attached as Exhibit A hereto) designed
+and developed over several months by independent, nationally recognized claims administration
+experts with extensive input from the Co-Executors and other interested parties, including
+claimants and their legal representatives. Because the need for the Program has grown increasingly
+urgent and with the support of claimants' counsel and the Attorney General of the United States
+Virgin Islands, the Co-Executors intend to authorize commencement on Monday, June 15, 2020
+of formal claims resolution proceedings under the Program, absent contrary direction from the
+Court.
+
+
+Filed 06/01/20 Page 5 of 20
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 2
+BACKGROUND
+As detailed in the Expedited Motion and the Co-Executors' subsequent filings with the
+Court, the Program will provide all eligible claimants an opportunity to receive compensation and
+voluntarily resolve their claims of sexual abuse against Mr. Epstein through a confidential, nonadversarial alternative to litigation, utilizing a process that is sensitive to the experiences and
+concern of claimants and treats them with compassion, dignity and respect.'
+On February 4, 2020, the Court heard extensive witness testimony concerning the Program
+(February 4, 2020 Hearing Tr. at 103:12-186:14); at that hearing, multiple claimants' counsel also
+spoke in favor of implementing the Program. (Id. 84:11-85:2; 85:6-19; 92:24-93:8.) As Your
+Honor recognized, the Program is not only consistent with the fiduciary duties of the Co-
+Executors, but in fact "
+...we agreed that everybody believes this program is a great program..."
+(Id. at 113:24-25.) That drumbeat of approval continues to swell; since the Co-Executors' most
+recent filing with the Court concerning the Program, counsel for 69 individual claimants have
+come forward to the Court in support of the Program.?
+1. Expedited Motion at l; see also Co-Executors' Request for Ruling on Expedited Motion for Establishment of a
+Voluntary Claims Resolution Program (filed December 4, 2019); Co-Executors' Request for Immediate Hearing
+or Conference Regarding Expedited Motion for Establishment of a Voluntary Claims Resolution Program (filed
+December 13, 2019); Co-Executors' Reply to Creditor Jane Doe's Response to Co-Executors' Expedited Motion
+for Establishment of a Voluntary Claims Resolution Program (filed January 15, 2020); Co-Executors' Reply to
+Government's Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program (filed
+January 31, 2020); Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation
+Program and Request for Ruling (filed March 24, 2020); Co-Executors' Corrections to Attorney General's Status
+Report on Voluntary Compensation Program and Renewed Request for Ruling (filed April 10, 2020).
+2. Co-Executors' Notice of Related Filing, dated April 17, 2020 (attaching Co-Executors' correspondence with
+claimants' New York counsel concerning commencement of the Program).
+3. See Status Report from Claimants dated April 20, 2020 (urging on behalf of 12 claimants that "the Program can
+and should proceed without delay"); Status Report from Claimants dated April 21, 2020 (stating on behalf of 5
+claimants that "permitting the Program to proceed would be in the best interests of the victims at this time");
+Motion for Status Conference Regarding the Victim Compensation Program dated April 28, 2020 (seeking on
+behalf of 52 claimants an Order "permitting the Program to proceed as agreed amongst the parties").
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 6 of 20
+Co-Executors* Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 3
+Il.
+THE PROGRAM PROTOCOL
+The Program Administrator and Designers have now finalized the Protocol for the
+Program, in close consultation with claimants' counsel and the Co-Executors.* As contemplated
+in the Expedited Motion, the Protocol sets forth the following non-exclusive guiding principles:
+• The Program is purely voluntary. It does not affect any rights a claimant may
+have unless and until she accepts the offered compensation and executes a
+release. A claimant may reject the offer of compensation and may stop
+participating in the Program and withdraw the claim at any time prior to
+execution of the release.
+• The Program is independent and will in no way be administered, controlled, or
+overseen by the Co-Executors. The Program Administrator is responsible for
+all decisions relating to the review, processing and evaluation of individual
+claims submitted to the Program. The Administrator will have final, binding,
+and exclusive authority to determine claimant eligibility and the valuation of
+each eligible individual claim. Decisions of the Administrator made pursuant
+to the Protocol are not subject to review or modification in any way by the Co-
+Executors or any other party or entity.
+• Subject to total Estate assets available, there is no cap or limitation on the
+aggregate amount of funds available to compensate all eligible claimants or on
+the amount of compensation to be made to each individual claimant. Each
+individual claim will be evaluated separately by the Program Administrator.
+The Administrator will determine, in her sole and exclusive discretion, issues
+of eligibility and the amount of compensation and the Estate will pay all eligible
+claims based on the Administrator's determination.
+• All claimants will be treated with respect, dignity, and fairness without regard
+manage the process so that all claimants can equally access the Program's claim
+process. Individuals with disabilities will be given the opportunity to
+effectively communicate their claims and to request special process
+accommodations.
+(See Protocol at pp. 1-2.)
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 7 of 20
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 4
+The Protocol also sets forth detailed aspects of the Program's administration, including
+eligibility criteria for the Program, proof requirements and claims procedures, the methodology
+for claims evaluation and determining compensatory awards, and timing and regular reports to the
+Court, as follows:
+• Eligibility. The Protocol identifies the criteria to determine whether a claimant
+is eligible to receive compensation under the Program. (See Protocol at pp. 3-
+4.)
+• Proof Requirements and Claims Procedures. The Protocol determines what
+types of supporting documentation or other evidence each individual will be
+required to submit to substantiate her claim, satisfy Program requirements, and
+allow the Program Administrator to review, process and evaluate that claim.
+(See Protocol at pp. 4-5.)
+• Claims Evaluation and Determination Methodology. The Protocol defines
+the factors and considerations to be used to determine the amount of
+compensation to be offered to any eligible claimant. (See Protocol at pp. 5-6.)
+• Timing. The Protocol sets forth the timeframe of the Program, including an
+effective commencement date and deadline for submission of all claims. (See
+Protocol at pp. 4-5.)
+• Reporting. The Protocol reflects the Program Administrator's commitment to
+provide the Court with regular monthly reports regarding the aggregate number
+and total value of claims paid each month through the Program. (See Protocol
+at p. 9.)
+III. URGENT NEED TO COMMENCE OF PROGRAM OPERATIONS
+In their fiduciary capacity, the Co-Executors engaged in extensive discussions with
+relevant parties in interest regarding the independent, fair, and timely resolution of the sexual abuse
+claims against Mr. Epstein. As noted above, many existing and potential claimants have expressed
+through their representatives their preference to participate in the Program rather than proceeding
+with litigation. Although there will be significant expense in administering the Program, the Co-
+Executors contemplate that the Program will substantially reduce the expenses to the Estate of
+litigating multiple lawsuits in numerous jurisdictions, and thus ultimately reduce expenses to the
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 8 of 20
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 5
+benefit of all parties with an interest in the Estate, including claimants and creditors. The
+expedited nature of the Program will also ensure resolution and compensation to claimants in a far
+more timely manner than through litigation.
+As described above, the Protocol is designed to ensure the proportionate restitution of
+approved claims for all claimants, in a manner that will provide similar compensation to similarly
+situated claimants. The Program is in the best interests of both claimants and the Estate because,
+among other things, it avoids the potential of disproportionate and inconsistent awards and should
+help to reduce the time, exposure and burden of handling claims through the courts, which could
+involve years of litigation and appeals and consume enormous resources, along with inflicting on
+all affected parties costs attendant to delay and uncertainty.
+IV. FUNDING FOR THE PROGRAM
+As the Court is aware, the Attorney General on January 31, 2020 unilaterally imposed
+criminal activity liens on the Estate's bank account in the Virgin Islands, freezing then-available
+funds - funds over which this Court has exclusive jurisdiction - for administration of the Estate
+and implementation of the Program.® On February 24, 2020, the Attorney General imposed similar
+liens against Southern Trust Company, Inc., one of the entities within the Estate. The Co-
+Executors have challenged the validity of the Attorney General's liens, and moved the Superior
+5. In the absence of the Program, litigation alleging sexual abuse by Mr. Epstein has increased in scope, pace and
+up each passing week.
+6. Following the Co-Executors' resulting emergency motion for release of funds necessary for administration of the
+Estate, the Court directed the Attorney General to lift her liens in amounts sufficient to allow the Co-Executors
+to pay the Estate's operational expenses and legal fees.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 9 of 20
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 6
+Court to vacate them in their entirety.? However, pending determination of that motion - as well
+as this Court's approval of the estimated budget for and expenses of designing, implementing and
+administering the Program, submitted by the Co-Executors on February 4, 2020 - the Co-
+Executors and the Attorney General have reached consensual resolution in which the latter will
+promptly lift those liens to pay amounts owed for the Program and to begin funding of the
+Program's active operations, including payment of compensation determinations to eligible
+claimants.®
+*
+*
+Because the need for the Program has grown increasingly urgent, and with the support of
+claimants' counsel and the USVI Attorney General - and because the remaining impediments have
+been resolved and the interested parties have consented to the Protocol attached as Exhibit A hereto
+- the Co-Executors intend to move forward with the Program on Monday, June 15, 2020, absent
+contrary direction from the Court.?
+Respectfully,
+Dated: June 1, 2020
+Kroblin
+KROBLIN, ESQ.
+ANDREW W. HEYMANN, ESQ.
+WILLIAM L. BLUM, ESQ.
+SHARI N. D'ANDRADE, ESQ.
+MARJORIE WHALEN, ESQ.
+7. See Expedited Motion to Vacate Liens, dated March 17, 2020 (Government of the U.S. Virgin Islands vs. Indyke,
+et al., Case No. ST-20-CV-14). The Attorney General filed no response to that expedited motion.
+8. As part of that resolution, the Co-Executors agreed not to assert that the Attorney General's release of such limited
+funds will act as a waiver of Government's ability, if any, to object to the Program's administrative expenses.
+including those paid with these initial funds.
+themselves available.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 10 of 20
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-/9-PB-80
+Page 7
+V.I. Bar Nos. 136. 966. 1221 & R2019
+KELLERHALS
+KROBLIN PLLC
+Palms Professional Building
+9053 Estate
+St.
+1 Suite 101
+• V.i. 00802
+Telephone: (340) 779-2564
+Facsimile: (888) 316-9269
+Email: wblum@solblum.com
+ckroblin@kellfer.com
+sdandrade@kellfer.com
+mwhalen@kellfer.com
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20
+
+Co-Executors' Status Report on Voluntary Compensation Program
+and Presentation of Program Protocol
+Probate No. ST-19-PB-80
+Page 8
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that on this Ist day of June 2020, I caused a true and exact copy
+of the foregoing Co-Executors' Status Report on Voluntary Claims Resolution Program and
+Presentation of Program Protocol to be served via electronic mail upon:
+John H. Benham, Esq.
+Law Office of John H. Benham, P.C.
+P.O. Box |1720
+St.
+F, VI 00801
+john@benhamlawvi.com
+A. Jeffrey Weiss, Esq.
+A.J. Weiss & Associates
+59,L Yes Lane
+. VI 00802
+jeffweiss@weisslaw-vi.net
+Douglas B. Chanco, Esq.
+ChancoSchiffer P.C.
+3355 Lenox Road, Suite 750
+Atlanta, GA 30326
+doug@csfirm.com
+Richard Bourne-Vanneck, Esq.
+Law Offices of Richard Bourne-Vanneck
+9800 Buccaneer Mall Suite #9
+St.
+VI 00802
+richard@rpvblawoffices.com
+John K. Dema
+Law Offices of John K. Dema
+1236 Strand Street, Suite 103
+St. Croix, VI
+jdema@demalaw.com
+Denise N.
+1, Esq.
+Attorney General
+Ariel M.
+Chief, Civil Division
+Virgin Islands Department of Justice
+34-38 Krondprinsdens Gade
+GERS Complex, 2nd Floor
+St.
+Virgin Islands 00804
+Sean
+r, Esa.
+Marjorie Rawls
+i, P.C.
+P.Q. Box 6347
+St.
+, VI 00804
+sean@marjorierobertspc.com
+Kevin F. D'Amour
+Gaylin Vogel, Esq.
+5143 Palm Pass 008, 186 & 196
+, VI 00802
+kevin.damour@comcast.net
+gaylin.vogel@comcast.net
+Melody D. Westfall, Esq.
+Westfall Law PLLC
+5032 Anchor Way, Suite 8
+Christiansted, St. Croix 00820
+mwestfall@westfalllaw.com
+Kevin Boyle, Esq. (Pro Hac Vice)
+Robert Glassman, Esq. (Pro Hac Vice)
+PANISH SHEA & BOYLE LLP
+11111 Santa Monica Blvd., Ste. 700
+Los Angeles, CA 90025
+boyle@psblaw.com
+glassman@psblaw.com
+/s/ Shari N. D'Andrade
+
+
+Filed 06/01/20
+
+Independent
+Epstein Victims' Compensation Program
+PROTOCOL
+May 29, 2020
+SUPERIOR COUR!
+VIRGIN ISL ANUS
+AM 8: 25
+PURPOSE AND OVERVIEW
+The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
+has been established to compensate and resolve the claims of victims-survivors of sexual abuse by
+Jeffrey Epstein ("Epstein").
+The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
+administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H.
+to design the
+Program.
+will also serve as the Administrator of the Program (the "Administrator"). This
+Protocol reflects input from victims-survivors, their lawyers, other potentially interested parties, and
+representatives of the Estate.
+Through the Program, the Estate wishes to acknowledge the wrongs endured by victims-survivors and
+offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
+The Program is governed by the following non-exclusive guiding principles:
+• The Program is purely voluntary. It does not affect any rights a Claimant may have
+unless and until the Claimant accepts the offered compensation and executes a
+Release. A Claimant may reject the offer of compensation and may stop
+participating in the Program and withdraw the claim at any time prior to execution
+of the Release.
+• The Program is independent and will in no way be administered, controlled or
+overseen by the Estate. The Administrator is responsible for all decisions relating to
+the review, processing and evaluation of individual claims submitted to the
+Program. The Administrator will have final, binding and exclusive authority to
+determine Claimant eligibility and the valuation of each eligible individual claim.
+Decisions of the Administrator made pursuant to this Protocol are not subject to
+review or modification in any way by the Estate or any other party or entity.
+• There is no cap or limitation on the aggregate amount of funds available to
+compensate all eligible Claimants or on the amount of compensation to be made to
+each individual Claimant. Each individual claim will be evaluated separately by the
+Administrator. The Administrator will determine, in her sole and exclusive
+discretion, issues of eligibility and the amount of compensation and the Estate will
+pay all eligible claims based on the Administrator's determination.
+1| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 13 of 20
+• All Claimants will be treated with respect, dignity and fairness without regard to
+race, color, sexual orientation, national origin, religion, gender or disability. To
+ensure claims will be adjudicated fairly, the Administrator will manage the process
+so that all Claimants can equally access the Program's claim process. Individuals
+with disabilities will be given the opportunity to effectively communicate their
+claims and to request special process accommodations.
+The Program is available to all victims-survivors regardless of where they were harmed, when they were
+harmed, whether the claim is time-barred by the applicable statute of limitations, and whether they
+have previously filed a lawsuit against or settled with Epstein and/or the Estate.
+The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
+individual claims filed with the Program must be filed within this period.
+To complement the Program's resources, the Administrator will, at her discretion and with the consent
+of the Claimant, consult with Professor Marci A.
+,, a nationally recognized sexual abuse expert,
+leading legal academic and advocate of victims' rights.
+; role will be to further inform the
+Administrator and her staff about the dynamics of sexual abuse, common responses to sexual abuse,
+and the impact of sexual abuse on victims; to serve as a resource for the Administrator in developing or
+updating policies and procedures; to advise the Administrator regarding sensitivities involved in
+interactions with victims; and to serve as a referral source for the Administrator in providing postdetermination information to claimants who seek guidance, counseling or other services. The
+Administrator may, at her discretion and with the Claimant's prior written consent, request that
+review an individual claimant file. The Administrator will determine on a case-by-case basis, in
+her discretion, the need to anonymize individual claimants' files before sharing them with
+As set forth above, the Administrator is solely responsible for all decisions relating to the administration
+of the Program, including the review, processing, evaluation, and determination of individual claims
+submitted to the Program.
+During the term of the Program,
+will not meet or speak with a Claimant or her
+representatives concerning any aspect of the Program without the Administrator present.
+will maintain in strict confidence and will not disclose outside the Program any information she obtains
+through her participation in the Program, including individual Claimants' submissions.
+2|Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 14 of 20
+Il.
+ELIGIBILITY REQUIREMENTS
+A. Eligibility Criteria
+The persons eligible to participate in this Program are individuals who allege they were sexually abused
+by Epstein. In addition, the following criteria apply:
+• The claim of sexual abuse must be directed against Epstein.
+• An individual whose claim is time-barred by the applicable statute of limitations may
+participate in the Program provided that other eligibility criteria are met.
+• An individual who previously entered into a settlement agreement resolving a claim of sexual
+abuse against Epstein may participate in the Program provided that other eligibility criteria are
+met.
+• An individual who allegedly assisted Epstein in procuring other victims-survivors may
+participate in the Program where there is a credible basis to determine that the individual
+acted under duress as a result of her own sexual abuse by Epstein, provided that other
+eligibility criteria are met.
+• If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
+prejudice any existing lawsuits, legal actions or claims filed against the Estate or related entities
+and/or related individuals. The Claimant must provide proof of such dismissal along with or
+prior to the signed acceptance of the compensation determination offer letter and executed
+Release in order to receive payment.
+B. Legal Representatives of Claimants
+An individual may file a claim on a victim's behalf where that individual has been granted legal authority
+to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
+individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
+guardian authorized by law to serve as the minor's legal representative; (2) in the case of an
+incompetent or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's
+legal representative in accordance with applicable law; (3) in the case of a deceased Claimant, a person
+who has been duly appointed to act as the personal representative of the Claimant's estate by a court of
+competent jurisdiction and is authorized to file and compromise a claim; or (4) an attorney authorized to
+represent the Claimant for purposes of pursuing a claim through this Program.
+Legal Representatives must provide proper documentation demonstrating representative capacity. Such
+proof may include a power of attorney; documentation showing the individual's appointment as
+guardian or guardian ad litem; documentation showing the individual's appointment as personal
+representative of the Claimant's estate (such as letters of administration); a copy of a retainer
+3 | Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 15 of 20
+agreement showing legal representation signed by both the Claimant and the attorney or a signed
+statement by an adult Claimant and the attorney that a licensed/admitted attorney is acting on her
+behalf.
+I!. CLAIMS ADMINISTRATION - SUBMISSION, EVALUATION AND DETERMINATION
+A. Claims Submission Process
+Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
+otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before the
+Effective Date will be sent a Claim Form and other relevant Program information, including Instructions
+for completion and submission of the Claim Form and a copy of this Protocol. Individuals who have filed
+a lawsuit need not agree to a stay of litigation or make any other concession in any pending litigation to
+be eligible to participate in the Program. Likewise, individuals who have not yet filed a lawsuit remain
+free to file a lawsuit and engage in litigation concurrently with participation in the Program. Individuals
+must, however, dismiss with prejudice any and all existing lawsuits, legal actions and claims prior to or at
+the time of acceptance of a compensation determination offer in order to receive payment.
+Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate or have
+not otherwise been identified as a victim of Epstein by their attorney to the Administrator on or before
+the Effective Date may register to participate in this Program on the Program's website at
+www.EpsteinVCP.com. To register, such individuals must complete a questionnaire setting forth their
+name, contact information, a summary description of the nature of the claim and other requested
+information. Upon registration, the Administrator will perform a preliminary review to consider if the
+individual is eligible to participate in the Program. If the Administrator deems that the individual is
+eligible to participate in the Program, she will then send that individual a Claim Form and other relevant
+Program information.
+Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
+that the Administrator has determined that such individual is eligible to participate in the Program. It
+does not indicate that the Administrator has determined that such individual is eligible to receive
+compensation. That determination is made only after a Claim Form and all required documentation has
+been submitted and evaluated by the Administrator.
+Registrations for individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the
+Estate or have not otherwise been identified as a victim of Jeffrey Epstein by their attorney to the
+Administrator on or before the Effective Date will be accepted by the Administrator from the Effective
+Date through a date that is 45 days prior to the Filing Deadline ("Registration Deadline"). It is important
+to note that the Registration Deadline is separate from, and precedes, the Filing Deadline. As explained
+above, all claims must be filed by the Filing Deadline.
+4| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 16 of 20
+All Claim Forms must be completed to the best of a Claimant's ability and filed no later than the Filing
+Deadline. Claim Forms should be uploaded to the Program website at www.EpsteinVCP.com, or mailed
+via overnight courier (a pre-paid courier voucher will be included with each packet) to the Administrator
+at the following address:
+Epstein Victims' Compensation Program
+Attn: Jordana H. L
+, Administrator
+P.O. Box 65488
+Washington, D.C. 20035
+Claimants are invited to provide documentation identified in the Claim Form, and any other
+corroborating or supporting information sufficient to substantiate the claim, satisfy eligibility
+requirements, and allow the Administrator to review, process and evaluate the claim. If the claim is
+being presented by a Legal Representative, then the Legal Representative will be responsible for
+submitting the necessary documentation relating to the represented Claimant.
+Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
+and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
+relevant to the Administrator's evaluation and determination of the claim before the Administrator's
+final disposition of the claim.
+If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant,
+explain the additional information that is needed, and work with the Claimant or the Claimant's Legal
+Representative (where applicable) to assist in submitting a complete claim.
+B. Claims Evaluation and Determination
+Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
+submitted individual claim in a prompt and fair manner. Claims will only be determined once all
+required documentation has been submitted to the Administrator, with due consideration granted to
+Claimant's good faith explanations for delays and/or absence of documentation.
+1. Factors Considered in Evaluating Claims
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, whether the allegations of sexual abuse are credible. The Administrator will
+consider appropriate factors and corroborative support, including but not limited to:
+• The level of documentation, corroboration or other circumstantial evidence regarding the
+nature and extent of the abuse, the frequency, location and other details of the abuse, and the
+age of the victim at the time of the abuse. Non-exhaustive examples of such evidence include
+(i) medical or psychiatric counseling/therapy records relevant to the abuse, and
+(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
+abuse by the Claimant to law enforcement authorities, parents, friends or others. The
+Administrator acknowledges that some Claimants may not be able to provide any
+5| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 17 of 20
+documentation to corroborate their Claim based on the nature and circumstances of Epstein's
+conduct. If a Claimant's written and oral presentation is deemed to be credible by the
+Administrator, the Claimant may still be eligible for compensation under the Program.
+• Whether there exists any information and/or pertinent findings offered by the appropriate
+Office of the District Attorney, United States Attorney's Office, or other law enforcement
+agency.
+• Whether the Administrator finds the claims of the individual to be credible after complete
+review of all relevant documentation and other evidence provided by the Claimant and the
+Estate. (
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, the amount of compensation that should be offered to each eligible Claimant.
+The Administrator will consider appropriate factors and corroborative support, including but not limited
+to:
+• The nature, duration and extent of the sexual abuse suffered by the Claimant.
+• The age of the Claimant at the time of the sexual abuse.
+• The nature and extent of the Claimant's physical or psychological damage resulting from the
+sexual abuse, and the effect of the sexual abuse on the Claimant.
+• The credibility of the claim based upon all of the facts and circumstances, supporting
+documentation and corroborating evidence.
+• Whether the Claimant previously entered into a settlement agreement with Epstein and
+received a payment pursuant to such agreement.
+The Administrator will confidentially send the Claimant a compensation determination offer letter
+including the following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of
+compensation offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered
+compensation; and (4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from
+the date of the compensation determination offer letter.
+The Administrator's determinations in this Program will not be binding on any potential criminal
+investigation involving Claimant's claims.
+2. Opportunities to be Heard
+The Claimant will be afforded an opportunity to be heard, either before or after the Administrator
+renders her determination. Upon request by the Claimant, the Administrator will be available to meet in
+person (as practicable in light of the COVID-19 pandemic), by video conference, or by teleconference to
+further discuss the claim. These meetings are completely optional and voluntary. Requests to meet
+6| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 18 of 20
+with the Administrator should be sent by email to ClaimantServices@EpsteinVCP.com and will be
+scheduled at a mutually convenient time and location. The Administrator may also request a meeting
+with a Claimant or her Legal Representative at a reasonable mutually convenient time and location,
+though the Claimant is not obligated to attend any such meeting.
+3. Release
+By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations
+of sexual abuse against Epstein and/or the Estate, and related entities and individuals as set forth in the
+Release. If a Claimant chooses to accept the offer of compensation pursuant to the Program, the
+Claimant will be required to sign and execute a full Release, in a form satisfactory to the Estate, of all
+past and future claims (including lis pendens, writs of attachment, etc.) relating to such allegations of
+sexual abuse against the Estate, related entities and/or related individuals. A Claimant may reject the
+offer of compensation and may stop participating in the Program and withdraw the claim at any time
+prior to the execution of the Release.
+The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
+may have to assert any claims relating to allegations of sexual abuse against the Estate, related
+entities and/or related individuals, to file an individual legal action relating to such allegations, or to
+participate in any civil legal action associated with such allegations, except as a witness. However,
+the Release will not operate to preclude or limit the Claimant's ability to report and discuss
+allegations of sexual abuse with law enforcement officials or anyone else. In other words, the
+Release will not impose any rules of confidentiality on claimants, who are expressly permitted to
+discuss their allegations without restriction, should they choose.
+Before signing a Release, the Claimant must consult with an attorney selected by the Claimant. If the
+Claimant is not represented by an attorney, the Program will provide an attorney to provide free legal
+counseling to the Claimant for the sole purpose of advising the Claimant concerning the language and
+binding nature of the Release.
+No one affiliated with the Program will provide tax or legal advice to those receiving payments under
+the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding
+tax liability for payments pursuant to the Program.
+4. Payments
+Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
+the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing
+lawsuit, legal actions or claims against the Estate or related entities and/or related individuals, the
+Administrator will initiate payment by check or electronic funds transfer to each eligible Claimant as
+directed by the Claimant. Checks will be sent to Claimants via overnight courier service. All
+payments made under the Program shall be for a Claimant's physical injuries, physical sickness and
+7| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 19 of 20
+resulting emotional distress within the meaning of Section 104(a) of the Internal Revenue Code.
+C. Program Integrity
+For the purpose of protecting both the integrity of the Program and financial resources for eligible
+Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
+claims, including taking steps to verify claims and analyze submissions for inconsistencies,
+irregularities or duplication.
+Each Claimant who signs the Claim Form at the time of submission certifies that the information
+provided in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the
+Claimant understands that false statements or claims made in connection with such submission may
+result in fines, imprisonment and/or any other remedy available by law. Claims that appear to be
+potentially fraudulent or to contain information known by the Claimant to be false when made will be
+forwarded to federal, state or local law enforcement agencies and/or the appropriate Office of the
+District Attorney and/or United States Attorney's Office for possible investigation and prosecution.
+D. Confidentiality/Privacy
+The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
+Representative (where applicable) agrees that information submitted by the Claimant pursuant to
+the Program will be used and/or disclosed by the Administrator and her designees only for the
+following purposes:
+1) Processing and evaluating the Claimant's claim;
+2) Administering the Program and other Program-related work; and
+3) Reports to law enforcement where appropriate, related to potentially fraudulent claims.
+When documents or other information maintained or submitted by the Estate become part of a
+Claimant's file for purposes of the Program, such materials will be reviewed by the Administrator to
+assist in processing and evaluating the claim, but will otherwise remain confidential. No information
+provided by Claimants will be provided to the Estate except for the Claimant's name and the date(s)
+and location(s) of the alleged abuse, for the sole purpose of processing and evaluating the claim and,
+for purposes of the Release, the names of any other individual(s) to whom or by whom the Claimant
+alleges she was trafficked or sexually abused. The Estate has agreed that no information obtained
+solely through the Program will be disclosed publicly or used by the Estate in defending itself from any
+claim, regardless of forum. The Program's files are not available for inspection, review or copying by
+the Estate or the Claimant or her representatives during or after the Program, and all pertinent
+mediation privileges, settlement privileges and other privileges apply.
+' All parties agree that they are using the services of a third-party administrator to help reach a resolution of individual claims
+of sexual abuse, and that this Program is entitled to confidentiality, privileges (mediation, settlement and all other pertinent
+privileges), and protection from disclosure under applicable law.
+8| Page
+
+
+Case 1:19-cv-11869-MKV-DCF Document 30 Filed 06/01/20 Page 20 of 20
+To protect the privacy of Claimants participating in the Program, all personal information provided by
+the Claimant during this process will be returned or destroyed within one year after the conclusion of
+the Program.
+Individual Claimants are not bound through the Program by any rules of confidentiality. Claimants may,
+at their sole and voluntary option, disclose information in their possession regarding their claim, their
+compensation and their experience with the Program.
+All confidentiality requirements are subject to law, regulation and judicial process.
+E. Reporting
+The Administrator shall, on a monthly basis, confidentially provide reports regarding the number and
+total value of claims paid each month to the Probate Court of the United States Virgin Islands and the
+Attorney General of the United States Virgin Islands. Such reports will report on an aggregate level
+only. No individual Claimant information will be published or disclosed in a way that compromises
+Claimant confidentiality.
+9 | Page
\ No newline at end of file
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+++ b/vision-fixhub/court-01/e9510c08fe5a4430af3daf18ab4f3ae3e897bbdde03b4e6b0d87add638ac9b74.md
@@ -0,0 +1,787 @@
+Case 9:08-CV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 1 of 27
+prey
+3/23
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO: 08-CV-80893-MARRA/JOHNSON
+JANE DOE,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT
+COMES NOW the Plaintiff, Jane Doe, by and through her undersigned counsel, pursuant
+to Fed.R.Civ.P. 33 and S.D. Fla. 26.1.G., and propounds unto the Defendant, Jeffrey Epstein, her
+First Set of Interrogatories, numbered 1 through 23, inclusive, to be answered separately, fully
+and under oath, within thirty (30) days of service.
+PRELIMINARY STATEMENT
+These interrogatories are deemed continuing. Pursuant to Rule 26(e) of the Federal Rules
+of Civil Procedure and applicable law, if any information sought by said interrogatories is not
+learned until after they are answered, or if any answers for any reason should later become
+incorrect, there shall be a continuing duty on the party answering said interrogatories to
+supplement or change answers previously submitted.
+DEFINITIONS
+The term "document" as used herein means and includes, without limitation, all
+writings of any kind, including the originals and all non-identical copies or drafts, whether
+different from the original by reason of any notation made on such copy or draft or otherwise
+including, without limitation, correspondence, memoranda, notes, diaries, statistics, letters, e-
+mail, electronic computer files, telegrams, minutes, contracts, reports, studies, checks,
+statements,
+receipts, returns, summaries, pamphlets, books, prospectuses,
+interoffice
+communications, offers, notations of any sort of conversation, telephone calls, meetings or other
+communications, bulletins, printed matter, computer print-outs, teletypes, facsimiles, invoices,
+work sheets and all drafts, alterations, modifications, changes, and amendments of any of the
+foregoing, graphic or aural writs, records or representations of any kind including, without
+(1
+30
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 2 of 27
+limitation, photographs, charts, graphs, microfiche, microfilm, videotape, recordings, motion
+pictures; and electronic, mechanical or electric records or representations of any kind including,
+without limitation, tapes, cassettes and disc recordings, and writings and printed material of
+every kind, whether or not the document is out of your possession, custody or control.
+2.
+The term "correspondence" as used herein is defined to mean any tangible object
+that conveys information or memorializes information that was conveyed in tangible or oral form
+including, but not limited to, writings, letters, memoranda, reports, notes, telegrams and
+interoffice communication.
+3.
+The term "relating to" as used herein is defined to mean evidencing, referring to,
+pertaining to, consisting of, reflecting, concerning, or in any way logically or factually connected
+with the matter discussed
+The phrase "describe and explain" and the term "state" as used herein are intended
+to and shall be interpreted to request a full and fair statement of the fact or matter being
+described and explained, including a statement of all facts, statements, events and circumstances
+necessary to understand and evaluate the fact or matter being described and explained.
+The term "identify" as used in each of the following Interrogatories requesting an
+identification of documents is intended to be interpreted to request and require:
+A. The date of the document;
+B. The originator of the document;
+C. The type of document;
+D. The addressee of the document, if any;
+E.
+Identification of persons to whom copies of the documents were furnished;
+F.
+Details as to the custody of the document on the date the Interrogatories
+are answered;
+G.
+Specific page numbers where the information requested may be found, if
+appropriate; or, alternatively, documents may be identified by numbering each such document
+and referring to the number in the answer and providing a true copy of each such numbered
+document with the Answers to Interrogatories.
+6.
+The term "identify" as used in each of the following Interrogatories requesting the
+identification of persons is intended to be interpreted to request and require for each witness
+known:
+A.
+The full name of the individual;
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 3 of 27
+B.
+The last known address and phone number of the individual;
+The last known place, address and phone number of employment of the
+individual;
+D.
+The substance of the witness' knowledge or information relating to the
+information requested.
+
+
+Case 9:08-cv-80119-KAM
+Document 343 Entered on FLSD Docket 10/06/2009 Page 4 of 27
+PLAINTIFF'S FIRST SET OF INTERROGATORIES TO DEFENDANT
+(If answering for another person or entity, answer with respect to that person or entity, unless
+otherwise stated.)
+What is the full name and Florida address of the person answering these interrogatories,
+and, if applicable, the person's official position or relationship with the party to whom the
+interrogatories are directed?
+2.
+Describe financial assets that are under your control, directly or indirectly, including
+interests in corporations or other business entities.
+Describe which financial assets listed in your answer to Interrogatory #2 that are located
+outside the 50 states of the United States and where they are located.
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 5 of 27
+4.
+Describe your net worth, including income and expenses for 2005, 2006, 2007, and 2008.
+S.
+Describe any real property in which you have a total or partial ownership interest, either
+directly or indirectly.
+Describe which real properties listed in your answer to Interrogatory #5 are located
+outside the 50 United States and where the properties are located.
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 6 of 27
+Describe any transfer of assets under your control, either directly or indirectly, to
+locations outside the 50 United States in 2005, 2006, 2007, and 2008.
+8.
+Describe, with specificity, your travel to locations outside the 50 states of the United
+States in 2005, 2006, 2007, and 2008, including your dates of travel, location to which
+you traveled and persons that accompanied you in each such travel.
+List each telephone number used by you or your assistants to call minor females directly,
+or indirectly, for the purpose of scheduling a massage to take place at your house located
+at 358 El Brillo Way, West Palm Beach (includes landlines, cell phones, and private jet
+or airplane lines). For each cell phone, list the provider.
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 7 of 27
+List the last known name, address, and telephone numbers of all persons that may have
+- any knowledge about any of the allegations in the Complaint, including, but not limited
+to, friends, acquaintances, employees, or others to whom you have spoken about the
+subject matter which forms the basis of this Complaint or who have observed such
+activity.
+11.
+Have you heard or do you know about any statement or remark (verbal or written) made
+by or on behalf of any party to this lawsuit, other than yourself, concerning any issue in
+this lawsuit? If so, state the name and address of each person who made the statement or
+remark, the name and address of each person who heard or read it, and the date, time,
+place and substance of each statement or remark.
+12.
+Do you intend to elicit testimony of witnesses other than Plaintiff regarding any
+tatements she has ever made? If so, what statements do you intend to produce throug
+estimony? Through which witness do you intend to elicit such statement? And for wha
+purpose do you intend to admit such statement?
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 8 of 27
+13.
+Are you transferring, or do you plan to, or might you transfer money or assets out of the
+country during the course of this litigation?
+14.
+Describe each property owned by you, including location, approximate value, and
+whether there is a mortgage on the property and the amount of any such mortgage.
+15.
+Describe with specificity the amount of money available to you in cash or that can be
+readily liquidated as such. Include the bank, financial institution, holding company, or
+other location of this money and the name on the account.
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 9 of 27
+16.
+State with as much specificity as possible when you met the Plaintiff, and include in your
+answer the following: (a) the circumstances and location of how and where you met, (b)
+describe the nature of your relationship; (c) describe how many occasions she was with
+you at your residence located at 358 El Brillo Way in Palm Beach, Florida.
+17.
+Provide the names, addresses, and phone numbers of all your current accountants,
+financial planners or money managers handling, or assisting in the handling, of your
+money or assets.
+18.
+Did you ever ask the Plaintiff to introduce you to minor females and/or to bring minor
+females to your house in Palm Beach, Florida and if so, when did this occur, and what
+was she asked by you to do, and what did you tell her about the reason for her to bring
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 10 of 27
+19.
+Did you ever engage in sexual activity of any kind whatsoever with the Plaintiff, and
+include in your answer what type of sexual activity took place, where it took place, and
+the dates or general timeframe when this activity occurred.
+20.
+Were there parameters or instructions by you to the Plaintiff as to the types of girls to
+bring to your Palm Beach, Florida house, including age range, what they would be asked
+to do, body type or socio-economic background?
+21.
+Describe any words or actions that you made to assure the Plaintiff that sexual activity
+with you was proper or appropriate?
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 11 of 27
+22.
+Describe what age you thought the Plaintiff was when you first had sexual activity with
+her, including your reasons for that belief.
+23.
+State the facts upon which you rely for each affirmative defense in your answer.
+
+
+Case 9:08-CV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 12 of 27
+I have read the foregoing Answers to Interrogatories and do swear that they are true and
+correct.
+Jeffrey Epstein, Defendant
+STATE OF FLORIDA
+iss.
+COUNTY OF
+The foregoing instrument was acknowledged before me this
+_day of
+2008, by JEFFREY EPSTEIN, who is personally known to me or who has produced
+as identification
+and who did
+My Commission Expires:
+did not
+_take an oath.
+Signature of Acknowledger
+Typed/Printed Name of Acknowledger
+Title or Rank
+Serial Number, if any
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 13 of 27
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that a true and correct copy of the above and foregoing has
+been provided via United States mail to the following addresses, this 23 day of March, 2009.
+Robert D. Critton, Jr., Esquire
+Michael J. Pike, Esquire
+Burman, Critton, Luttier & Coleman, LLP
+515 North Flagler Drive
+Suite 400
+West Palm Beach, Florida 33401
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Jack Alan Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+jagesq@bellsouth.net
+Michael R. Tein, Esquire
+|| Tein, P.L.
+3059 Grand Avenue
+Suite 340
+Coconut Grove, Florida 33133
+tein@lewistein.com
+Respectfully Submitted,
+THE LAW OFFICE OF BRAD |
+ASSOCIATES, LLC
+By:
+Brad
+Esquire
+Attorney for Plaintiff
+Florida Bar No. 542075
+2028|
+I Street
+Suite 202
+Hollywood, Florida 33020
+Telephone:
+954-414-8033
+Facsimile:
+954-924-1530
+E-Mail:
+be@bradedwardslaw.com
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 14 of 27
+Paul G. Cassell
+Attorney for Plaintiff
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone:
+801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 15 of 27
+Pldg
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV- 80893 - MARRA/.
+JANE DOE,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S ANSWER & OBJECTIONS TO PLAINTIFF'S
+FIRST SET OF INTERROGATORIES (dated 03/23/09)
+Defendant, JEFFREY EPSTEIN, (EPSTEIN"), by and through his undersigned
+attorneys, serves his answers to Plaintiff's First Set of Interrogatories, dated March 23,
+2009. Rules 33 and 26.1, Fed.R.Civ.P. (2009), attached hereto.
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S
+Jail and facsimile to the following addressees this /8 day of May, 2009
+Brad
+Esq.
+Rothstein Roseneldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+561-835-8691 Fax
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+IGTE DI
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 16 of 27
+Page 2
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff
+Respectfully submitted,
+By:
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 17 of 27
+Jane Doe V. Epstein, et al.
+Page 3
+DEFENDANT'S ANSWERS TO FIRST SET OF INTERROGATORIES
+Interrogatory No. 1.
+What is the full name and Florida address of the person
+answering these interrogatories, and, if applicable, the person's official position or
+relationship with the party to whom the interrogatories are directed?
+Answer:
+Jeffery Epstein, Defendant
+358 El Brillo Way, Palm Beach, Florida
+Robert D. Critton, Jr., Attorney for Defendant (if RDC only answers "RDC")
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401 (objections other than constitutional, are
+made by RDC on behalf of Defendant)
+Interrogatory No. 2.
+Describe financial assets that are under your control, directly
+or indirectly, including interests in corporations or other business entities.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 3.
+Describe which financial assets listed in your answer to
+interrogatory #2 that are located outside the 50 states of the United States and where
+they are located
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 18 of 27
+Page 4
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 4.
+Describe your net worth, including income and expenses for
+2005, 2006, 2007 and 2008.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his
+constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 5.
+Describe any real property in which you have a total or
+partial ownership interest, either directly or indirectly.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 19 of 27
+Page 5
+Interrogatory No. 6.
+Describe which real properties listed in your answer to
+interrogatory #5 are located outside the 50 United States and where the properties are
+located.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 7.
+Describe any transfer of assets under our control, either
+directly or indirectly, to locations outside the 50 United States in 2005, 2006, 2007 and
+2008.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 8.
+Describe, with specificity, your travel to locations outside the
+50 states of the United States in 2005, 2006, 2007 and 2008, including your dates of
+travel, location to which you traveled and persons that accompanied you in each such
+travel.
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 20 of 27
+Page 6
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 9.
+List each telephone number used by you or your assistants
+to call minor females directly, or indirectly, for the purpose of scheduling a massage to
+take place at your house located at 358 El Brillo Way, West Palm Beach (includes
+landlines, cell phones, and private jet or airplane lines). For each cell phone, list the
+provider.
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that I cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, 1 assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Interrogatory No. 10.
+List the last known name, address and telephone numbers
+of all persons that may have any knowledge about any of the allegations in the
+Complaint, including, but not limited to, friends, acquaintances, employees, or others to
+whom you have spoken about the subject matter which forms the basis of this
+Complaint or who have observed such activity.
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges.
+I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 21 of 27
+Page 7
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence. The scope of the information is so overbroad that
+it also includes information that is attorney-client and work-product privileged.
+Interrogatory No. 11.
+Have you heard or do you know about any statement or
+remark (verbal or written) made by or on behalf of any party to this lawsuit, other than
+yourself, concerning any issue in this lawsuit? If so, state the name and address of
+each person who made the statement or remark, the name and address of each person
+who heard or read it, and the date, time, place and substance of each statement or
+remark.
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit,
+, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his
+constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence. The scope of the information is so overbroad that
+it also includes information that is attorney-client and work-product privileged.
+Interrogatory No. 12.
+Do you intend to elicit testimony of witnesses other than
+Plaintiff regarding any statements she has ever made? If so, what statements do you
+intend to produce through testimony? Through which witness do you intend to elicit
+such statement? And for what purpose do you intend to admit such statement?
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges.
+I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 22 of 27
+Page 8
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence. Additionally, work-product and attorney-client.
+Interrogatory No. 13.
+Are you transferring, or do you plan to, or might you transfer
+money or assets out of the country during the course of this litigation?
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 14.
+Describe each property owned by you, including location,
+approximate value, and whether there is a mortgage on the property and the amount of
+any such mortgage.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 23 of 27
+Page 9
+Interrogatory No. 15.
+Describe with specificity the amount of money available to
+you in cash or that can be readily liquidated as such. Include the bank, financial
+institution, holding company, or other location of this money and the name of the
+account.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 16.
+State with as much specificity as possible when you met the
+Plaintiff, and include in your answer the following: (a) the circumstances and location of
+how and where you met (b) describe the nature of your relationship, (c) describe how
+many occasions she was with you at your residence located at 358 El Brillo Way in
+Palm Beach, Florida.
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that I cannot provide answers to any questions relevant to this lawsuit and | must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Interrogatory No. 17.
+Provide the names, addresses, and phone numbers of all
+your current accountants, financial planners or money managers handling, or assisting
+in the handling, of your money or assets.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 24 of 27
+Page 10
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence.
+Interrogatory No. 18.
+Did you ever ask the Plaintiff to introduce you to minor
+females and/or to bring minor females to your house in Palm Beach, Florida and if so,
+when did this occur, and what was she asked by you to do, and what did you tell her
+about the reason for her to bring these other minor girls?
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that | cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Interrogatory No. 19.
+Did you ever engage in sexual activity of any kind
+whatsoever with the Plaintiff, and include in your answer what type of sexual activity
+took place, where it took place, and the dates or general timeframe when this activity
+occurred.
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that I cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+
+
+Case 9:08-cV-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 25 of 27
+Page 11
+Interrogatory No. 20.
+Were there parameters or instructions by you to the Plaintiff
+as to the types of girls to bring to your Palm Beach, Florida house, including age range,
+what they would be asked to do, body type or socio-economic background?
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that I cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Interrogatory No. 21.
+Describe any words or actions that you made to assure the
+Plaintiff that sexual activity with you was property or appropriate?
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that | cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Interrogatory No. 22.
+Describe what age you thought the Plaintiff was when you
+first had sexual activity with her, including your reasons for that belief.
+Answer: Defendant asserts specific U.S. constitutional privileges. I intend to respond
+to all relevant questions regarding this lawsuit, however, my attorneys have counseled
+me that I cannot provide answers to any questions relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth, Sixth, and
+Fourteenth Amendments as guaranteed by the United States Constitution. Drawing an
+adverse inference under these circumstances would unconstitutionally burden my
+exercise of my constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 26 of 27
+Jane Doe V. Epstein, et al.
+Page 12
+Interrogatory No. 23.
+defense in your answer.
+State the facts upon which you rely for each affirmative
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to ali relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that | cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. in additior
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is so overbroad and, thus, seeks information that is neither relevant to the
+subject matter of the pending action nor does it appear reasonably calculated to lead to
+the discovery of admissible evidence. No answer has yet been filed, so not applicable
+(RDC)
+I have read the foregoing answers to Interrogatories and do swear that they are true
+and correct.
+Jeffrey Epstein
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+SWORN TO AND SUBSCRIBED before me this 1f day of la
+_ 2009 by
+Jeffrey Epstein,
+who is personally known to me or has produced the following
+identification
+which is current or has been issued within
+the past five years and bears a serial or other identifying number.
+MAHONEY
+CC
+Ш
+I
+cD:
+My Comm: Expire
+Print Name
+6 Signature
+1l2 Make
+CC
+NOTARY PUBLIC - STATE OF FLORIDA
+STATE OF
+
+
+Case 9:08-cv-80119-KAM Document 343 Entered on FLSD Docket 10/06/2009 Page 27 of 27
+Page 13
+Commission Number:
+My commission expires:
+(Notary Seal)
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.md b/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.md
new file mode 100644
index 0000000000000000000000000000000000000000..d221c57d8fea96fad0032714675732378df7ef8f
--- /dev/null
+++ b/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.md
@@ -0,0 +1,304 @@
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF,
+JANE DOE NO. 3, To ANSWER DEFENDANT'S FIRST SET OF
+INTERROGATORIES AND TO OVERRULE OBJECTIONS, AND
+FOR AN AWARD OF DEFENDANT'S REASONABLE EXPENSES
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order compelling Plaintiff, JANE DOE No. 3 to answer
+Defendant's First Set of Interrogatories and to overrule her objections asserted in
+Plaintiff's Answers To Defendant's First Interrogatories, dated January 26, 2009.
+Defendant further seeks an award of his reasonable expenses, including expenses,
+associated with the making of this motion. Rule 37, Fed.R.Civ.P. (2008); Local Gen.
+Rules 7.1 and 26.1 H (S.D. Fla. 2008). In support of his motion, Defendant states:
+Introduction
+Prior to the filing of this motion, counsel for Defendant and counsel for Plaintiff
+corresponded with each other and were able to resolve some of the discovery issues
+related to Defendant's First Interrogatories and Plaintiff's answers and objections
+thereto. By letter, dated March 3, 2009, the Plaintiff agreed to withdraw her "General
+Objections" set forth in her response. As well, issues as to interrogatories nos. 10 and
+14 are presently resolved.
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 2 of 9
+Page No. 2
+Also, Defendant has filed simultaneously with this motion a Motion To Compel
+directed to certain of Plaintiff's Responses to Defendant's First Request To Produce,
+also dated January 26, 2009, and which addresses identical discovery issues. Both
+motions should be determined at the same time.
+Motion To Compel Answers to Interrogatories Nos. 18, 19, 20, and 21
+18.
+List separately the names, addresses and phone numbers of all males,
+excluding Mr. Epstein, with whom you have had sexual activity since age 10 (by year)
+up through your current age. Describe the nature of sexual activity, the date(s) and
+whether you received money or other consideration from the person
+19. List separately the names, addresses and phone numbers of all males,
+excluding your claims against Mr. Epstein,
+whom you have claimed (formally or
+informally) committed sexual assault or battery on you since age 10 (by year) up
+through your current age. Describe the nature of sexual assault or battery, the date(s)
+and whether you received money or other consideration from the person
+State the names, addresses and phone numbers of all males, excluding
+your claims against Mr. Epstein,
+whom you have claimed (formally or informally)
+committed lewd or lascivious conduct to you since age 10 (by year) up through your
+current age. Describe the lewd or lascivious conduct, the date and whether you
+received money or other consideration from the person
+21.
+State the names, addresses and phone numbers of all males, excluding
+your claims against Mr. Epstein,
+whom you have claimed (formally or informally)
+committed lewd or lascivious exhibition to you since age 10 (by year) up through your
+current age. Describe the lewd or lascivious exhibition, the date and whether you
+received money or other consideration from the person
+Plaintiff asserted the identical answer to each of the above stated interrogatories:
+Answer:
+Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome,
+harassing, and not reasonably calculated to lead to discovery of admissible evidence.
+Moreover, this interrogatory is outrageous, offensive and apparently posed for the
+purpose of intimidating the victim.
+Fed.R.Evid. 412 makes any answer to this
+interrogatory inadmissible, and nothing in the answer could plausibly lead to discovery
+of admissible evidence.
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 3 of 9
+Page No. 3
+Legal Argument Supporting Entitlement to Discovery
+Plaintiff does not make a relevancy objection, but instead claims that the
+requests are "not reasonably calculated to lead to the discovery of admissible
+evidence," claiming that such "evidence ... would not be admissible under Fed.R.Evid.
+412." Plaintiff further claims, without making any showing in her answer and without
+moving for a protective order in accordance with Rule 26(c) and Local Gen. Rule 26.1 H
+(S.D. Fla. 2008), that the interrogatory is "harassing,' "outrageous, offensive and is
+apparently posed for the purpose of intimidating Plaintiff."
+It is well settled that relevant information is discoverable, even if not admissible at
+trial, so long as the discovery is reasonably calculated to lead to the discovery of
+admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.; Donahay v. Palm Beach Tours &
+trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007). Contrary to Plaintiff's assertion, Rule 412
+does not automatically result in a determination that such sexual history and sexual
+activity/behavior information is never admissible. In fact, written into the Rule are the
+procedures to follow in determining when such information is admissible at trial. The
+Advisory Committee Notes to Rule 412, Fed.R.Evid, makes clear that the procedures to
+determine admissibility of an alleged victim's/plaintiff's sexual conduct or activity in civil
+cases does not apply to discovery of such information. Rather, discoverability of such
+information is governed by Rule 26, Fed.R.Civ.P., pursuant to which the scope of
+discovery is broad. Donahay, supra, at 686, and cases cited therein. "Parties may
+obtain discovery regarding any matter, not privileged, which is relevant to the claims or
+defense of any party involved in the pending action." Id.
+Rule 412, entitled "Sex Offense Cases; Relevance of Alleged Victim's Past
+Sexual Behavior or Alleged Sexual Predisposition," provides in relevant part -
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 4 of 9
+Page No. 4
+(a) Evidence generally inadmissible.--The following evidence is not admissible
+in any civil ... proceeding involving alleged sexual misconduct except as
+provided in subdivisions (b) and (c):
+(1) Evidence offered to prove that any alleged victim engaged in other sexual
+behavior.
+(2) Evidence offered to prove any alleged victim's sexual predisposition.
+(b) Exceptions.—
+*
+*
+*
+(2) In a civil case, evidence offered to prove the sexual behavior or sexual
+predisposition of any alleged victim is admissible if it is otherwise admissible
+under these rules and its probative value substantially outweighs the danger of
+harm to any victim and of unfair prejudice to any party. Evidence of an alleged
+victim's reputation is admissible only if it has been placed in controversy by the
+alleged victim.
+(c) Procedure to determine admissibility.--
+(1) A party intending to offer evidence under subdivision (b) must—
+(A) file a written motion at least 14 days before trial specifically describing
+the evidence and stating the purpose for which it is offered unless the court, for
+good cause requires a different time for filing or permits filing during trial; and
+(B) serve the motion on all parties and notify the alleged victim or, when
+appropriate, the alleged victim's guardian or representative.
+(2) Before admitting evidence under this rule the court must conduct a
+hearing in camera and afford the victim and parties a right to attend and be
+heard. The motion, related papers, and the record of the hearing must be
+sealed and remain under seal unless the court orders otherwise.
+In confirming that Rule 412 does not control the discoverability of such
+information, the Advisory Committee Notes (1994 Amendments) state -
+The procedures set forth in subdivision (c) do not apply to discovery of a
+victim's past sexual conduct or predisposition in civil cases, which will be
+continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the
+rationale of Rule 412, however, courts should enter appropriate orders pursuant
+to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and
+to ensure confidentiality. Courts should presumptively issue protective orders
+barring discovery unless the party seeking discovery makes a showing that
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 5 of 9
+Page No. 5
+the evidence sought to be discovered would be relevant under the facts
+and theories of the particular case, and cannot be obtained except
+through discovery. In an action for sexual harassment, for instance, while
+some evidence of the alleged victim's sexual behavior and/or predisposition in
+the workplace may perhaps be relevant, non-work place conduct will usually be
+irrelevant. Cf.
+_v. McGregor Electronic Industries, Inc., 989 F.2d 959, 962-
+63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant
+to issue of unwelcomeness of sexual advances at work). Confidentiality
+orders should be presumptively granted as well.
+(Emphasis added).
+In accordance with Rule 412 and Rule 26, the discovery sought regarding
+Plaintiff's sexual activity with males, including whether she received any compensation
+or consideration therefore, in interrogatory no. 18, whether she claims other males
+committed sexual assault or battery on her in no. 19, whether she claims other males
+committed lewd and lascivious conduct to her in no. 20, and whether other males
+committed lewd or lascivious exhibition to her in no. 21, are all relevant to Plaintiff's
+damages claims and the type of injury she claims she has suffered. Defendant has no
+other means of obtaining such information and obtaining such information through
+Plaintiff will better protect the confidentiality until the Court can make a determination in
+accordance with the procedures under Rule 412(c) whether such information will be
+admissible at trial. See Rule 412(c) quoted above. Defendant will agree to an order
+keeping the confidentiality of the information obtained through discovery.
+The evidence sought is relevant based on the facts and theories of this action.
+In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for
+"Sexual Assault and Battery," Count Il for "Intentional Infliction of Emotional Distress,"
+and in Count III for "Coercion and Enticement to Sexual Activity in Violation of 18
+U.S.C.A. §2422," and seeks damages pursuant to 18 U.S.C. §2255(a). (Plaintiff alleges
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 6 of 9
+Page No. 6
+diversity of citizenship as a basis for this Court's jurisdiction. 2d Am. Complaint, 15).
+Counts I and Il are brought pursuant to state law.
+In her complaint, Plaintiff alleges that "she has suffered and will continue to suffer
+severe and permanent traumatic injuries, including mental, psychological and emotional
+damages," and "severe mental anguish and pain." She also seeks compensatory
+damages for her alleged injuries. 2d Am. Complaint, 11121, 27, 33, and "Wherefore"
+clauses. In her answers to interrogatories nos. 9 and 10, Plaintiff further states that:
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation, anxiety, depression, suicidal ideation, guilt, self-blame,
+feelings of being degraded, feeling unattractive, diminished sense of femininity,
+fluctuations in weight/appetite, sexual intimacy problems, flashbacks, disturbing
+memories, stress, irritability, feelings of being isolated and trapped, diminished
+trust, social problems, problems in personal relationships, indecisiveness, lower
+energy, lower ambition and initiative, headaches, back pain, feels stress
+(particularly around men), obsessive thoughts, problems concentrating, alcohol
+abuse, corruption of morals and values, loss of innocence, and cries a lot.
+(Interrog. No. 9).
+... she seeks damages arising from her psychological and emotional
+injuries. These damages include pain and suffering, costs of psychological care
+and treatment, and loss of earning capacity.... (Interrog. No. 10).
+Plaintiff also alleges that "
+a Palm Beach Community College
+student," was a part of "Epstein's plan and scheme (which) reflected a particular pattern
+and method" in the alleged recruiting of girl's to come to EPSTEIN's Palm Beach
+mansion and give him "massages" in exchange for money. 2^d Am. Complaint, 110-12.
+According to the complaint allegations - "Upon information and belief Epstein has a
+sexual preference and obsession for underage minor girls." 18. The "girl would be led
+up a flight of stairs to a bedroom that contained a massage table ... The girl would be
+alone with EPSTEIN; "Epstein would then perform one or more lewd, lascivious and
+sexual acts, including masturbation and touching the girl sexually." 2°° Am. Complaint,
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 7 of 9
+Page No. 7
+111, 12. Plaintiff alleges that 'in 2004-2005," she, "then approximately 16 years old, fell
+into Epstein's trap and became one of his victims." 178. Plaintiff alleges that Epstein
+"sexually assaulted" her and "masturbated during the massage." 1|12 Plaintiff further
+alleges that "Epstein committed willful acts of child sexual abuse" on her, which resulted
+in "mental or sexual injury," and "caused or likely to cause Jane Doe's mental or
+emotional health to be significantly impaired." 2d Am. Complaint, 125.
+The information sought is clearly relevant to the injuries and damages claimed by
+Plaintiff. The nature of her claimed injuries and damages are such that Defendant is
+entitled to evidence which would show the nature of her relationship with males,
+whether she has suffered other acts of sexual misconduct as alleged in her complaint,
+and whether she suffered injury and damages as a result of the other claimed sexual
+misconduct with males. See United States v. Bear Stops, 997 F.2d 451 (8 Cir.
+1993)(Defendant charged with sexual abuse of six year old boy was entitled to
+admission of evidence relating to victim's sexual assault by 3 older boys to establish
+alternative explanation for why victim exhibited behavioral manifestations of sexually
+abused child.).
+In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d
+1076 (Fla. 5" DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as
+Exhibit A as it is on point to the discovery issues in this action, and the relevancy and
+discoverability of Plaintiff's history of sexual activity and any payment, therefore. See
+interrogatories
+: 8, 22 and 30 propounded in the Balas case and footnote 1 herein. '
+" In Balas v. Ruzzo, supra, the Plaintiffs alleged a multicount complaint including claims for
+"coercion of prostitution" pursuant to $796.09, Fla. Stat.; for battery for the unwanted and
+offensive touching of petitioners' bodies; false imprisonment for physically confining the
+petitioners against their will; invasion of privacy; and intentional infliction of emotional distress.
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 8 of 9
+Page No. 8
+Additionally and significantly, in other pending state court civil actions against Defendant
+EPSTEIN attempting to assert similar claims and damages, the Circuit Court Judges
+have already ruled that such information is discoverable as it is relevant to the damages
+claims of Plaintiff. See Composite Exhibits B and C hereto. Composite Exhibit B
+are the Orders, dated February 23, 2009, entered in the case of A.C. v. Epstein, and
+Case No. 502008CA025129 MB Al, 15"* Judicial Circuit, In and For Palm Beach
+County, State of Florida, which granted Defendant's motion to compel therein directed
+to discovery identical to interrogatory no. 18 above, and to requests for production nos.
+17 and 18 addressed below herein. (In the A.C. case, the Plaintiff answered without
+objection interrogatories identical to nos. 19, 20, and 21 herein.) Composite Exhibit C
+is a portion the transcript from a March 3, 2009 hearing on Defendant's motion to
+Case No.
+compel discovery in the case of Jane Doe II v. Epstein, and
+502008CA020614 MB AF, 15" Judicial Circuit Court, In and For Palm Beach County,
+State of Florida. Again, the Circuit Court Judge determined that the information sought
+is relevant to the issue of damages and, thus, discoverable.
+WHEREFORE, Defendant requests that this Court grant his motion to compel
+and award his attorney's fees and costs, associated with this motion, in accordance with
+Rule 37, Fed.R.Civ.P., and applicable Local Rules.
+Rule 7.1 Certification
+I hereby certify that counsel for the respective parties communicated by letters in
+a good faith effort to resolve the discovery issues prior to the filing of this motion to
+compel. Some of the issues were resolved.
+Robert D. Cultton, Jr.
+Attorney for Defendant Epstein
+
+
+Case 9:08-cv-80232-KAM Document 60 Entered on FLSD Docket 04/02/2009 Page 9 of 9
+Page No. 9
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+nanner specified by CM/ECF on this fday of April, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No! 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.receipt.json b/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4db2b5fd4ad9a2ff55b873fa331aa316ea2e9e99
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+++ b/vision-fixhub/court-01/e97902fd3257e38ba9a7c05fada76ac80cc0cda9deaf0aed97b2e4a6bee00e1a.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "d8f3b3860c2d1a4661459cc1c5831d758153ae99c496ed8b59c1af4cd39620e2",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.md b/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.md
new file mode 100644
index 0000000000000000000000000000000000000000..f8c7bbbb8d222da198aa9f183853cd0595985a08
--- /dev/null
+++ b/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.md
@@ -0,0 +1,74 @@
+Case 9:08-cv-80381-KAM Document 35 Entered on FLSD Docket 07/29/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80119-CIV-KAM-LRJ
+JANE DOE NO. 2,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 3,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 4,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 5,
+VS.
+JEFFREY EPSTEIN.
+CASE NO.: 08-80232-CIV-KAM-LRJ
+CASE NO.: 08-80380-CIV-KAM-LRJ
+CASE NO.: 08-80381-CIV-KAM-LRJ
+DEFENDANT'S NOTICE OF FILING EXHIBITS
+Defendant Jeffrey Epstein hereby files the following two exhibits to his Reply in Support
+of Motion to Stay, filed under seal on July 28, 2008:
+A.
+Exhibit "A" is the July 9, 2008 Declaration of Assistant United States Attorney Ann
+— C. Villafana, previously filed by the United States in In re: Jane Doe, Case No. 08-
+80736-CIV-Marra/
+(S.D. Fla.) (DE 14).
+Lewis Tein.
+
+
+Case 9:08-cv-80381-KAM Document 35 Entered on FLSD Docket 07/29/2008 Page 2 of 3
+B.
+Exhibit "B" is a copy of Title 18, United States Code, section 1595.
+These exhibits were inadvertently omitted from the reply memorandum.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101 Fax: 305 442 6744
+By:
+Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300 Fax. 561 835 8691
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that on July 29, 2007, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
+is being served this day on all counsel of record on the attached service list by transmission of
+Notice of Electronic Filing generated by CM/ECF.
+Is/ Michael R. Tein
+2
+Tein.
+
+
+Case 9:08-cv-80381-KAM Document 35 Entered on FLSD Docket 07/29/2008 Page 3 of 3
+SERVICE LIST
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, Florida 33160
+3
+Teinr.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.receipt.json b/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..25debd298a09727a2656562bd65f0d7da0511e80
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+++ b/vision-fixhub/court-01/e99d4d9fcfe9dd85feb3092bbd9392a384c5e3c34425fb9f917b634ab2bd81e6.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "fa70d5051e934ddc4534a34c6df112cb70db70badb56854a9953287e66d0a766",
+  "output_sha256": "103fdc85baa7269cdd8a247dffe9f672077ca69fa3564aa9263db55bb0f7c361",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.md b/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..9bb1bb2fab81c47e7e14bfb23d5e5d01a3238831
--- /dev/null
+++ b/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.md
@@ -0,0 +1,29 @@
+Case 1:19-cv-10577-LJL-DCF Document 33 Filed 02/28/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff.
+V.
+DARREN I. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendants.
+Case No. 1:19-cv-10577-LJL-DCF
+NOTICE OF DEFENDANTS' MOTION TO DISMISS
+PLEASE TAKE NOTICE that upon the accompanying Memorandum of Law and all prior
+pleadings and proceedings in this action, Defendants will move this Court before the Hon.
+J. Liman, United States District Judge, at the Daniel
+Moynihan United States Courthouse,
+500 Pearl St., New York, NY 10007, at a time to be scheduled by this Court, for an Order pursuant
+to Rule 12(D(6) of the Federal Rules of Civil Procedure dismissing Plaintiff Jane Doe 1000's
+Complaint and claims for punitive damages with prejudice (ECF No. 1); and for such other and
+further relief as may be just and proper.
+Dated: New York, New York
+February 28, 2020
+By: /s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Attorneys for Defendants
+41605963vl
diff --git a/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.receipt.json b/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c2e343ec58be698e3f8574366640ad642af39f81
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+++ b/vision-fixhub/court-01/e9d6d9a7f0ca6d8859c4aa0b9451ea343a595089c568343a02db8f75897a27ee.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e77d0d6dc439fe924ee9fa8edab843e0fed765c3238892de015c58a665e76f1c",
+  "output_sha256": "86b63397552caf895f04f70c4a6872b1ca8fb6ea4dd4b88c3faaa34bf6268aec",
+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.md b/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.md
new file mode 100644
index 0000000000000000000000000000000000000000..8d6bc8efe412041fad31fe208f0cbf7ee71544f1
--- /dev/null
+++ b/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.md
@@ -0,0 +1,32 @@
+Case 9:09-cv-80802-KAM Document 19-1
+Entered on FLSD Docket 11/20/2009 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+AGREED ORDER ON DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+(AS TO CMA V. EPSTEIN AND
+08-CIV-80811)
+This matter came before the Court on Defendant Epstein's Motion to Attend
+Mediation and Plaintiffs counsel being in agreement with the entry of this order, it is
+HEREBY ORDERED and ADJUDGED that:
+The court's no contact order, [DE 238], shall not preclude Defendant Epstein
+deposition, mediation, or the trial of this
+from attending Plaintiff
+case.
+DONE and ORDERED this
+_day of
+_ 2009
+Linnea R.
+United States Magistrate Judge
+Courtesy Copies:
+Judge Kenneth Marra
+Counsel of record
diff --git a/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.receipt.json b/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7d9b877772bd0dd2a7a0684d81313a7888b99040
--- /dev/null
+++ b/vision-fixhub/court-01/e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "e9eb896e5b4162da34d4fe9727ad46172384d9461acf176caeb8bbc3994d5fdd",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e3cbe73c75476258a973db4c1d106b19aef6e2e6d1e6e54f6db951d3e454f1bd",
+  "output_sha256": "8d11716c9b2730be505a467e4514f35b271adacd70d2b5b48bde6a07eccea2c6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/e9eee9555a06c710776c80c5f9617c90675bb81ca6e56571fa6965a855850bdf.md b/vision-fixhub/court-01/e9eee9555a06c710776c80c5f9617c90675bb81ca6e56571fa6965a855850bdf.md
new file mode 100644
index 0000000000000000000000000000000000000000..0343325d66bc5166975b560f472dae8895a38699
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@@ -0,0 +1,376 @@
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 1 of 13
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE AND RICHARD D. KAHN,
+in their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN, GHISLAINE
+MAXWELL, an individual,
+Defendants.
+Index No. 1:20-cv-00484-JGK-DCF
+STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER
+WHEREAS, Plaintiff Jane Doe, Defendants Darren K. Indyke and Richard D. Kahn, Co-
+Executors of the Estate of Jeffrey E. Epstein, and Defendant Ghislaine Maxwell (collectively, the
+"Parties" and each individually, a "Party") request that this Court issue a protective order pursuant
+to Federal Rule of Civil Procedure 26(c) to protect the confidentiality of nonpublic and sensitive
+information that they may need to disclose in connection with discovery in this action;
+WHEREAS, the Parties, through counsel, agree to the following terms; and
+WHEREAS, this Court finds that good cause exists for issuance of an appropriately
+tailored confidentiality order governing the pretrial phase of this action;
+IT IS HEREBY ORDERED that the Parties to this action, their respective agents,
+employees, and attorneys, any other person in active concert or participation with any of the
+foregoing, and all other persons with actual notice of this Order will adhere to the following
+terms, upon pain of contempt:
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 2 of 13
+"Producing Party" shall mean the parties to this action and any third parties
+producing Confidential Information.
+"Receiving Party" shall mean the party to this action and/or any non-party
+receiving Confidential Information.
+3.
+With respect
+, "Discovery Material" (i.e., documents, depositions and
+deposition exhibits, information or tangible things of any kind produced or disclosed in the course
+of discovery in this action) that a Producing Party has designated as "Confidential" pursuant to
+this Order, no Receiving Party may disclose such Confidential Discovery Material to anyone else
+except as expressly permitted hereunder.
+4.
+The Producing Party may designate as Confidential only the portion of such
+material that it reasonably and in good faith believes consists of information whose public release
+would violate common law and statutory privacy interests, including without limitation,
+information concerning:
+(a) medical, mental health and/or other psychological conditions;
+(b) medical or psychological treatment;
+(c) other health care records;
+(d) use of controlled substances;
+(e) consensual or non-consensual sexual activity, sexual contact, or alleged sexual
+abuse;
+(f) education records;
+(g) email addresses, home addresses, Social Security numbers, personal telephone
+numbers, tax returns, and credit and banking information of any person, or similarly
+personally identifying information for parties and third-party witnesses;
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 3 of 13
+(h) names of alleged minor victims of sexual abuse;
+(i) any information subject to N.Y. Civil Rights Law §$ 50 or 51;
+(i) previously non-disclosed financial information including personal financial
+information;
+(k) non-public information that the producing person in good faith considers to
+be, reflect, or reveal business, marketing, financial, or regulatory information or
+data, or information of commercial value, including, without limitation, trade
+secrets, contracts with third parties, or other information required by law or
+agreement to be kept confidential; and
+(1) any other category of information given confidential status by this Court or a
+Court of competent jurisdiction to include the tort of publication of private facts.
+With respect to the Confidential portion of any Discovery Material other
+than deposition transcripts and exhibits, the Producing Party or its counsel may designate
+such portion
+as "Confidential" by: (a) stamping or otherwise clearly marking as
+"Confidential" the protected portion in a manner that will not interfere with legibility or
+audibility; and (b) producing for future public use another copy of said Discovery Material
+with the confidential information redacted.
+A Producing Party or its counsel may designate deposition exhibits or portions
+of deposition transcripts as Confidential Discovery Material either by: (a) indicating on the
+record during the deposition that a question calls for Confidential information, in which case the
+reporter will bind the transcript of the designated testimony in a separate volume and mark it as
+"Confidential Information Governed by Protective Order;" or (b) notifying the reporter and all
+counsel of record, in writing, within 30 days after a deposition has concluded, of the specific
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 4 of 13
+pages and lines of the transcript that are to be designated "Confidential," in which case all
+counsel receiving the transcript will be responsible for marking the copies of
+the designated transcript in their possession or under their control as directed by the Producing
+Party or that person's counsel. During the 30-day period following a deposition, all Parties will
+treat the entire deposition transcript as if it had been designated Confidential.
+7.
+If at any time before the termination of this action a Producing Party realizes
+that it should have designated as Confidential some portion(s) of Discovery Material that it
+previously produced without limitation, the Producing Party may so designate such material by
+notifying all Parties in writing. Thereafter, the Receiving Party will treat such designated
+portion(s) of the Discovery Material as Confidential. In addition, the Producing Party shall
+provide each Receiving Party with replacement versions of such Discovery Material that bears
+the "Confidential" designation within two business days of providing such notice.
+8.
+Nothing contained in this Order will be construed: (a) as a waiver by a Party or
+person of its right to object to any discovery request; (b) so as to prejudice a Party's ability to
+seek discovery in this or any other legal proceedings; nor to a Party's ability to object to such
+discovery; (c) as a waiver of any privilege or protection; or (c) as a ruling regarding the
+admissibility at trial of any document, testimony, or other evidence.
+Where a Producing Party has designated Discovery Material as Confidential,
+the Receiving Party may disclose such information only to the following persons:
+(a) the Parties to this action;
+(b)counsel of record to the Parties, including any paralegal, clerical, or other
+assistant that such counsel employs and assigns to this matter;
+
+
+Case 1:20-Cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 5 of 13
+10.
+(c) outside vendors or service providers (such as copy-service providers and
+document-management consultants) that counsel hire and assign to this
+matter, provided such person has first executed a Non-Disclosure Agreement
+in the form annexed as Exhibit A hereto;
+(d) any mediator or arbitrator that the Parties engage in this matter or that
+this Court appoints, provided such person has first executed a Non-
+Disclosure Agreement in the form annexed as Exhibit A hereto;
+(e) as to any document, its author, its addressee, and any other person indicated
+on the face of the document as having received a copy;
+(f) any witness who counsel for a Party in good faith believes may be called to
+testify at trial or deposition in this action, and such person's counsel, provided
+such person has first executed a Non-Disclosure Agreement in the form annexed
+as Exhibit A hereto;
+(g) any person a Party retains to serve as an expert witness or otherwise provide
+specialized advice to counsel in connection with this action, provided such person
+has first executed a Non-Disclosure Agreement in the form annexed as Exhibit
+A hereto;
+(h) stenographers engaged to transcribe depositions the Parties conduct in
+this action; and
+(i) this Court, including any appellate court, its support personnel, and
+court reporters.
+Before disclosing any Confidential Discovery Material to any person referred to
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 6 of 13
+in subparagraphs 9(c), 9(d), 9(f), or 9(g) above, counsel must provide a copy of this Order to such
+person, who must sign a Non-Disclosure Agreement in the form annexed as Exhibit A hereto stating
+that he or she has read this Order and agrees to be bound by its terms. Said counsel must retain each
+signed Non-Disclosure Agreement, hold it in escrow, and produce it to opposing counsel either
+before such person is permitted to testify (at deposition or trial) or at the conclusion of the case
+including any and all appeals, whichever comes first.
+11.
+For the avoidance of doubt, nothing in Paragraph 9 shall impose any limitation
+on the ability of a Producing Party to disclose its own Confidential Discovery Material; provided,
+however, that nothing in this Section precludes an argument or judicial determination that, by
+voluntarily disclosing its own Confidential Discovery Material outside this litigation, a Producing
+Party has waived confidentiality claims over such materials. A Producing Party shall not be
+required to obtain an executed Non-Disclosure Agreement from its own current or former
+employees with respect to disclosure of its own Confidential Discovery Material.
+12.
+This Order binds the Parties and certain others to treat as Confidential any
+Discovery Materials so classified. The Court has not, however, made any finding regarding the
+confidentiality of any Discovery Materials, and retains full discretion to determine whether to
+afford confidential treatment to any Discovery Material designated as Confidential hereunder.
+All persons are placed on notice that the Court is unlikely to seal or otherwise afford confidential
+treatment to any Discovery Material introduced into evidence at trial, even if such material has
+previously been sealed or designated as Confidential.
+13.
+In filing Confidential Discovery Material with this Court, or filing portions of any
+pleadings, motions, or other papers that disclose such Confidential Discovery Material
+(Confidential Court Submission"), the Parties shall publicly file a redacted copy of the
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 7 of 13
+Confidential Court Submission via the Electronic Case Filing System. The Parties shall file an
+unredacted copy of the Confidential Court Submission under seal with the Clerk of this Court,
+and the Parties shall serve this Court and opposing counsel with unredacted courtesy copies of
+the Confidential Court Submission. Any Party that seeks to file Confidential Discovery Material
+under seal must file an application and supporting declaration justifying—on a particularized
+basis—the sealing of such documents. The parties should be aware that the Court will unseal
+documents if it is unable to make "specific, on the record findings ... demonstrating that closure
+is essential to preserve higher values and is narrowly tailored to serve that interest." Lugosch v.
+Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006). Notwithstanding any other
+provision of this paragraph, if the parties stipulate that specific portions of a document are both
+confidential and immaterial to this lawsuit, a party may publicly file a version of the document
+with those confidential and immaterial portions redacted, and that party need not submit an
+unredacted version to the Court or file a motion to seal.
+14.
+Any Party who objects to any designation of confidentiality may at any time
+before the trial of this action serve upon counsel for the Producing Party a written notice stating
+with particularity the grounds of the objection. If the Parties cannot reach agreement promptly,
+counsel for all affected Parties will address their dispute to the Court by motion. The Party seeking
+confidentiality shall bear the burden of establishing that the material at issue was properly
+designated as confidential. The Parties shall treat the disputed materials as Confidential pending
+the Court's resolution of such motion.
+15.
+Any Party who requests additional limits on disclosure (such as "attorneys' eyes
+only" in extraordinary circumstances), may at any time before the trial of this action serve upon
+counsel for the recipient Parties a written notice stating with particularity the grounds of the
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 8 of 13
+request. If the Parties cannot reach agreement promptly, counsel for all affected Parties will
+address their dispute to the Court.
+16.
+Absent an Order from a court of competent jurisdiction, Recipients of Confidential
+Discovery Material under this Order may use such material solely for the prosecution and defense
+of this action and any appeals thereto, and not for any other purpose or in any other litigation
+proceeding, including in any criminal action that involves any of the parties to this action, either as
+witnesses, defendants or otherwise. Nothing contained in this Order, however, will affect or
+restrict the rights of any Party with respect to its own documents or information produced in this
+action. Nor shall anything contained in this Order prejudice a Party's ability to seek discovery in
+this and any other legal proceedings, without prejudice to any other Party's right to object to such
+discovery.
+17.
+In the event that a party who has possession of Confidential Discovery Material
+pursuant to the terms of this Order receives a subpoena or other compulsory legal process which
+calls for the production of the Confidential materials, the person-in-possession shall respond that
+the materials are not disclosable absent an Order of the Court and shall promptly notify the
+Producing Party from whom they received the Confidential Discovery Material, and all other
+Parties, of the subpoena or other compulsory process. Such notice must be provided within 3
+business days of the receipt of the subpoena or other compulsory process. Upon receiving such
+notice, the Producing Party or other Parties will bear the burden to oppose compliance with the
+subpoena, other compulsory process, or other legal notice if the Producing Party or other Parties
+deem it appropriate to do so.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 9 of 13
+18.
+Each person who has access to Discovery Material designated as Confidential
+pursuant to this Order must take all reasonable precautions to prevent the unauthorized or
+inadvertent disclosure of such material.
+19.
+If a Receiving Party receives documents or other materials that it has reason to
+believe are subject to a good faith claim of attorney-client privilege, work product protection,
+or other privilege or immunity from disclosure, the Receiving Party must refrain from
+examining the documents or other materials any more than is essential to ascertain whether
+the documents or other materials are reasonably subject to such a claim. The Receiving Party
+shall promptly notify the producing person in writing that the Receiving Party possesses
+documents or other material that appears to be privileged or otherwise protected from
+disclosure.
+20.
+If, in connection with this litigation, a producing person inadvertently discloses
+information that is subject to a claim of attorney-client privilege, attorney work product
+protection, or any other privilege or immunity from disclosure (Inadvertently Disclosed
+Information"), such disclosure shall not constitute or be deemed a waiver or forfeiture of any
+claim of privilege, work product protection, or other privilege or immunity from discovery with
+respect to the Inadvertently Disclosed Information or its subject matter. In addition, a producing
+person may use its own document (e.g., as a deposition exhibit) containing material that is subject
+to a claim of privilege or immunity from disclosure for the purpose of establishing the basis of
+such claim without waiver of any applicable privilege or immunity from disclosure, unless the
+producing person affirmatively uses or relies upon the specific material contained in the document
+that is subject to the claim of privilege or immunity from disclosure for any purpose other than
+establishing the basis of such claim.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 10 of 13
+21.
+If a producing person makes a claim of inadvertent disclosure, the Receiving
+Party shall, within five business days, return or destroy all copies of the Inadvertently Disclosed
+Information, and provide a certification of counsel that all such information has been returned
+or destroyed, unless the Receiving Party seeks to dispute that the information is privileged or
+otherwise protected as set forth below. Until the dispute is resolved or ruled upon, the Receiving
+Party shall undertake to keep such information restricted solely for use in connection with the
+dispute over the privilege or protection.
+22.
+Within five business days after the notification that such Inadvertently Disclosed
+Information has been returned or destroyed, the producing person shall produce a privilege log
+with respect to the Inadvertently Disclosed Information.
+23.
+The Receiving Party may move the Court for an Order compelling production of
+the Inadvertently Disclosed Information. Pursuant to the parties' obligations set forth herein, the
+motion shall not quote or paraphrase the substance of the document subject to the motion to
+compel beyond the description of the document contained in the privilege log entry for the
+document. The motion shall be filed under seal, and shall not assert as a ground for entering such
+an Order the fact or circumstances of the inadvertent production in this action.
+24.
+The Producing Party retains the burden of establishing the privileged or
+protected nature of any Inadvertently Disclosed Information. Nothing in this Order shall limit
+the right of any Producing Party or Receiving Party to request an in camera review of the
+Inadvertently Disclosed Information.
+25.
+Unless the parties otherwise agree or a court of competent jurisdiction otherwise
+orders, within 60 days of the final disposition of this action—including all appeals—all Receiving
+Parties must either return Confidential Discovery Material—including all copies thereof—to the
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 11 of 13
+Producing Party, or destroy such material—including all copies thereof. In either event, by the 60-
+day deadline, the Receiving Party must certify its return or destruction by submitting a written
+certification to the Producing Party that affirms that it has not retained any copies, abstracts,
+compilations, summaries, or other forms of reproducing or capturing any of the Confidential
+Discovery Material. Notwithstanding the foregoing: (i) Discovery Materials that have been
+received electronically and that cannot be returned or destroyed must be electronically deleted and
+deleted from "trash" files, and the Receiving Party must take reasonable measures to ensure
+that unauthorized persons do not have access to Confidential information residing on the
+Receiving Party's computer server and back-up media; and (ii) outside counsel for the parties are
+permitted to retain one archival copy of all pleadings, motion papers, court filings made under
+seal, transcripts, legal memoranda, correspondence, attorney work product, written discovery
+responses, deposition and trial exhibits, and expert reports, even if such materials contain
+Confidential Discovery Material, subject to a continuing obligation to protect information
+designated Confidential pursuant to this Order.
+26.
+This Order will survive the termination of the litigation and will continue to
+be binding upon each Receiving Party.
+27.
+This Court will retain jurisdiction over all persons subject to this Order to
+the extent necessary to enforce any obligations arising hereunder or to impose sanctions for
+any contempt thereof.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20 Page 12 of 13
+SO STIPULATED AND AGREED.
+HADDON.
+&
+PANISH SHEA & BOYLE LLP
+. P.C.
+/s/ -
+-/s/--
+Laura A. Menninger
+150 E. 10th Avenue
+Denver, CO 80203
+(303) 831-7364
+Imenninger@hmflaw.com
+Counsel for Defendant Ghislaine
+Doe Maxwell
+Dated: August
+_, 2020
+2020 TROUTMAN PEPPER LLP
+Robert Glassman
+11111 Santa Monica Blvd.
+Los Angeles, CA 90025
+(310) 477-1700
+glassman@psblaw.com
+Counsel for Plaintiff Jane
+Dated: August
+/s/
+Bennet J. Moskowitz
+875 Third Avenue
+New York, New York 10022
+(212) 704-6000
+bennet.moskowitz@troutman.com
+Counsel for Defendants Darren K. Indyke
+and Richard D. Kahn, Co-Executors of
+the Estate of Jeffrey E. Epstein
+Dated: August _
+- 2020
+SO ORDERED.
+Dated:
+New York, New York
+DEBRA FREEMAN
+United States Magistrate Judge
+
+
+Case 1:20-cv-00484-JGK-DCF Document 76-1 Filed 08/26/20
+
+
+to Stipulated Confidentiality
+Agreement and Protective
+Order
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE AND RICHARD D. KAHN,
+in their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN, GHISLAINE
+MAXWELL, an individual,
+Defendants.
+Index No. 1:20-cv-00484-JGK-DCF
+NON-DISCLOSURE AGREEMENT
+I,
+, acknowledge that I have read and understand
+the Protective Order in this action governing the non-disclosure of those portions of Discovery
+Material that have been designated as Confidential. I agree that I will not disclose such
+Confidential Discovery Material to anyone other than for purposes of this litigation and that at
+the conclusion of the litigation I will return all discovery information to the party or attorney
+from whom I received it. By acknowledging these obligations under the Protective Order, I
+understand that I am submitting myself to the jurisdiction of the United States District Court for
+the Southern District of New York for the purpose of any issue or dispute arising hereunder and
+that my willful violation of any term of the Protective Order could subject me to punishment
+for contempt of Court.
+Date:
diff --git a/vision-fixhub/court-01/e9eee9555a06c710776c80c5f9617c90675bb81ca6e56571fa6965a855850bdf.receipt.json b/vision-fixhub/court-01/e9eee9555a06c710776c80c5f9617c90675bb81ca6e56571fa6965a855850bdf.receipt.json
new file mode 100644
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "1cb3eaa103259619fb939b506a24a316e2face9232dd3bda9d176132bff106fb",
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diff --git a/vision-fixhub/court-01/ea0ab826446da11a44b0db1d8036dcbe173a5b57275b4da01bf4f2c6b0a3e82a.md b/vision-fixhub/court-01/ea0ab826446da11a44b0db1d8036dcbe173a5b57275b4da01bf4f2c6b0a3e82a.md
new file mode 100644
index 0000000000000000000000000000000000000000..182fcd203c641ee2455a3010c1eeccddb95ca0dc
--- /dev/null
+++ b/vision-fixhub/court-01/ea0ab826446da11a44b0db1d8036dcbe173a5b57275b4da01bf4f2c6b0a3e82a.md
@@ -0,0 +1,217 @@
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/]
+1
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 2 of 8
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA1
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/C
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA /C
+2
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 3 of 8
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/JOHNSON
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRAJ
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS JANE DOES' 2-7 MOTION FOR PROTECTIVE
+ORDER AND INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, Jane Does 2-7 ("Plaintiffs" or individually, "Plaintiff"), by and through
+undersigned counsel, hereby file Plaintiffs' Motion for Protective Order, pursuant to
+S.D.Fla.L.R. 7.1, and state as follows:
+1.
+Plaintiffs Jane Does 2-7 are proceeding with a Jane Doe pseudonym as this case
+involves facts of the utmost intimacy and there is a genuine risk of psychological harm if their
+identities are disclosed. See Exhibit "A" (Declaration of Gilbert Kliman, M.D.) (See also DE
+144, Jane Does' 2-7 Response to Defendant's Motion to Compel Identity, et al.).
+3
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 4 of 8
+2.
+Despite the obvious need for Plaintiffs to have their identities protected,
+Defendant Jeffrey Epstein has employed investigators who have made repeated contacts with exboyfriends, former employers, and others who know nothing of the underlying facts of the case.
+These investigators have contacted such nonparties asking them for extensive personal
+information about a Plaintiff, such as names and contact information of former boyfriends and
+other friends and acquaintances in the Plaintiff's community.
+3.
+The Defendant's repeated contacts with these nonparties is harassing and
+designed to intimidate the Plaintiffs. The purpose and intent of these contacts is to brand the
+Plaintiffs as alleged sexual abuse victims to their families, friends and communities.
+4.
+A Motion is pending in which this Court is being asked to determine whether and
+how Defendant may obtain discovery from nonparties. (DE 91, 144). Defendant's investigative
+efforts improperly circumvent the issues in the pending Motion, and only serve to highlight the
+need for this Court to implement appropriate protective measures to prevent Defendant from
+harassing, intimidating, and intruding unnecessarily into the personal lives of the Plaintiffs.
+5.
+While it is not unusual for a defendant to use appropriate means to obtain records
+from former employers and others referenced in a plaintiff's discovery responses, it is not
+customary for a defendant to retain private investigators to make personal contact with these
+individuals. Indeed, this practice is particularly inappropriate in a sexual abuse case where these
+nonparties are unaware of the underlying abuse. Plaintiffs have a well-grounded fear that the
+investigators will use the opportunity of their contacts with these nonparties to "out" the
+Plaintiffs' as alleged childhood sexual abuse victims of Jeffrey Epstein. (See Kliman Decl., Exh.
+"A" hereto).
+4
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 5 of 8
+6.
+As an example of the investigators' intimidation tactics, three of Defendant's
+investigators recently called the former employer of Jane Doe 4 on repeated occasions over a
+two-day period, asking personal questions about her, including the name and telephone number
+of her ex-boyfriend. See Exhibit "B", Declaration of Jane Doe 4.
+7.
+Similarly, one of Defendant's investigators contacted the former employer of Jane
+Doe 6. See Exhibit "C", Declaration of Jane Doe 6.
+8.
+There is no basis for Defendant or his multiple investigators to make repeated
+personal contacts with former employers and ex-boyfriends to ask personal questions about a
+Plaintiff. It is apparent that these contacts are not designed to obtain relevant information, but
+rather are intended to intimidate the Plaintiffs and to reveal that they are childhood sexual abuse
+victims.
+9.
+Accordingly, Plaintiffs request the entry of a protective order that would prevent
+Defendant, his attorneys and investigators from making ex parte contacts concerning this
+litigation with nonparties who have no knowledge that a Plaintiff was a childhood sexual abuse
+victim of Jeffrey Epstein.
+10. This Court has discretion to enter a protective order designed to protect a party
+from, among other things, annoyance or embarrassment. Fed.R.Civ.P. 26(c). As set forth above,
+given the investigators' conduct, a protective order is appropriate to prevent unnecessary
+intrusion into the Plaintiffs' personal lives and divulgation of Plaintiffs in their communities as
+childhood sexual abuse victims.
+WHEREFORE, Plaintiffs Jane Does 2-7, respectfully request that this Court grant
+Plaintiffs' Motion for Protective Order, as follows: (i) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties identified in plaintiffs" discovery
+5
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 6 of 8
+responses, such as, for example, former employers; (ii) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties found during the course of
+discovery or investigation who know the Plaintiff or live in her community, such as, for example,
+current and former boyfriends and family friends of the Plaintiffs; (il) order Defendant, his
+attorneys and investigators to cease making ex parte contacts with nonparties who otherwise
+know one of the Plaintiffs personally but who are unaware that she is an alleged victim of
+childhood sexual abuse by Jeffrey Epstein; and (iv) grant all such other relief this Court deems
+just and appropriate.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: July 29, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+6
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on July 29, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+7
+
+
+Case 9:08-cv-80380-KAM Document 143 Entered on FLSD Docket 07/29/2009 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Is/ Adam D. Horowitz
+8
diff --git a/vision-fixhub/court-01/ea0ab826446da11a44b0db1d8036dcbe173a5b57275b4da01bf4f2c6b0a3e82a.receipt.json b/vision-fixhub/court-01/ea0ab826446da11a44b0db1d8036dcbe173a5b57275b4da01bf4f2c6b0a3e82a.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/ea256e4e452c00b6a3a3ffd2fb967761e754541969cc271bcb81f6be6f30129b.md b/vision-fixhub/court-01/ea256e4e452c00b6a3a3ffd2fb967761e754541969cc271bcb81f6be6f30129b.md
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@@ -0,0 +1,72 @@
+Casech3o peo 23652305-DAF DoerHenert 5Filet eg/P3/28/2Page 897 2 of 2
+AO 440 (Rev. 06/12) Summons in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+JANE DOE,
+Plaintiffs)
+V
+DARREN K. INDYKE AND RICHARD D. KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendant(s)
+Civil Action No.
+SUMMONS IN A CIVIL ACTION
+To: (Defendant's name and address) DARREN K. INDYKE
+875 Third Avenue
+New York, NY 10022
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
+are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
+P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
+the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
+whose name and address are: Daniel J. Kaiser, Esq.
+Kaiser Saurbron & Mair, P.C
+30 Broad Street, 37th Floor
+New York, NY 10004
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
+You also must file your answer or motion with the court.
+CLERK OF COURT
+Date:
+03/18/2020
+Is/ P. Canales
+Signature of Clerk or Deputy Clerk
+Sulays
+
+
+Casech30220 23652385-DAF Doterhener 5Filet eg/P3/28/2Page 297 2 of 2
+AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (D))
+This summons for (name of individual and title, if any)
+was received by me on (date)
+• I personally served the summons on the individual at (place)
+on (date)
+; or
+] I left the summons at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the summons on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+, who is
+• I returned the summons unexecuted because
+• Other (specify):
+; or
+My fees are $
+for travel and $
+I declare under penalty of perjury that this information is true.
+for services, for a total of $
+0.00
+•
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc:
+Print
+Save As...
+Reset
diff --git a/vision-fixhub/court-01/ea256e4e452c00b6a3a3ffd2fb967761e754541969cc271bcb81f6be6f30129b.receipt.json b/vision-fixhub/court-01/ea256e4e452c00b6a3a3ffd2fb967761e754541969cc271bcb81f6be6f30129b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..dbcc95583daf22045f71bb63c279e44aad37875d
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+++ b/vision-fixhub/court-01/ea256e4e452c00b6a3a3ffd2fb967761e754541969cc271bcb81f6be6f30129b.receipt.json
@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.md b/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.md
new file mode 100644
index 0000000000000000000000000000000000000000..817f38aa648fed3e683d66a1e0f08e026bfad94c
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+++ b/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.md
@@ -0,0 +1,55 @@
+Case 1:19-cv-08673-KPF-DCF Document 18 Filed 11/05/19 Page 1 of 2
+KAPLAN HECKER & FINK LLP
+350 FIFTH AVENUE | SUITE 7110
+NEW YORK, NEW YORK 10118 *
+TEL (212) 763-0883 | FAX (212) 564-0883
+WWW.KAPLANHECKER.COM
+DIRECT DIAL 212.763.0885
+DIRECT EMAIL jfink@kaplanhecker.com
+November 5, 2019
+VIA ECE
+The Honorable Katherine Polk Failla
+United States District Court
+Southern District of New York
+Thurgood Marshall United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re:
+Doe 17 v. Indyke et al., No. 19-cv-9610 (Engelmayer, J.)
+Dear Judge Failla:
+We represent Plaintiff Jane Doe in Doe v. Indyke et. al., No. 19-cv-08673. We write to
+supplement our November 1, 2019 Letter to the Court (ECF 16), in which we requested that the Court
+mark the following cases as related and assigned to a single judge: VE v. Nine East 71st Street et al., No.
+19-cv-07625 (S.D.N.Y.) (Nathan, J.); Doe 1 et al. v. Jeffrey Epstein et al., No. 19-cv-07675 (S.D.N.Y)
+(Daniels, J.); Doe v. Darren K. Indyke et al., No. 19-cv-07771 (S.D.N.Y.) (Castel, J.); Doe v. Darren K.
+Indyke et al., No. 19-cv-07772 (S.D.N.Y.) (Carter, J.); Doe v. Darren K. Indyke et al., No. 19-cv-07773
+(S.D.N.Y.) (Ramos, J.); and, Doe v. Indyke et. al., No. 19-cv-08673 (S.D.N.Y.) (Failla, J.).
+It has come to our attention that an additional case, Doe 17 v. Indyke et al., No. 19-cv-9610
+(S.D.N.Y.) (Engelmayer, J.), concerns similar parties and substantial factual overlap with the
+aforementioned cases. Therefore, we request that it too be marked as related.
+Thank you for your consideration of this request. We copy on this letter all the Southern District
+of New York Judges currently assigned to these cases, the Chief Judge of the Southern District, and
+counsel in the other related cases.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 18 Filed 11/05/19 Page 2 of 2
+KAPLAN HECKER & FINK LLP
+2
+cc: Counsel of Record
+The Honorable Alison J. Nathan
+The Honorable
+B. Daniels
+The Honorable P. Kevin Castel
+The Honorable Andrew L. Carter
+The Honorable Edgardo Ramos
+The Honorable Paul A. Engelmayer
+The Honorable Colleen McMahon
+Arick W. Fudali, Esg.
+James
+, Esq.
+Brittany
+Esq.
+John Pottinger, Esq.
+David H. Brodie Esq.
+Laura Jane Starr Esq.
+Andrew Scott Buzin Esq.
diff --git a/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.receipt.json b/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1b14fbc9a404b1cadc6f9bf9f24404af53f3425a
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+++ b/vision-fixhub/court-01/ea3c754d574f3bffe8c6ede8cc8e0bd019ca2ad13464689fcf226c7b15cee87e.receipt.json
@@ -0,0 +1,14 @@
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ea3f3b32f86e39266701938199bea13d1144f097e45000516de008a420aa78c5.md b/vision-fixhub/court-01/ea3f3b32f86e39266701938199bea13d1144f097e45000516de008a420aa78c5.md
new file mode 100644
index 0000000000000000000000000000000000000000..b6cb3c4a34fef9208c19ca2129d81da454216c1f
--- /dev/null
+++ b/vision-fixhub/court-01/ea3f3b32f86e39266701938199bea13d1144f097e45000516de008a420aa78c5.md
@@ -0,0 +1,631 @@
+Case 1:19-CV-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 1 of 17
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+AND ST. JOHN
+********************************
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+)
+Deceased.
+PROBATE NO. ST-19-PB-80
+ACTION FOR TESTATE
+)
+ADMINISTRATION
+CO-EXECUTORS' CORRECTIONS TO ATTORNEY GENERAL'S
+STATUS REPORT ON VOLUNTARY COMPENSATION PROGRAM
+AND RENEWED REQUEST FOR RULING
+On March 24, 2020, the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"),
+DARREN K. INDYKE and RICHARD D. KAHN, asked the Court to grant their Expedited
+Motion for Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019,
+and allow the Co-Executors to move forward with that Program as carefully constructed in
+consultation with claimants' counsel and leading independent claims program experts.
+The Co-Executors hereby renew their request. Because the Attorney General of the Virgin
+Islands has no standing in this Court to seck to re-shape the Program to suit her whims —
+demanding changes that go against the considered views of the Co-Executors, recommendations
+of nationally recognized experts in the field, and endorsement by multiple claimants' counsel —
+the Court should reject her continued efforts to undermine the Program. As detailed below, the
+Attorney General's most recent Status Report (filed April 7, 2020) substantially misrepresents the
+actual state of affairs regarding the Program, and requires correction.
+The Attorney General Misrepresents Claimants' Position Regarding
+the Program's Third-Party Release
+The Attorney General informs the Court that she and claimants' counsel are aligned on
+rejecting the third-party release (the "Release") that those claimants who elect to receive
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 2 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 2
+compensation under the Program would execute. (See 4/7/2020 AG Status Report at 2-3.)' That
+is false. On the very day that the Attorney General made that (mis)representation to the Court, the
+two most active claimants' counsel — together, representing by far the largest number of claimants
+- informed the Co-Executors and the Attorney General that they are prepared to proceed with
+the Program without change to the existing Release.
+The evidence on this point is undisputed. On the morning of April 7, 2020, David Boies
+of Boies Schiller Flexner LLP (counsel for at least five prospective claimants) informed the Co-
+Executors that the existing Release was acceptable as written:
+"I spoke with [counsel for the Co-Executors] this morning. I am now in
+agreement that we should move forward with the claims process without trying
+to further modify the (R]elease.
+I am influenced by the desirability of getting the [P]rogram underway so
+be limited to persons who provided services to Epstein, with the [Re]lease signed
+by individual victims who accept an award having a space to make clear that certain
+individuals ... are not released, and by the fact that the release of Epstein's
+employees/service providers will be taken into account by the [Program]
+Administrator in setting the amount of the award. And, of course, this is a
+voluntary process where our clients get to decide whether to be bound after
+learning the amount of the proposed award."
+(See email from David Boies dated April 7, 2020 to
+and counsel for the Co-
+Executors, copy attached here as Exhibit B; emphasis supplied.)
+Claimants' counsels' intent to proceed with the Program including the Release as written
+was known to the Attorney General before she informed the Court otherwise. On April 6, 2020
+— the day before the Attorney General filed her most recent Status Report — lead counsel for
+some two dozen other prospective claimants told her exactly that. Writing to Mr. Boies,
+1. A copy of the Release, provided on March 16, 2020 by the Co-Executors to the Attorney General and
+claimants' counsel, is attached hereto as Exhibit A.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 3 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 3
+explained his agreement to accept the Release as written, and noted that he had the day
+before told the Attorney General of that fact:
+"We are now both on the same page. I would like, with your permission to
+forward that email [i.e., Mr. Boies' email quoted infra, approving the Release as
+written] to the AG, as I voiced a very similar position to her yesterday."
+(See email from
+dated April 7, 2020 to David Boies and counsel for the Co-
+Executors; copy attached as Exhibit C).?
+It is one thing for the Attorney General, who has no experience or expertise with mass tort
+compensation programs, to inveigh against the Program. It is quite another for her to misrepresent
+to the Court that claimants' counsel join in her criticism of the Release. They do not.
+The Attorney General Misrepresents the Scope of the Release,
+Which is Designed to Prevent "Double Dipping" by Claimants
+The Attorney General also misrepresents the scope of the Release, asserting that the Estate
+seeks the release of "any party" who themselves participated in wrongdoing, including
+"individuals for whom the Estate has no liability." (See 4/7/2020 AG Status Report at 3.) Again,
+that is false.
+The Release is closely modeled on releases employed in multiple voluntary compensation
+programs administered by the Program Administrator and Designers, including the sexual abuse
+scandals currently faced by the Catholic Church. Contrary to the Attorney General's claim, it does
+not include "any party" who committed wrongdoing, nor have the Co-Executors ever proposed
+2. Both Mr. Boies and the Co-Executors immediately consented to Mr. |
+request to share
+Mr. Boies' email with the Attorney General, who thus had both Mr. Boies' and Mr.
+statements accepting the Release as written before she filed her misleading Status Report with the
+Court.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 4 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 4
+that it would. Rather, as the Co-Executors have explained several times to the Attorney General,
+the Release is aimed at protecting the assets of the Estate by ensuring that an individual claimant
+does not "double dip" — i.e., she cannot both elect to (1) receive full compensation from the Estate
+through the Program, and also (2) sue individuals affiliated with the Estate who may well implead
+the Estate under doctrines of contribution, indemnification, respondeat superior or otherwise.*
+The Co-Executors' duties under Virgin Islands law require them to protect the Estate's assets,
+including for the benefit of its creditors and claimants. The Release is indispensable in achieving
+that result.
+Nor should the Court accept the Attorney General's straw-man formulation that,
+"[a]ssuming a fairly bargained transaction, the Estate would have to offer increased compensation
+to victims to secure the third-party release to satisfy claims for which it has no legal responsibility."
+(4/7/2020 AG Status Report at 4.) As explained above, the Release is not aimed at claims for
+3. The subjects of the Release are limited to the individuals or entities affiliated with or who provided
+services to Mr. Epstein, as follows:
+"The Co-Executors of the Estate of Jeffrey E. Epstein (the 'Epstein Estate"), the Co-
+Trustees of The 1953 Trust, the Epstein Estate, any entities owned or controlled in whole
+or part by the Estate (the 'Epstein Entities') and their respective current and former
+principals, officers, directors, stockholders, managers, members, partners, limited partners,
+trustees, beneficiaries, administrators, agents, employees, attorneys, predecessors,
+successors, assigns and affiliates, and any entities or individuals who are or have ever been
+engaged by (whether as independent contractors or otherwise), employed by, worked in
+any capacity for, or provided any services to Mr. Epstein, the Epstein Entities or the Epstein
+Estate." (Ex. A at 1-2.)
+The Release specifically provides that it will not release third parties unaffiliated with the Epstein
+Entities, including individuals specified by the claimant. (Id. at 4.)
+4. This is no theoretical risk. On March 12, 2020, one of the primary individuals alleged to have worked
+as a "recruiter" of young women for Mr. Epstein brought suit in the Virgin Islands against the Estate
+and the Co-Executors, demanding indemnification. Ghislaine Maxwell v. Estate of Jeffrey E. Epstein,
+et al., Civil Case No. ST-20-CV-155 (Superior Court of the Virgin Islands, Division of St.
+and
+St. John).
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 5 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 5
+which the Estate "has no legal responsibility". Rather, its function is exactly the opposite: the
+Release's acknowledged purpose is to avoid having the Estate pulled into litigation by individuals
+who claim that the Estate is legally responsible for their actions. And, as claimants' counsel Mr.
+Boies recognized, the Program will properly offer compensation to legitimate claimants that
+reflects their release of any third parties who are affiliated with Mr. Epstein or the Estate.
+Consistent with their fiduciary duties, the Co-Executors determined that the benefits of
+including within the Release those individuals who
+Maxwell has already done)
+that the Estate bears financial responsibility for the claims against them, substantially outweighs
+the downside of not requiring a release of those persons. Those downsides include that the Co-
+Executors would be forced to (1) litigate against the very claimants the Estate will have
+compensated through the Program and thereby sought to both avoid being adverse to those
+claimants and incurring the financial costs of litigating against them; (2) litigate alongside persons
+for harms caused by their alleged conduct for which the Estate has already paid the plaintiff, and
+(3) pay twice for any harm caused by Mr. Epstein if the damages awarded in that litigation focus
+not just on the conduct of the released person but also Mr. Epstein's conduct.
+The Attorney General Lacks Standing to Re-Shape the Program Developed
+by the Co-Executors and Experts in the Field
+More than two months ago — but five months after the Co-Executors and the independent
+claims program experts began working arduously to establish the Program — the Attorney General
+sought to intervene in this probate proceeding in order to oppose the Co-Executors
+
+
+Case 1:19-CV-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 6 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 6
+implementation of the Program. At the hearing on February 4, 2020, during which the Attorney
+General displayed her disregard for probate procedures and the Court's statutory authority, the
+Court expressly denied the Attorney General's motion. (February 4, 2020 Hearing Tr. at 98:8-12.)
+Accordingly, the Attorney General has no standing to demand that the Court re-shape the Program
+to suit her preferences or priorities. That includes her most recent demand that the Court ignore
+the Co-Executors, claimants' counsel and acknowledged experts in the field in order to rewrite the
+text of the Release.
+Just as the Attorney General sought to position herself as a substitute for the Court in
+reviewing and approving the Co-Executors' regular administration of the Estate, she now seeks
+to assume the mantle of Program overseer: demanding that her own hand-picked choice (Marci
+D be placed on the Program's payroll; requiring that $25 million from the Estate be made
+unavailable to pay legitimate claimants through the Program;? and rewriting the scope of the
+Release when everyone but her — including claimants' counsel, whose clients (unlike the Attorney
+General) would sign the Release
+- has accepted that Release as written. That is improper.
+The Attorney General has no right to inject herself into the Program, dictating its policies,
+procedures and administration. To allow her to do so would rob the Program of its independence,
+one of its most critical attributes. And the Attorney General has no business forcing the Court to
+act as umpire on each of her dissatisfactions with the Program; as the Court indicated on more than
+one occasion, it is up to the Co-Executors — acting as duly appointed extensions of the Court —
+6. See Attorney General's Motion to Intervene, filed January 23, 2020 (attaching Government's
+Opposition to Estate's Motion for Establishment of a Voluntary Claims Program).
+7. Sho motion from ale Espare arco. tier public procese ens not adanial a thraimly
+General has never offered to make a penny of those Funds available to victims of sexual abuse.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 7 of 17
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+Probate No. ST-19-PB-80
+Page 7
+to fulfill their fiduciary duties to the Estate. As designed and to be implemented by nationally
+recognized experts, and as approved by virtually every claimants' counsel, the Epstein Victims'
+Compensation Program accomplishes that precise goal.
+*
+*
+*
+As in their March 24, 2020 application, the Co-Executors again ask the Court to allow them
+to continue to perform their fiduciary duties, and — for the benefit of all stakeholders in the Estate,
+including those women who seek to participate in the Program — grant their motion to establish
+the Program as originally conceived and presented to the Court on November 14, 2019.
+Respectfully,
+Dated: April 10, 2020
+/s/
+Kroblin, Esg.
+KROBLIN, ESQ.
+ANDREW W. HEYMANN, ESQ.
+WILLIAM L. BLUM, ESQ.
+SHARI N. D'ANDRADE, ESQ.
+MARJORIE WHALEN, ESQ.
+V.I. Bar Nos. 966, 266, 136, 1221 & R2019
+HALS
+KROBLIN PLLC
+Palms Professional Building
+9053 Estate
+• Suite 101
+St.
+1 V.I. 00802
+Telephone: (340) 779-2564
+Facsimile: (888) 316-9269
+Email: ckroblin@kellfer.com
+aheymann@solblum.com
+wblum@solblum.com
+sdandrade@kellfer.com
+mwhalen@kellfer.com
+• Mr. Boies' co-counsel, Kevin D'Amour, echoed the statements of numerous claimants' counsel at the
+February 4, 2020 hearing: "I think if we go forward with this program we are going to see great results
+and I think we are going to have a much better outcome if we can go forward with this program as soon
+as possible." (February 4, 2020 Hearing Tr. at 88:15-19.) The Court summarized the view of those
+present at that hearing, noting as follows: "I think we agreed that everybody believes this program is a
+great program..." (Id. at 113:24-25.)
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 8 of 17
+Probate No. ST-19-PB-80
+Page 8
+Co-Executors' Corrections to AG's Status Report & Renewed Request for Ruling
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 10th day of April 2020, I caused a true and exact copy
+of the foregoing Co-Executors' Corrections to Attorney General's Status Report on
+Voluntary Compensation Program and Renewed Request for Ruling to be served via
+electronic mail upon:
+John H. Benham, Esq.
+Law Office of John H. Benham, P.C.
+P.O. Box 11720
+St.
+,, VI 00801
+john@benhamlawvi.com
+Douglas B. Chanco, Esq.
+ChancoSchiffer P.C
+3355 Lenox Road, Suite 750
+Atlanta, GA 30326
+doug@csfirm.com
+Richard Bourne-Vanneck, Esq.
+Law Offices of Richard Bourne-Vanneck
+9800 Buccaneer Mall Suite #9
+St.
+VI 00802
+richard@rpvblawoffices.com
+John K. Dema
+Law Offices of John K. Dema
+1236 Strand Street, Suite 103
+St. Croix, VI
+jdema@demalaw.com
+Denise N. I
+Attorney General
+Esq.
+Ariel M.
+_. Esq.
+Chief, Civil Division
+Virgin Islands Department of Justic
+34-38 Krondprinsdens Gad
+GERS Complex, 2id Floor
+St.
+Virgin Islands 00804
+A. Jeffrey Weiss, Esq.
+A.J. Weiss & Associates
+6934 Vessup Lane
+St.
+. VI 00802
+jeffweiss@weisslaw-vi.net
+Sean
+Esq.
+Marjorie Rawls
+P.C.
+P.O. Box 6347
+St.
+, VI 00804
+sean@marjorierobertspc.com
+Kevin F. D'Amour
+Gaylin Vogel, Esq.
+5143 Palm Passage, 18b & 19b
+St.
+, VI 00802
+kevin.damour@comcast.net
+gaylin. vogel@comcast.net
+Melody D. Westfall, Esq.
+Westfall Law PLLC
+5032 Anchor Way, Suite 8
+Christiansted, St. Croix 00820
+mwestfall@westfalllaw.com
+/s/|
+Kroblin
+96616273_6
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 9 of 17
+Kroblin Mail - FW: EVCP - General Release
+4/10/2020
+GMail
+by engla
+FW: EVCP - General Release
+1 message
+Marjorie whalen <mwhalen@kellfer.com>
+Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>
+Fri, Apr 10, 2020 at 11:58 AM
+To: "ckroblin@kellfer.com" <ckroblin@kellfer.com>, Shari D'Andrade <s.dandrade@kellfer.com>, Marjorie Whalen
+<mwhalen@kellfer.com>
+Daniel H. Weiner | Partner
+Hughes Hubbard &
+LLP
+One Battery Park Plaza, 15th floor | New York, NY 10004-1482
+Office +1 (212) 837-6874 | Cell +1 (917) 574-3407 | | Fax +1 (212) 299-6874
+daniel.weiner@hugheshubbard.com | bio
+This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
+disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete
+this e-mail from your syster. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted,
+lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the
+contents of this message, which arise as a result of e-mail transmission, If verification is required please request a hard-copy version.
+From: Weiner, Daniel H.
+Sent: Monday, March 16, 2020 10:03 PM
+To: !
+Linda' <singer@motlevrice.com>
+Cc:
+@vi.gov»; pamela.tepper@vi.gov'<pamela.tepper@vi.govs;
+Francois@vi.gov>; 'Brad
+I<brad@epllc.coms;
+'Brittany@epllc.com' <Brittany@epllc.com>; Tomback, Andrew' <andrew.tomback@whitecase.com»; Chris
+Kroblin <ckroblin@kellfer.com»; 'cscott@motleyrice.com' <cscott@motleyrice.com>
+Subject: EVCP - General Release
+Linda -
+As requested, we attach a proposed release to be executed by those claimants who elect to accept compensation
+through the Epstein Victims' Compensation Program.
+Best,
+Dan
+- RELEASE NEW - 96483947_5.pdf
+67K
+https://mail.google.com/mail/u/0?ik=e7c42fa0b0&view=pt&searc
+
+A
+599236296230186%7Cmsg-1%3A16635992362962... 1/2
+
+
+4/10/2020
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 10 of 17
+Kroblin Mail - FW: EVCP - General Release
+https://mail.google.com/mail/u/D?ik=e7c42fa0b0&view=pt&search=all&permthid=thread-1%3A1663589236296230186%7Cmsg-1%3A16635992362962...
+212
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 11 of 17
+EPSTEIN VICTIMS' COMPENSATION PROGRAM ("EVCP")
+GENERAL RELEASE
+This General Release is made this
+_ day of
+20
+WHEREAS,
+(the "Claimant"), submitted a claim for
+compensation to the Epstein Victims' Compensation Program ("EVCP") asserting that
+she is a victim of sexual abuse by Jeffrey E. Epstein; and
+WHEREAS, the EVCP Program Administrator (the "Administrator") determined
+pursuant to the EVCP Protocol that Claimant is eligible to participate in the EVCP; and
+WHEREAS, after reviewing Claimant's submissions and after careful consideration of
+documentation and proof, and after due deliberation, the Administrator issued a
+compensation determination to Claimant ("Compensation Offer"); and
+WHEREAS, several jurisdictions within the United States have enacted claims revival
+statutes concerning the timeliness of claims of sexual abuse; and
+WHEREAS, Claimant is aware that, by accepting this Compensation Offer from the
+EVCP, Claimant waives and releases certain individuals and entities from any and all
+claims or causes of action arising from Mr. Epstein's conduct, whether pursuant to claims
+revival statutes or otherwise; and
+WHEREAS, after careful consideration of the proposed Compensation Offer, including
+consultation with her legal counsel regarding the Compensation Offer, Claimant
+informed the Administrator that Claimant has decided to accept the Compensation Offer.
+NOW THEREFORE,
+Claimant,
+_ for and on behalf of herself and her heirs, devisees,
+legatees,
+distributees, executors, administrators, trustees, personal representatives,
+successors and assigns (collectively, "Releasor"), for and in consideration of
+-) (the Compensation Offer) to
+be received from the EVCP, the adequacy and sufficiency of which are hereby
+acknowledged, hereby releases and forever discharges the Co-Executors of the Estate of
+Jeffrey E. Epstein (the "Epstein Estate"), the Co-Trustees of The 1953 Trust, the Epstein
+Estate, any entities owned or controlled in whole or part by the Epstein Estate (the
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 12 of 17
+"Epstein Entities") and their respective current and former principals, officers, directors,
+stockholders, managers, members, partners, limited partners, trustees, beneficiaries,
+administrators, agents, employees, attorneys, predecessors, successors, assigns and
+affiliates, and any entities or individuals who are or have ever been engaged by (whether
+as independent contractors or otherwise), employed by, worked in any capacity for, or
+provided any services to Mr. Epstein, the Epstein Entities or the Epstein Estate (jointly
+and severally, the "Releasees"), from any and all claims, demands, actions, causes of
+action, suits, debts, dues, sums of money, accounts, variances, trespasses, damages and
+judgments, whether sounding in equity, tort, common law, contract, statute, regulation
+or otherwise and whether now existing, hereafter existing or revived in the future
+whatsoever in law, admiralty, equity or otherwise, including without limitation any and
+all claims or causes of action that arise or may arise from or which otherwise concern acts
+of sexual abuse by Mr. Epstein (the "Claims") which against the Releasees, Releasor ever
+had, now have or hereafter can, shall or may have, for, upon, or by reason of any matter,
+cause or thing whatsoever from the beginning of the world through the date of this
+General Release.
+This General Release is a broad release of any and all Claims of Releasor against
+any and all Releasees, including without limitation any and all causes of action, lawsuits,
+claims, demands, damages and liability whatsoever, and also including without
+limitation to the extent of their respective liability for the same, any and all such claims
+against any and all Releasees for contribution as to any other person or persons who may
+be determined to have been joint tortfeasors arising out of or in any way related to any
+and all known and unknown personal injuries, and also including without limitation any
+derivative claims for loss of consortium, under any federal, state or local law, without
+limitation. This General Release is all-encompassing and is specifically made and given
+on the premise that any and all Claims by Releasor are hereby released and extinguished,
+whether said Claims arose in Florida, New Mexico, New York, the United States Virgin
+Islands, France or any other country, state, territory, possession or jurisdiction, or
+otherwise.
+This General Release extends to released Claims that Releasor does not know or
+suspect to exist in her favor, which, if known by Releasor, would have materially affected
+her decision to enter into this General Release, and Releasor understands and agrees that
+she is releasing any and all such unknown or unsuspected Claims in Releasor's favor.
+Releasor acknowledges that she is familiar with Section 1542 of the California Civil Code,
+which provides as follows:
+2
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 13 of 17
+A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS THAT THE
+CREDITOR OR RELEASING PARTY DOES NOT KNOW OR SUSPECT TO EXIST IN
+HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE AND THAT, IF
+KNOWN BY HIM OR HER, WOULD HAVE MATERIALLY AFFECTED HIS OR HER
+SETTLEMENT WITH THE DEBTOR OR RELEASED PARTY.
+Releasor expressly waives and relinquishes any right or benefit that Releasor has
+or may have under Section 1542 of the California Civil Code and under any other statute
+or legal principle with similar effect. In connection with such waiver and relinquishment,
+Releasor acknowledges that she is aware that, after executing this General Release,
+Releasor or Releasor's attorneys or agents may discover released Claims or facts in
+addition to, or different from, those which they now know or believe to exist with respect
+to the subject matter of this General Release, but that it is Releasor's intent hereby to fully,
+finally and forever settle and release all of the Claims, whether known or unknown,
+suspected or unsuspected, which now exist, may exist, or heretofore may have existed.
+In furtherance of this intent, this General Release shall be, and remain in effect as, a full
+and complete release of the Claims notwithstanding the discovery or existence of any
+such additional or different Claims or facts.
+The Administrator of the EVCP has retained
+to confirm that
+the Centers for Medicare and Medicaid Services ("CMS") and Medicaid will not assert
+any reimbursement claim or lien with respect to compensation awarded to any
+participating claimant under the EVCP; provided, however, that if either entity does
+assert any such interest, _
+is hereby authorized to act on behalf of the EVCP to verify
+and resolve such lien or reimbursement claim. Releasor agrees to allow the
+Administrator to provide to _
+_ certain information as to Releasor, including: (1) first
+name, last name and middle initial, (2) Social Security number; (3) date of birth, (4) gender
+and (5) basic information regarding the nature of Releasor's Claims, and hereby
+authorizes the Administrator and m
+_ to use, exchange and report this information to
+Medicare, if necessary, for purposes of ensuring compliance with the Medicare
+Secondary Payer Act, 42 U.S.C. § 1395(y)(b), and its accompanying regulations.
+Releasor represents and acknowledges that she is voluntarily and freely granting
+this General Release in exchange for payment of the Compensation Offer, and that she is
+legally competent to execute and deliver this General Release. Releasor further
+represents that she is represented by legal counsel and has received legal advice prior to
+entering into this General Release and that she has been advised by said attorney
+regarding the terms and conditions of this General Release, which she has completely
+read and fully understands, including that accepting the Compensation Offer and signing
+3
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 14 of 17
+this General Release is a full and final compromise, adjustment and resolution of any and
+all Claims that Releasor may now have or ever will have against Releasees.
+Pursuant to the EVCP Protocol, the Administrator will maintain the confidentiality
+of all information and documentation relating to claimants who participate in the EVCP
+Program. This General Release does not require participating claimants to maintain such
+confidentiality and Releasor may - at Releasor's voluntary and sole option -- disclose
+such information regarding the claims process and/or the Compensation Offer and any
+other information pertaining to her claim.
+This General Release specifically does not include
+as a Releasee or
+released party under this Agreement, and all parties expressly acknowledge, agree and
+understand that any and all claims that Releasor has or may have against
+are expressly preserved.
+Releasor represents and warrants that she has not assigned any Claims released
+pursuant to this General Release.
+As soon as is reasonably practicable after payment of the Compensation Offer is
+made, and in no event later than three (3) business days from the date thereof, Releasor
+will dismiss with prejudice any legal actions - whether lawsuits, probate claims or
+otherwise - that Releasor has filed against any of Releasees, with each party to bear her,
+his or its own costs and attorneys' fees.
+This General Release contains the entire understanding of the Releasor and the Co-
+Executors of the Epstein Estate. Any modification of any of the provisions of this General
+Release shall be effective only if made in writing and executed by Releasor and the Co-
+Executors of the Epstein Estate with the same formality as this General Release.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2 Filed 04/15/20 Page 15 of 17
+IN WITNESS WHEREOF, Claimant has executed this General Release on the date
+below her signature.
+(Signature: Claimant)
+(Date)
+STATE OF
+sS:
+COUNTY OF
+On
+_ 20_ before me personally came
+→ to
+me known, who, by me duly sworn, did depose and say that deponent is the Releasor
+who executed the foregoing General Release.
+Notary Public
+Reviewed and approved:
+Type (or print) Name of Claimant:
+Attorney for Releasor:
+Type (or print) Name of Attorney:
+Signature:
+5
+96483947_5
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2
+Filed 04/15/20 Page 16 of 17
+Kellerhals |
+Kroblin Mail - FW: Where we are
+4/10/2020
+GMail
+Marjorie whalen <mwhalen@kellfer.com>
+FW: Where we are
+1 message
+Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>
+Fri, Apr 10, 2020 at 12:00 PM
+To: "ckroblin@kellfer.com" < ckroblin@kellfer.com>, Shari D'Andrade < s.dandrade@kellfer.com>, Marjorie Whalen
+<mwhalen@kellfer.com>
+Daniel H. Weiner | Partner
+Hughes Hubbard &
+LLP
+One Battery Park Plaza, 15th floor | New York, NY 10004-1482
+Office +1 (212) 837-6874 | Cell +1 (917) 574-3407 | | Fax +1 (212) 299-6874
+daniel.weiner@hugheshubbard.com | bio
+This message contains confidential information and is intended only for the individual named, If you are not the named addressee you should not
+disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete
+this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted,
+lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the
+contents of this message, which arise as a result of e-mail transmission. If verification is required please request a hard-copy version.
+-Original Message...
+From: David Boies <xboies@gmail.com>
+Sent: Tuesday, April 7, 2020 10:48 AM
+To: Brad
+<brad@epllc.com>
+Cc: Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>; Andrew Tomback <andrew.tomback@whitecase.com>
+Subject: Where we are
+CAUTION: This email was sent by someone outside of the Firm.
+I spoke with Dan and Andy (whom I am copying) this morning. I am now in agreement that we should move forward with
+the claims process without trying to further modify the release. I am influenced by the desirability of getting the program
+underway so that our clients can begin getting compensation; by the fact that the release will be limited to persons who
+provided services to Epstein, with the lease signed by individual victims who accept an award having a space to make
+clear that certain individuals (e.g., Prince Andrew or others to whom our clients were trafficked) are not released; and by
+the fact that the release of Epstein's employees/service providers will be taken into account by the Administrator in setting
+the amount of the award. And, of course, this is a voluntary process where our clients get to decide whether to be bound
+after learning the amount of the proposed award.
+JIBIT
+https://mail.google.com/mail/u/0?ik=e7c42faOb0&view=p
+3A1663598838122653552%7Cmsg-f%3A16635990744492..
+1/1
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-2
+Filed 04/15/20 Page 17 of 17
+| Kroblin Mail - FW: Where we are
+4/10/2020
+GMail
+Marjorie whalen <mwhalen@kellfer.com>
+FW: Where we are
+1 message
+Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>
+Fri, Apr 10, 2020 at 12:02 PM
+To: "ckroblin@kellfer.com" <ckroblin@kellfer.com>, Shari D'Andrade <s.dandrade@kellfer.com>, Marjorie Whalen
+<mwhalen@kellfer.com>
+Daniel H. Weiner | Partner
+Hughes Hubbard &
+LLP
+One Battery Park Plaza, 15th floor | New York, NY 10004-1482
+Office +1 (212) 837-6874 | Cell +1 (917) 574-3407 | | Fax +1 (212) 299-6874
+daniel.weiner@hugheshubbard.com | bio
+This message contains confidential information and is intended only for the individual named. If you are not the named addressee you should not
+disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete
+this e-mail from your system. E-mail transmission cannot be guaranteed to be secure or error-free as information could be intercepted, corrupted,
+lost, destroyed, arrive late or incomplete, or contain viruses. The sender therefore does not accept liability for any errors or omissions in the
+contents of this message, which arise as a result of e-mail transmission, If verification is required please request a hard-copy version.
+-Original Message..
+From: Brad
+<brad@epllc.com>
+Sent: Tuesday, April 7, 2020 11:00 AM
+To: David Boies <xboies@gmail.coms
+Cc: Weiner, Daniel H. <daniel.weiner@hugheshubbard.coms; Andrew Tomback <andrew.tomback@whitecase.com>
+Subject: Re: Where we are
+CAUTION: This email was sent by someone outside of the Firm.
+We are now both on the same page. I would like, with your permission, to forward that email to the AG, as I voiced a very
+similar position to her yesterday.
+Sent from my iPhone
+> On Apr 7, 2020, at 10:48 AM, David Boies <xboies@gmail.com> wrote:
+>
+I spoke with Dan and Andy (whom I am copying) this morning. I am now in agreement that we should move forwa
+ith the claims process without trying to further modify the release. I am influenced by the desirability of getting th
+program underway so that our clients can begin getting compensation; by the fact that the release will be limited to
+persons who provided services to Epstein, with the lease signed by individual victims who accept an award having a
+space to make clear that certain individuals (e.g., Prince Andrew or others to whom our clients were trafficked) are not
+released; and by the fact that the release of Epstein's employees/service providers will be taken into account by the
+Administrator in setting the amount of the award. And, of course, this is a voluntary process where our clients get to
+decide whether to be bound after learning the amount of the proposed award.
+
+https://mail.google.com/mail/u/07ik-e7c42fa0b0&view=pt8s
+63598838122653552%7Cmsg-f%3A16635988381226...
+1/1
\ No newline at end of file
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-01/ea7e1b91dde8b7ce1ea87487a6e20c991c22463214f9fc84c7532c9174b604f8.md b/vision-fixhub/court-01/ea7e1b91dde8b7ce1ea87487a6e20c991c22463214f9fc84c7532c9174b604f8.md
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@@ -0,0 +1,46 @@
+Case 9:08-cv-80736-KAM Document 2 Entered on FLSD Docket 07/07/2008 | Regeb ofD.J
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+08-80736-Civ-MARRA/
+ELECTRONIC
+JULY 7, 2008
+D.C.
+Inre:
+Jane
+DoC
+V.
+United States
+of America
+Plaintiff
+Defendant
+CERTIFICATION OF EMERGENCY
+I hereby certify that, as a member of the Bar of this Court, I have carefully examined this matter and it is a true
+emergency.
+I further certify that the necessity for this emergency hearing has not been caused by a lack of due diligence
+on my part, but has been brought about only by the circumstances of this case. The issues presented by this matter have
+not been submitted to the Judge assigned to this case or any other Judge or Magistrate Judge of the Southern Distric
+of Flerida prior hereto.
+I further certify that I have made a bona fide effort to resolve this matter without the necessity of emergency
+Dated this_ /_day of Jul
+Signature: c
+50c2l
+Print Name:
+Brad
+-
+Florida Bar Number:
+Telephone Number:_
+
+954-414-8033
+**************Ф****************************:
+******
+********
+I hereby certify that the Judge assigned to this case is unavailable for this emergency (a copy of his/her
+notification to the Clerk is on file). In accordance with Local Rule 3.7, the Honorable
+_ was randomly drawn from the Emergency Wheel.
+Dated:
+STEVEN M. LARIMORE
+Court Administrator • Clerk of Court
+By:
+Deputy Clerk
+1 of 1
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+  "idempotent": true,
+  "input_sha256": "ca3de9b9e2bb7533518b74406752e87997c36aaff7699b0d44eb26e681ac2ea6",
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ea8e5905c7aaee73aa40f0f28fb5df51e2a7fc02a8bb9090a78639a71603f5df.md b/vision-fixhub/court-01/ea8e5905c7aaee73aa40f0f28fb5df51e2a7fc02a8bb9090a78639a71603f5df.md
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@@ -0,0 +1,94 @@
+Case 1:20-cv-00484-JGK-DCF Document 68 Filed 08/14/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+20cv 00484 (JGK) (DF)
+SCHEDULING ORDER
+-against-
+DARREN K. INDYKE, et al.,
+Defendants.
+DEBRA FREEMAN, United States Magistrate Judge:
+This matter having been referred to this Court for general pretrial supervision; and this
+Court having held a case management conference on August 5, 2020 with counsel for all parties;
+and this Court having directed counsel to confer regarding certain discovery deadlines and to
+make a follow-up joint submission regarding those deadlines (see Dkt. 62); and this Court having
+no such joint submission, but having, instead, received three separate letters from counsel
+(Dkts. 63, 66, 67); and this Court having reviewed those submissions; it is hereby ORDERED as
+follows:
+1.
+In light of the fact that counsel for defendant Ghislaine Maxwell ("Maxwell") has
+reportedly had difficulty arranging to communicate with Maxwell (who is currently in pretrial
+detention at the Metropolitan Detention Center) regarding certain issues in this case, and in light
+of the potential ramifications of Maxwell's being required to respond to discovery demands in
+this case while a criminal prosecution is pending against her, the request by Maxwell's counsel
+for an extension of time to August 19, 2020, either to participate in a joint request regarding the
+setting of additional discovery deadlines or to move for a stay of any or all of these proceedings,
+is granted. If Maxwell moves for a stay of these proceedings, in whole or in part, then, within
+two business days of the motion's submission, the parties should jointly propose a schedule for
+
+
+Case 1:20-cv-00484-JGK-DCF Document 68 Filed 08/14/20 Page 2 of 4
+opposition and reply submissions, and should also inform this Court of their views as to whether
+the motion should (or should not) affect any other deadlines set by this Order.
+2.
+This Court expects to enter a protective order in this case to protect, at a
+minimum, the personal information of individuals who are not parties to this action, but who
+claim to have been victims of sexual abuse by Jeffrey E. Epstein ("Epstein"). All counsel are
+directed to confer in good faith regarding the terms of a protective order, and to make a joint
+proposal to the Court no later than August 26, 2020, regarding the same. If the parties are unable
+to agree to proposed terms, then they should make separate proposals by that date, explaining
+any areas of disagreement. Document production shall be stayed pending this Court's entry of a
+protective order, but the parties should be prepared to produce documents in response to any
+outstanding document requests (or in accordance with the parties" initial disclosure
+requirements) within one week of the entry of such an order.
+3.
+Except with respect to any document production, which shall be governed by
+paragraph 2, above, Maxwell's obligation to make initial disclosures, pursuant to Rule 26(a)(1)
+of the Federal Rules of Civil Procedure, has not been excused. Although Maxwell apparently
+did not make those disclosures by the August 10, 2020 deadline previously set by this Court (see
+Dkt. 62), her time to do so shall be extended to August 26, 2020, so as to afford her counsel a
+fair opportunity to confer with her in advance of making those disclosures.
+If, pursuant to Rule 26(a)(1)(A)(i), Maxwell or any party identifies as witnesses
+any women who claim to have been victims of Epstein, then the identities of those witnesses
+shall be maintained by all parties as confidential, pending the Court's entry of a protective order.
+The same principle shall apply to any claimed victims' identities and personal information that
+may be obtained in this action through any other means of discovery, such as by interrogatory
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 68 Filed 08/14/20 Page 3 of 4
+responses, deposition testimony, or subpoena; all such information shall be maintained as
+confidential, pending the entry of a protective order.
+The parties are directed to set a date for Plaintiff's requested deposition of
+defendant Richard D. Kahn, in his capacity as an executor of Epstein's estate. If Plaintiff also
+wishes to depose Kahn in his individual capacity, then Plaintiff's counsel should inform
+Defendants' counsel of this, and, if the parties cannot agree as to whether this would be
+permissible, then they should stipulate to a schedule to place the issue before this Court for
+resolution, in advance of the deposition.
+6.
+To the extent Plaintiff has not yet amended her Rule 26(a)(1) damages
+computation as directed at the August 5, 2020 conference, Plaintiff is directed to do so no later
+than August 26, 2020.
+Plaintiff's counsel is directed to ensure that Defendants are given advance notice
+of any subpoenas served by Plaintiff on any non-parties, see Fed. R. Civ. P. 45(a)(4), and are
+further directed to ensure that Defendants are notified of the receipt of any documents in
+response to such subpoenas. If Plaintiff has served any Rule 45 subpoenas and has not provided
+the required advance notice, or has failed to notify Defendants regarding the receipt of
+responsive documents, then Plaintiff's counsel is directed to furnish such notice forthwith. If, on
+the other hand, Plaintiff has not, to date, served any Rule 45 subpoenas in connection with this
+case, then Plaintiff's counsel should clarify this point to Defendants' counsel.
+Dated: New York, New York
+August 14, 2020
+SO ORDERED
+Дми Іт
+DEBRA FREEMAN
+United States Magistrate Judge
+3
+
+
+Case 1:20-cv-00484-JGK-DCF Document 68 Filed 08/14/20 Page 4 of 4
+Copies to:
+All counsel (via ECF)
+4
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new file mode 100644
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/eac492ccd03ddbda11eaf50262285235fe8cb9762ce541370ef51bc854549b18.md b/vision-fixhub/court-01/eac492ccd03ddbda11eaf50262285235fe8cb9762ce541370ef51bc854549b18.md
new file mode 100644
index 0000000000000000000000000000000000000000..845cd1508f0b40b1f5cc596b70d0da11f1b159e1
--- /dev/null
+++ b/vision-fixhub/court-01/eac492ccd03ddbda11eaf50262285235fe8cb9762ce541370ef51bc854549b18.md
@@ -0,0 +1,27 @@
+Case 1:19-cv-08673-KPF-DCF Document 8 Filed 09/20/19 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN •. INDYKE and RICHARD D. KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendants.
+Case No. 19 Civ. 8673
+NOTICE OF APPEARANCE
+To the Clerk of this court and all parties of record:
+Please enter my appearance as counsel in this case for Plaintiff Jane Doe. I certify
+that I am admitted to practice in this Court.
+Dated: September 20, 2019
+New York, New York
+Is/ Justin Horton
+Justin Horton
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Telephone: (212) 763-0883
+Facsimile: (212) 564-0883
+jhorton@kaplanhecker.com
+Counsel for Plaintiff Jane Doe
+1
diff --git a/vision-fixhub/court-01/eac492ccd03ddbda11eaf50262285235fe8cb9762ce541370ef51bc854549b18.receipt.json b/vision-fixhub/court-01/eac492ccd03ddbda11eaf50262285235fe8cb9762ce541370ef51bc854549b18.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fe5920ede012ba740ea732daeb9ae39cee5d0760
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.md b/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.md
new file mode 100644
index 0000000000000000000000000000000000000000..6b8f2d4300373d38f79313934928d6a9e167c8cf
--- /dev/null
+++ b/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.md
@@ -0,0 +1,23 @@
+Case 1:19-cv-10577-LJL-DCF Document 8 Filed 11/20/19 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff,
+CASE NO:
+19-cv-10577-LGS
+V.
+DARREN L. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the
+ESTATE OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+[PROPOSED| ORDER ON PLAINTIFF'S
+MOTION TO PROCEED ANONYMOUSLY
+WHEREAS Plaintiff Jane Doe 1000 filed a Complaint in this action on November 14,
+2019;
+WHEREAS by Notice of Motion dated November 20, 2019, and Memorandum of Law
+dated November 20, 2019, Plaintiff requested that the Court grant her leave to proceed
+anonymously in this action;
+IT IS HEREBY ORDERED THAT Plaintiff may proceed anonymously in this action.
+Dated:
+Hon. Lorna G. Schofield
+United States District Judge
diff --git a/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.receipt.json b/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e06a5ce97a39cb846d9e62ca7fa87bd1e5d9e347
--- /dev/null
+++ b/vision-fixhub/court-01/eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "eac70b488ad8bbc550683137bfb961cabebbc3ca0da36d72109c5269a2068d60",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a03863c4b554471478919eb871926b051c380c1d4307e318ab8362b7559c2315",
+  "output_sha256": "9a6c8ab729aa5ea526a78a702f00c09e57396521f7e17c5abfa59ea2b8824825",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.md b/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.md
new file mode 100644
index 0000000000000000000000000000000000000000..0a3516258bbfed34885c42e32ccef5dfa61ec592
--- /dev/null
+++ b/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.md
@@ -0,0 +1,97 @@
+Case 9:08-cv-80736-KAM Document 262 Entered on FLSD Docket 10/09/2014 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/_
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR EXTENSION OF
+TIME TO ASSERT OBJECTIONS TO GOVERNMENT'S ASSERTION OF PRIVILEGE
+and OTHEWISE COMPLY WITH COURT ORDER DE 257
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court for an additional week extension of time in
+which to assert Objections to Government's Assertion of Privilege and Otherwise Comply with
+this Honorable Court's Order (DE 257).
+This Court's Order [DE 257] granted Petitioners' Motion for Ordinary Briefing Schedule
+and Ordinary Page Limits to Respnd to the Government's Privilege Assertions [DE 218], stating
+that Petitioners may file their motion re-asserting the objections to the government's assertions
+of privilege within 21 days from September 21, 2014, which would be October 13, 2014.
+The victims are represented by two attorneys,
+and Paul G. Cassell.
+Both have scheduling conflicts that take them outside of their offices during the time in which
+they would need to prepare a response.
+The victims request that their time to Assert Objections and otherwise comply with Court
+Order be due on or before October 20, 2014.
+1
+
+
+Case 9:08-cv-80736-KAM Document 262 Entered on FLSD Docket 10/09/2014 Page 2 of 3
+The Government does not oppose this motion.
+A proposed order to this effect is attached to this motion.
+For all these reasons, the Court should extend the victim's time to Assert Objections to
+the Government's Assertion of Privilege and otherwise comply with Court Order (DE 257), to
+due on or before October 20, 2014.
+DATED: October 9, 2014
+Respectfully Submitted,
+/s/
+JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 3330
+Telephone (954) 524-2820
+Forida Be No: 42732
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+2
+
+
+Case 9:08-cv-80736-KAM Document 262 Entered on FLSD Docket 10/09/2014 Page 3 of 3
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on October 9, 2014, on the following
+using the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+Assistant U.S. Attorneys
+500 S. Australian Ave.., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter. Lee@usdoj.gov
+E-mail:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+Email: pleading@royblack.com
+(305) 37106421
+(305) 358-2006
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Email: lefkowitz@kirkland.com
+(212) 446-4970
+G. Weinberg, P.C.
+20 Park Plaza
+Suite 1000
+Boston, L
+02116
+Email: owlmgw@att.net
+(617) 227-3700
+(617) 338-9538
+Criminal Defense Counsel for Jeffrey Epstein
+Is/
+3
diff --git a/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.receipt.json b/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..42695d39b5ecc877122c9d7a36d9bfad4767bc53
--- /dev/null
+++ b/vision-fixhub/court-01/ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "ead7aaeafd79694ce27449f62207dc04279c6d9a65cd2e1add03604520dfab8a",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8f8450746e1796c3251bb72fdcc87a304ff5fe8f3a91548992ce1453ab78e8d2",
+  "output_sha256": "f30f25f6de0ca9d7d68c98ffe9e6a3c58f2cb0375b83e53f06791baf94023b19",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/eb29c82b1c98bf953bab93fc3401725244bad9f798d104db61a4bbef10d5c5b5.md b/vision-fixhub/court-01/eb29c82b1c98bf953bab93fc3401725244bad9f798d104db61a4bbef10d5c5b5.md
new file mode 100644
index 0000000000000000000000000000000000000000..96cfa93f97d535fa6df48480d40ecd54cc95ba8f
--- /dev/null
+++ b/vision-fixhub/court-01/eb29c82b1c98bf953bab93fc3401725244bad9f798d104db61a4bbef10d5c5b5.md
@@ -0,0 +1,217 @@
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+Related Cases:
+08-80119, 08-80232, 08-80380, 08-80381,
+08-80994, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFF JANE DOE'S NOTICE THAT ADDITIONAL EVIDENCE OF EPSTEIN'S
+FRAUDULENT ASSET TRANSFERS WILL BE FILED SHORTLY AND MOTION FOR
+CONSIDERATION BY THE COURT OF MATERIALS IN DOCKET NUMBERS 282
+AND 283 IN DETERMINING MOTION FOR APPOINTMENT OF A RECEIVER
+RESTRAINING FRAUDULENT ASSETS TRANSFERS AND INCORPORATED
+MEMORANDUM OF LAW
+Plaintiff Jane Doe (Case #80893), hereby gives notice to the Court that she will
+shortly be filing additional evidence of fraudulent asset transfers by Jeffrey Epstein and
+to move the court to consider these materials and all of the materials found in Docket
+Numbers 282 and 283 in determining whether to grant Jane Doe's Motion for Injunction
+Restraining Fraudulent Transfer of Assets (DE 165 in case no. 9:08-CV-80119).
+ADDITIONAL EVIDENCE OF EPSTEIN'S FRAUDULENT ASSET TRANSFERS
+WILL BE FILED SHORTLY
+As the Court knows, on June 19, 2009, Jane Doe filed a motion asking for
+appointment of a receiver to take control of defendant Jeffrey Epstein's assets and to
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 2 of 8
+CASE NO: 08-CV-80119-MARRA/S
+post a $15 million bond to secure any potential judgment in this case (DE 165 in case
+no. 9:08-CV-80119). The motion alleged that Epstein was hiding hundreds of millions of
+dollars in assets in an effort to defeat any judgment that Jane Doe (and many other
+victims of his child sexual abuse) might obtain against him. On July 13, 2009, Epstein
+filed his response. Without specifically denying any of Jane Doe's allegations of
+fraudulent transfers, Epstein essentially argued that Jane Doe lacked any proof of such
+transfers [DE 198).
+Jane Doe filed a reply to Epstein's response on July 23, 2009 [DE 217]. But, in
+addition to the information and arguments provided there, Jane Doe now wants to alert
+the Court to newly-discovered evidence bolstering her arguments regarding Epstein's
+fraudulent concealment of his assets. Yesterday (October 15, 2009) counsel for Jane
+Doe took the deposition of Larry Visoski, who has been Jeffrey Epstein's personal pilot
+for approximately 18 years, flying (for example) Epstein's Boeing 727 jet. Visoski
+declared that, in the last year, Epstein has transferred to him four very valuable cars
+and a boat and registered them in his (Visoski's) name. A transcript of the deposition
+will not be available until October 22, 2009. But in view of the extreme relevance of this
+information to Jane Doe's pending-motion, she wanted to advise the Court of the
+substance of this testimony immediately - and will provide precise quotations from the
+deposition as soon as it is available.
+While a precise transcript is not yet available, counsel represents that during the
+deposition, Visoski testified that the four cars and the boat were Epstein's, but that they
+were registered in his (i.e., Visoski's) name. The cars are a Land Rover/Range Rover
+2
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 3 of 8
+Sport 2008 that Epstein purchased in the last year; a Mercedes Benz CLK 2005; Jaguar
+X 2005; and a
+_ F250 2008. The F250 is apparently being kept on St.
+Island. Visoski was not aware that the
+F250 was registered in his name, although
+he was aware of the other vehicles that Epstein registered in his (Visoski's) name.
+In addition, Visoski now has a 35-foot JVC Powerboat. Visoski indicated that the
+owner of the boat is LSJ LLC. "LSJ" stands for "Little St. John's" Island and the LLC is
+controlled by Epstein. The boat is now registered in Visoski's name.
+In addition, Visoski, admitted that a 2003 Ferrari 575M, owned by Epstein, is
+currently being sold in his name for an asking price of $159,000. The Ferrari is being
+sold
+in New York, where Epstein maintains a residence.
+See
+http://www.dupontregistry.com/autos/search/DRauSearchDetails.aspx?itemid=437771
+website visited on Oct. 15, 2009). Visoski did not know why the car was being sold in
+his name, and although he found it curious and strange that all these title conveyances
+were taking place, he did not question Defendant Epstein's motives.
+Visoski also testified that he received a Hummer automobile recently from
+Epstein.
+Jane Doe will provide the relevant parts of Visoski's testimony to the Court when
+it becomes available next week and will ask the Court to consider this newly-discovered
+information in ruling on her motion for appointment of receiver to take control of Jeffrey's
+Epstein's assets. Because Epstein has recently given notice to the Court that the
+motion for appointment of a receiver has been pending for roughly 90 days [DE 347]
+and has asked for a prompt ruling on the motion, Jane Doe wanted to promptly alert the
+3
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 4 of 8
+CASE NO: 08-CV-80119-MARRA/_
+Court to this new information. Because this new information also provides additional
+evidence of on-going fraudulent transfers, Jane Doe would join Epstein and respectfully
+request a ruling on her motion for appointment of a receiver as quickly as the Court
+believes that it has the necessary information to rule. A quick ruling is necessary to
+avoid further concealment of assets by Epstein.
+THE COURT SHOULD REVIEW MATERIALS FILED IN DOCKET NUMBERS 282
+AND 283 IN DETERMINING MOTION FOR APPOINTMENT OF A RECEIVER TO
+RESTRAIN FRAUDULENT ASSETS TRANSFERS
+In ruling on Jane Doe's motion for appointment of a receiver, the Court should
+also consider additional evidence not available at the time that Jane Doe filed her
+motion - materials provided by Epstein in camera in DE 282 and DE 283.
+As the Court is aware, Jane Doe propounded requests for production, requests
+for admission, and interrogatories to Epstein to confess his fraudulent transfer of assets.
+Epstein refused to answer any questions about his asset transfers on Fifth Amendment
+grounds. Jane Doe then filed motions to compel answers to these questions. See DE
+194, DE 195 and DE 196.
+Epstein filed responses to the motions to compel, asserting that he was
+confronted with a "substantial and real" threat of criminal prosecution if he answered the
+questions (among others). See DE 339, DE 342 and DE 343. In connection with his
+responses, Epstein cross-referenced sealed, ex parte submissions he had made in
+other pleadings in consolidated cases. Epstein represented that "as set forth in more
+detail in DE 282 and 283" responding to the requests from information about his asset
+transfers would reveal incriminating information. See DE 339 at 13.
+4
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 5 of 8
+Jane Doe now asks the Court to consider these two sealed submissions not only
+in connection with Epstein's argument that he need not respond, but also in connection
+with Jane Doe's motion for appointment of a receiver. If it is true - as Epstein
+represents - that these sealed submissions truly demonstrates that responding to
+questions about asset transfers poses a real risk of criminal prosecution, then that same
+information is obviously relevant to Jane Doe's motion for appointment of a receiver.
+There is, of course, no barrier to the Court considering that information in ruling
+on Jane Doe's motion. Epstein filed the documents under seal not to keep them from
+the Court, but to keep them from Jane Doe. Moreover, there is no Fifth Amendment
+prohibition to considering the information. Epstein has chosen to voluntarily reveal the
+information for his purposes in prevailing on his arguments on his motion to compel.
+The Court should be consider the information not only on that motion but on other
+motions as well. And, in any event, "the Fifth Amendment does not apply in civil cases.
+..." United States v. Scrivner, 167 F.3d 525, 535 (9th Cir. 1999). See U.S. Const.
+amend. V ("No person
+... shall be compelled in any criminal case to be a witness
+against himself
+....") (emphasis added).
+Finally, common sense suggests that the Court should consider the information
+in ruling on Jane Doe's motion for appointment of a receiver. Any other conclusion
+would essentially mean that the Court would have to turn a blind eye to a defendant
+who explains (in a sealed submission) how he is perpetrating an on-going fraud. The
+Court should not bless Epstein's effort to hide his assets. Instead, it should consider all
+5
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 6 of 8
+CASE NO: 08-CV-80119-MARRA/_
+of the information in the sealed submission and, after doing so, should promptly grant
+Jane Doe's motion for appointment of a receiver to prevent fraudulent transfer of assets.
+CONCLUSION
+For all these reasons, the Court should consider the additional information
+described in this pleading in support of Jane Doe's motion for appointment of a receiver
+to prevent fraudulent transfers of assets.
+DATED October 16, 2009
+Respectfully Submitted,
+S/
+J.
+J.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Bivd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+-acsimile (954) 527-866.
+Florida Bar No.: 54207
+E-mail: bedwards@rra-law.com
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+6
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on October 16, 2009 | electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+S/
+SERVICE LIST
+Jane Doe v. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+7
+
+
+Case 9:08-cv-80119-KAM Document 357 Entered on FLSD Docket 10/16/2009 Page 8 of 8
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+8
\ No newline at end of file
diff --git a/vision-fixhub/court-01/eb29c82b1c98bf953bab93fc3401725244bad9f798d104db61a4bbef10d5c5b5.receipt.json b/vision-fixhub/court-01/eb29c82b1c98bf953bab93fc3401725244bad9f798d104db61a4bbef10d5c5b5.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/eb37bf54be460d716eaba20135b6c800a80cdca87d681d830fb8c706fcbe28b3.md b/vision-fixhub/court-01/eb37bf54be460d716eaba20135b6c800a80cdca87d681d830fb8c706fcbe28b3.md
new file mode 100644
index 0000000000000000000000000000000000000000..638301bcd9bacd18211b7fe167ae980781262541
--- /dev/null
+++ b/vision-fixhub/court-01/eb37bf54be460d716eaba20135b6c800a80cdca87d681d830fb8c706fcbe28b3.md
@@ -0,0 +1,87 @@
+Case 9:08-cv-80232-KAM Document 69 Entered on FLSD Docket 04/16/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA|
+JANE DOE NO. 3,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+Defendant's Amended Motion For Extension Of Time In Which To Respond To
+Plaintiff's Motion For Protective Against Piecemeal Depositions Of Jane Doe.
+No.3, Motion To Consolidate Cases For Purposes Of Discovery And Incorporated
+Memorandum Of Law
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+respond to Plaintiff's Motion For Protective Against Piecemeal Depositions Of Jane
+Doe. No.3, Motion To Consolidate Cases For Purposes Of Discovery And Incorporated
+Memorandum Of Law "Motion"). Local General Rule 7.1 A. 1 and Rule 6, Fed. R. Civ. P.
+(2009). Defendant seeks an extension until April 24, 2009 to file his response. As good
+cause in support of granting the motion, Defendant states:
+1. Defendant's response to the Motion is due on or about April 6, 2009, and an
+extension of time was given to April 13, 2009.
+2. Plaintiff's counsel also represents five (5) other Plaintiffs pursuing claims against
+Defendant, EPSTEIN, most of which have filed similar Motions. In order to fully and
+
+
+Case 9:08-cv-80232-KAM Document 69 Entered on FLSD Docket 04/16/2009 Page 2 of 3
+Jane Doe No. 3 v. Epstein
+Page 2
+adequately respond to this and the other motions, Defendant is in need of an extension
+until April 24, 2009.
+3. In addition to the multiple motions, good cause for the extension also includes
+that counsel has been attempting to resolve discovery issues in this and other cases
+against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who
+works extensively on this case is currently out of the office and the undersigned was
+working on and has filed between 12-15 motions and responses in the various cases
+during the time these motions were filed.
+4. The requested extension is fair and reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately respond to this
+and the other motions. In addition, this action is still at its early stages.
+5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
+Plaintiff's counsel is in agreement with the requested extension.
+WHEREFORE, Defendant requests that this Court enter an order granting
+Defendant an extension until April 24, 2009, in which to respond to the Above Motion.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and
+Defendant to respond to the Motion.
+ROBERTD. CRITTON, JR., ESQ.
+
+
+Case 9:08-cv-80232-KAM Document 69 Entered on FLSD Docket 04/16/2009 Page 3 of 3
+Jane Doe No. 3 v. Epstein
+Page 3
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+nanner specified by CM/ECF on this fo
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #3
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/eb37bf54be460d716eaba20135b6c800a80cdca87d681d830fb8c706fcbe28b3.receipt.json b/vision-fixhub/court-01/eb37bf54be460d716eaba20135b6c800a80cdca87d681d830fb8c706fcbe28b3.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/eb7f23e2495c68109ea2423d4c3e16b11dbdda5b238c06698198d8be4fa51b0b.md b/vision-fixhub/court-01/eb7f23e2495c68109ea2423d4c3e16b11dbdda5b238c06698198d8be4fa51b0b.md
new file mode 100644
index 0000000000000000000000000000000000000000..b2369b172ab30e4ad0265ecccfcf9a62ea546810
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@@ -0,0 +1,34 @@
+Case 1:20-cv-00484-JGK-DCF Document 10 Filed 01/23/20 Page 1 of 1
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman™
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz(@troutman.com
+January 23, 2020
+ECF
+Hon. John G. Koelti
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007-1312
+Re:
+Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as co-executors
+of the Estate of Jeffrey E. Epstein, and Ghislaine Maxwell, 1:20-cv-00484-JGK
+Dear Judge Koeltl:
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E.
+Epstein (together, the "Co-Executors"), in the above-referenced action. We write to respectfully
+request the Court's approval of the parties' agreement described below.
+On January 22, 2020, subject to the Court's approval: (1) we agreed to accept service of
+Plaintiff's Complaint (ECF #9) on the Co-Executors' behalf; (2) Plaintiff consented to the Co-
+Executors having through Monday, March 23, 2020 to answer, move or otherwise respond to
+Plaintiff's Complaint and Motion to Proceed by Pseudonym (ECF #5); and (3) the parties agreed
+to adjourn the initial case conference in this matter to a mutually agreeable time after the Co-
+Executors' deadline to respond to the Complaint. There have been no previous requests for
+adjournments or extensions of time in this action.
+Respectfully submitted,
+Is/ Bennet J. Moskowitz
+Bennet J. Moskowitz
diff --git a/vision-fixhub/court-01/eb7f23e2495c68109ea2423d4c3e16b11dbdda5b238c06698198d8be4fa51b0b.receipt.json b/vision-fixhub/court-01/eb7f23e2495c68109ea2423d4c3e16b11dbdda5b238c06698198d8be4fa51b0b.receipt.json
new file mode 100644
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ae78fc47a0daa9c9e01073a2f8ef82128962acd702b6934004d31fc90fc3a5ac",
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/eb7f53d5181483ae87c0eaa601816fab7057018b9dd99a63b87b522a63bd78bf.md b/vision-fixhub/court-01/eb7f53d5181483ae87c0eaa601816fab7057018b9dd99a63b87b522a63bd78bf.md
new file mode 100644
index 0000000000000000000000000000000000000000..672395cbc4ec9d60b249dd1e555ebe51945641a6
--- /dev/null
+++ b/vision-fixhub/court-01/eb7f53d5181483ae87c0eaa601816fab7057018b9dd99a63b87b522a63bd78bf.md
@@ -0,0 +1,1314 @@
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 1 of 33
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+Case No. 1:20-cv-00484-JGK
+DECLARATION OF ROBERT S. GLASSMAN
+ROBERT GLASSMAN, pursuant to 28 U.S.C. § 1746, declares under penalty of perjury
+that the following is true and correct:
+I am an attorney at the law firm Panish, Shea & Boyle LLP and am admitted before
+this Court. I represent Plaintiff Jane Doe in this matter.
+2.
+I respectfully submit this Declaration in support of Plaintiff's Motion to Approve
+Alternate Service Pursuant to Federal Rule of Civil Procedure 4(e)(I).
+3.
+Attached hereto as Exhibit 1 are true and correct copies of declarations provided
+by process servers documenting five (5) unsuccessful attempts at service on Maxwell at addresses
+associated with her in both Florida and New York: 116 E. 65th Street, New York, NY 10065; 457
+Madison Avenue, 4th Floor, New York, NY 10022; 1000 Venetian Way, APT 801, Miami Beach,
+FL 33139; 358 El Brillo Way, Palm Beach, FL 33480; 20 E 66th ST, New York, NY 10065. My
+office conducted extensive Internet searches on Maxwell's whereabouts to find the addresses at
+which service was attempted.
+Attached hereto as Exhibit 2 is a true and correct copy of an email that my office
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 2 of 33
+sent to gmax@ellmax.com on April 24, 2020 which attached a copy of the Complaint in this
+matter (ECF No. 9) and the summons as to Ghislaine Maxwell (ECF No. 17). We did not receive a
+response to that email, nor did we receive any indication that the email had not been delivered.
+We also sent the same email to several other email addresses associated with Maxwell (namely,
+hello@theterramarproject.org; gmaxwell@theterramarproject.org;
+maxwellg@theterramarproject.org: ghislaine@theterramarproject.org;
+gmax @theterramarproject.org; maxwell@theterramarproject.org;
+ghislaine.maxwell@theterramarproject.org), but received no response.
+5.
+Attached hereto as Exhibit 3 is a true and correct copy of the April 2, 2020 letter
+that my office sent to Maxwell's attorney Laura A. Menninger of Haddon,
+and
+P.C. Enclosed in the letter is a copy of the Complaint in this matter (ECF No. 9) and the summons
+as to Ghislaine Maxwell (ECF No. 17).
+6.
+Attached hereto as Exhibit 4 is a true and correct copy of a letter from Maxwell's
+attorney Laura A. Menninger dated April 13, 2020 in which she indicated she is not authorized to
+accept service on behalf of Maxwell.
+Despite these enormous efforts, we have been unable to effectuate service on
+Maxwell.
+8.
+Attached hereto as Exhibit 5 is a true and correct copy of the order issued by this
+Court in
+v. Epstein, 2018 WL 637421, at *1 (S.D.N.Y. Jan. 30, 2018), in which the Court
+found service upon Maxwell to be impracticable and approved Plaintiff serving the complaint and
+summons on Maxwell's attorneys as Haddon
+as an appropriate mode of alternative
+service.
+9.
+In the
+v. Indyke, et al., 1:19-cv-10475-LGS-DCF (S.D.N.Y.), which is
+related to this case, the court granted alternate service in a text-only order issued on February 12,
+2020 which appears as ECF No. 27 as follows: "ORDER granting 18 Motion to Approve Alternate
+Service on Defendant Ghislaine Maxwell ("Maxwell"). Plaintiff's motion is unopposed, and, based
+on her representations regarding her inability to locate a current address for Maxwell despite
+diligent efforts, the Court finds that Plaintiff has adequately demonstrated that personal service
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 3 of 33
+would be impracticable. See
+v. Epstein, No. 17cv616 (JGK), 2018 WL 637421, at *1
+(S.D.N.Y. Jan. 30, 2018). This Court further finds that Plaintiff's provision of a copy of the
+Summons and Complaint by email to Maxwell's counsel of record in another action before the
+Court (
+v. Maxwell, 15cv7433 (LAP)(S.D.N.Y.)), as well as to an email address publicly
+associated with Maxwell (see Plaintiff's Memorandum (Dkt. 19), at 3), was reasonably calculated
+to place Maxwell on notice of this suit and to constitute sufficient service under the circumstances.
+No later than 2/14/20, Plaintiff is directed to serve Maxwell with a copy of this Text Order by the
+same means (i.e., by email to Maxwell's counsel of record in the
+case and to the email
+address publicly associated with Maxwell), and to file proof of such service on the Docket of this
+action. Maxwell may then have until 3/6/20 to move, answer, or otherwise respond to the
+Complaint. (HEREBY ORDERED by Magistrate Judge Debra Freeman)(Text Only Order)
+(Freeman, Debra) (Entered: 02/12/2020)."
+Respectfully submitted,
+Dated: May 27, 2020
+Los Angeles, California
+Robert Glassman
+3
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 4 of 33
+
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20
+ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
+Robert S Glassman,Esq SBN: Bar No.269816
+11111 Santa Monica Bivd Sulte 700 GLORIA CELL$ 213-444-8132 Los Angeles, CA 90025
+TELEPHONE NO.: (310) 477-1700
+FAXNO: (310) 477-1699
+E-MAIL ADDRESS (Optonal):
+ATTORNEY FOR (Name):
+UNITED STATED DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+STREET ADORESS: 40 FOLEY SQUARE ROOM 435
+CITY AND ZIP CODE: NEW YORK, NY 10007
+
+FOR COURT USE ONLY
+HEARING DATE:
+HEFERENCE NUNBER:
+DOE/INDYKE
+Plaintiff(s): JANE DOE
+Defendants): DARREN K. INDYKE, et al.
+CASE NUMBER
+1:20-cv-004B4-JG
+DECLARATION OF DILIGENCE
+I received the within assignment for filing and/or service on April 24, 2020 and that after due and diligent effort I have
+not been able to serve said person.I attempted service on this servee on the following dates and times:
+Servee: Ghislaine Maxwell
+Documents: COMPLAINT FOR DAMAGES;SUMMONS IN A CIVIL ACTION;
+Address: 457 Madison Avenue 4th Floor
+New York, NY 10022
+As enumerated below:
+4/24/2020 - 7:40 PM
+457 Madison Avenue, 4th Floor
+Business
+New York, NY 10022
+ad address. This is a mutti dwelling apartment complex under the name of Lotte New York. Spoke with Jerry 1 Securi
+upervisor for the building who informed me that the whole building is empty at this time due to the corona virus. No one
+currently residing here. No further information provided nor guard would confirm nor deny if subject resides here.
+N
+County:
+Registration No.:
+Nationwide Legal. LLI
+1609 James M
+Blvd.
+Los Angeles, CA 90015
+Signature:
+DECLARATION OF DILIGENCE
+Michaels. Levey
+Order#: LA51503/DIIFormat.mdi
+
+
+Case 1:20-cv-00484-JGK-DCF
+Document 43-2 Filed 05/27/20
+ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address)
+Robert S Glassman,Esq SBN: Bar No.269816
+11111 Santa Monica Bivd Sulte 700 GLORIA CELL# 213-444-8132 Los Angeles, CA 90025
+TELEPHONE NO.: (310) 477-1700
+FAXNO: (310) 477-1699
+E-MAIL ADDRESS (Oprional):
+ATTORNEY FOR (Nama):
+UNITED STATED DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+STREET ADORESS: 40 FOLEY SQUARE ROOM 435
+CITY AND ZIP CODE: NEW YORK, NY 10007
+
+FOR COURT USE ONLY
+REFERENCE NUMBER
+HEARING DATE:
+DOEJINDYKE
+Plaintiffs): JANE DOE
+Defendant(s): DARREN K. INDYKE, et al.
+DECLARATION OF DILIGENCE
+CASE NUMBER.
+1:20-cv-00484JG
+I received the within assignment for filing and/or service on April 24, 2020 and that after due and diligent effort I have
+not been able to serve said person./ attempted service on this servee on the following dates and limes:
+Servee: Ghislaine Maxwell
+Documents: COMPLAINT FOR DAMAGES;SUMMONS IN A CIVIL ACTION;
+Address: 457 Madison Avenue 4th Floor
+New York, NY 10022
+As enumerated below:
+4/24/2020 - 7:17 PM
+116 E. 65th Street
+Home
+New York, NY 10065
+Bad address. This is a 4/5 story
+building. Doors locked. No one seen or heard inside the buliding. All shades are
+drawn shut, there is not a single light on in any of the floors nor on in any of the units. The whole builidiing is dark. There a
+2019 construction permit posted on the door from the city of New York for work to be performed there. Could not establish
+contact with anyone at this address.
+4/24/2020 — 7:29 PM
+20 E 66TH ST
+Home
+New York, NY 10065
+Bad address. This is a multi dwelling apartment complex. No names listed on the directory. Spoke with building
+superintendant by the name of Cesar Abreu, who stated that subject, Ghislaine Maxwell is not known to him, nor is she i
+tenant there according to his list of tenants. No further information provided.
+County:
+Los Angeles, CA 90015
+Signature:
+DECLARATION OF DILIGENCE
+Michael S. Levey
+Order#: LAS1503/DilFormat.mdf
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 7 of 33
+AFFIDAVIT OF NON-SERVICE
+District of New York
+Index Number: 1:20-CV-00484
+Date Filed: 1/28/2020
+Plaintiff:
+JANE DOE
+VS.
+Defendants:
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual
+For:
+Kevin Boyle, Esquire
+11111 Santa Monica Blvd.
+Suite 700
+Los Angeles, CA 90025
+Received by U Got Served, LLC on the 24th day of April, 2020 at 12:17 pm to be served on GHISLAINE MAXWELL, 358 EL
+BRILLO WAY, PALM BEACH, FL 33480.
+1, Sandra Harris, being duly sworn, depose and say that on the 25th day of April, 2020 at 9:58 am, I:
+NON-SERVED the SUMMONS IN A CIVIL ACTION AND COMPLAINT FOR DAMAGES, DEMAND FOR JURY TRIAL for
+the reason that I failed to find GHISLAINE MAXWELL or any information to allow further search. Read the comments below
+for further details.
+Additional Information pertaining to this Service:
+4/24/2020 3:11 pm Service was attempted at 358 EL BRILLO WAY, PALM BEACH, FL 33480; the property has a gate with a
+call box; no one answered. I was unable to gain access to the property. The windows of the property have shutters.
+4/25/2020 9:58 am Attempted service at 358 EL BRILLO WAY, PALM BEACH, FL 33480; The home caretaker came to the
+house while I was parked on front of the property. He stated that the Defendant does not live at this address. He has been
+living here for the last 3 years. I also spoke with the maintenance man at the house across the street; He stated that he has
+not seen the Defendant at the property.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 8 of 33
+AFFIDAVIT OF NON-SERVICE For 1:20-CV-00484
+I certify that I am over the age of 18, have no interest in the above action, and 1 am a Certified Process Server, in good standing,
+in the Judicial Circuit in which the process was served. Pursuant to F.S. 95.525 "Under penalties of perjury", I declare that I have
+read the foregoing Return of Service and that the facts stated in it are true and correct" Notary not required as per FS 92.525.
+VICTOR R.
+MY COMMISSION # GG 968335
+EXPIRES: March 11, 2024
+Bonded Thru Notary Public Underwriters
+State of Florida
+_County of Palm Beach
+Sworn and Subscribed before me on this 28_day
+of rigil
+_2020. By
+Personally known
+or Produce identification
+Type of identification
+produced Liver licensE
+NOTARY PUBLIC
+NAME Victor Garcia
+My Commission Expires
+march 1, 20-4
+Xamchattans
+Sandra Harris
+#1682
+U Got Served, LLC
+1279 W. Palmetto Park Road
+Unit 273938
+Boca Raton, FL 33427
+(561) 361-7111
+Our Job Serial Number: AOA-2020000803
+Ref: Kevin Boyle, Esquire
+Copyright © 1992-2020 Database Services, Inc. - Process Server's Toolbax VB. te
+
+
+Filed 05/27/20 Page 9 of 33
+AFFIDAVIT OF NON-SERVICE
+District of New York
+Index Number: 1:20-CV-00484
+Date Filed: 1/28/2020
+Plaintiff:
+JANE DOE
+VS.
+Defendants:
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual
+For:
+Kevin Boyle, Esquire
+11111 Santa Monica Blvd.
+Suite 700
+Los Angeles, CA 90025
+Received by U Got Served, LLC on the 24th day of April, 2020 at 12:17 pm to be served on GHISLAINE MAXWELL, 1000
+VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139.
+1, Natasha Caplan, being duly sworn, depose and say that on the 24th day of April, 2020 at 8:00 pm, I:
+NON-SERVED the SUMMONS IN A CIVIL ACTION AND COMPLAINT FOR DAMAGES, DEMAND FOR JURY TRIAL for
+the reason that I failed to find GHISLAINE MAXWELL or any information to allow further search. Read the comments below
+for further details.
+Additional Information pertaining to this Service:
+4/24/2020 8:00 pm Service was attempted at 1000 VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139; I knocked on the
+door and no one answered. I heard music and noise inside the apartment. I spoke with the security guard; he did not know who
+was GHISLAINE MAXWELL. I showed him a picture of her and he stated that he has not seen her. I also spoke with the
+employees at the front desk who stated that they have not seen her. They also did not recognize her from the picture. She is not
+listed as a resident. The Keffler Family is listed a living at that unit.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 10 of 33
+AFFIDAVIT OF NON-SERVICE For 1:20-CV-00484
+I certify that I am over the age of 18, have no interest in the above action, and I am a Certified Process Server, in good standing,
+in the Judicial Circuit in which the process was served. Pursuant to F.S. 95.525 "Under penalties of perjury", I declare that I have
+read the foregoing Return of Service and that the facts stated in it are true and correct" Notary not required as per FS 92.525.
+State of Florida County of
+MAM: DAdE
+Sworn and Subscribed before me on this. 28 day
+Apriy
+2020. B
+HASTA A. CADAI
+Personally known
+_ or Produce identification
+Type of identification
+produced
+NAME_
+My Commission Ex 14/2023
+Natasha Caplan
+CPS #2327
+Stephanie Nin
+a NOTARY PUBLIC
+É STATE OF FLORIDA
+€ Comm# GG299147
+Expires 2/6/2023
+Copyright © 1992-2020 Database Services. Inc. - Process Server's Toolbax VB.1c
+U Got Served, LLC
+1279 W. Palmetto Park Road
+Unit 273938
+Boca Raton, FL 33427
+(561) 361-7111
+Our Job Serial Number: AOA-2020000802
+Ref: Kevin Boyle, Esquire
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 11 of 33
+Case 1:20-cv-00484-JGK-DCF Document 17 Filed 01/28/20 Page 2 of 2
+AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (D))
+This summons for (name of individual and title, if any) GHISLAINE MAXWELL
+was received by me on (date)
+4/24/2020
+• I personally served the summons on the individual at (place)
+on (date)
+; or
+• I left the summons at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the summons on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+* I returned the summons unexecuted - 1 attempted service on 4/24/2020 at 8:00
+p.m. at 1000 VENETIAN WAY, APT 801, MIAMI BEACH, FL 33139; I knocked
+on the door and no one answered. I heard music and noise inside the apartment. I
+spoke with the security guard; he did not know who was GHISLAINE MAXWELL
+I showed him a picture of her and he stated that he has not seen her. I also spoke
+with the employees at the front desk who stated that they have not seen her. They
+also did not recognize her from the picture. She is not listed as a resident. The
+Keffler Family is listed a living at that unit.
+• Other (specify):
+, who is
+My fees are S
+for travel and S
+for services, for a total of $
+0.00
+1 declare under penalty of perjury that this information is true.
+Date: 4/28/20
+Magda
+NATASHA CAPLAN, CPS #2327
+Printed name and title
+U Got Served, LLC, 1279 W. Palmetto Park Rd.,
+#273938, Boca Raton, Fl 33427
+Server's address
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 12 of 33
+
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 13 of 33
+Keilah Betts
+From:
+Sent:
+To:
+Cc:
+Subject:
+Attachments:
+Keilah Betts
+Friday, April 24, 2020 8:49 AM
+'gmax@ellmax.com'
+Robert Glassman; Nathan Werksman; Claudia Lomeli
+DOE, Jane v. The Estate of Jeffrey Epstein et al.:
+SUMMONS.pdf; COMPLAINT.pdf
+Ms. Maxwell,
+Please be advised that this office represents a victim of Jeffrey Epstein, Jane Doe, who filed a lawsuit against you on
+January 22, 2020 in the Southern District of New York (Docket No. 20-cv-00484). I am attaching Jane Doe's summons and
+complaint to this email. We sent these documents to your attorney already and requested that she accept service on
+your behalf. Your attorney refused to accept service. Please confirm receipt of this email.
+Thank you,
+Keilah Betts
+Panish Shea & Boyle LLP
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: betts@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 14 of 33
+
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 15 of 33
+PANISH
+SHEA &
+BOYLE
+LLP
+April 2, 2020
+VIA U.S. MAIL, FACSIMILE & EMAIL
+Laura A. Menninger
+Haddon,
+and
+, P.C
+150 East 10th Avenue
+Denver, Colorado 80203
+Fax: (303) 832-2628
+Email: Imenninger@hmflaw.com
+Re: Jane Doe v. Darren Indyke, et al., 20-cv-00484 (JGK) (DCF)
+Dear Ms. Menninger:
+Please be advised that we represent a woman identified as plaintiff Jane Doe in the
+above-referenced litigation filed in the Southern District of New York. It is our understanding
+that you represent Ghislaine Maxwell in a related action entitled
+v. Darren Indyke, et al.
+(19-cv-10475-LGS-DCF) and appeared as counsel of record for Ms. Maxwell in that action on
+March 4, 2020. Ms. Maxwell has also been named a defendant in our case.
+Pursuant to the Court's order in
+v. Epstein, et al., 17-cv-616 (JGK), ECF No.
+107, and the Court's order in
+_ ECF No. 27, the delivery of this letter and its attachments
+(including plaintiff's complaint and summons) to you and your law firm, as counsel of record for
+defendant Maxwell, shall constitute service of the complaint and summons as to defendant
+Ghislaine Maxwell.
+Considering the well-documented impracticability of other methods of service on
+detendant Maxwell and the fact that you and your firm are actively representing Ms. Maxwell in
+other pending related litigation before the same court, this method of service is reasonably
+calculated to provide defendant Maxwell with notice of this lawsuit and an opportunity to
+respond.
+Accordingly, we are requesting that you agree to appear on behalf of Ms. Maxwell and
+respond to the complaint within twenty-one (21) days in lieu of us seeking another court order
+granting permission to effectuate service on Ms. Maxwell by alternative service pursuant to
+FRCP 4(e)(I). If Ms. Maxwell chooses not to appear, we may pursue any and all available
+remedies, including the entry of a default judgment. Please do not hesitate to contact me should
+you wish to discuss any of the foregoing.
+11111 Santa Monica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com
+
+
+Filed 05/27/20
+Laura A. Menninger
+Haddon,
+and
+April 2, 2020
+Page 2
+, P.C.
+PARISHi
+SHEA &
+BOYLE™
+Very truly yours,
+PANISH SHEA & BOYLE
+Robert S. Glassman
+Encls.
+
+
+AO 440 (Rev, 06/12) Summons in a Civil Action
+for the
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiffs)
+V.
+Civil Action No. 1:20-cv-00484
+DARREN K. INDYKE and RICHARD D. KAHN, in their
+capacities as executors of the ESTATE OF JEFFREY E. EPSTEIN, et al.
+Defendant(s)
+)
+SUMMONS IN A CIVIL ACTION
+To: (Defendant's name and address)
+Ghislaine Maxwell
+116 East 65th Street,
+New York, NY 10065
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
+ire the United States or a United States agency, or an officer or employee of the United States described in Fed. R. CIv
+. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 o
+the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
+whose name and address are: Kevin R. Boyle
+Robert S. Glassman
+Panish Shea & Boyle LLP
+11111 Santa Monica, Blvd., Suite 700
+Los Angeles, CA 90025
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
+You also must file your answer or motion with the court.
+CLERK OF COURT
+Date:
+01/28/2020
+TES DISTA
+/a/D. Howie
+Signature of Clerk or Deputy Clerk
+NEW YOR
+
+
+AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (D)
+This summons for (name of individual and title, if any)
+was received by me on (date)
+• I personally served the summons on the individual at (place)
+on (date)
+; or
+] I left the summons at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the summons on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+, who is
+• I returned the summons unexecuted because
+• Other (specify):
+; or
+My fees are $
+for travel and $
+for services, for a total of $
+0.00
+I declare under penalty of perjury that this information is true.
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc:
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 162864120181-0618495K Doeument $3-filed 091225287/Page Rase109 of 33
+1
+2
+SOUTHERN DISTRICT OF NEW YORK
+3
+4
+5
+JANE DOE,
+Plaintiff,
+Case No. 1:20-cv-00484
+6
+7
+8
+9
+10
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+DEMAND FOR JURY TRIAL
+=
+12
+Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges as follows:
+13
+INTRODUCTION
+14
+This case arises out of years of sexual abuse and exploitation of a young girl by
+15
+notorious pedophile and convicted sex offender Jeffrey Epstein ("Epstein"). It all started in 1994
+16
+when 13-year-old Jane Doe met Epstein and Defendant Ghislaine Maxwell ("Maxwell") at a
+17
+summer camp in Michigan. Jane Doe was their first known victim and was subsequently abused
+18
+by Epstein and Maxwell for years as a young girl, suffering unimaginable physical and
+psychological trauma and distress. Despite that, Jane Doe has persevered and survived to tell her
+20 | story, to hold her perpetrators accountable and to seek justice for the atrocities committed against
+21 her.
+22
+Throughout his life, Epstein systematically perpetrated acts of molestation,
+23
+exploitation, assault and rape on hundreds of young girls. Epstein's system of abuse was
+24| facilitated in large part by his co-conspirator and accomplice, Maxwell, who helped supply him
+25
+with a steady stream of young and vulnerable girls—many of whom were fatherless, like Jane
+26
+Doe, and came from struggling families.
+27
+28
+1
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 1628€4120481-061849EK Doeument $3-filedF091225287/₽age 2asre180 of 33
+1
+2
+3
+3.
+This system, which took years to develop, all started with them exploiting and
+abusing Jane Doe who they used as a guinea pig to refine their criminal enterprise and widen their
+network of additional sexual abuse victims.
+4
+THE PARTIES
+5
+4.
+Plaintiff Jane Doe is a citizen of the State of California. At all times relevant to this
+6
+suit, Doe was a minor child living in Florida and New York and who was sexually abused while
+7
+she was a minor by Defendants in New York.
+8
+5.
+Defendant Ghislaine Maxwell is domiciled in the State of New York.
+9
+6.
+Defendant Darren K. Indyke is sued in his capacity as an appointed executor of the
+10
+Estate of Jeffrey E. Epstein.
+11
+7.
+Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the
+12
+| Estate of Jeffrey E. Epstein.
+13
+JURISDICTION AND VENUE
+14
+8.
+Plaintiff is domiciled in California.
+15
+Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin
+16
+Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein,
+17
+Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands. The matter
+in controversy exceeds the sum of $75,000, and therefore jurisdiction in this Court is proper. 28
+19
+U.S.C. § 1332(c)(2).
+20
+10. Ghislaine Maxwell is domiciled in New York.
+21
+11. A substantial part of the events giving rise to these causes of action occurred in the
+22| Southern District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2).
+23
+JURY DEMAND
+24
+12. Plaintiff hereby demands a trial by jury on all of her claims in this action.
+25
+FACTUAL ALLEGATIONS
+26
+Epstein and Maxwell's Abuse of Doe
+27
+13. In the summer of 1994, Jane Doe met Jeffrey Epstein and Ghislaine Maxwell at
+28| Interlochen Arts Camp in Michigan when she was only 13-years-old. Doe was there as a student
+2
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 162864120181-0618495K Doeument $3-filed 091225287/Page Base181 of 33
+1
+3
+4
+5
+6
+7
+in the voice program. Doe was sitting alone on a bench between classes when Epstein and
+Maxwell approached her. Epstein bragged to her about being a patron of the arts and giving
+scholarships to talented young artists like Doe. Epstein and Maxwell probed her at length about
+her background, family situation and where she lived. As Doe got up to leave, Epstein requested
+her mother's phone number back in Florida. She was alarmed by his request, but also feared that
+she could not refuse the older man's request so she complied and provided him with the phone
+number.
+8
+14.
+Several weeks later, once Doe had returned from Michigan to Florida, Epstein
+9
+10
+11
+12
+13
+called Doe's home. Epstein first spoke with Doe's mother about how he mentors young kids and
+provides scholarships for the arts. He requested to speak to Doe and invited her and her mother to
+his mansion in Palm Beach. He sent a driver across town to pick them up.
+15. Over the course of the next several months, Epstein and Maxwell attempted to
+groom and mentor 13-year-old Jan Doe. Epstein gave himself the name of Doe's "godfather"
+14
+while Maxwell acted like an older sister to her. They took her to movies, went shopping with her
+15
+and lounged around Epstein's estate with her. Epstein and Maxwell then started to make sexual
+16
+references when they were with her. For instance, Maxwell told Doe that having sex with ex-
+17
+boyfriends was easy because once you slept with them "they've been grandfathered in and you
+18
+could go back and fuck them whenever you wanted." Epstein also started to slowly display his
+19
+pedophilic ways when shopping with Doe and Maxwell. Instead of Doe picking out clothes she
+20
+wanted to wear, Epstein insisted that she pick out and wear little children's cotton underwear.
+21
+Also, after nearly every visit with Epstein and Maxwell, Epstein sent Doe home with two or three
+22
+one-hundred-dollar bills to give her mother since "she's having a hard time and struggling as a
+23
+widow."
+24
+16.
+While these visits made Doe extremely uncomfortable, Epstein and Maxwell made
+25
+her feel she could not refuse them. During this time, Epstein started to pay for voice lessons for
+26
+Doe and insisted that Doe could not advance her career in any way without him. When Doe
+27
+expressed hesitation about spending time with Epstein and Maxwell or acquiescing to their
+28
+desires, Epstein and Maxwell would threaten Doe, and scold her for being "ungrateful".
+3
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 16864120181-0618095K Doeument $3-filed 091225287/Page 9ase182 of 33
+1
+2
+3
+4
+5
+17.
+During one of Doe's encounters with Epstein, he took her to Mar-a-Lago where he
+introduced her to its owner, Donald J. Trump. Introducing 14-year-old Doe to Donald J. Trump,
+Epstein elbowed Trump playfully asking him, referring to Doe, "This is a good one, right?"
+Trump smiled and nodded in agreement. They both chuckled and Doe felt uncomfortable, but, at
+the time, was too young to understand why.
+6
+18.
+Towards the end of 1994, Epstein invited Doe into his pool house, where he
+7
+grabbed her, put her on his lap and started masturbating. Epstein told her that was what to expect
+from photographers who were soon going to be take modeling pictures of her. However, when
+9
+Doe was ultimately photographed by these professional photographers, they did no such thing.
+10
+19.
+Over the next few years, the sexual abuse escalated. On a regular basis, Epstein
+11
+would digitally penetrate Doe, force Doe to perform sexual acts on him and apply vibrators on
+12
+different parts of Doe's body. The abuse occurred at Epstein's home in Palm Beach, Florida,
+13
+Epstein's townhouse on 9 East 71st Street in New York City, and Epstein's ranch in New Mexico.
+14
+When travelling to these places, Doe often flew with Epstein and Maxwell in Epstein's private jet.
+15
+20.
+In 1996, when Doe was 16-years-old, Epstein moved Doe to New York City. At
+16
+first, Epstein put Doe up in his apartment on 65th Street and 2nd Avenue. After a few months,
+17
+Epstein co-signed the lease for Doe and Doe's mother for an apartment. Additionally, Epstein paid
+18
+her tuition at a private high school in Manhattan as well.
+19
+21.
+Once Epstein had secured Doe in New York and made her and her family
+20 | completely dependent on him financially (including, for the roof over their heads), Epstein's abuse
+21
+of Doe continued to escalate.
+22
+22.
+In 1997, while at Epstein's townhouse on 9 East 71st Street in the City of New
+23
+York, Epstein asked 17-year-old Doe if she had a boyfriend. Doe replied that she did not. Epstein
+24
+responded that when she did have a boyfriend she would want the sex to be "good" and that she
+25
+should "get it over with already," meaning lose her virginity. Despite Doe's resistance, Epstein
+26
+then pushed Doe down onto her stomach and raped her. From that point forward for several years
+27
+in New York, Epstein raped Doe on multiple occasions.
+28
+4
+
+
+Case 16864120181-0618495K Doeument $3-filed 091225287/Page Basre183 of 33
+1
+23.
+During Doe's time in New York, Maxwell also regularly facilitated Epstein's abuse
+2
+of Doe and was frequently present when it occurred.
+3
+24.
+In 1999, Doe moved to Los Angeles to start a career. Upon moving to Los Angeles
+4
+and being physically away from Epstein and Maxwell, Doe finally felt like she could escape
+5
+Epstein's abuse and stopped returning his frequent calls where he would threaten and berate her for
+6
+not appreciating him.
+7
+25.
+Despite Doe's physical escape from Epstein and Maxwell, the years of abuse and
+8
+exploitation perpetrated against her by them cause her immeasurable pain and suffering every day.
+Epstein's Death and Will
+10
+26.
+In July 2019, Epstein was indicted by the Unites States Attorney's Office for the
+11
+Southern District of New York.
+12
+27.
+On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan
+13
+Correctional Center, where he was being held pending trial. Upon information and belief, New
+14
+York City's medical examiner concluded Epstein died by suicide.
+15
+28.
+On August 15, 2019, Epstein's last will and testament (the "Will"') was filed in the
+16
+Probate Division of the Superior Court of the Virgin Islands.
+17
+29.
+The Will indicated that it was executed by Epstein on August 8, 2019 at the
+18
+Metropolitan Correctional Center. The Will was accompanied by affidavits from Darren K.
+19
+Indyke and Richard D. Kahn attesting to their "Oath of Willingness to Serve as Executor and
+20
+Appointment of Local Counsel." Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for
+21
+Letters Testamentary in the Superior Court of the Virgin Islands.
+22
+30.
+The Will's first article directs Epstein's executors "to pay from my estate all
+23
+expenses of my last illness, my funeral and burial expenses, the administration expenses of my
+24
+estate and all of my debts duly proven and allowed against my estate." The Will further directs
+25
+that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my
+26
+property, real and personal, wherever situated..to the then acting Trustees of The 1953 Trust."
+27
+28
+5
+
+
+Case 16864120181-0618495K Doeument $3-filed 091225287/Page Basre184 of 33
+1
+2
+3
+31.
+On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with
+the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are
+the two Trustees of The 1953 Trust.
+4
+32.
+On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the
+5
+Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and
+6
+authorized Mr. Indyke and Mr. Kahn to administer the estate.
+7
+FIRST CAUSE OF ACTION
+8
+(Sexual Assault)
+9
+33.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+10
+if set forth fully herein.
+11
+34.
+On numerous occasions over several years, Epstein, with Maxwell's assistance,
+12
+made violent sexual demands on Plaintiff while placing his hands on her body in a position of
+13
+dominance and control and while touching Plaintiff in violent and invasive ways.
+14
+35.
+These demands, often made when young Plaintiff was alone with Epstein or with
+15
+only Epstein and Maxwell, were intended to frighten Plaintiff into submitting to his sexual
+16
+demands and placed Plaintiff in apprehension of harm.
+17
+36.
+This conduct caused Plaintiff serious and persistent harm and contributed to
+18 injuries that Plaintiff continues to suffer.
+19
+37.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+20 (McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+21
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+22 the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+23
+SECOND CAUSE OF ACTION
+24
+(Sexual Battery)
+25
+38.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+26 if set forth fully herein.
+27
+39.
+On numerous occasions over several years, Epstein raped Doe.
+28
+6
+
+
+Case 162864120181-0618295K Document 93-filed 091225287/Page 7a8185 of 33
+1
+40.
+On numerous occasions over several years, Epstein digitally penetrated Doe with
+2
+his fingers, tongue and foreign objects.
+3
+41.
+On numerous occasions over several years, Epstein made otherwise unwanted,
+4
+unlawful, harmful, and offensive physical contact with Plaintiff's body.
+5
+42. This conduct caused Plaintiff serious and persistent harm and contributed to
+6
+injuries that Plaintiff continues to suffer.
+7
+43.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+9 under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+11
+THIRD CAUSE OF ACTION
+12
+(Intentional Infliction of Emotional Distress)
+13
+44.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+14
+if set forth fully herein.
+15
+45.
+Epstein and Maxwell's campaign of sexual abuse against a teenaged Plaintiff was
+16
+extreme and outrageous conduct that shocks the conscience.
+17
+46.
+Epstein and Maxwell's serial sexual assaults, committed during the course of a
+methodical plan of recruitment, enticement, and attack, inflicted severe pain and anguish upon
+19 Plaintiff.
+20
+47. Epstein and Maxwell directed this conduct at Plaintiff and knew that it would cause
+21
+severe and lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting
+22
+emotional distress and serious injuries to her mental health.
+23
+48.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+24
+•(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+25
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+26
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. $ 130.55.
+27
+FOURTH CAUSE OF ACTION
+28
+(Negligent Infliction of Emotional Distress)
+7
+
+
+310.477.1700 phone - 310.477.1699 fax
+Case 162864120481-0618495K Doeument $3-filed 091225287/Page 8a5186 of 33
+1
+49.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+2
+if set forth fully herein.
+3
+50.
+Epstein and Maxwell coaxed Plaintiff, then a teenaged girl, into Epstein's home for
+4
+a period of several years. They worked hard to groom her. Once under their supervision and
+5
+influence, Epstein and Maxwell proceeded methodically to sexually abuse Plaintiff.
+6
+51.
+Epstein and Maxwell's conduct was extreme and outrageous, breached a duty owed
+7
+directly to Plaintiff, endangered her physical safety, and caused severe and lasting emotional
+8
+distress and serious injuries to Plaintiff's mental health.
+52. This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+10
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+11
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+12
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+13
+FIFTH CAUSE OF ACTION
+14
+(False Imprisonment)
+15
+53.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+if set forth fully herein.
+17
+54.
+Defendants, in perpetrating the above-described non-consensual sexual assaults,
+18
+did, by use of threat and/or physical force, willfully and intentionally confine, detain, imprison
+19
+and/or restrain Plaintiff without lawful authority to do so, against her will, and without her
+20 consent.
+21
+55.
+Plaintiff was aware of, and suffered the extreme effects of, the Defendants'
+22| unlawful confinement.
+23
+56.
+As a consequence of Defendants' false imprisonment of Plaintiff, she sustained
+24 | conscious pain and suffering, Plaintiff's health was impaired, Plaintiff suffered great mental
+25| distress, shock, fright and humiliation, and Plaintiff's reputation and character were injured.
+26
+57. As a consequence of the conduct of Defendants, Plaintiff has incurred severe
+27 | psychological trauma and damage, has suffered great humiliation, loss of esteem, mental anguish
+28
+and suffering.
+8
+
+
+66029|
+Case 1626v 248-d809k Daeument $3-filedder22F287/Page Bage187 of 33
+Los Angeles, Calfomia 90025
+310.477.1700 phone
+•
+310.477.1699
+1
+2
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+58.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. $ 130.55.
+PRAYER FOR RELIEF
+WHEREFORE, Plaintiff Jane Doe prays for this Court to:
+59.
+Issue a judgment declaring that Defendant ESTATE OF JEFFREY E. EPSTEIN by
+8 and through its executors, DARREN K. INDYKE and RICHARD D. KAHN, as legal
+representatives of the Estate of Jeffrey E. Epstein, and Defendant GHISLAINE MAXWELL are
+liable for the violations of law alleged in this case;
+60.
+Award actual, compensatory, statutory, consequential and punitive damages;
+61.
+Award pre-judgment and post-judgment interest at the highest rate allowed by law;
+and
+62.
+Grant such further relief as this Court may deem just and proper.
+Respectfully submitted,
+Dated: January 16, 2020
+Kevin Boyle (admission pending)
+Robert Glassman (admission pending)
+Nathan Werksman (admission pending)
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, CA 90025
+Telephone: (310) 477-1700
+Facsimile: (310) 477-1699
+boyle@psblaw.com
+glassman@psblaw.com
+werksman@psblaw.com
+Is/ Benedict P. Morelli
+Benedict P. Morelli
+David T. Sirotkin
+Sara A. Mahoney
+MORELLI LAW FIRM PLLC
+9
+
+PANISH SHEA & BoYLE LLP
+310.477.1700 phone - 310.477.1699 fax
+Case E39eCX:2048400464DK Document93 RledF0l7d220712age PageRB of 33
+2
+3
+4
+5
+6
+7
+8
+777 Third Avenue, 31" Floor
+New York, NY 10017
+Telephone: (212) 751-9800
+Facsimile: (212) 751-0046
+bmorelli@morellilaw.com
+dsirotkin@morellilaw.com
+smahoney@morellilaw.com
+Attorneys for Plaintiff
+21
+22
+23
+24
+25
+26
+27
+28
+10
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 29 of 33
+
+
+
+Filed 05/27/20 Page 30 of 33
+HADDON
+N
+N
+Haddon,
+and
+I P.C
+Laura A. Menninger
+150 East 10th Avenue
+Denver, Colorado 80203
+PH 303.831.7364 x 303.832.2628
+www.hmflaw.com
+Imenninger@hmflaw.com
+April 13, 2020
+Via Email
+Robert S. Glassman
+Panish, Shea & Boyle LLP
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, CA 90025
+Re:
+20-CV-00484 (JGK-DCF), Jane Doe v. Darren K. Indyke, et al.,
+Dear Mr. Glassman:
+I am not authorized to accept service of any complaint on behalf of Ghislaine
+Maxwell.
+Your statement that your letter to me "shall constitute service of the complaint
+and summons as to defendant Ghislaine Maxwell" is an incorrect statement of the
+law. I am unaware of any authority for you to use decisions in other cases with other
+parties under other circumstances to support your own sua sponte service of a
+Complaint under Rule 4. If you have such authority, please share it with me. It also
+appears that you have undertaken no efforts to serve Ms. Maxwell consistent with the
+Rules.
+Your threat to seek "default judgment" when you have failed to follow the
+Rules or the applicable authority in New York is not well-founded in law. Please
+refrain in the future from making such threats.
+Sincerely,
+Laura A. Menninger
+
+
+Case 1:20-cv-00484-JGK-DCF Document 43-2 Filed 05/27/20 Page 31 of 33
+
+
+
+SEts; Noi96481-1CKed.Supp. 2A8yment 43-2 Filed 05/27/20 Page 32 of 33
+Only the Westlaw citation is currently available.
+United States District Court, S.D. New York.
+Plaintiff,
+Jeffrey EPSTEIN, et al., Defendants.
+17-CV-616 (JGK)
+Signed 01/30/2018
+Attorneys and Law Firms
+Justin Y.K.
+Michael Campion
+Steptoe &
+, LLP, Alexander Seton Lorenzo, Alston & Bird, LLP,
+New York, NY, Laura A. Menninger, Haddon,
+and
+, P.C., Denver, CO, John E. Stephenson, Jr., Alston
+& Bird LLP, Atlanta, GA, for Defendants.
+MEMORANDUM OPINION AND ORDER
+John G. Koeltl, United States District Judge
+*1 The plaintiff,
+, has moved the Court
+to approve alternative service on the defendant Ghislaine
+Maxwell and to find that service has been effected. The
+plaintiff asserts that, despite diligent measures, she has been
+unable to serve Maxwell personally. The plaintiff argues,
+however, that she has taken reasonable measures to provide
+Maxwell with notice of the pending lawsuit and requests that
+this service should be deemed sufficient. Non-party Haddon
+, P.C. ("Haddon
+), Maxwell's
+counsel in another litigation pending in this Court, has refused
+to accept service on behalf of Maxwell and has objected to
+becoming a general agent of process for Maxwell, but has
+taken no position on the plaintiff's application to deem service
+effected through the email efforts that the plaintiff has already
+made. Neither Maxwell nor any representative of Maxwell
+has otherwise opposed the current motion.
+Federal Rule of Civil Procedure 4(e)(1) permits a plaintiff
+to serve a defendant by following the procedures set forth
+by state law in the state where the district court is located.
+New York Civil Practice Law and Rules Section 308 sets
+forth available methods of service. Where service under
+§§ 308(I), (2), or (4)-which generally provide variants of
+personal serviceis impracticable, § 308(5) provides that the
+Court may approve alternative service methods. See, e.g.,
+Rampersad v. Deutsche Bank Sec., Inc., No. 02-cv-7311(LTS)
+(AJP), 2003 WL 21073951, at *1 (S.D.N.Y. May 9, 2003).
+Service under § 308(5) requires a showing of impracticability
+of the other methods of service, but does not require a showing
+of due diligence. Id.
+The plaintiff has taken various steps in an effort to serve
+Maxwell personally—all to no avail. The plaintiff retained
+a private investigation firm to attempt to determine where
+Maxwell resides, and that firm attempted service at three
+physical addresses potentially associated with Maxwell. The
+plaintiff also emailed the summons and complaint to several
+email addresses that are publicly associated with Maxwell,
+only one of which has been returned as undelivered. The
+plaintiff has also provided a copy of the summons and
+complaint to Haddon L
+who currently represents
+Maxwell in another litigation pending in this district.
+Under these circumstances, the plaintiff has demonstrated
+impracticability, because she has made numerous efforts to
+obtain information about the defendant's current residence
+and general contact information to effectuate personal service
+but has been unable to locate Maxwell. See, e.g., S.E.C. v.
+Nnebe, No. 01-cv-5247 (KMW), 2003 WL 402377, at *3
+(S.D.N.Y. Feb. 21, 2003) (collecting cases). Accordingly, the
+Court finds that the plaintiff has demonstrated that service
+on Maxwell is impracticable and thus grants the motion for
+alternative service.
+*2 Further, the steps already taken by the plaintiff to serve
+Maxwell are "reasonably calculated, under the circumstances,
+to apprise [her] of the pendency of the action and afford [her]
+an opportunity to present [he]r objections," and the Court
+therefore deems service of the summons and complaint to be
+complete as to defendant Maxwell. See, e.g., Bozza v. Love,
+No. 15-CV-3271 (LGS), 2015 WL 4039849, at *2 (S.D.N.Y.
+July 1, 2015) (holding that service upon the defendant's
+counsel in an unrelated matter was sufficient); Rampersad,
+2003 WL 21073951, at *1.
+Finally, Haddon
+objection to becoming a general
+agent of process for Maxwell is unfounded. The Court's
+ruling that service by email and personal delivery to Haddon
+has been reasonably calculated to provide Maxwell
+with notice of this lawsuit and an opportunity to respond does
+not turn Haddon
+into a general agent for Maxwell.
+Indeed, this order does not even require Haddon_
+to
+accept service on behalf of Maxwell, but rather finds that
+WESTLAW © 2020 Thomson Reuters. No claim to original U.S. Government Works.
+
+
+Ransoma: Epin; NoiR 481ed CKed.Supp. 2Asyment 43-2 Filed 05/27/20 Page 33 of 33
+service on Haddon
+is likely to provide notice of the
+lawsuit to Maxwell, given that Haddon
+is presumably
+in contact with Maxwell with regards to their representation
+of her in the other pending matter. See Bozza, 2015 WL
+4039849, at *2.
+Accordingly, the motion for alternative service is granted.
+The Clerk of Court is directed to close the motion pending
+at Docket Number 97. Defendant Maxwell's time to move
+or answer is twenty-one days from the date of this order.
+If Maxwell chooses not to appear, the plaintiff may pursue
+whatever remedies are available, including the entry of a
+default judgment.
+SO ORDERED.
+All Citations
+Not Reported in Fed. Supp., 2018 WL 637421
+Footnotes
+The Clerk of Court is directed to amend the case caption to name
+as the plaintiff. See Docket No. 96.
+End of Document
+© 2020 Thomson Reuters. No claim to original U.S. Government Works.
+WESTLAW © 2020 Thomson Reuters. No claim to original U.S. Government Works.
+2
\ No newline at end of file
diff --git a/vision-fixhub/court-01/eb7f53d5181483ae87c0eaa601816fab7057018b9dd99a63b87b522a63bd78bf.receipt.json b/vision-fixhub/court-01/eb7f53d5181483ae87c0eaa601816fab7057018b9dd99a63b87b522a63bd78bf.receipt.json
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-01/ebc14d55495352baa43ca29899b263d88e1e89892f6ea3ca51e4b0d8c5c8bc90.md b/vision-fixhub/court-01/ebc14d55495352baa43ca29899b263d88e1e89892f6ea3ca51e4b0d8c5c8bc90.md
new file mode 100644
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@@ -0,0 +1,123 @@
+Case 9:08-cv-80119-KAM Document 123 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO.2,
+Plaintiff,
+CASE NO.; 08-CV-80119-MARRALI
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.3,
+Plaintiff,
+CASE NO.; 08-CV-80232-MARRAL
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.4,
+Plaintiff,
+CASE NO.; 08-CV-80380-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.; 08-CV-80381-MARRAL
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 123 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+Page 2
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendants.
+CASE NO.; 08-CV-80994-MARRAI
+CASE NO.; 08-CV-80993-MARRAL I
+CASE NO.; 08-CV-80811-MARRAL TI
+CASE NO.; 08-CV-80893-MARRAJI
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al,
+CASE NO.; 08-CV-80469-MARRA1I
+
+
+Case 9:08-cv-80119-KAM Document 123 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+Page 3
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.; 08-CV-80591-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.; 08-CV-80656-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+NOTICE OF FILING
+The Defendant, EPSTEIN, by and through his undersigned attorneys, hereby files this
+Proposed Order Granting Unopposed Motion for Extension of Time to File Reply to Plaintiffs'
+Jane Does 2-7 Responses in Opposition to Motion to Compel Answers to 1 set of
+Interrogatories and 1" Request to Produce (DE 102).
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+don alim this record identified on the following Service List in the manner specified by
+
+
+Case 9:08-cv-80119-KAM Document 123 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+Page 4
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted;
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/ebc14d55495352baa43ca29899b263d88e1e89892f6ea3ca51e4b0d8c5c8bc90.receipt.json b/vision-fixhub/court-01/ebc14d55495352baa43ca29899b263d88e1e89892f6ea3ca51e4b0d8c5c8bc90.receipt.json
new file mode 100644
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ebc26b9f121f2daf256edfb635198ff3f7d614979415680f6fade4bc5cf6b1fc.md b/vision-fixhub/court-01/ebc26b9f121f2daf256edfb635198ff3f7d614979415680f6fade4bc5cf6b1fc.md
new file mode 100644
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@@ -0,0 +1,104 @@
+Filing # 152569490 E-Filed 07/01/2022 09:23:08 AM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner,
+VS.
+DAVE ARONBERG,
+SHARON R. BOCK,
+Defendant/Respondents.
+COPY
+ORDER RESETTING HEARING ON DEFENDANT DAVE ARONBERG'S
+AMENDED MOTION FOR ATTORNEYS' FEES
+THIS CAUSE having come before the Court at Caléndar Call on June 10, 2022, upon Defendant
+DAVE ARONBERG's Amended Motion for Attorneys' Fees filed on November 19, 2020 it is
+ORDERED that the hearing on Defendant DAVE ARONBERG's Amended Motion for Attorneys'
+Fees filed November 19, 2020 is reset as a backup before the Honorable DONALD W. HAFELE to take
+place between September 6, 2022 and September 9, 2022, in Courtroom I0D, 205 N. Dixie Hwy, West
+Palm Beach, Florida 33401. This is a specialiset hearing which shall be limited to two (2) hours. It is
+ORDERED that the attorneys/parties must submit to the Court by hard copy seven (7) working
+days before the hearing noting the date and time of the hearing:
+1.
+copies of all releyant pleadings;
+2.
+a copy of any memorandum of law (not to exceed 10 double spaced pages with case
+authority in no less than 12 point font for body and any footnotes);
+3.
+copies of all case law authority; and
+copies of exhibit and witness lists.
+Mandatory compliance with Local Rule 4 is strictly enforced. Specifically, attorneys
+are required to "make reasonable efforts to actually speak to one another and engage in
+reasonable compromises to resolve or narrow the disputes before seeking court
+intervention." Prior to scheduling, the "attorney noticing the motion shall attempt to resolve the
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 07/01/2022 09:23:08 AM
+
+
+matter and shall certify to the Court the good faith attempt to resolve." If you do not comply with
+Local Rule 4, your hearing may be canceled.
+This hearing has been specially set by the Court and shall not be cancelled unless the issues of this
+motion have been settled and an order entered, or the motion withdrawn.
+If an interpreter is needed for a party or witness in this case, it
+party needing same to provide a qualified interpreter.
+be the responsibility of the
+DONE and ORDERED in
+in West Palm Beach, Palm Beach County, Florida.
+Circult Judge
+07/01/2022
+COPIES TO:
+DOUGLAS A. WYLER
+502019CA014681XXXXMB
+Donald Hafele
+Circuif Judge
+doug.wyler@comcast.net
+COLLIN D.
+LAUREN R WHETSTONE
+MARK F BIDEAU
+MICHAEL GRYGIEL
+NINA D. BOYAJIAN
+961687 Gateway Blvd.
+Suite 201-1
+5203adina Beach fl
+Post Office Box 229
+West Palm Beach, FL
+33401
+Greenberg Traurig, P.A.
+777 South Flagler Drive
+Suite 300 East
+West Palm Beach, FL 33401
+Greenberg Traurig, P.A.
+777 South Flagler Drive
+Suite 300 East
+West Palm Beach, FL 33401
+Greenberg Traurig, P.A.
+54 State Street
+6' Floor
+Albany, NY 12207
+Greenberg Traurig, P.A.
+1840 Century Park East
+Suite 1900
+Los Angeles, CA 90067
+eservicel@mypalmbeachclerk.com
+whetstonel@gtlaw.com
+L.Service@gtlaw.com
+sandra.famadas@gtlaw.com
+bideaum@gtlaw.com
+thomasd@gtlaw.com
+FLService@gtlaw.com
+grygielm@gtlaw.com
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+
+
+STEPHEN A.
+MENDELSOHN, ESQ
+Greenberg Traurig, P.A.
+401 East Las Olas Boulevard
+Suite 2000
+Fort Lauderdale, FL 33301
+mendelsohns@gtlaw.com
+smithl@gtlaw.com
+flservice@gtlaw.com
+NOT A CERTIFIED COPY
diff --git a/vision-fixhub/court-01/ebc26b9f121f2daf256edfb635198ff3f7d614979415680f6fade4bc5cf6b1fc.receipt.json b/vision-fixhub/court-01/ebc26b9f121f2daf256edfb635198ff3f7d614979415680f6fade4bc5cf6b1fc.receipt.json
new file mode 100644
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ec18f1d6339199a2b0101803f5a0d400cc4e7c015ae2ff7d39b1418206c704fe.md b/vision-fixhub/court-01/ec18f1d6339199a2b0101803f5a0d400cc4e7c015ae2ff7d39b1418206c704fe.md
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index 0000000000000000000000000000000000000000..7748bb357773db9a249fb5de71b031164b62b720
--- /dev/null
+++ b/vision-fixhub/court-01/ec18f1d6339199a2b0101803f5a0d400cc4e7c015ae2ff7d39b1418206c704fe.md
@@ -0,0 +1,264 @@
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANDE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION TO USE CORRESPONDENCE TO
+PROVE VIOLATIONS OF THE CRIME VICTIMS' RIGHT ACT AND TO HAVE
+THEIR UNREDACTED PLEADINGS UNSEALED
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court to allow use of correspondence between the
+U.S. Attorney's Office and counsel for Jeffrey Epstein to prove violations of the Crime Victims'
+Rights Act. Because this Court has already ruled that the correspondence is not privileged - and
+because it is highly relevant to the victims' case - the motion should be granted. The victims'
+unredacted pleading quoting the correspondence should also be unsealed, particularly in light of
+the intense, international public interest in Epstein's controversial plea deal.
+BACKGROUND
+As the Court is aware, beginning 2008, Jane Doe #1 and Jane Doe #2 pursued civil
+litigation against Jeffrey Epstein for sexually abusing them. During the course of that litigation,
+in June 2001, they obtained correspondence between the U.S. Attorney's Office and Jeffrey
+Epstein's legal counsel. Jane Doe #1 and Jane Doe #2 ultimately settled their civil suits in July
+2010. During the settlement discussions, they informed Epstein's legal counsel that they would
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 2 of 10
+be using the correspondence in this CVRA action. Epstein requested advance notice of such
+filing. Jane Doe #1 and Jane Doe #2 saw no basis for any objection to their using the materials,
+but agreed to give advance notice to Epstein so that he could make whatever arguments he
+wished. Accordingly, as part of their settlement, the victims agreed with Epstein that they would
+file under seal the correspondence so that Epstein would have an opportunity to object if he so
+desired:
+Counsel for [Jane Doe #1 and Jane Doe #2] have received, as part of discovery in
+this lawsuit, certain correspondence between Epstein's agents and federal
+prosecutors. [Jane Doe #1 and Jane Doe #2] may desire to use this
+correspondence to prove a violation of [their] right to notice by the government
+and to be treated with fairness, dignity, and respect during criminal investigations
+and prosecutions under the Crime Victims' Rights Act (CVRA), 18 U.S.C.
+section 3771, and to seek remedies for any violation that [they] may prove. The
+parties agree that Epstein will receive at least seven days advance notice, in
+writing, of intent to so use the correspondence in any CVRA case ... [Jane Doe
+#I and Jane Doe #2] agree to ... file the documents ... under seal until a judge
+has ruled on any objection that Epstein may file."
+On August 26, 2010, Jane Doe #1 and Jane Doe #2 provided the specified advance notice
+to Epstein of their intent to use the correspondence. The notice specifically covered this CVRA
+action:
+[A]s you know, there is currently pending before Judge Marra a case filed under
+the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, in which two victims
+of sexual assault by [you] allege they were deprived of their rights under the Act.
+For example, the victims allege that there were deprived of notice of pending plea
+bargain arrangements and an opportunity to be heard as well as the right to
+meaningfully confer with prosecutors. The correspondence provided to us is
+compelling evidence in support of their claims, as it demonstrates that federal
+prosecutors were conducting plea discussions with Epstein months before they
+alerted the victims to any possible plea bargain. The correspondence alsc
+demonstrates a willful plan to keep the victims in the dark about the plea
+discussions. In light of these facts, we intend to make use of this correspondence
+in the [CVRA] . lawsuit]] …..
+2
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 3 of 10
+Letter from
+to Robert D. Critton, Jr., Case No. 9:08-CV-80893, Doc. #214
+(attachment 2).
+On September 2, 2010, Epstein filed a motion for a protective order, seeking to bar
+disclosure of the U.S. Attorney's correspondence in both a pending state court case and the
+CVRA case. Case No. 9:08-CV-80893, Doc. #214.
+On September 13, 2010, Jane Doe #1 and Jane Doe #2's responded, explaining that
+Epstein had already litigated - and lost - the claim that the information was somehow protected.
+They also explained that Epstein could not object to use of the information in the CVRA case
+unless he intervened in the CVRA case. Doc. #217.
+One day later, on September 14, 2010, the Court (Magistrate Judge
+denied the
+motion for a protective order. Doc. #218. The Court explained that "It]he Court agrees with
+[Jane Doe] ... that if [Epstein] believes he has a valid basis for preventing disclosure of the
+subject documents in the subject state court proceeding, he should file a motion to that effect in
+the appropriate state court."
+On September 28, 2010, Epstein filed an appeal of the Magistrate Judge's order. Epstein
+argued that because the Magistrate Judge had ruled so rapidly, he had been precluded from filing
+a reply brief.
+On October 7, 2010, Jane Does' legal counsel filed a response (Doc. #221), explaining
+that no basis existed for barring use of the documents and that, in any event, Epstein needed to
+intervene in the CVRA case if he was going to have standing to object to use of the documents
+there.
+3
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 4 of 10
+On October 20, 2010, this Court (Marra, J.), entered an order (Doc. #222) remanding to
+the magistrate judge to give Epstein an opportunity to file a reply brief.
+On November 1, 2010, Epstein filed a reply to the response to his motion for protective
+order. Doc. #223.
+On January 5, 2011, this Court (
+, J.) entered an order (Doc. #226) resolving
+Epstein's objection. The Order began by stating: "To the extent Epstein's Counsel ask the Court
+to find the subject correspondence privileged and on that basis prohibiting Plaintiffs' Counsel
+from disclosing it in either of the two proceedings, said request is denied." Id. at 3. The Order,
+however, indicated that Jane Does' counsel should file the correspondence under seal with "the
+appropriate institution" so that the institution could "make the determination of admissibility as it
+relates to their respective cases." Id. at 3.'
+DISCUSSION
+JANE DOE #1 AND JANE DOE #2 SHOULD BE PERMITTED TO USE THE
+CORRESPONDENCE, AS IT IS HIGHLY RELEVANT TO THEIR CASE.
+Under the Magistrate Judge's Order, Jane Doe #1 and Jane Doe #2 are directed to submit
+the correspondence to "the appropriate institute" for a "determination of admissibility." The
+victims have done that, filing only a redacted version of their pleading in the public court file,
+'At one point, the Magistrate Judge appeared to think that the "appropriate institution"
+for the CVRA was the Justice Department, as the Magistrate Judge thought that Jane Doe was
+proceeding by way of an "internal Justice Department Complaint procedure." Of course, Jane
+Doe is not proceeding here by way of the internal Justice Department procedure, but rather the
+statutorily authorized procedure for filing a motion in the district court. See 18 U.S.C. §
+3771(d)(3).
+4
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 5 of 10
+submitting an unredacted version to the Court. The victims have also submitted all of the
+correspondence to the Court under seal as well.
+The only remaining issue for the Court under the Magistrate Judge's Order is a
+"determination of admissibility as it relates" to the CVRA case. The correspondence is plainly
+admissible, as it is highly relevant to the victims' argument that the Justice Department has
+intentionally concealed the existence of the non-prosecution agreement from them. The
+correspondence specifically shows that the U.S. Attorney's Office reached a firm nonprosecution agreement with Epstein in September 2007, but subsequently deliberately decided to
+conceal the existence of that agreement from the victims. The correspondence further shows that
+the U.S. Attorney's Office was aware of its statutory obligation to inform the victims of the nonprosecution agreement. Indeed, some of the correspondence involves specific discussion of the
+CVRA and victim notices.
+All relevant evidence is admissible. See Fed. R. Evid. 402. Relevant evidence is
+"broadly defined," United States v. Glasser, 773 F.2d 1553, 1560 (11" Cir. 1985), as evidence
+that has "any tendency to make the existence of any fact that is of consequence to the
+determination of the action more probably or less probable than it would be without the
+evidence." Fed. R. Evid. 401. Much of the correspondence bears directly on points that the U.S.
+Attorney's Office has already discussed in its pleadings. The Government's Response to the
+Victim's Petition, for example, contains an extensive discussion of the background of the
+investigation, the plea negotiations, and the U.S. Attorney's Office's understanding of its
+obligations under the CVRA. See Government's Resp. to Victim's Emergency Petition for
+Enforcement of Crime Victims Rights Act at 3-6 (doc. #13) (citing Declaration of Asst. U.S.
+5
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 6 of 10
+Attorney
+Villafaña). These same subjects were also discussed at length at the Court's
+July 11, 2008, hearing on the matter. See, e.g., Tr. July 11, 2008, at 3-4, 18-19, 22-29. The
+correspondence provides far more detailed information on this subject than was previously
+available to the victims. More important, the correspondence also shows a concerted effort by
+the U.S. Attorney's Office and Epstein to conceal the non-prosecution agreement from the
+victims.
+The victims should therefore be allowed to use the correspondence, as it sheds important
+light on the events surrounding the non-prosecution agreement, which are central to the victims'
+arguments that the U.S. Attorney's Office violated their rights.
+II. THE VICTIMS' PLEADINGS SHOULD BE UNSEALED.
+The victims' pleadings should also be unsealed. The victims have, of course, filed only a
+redacted version of their pleading in the court public file, thereby ensuring full compliance with
+the Court's order that they give Epstein a chance to object. But there is no underlying reason for
+sealing of these documents.
+The Court has already ruled that the correspondence is not
+privileged. Accordingly, no good reason exists for keeping the pleadings confidential, and
+accordingly they should be made part of the Court's public file.
+In addition, no sealing order could be justified in this case. The Eleventh Circuit has
+instructed that the district courts must make substantial findings before sealing records in cases
+before it. For instance, in United States v. Ochoa-Vasque, 428 F.3d 1015 (11" Cir. 2005), it
+reversed an order from this Court that had sealed pleadings in a criminal case, emphasizing the
+importance of the public's historic First Amendment right of access to the courts. To justify
+6
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 7 of 10
+sealing, "a court must articulate the overriding interest along with findings specific enough that a
+reviewing court can determine whether the closure order was properly entered." Id. at 1030.
+Here there is no overriding interest in keeping the pleadings secret. To the contrary, there
+is an overriding interest in having these matters exposed to public light. There is considerable
+public interest in the question of how a serial pedophile could arrange such a lenient plea
+agreement with the U.S. Attorney's Office. There has long been suspicion that Jeffrey Epstein
+was receiving favorable treatment in the criminal investigation because of his wealth and power.
+See, e.g., Abby Goodnough, Questions of Preferential Treatment Are Raised in Florida Sex
+Case, N.Y. TIMES, Sept. 3, 2006, at 19 (noting questions that the public had been left "to wonder
+whether the system tilted in favor of a wealthy, well-connected alleged perpetrator and against
+very young girls who are alleged victims of sex crimes"). Indeed, the interest in the matter is
+strong enough that the widely-viewed television program Law and Order: Special Victim Unit
+devoted an episode to it last month, suggesting in its plot that federal government had intervened
+improperly to prevent effective prosecution. See Law & Order Commemorates Jeffrey Epstein's
+Taste for Teen Hookers, http://gawker.com/#!5751094/law--order-commemorates-jeffreyepsteins-taste-for-teen-hookers. Also, there is strong current media interest in the case. "British
+tabloids have gone berserk the past two weeks with the growing scandal over the friendship that
+Prince Andrew, 51, fourth in line for the throne, has maintained with the multimillionaire, a
+registered sex offender [Jeffrey Epstein]." Jose Lambiet, Prince's Friendship with Pedophile
+Causes Furor Across the Pond, PALM BEAcH Post, Mar. 9, 2011, at 2B. There are also current
+reports that the FBI is reopening its investigation into the matter. See Sharon Churcher, FBI Will
+Reopen Case Against Prince's Friend, SUNDAY MaIl (UK), Mar. 6, 2011.
+7
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 8 of 10
+Of course, the Court is not being asked in this pleading to decide the wisdom of the nonprosecution agreement entered into by the U.S. Attorney's Office. The public can make up its
+own mind on that subject - but only if it is allowed to review the facts surrounding the
+negotiation of the agreement and the treatment of crime victims during the negotiation process.
+The Court should accordingly unseal the victims' pleading.
+III. EPSTEIN HAS NO "STANDING" TO RAISE ANY OBJECTIONS WITHOUT
+INTERVENING IN THE CVERA CASE.
+As a courtesy to Epstein, we have provided copies of all these pleadings to defendant
+Epstein. It should be noted, however, that while Epstein is well aware of this CVRA action, he
+has chosen not to intervene. Cf. Fed. R. Civ. P. 24 (providing procedures for intervention).
+Without intervening in the case, he cannot raise any objections to use of the correspondence in
+this case - or to any relief that the Court might grant to the victims.
+The victims have no objection to Epstein intervening in this case - at this time. If,
+however, Epstein delays intervention until after a reasonable period of time, the victims will
+argue that his motion to intervene is untimely. The victims will argue that any attempted
+intervention by Epstein after the date on which the Government must respond to the victims'
+motion for a finding of violation of the CVRA is untimely, as that is when the victims must
+begin drafting reply pleadings. See United States v. Jefferson County, 720 F.2d 1511, 1516 (11"*
+Cir. 1983) (listing factors to be considered in determining whether motion to intervene is timely).
+CERTIFICATE OF CONFERENCE
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 9 of 10
+The Government has no objection to the motion to unseal. On August 26, 2010, Epstein
+was given notice of the victims' intent to use these materials in this case. He has yet to intervene
+in this case, let alone interpose any objection in this case.
+CONCLUSION
+For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 to use
+the U.S. Attorney's correspondence in this CVRA action. The Court should therefore unseal the
+victims redacted pleading, entering the full pleading - and the attached correspondence - as
+publicly accessible records.
+DATED: March 21, 2011
+Respectfully Submitted,
+S/
+JAFFE, WEISSING,
+, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+9
+
+
+Case 9:08-cv-80736-KAM Document 51 Entered on FLSD Docket 03/21/2011 Page 10 of 10
+CERTIFICATE OF SERVICE
+The foregoing document was served on March 21, 2011, on the following using the Court's
+CM/ECF system:
+A.
+Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave.., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail:
+Attorney for the Government
+L. Ackerman, Jr.
+Burnett PA
+777 S. Flagler Drive, West Tower, Suite 901
+West Palm Beach, FL 33401
+Criminal Defense Counsel for Jeffrey Epstein
+(courtesy copy of pleading via U.S. mail)
+10
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diff --git a/vision-fixhub/court-01/ec3d4d8f8bd0b575acd758111d970d5e5f0142c9e241a3cb5a200a7ac930faae.md b/vision-fixhub/court-01/ec3d4d8f8bd0b575acd758111d970d5e5f0142c9e241a3cb5a200a7ac930faae.md
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@@ -0,0 +1,74 @@
+Case 9:08-cv-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 1 of 2
+Case 9:08-cv-80119-KAM Document 291-9
+Entered on FLSD Docket 09/08/2009
+
+The Psychological Trauma Center
+•a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpnschiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
+Tape 2
+with Dr. Kliman
+12/2/08
+Transcription by: K. Rios
+00:00:05
+Dr. Kliman:
+This is the second tape we're making today; you know I realized that I
+didn't get your preference for what you would like me to call you.
+Oh
+Dr. Kliman:
+I apologize. B
+That's okay.
+Dr. Kliman:
+you say that those were serious problems for you, emotionally?
+Emotionally, yes I cared about him but I mean you can only take so much;
+I mean I was with him, known him for like 5 years; and after a while you
+just kinda like... you realize like you love the person but your not in love
+with the person; and that's kinda like, kinda how what happened to me;
+like I loved him and I knew I wasn't in love with him that's not the person
+I wanted to be with. So I mean, I took me like 3 years to realize that; 2 ½
+years I mean the last like two years I mean there was really nothing there I
+just kinda of kept going back to the like same old same old and after a
+while you just, I don't know; I didn't want to be with him anymore.
+"B
+
+
+Case 9:08-cv-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 2 of 2
+Case 9:08-cv-80119-KAM
+Document 291-9
+Entered on FLSD Docket 09/08/2009 Page 2 of 4
+00:02:39
+Dr. Kliman:
+What emotional reactions did you have to this change in your
+relationship?
+Nothing really, I mean its not like I was around him all the time because I
+lived in Boca and he was living in Jacksonville. So it wasn't like he was
+around all the time for me to like really be disappointed because when I
+went to college I was single, I was by myself. I was going up to
+Jacksonville pretty much like every weekend though to go visit him, but I
+was used to like being by myself throughout the week and like the girls on
+my team were there to help me and support me and like one of my
+roommate was kinda of like going through the same thing; so we were
+both kinda there for each other; and I don't know, I just have...I have a lot
+of good friends there to help me like, I was going out with my friends get
+my mind off of it and eventually that's when I met....I ended up meeting
+somebody else he kinda filled that void for me.
+00:03:47
+Dr. Kliman:
+How long did it take you between the time of the restraining order and the
+time of meeting someone else?
+Well...] got the restraining order when I was probably like 17 years old;
+and I got back together with Preston when I was probably around 18. So
+its not like the restraining order was what made me stop seeing Preston. I
+met Allan, I knew Allan... my new boyfriend; I met him at the end; like
+Dr. Kliman:
+Last week of the first year of college?
+Yeah
+Dr. Kliman:
+Freshman year?
+00:05:15
+Dr. Kliman:
+Does he spell his name with an "E"?
+2
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diff --git a/vision-fixhub/court-01/ec458d8d38b44128fd3b96c86710d94256b27d740a80018928836a47680c05fc.md b/vision-fixhub/court-01/ec458d8d38b44128fd3b96c86710d94256b27d740a80018928836a47680c05fc.md
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@@ -0,0 +1,36 @@
+Case 1:19-cv-11869-MKV-DCF Document 40 Filed 11/02/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ANASTASIA DOE,
+Plaintiff,
+CASE NO.: 1:19-CV-11869
+VS.
+DARREN K. INDYKE AND RICHARD D.
+KAHN AS CO-EXECUTORS OF THE
+ESTATE OF JEFFREY E. EPSTEIN,
+Defendant.
+JOINT STIPULATION FOR DISMISSAL
+Plaintiff, ANASTASIA DOE, and Defendants, Darren K. Indyke and Richard D. Kahn, as
+Co-Executors of the Estate of Jeffrey E. Epstein, by and through their undersigned counsel, hereby
+stipulate and agree that due to Plaintiff's resolution of her claims) against Defendants via the
+Epstein Victims' Compensation Program, this action shall be DISMISSED WITH PREJUDICE,
+with each party to bear its own attorneys' fees and costs.
+Dated: November 2, 2020
+Respectfully Submitted,
+POTTINGER LLC
+TROUTMAN PEPPER
+SANDERS LLP
+By: /s/
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Brad@epllc.com
+Brittany@epllc.com
+Attorneys for Plaintiff
+By: /s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+875 Third Avenue
+New York, NY 10022
+(212) 704-6000
+bennet.moskowitz@troutman.com
+Attorneys for Defendants
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diff --git a/vision-fixhub/court-01/ec7df5ce91d6bee5c22c2e4afdb590a4b73323e501e7b9a8bb2af62aaa4698e2.md b/vision-fixhub/court-01/ec7df5ce91d6bee5c22c2e4afdb590a4b73323e501e7b9a8bb2af62aaa4698e2.md
new file mode 100644
index 0000000000000000000000000000000000000000..0e564f75012cd6fc3d71cad1aadbf1363afd490f
--- /dev/null
+++ b/vision-fixhub/court-01/ec7df5ce91d6bee5c22c2e4afdb590a4b73323e501e7b9a8bb2af62aaa4698e2.md
@@ -0,0 +1,49 @@
+Case 9:08-cv-80736-KAM Document 36 Entered on FLSD Docket 02/12/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/
+JANE DOES #1 AND #2,
+Petitioners,
+V.
+UNITED STATES OF AMERICA,
+Respondent.
+ORDER
+THIS CAUSE comes before the Court on the Petitioners' Motion to Unseal Non-Prosecution
+Agreement (DE 28), filed September 25, 2008. Respondent filed its response (DE 29), on October
+8, 2008, and Petitioners filed their reply (DE 30) on October 16, 2008. The Court has carefully
+considered the motion and the record and is otherwise fully advised in the premises.
+Petitioners motion seeks the Court to enter an order unsealing the Non-prosecution
+Agreement, including any modifications and addenda thereto (collectively referred to as the
+"Agreement"), between the United States Attorney's Office for the Southern District of Florida
+("USAO") and Jeffrey Epstein ("Epstein"). At a hearing held on August 14, 2008, the Court ordered
+the USAO to produce the Agreement to counsel for the Petitioners and to any other victims
+identified by the USAO and their counsel, pursuant to the terms of the Court's Order. (See DE 26,
+August 21, 2008). Petitioners argue that the Agreement "should now be unsealed."
+First, as Respondent points out, the Agreement was not filed in this case, under seal or
+otherwise. Petitioners also assert that the Agreement should be "unsealed" because the victims
+
+
+Case 9:08-cv-80736-KAM Document 36 Entered on FLSD Docket 02/12/2009 Page 2 of 2
+and/or their attorneys believe the Government has mischaracterized some of its provisions. If and
+when such alleged mischaracterizations become relevant to an issue to be decided by the Court, the
+parties will be given the opportunity to advance their positions and the Court will resolve the issue.
+If disclosure of the Agreement will be required for the Court to resolve the issue, appropriate
+disclosure will be ordered.
+Furthermore, to the extent Petitioners are seeking modification of the restrictions placed
+upon their use of the Agreement by the Court's August 21, 2008 order, Petitioners have not met their
+burden to justify a modification. Petitioners' mere desire to discuss the Agreement with third parties
+is insufficient, in and of itself, to warrant the granting of such relief. If and when Petitioners have
+a specific tangible need to be relieved of the restrictions, they should file an appropriate motion. If
+a specific tangible need arises in a civil case Petitioners or other alleged victims are pursuing against
+Epstein, relief should be sought in that case, with notice to the United States, the other party to the
+Agreement. Accordingly, it is
+ORDERED AND ADJUDGED that Petitioners' Motion to Unseal Non-Prosecution
+Agreement (DE 28) is DENIED.
+DONE and ORDERED in
+in West Palm Beach, Palm Beach County, Florida,
+this 12" day of February, 2008.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies furnished to:
+all counsel of record
+2
diff --git a/vision-fixhub/court-01/ec7df5ce91d6bee5c22c2e4afdb590a4b73323e501e7b9a8bb2af62aaa4698e2.receipt.json b/vision-fixhub/court-01/ec7df5ce91d6bee5c22c2e4afdb590a4b73323e501e7b9a8bb2af62aaa4698e2.receipt.json
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diff --git a/vision-fixhub/court-01/ec8e020982480ae83b4a601351cab027c83cf6c4dfb9e30ac8677da6a693a6b0.md b/vision-fixhub/court-01/ec8e020982480ae83b4a601351cab027c83cf6c4dfb9e30ac8677da6a693a6b0.md
new file mode 100644
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@@ -0,0 +1,44 @@
+Case 9:08-cv-80119-KAM Document 270 Entered on FLSD Docket 08/17/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+AUG 17 2009
+Related cases:
+TEVEN US SE
+.D. OF FLA. - W.P
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON DEFENDANT'S MOTION FOR EXTENSION DIRECTED
+TO THE COURT PURSUANT TO RULE 4, REVIEW AND APPEAL:
+SOUTHERN DISTRICT, IN CONNECTION WITH THIS COURT'S ORDER
+DATED AUGUST 4, 2009 [DE 242]
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+For Extension Directed to the Court Pursuant to Rule 4, Review and Appeal-Southern
+District, In Connection With This Court's Order [DE 242] Dated August 4, 2009.
+(0.e+264)
+Having considered Defendant's motion it is HEREBY ORDERED and ADJUDGED that
+the motion is GRANTED as follows:
+The Defendant shall file with the clerk of Court, and serve on all parties, written
+objections which shall specifically set forth the order, or part thereof, appealed from an a
+concise statement of the alleged error in ruling, along with statutory, rule or case
+authority in support of his position, on or before August 31, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 270 Entered on FLSD Docket 08/17/2009 Page 2 of 2
+08-CIV-80119-Marra/Johnson
+Related cases 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-81092
+Page 2
+DONE and ORDERED this day or try
+_ 2009.
+Konnoir A. Mara LiNNEA R.Johnscn
+United States Diptriot Judge
+MAGiSTANTE
+Courtesy Copies:
+Counsel of Record
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diff --git a/vision-fixhub/court-01/ecdbf57462e994944ab94fff6c138c2379e360200114701c91cdb59b93f25ff2.md b/vision-fixhub/court-01/ecdbf57462e994944ab94fff6c138c2379e360200114701c91cdb59b93f25ff2.md
new file mode 100644
index 0000000000000000000000000000000000000000..92f3d31b97bb0fb56546d0470e0d72f78aaf03a2
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+++ b/vision-fixhub/court-01/ecdbf57462e994944ab94fff6c138c2379e360200114701c91cdb59b93f25ff2.md
@@ -0,0 +1,115 @@
+Filing # 100318950 E-Filed 12/13/2019 05:23:13 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO: 2019CA014681XXXX MB AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+VS.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida, SHARON R. BOCI
+as Clerk & Comptroller, Palm Beach County
+Florida,
+COPY
+Defendants.
+DEFENDANT, SHARON R. BOCK, AS CLERK & COMPTROLLER, PALM BEACH
+COUNTY'S MOTION TO DISMISS
+DEFENDANT, Sharon R. Bock, as Clerk & Comptroller, Palm Beach County, pursuant to
+the Florida Rules of Civil Procedure 1.420, hereby files this Motion to Dismiss the Complaint of
+Plaintifi, CA Florida Holdings, LIC, Publisher of The Palm Beach Post, and as grounds states as
+follows:
+I.
+Argument and Standard of Review
+Plaintiff Fails to State a Cause of Action
+To state a cause of action, a complaint must allege sufficient ultimate facts to show that the
+pleader is entitled to relief. Florida Rules of Civil Procedure 1.110(b) requires "a short and plain
+statement of the ultimate facts showing that the pleader is entitled to relief." In reviewing an order
+granting a motion to dismiss for failure to state a cause of action, the Court must accept as true all
+well-pled allegations in a complaint, and it must draw all reasonable inferences in favor of the
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/13/2019 05:23:13 PM
+
+
+pleader.
+Whether a complaint is sufficient to state a cause of action is an issue of law.
+W.R. Townsend Contracting, Inc. v. Jensen Civil Construction, Inc., 728 So.
+2d 297, 299, (Fla. Ist DCA 1999). When a trial court rules on a motion to
+dismiss, the trial court is confined to the allegations within the four corners of
+the Complaint, must accept these allegations as true, and may not speculate as
+to what the true facts may be or what facts may ultimately be proved in the
+trial of the cause. See Al-
+v. Holder, 787 So. 20939, 941 (Fla. 2d DCA
+2001);
+- Infante v. Union Cent. Life Ins. Co., 809 So. 2d 13 (Fla, 3d
+DCA 2002).
+The purpose of a motion to dismiss is to determine whether the plaintiff has alleged a viable
+cause of action.
+. Hammons v. Buckeye Cellulose Corp., 285 So. 2d 7, 10 (Fla. 1973). In fact,
+"[dJespite the elemental proposition that on a motion to dismiss for failure to state a cause of action
+all allegations are taken as true, [a] court will not "by inference on inference or speculations supply
+essential averments that are lacking.'"
+v. Ed A Produce Corp., 708 So. 2d 997, 1000 (Fla.
+3d DCA 1998); see also Conley v. Shutts & Bowen, P.A., 616 So. 2d 523, 524-25 (Fla. 3d DCA
+1993).
+Taking the facts alleged therein and exhibits attached to the Complaint, Plaintiff failed to
+state a cause of action against the Clerk, and therefore, the Complaint against the Clerk should be
+dismissed because under no set of facts can the Plaintiff state a cause of action for which relief can
+be granted.
+COUNT I
+(Florida Statutes Section 905.27)
+Admittedly, Fla. Stat. § 905.27, sets forth possible exceptions to the disclosure of grand jury
+testimony. Plaintiff here brings an attempted cause of action under the same statute; however, a
+review of the statute in question reveals that no cause of action is provided for therein, and therefore,
+Plaintiff's Complaint must be dismissed as a matter of law.
+2
+
+
+Moreover, a review of the statute at issue clearly indicates that even if § 905.27, Fla. Stat.
+provided a basis for an independent cause of action, Plaintiff is barred from access to the records it
+seeks for the purposes it has set forth as Fla. Stat. § 905.27(2) states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a
+civil case, it may be disclosed to all parties to the case and to their attorneys and by
+the latter to their legal associates and employees. However, the grand jury testimony
+afforded such persons by the court can only be used in the defense or prosecution of
+the civil or criminal case and for no other purpose whatsoever.
+Here, despite the clear statutory guidelines for disclosure of grand jury materials in a civil
+case, Plaintiff is improperly seeking the requested 2006 grand jury materials for the purposes of
+public disclosure and publication pursuant to the court's inherent authority and supervisory powers
+over the grand jury. Again, even if Plaintiff properly asserted a cause of action under Fla. Stat.
+905.27, the statute unambiguously states that grand jury testimony "can only be used in the defense
+or prosecution of the civil or criminal case and for no other purpose whatsoever", which is distinctly
+different from Plaintiff's intended purpose for public disclosure of the grand jury evidence. Fla.
+Stat. § 905.27(2).
+CONCLUSION
+Here, the Clerk's sole involvement in this action is as the custodian of the record as set forth
+in section 28.13, Florida Statute.
+This duty includes keeping grand jury records confidential
+pursuant to section 905.27, Florida Statute. The Clerk must follow strict statutory guidelines to
+maintain these record's confidentiality. Further emphasizing the statutory intent of confidentiality,
+section 905.395 Florida Statute even imposes a penalty for improper disclosure of grand jury
+proceedings or identity of persons, at the level of a felony of the third degree.
+Plaintiff's Complaint is an extensive recitation of the factual background regarding Jeffery
+Epstein and the testimony and evidence presented to the 2006 grand jury in Palm Beach County,
+3
+
+
+Florida. However, that recitation fails to state a cause of action for which relief can be granted.
+WHEREFORE, based on the foregoing argument and supporting authority, Defendant,
+Sharon R. Bock, as Clerk & Comptroller, Palm Beach County respectfully prays for the Court to grant
+this Motion to Dismiss with prejudice, provide direction to the Clerk as needed, and grant such other
+and further relief as the court deems proper.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true copy of the foregoing has been emailed in compliance
+with the Florida Rules of Judicial Administration 2.516, on this 13th day of December, 2019, to:
+Stephen A. Mendelsohn, Esq., Greenberg Traurig, P.A., 5100 Town Center Circle, Suite 400, Boca
+Raton, FL 33486, email: mendelsohns@gtlaw.com and Douglas A. Wyler, Esq., 961687 Gateway
+Blvd., Suite 201-1, Fernandina Beach, FL 32034, email: jacobsscholzlaw@comcast.net.
+Hampton C. Peterson, General Counsel
+For Sharon R. Bock, Clerk & Comptroller
+Post Office Box 229
+West Palm Beach, FL 33402
+Telephone: (561) 355-2983
+E-service: Clerk_E-service@mypalmbeachclerk.com
+BY: s/Hampton C. Peterson
+Florida Bar No. 331384
+NOT
+4
diff --git a/vision-fixhub/court-01/ecdbf57462e994944ab94fff6c138c2379e360200114701c91cdb59b93f25ff2.receipt.json b/vision-fixhub/court-01/ecdbf57462e994944ab94fff6c138c2379e360200114701c91cdb59b93f25ff2.receipt.json
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+}
diff --git a/vision-fixhub/court-01/ecfdc789e6e5dbddfc347cc7524783d5f2cd34e2334461f5d08f7a09bbf88587.md b/vision-fixhub/court-01/ecfdc789e6e5dbddfc347cc7524783d5f2cd34e2334461f5d08f7a09bbf88587.md
new file mode 100644
index 0000000000000000000000000000000000000000..cd5edfec3b652a3c0d5cf43973b6c81dbfa45287
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@@ -0,0 +1,432 @@
+Case 9:08-Cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 1 of sincl
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:
+08-CV-80994-Hurley-
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+FILED by
+ELECTRONIC
+VT
+_D.C.
+SEPT. 10, 2008
+. D. OF FLA. - MIAN
+/
+COMPLAINT
+Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties. Jurisdiction and Venue
+Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+HERMAN & MERMELSTEIN, P. A.
+- 1-
+1 o17
+
+
+08-CVa80994 IharleyHopkins1 Entered on FLSD Docket 09/11/2008 Page 2 of 7
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+8.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male,
+approximately 52 years old. Epstein is a financier and money manager with a secret clientele limited
+exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He
+maintains his principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in
+Palm Beach.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004, Jane Doe, then approximately 13 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St. HI
+11.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary compensation
+in his Palm Beach mansion. Epstein, upon information and belief, generally sought out economically
+disadvantaged underage girls from western Palm Beach County who would be enticed by the money
+Herman & Mermelstein, P. A.
+- 2-
+2 of7
+
+
+08-C.Va80994 farley-HOpkins1 Entered on FLSD Docket 09/11/2008 Page 3 of 7
+being offered - generally $200 to $300 per "massage" session - and who were perceived as less likely
+to complain to authorities or have credibility if allegations of improper conduct were made. This
+was an important element of Epstein's plan.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would
+then find herself alone in the room with Epstein, who would be wearing only a towel. He would then
+remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
+13.
+Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years old,
+she was recruited by another girl to give Epstein a massage for monetary compensation. Jane was
+brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to the
+room with the massage table. Epstein came into the room and directed Jane to remove her clothes
+and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein then
+sexually assaulted Jane during the massage. In addition, Epstein masturbated during the massage.
+Epstein then paid Jane money.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNT I
+Sexual Assault and Battery
+15.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+16.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril and sexual assault.
+HERMAN & MERMELSTEIN, P. A.
+- 3-
+3 of 7
+
+
+.Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 4 of 7
+17.
+Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+Jane Doe.
+18.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+19.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were done
+willfully and maliciously.
+20.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and will
+continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+21.
+22.
+23.
+of decency.
+24.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+25.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+HERMAN & MERMELSTEIN, P. A.
+- 4-
+
+
+•Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 5 of 7
+•
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+27.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+28.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+30.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+31. Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual and
+compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as this
+Court deems just and proper.
+HERMAN & MERMELSTEIN, P. A.
+- 5-
+
+
+Case 9:08-cv-80994-KAM Document 1 Entered on FLSD Docket 09/11/2008 Page 6 of 7
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: September 10
+_, 2008
+Respectfully submitted,
+By:
+Jeffrey M. Herman (FL Bar No. 521647)
+Jherman@hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+HERMAN
+& MERMELSTEIN, P. A
+- 6-
+
+
+C5'9144
+08-CV-80994-Hurley Hopkins OIL COWERISHEED Docket 09/11/2008 Page 7 of 7
+The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing, and service of pleading or other papers as required by law,
+except as provided by local rules of court. This form, approved by the Judicial Conference of the United States in September 1974, is required for the use of the Clerk of
+the Court for the purpose of initiating the civil docket sheet. (SEE INSTRUCTIONS ON THE REVERSE OF THE FORM.)
+I(a) PLAINTIFFS
+DEFENDANTS
+JANE DOE NO. 6,
+JEFFREY EPSTEIN
+(b) COUNTY OF RESIDENCE OF FIRST LISTED PLAINTIFF
+COUNTY OF RESIDENCE OF FIRST LISTED DEFENDANT NEW YORK
+(IN U.S. PLAINTIFF CASES ONLY)
+PALM BEACH COUNTY
+(EXCEPT IN U.S. PLAINTIFF CASES)
+(c) ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER)
+Herman & Mermelstein, P.A, 18205 Biscayne Blvd., Suite 2218, Miami,
+FL 33160, (305) 931-2200
+ATTORNEYS (IF KNOWN)
+(d) CIRCLE COUNTY WHERE ACTION AROSE: PALM BEACH
+II. BASIS OF JURISDICTION
+(PLACE AN X ONE BOX ONLY)
+• 1. U.S. Government X 3. Federal Question
+Plaintiff
+(U.S. Govemment Not a Party)
+• 2 U.S. Government
+• 4. Diversity
+Defendant
+(Indicate Citizenship of Parties in Item
+9108CV 80994-Aerley-thpkans
+III. CITIZENSHIP OF PRINCIPAL PARTIES
+(For Diversity Case Only)
+0 4
+Citizen of This State
+Citizen of Another State
+02 02
+Citizen or Subject of a Foreign Country • 3 • 3
+AND ONE FOR DEFENDANT
+Incorporated of Principal Place of
+Business in This State
+Incorporated and Principal Place of O 5 0 5
+Business in Another State
+Foreign Nation
+• 6 06
+I5l)
+IV. CAUSE OF ACTION
+(CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE
+DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY.
+ACTION FOR SEXUAL ASSAULT UNDER 18 U.S.C. §2422 AND STATE LAV
+IVa. 5 days estimated (for both sides) to try entire case
+V. NATURE OF SUIT
+(PLACE AN XIN ONE BOX ONLY)
+A CONTRACT
+A TORTS
+A BANKRUPTCY
+A OTHER STATUS
+00000
+110 Insurance
+88
+140
+Act
+Negotacle instrument
+150 Racovery of Overpayment
+Judgmen
+0151 McCare AC
+O 152 Recovery of Defauled
+Student Loans (Excl
+Vesarars) B
+• 153 Recovery of Overpayment
+of Veteran's Benefts B
+• 180 Stockholder's Suits
+106 Contract Product Liabilty
+PERSONAL INJURY
+© 310 Airplane
+© 302 Personal Injury-Med Malpraction
+• 315 Airplane Product Liability
+© 385 Personal Irjury-Produet Liabilty
+• 320 Assault, Libel & Slander
+• 368
+Asbestos Personnel
+• 330 Federal Employers' Liabilly
+Injury Product Liability
+• 340 Marine
+© 345 Marine Product Liabilty
+PERSONAL PROPERTY
+• 350 Motor Vehicle
+© 355 Motor Vehicle Product Liability O370
+Other Fraud
+X 300 Other Parsonal injury
+0371
+Truth in Landing B
+0 300
+Other Personnel
+• 385
+rty Damage
+Product Liabilty
+B FORFEITURE
+PENALTY
+• 610 Agricuiture
+D 620 Other Food & Crup
+0 625 Drug Related Seizure
+of Property 21 USC 661
+O 830 Liquor Laws
+• 640 R.R. & Truck
+• 650 Airline Regs
+• 660 Ocoupational
+Safety/Heate
+• 000 Ofer
+• 422 Appeal 28 USC 158
+• 423 Wandrawal 28 USC 157
+A REAL PROPERTY
+A CIVIL RIGHTS
+B PRISONER PETITIONS
+A PROPERTY RIGHTS
+0 820 Copyrights
+O830 Patent
+• 840 Trademark
+B SOCIAL SECURITY
+0861 HIA (130511)
+O 862 Black Lung (923)
+0 863 DIWC/D/W(405(p)/
+• 864 SSID TEe XVI
+• 685 RSI (405(gl)
+• 200 Land Condemnator
+220 Foreclosure B
+00
+230 Rent Lease & Ejectment
+240
+Torts to Land
+15 Tort Product Liabi
+200 An Other Real Prope
+• 400
+Status Reappointment
+• 410 Anstrust
+• 430 Banks and Banking
+• 450
+CommerceCC Rates/ec B
+• 460 Deportation
+• 470 Racketeer infuenced and
+Corrupt Organcations
+g so Sacule Come
+Securties/ Commodies/
+FASTER
+• 87s
+Customer Chailenge
+I2USC3410
+• 991
+Agricuitural Acta
+] 882
+0000
+Economic Stabilization Act
+Environmental Maters
+890
+Energy Allocation Act
+Freedom of information Act
+900
+Appeal of Fee Determination
+Under Equal Access to
+Justice
+• 950 Corsilutonality of Sule
+Statutes
+• 441 Voting
+442 Employment
+443 Housing/Acoommodations
+444 Welfare
+440 Other Chl Rights
+• 510 Motions to Vacate Sentence
+Habeas Corpus
+• $30 General
+535 Death Penalty
+540 Mandamus & Other
+A LABOR
+X710 Far Labor Standards
+Act
+• 720 Labor Management
+• 730 Labor Managemen
+Reporting & Disclosure
+Act
+© 740 Raiway Labor Act
+• 790 Osher Labor Litigator
+• 701 Employee Ret inc
+Security Act B
+A FEDERAL TAX SUITS
+Declaratory relef and state law claims
+dor delamation
+87O Tases (U.S. Plantit or Defenda
+871 IR.$-Third Party 20 USC 76
+VI. ORIGIN
+× 1. Original
+Proceeding
+VIl. REQUESTED
+IN COMPLAINT
+• 2. Removed from • 3. Remanded from
+04. Refilled
+O7.
+• 6. Multidistrict Litigation
+Appeal to District Judge from
+State Court
+Appellate Court
+• 5. Transferred from another district
+(Specify)
+Magistrate Judgment
+CHECK IF THIS IS A
+• CLASS ACTION
+DEMAND S
+• UNDER F.R.C.P. 2:
+Check YES only if demanded in X YES
+complaint
+JURY DEMAND:
+• NO
+VIII. RELATED
+(See instructions):
+CASE(S) IF ANY
+Jane Doe 2 v. Jeffrey Epstein
+Jane Doe 3 v. Jeffrey Epstein
+Jane Doe 4 v. Jeffrey Epstein
+Jane Doe 5 v. Jeffrey Epstein
+DATE
+Sept 10, 2608
+UNITED STATES DISTRICT COURT
+REV. 9/94
+(SEE ATTACHED)
+JUDGE KENNETH A. MARRA
+DOCKET NUMBER 08-CV-80119-MARRA-
+JUDGE KENNETH A. MARRA
+DOCKET NUMBER 08-CV-80232-MARRA
+JUDGE KENNETH A MARRA
+DOCKET NUMBER 08-CV-80380-MARRA
+JUDGE KENNETH A MARRA
+OCKET NUMBER 08-80381-CIV-MARF
+SIGNATURE OF ATTORNEY OF RECORD
+FOR OFFICE USE ONLY: Receipt No.
+Amount 30°
+Date Paid:
+
+• Mifp:
\ No newline at end of file
diff --git a/vision-fixhub/court-01/ecfdc789e6e5dbddfc347cc7524783d5f2cd34e2334461f5d08f7a09bbf88587.receipt.json b/vision-fixhub/court-01/ecfdc789e6e5dbddfc347cc7524783d5f2cd34e2334461f5d08f7a09bbf88587.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ef55f3fe01dfc642118325561275a38d4e500382
--- /dev/null
+++ b/vision-fixhub/court-01/ecfdc789e6e5dbddfc347cc7524783d5f2cd34e2334461f5d08f7a09bbf88587.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
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+}
diff --git a/vision-fixhub/court-01/ed06ddd503ce3b60bdfbbde1a1fa3fd2689c84bcbe9f1c4000f80b252d4fee2f.md b/vision-fixhub/court-01/ed06ddd503ce3b60bdfbbde1a1fa3fd2689c84bcbe9f1c4000f80b252d4fee2f.md
new file mode 100644
index 0000000000000000000000000000000000000000..e4009c10aeae7083ec2706798d835f5bc38fac1a
--- /dev/null
+++ b/vision-fixhub/court-01/ed06ddd503ce3b60bdfbbde1a1fa3fd2689c84bcbe9f1c4000f80b252d4fee2f.md
@@ -0,0 +1,26 @@
+Case 9:08-cv-80232-KAM Document 149 Entered on FLSD Docket 06/25/2010 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA|
+JANE DOE NO. 3
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+FINAL ORDER OF DISMISSAL WITH PREJUDICE
+THIS CAUSE is before the Court upon the parties' Stipulation of Dismissal with
+Prejudice [DE 148], filed June 25, 2010. The Court has reviewed the Stipulation, the
+pertinent portions of the record, and is otherwise advised in the premises. In
+accordance with the parties' Stipulation, it is ORDERED AND ADJUDGED as follows:
+1. The above-styled action is hereby DISMISSED WITH PREJUDICE.
+2. All pending motions are DENIED AS MOOT.
+3. The Court shall retain jurisdiction to enforce the terms of the parties'
+settlement.
+4. The Clerk shall CLOSE THIS CASE.
+DONE AND ORDERED In
+at West Palm Beach, Florida this 25 day
+of June, 2010.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Copies Furnished to:
+All Counsel of Record
diff --git a/vision-fixhub/court-01/ed06ddd503ce3b60bdfbbde1a1fa3fd2689c84bcbe9f1c4000f80b252d4fee2f.receipt.json b/vision-fixhub/court-01/ed06ddd503ce3b60bdfbbde1a1fa3fd2689c84bcbe9f1c4000f80b252d4fee2f.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ed1494604264e3876fe55f8c605842fdfb5463e1cbe8eca3139a349361561bf1.md b/vision-fixhub/court-01/ed1494604264e3876fe55f8c605842fdfb5463e1cbe8eca3139a349361561bf1.md
new file mode 100644
index 0000000000000000000000000000000000000000..3e35dc54d392c29e84e471f07b0fb97977bb1035
--- /dev/null
+++ b/vision-fixhub/court-01/ed1494604264e3876fe55f8c605842fdfb5463e1cbe8eca3139a349361561bf1.md
@@ -0,0 +1,91 @@
+• Case 9:08-cv-80994-KAM Document 23-2 Entered on FLSD Docket 03/25/2009 Page 1 of 3
+..
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+1.
+1, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A..,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+3.
+I represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida.
+(The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+• Case 9:08-cv-80994-KAM Document 23-2 Entered on FLSD Docket 03/25/2009 Page 2 of 3
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+6.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+• Case 9:08-cv-80994-KAM Document 23-2 Entered on FLSD Docket 03/25/2009 Page 3 of 3
+The NPA expires in late 2010.
+FURTHER THE AFFIANT SAYETH NAUGHT,
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer
+oaths and take
+acknowledgments, personally
+appeared
+Jack A. Goldberger, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+executed the same, that ! relied upon the following form of identification of the
+above named person: Awon tersonally
+-, and that an oath was/was
+not taken.
+this
+¿NINESS my hand and official seal in the County and State last aforesaid
+rebruary
+(SEAGE
+dotary Public State of Flonia
+LE Rosin
+My Commission DD489790
+Expires 11/13/2009
+KIn E ROSIr
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11/13/2009
+Page - 3 -
diff --git a/vision-fixhub/court-01/ed1494604264e3876fe55f8c605842fdfb5463e1cbe8eca3139a349361561bf1.receipt.json b/vision-fixhub/court-01/ed1494604264e3876fe55f8c605842fdfb5463e1cbe8eca3139a349361561bf1.receipt.json
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/ed14ee6227fd94f7de2660cfdade1bea40c44ce0b2f69f2622af9b8aa66d19e0.md b/vision-fixhub/court-01/ed14ee6227fd94f7de2660cfdade1bea40c44ce0b2f69f2622af9b8aa66d19e0.md
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@@ -0,0 +1,152 @@
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-Civ-Marra/
+JANE DOE #1 AND JANE DOE #2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+REPLY TO JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO
+INTERVENE OR IN THE ALTERNATIVE FOR A SUA SPONTE RULE 11 ORDER
+Comes now, Movant Bruce E. Reinhart, and replies to Plaintiffs' Response to his Motion
+To Intervene Or In The Alternative For A Sua Sponte Rule 11 Order. Plaintiffs wrongly assert
+that there is no common question of law or fact sufficient to support permissive intervention.
+Plaintiffs do not address, nor oppose, Movant's request that the Court on its own initiative
+require Plaintiffs and their counsel to show their compliance with Federal Rule of Civil
+Procedure 11. The Court should hold a sanctions hearing, either through Movant's intervention
+or sua sponte.
+Plaintiffs also prematurely ask that, if the Court permits intervention, they should be
+allowed to take Movant's deposition. Issues of discovery are not ripe at this time.
+On March 21, 2011, Plaintiffs filed a Motion for Finding of Violations of the Crime
+Victims' Rights Act (the CVRA Motion") [DE 48]. Paragraphs 52 and 53 of the CVRA Motion
+falsely alleged that Movant, a non-party to this matter, violated Florida Bar rules and Department
+of Justice regulations by representing employees of Jeffrey Epstein ("Epstein") in civil litigation
+
+
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 2 of 6
+after the undersigned retired from the United States Attorney's Office for the Southern District of
+Florida (the "Office"). The CVRA Motion also falsely alleged that Movant, while still employed
+by the Office engaged in improper conduct relating to Epstein. The CVRA Motion did not even
+attempt to connect these allegations to the relief it seeks. It did not explain how the accusations
+against Movant were relevant to its claims under the CVRA, nor did it explain how Movant's
+alleged conduct could be imputed to any party in the action. Because there was no proper
+purpose for these allegations, Movant sought leave to intervene under Fed. R. Civ. P. 24(b) to
+file a Motion for Sanctions (the "Intervention Motion" [D.E. 79]. In the alternative, Movant
+asked the Court sua sponte to conduct a sanctions hearing. Plaintiffs have now filed a Response
+to the Motion to Intervene [DE 81] (the "Response").
+Movant meets the requirements for permissive intervention under Rule 24(b). See New
+York News, Inc. v. Newspaper and Mail Deliverer's Union, 139 F.R.D. 291, 293 (S.D.N.Y.
+1991), aff'd sub nom New York News v. Kheel, 972 F.2d 482, 487 (2d Cir. 1992). The gratuitous
+attack on Movant's reputation creates a sufficient common question of law or fact to justify
+intervention. Plaintiffs have not articulated any undue prejudice that would outweigh Movant's
+interest in pursuing sanctions against them.
+A request for sanctions based on an attack on a lawyers' reputation creates a sufficient
+common question of law or fact to satisfy Rule 24(b). Kheel, 972 F.2d at 488. Nevertheless,
+Plaintiffs incorrectly cite Kheel for the proposition that Movant lacks standing to seek Rule 11
+sanctions because he is not a party to the litigation. See Response at pp. 3-4. They cite the wrong
+portion of Kheel. The lawyer in Kheel sought sanctions two ways: first, by intervening as a
+party; second, directly under Rule 11 as a non-party. The language cited in the Response is from
+the appellate court's discussion of why the lawyer could not seek sanctions directly under Rule
+11. Here, Movant is seeking to intervene as a party before seeking sanctions. Unlike the lawyer
+2
+
+
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 3 of 6
+in Kheel, Movant does not seek Rule 11 sanctions as a non-party. Rather, Movant seeks to
+become a party, through permissive intervention, prior to seeking sanctions. Plaintiff's reliance
+on Kheel to attack Movant's standing is simply wrong.
+Plaintiffs also make the incorrect argument that if Movant's motion is granted, "legions
+of bystanders will have the ability to intervene in lawsuits through the simple device of claiming
+an interest in filing a Rule 11 sanctions motion." Response at p. 4. Plaintiffs ignore the Court's
+broad discretion under Rule 24(b). That discretion gives the Court the power to police requests
+to intervene, and empowers the Court to prevent "bystanders" from unnecessarily flooding into
+federal court.
+In the instant case, the sanctionable conduct is so clear and egregious that the Court
+should exercise its discretion to permit intervention. The CVRA Motion makes inflammatory
+assertions of unethical conduct by a non-party, which are irrelevant to the relief Plaintiffs seek.
+It does not require substantial judicial resources to look at the face of the CVRA Motion and
+recognize that the allegations against Movant are completely irrelevant to the underlying motion
+and are not included for any proper purpose. These allegations are not repeated in any of the
+subsequent pleadings in support of the CVRA Motion. No existing party has chosen to refute or
+defend against these allegations because they are so clearly irrelevant to the relief sought. This
+Court should not countenance such blatant abusive litigation tactics.
+Plaintiffs have not pointed to any undue prejudice to them from permitting Movant to
+intervene, other than the asserted need to brief an additional issue. Should Plaintiffs avail
+themselves of the 21 day safe harbor under Rule 11 and remove the offending allegations against
+Movant, they will not have to brief anything. They merely will have to file an amended pleading
+that deletes two irrelevant paragraphs. Otherwise, they simply will have to identify for the
+Court facts that are already known to them, that is, what due diligence they undertook before
+3
+
+
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 4 of 6
+filing the CVRA Motion. This process should not require substantial time or resources. The
+interests of justice in deterring frivolous and vexatious litigation outweigh any minimal prejudice
+that arises from requiring Plaintiffs to articulate a legitimate justification for the statements in
+paragraphs 52 and 53 of the CVRA Motion.
+In a further example of their "hit and run" litigation tactics, Plaintiffs now assert that they
+met with representatives of the United States Attorney's Office prior to filing the CVRA Motion.
+They state that Movant's "involvement in the Epstein investigation was discussed." Response at
+p. 6. Nevertheless, in neither the CVRA Motion nor the Response do they state any facts learned
+in those discussions that would support their assertion that Movant violated the Florida Bar rules
+or the Department of Justice regulations. The Court should infer, therefore, that no supporting
+facts exist. The absence of these facts is a further reason the Court should exercise its discretion
+to permit intervention or should sua sponte convene a sanctions hearing.
+Plaintiffs also assert that the Intervention Motion should be denied because Movant is not
+the real party-in-interest in the CVRA litigation. They suggest, without any factual support, that
+Movant is acting as a surrogate for Jeffrey Epstein in attempting to "undercut the victims [sic]
+CVRA lawsuit without Epstein himself becoming involved." Response at pp. 2-3. This
+conspiratorial assertion is baseless. Movant does not seek to intervene in any way on the merits
+of the CVRA claim. Plaintiffs are correct that "[i]t is of no concern to [Movant] whether or not
+the Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the
+Crime Victims' Rights Act." Response at p. 1. Movant had nothing to do with whether or not
+the Government complied with the CVRA. It is for precisely this reason that Plaintiffs and their
+counsel should be sanctioned for including gratuitous personal attacks on Movant in the CVRA
+Motion.
+4
+
+
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 5 of 6
+Plaintiffs summarily assert that Movant's motion is untimely. As noted in the
+Intervention Motion, and not refuted in the Response, Movant did not receive a copy of the
+CVRA Motion until April 20, 2011. The Intervention Motion was filed on May 3, 2011, which
+is within the two week time period normally applicable to a motion response. Plaintiffs have not
+pointed to any prejudice from this allegedly late filing.
+Although it has no relevance to the Intervention Motion currently pending before the
+Court, the Response notes that Plaintiffs requested an interview with Movant after they received
+the Intervention Motion and that Movant declined to be interviewed. The belated request was
+made after Plaintiffs received the Intervention Motion and a sworn declaration from Movant. It
+is further evidence that Plaintiffs did not comply with their Rule 11 obligations before filing the
+CVRA Motion.'
+Plaintiff's alternative request for relief - taking Movant's deposition -- is premature and
+irrelevant to whether intervention is proper. Should the Court grant intervention, Movant will
+serve the proposed Rule 11 motion pursuant to Rule 5. See Fed. R. Civ. P. 11(c)(2). Plaintiffs
+will then have 21 days to withdraw or amend their underlying motion. Id. Should they decline
+to withdraw or amend the motion, Movant would then file the Rule 11 motion with the Court. At
+that time, Plaintiffs would be entitled to respond and to seek whatever discovery is warranted.
+Until the Rule 11 motion is filed, it is premature for the Court to decide what discovery, if any,
+would be appropriate.
+1 The request for interview went far beyond the question of whether Movant had any role
+in the Government's alleged non-compliance with the CVRA.
+5
+
+
+Case 9:08-cv-80736-KAM Document 83 Entered on FLSD Docket 05/23/2011 Page 6 of 6
+This Court should exercise its discretion to permit intervention under Fed. R. Civ. P.
+24(b), or in the alternative should sua sponte convene a sanctions hearing.
+Respectfully submitted,
+Is/ Bruce E. Reinhart
+BRUCE E. REINHART,P.A.
+Florida Bar # 10762
+250 S. Australian Avenue, Suite 1400
+West Palm Beach, Florida 33401
+(561) 202-6360 fax (561) 202-6976
+Breinhart @BruceReinhartLaw.com
+CERTIFICATE OF SERVICE
+I hereby certify that a true and correct copy of the foregoing Motion to Intervene or in the
+Alternative for a Sua Sponte Rule 11 Order was served on all counsel of record by CM/ECF on
+May 23, 2011.
+Is/Bruce Reinhart
+BRUCE REINHART
+6
diff --git a/vision-fixhub/court-01/ed14ee6227fd94f7de2660cfdade1bea40c44ce0b2f69f2622af9b8aa66d19e0.receipt.json b/vision-fixhub/court-01/ed14ee6227fd94f7de2660cfdade1bea40c44ce0b2f69f2622af9b8aa66d19e0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..07b2829e96dcaef8b8df5d3113e001f804188bd9
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diff --git a/vision-fixhub/court-01/ed27bc62c21387096346f8e5ed0a6ecd59131f1398b7b808c973a2eea4bc4faf.md b/vision-fixhub/court-01/ed27bc62c21387096346f8e5ed0a6ecd59131f1398b7b808c973a2eea4bc4faf.md
new file mode 100644
index 0000000000000000000000000000000000000000..8df36cb365386c6b50be0a4844793251c712fba4
--- /dev/null
+++ b/vision-fixhub/court-01/ed27bc62c21387096346f8e5ed0a6ecd59131f1398b7b808c973a2eea4bc4faf.md
@@ -0,0 +1,127 @@
+Case 1:20-cv-00484-JGK-DCF Document 106 Filed 05/11/21 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+X
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of
+the ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+20-cv-00484-JGK
+------
+GHISLAINE MAXWELL'S MEMORANDUM OF LAWIN SUPPORT OF
+HER APPLICATION FOR COSTS SOUGHT AGAINST PLAINTIFE
+Laura A. Menninger
+HADDON, D
+150 East 10" Avenue
+Denver, CO 80203
+303.831.7364
+AND
+L. P.C.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 106 Filed 05/11/21 Page 2 of 4
+On March 19, 2021, this Court dismissed plaintiff's case with prejudice, based on her
+motion for voluntary dismissal pursuant to Fed. R. Civ. P. 41(a)(2). As the prevailing party in
+this matter, Ms. Maxwell hereby requests, pursuant to Fed. R. Civ. P. 54(d)(1), an order
+awarding her taxable costs against plaintiff Jane Doe.
+Rule 54(d)(1) provides that "[u]nless a federal statute, these rules, or a court order
+provides otherwise, costs—-other than attorney's fees—should be allowed to the prevailing
+party." Fed. R. Civ. P. 54(d)(1). "Courts consistently have found defendants to be prevailing
+parties where the action against them was voluntarily dismissed with prejudice." Cir. for
+Discovery, Inc. v. D.P., No. 16-CV-3936-MKB-RER, 2018 WL 1583971, at *14 (E.D.N.Y. Mar.
+31, 2018); see Beer v. John Hancock Life Ins. Co., 211 F.R.D. 67, 70 (N.D.N.Y. 2002) ("All
+circuit courts to have directly addressed this issue have concluded that a defendant [who has
+obtained a voluntary dismissal with prejudice] is a prevailing party, or alternatively, that a
+district court has discretion to award costs to the defendant."); see also Carter v. Inc. Vill. of
+Ocean Beach, 759 F.3d 159, 165 (2d Cir. 2014) (disclaiming prior Second Circuit dicta which
+stated that "generally the defendant is not considered the prevailing party when, as here, there is
+a voluntary dismissal of the action by the plaintiff with prejudice." (citations omitted)). "A
+voluntary dismissal of an action with prejudice [is considered to materially alter the relationship
+of the parties], because it constitutes 'an adjudication on the merits for purposes of res
+judicata."" Carter, 759 F.3d at 165 (citation omitted); accord Feb. 12, 2021, Opinion and Order,
+DE 118; accord Jane Doe v. Darren K. Indyke et. al, Case No. 20-cv-484 (JGK), DE 98 at 5
+(addressing identical Rule 41(a)(2) motion and holding "Ms. Maxwell is correct that under
+Second Circuit law, she is the prevailing party for the purposes of Rule 54(d)").
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 106 Filed 05/11/21 Page 3 of 4
+An award of costs under Rule 54 is the "normal rule," and "the losing party has the
+burden to show that costs should not be imposed." Torcivia v. Suffolk Cty., 437 F. Supp. 3d 239,
+249 (E.D.N.Y. 2020) (quoting Harris v.
+1. No. 08-CV-1703 MKB, 2013 WL 632247, at *1
+(E.D.N.Y. Feb. 20, 2013). Once "the prevailing party demonstrates the amount of its costs and
+that they fall within an allowable category of taxable costs, see Local Rule 54.1(a), that party
+enjoys a presumption that its costs will be awarded." Equal Employment Opportunity Comm'n v.
+United Health Programs of Am., Inc., 350 F. Supp. 3d 199, 236 (E.D.N.Y. 2018) (quoting
+Patterson v. McCarron, No. 99-cv-11078 (RCC), 2005 WL 735954, at *1 (S.D.N.Y. Mar. 30,
+2005).
+Annexed hereto is Ms. Maxwell's Bill of Costs, including the Affidavit of Laura
+Menninger and exhibits, in the form required by Local Civil Rule 54.1 and including only those
+taxable costs prescribed by the rule.' As the prevailing party, Ms. Maxwell is presumptively
+entitled to an award of cost, and plaintiff is unable to meet her burden to demonstrate why costs
+should not be imposed. Accordingly, Ms. Maxwell requests that the Court order plaintiff to pay
+her costs in the amount detailed in the attached.
+WHEREFORE, Ms. Ghislaine Maxwell requests an award of costs pursuant to Fed. R.
+Civ. P. 54(d)(I) as the prevailing party in this action.
+'Ms. Maxwell seeks herein only her costs and expressly reserves her right to seek
+attorneys' fees incurred in defense of this action in future litigation either against plaintiff (e.g.,
+as claims for malicious prosecution or abuse of process), against the Estate of Epstein (under an
+indemnification theory), or both. See Opinion and Order of Feb. 10, 2021 at 5 (DE 118); accord
+Opinion and Order of Mar. 9, 2021, Jane Doe v. Darren K. Indyke et. al, 20-cv-484 (JGK), at 5
+(Dkt. 98) (striking language from proposed Rule 41(a)(2) dismissal relating to each party paying
+their own fees and costs to preserve right to seek attorneys' fees from this litigation in potential
+future litigation for claims including the torts of abuse of process and malicious prosecution).
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 106 Filed 05/11/21 Page 4 of 4
+Dated: May 11, 2021
+Respectfully submitted,
+s/ Laura A. Menninger
+Laura A. Menninger (LM-1374)
+HADDON,
+AND
+150 East 10"" Avenue
+Denver, CO 80203
+Phone: 303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+Attorneys for Ghislaine Maxwell
+P.C.
+Certificate of Service
+I hereby certify that on May 11, 2021, I electronically filed the foregoing Ghislaine
+Maxwell's Memorandum of Law In Support of Her Application for Costs Sought Against Plaintif)
+with the Clerk of Court using the CM/ECF system which will send notification of such filing to
+the following:
+Kevin Boyle
+Robert Glassman
+Panish, Shea & Boyle
+11111 Santa Monica Blvd., Ste 700
+Los Angeles, CA 90025
+boyle@psblaw.com
+glassman@psblaw.com
+Bennet J. Moskowitz
+Charles L. Glover
+Mary
+W. Metcalfe
+Troutman Pepper|
+Sanders LLP
+875 Third Avenue
+New York, NY 10022
+bennet.moskowitz@troutman.com
+charles.glover@troutman.com
+marygrace.metcalfe@troutman.com
+Molly S. DiRago
+routman Peppe
+Sanders LLP
+27 W. Monroe Street, Suite 390
+Chicago, IL 60606
+nolly.dirago@troutman.com
+s/ Nicole
+3
diff --git a/vision-fixhub/court-01/ed27bc62c21387096346f8e5ed0a6ecd59131f1398b7b808c973a2eea4bc4faf.receipt.json b/vision-fixhub/court-01/ed27bc62c21387096346f8e5ed0a6ecd59131f1398b7b808c973a2eea4bc4faf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..75d0be2fdf0e26eafc393be3deee74759e9fce41
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+}
diff --git a/vision-fixhub/court-01/ed503c29d35af3b39a6448fc0579dd7da1d925fe4f3aeb1b0f469aa76d602ead.md b/vision-fixhub/court-01/ed503c29d35af3b39a6448fc0579dd7da1d925fe4f3aeb1b0f469aa76d602ead.md
new file mode 100644
index 0000000000000000000000000000000000000000..c462208075b531b9bd3db9b7a9c8f14a2c1a5582
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@@ -0,0 +1,213 @@
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 09-cv-80469-Marra
+JANE DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN.
+and
+REPLY TO PLAINTIFF'S RESPONSE IN OPPOSITION TO
+MOTION TO SET ASIDE DEFAULT
+Defendant
+by and through undersigned counsel, and pursuant to the
+Federal Rules of Civil Procedure and Local Rule 7.1, replies to Plaintiff's Memorandum Of Law In
+Opposition to Defendant
+Motion To Set Aside Default (DE 47) and states as follows:
+asks the Court to set aside default in this case because service of process was
+legally deficient under New York law, and, the entry of default was premature. Moreover, L
+asks the Court to set aside the default because she has a meritorious defense to the instant
+action which might affect the outcome, granting her motion to set aside the default would not result
+in prejudice to the non-defaulting party, and default in this action was not willful.
+Service of Process Was Legally Deficient Under New York Law
+It is undisputed by the parties that the purported service of process on
+in this
+action is pursuant to Federal Rule of Procedure 4(e)(1) which allows service "pursuant to the law
+of the state ... in which effected." In this case, Plaintiff claims to have served
+in New
+York under section 308(4) of the New York Civil Practice Law and Rules ("CPLR"), which is
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 2 of 7
+colloquially known as "nail and mail service." This type of service is disfavored in New York. In
+fact, New York's highest court has construed the statutory requirements of nail and mail service
+"strictly" stating that "the liberalization of the requirements of service would jeopardize the primary
+statutory purpose of ensuring that defendants receive actual notice of the pendency of litigation
+against them." Feinstein v. Berger, 397 N.E.2d 1161, 1164 (1979).
+1. Plaintiff Failed to Exercise Due Diligence
+"It is well settled that "nail and mail' service pursuant to CPLR 308(4) may be used only
+where personal service under CPLR 308(1) and (2) cannot be made with 'due diligence."" Silber v.
+1. 731 N.Y.S. 2d 227, 228 (N.Y. App. Div. 2001). Plaintiff has the burden of showing due
+diligence for the purposes of CPLR 308(4). See State Higher Educ. Servs. Corp. V. Cacia, 652
+N.Y.S. 2d 883 (N.Y. App. Div. 1997). Courts strictly enforce the due diligence requirement "given
+the reduced likelihood that a summons served pursuant to the action will be received." See
+Lemberger v. Khan, 794 N.Y.S. 2d 416 (N.Y. App. Div. 2005). A plaintiff that resorts to using
+CPLR 308(4) should be prepared to make a detailed showing of the efforts constituting due
+diligence, inasmuch as rigid adherence to the requirement of due diligence is expected. There is no
+set fast rule as to what constitutes due diligence. Instead, courts consider the facts and
+circumstances of each case. Hanover New England v. MacDougall, 608 N.Y.S. 2d 561, 561-62
+(N.Y. App. Div. 1994).
+Here, Plaintiff fails to meet her burden of showing due diligence for the purposes of CPLR
+308(4). In fact, the only reference Plaintiff makes to due diligence in her Response is the following
+phrase: "the process server, who made six (6) attempts to serve before being forced to resort to nail
+and mail service, valid under New York law." Importantly, all six attempts to serve
+2
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 3 of 7
+occurred between April 14 and April 25, 2009, a span of eleven days. The process server states that
+on April 14, 2009, April 21, 2009 and April 24, 2009 he was informed by the doorman at
+apartment residence that
+was "out of town." Certainly, given the consistency
+of the statement that
+was out of town, the process server should have exercised due
+diligence and waited an appropriate period of time for
+to return to town. His repeated
+attempts to serve
+when he possessed knowledge that she was not at the residence speaks
+to his failure to exercise due diligence.
+Notably, the case law Plaintiff relies upon in her Response clearly supports
+S
+legal position. Plaintiff relies upon Maines Paper & Food Service, Inc., v. Boulevard Burgers, 52
+A.D. 3d 1150, 1152 (N.Y.S. App. Div. 2008) to support her claim that the process servers efforts
+comply with New York Law. However, Plaintiff fails to point out that Maines states that "due
+diligence ... refers to the quality of the efforts made to effect personal service ... not to their
+quantity or frequency." Id. Unlike the efforts in this case, in Maines the process server not only
+made repeated attempts to serve at the residence, he also spoke to neighbors, and sought out persons
+who worked with the individual, and he had counsel investigate the individual and research
+databases, credit applications, verify home addresses, and check with the Secretary of State as to
+property ownership. Id. Here, Plaintiff's process server efforts are merely six visits to
+residence when he knew she was out of town. Plaintiff also cites Leviton v. Unger, 868 N.Y.S. 2d
+126 (N.Y.S. App. Div. 2008) in her Response. However, once again Plaintiff fails to point out to
+the Court that in Leviton the court found that service of process by "nail and mail" was insufficient
+as a matter of law because the process server repeatedly went to the person's residence on a day and
+time when the person was likely to be working or commuting, and statements by the process server
+3
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 4 of 7
+as to his efforts to determine where the person worked were conclusory and ambiguous. In this case,
+Plaintiff demonstrates significantly less due diligence that what was at issue in Leviton and Maines.
+Accordingly, Plaintiff's due diligence efforts fail as a matter of law.
+2.
+The Entry of Default Was Premature
+Once the due diligence burden is met, the plain language of the New York "nail and mail"
+statute, CPLR 308(4) requires three steps for service to be complete: (1) the summons must be
+affixed to the door; (2) a copy of the summons and complaint must be served upon the person by
+mail; and (3) plaintiff must file "proof of service" with the court. See N.Y.C.P.L.R. 308(4). The
+plain language of the New York statute states that plaintiff must fulfill each of these elements for
+service to be complete.
+In this case, Plaintiff did not file her proof of service as required by the "nail and mail"
+statute until June 12, 2009, when she attached the proof of service to her motion for default against
+(DE 37). Only upon filing of this notice is service deemed complete by New York law.
+Once service is complete the time in which to answer, appear or move is set by the Federal Rules
+of Civil Procedure. Importantly, Plaintiff admits in her Response that the filing of the proof of
+service required under CPLR 308(4) "pertains solely to the time within which a defendant may
+answer." (Plaintiff's Response DE 47:2). It is well settled New York law that "the failure to file
+proof of service merely enlarge[s] the defendant's time to appear, answer or move." Browning v.
+Nix, 47 Misc. 2d 709, 711 (N.Y.Sup. 1965).
+acknowledges that Plaintiff's failure to file
+a proof of service, standing by itself, does not defeat the efficacy of otherwise valid service. The
+purpose of the filing of the proof of service under the nail and mail statute is to go an extra step so
+as to ensure that someone who has not been personally served has every opportunity to comply. Id.
+4
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 5 of 7
+Here,
+had 20 days from June 12, 2009, specifically until July 2, 2009, in which
+to file a responsive pleading. However, on June 17, 2009, the Court granted Plaintiff's motion and
+entered a default. Five days later, on June 23, 2009|
+moved to set aside the default (DE
+42). Because the Order of Default was entered before the time in which
+had to file a
+responsive pleading expired the Order was premature, there was no default, and the Order should
+be vacated.
+Importantly, soon after filing her Motion to Set Aside Default,
+1, through counsel,
+commenced good faith efforts with Plaintiff to effect a waiver of service. Counsel for Plaintiff was
+contacted by the undersigned by certified letter, email, and telephone. Plaintiff never responded.
+The Default Should Be Set Aside For Good Cause Shown
+Federal Rule of Civil Procedure 55(c) provides the standard for setting aside an entry of
+default. The rule states that "[fJor good cause shown the court may set aside an entry of default. Fed.
+R. Civ. P. 55( c). The Eleventh Circuit holds that the standard for setting aside a default is different
+and less burdensome than the setting aside of a default judgment. See E.E.O.C. v. Mike
+Pontiac GMC, Inc., 896 F.2d 524, 527-28 (11th Cir. 1990). Good cause is a liberal standard. Coon
+v. Grenier, 867 F.2d 73, 76 (Ist Cir. 1989). The relevant factors courts consider under "good
+cause" include "whether (1) the default was willful, (2) a set-aside would prejudice plaintiff, and
+(3) the alleged defense was meritorious." See Compania Interamericana Export-Import, S.A. v.
+Compania Dominicana De Aviacion, 88 F.3d 948, 951 (11 th Cir. 1996).
+First,
+Here, even if the default was properly entered, all factors weigh in favor of setting it aside.
+conduct was not willful. Willfulness is determined by considering whether the
+party intended to violate court rules and procedure and not merely whether the party failed to
+5
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 6 of 7
+answer. Widmer-Baum v.
+-Halford, 162 F.R.D. 545 (N.D. Iowa 1995). Situations where
+a party absconds to avoid liability have been found to be willful. Good faith or the inadvertent
+failure to answer are not willful. Commercial Bank of Kuwait v. Rafidain Bank, 15 F.3d 238, 27
+Fed. R. Serv. 3d 1353 (2d Cir. 1994). Here, there is no evidence that, prior to the default being
+entered,
+or her counsel knew she had been properly served under the New York "nail
+and mail" statute', and that therefore a responsive pleading was due. As set forth above, Plaintiff's
+process server showed no due diligent efforts to provide actual notice to
+Instead, the
+process server merely repeatedly showed up to serve
+when he knew she was not at that
+location.
+Second, Plaintiff will not be prejudiced by setting aside the default because litigation in this
+case has just begun. Plaintiff filed this case in late March 2009. Litigation is in its early stages. See
+Feliciano v. Reliant Tooling Co., 691 F.2d 653, 656-57 (3rd Cir. 1982)(finding that plaintiff's
+expenses, or delay in realizing satisfaction do not constitute sufficient prejudice).
+Third,
+has a meritorious defense to this action.
+did not personally
+commit any sexual battery on the Plaintiff, nor did she conspire with Mr. Epstein to do so. In fact,
+Plaintiff does not allege any physical contact with
+nor does she allege that
+was present for any improper sexual touching. At best, she alleges that
+arranged for
+Plaintiff to massage Mr. Epstein. The evidence will show that
+was not aware of
+whatever happened (or would happen) privately between Mr. Epstein and Plaintiff. As such,
+Plaintiff will not be able to prove
+knowledge or intent to commit any tortious conduct,
+nor her agreement to further such conduct.
+'Florida law does not permit this kind of service.
+6
+
+
+Case 9:09-cv-80469-KAM Document 48 Entered on FLSD Docket 07/21/2009 Page 7 of 7
+Last, "[dJefaults are seen with disfavor because of the strong policy of determining cases on
+their merits." Florida's Physician's Ins. Co. V. Ehlers, 8 F.3d 780, 783(11th Cir. 1993)(internal
+citations omitted). Long-standing Eleventh Circuit precedent holds that "[e]ntry of judgment by
+default is a drastic remedy which should be used only in extreme circumstances. " Wahl v. Melver,
+773 F.2d 1169, 1174 (11th Cir. 1984). The facts and circumstances set forth in this case do not rise
+to an extreme circumstance. Even if the Court finds that service was proper, L
+should be
+afforded the opportunity to have this dispute determined on its merits.
+For the foregoing reasons,
+respectfully requests that her Motion To Set Aside
+Default be granted
+Dated: July 21, 2009
+Respectfully submitted,
+BRUCE E. REINHART, P.A.
+By: /s/ Denise Kalland
+DENISE KALLAND
+Florida Bar No. 39025
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, Florida 33401
+Tel: (561) 202-6360
+Fax: (561) 863-8691
+Dkalland@BruceReinhartLaw.com
+CERTIFICATE OF SERVICE
+"HIS IS TO CERTIFY that on July 21, 2009, the undersigned served copies of [
+Reply to Plaintiff's Memorandum of Law in Opposition to Defendan
+Motion
+to Set Aside Default by electronic CM/ECF filing to all counsel of record.
+Is/Denise Kalland
+DENISE KALLAND
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diff --git a/vision-fixhub/court-01/ed835011abc6b223801859f6c5948e7f8eac335f461ea84425f9ad284c9d9159.md b/vision-fixhub/court-01/ed835011abc6b223801859f6c5948e7f8eac335f461ea84425f9ad284c9d9159.md
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@@ -0,0 +1,36 @@
+Case 9:08-cv-80119-KAM Document 503-1 Entered on FLSD Docket 03/26/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER ON DEFENDANT'S MOTION FOR EXTENSION TO FILE RESPONSE
+TO PLAINTIFES JANE DOE NOS. 2-8' APPEAL PURSUANT TO
+S.D.FLA.MAG.4 AND OBJECTIONS AS TO MAGISTRATE JUDGE'S ORDER
+ON NET WORTH DISCOVERY (DE 493)
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion
+for Extension to file Response to Plaintiffs Jane Doe Nos. 2-8' Appeal Pursuant to
+S.D.Fla.Mag.4 and Objections as to Magistrate Judge's Order on Net Worth Discovery
+(DE 293) dated March 18, 2010. Having considered Defendant's motion it is HEREBY
+ORDERED and ADJUDGED that the motion is GRANTED as follows:
+The Defendant shall file with the clerk of Court, and serve on all parties, his
+Response to Plaintiffs Jane Doe Nos. 2-8' Appeal Pursuant to S.D.Fla.Mag.4 and
+Objection s as to Magistrates Judge's Order on Net Worth Discovery on or before April
+12, 2010.
+
+
+Case 9:08-cv-80119-KAM Document 503-1 Entered on FLSD Docket 03/26/2010 Page 2 of 2
+DONE and ORDERED this
+day of
+, 2010.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record
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diff --git a/vision-fixhub/court-01/ed9abdbe29b3772217c1bf66fd6c6db49271bcf22bcd3d2661f819577fe22bb6.md b/vision-fixhub/court-01/ed9abdbe29b3772217c1bf66fd6c6db49271bcf22bcd3d2661f819577fe22bb6.md
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@@ -0,0 +1,691 @@
+Filed 04/15/20
+
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+& ST. JOHN
+********************************
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+Deceased.
+PROBATE NO. ST-19-PB-80
+ACTION FOR TESTATE
+ADMINISTRATION
+CO-EXECUTORS' STATUS REPORT ON CONTINUING
+EFFORTS TO ESTABLISH VOLUNTARY COMPENSATION PROGRAM AND
+REQUEST FOR RULING
+Come now the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate").
+DARREN K. INDYKE and RICHARD D. KAHN. and provide the Court with this Status Report
+on their continuing efforts to establish an independent and voluntary claims resolution program
+(the "Program") for purposes of resolving sexual abuse claims against Jeffrey E. Epstein, deceased.
+If the Program fails to launch, it will be an extraordinary lost opportunity for
+eligible claimants to receive compensation and voluntarily resolve their claims of sexual abuse
+against Mr. Epstein through a confidential, non-adversarial alternative to litigation. And there will
+be only one culprit: the Attorney General of the Virgin Islands. Despite weeks of negotiation with
+the Attorney General's representatives — who prefer to file misleading "status reports" with the
+Court rather than engage in actual, good-faith discussions - the Co-Executors are no closer than
+before to having the Attorney General lift her liens on the Estate's accounts so that the Program
+can receive funds essential for its operations.
+The Co-Executors and the Attorney General agree on one point: both now seek a
+ruling from the Court that will enable the Program to go forward. The Co-Executors disagree,
+however, on the appropriate issue before the Court. According to the Attorney General, "[her]
+Office seeks a ruling from this Court as to whether the Program, as proposed, should be approved,
+or whether additional concessions, as outlined by the Attorney General, and in the better interests
+SUPERIOR
+SUPERIOR COUR
+VIRGI
+ANL'S
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 2 of 20
+Probate No. ST-19-PB-80
+Page 2
+of the victims, are required for its approval and fair administration." That is not the correct
+question: rather, it is whether the Co-Executors have acted in accordance with their fiduciary
+obligations imposed by USVI law on executors of estates.
+As the Court noted during the February 4, 2020 hearing (the "February 4 Hearing"),
+the Co-Executors function as an arm of the Court and are vested by law with the responsibility of
+administering the Estate. The actual issue before the Court is whether the Program that the Co-
+Executors seek to implement is consistent with their fiduciary duties. As Your Honor recognized.
+the Program as originally designed is not only consistent with the fiduciary duties of the Co-
+Executors, but, in fact ".... we agreed that everybody believes this program is a great program..."
+(February 4 Hearing Tr. at | 13:24-25.)
+Accordingly, the Co-Executors ask that the Court grant their Expedited Motion for
+Establishment of a Voluntary Claims Resolution Program, filed November 14, 2019, and allow
+the Co-Executors to move forward with the Program as originally conceived.
+Background
+More than seven months ago, the Co-Executors sought to establish the Program by
+interviewing numerous highly-qualified candidates for the role of independent claims program
+designer and administrator. The individuals selected — Jordana
+1. Kenneth Feinberg, and
+Camille Biros— are the gold standard, with unparalled experience in that regard.? Designed and
+to be implemented by independent, nationally recognized claims administration experts, with input
+I. Government's Status Report, dated March 18. 2020 ("Gov't. March 18 Status Report"). at 7 (emphasis supplied).
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 3 of 20
+Probate No. ST-19-PB-80
+Page 3
+from interested parties including claimants and their representatives, the Program seeks to timely
+resolve claims through a process that is sensitive to the experiences and concerns of claimants and
+treats them with compassion, dignity, and respect.
+On February 4, 2020, the Court held an extensive hearing on the bona fides of the
+Program, taking detailed testimony from Program Administrator Jordana
+and Program
+Designer Kenneth Feinberg. (February 4 Hearing Tr. at 103:12-186:14.) The Court also heard
+repeated approval of the Program from the multiple claimants' counsel present at that hearing. (Id.
+84:11-85:2; 85:6-19; 92:24-93:8.) As noted above, the Court recognized toward the end of the
+hearing that the Program is widely viewed as an important, positive step for both claimants and
+the Estate. (Id. at |13:24-25 ("THE COURT: ... I think we agreed that everybody believes this
+program is a great program ...").) Only one person, alone among all involved, opposes the
+Program: the Attorney General.? To hold the Program hostage, the Attorney General issued
+Criminal Activity Liens freezing the Estate's accounts, including funds necessary to staff and
+operate the Program.*
+At the conclusion of the February 4 hearing, the Court urged the Co-Executors and
+the Attorney General's representatives to see if they could come to an agreement on funding the
+Program. (Id. 112:4-12; 204:4-10.) Incredibly, the Attorney General tells the Court (twice) that
+it wrote to the Estate on February 10, 2020, but "received no response."S That is false: on February
+12, 2020, counsel for the Estate wrote a six-page letter to the Attorney General addressing each of
+3. See Attorney General's Motion to Intervene, filed January 23, 2020 (attaching Government's Opposition to
+Estate's Motion for Establishment of a Voluntary Claims Resolution Program).
+4. The Co-Executors have now moved in the Superior Court to vacate those Liens. (See Expedited Motion to Vacate
+Liens, dated March 17, 2020).
+5. Gov't. March 18 Status Report, at 1, 2.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 4 of 20
+Probate No. ST-19-PB-80
+Page 4
+the points raised in her letter two days earlier. [Exhibit A] And now, more than five weeks later,
+the Attorney General continues to seek to accomplish her previously-stated goal of scuttling the
+Program before it has a chance to succeed.
+Recent Developments
+On February 28, 2020, the Attorney General
+— who has no experience whatsoever
+with claims resolution programs
+- presented the Co-Executors with an eleven-point laundry list
+of changes she demanded to the Program's funding, structure, and operations.® In their continued
+effort to make the Program a reality, the Co-Executors agreed to eight of those demands without
+substantial change; as to the other three, the Co-Executors agreed to the extent their fiduciary
+duties allow them.? Each of these three latter items is discussed below.
+The Attorney General Demands that Her Personally-Selected Candidate, a
+Biased Advocate with No Claims Administration Experience, Become a Co-
+Equal Program Administrator
+The Attorney General demands that Professor Marci
+,, a legal academic in
+child sexual abuse at the University of Pennsylvania, assume a role in the Program co-equal with
+as Program Administrator.' But
+has no experience in mass tort claims
+resolution, and shoe-horning her into that inappropriate role will force the Estate to incur
+substantial additional time and expense with no commensurate benefit to the Program. That is not
+just the Co-Executor's view: the Program Administrator and the Program Designers unanimously
+6. See Gov't. March 18 Status Report, at Exhibit B.
+7. Bizarrely, the Attorney General reports that she offered the "concession]" that the Estate's cooperation with law
+enforcement not be tied to her approval of the Program. (Gov't. March 18 Status Report, at 3.) The Co-Executor:
+are extensions of the Court; they neither need nor require the Attorney General's concession" to uphold thei
+fiduciary duties to the Estate or cooperate with legitimate law enforcement efforts.
+8. See Gov't. March 18 Status Report, at 2.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 5 of 20
+Probate No. ST-19-PB-80
+Page 5
+oppose this role for
+The Court had the opportunity to hear
+testify
+about her experience and to explain her efforts to address the views of all those interested in the
+design and the implementation of the Program. And, before the Attorney General raised
+candidacy, not a single claimants' counsel raised any concern about
+qualifications, expertise or independence from the Estate.
+Nor would hiring
+in the role demanded by the Attorney General be
+consistent with the Co-Executors" fiduciary duties.
+outspoken views on the
+purported criminality of Mr. Epstein and those around him reveal her deep-seated bias against the
+Estate. It is rich irony that the Attorney General compares
+of a neutral arbitrator. In this matter, |
+proposed role to that
+is as far from a neutral party as one could
+possibly be: her public statements — on television, in opinion pieces and in multiple news articles
+— are replete with her strong, loudly-voiced bias against Decedent and anyone who knew him
+when he was alive, such that she believes the Estate should be drained of all assets without regard
+to any nexus to individual claims. Here are but a few examples:
+"It took us 16 years, but New York will be the epicenter for taking
+down the powerful who sexually abused children in New York. It
+will start to happen this year — in the civil courts. That is because
+there is another path that justice will take to force the facts into the
+public square: On Aug. 14, the one-year look-back window in the
+New York Child Victims Act will kick into effect. When it does,
+every girl who was sexually abused through Epstein's scheme will
+be able to sue for civil damages the ones who caused the abuse.
+Epstein is wealthy and so are many of his friends who enjoyed
+spending time partying with him when these girls - lured into
+doing 'massages' for much-needed cash — were turned into victims
+of a wealthy sex-trafficking ring. The CVA will level the playing
+eld by handing these women potent legal weapons. It's a ne
+orld, and it's finally getting close to fair." Marci
+1. New
+York Daily News, July 8, 2019 ("What Jeffrey Epstein's arrest
+9. See Gov't. March 18 Status Report. at 2.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 6 of 20
+Estale of Jeffrey E. Epstein
+Probate No. ST-19-PB-80
+Page 6
+-
+-
+-
+means: it's a sign of how profoundly things have changed for sex
+abuse victims and perpetrators," available at
+http://www.nydailynews.com/opinion/ny-oped-what-epsteins-arrestmeans-20190708-bdhg5ktn7bds3gf6uti71pssui-story.html).
+"Marci
+•. a child sex-abuse expert and founder of the
+nonprofit think tank CHILD USA, alleges that there's "no question'
+that the men who palled around with Epstein must have noticed the
+presence of underage girls. "There's also no question that they had
+to have known that these girls were supposedly providing massages
+- and that should have been warning bells all over the place,'
+added." (Meera Jagannathan, MarketWatch, July 14.
+2019 ("Amid new Jeffrey Epstein allegations, here's how to help a
+victim
+of
+child
+Sex
+trafficking,"
+available at https://www.marketwatch.com/story/how-to-help-a-
+victim-of-child-sex-trafficking-2019-07-11).
+"Have you noticed that the latest in the Jeffrey Epstein child sextrafficking scandal has focused on the powerful men involved, from
+Epstein to President Trump, Alex Acosta, Bill Clinton, Ken Starr,
+Alan Dershowitz and New York Attorney Geoffrey Berman? To be
+sure, these men-except for Berman operated together to
+empower Epstein to abuse far more girls than he might have
+otherwise, and that is newsworthy." (Marci
+Miami
+Herald, July 14, 2019 ("Epstein's victims deserve to find justice in
+civil
+court,
+100";
+available
+at
+https://www.miamiheraldcom/opinion/op-ed/article 232663662.html).
+"Basically, this failure to protect children is a political problem
+across the culture ... This is outrageous that the [Epstein] victims
+themselves were not even part of the negotiation process. The
+Dozens of them ...
+(Marci)
+The Rachel dow Show Decehber 3, 20y.
+available at http://www. msnbc.com/rachel-maddow/watch/trumpcabinet-members-s-leniency-towed-sex-offender-stirs-outrage-
+1387 897923 761).
+That is not a criticism of
+— as a zealous advocate for children, she
+is of course entitled to voice her deeply-held beliefs. But it does disqualify her as any sort of a
+"neutral" voice in hearing and determining claims through the Program.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 7 of 20
+Probate No. ST-19-PB-80
+Page 7
+Despite
+obvious bias against the Estate and those around Mr.
+Epstein, the Co-Executors still sought to find a way in which her expertise on relevant issues might
+be used to benefit claimants, while at the same time avoiding opportunities for her prejudice to
+mar the Program Administrator's independent, neutral determinations.
+In their efforts at
+continuing compromise, the Co-Executors proposed to the Attorney General that
+play an extensive consulting role with the Program, a significant concession given
+bias:
+*Professor Marci A.
+leading legal academic and advocate of victim's rights, will work closely
+with the Program Administrator to complement the Program's resources.
+role will be to further inform the Administrator and her staff
+about the dynamics of sexual abuse, common responses to sexual abuse.
+and the impact of sexual abuse on victims; to serve as a resource for the
+Administrator in developing or updating policies and procedures; to advise
+the Administrator regarding sensitivities involved in interactions with
+victims; and to serve as a referral source for the Administrator in providing
+post-determination information to claimants who seek guidance, counseling
+or other services."
+(See email from Daniel H. Weiner to Linda |
+dated March 16, 2020, annexed as Exhibit D to
+the Government's March 18, 2020 Status Report.) '°
+Regrettably, the Attorney General rejected that generous proposal out-of-hand in
+her latest public filing."
+10. While the Attorney General purports to quote the Co-Executors" proposal, she leaves out entirely this extensive
+description of the role offered to
+(Gov't. March 18 Status Report, at 4.) That is disingenuous in
+the extreme.
+11. See Gov't. March 18 Status Report. at 4-5.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 8 of 20
+Probate No. ST-19-PB-80
+Page 8
+2.
+The Attorney General Demands that the Co-Executors Restrict Funds
+Available to Claimants Under the Program
+The Attorney General also demands that the Co-Executors "set aside" — ie., make
+unavailable to claimants seeking compensation through the Program — $40 million for the next
+three years. " Restricting the Estate's funds available to pay compensation determinations under
+the Program is anathema to the Co-Executors
+- after all, one of the primary attractions of the
+Program is that all of the Estate's funds are available to it. Removing $40 million from the Estate's
+assets available to the Program — on top of the Attorney General's demand that, to ensure she
+gets paid if she prevails in her CICO action against the Estate, the Estate also "set aside" Little St.
+James Island, Great Saint James Island, and $73.1 million in cash for past tax incentives - risks
+leaving the Program with insufficient funds to make good on its promise of speedy, just
+compensation.
+As a compromise, the Co-Executors offered to set aside $25 million in assets for
+eighteen months, a time period that will extend well beyond the expected term of the Program.
+The Attorney General did not respond to the Co-Executors' good-faith compromise proposal.
+3.
+The Attorney General Demands that the Co-Executors Report to Her
+Information Not Required by Virgin Islands Law
+Finally, the Attorney General demands that, in addition to performing their
+fiduciary duties to the Court by accounting for all items concerning the Estate in accordance with
+Virgin Islands law, the Co-Executors also report to the Attorney General on matters and entities
+outside the probate proceeding. Once again, that is inappropriate: the Attorney General, an active
+12 The Attorney General initially insisted that any unused funds from this set-aside be donated to charity. That
+would constitute a direct breach of the Co-Executors' obligations under Virgin Islands law.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 9 of 20
+Probate No. ST-19-PB-80
+Page 9
+litigant against the Estate, has no right to usurp the Court's authority to oversee the Co-Executors'
+administration of the Estate.'
+*
+***
+As the Attorney General continues to prolong her refusal to fund the Program —
+finding one pretext after another to claim she simply wants to improve the Program, while taking
+actions that would remove over $200 million from the Program and make it more costly and less
+effective — the Estate is forced to actively litigate scores of cases that could otherwise have been
+resolved through the Program. As a result, both claimants and the Estate are expending precious
+resources that would have been far better used in resolving claims through the Program.'*
+It is now-or-never for the Program. Accordingly, the Co-Executors ask the Court
+to allow the Co-Executors to continue to perform their fiduciary duties, and — for the benefit of
+all stakeholders in the Estate, including those who seek to participate in the Program — grant their
+motion to establish the Program as originally conceived and presented to the Court on November
+14, 2019.
+13. The Attorney General also takes a cheap shot at Program Designer Kenneth Feinberg, citing nine-year-old
+criticism of Mr. Feinberg in the BP Deepwater Horizon litigation. (Gov't. March 18 Status Report at 6 and Exhibit
+E.) Yet the court in that case expressly found that Mr. Feinberg was "independent" in the sense that BP did not
+control his evaluation of individual claims. (Id. Exh. D at p. 1I.) And Mr. Feinberg is not the Program
+Administrator here —
+is.
+14. The Attorney General's interference has forced the Estate to litigate against numerous plaintiffs who would have
+participated in the Program if they had the opportunity to do so. As we emphasized to the Court at our February
+21, 2020 conference, the Co-Executors affirmatively decided to reduce litigation (and the adversity inherent in it)
+by making the Program available to litigants as well as to those who were harmed but either were not prepared to
+litigate in a public forum, or barred from recovery through the courts due to statute of limitations or other reasons.
+The Attorney General's actions have had the unfortunate effect of pitting many plaintiffs against the Estate. That
+is precisely the opposite of what the Co-Executors sought and the Court endorsed at the February 4 Hearing.
+
+
+Filed 04/15/20 Page 10 of 20
+Probate No. ST-19-PB-80
+Page 10
+Respectfully,
+Dated: March 23, 2020
+Kroblin
+KROBLIN, ESQ.
+ANDREW W. HEYMANN, ESQ.
+WILLIAM L. BLUM, ESQ.
+SHARI N. D'ANDRADE, ESQ.
+MARJORIE WHALEN, ESQ.
+V.I. Bar Nos. 966, 266, 136, 1221 & R2019
+KELLERHALS FERGUsON KroBlIN PLLC
+Palms Professional Building
+9053 Estate
+, Suite 101
+St.
+1. V.I. 00802
+Telephone: (340) 779-2564
+Facsimile: (888) 316-9269
+Email: ckroblin@kellfer.com
+aheymann@solblum.com
+wblum@solblum.com
+sdandrade@kellfer.com
+mwhalen@kellfer.com
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 11 of 20
+Probate No. ST-19-PB-80
+Page 11
+CERTIFICATE OF SERVICE
+THEREBY CERTIFY that on this 23d day of March 2020, 1 caused a true and exact copy
+of the foregoing Co-Executors' Status Report on Continuing Efforts to Establish Voluntary
+Compensation Program and Request for Ruling to be served via electronic mail upon:
+John H. Benham, Esq.
+Law Office of John H. Benham, P.C.
+P.O. Box 11720
+St.|
+, VI 00801
+john@henhamlavvi.com
+Douglas B. Chanco, Esq.
+ChancoSchiffer P.C.
+3355 Lenox Road, Suite 750
+Atlanta, GA 30326
+doug@csfirm.com
+Richard Bourne-Vanneck, Esq.
+Law Offices of Richard Bourne-Vanneck
+9800 Buccaneer Mall Suite #9
+St.
+VI 00802
+richard@rpvblawoffices.com
+John K. Dema
+Law Offices of John K. Dema
+1236 Strand Street, Suite 103
+St. Croix, VI
+jdema@demalaw.com
+Denise N.
+Esq.
+Attorney General
+Ariel M.
+_. Esq.
+Chief, Civil Division
+Virgin Islands Department of Justice
+34-38 Krondprinsdens Gade
+GERS Complex, 2°° Floor
+St.
+Virgin Islands 00804
+A. Jeffrey Weiss, Esq.
+A.J. Weiss & Associates
+6934 Vessup Lane
+St.
+1 VI 00802
+jeffweiss@weisslaw-vi.net
+Sean
+i. Esg.
+Marjorie Rawls
+P.O. Box 6347
+P.C.
+St.
+1 VI 00804
+sean@marjorierobertspc.com
+Kevin F. D'Amour
+Gaylin Vogel, Esq.
+5143 Palm Passage. 18b & 19b
+St.
+, VI 00802
+kevin.damour@comcast.net
+gaylin.vogel@comcast.net
+Melody D. Westfall, Esq.
+Westfall Law PLLC
+5032 Anchor Way, Suite 8
+Christiansted, St. Croix 00820
+wwestfall@westfalllaw.com
+/s/
+Kroblin_
+
+
+Filed 04/15/20 Page 12 of 20
+* Kellerhals|
+Kroblin PLLC
+Palms Professional Building, 9053 Estate |
+340.779.2564 Telephone | 1.888.316.9269 Fax. | www.kelifer.com
+- Suite 101, St.
+. VL. 00802
+February 12, 2020
+BY E-MAIL
+Denise N.
+Esq.
+Attorney General
+Virgin Islands Department of Justice
+Office of the Attorney General
+34-38 Kronprindsens Gade
+GERS Complex, 2nd Floor
+St.
+VI 00802-5749
+Re: In the Matter of the Estate of Jeffrey E. Epstein
+Probate No. ST-19-PB-80
+Attorney General
+As promised in my e-mail to you dated February 10, 2020, we write in response to
+your letter sent earlier that day regarding the formation of the voluntary compensation
+program - officially known as the Epstein Victims' Compensation Program (the
+"Program") - proposed by the Co-Executors in November 2019 and endorsed by
+Superior Court Judge Hermon-Percell and multiple claimants' counsel at the Court's
+hearing held on February 4, 2020 (the "February 4 Hearing"). We believe your letter
+misapprehends both the Court's direction to the Co-Executors and the Attorney
+General's limited role in this matter, and that your suggestions concerning the purpose,
+structure and administration of the Program are far outside the scope of the single issue
+as to which the Court requested that we confer.
+
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 13 of 20
+1.
+The Program is Designed and Will be Administered by the Nation's
+Leading Experts in the Field.
+As your representatives have no doubt reported to you, both Program
+Administrator Jordana H.
+and Program Designer Kenneth R. Feinberg testified
+at length at the February 4 Hearing. Nationally renowned and respected experts in the
+highly specialized field of mass tort claims resolution,
+Mr. Feinberg, and
+their colleague Camille Biros have extraordinary experience in administering programs
+addressing the Catholic Church's sexual abuse scandal, the Pennsylvania State
+University sexual abuse scandal, the Boeing 737 Max airplane crashes, the General
+Motors transmission recall, the Volkswagen diesel emissions scandal, the BP Deepwater
+Horizon oil spill, the Boston Marathon bombing, the September 11th terrorist attacks, and
+victims of exposure to Agent Orange, DES and asbestos, as well as several other mass
+torts.
+Both
+and Mr. Feinberg testified regarding their absolute
+independence from the Co-Executors in resolving through the Program claims of sexual
+abuse against Mr. Epstein, explaining that such independence is the sine qua non of their
+agreement to design and implement the Program. Far from questioning the capabilities,
+integrity, or independence of|
+and Mr. Feinberg, the multiple stateside and
+Virgin Islands counsel for nearly three dozen individual claimants present at the
+February 4 Hearing supported the Program and the manner in which it was expeditiously
+developed without exception.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 14 of 20
+Other than your counsel, no one in the courtroom (or elsewhere) voiced any
+objections to the Program, which - as designed by
+1, Mr. Feinberg and Ms.
+Biros - will provide claimants with an entirely voluntary, easily accessible, nonadversarial alternative to protracted civil litigation. As Judge Hermon-Percell
+appropriately concluded at the February 4 Hearing, the Program has the potential to save
+enormous amounts of time, risk, and money for both individual claimants and the Estate.
+2.
+The Court Urged the Co-Executors to Consult with the Attorney General
+on a Single Issue: Providing Adequate Funding for the Program.
+Your Office previously raised several objections to the Program?; each was
+addressed in detail at the February 4 Hearing. As the testimony of|
+and Mr.
+Feinberg elucidated, those critiques were either misguided or mistaken, or both. 2 While
+there are various possible permutations in developing the precise details of a
+compensation mechanism, the Program designed by
+, Mr. Feinberg and Ms.
+Biros - with substantial input from claimants' counsel - is cost-effective, fair and just.
+Perhaps most important, the Program is already well underway. As you know,
+and as
+and Mr. Feinberg testified, they have been working on the Program
+1. See Opposition to Estate's Motion for Establishment of a Voluntary Claims Resolution Program, dated
+January 23, 2020.
+2. Your February 10 letter indicates your Office's Lingering confusion on certain aspects of the Program.
+For example, the Co-Executors have not jettisoned the concept of individual claimants signing releases
+if, and only if, those individuals elect to accept the compensation offered by the Program Administrator.
+It would be nonsensical for the Co-Executors to do so, since the Estate would otherwise risk being
+dragged back into litigation through third-party demands for contribution or indemnification. Given
+the Estate's need for legal finality and claimants' unfettered ability to pursue their claims in other fora,
+including through the courts, it is no surprise that - as both
+and Mr. Feinberg testified
+- such releases are commonplace in mass tort compensation programs.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 15 of 20
+since well before the Co-Executors announced the "Establishment of the Epstein Victims'
+Compensation Program" on November 14, 2019 - almost three months ago. As
+Mr. Feinberg and counsel for the claimants made clear at the February 4
+Hearing, they have been working diligently and cooperatively to develop a Protocol for
+Judge Hermon-Percell's review and approval.
+Mr. Epstein died on August 10, 2019 - six months ago. You only first expressed
+disagreement with the Program when you filed your Complaint in the Superior Court on
+January 15, 2020. You did not seek to intervene in the Probate Court until January 23,
+2020 or issue your liens until January 31, 2020. The concerns you now express raise an
+obvious question as to why you didn't propose a different compensation program before
+filing these pleadings - which taken together amount to an effort to block or at least
+substantially delay the Program. You certainly had every opportunity to contact the Co-
+Executors or
+Mr. Feinberg, or Ms. Biros and present your concerns and
+make your suggestions to improve the existing Program, but chose not to do so. And
+while this is neither the time nor the place to address each of your purported concerns
+about the Program, it is worth emphasizing that your letter is long on criticisms -
+misplaced in our view - and woefully short on solutions.
+The bottom line is that the claimants have invested in the Program and both the
+Estate and the claimants are already incurring significant resources unnecessarily
+litigating while you are delaying the Program. That is something no one who is truly
+concerned about conserving Estate resources and offering claimants an alternative to
+litigation should desire.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 16 of 20
+As the Co-Executors pointed out in their recent filings in the Superior Court, it is
+for the Court, not your Office, to oversee administration of the Estate and determine the
+propriety of the Co-Executors' actions under Virgin Islands law. There is only one point
+remaining to be discussed: how best to provide adequate funds for the Program. On this
+issue, the Co-Executors have made their position clear since the outset - they have
+placed no limits, either individually or in the aggregate, on the compensation that
+individual claimants may receive under the Program. That is the very best that the Co-
+Executors can do for existing and potential claimants, as they exercise their fiduciary
+duties under Virgin Islands law in administering the Estate. Your efforts seem singularly
+designed to thwart the proper exercise of these fiduciary duties to the substantial
+detriment of all such claimants.
+As you know, the Co-Executors believe that the liens placed by your Office on the
+Estate's assets are improper and invalid under Virgin Islands law. It is for that reason
+that they seek judicial relief from those liens, which if left in place will cause irreparable
+harm to the Estate's property - including assets that would otherwise be available to
+fund the Program. Already, the Co-Executors' ability to preserve the Estate's assets have
+been severely undercut. The enclosed check written to an exterminator needed to
+preserve one of the properties is the first of what will be many checks to bounce as a result
+of the lien imposed by your Office on the Estate's operating bank account. This is the first
+3. See Supplemental Brief Regarding Co-Executors' Obligations to Satisfy Expenses of Administration
+Notwithstanding Liens Issued to "The Estate," dated January 31, 2020; Emergency Motion for Order
+Releasing Funds for Administration of Estate, dated February 10, 2020.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 17 of 20
+of what will become an avalanche of harms to the Estate. Your lien has also stripped the
+Co-Executors of their ability to meet payroll, and prevents them from paying electric,
+water, and other basic bills. As a result of your actions, all the Estate's assets - including
+the islands in St.
+i - will rapidly lose value. Likewise, the impact on the properties
+in Paris, New York City, and Florida if the Estate is unable to pay for their operating and
+maintenance expenses will likely be swift and severe. And it will be hard if not
+impossible to rehire staff once they are forced to seek alternative employment. The harm
+will be irreparable and substantial. Most disappointing and in disregard of the Court's
+request, your Office is holding the Program hostage, thereby threatening to derail a
+vitally important process for claimants to obtain justice.
+The Co-Executors continue to hope that you will reverse your Office's position. In
+the interests of all concerned, the Co-Executors remain willing to work with you on how
+best to adequately fund the Program. Time is of the essence if the Program, and the hopes
+of those women who are eager to use it, are to survive.
+Respectfully,
+Chutch All Kille
+_Kroblin
+CC:
+Jordana H.
+Program Administrator
+
+
+Filed 04/15/20 Page 18 of 20
+Attack Exterminating Company LIC
+7105 3rd Avenue #438
+Brooklyn, NY 11209
+info@attackexterminating.com
+www.attackexterminating.com
+EKTERNTRATIHG
+BILL TO
+NES, LLC
+9 East 71st Street
+New York, NY 10021
+INVOICE # 2395
+DATE 01/01/2020
+DUE DATE 01/31/2020
+TERMS Net 30
+Monthly Service
+9 Bast 71st
+Street
+1
+100.00
+100.00T
+SUBTOTAL
+TAX
+TOTAL
+BALANCE DUE
+100.00
+8.88
+($108.88
+MUL.
+•
+
+
+Filed 04/15/20 Page 19 of 20
+FIRST BANK
+STAGE Cada
+VI 00802
+101-7285/2216
+
+ESTATE OF JEEEREY EPSTEIN
+9053 ESTATE
+STE 101
+VI 00802
+DATE
+$ **108.88
+MEMO
+Attack Exterminating Company LLC
+One Hundred Eight and 88/100***
+Attack Exterminating Company LLC
+7105 3rd Avenue #438
+Brooklyn, NY 11209
+DOLLARS
+MP
+PIZED SIGNATI
+ESTATE OF JEFFREY EPSTEIN
+Attack Exterminating Company LLC
+
+First Bank Estate JE
+ESTATE OF JEFFREY EPSTEIN
+Attack Exterminating Company LLC
+
+First Bank Estate JE
+TO REORDER CALL 708-813-2447 OF VISIT www.extravaluechecks.com.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 28-1 Filed 04/15/20 Page 20 of 20
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+& ST. JOHN
+********************************
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+)
+)
+Deceased.
+PROBATE NO. ST-19-PB-80
+ACTION FOR TESTATE
+ADMINISTRATION
+ORDER
+THIS MATTER is before the Court on the Co-Executors' Status Report on Continuing
+Efforts to Establish Voluntary Compensation Program and Request for Ruling. Having reviewed
+the Co-Executors' Status Report on Continuing Efforts to Establish Voluntary Compensation
+Program and Request for Ruling, the Court will grant the same.
+Accordingly, it is hereby:
+ORDERED that the Co-Executors' Status Report on Continuing Efforts to Establish
+Voluntary Compensation Program and Request for Ruling is GRANTED; and it is further
+ORDERED that the Co-Executors' Expedited Motion for Establishment of a Voluntary
+Claims Resolution Program is GRANTED; and it is further
+ORDERED that a copy of this Order shall be directed to counsel of record.
+:
+Dated:
+ATTEST: TAMARA CHARLES
+Clerk of the Court
+BY:
+Court Clerk Supervisor
+/
+CAROLYN P. HERMON-PERCELL
+Magistrate Judge of the Superior Court
+of the Virgin Islands
+/
\ No newline at end of file
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@@ -0,0 +1,89 @@
+• Case 9:08-cv-80380-KAM Document 72-2 Entered on FLSD Docket 03/25/2009 Page 1 of 3
+..
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+1.
+1, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A..,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+3.
+I represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida.
+(The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+• Case 9:08-cv-80380-KAM Document 72-2 Entered on FLSD Docket 03/25/2009 Page 2 of 3
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+• Case 9:08-cv-80380-KAM Document 72-2 Entered on FLSD Docket 03/25/2009 Page 3 of 3
+The NPA expires in late 2010.
+FURTHER THE AFFIANT SAYETH NAUGHT,
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer
+oaths and take
+acknowledgments, personally
+appeared
+Jack A. Goldberger, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+executed the same, that ! relied upon the following form of identification of the
+above named person: Awon Personally
+-, and that an oath was/was
+not taken.
+this
+¿NINESS my hand and official seal in the County and State last aforesaid
+rebruary
+(SEAGE
+dotary Public State of Flonia
+LE Rosin
+My Commission DD489790
+Expires 11/13/2009
+KIn E ROSIr
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11/13/2009
+Page - 3 -
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diff --git a/vision-fixhub/court-01/edc1c002b20c45e096bd42e1eb9ffdc6bda7c9e7bd2b9212267a61f24a8e5efc.md b/vision-fixhub/court-01/edc1c002b20c45e096bd42e1eb9ffdc6bda7c9e7bd2b9212267a61f24a8e5efc.md
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@@ -0,0 +1,291 @@
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+-against-
+DARREN K. INDYKE and RICHARD D. KAHN, in their
+capacities as executors of the ESTATE OF JEFFREY E.
+EPSTEIN; NES, LLC; NINE EAST 71ST STREET
+CORPORATION; FINANCIAL TRUST COMPANY, INC.;
+NEW YORK STRATEGY GROUP, LLC; DARREN K.
+INDYKE, in his capacity as trustee of EPSTEIN INTERESTS;
+DARREN K. INDYKE, in his capacity as a representative of
+J. EPSTEIN VI FOUNDATION; J. EPSTEIN VIRGIN
+ISLANDS FOUNDATION, INC.; C.O.U.Q. FOUNDATION,
+INC.; GRATITUTE AMERICA LTD.; DARREN K. INDYKE
+and RICHARD D. KAHN, in their capacities as trustees of THE
+1953 TRUST; SOUTHERN TRUST COMPANY, INC.;
+MAPLE, INC.; CYPRESS, INC.; LAUREL, INC.; SCI JEP;
+POPULAR, INC.; NAUTILUS, INC.; HBRK ASSOCIATES,
+INC.; JEGE, LLC; JEGE, INC.; PLAN D, LLC; HYPERION
+AIR, LLC; FREEDOM AIR INTERNATIONAL, INC.; ZORRO
+DEVELOPMENT CORP.; LSJE, LLC; L.S.J., LLC; ZORRO
+MANAGEMENT, LLC,
+Defendants.
+Docket No. 20-CV-02365
+----X
+MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S
+APPLICATION TO PROCEED ANONYMOUSLY
+KAISER SAURBORN & MAIR, P.C.
+Daniel J. Kaiser
+30 Broad Street, 37" Floor
+New York, New York 10004
+(212) 338-9100
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 2 of 10
+TABLE OF CONTENTS
+PRELIMINARY STATEMENT
+BACKGROUND FACTS
+ARGUMENT
+THE MULTI FACTOR SECOND CIRCUIT TEST FOR PROCEEDING
+ANONYMOUCLY SUPPORTS JANE DOE'S RIGHT TO PROCEED
+ANONYMOUSLY
+B.
+The litigation involves matters that are highly sensitive
+and personal in nature
+Whether identification poses a risk of retaliatory physical or
+mental harm to the party seeking to proceed anonymously
+C. Whether the identification process poses other harm
+D.
+Whether the Plaintiff is particularly vulnerable to the harms
+resulting from disclosure.
+F.
+Whether the suit is challenging the actions of the government
+or private parties
+Whether the defendant would be prejudiced by permitting
+Plaintiff to proceed anonymously
+G. Whether plaintiff's identity has thus far been kept confidential.
+H. Whether the public's interest is furthered by requiring
+disclosure of Plaintiff's identity
+I.
+J.
+The public's interest on knowing the plaintiff's identity based
+purely on the legal nature of the issues presented.
+Whether there are any alternative mechanism for protecting
+the plaintiff's identily.....
+Page
+..1
+.2
+.3
+.3
+.4
+.4
+.5
+.5
+.5
+.5
+.6
+.6
+.6
+CONCLUSION
+.6
+.7
+i
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 3 of 10
+TABLE OF AUTHORITIES
+Case
+A.B. v. Hilton Worldwide Holdings, 484 F.Supp.3d 921 (D.Oregon 2020)
+Doe v. Epstein, 2008 WL 11332056 (S.D.Fl. 2008).
+Doe v. Steele, 2020 WL 6712214 (S.D.Cal).
+Jane Doe v. Kolko, 242 FRD 193 (EDNY 2006)
+John Doe v. Colgate University, 2016 WL 1448829 (W.D.N.Y. 2016).
+Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185 (2nd Cir. 2008)
+S.Y. v. Vomini & Kudai, LLC, 2021 WL 3054871 (M.D.F1. 2021).
+Page
+.5
+.5
+..5
+.4
+.4
+....3,4
+........5
+ii
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 4 of 10
+PRELIMINARY STATEMENT
+Plaintiff, Jane Doe, was during the course of a decade repeatedly and violently sexually
+assaulted by Jeffrey Epstein while being trafficked globally. Despite this unspeakable abuse,
+there are some who have mercilessly disparaged Jane Doe and even threatened her with death. If
+Jane Doe's name were to be made public, others would likely descend upon her with further
+death threats.
+Jane Doe's Jeffrey Epstein story has never been told. Those who have followed the
+Epstein saga have no understanding of the constant and ritualistic abuse Jane Doe endured. As
+her therapist attests to in her affidavit, her psychological state is tenuous and severe. If she were
+to be required to proceed publicly it would likely further exacerbate her dangerous psychiatric
+condition.
+The Second Circuit has articulated a multi factor test when deciding whether to permit a
+Jane Doe to proceed with a lawsuit anonymously. As discussed below, nearly all of the factors
+weigh in favor of permitting Jane Doe to proceed with her lawsuit anonymously.
+Most of Epstein's other victims have proceeded in court anonymously. Further, Jane Doe
+has rejected countless media requests for interviews and TV specials because of her desire and
+need to proceed anonymously.
+The granting of this motion provides Jane Doe the protection she needs while at the same
+time resulting in no disadvantage or prejudice to Defendants. Jane Doe's mental health and
+physical safety requires this protection. At the same time, Defendants retain their right and
+ability to fully and fairly defend against these claims.
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 5 of 10
+BACKGROUND FACTS
+The filed pleading avoids too much detail in order to protect Jane Doe's identity which
+otherwise could be inferred from a detailed publicly filed presentation.
+The basic narrative, however, is that Jane Doe was sex trafficked by Mr. Epstein for more
+than a decade during which time she was nearly always required to be sexually available to Mr.
+Epstein wherever he might be located. The sexual abuse included at times violence and very
+often occurred in the middle of the evening with Mr. Epstein crawling into Jane Doe's bed and
+sexually abusing her.
+Abbie Tuller's affidavit makes clear that Jane Doe's current psychiatric condition is
+severely debilitating and further opines that requiring her to proceed publicly would likely do
+grievous psychological harm. [See Abbie Tuller's Affidavit attached as Exhibit "B" to
+Declaration of Daniel J. Kaiser ["Kaiser Affirm."]
+For reasons that if elaborated upon here may itself reveal her identity, there are some who
+would seek to disparage and perhaps threaten Jane Doe if she were to proceed publicly. These
+facts, if necessary, can be provided in confidence to the Court.
+The facts of abuse included in the currently filed complaint are as follows:
+Jeffrey Epstein specifically targeted underprivileged, emotionally vulnerable and/or
+economically disadvantaged young females exactly like Plaintiff to sexually molest and
+abuse. [Complaint 9| 19 attached as Exhibit "A" to Kaiser Affirm.]
+Epstein's continuous psychological and physical control over Jane Doe facilitated his
+sexual abuse of her on a relatively consistent basis for many years. [Id. | 20]
+The sexual abuse took many forms including Epstein's violent rape of Plaintiff. [Id. 9
+21]
+2
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 6 of 10
+He would also enter plaintiff's room and get into her bed while she was sleeping and
+then fondle or penetrate her with his fingers. This occurred often and repeatedly. [Id. | 22]
+He often directed her to undress and pose in certain ways and/or touch him and herself
+while he masturbated. This occurred often and repeatedly. [Id. 1 23]
+Epstein frequently directed Jane Doe to turn her head back during their sexual
+encounters, telling her that he did not want to see her face. [ld. 1 24]
+Epstein also repeatedly required Jane Doe to bathe with him and perform oral sex on
+him. [Id. 9| 25]
+This occurred in New York, Palm Beach, New Mexico, London, Paris, on Epstein's
+private island, on Epstein's airplanes and other locations. [Id. 4 26]
+Jane Doe was paid in large part to be sexually available to Epstein. [ld. 9| 27]
+In or about January or February 2012, Epstein grabbed Plaintiff by the hand while at his
+New York City Residence and took her to a small room on the third floor. It was a room with
+two chairs in it. He sat her down, pulled her pants down, covered her eyes, and used a vibrator
+on her. Epstein laughed afterwards. [Id. 9| 28]
+ARGUMENT
+THE MULTI FACTOR SECOND CIRCUIT TEST FOR PROCEEDING
+ANONYMOUSLY SUPPORTS JANE DOE'S RIGHT TO PROCEED ANONYMOUSLY
+In articulating its test for proceeding anonymously, the Second Circuit in Sealed Plaintiff
+v. Sealed Defendant, 537 F.3d 185 (2nd Cir. 2008) noted:
+Accordingly, we endorse the Ninth Circuit's formulation and hold
+that when determining whether a plaintiff may be allowed to
+aintain an action under a pseudonym, the plaintiff's interest i
+nonymity must be balanced against both the public interest i
+disclosure and any prejudice to the defendant.
+************
+3
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 7 of 10
+This balancing of interests entails the consideration of several
+factors that have been identified by our sister Circuits and the
+district courts in the Circuit. We note with approval the following
+factors......
+Id. at 189; Jane Doe v. Kolko, 242 FRD 193 (EDNY 2006) (court held Second Circuit test
+supported Plaintiff's right to proceed anonymously); John Doe v. Colgate University, 2016 WL
+1448829 (S.D.N.Y. 2016) (court held that plaintiff would be permitted to proceed anonymously
+noting in particular that Defendant would suffer not prejudice)
+The Sealed Plaintiff factors are discussed below.
+A. The litigation involves matters that are highly sensitive and
+personal in nature
+Here, the allegations could not be more sensitive or more of a personal nature. Jane Doe
+has been psychiatrically ravaged by Epstein's abuse. Very often, sexual assault victims do not
+come forward or in any manner or respect reveal themselves because sexual assault cases are so
+highly sensitive. Here, heap on top of that that the abuser was the notorious Jeffrey Epstein and
+revealing yourself as a victim becomes extraordinarily difficult.
+B. Whether identification poses a risk of retaliatory physical
+or mental harm to the party seeking to proceed anonymously
+As noted, there are many others involved in the Epstein story in various roles, who
+knowing nearly nothing of Jane Doe's story have disparaged and insulted her premised upon
+false facts and a lack of any understanding of Jane Doe's own sexual abuse. She has also
+received death threats in the past, which have stopped her from coming forward with details of
+her abuse publicly.
+A requirement that Jane Doe proceed publicly would unnecessarily expose her to not
+only potentially life threatening physical abuse from this group of persons, but the psychological
+consequences for Jane could be profound.
+4
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 8 of 10
+C. Whether the identification process poses other harms
+Jane Doe would likely be damaged psychologically even if not from the direct result of
+retaliation. Her therapist's affidavit is clear on that point.
+D. Whether the Plaintiff is particularly vulnerable to the harms
+resulting from disclosure
+She certainly is. Her current psychological state is precarious and any small additional
+stress could result in catastrophic consequences. She also has no way to physically protect
+herself should anyone try to follow through with their death threats.
+E. Whether the suit is challenging the actions of the government
+or private parties
+This is the only factor that weighs in slightly favor of proceeding publicly.
+F. Whether the defendant would be prejudiced by permitting
+Plaintiff to proceed anonymously
+Defendants would suffer no prejudice. Defendants know Jane Doe's identity and will
+have the ability to obtain any and all discovery to which they are entitled. Defendants' ability to
+defend this action is not compromised in any respect. In numerous other lawsuits against Epstein
+by sexual assault and trafficking victims, as well as other sex trafficking cases, they proceeded
+anonymously without any difficulty. See, Doe v. Epstein, 2008 WL 11332056 (S.D.Fl. 2008)
+(court held Jane Doe could proceed anonymously); Doe v. Steele, 2020 WL 6712214 (S.D.Cal)
+(court held that sex trafficking victim would be permitted to proceed anonymously); A.B. v.
+Hilton Worldwide Holdings, 484 F.Supp.3d 921 (D.Oregon 2020) ( court held that sex
+trafficking victim would be permitted to procced anonymously); S.Y. v. Vomini & Kudai, LLC,
+2021 WL 3054871 (M.D.Fl. 2021) (court held that sex trafficking victim would be permitted to
+proceed anonymously).
+5
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31 Filed 07/30/21 Page 9 of 10
+G. Whether plaintiff's identity has thus far been kept confidential
+Jane Doe has remained confidential from the beginning of this litigation which
+underscores her desire and need for continued confidentiality. Also, Jane Doe has fielded
+through countless requests for interviews from media outlets and has turned all of them down
+consistent with her desire to remain anonymous.
+H. Whether the public's interest is furthered by requiring disclosure of
+Plaintiff's identity
+There is no public interest that is advanced through public disclosure. The Epstein story
+is well known and has been extensively covered in the media. Generally, Epstein victims have
+been permitted to proceed anonymously undercutting any argument that the public's interest is
+compromised.
+I. The public's interest in knowing the plaintiff's identity based purely
+on the legal nature of the issues presented
+No legal issues present that elevate the public's interest in disclosure. This matter is a
+straightforward sex trafficking case the facts of which do not present novel legal issues for
+resolution by this Court.
+The central factual dispute as to whether Mr. Epstein sexually abused Jane Doe,
+including raping her, and whether she was trafficked in connection with that abuse are resolved
+without and novel and/or first impression legal rulings.
+J. Whether there are any alternative mechanism for protecting the plaintiff's
+Identity
+There are no alternatives to permitting Jane Doe to proceed anonymously that can
+protect Jane Doe.
+6
+
+
+Case 1:20-cv-02365-LJL-DCF Document 31
+Filed 07/30/21 Page 10 of 10
+CONCLUSION
+For all of the foregoing reasons, Plaintiff respectfully requests that her motion to be
+permitted to proceed anonymously be granted.
+Dated: New York, New York
+July 30, 2021
+Kaiser Saurborn & Mair, P.C.
+V-12
+By:
+Daniel J. Kaiser, Esq.
+Attorneys for Plaintiff
+30 Broad Street, 37 Floor
+New York, New York 10004
+(212) 338-9100
+7
diff --git a/vision-fixhub/court-01/edc1c002b20c45e096bd42e1eb9ffdc6bda7c9e7bd2b9212267a61f24a8e5efc.receipt.json b/vision-fixhub/court-01/edc1c002b20c45e096bd42e1eb9ffdc6bda7c9e7bd2b9212267a61f24a8e5efc.receipt.json
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diff --git a/vision-fixhub/court-01/edd2155e878fd4decf768a514f3c18bd4838947f840a437f930af24658291abd.md b/vision-fixhub/court-01/edd2155e878fd4decf768a514f3c18bd4838947f840a437f930af24658291abd.md
new file mode 100644
index 0000000000000000000000000000000000000000..41632a5445f2ce270530c9819a3cc926ddefd1df
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+++ b/vision-fixhub/court-01/edd2155e878fd4decf768a514f3c18bd4838947f840a437f930af24658291abd.md
@@ -0,0 +1,132 @@
+Filing # 175016820 E-Filed 06/09/2023 03:10:27 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIRCUIT CIVIL DIVISION: AG
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+CA FLORIDA HOLDINGS LLC
+PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner
+VS.
+DAVE ARONBERG, as the State Attorney of Palm
+Beach County, Florida, and
+ABRUZZO, as the Clerk of the Circuit Court
+and Comptroller of Palm Beach County, Florida,
+Defendant/Respondents.
+COPY
+ORDER DIRECTING CLERK OF COURT TO DELIVER GRAND JURY MATERIALS
+FOR IN CAMERA INSPECTION
+THIS CAUSE came before the Court on a Mandate from the Fourth District Court of
+Appeal issued on May 26, 2023. Pursuant to the opinion dated May 10, 2023, this Court is directed
+to conduct an in-camera inspection of grand jury materials involving the late Jeffrey Epstein. This
+Court is to decide whether disclosure of the material sought in this case would further justice.
+The Court notes that Dave Aronberg, as the State Attorney of Palm Beach County,
+executed an affidavit stating that he does not have any control, custody, or possession of the
+testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand jury
+nor does the Office of the State Attorney for the Fifteenth Judicial Circuit. [DE # 39].
+However,
+Abruzzo, in his official capacity as the Clerk of the Circuit Court and
+Comptroller for Palm Beach County, is in possession of material sought as the custodian of the
+grand jury materials.
+Accordingly, it is hereby:
+1
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 06/09/2023 03:10:27 PM
+
+
+ORDERED that a representative of the Clerk of the Circuit Court and Comptroller shall
+provide and deliver all materials and documents, exhibits, testimony transcripts, audio and visual
+materials, and all other items presented to the grand jury in proceedings instituted by the Office of
+the State Attorney for the 15'* Judicial Circuit in and for Palm Beach County related to Jeffrey
+Epstein. The Clerk of the Circuit Court and Comptroller shall contemporaneously provide a list
+specifying the chain-of-custody of the materials to the Court.
+The items shall be hand delivered only to Judge Delgado while in his chambers on June
+26, 2023 at 10:00 a.m. The Court will secure the materials until it starts the process for an incamera inspection.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida.
+Copies To:
+CER
+5020194024681XXXMB, 8609203 IRCUIT
+Luis Delgado, Circuit Judge
+502019CA014681XXXXMB 06/09/2023
+Luis Delgado
+Circuit Judge
+Name
+Address
+Email
+n/a
+P.O. BOX 229 WEST clerk_e-service@mypalmbeachclerk.com,
+COLLIN D.JACKSON PALM BEACH, FL
+eservice@mypalmbeachclerk.com,
+33401
+cdjackson@mypalmbeachclerk.com
+CYNTHIA M
+GUERRA
+Clerk_e-service@mypalmbeachclerk.com
+DOUGLAS A.
+WYLER
+n/a
+961687 GATEWAY
+BLVD SUITE 201-1
+FERNANDINA
+BEACH, FL 32034
+doug@jswflorida.com,
+doug.wyler@comcast.net
+2
+
+
+Name
+JESSICA NEER
+MCDONALD
+Address
+Email
+POST OFFICE BOX CLERK_E-
+229 WEST PALM
+SERVICE@MYPALMBEACHCLERK.COM,
+BEACH, FL 33401
+jnmedonald@mypalmbeachclerk.com
+JOHN SCAROLA
+n/a
+_scarolateam@searcylaw.com,
+mmccann@searcylaw.com
+777 S FLAGLER DR
+LAUREN R.
+WHETSTONE
+STE 300 E WEST
+WHETSTONEL@GTLAW.COM,
+PALM BEACH, FL
+flservice@gtlaw.com,
+33401
+sandra.famadas@gtlaw.com
+MARK F BIDEAU
+n/a
+bideaum@gtlaw.com, thomasd@gtlaw.com,
+FLService@gtlaw.com
+MARK F. BIDEAU
+n/a
+bideaum@gtlaw.com,thomasd@gtlaw.com,
+FLService@gtlaw.com
+54 STATE STREET
+MICHAEL GRYGIEL 6TH FLOOR
+ALBANY, NY 12207
+GRYGIELM@GTLAW.COM
+MICHAEL J.
+n/a
+GRYGIEL
+NINA D. BOYAJIAN n/a
+grygielm@gtlaw.com
+boyajiann@gtlaw.com, riveraal@gtlaw.com
+1840 CENTURY
+NINA D. BOYAJIAN
+PARK EAST SUITE
+1900 LOS ANGELES,
+CA 90067
+5100 TOWN CEŃTER
+STEPHEN A.
+CIR SUITE 400
+MENDELSOHN, ESQ
+mendelsohns@gtlaw.com,
+BOCA RATON, FL
+flservice@gtlaw.com
+33486
+NOT
+3
diff --git a/vision-fixhub/court-01/edd2155e878fd4decf768a514f3c18bd4838947f840a437f930af24658291abd.receipt.json b/vision-fixhub/court-01/edd2155e878fd4decf768a514f3c18bd4838947f840a437f930af24658291abd.receipt.json
new file mode 100644
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+}
diff --git a/vision-fixhub/court-01/ede6dbc6259c895366c9e719c6412c96ad9a16625a8f48b534dfdb692b7701a6.md b/vision-fixhub/court-01/ede6dbc6259c895366c9e719c6412c96ad9a16625a8f48b534dfdb692b7701a6.md
new file mode 100644
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@@ -0,0 +1,839 @@
+Entered on FLSD Docket 09/08/2009 Page 1 of
+10
+'ASE NO
+# ::
+502006CF014171AXXXMB
+ST OF FL VS
+GRAND THEFT FROM A DWELLING
+R213
+7*4:35
+2005F0C:4527 TYPE SB
+3. 000
+1/31/07
+ASA
+bickwith
+DC EC
+avarga
+/Do
+Crt. Rep.
+Beltrax
+Deft-
+Pry: / Not Pres.
+Def. Co.
+A Stine
+/ PD
+/ Not Pres.
+Before the Court for:
+• Granted J Denied
+With / Without Prejudice
+• Withdrawn • Court Reserves Ruling
+• Written Order to Follow
+Warrant O Ordered • Recalled • Bond Sgt at S
+• Bond Forf
+→ Serbelow
+•Also Covers OSpCond
+DOR: Disch/Revoked/Reinstated
+ArBond
+croked
+ASOR/Disch/Revoked/Reinstated
+J Bond Fort Vacated 3 Previous Bond Reinstated, if Bondsman agrees
+• State failedi to file charges (
+• Released O.R. / S.O.R
+• Defi
+Indigent
+• PD Appt
+• Hrg only
+PD Pres
+• Court Appts
+Evaluation for: • Drug Farm
+O DOC Non-Secure Bed by
+• Pre-Plea
+• PSI ordered by/within
+days
+• w/input from DJJ / Staffing
+• Referred to: PTI / SAAP/ PADD
+• Case placed on the absentee docket
+DEFT ENTERED A PLEA 1 2
+] NOT GUILTY
+• NO CONTEST
+• BEST INTEREST O TO THE COURT
+Lesser Cis
+Lesser Charge
+Sw & Test
+Ady of Ris
+TO Waived PSI
+Lesser Cts
+Lesser Charge
+• ADJ GUILTY as Charged as to Cts
+Lesser Cis
+FOUND GUILTY as Charged as to Cts
+Lesser Cts
+_ ADJ W/HELD as to Cts
+FOUND AND ADUATED DELINQUENT a Ca
+• SENT W/HELD as to Cts
+•Dispo Orderto follow/Filed
+| FOUND & ADJ NOT GUILTY as to Cts ..
+• Dismiss
+• Nolle Prosse Cts
+Prob / Comm Control: O Revoked O Reinstated
+• Modified • Term. Successfully / Unsuccessfully
+• Stip/Found: (violent) Habitual Off. 775.084
+• Stip/Found: Sexual Offender / Sexual Predator
+SENTENCE:
+PBCJ:
+Cts:
+• Stip/Found: P.R.R.
+/ DOC:
+PBCJ:..
+Cis:
+/ DOC:
+Cts:
+Cts:
+C7 W/Credit for
+Days / Mos. / Yrs.
+• Deft Remanded OJ Deft to remain on same rel, status pending sent.
+Conc / Consee / Co-Term w/cases / cts:
+] Execution of Sentence Stayed J Sentence Suspended O Time served as to Cis
+Youthful Off • Habitual Off • Min / Mand:
+as to Cts
+ABOVE SENTENCE TO BE FOLLOWED By: Probation Drug/Sex OffProb Comm. Control O1 JilSee Pg.?
+DRIVERS LICENSE TO BE SUSPENDED / REVOKED FOR
+YEARS AS A RESULT OF THIS PLEA.
+deft. mother present
+Del sin
+Def Co
+Proh
+7 Jail 7 DJ 7 GAL
+1 County Courthouse
+205 N. Dixie. West Palm Beach
+Se1 / Remains Set / Reset
+Set / Remains Set / Reset
+7 ASA
+Notified by mail by:
+J Couriroom. Criminal Justice Bldg
+38844 State Road 80. Belle Glad
+Div
+Div
+Rm
+Rm
+at
+J Bondsman
+AM/PM
+AM/PM
+/
+SCH LE05'
+
+
+Entered on FLSD Docket 09/08/2009 Page 2 of
+DATE: 1/31/07
+Page 2
+CASENO. OCF014|71 AXX
+NAME!
+TERM OF (Prob) Sex Off / Drug Off Prob / C.C. I / C.C. II: -
+_mos yrs)as to Cis.
+conc bach ofher
+(ist 9 mas. to be seved on CC II)
+• Probation transferred to:
+SPECIAL CONITIONS:
+legenning tiday
+• Complete Originally Ordered Conditions
+• Curfew: _
+-p.m., with the following exception:
+Deft. to report to Prob. Dept. immediately upon release
+Deft. not to have in care, custody, or control any unlawful or illegal material, subst., device, or object.
+Deft. to immediately notify Prob. Officer if place of residence or job changes.
+Restitution CRO filed
+Subject to all ordinary and special conditions of Probation
+9 Substance Abuse Eval. ) Psycholgical Eval. / Psychosexual Eval. within/ ty_ 30daya
+and deft. to successfully complete recommended treatment
+Random Drug/Alcohol Testing
+X At Deft's Expense
+• Costs Waived
+No Consumption/Possession of Alcohol or Drugs or Intoxicants without a Prescription.
+Attend
+AA and/or NA Meetings per Week.
+Deft. not to frequent any place of business whose primary purpose is the sale of alcohol.
+Complete
+Hrs. of Community Service to be done at the rate of .
+_Hrs. per Wk / Mo. (Min.)
+License Revoked / Suspended for
+_ mos / yrs
+Attenc-and successfully complete DUl school and 1 session of Victim Impact Panel
+Vo Contac) / No Violent Contact / No Direct or Indirect contact w/Viçtim(s) or others listed
+i victim or
+uctims temel
+No Contact w/Minor Children w/o Adult Supervision aware of this casel and the disposition.
+Cost of Supervision: $
+per month
+• Waived by Court.
+Enter and Successfully Complete DOC Non-Secure Bed Program and Any Recommended Aftercare.
+Hold in Custody, release only to DOC Non-Secure Bed Program Officer.
+Enter and Successfully Complete PBSO Long / Short Track Drug Farm and Any Rec. Aftercare.
+Forfeit Weapon / Money seized at the time of arrest to:
+Enter and Complete:
+• Anger Management Program
+C
+• Theft Abatement Program: -
+• Defendant may apply for Early Termination after
+• Serve
+days / months in PBCJ, with credit for
+Batterers Intervention Program
+Other:
+-, provided all conds, are satisfied.
+days / months.
+A Youthzul Oflender Probation
+A d DNA samples
+de restitution $350 to be paid w/in 30 dayp to victim
+0
+FORM 373 rev 3/02
+
+
+| Document 291-14 Entered on FLSD Docket 09/08/2009 Page 3 of
+10
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT,
+CRIMINAL DIVISION, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO:
+06-1411CFAMB
+STATE OF FLORIDA,
+VS.
+Defendani.
+DO NOT WRITE IN THIS AREA
+ORDER FOR RESTITUTION
+IN ADDITION TO ANY OTHER PUNISHMENT imposed by the Court in this case,
+RESTITUTION IS ORDERED. It is hereby
+Shawn Living st 936
+of birth
+9-30-1990
+_, social security number
+the sum of
+$ 350.00 Said sum (see section 775.089(3)(al), (b) (C)):
+Yuis a condition of probation/community control, and is to be paid in.
+designate are sedate tell to be paid within
+of $.
+_ and a final installment of $
+_ on the ..
+_ day of each month, to
+installments 30 day
+commence on
+_, 20.
+1 ] is to be paid before
+- 20
+[ ] is to be paid immediately, hence, FOR WHICH LET EXECUTION ISSUE.
+Complete satisfaction of this Order is a condition of any probation, community control or parole
+of the Defendant. (See Section 775.089(4))
+This Order for Restitution may be enforced by the State, or a victim named in this Order
+to receive the restitution, in the same manner as a judgment in a civil action. (See Section
+775.089(5))
+DONE AND ORDERED at West Palm Beach, Florida, this 315*
+. day of
+_, 200_k
+BLUE: Victim
+YELLOW: Probation
+GOLD: Defendant
+: State
+Defense
+FILED
+Circui Criminal Department
+JA:: 3 1 2üU/
+SHARON R. BOCK
+lerk & Comptrolle
+'alm Beach Coun
+_..
+---
+23
+Form 27
+
+
+Entered on FLSD Docket 09/08/2009 Page 4 of
+10
+STATE OF FLORIDA
+I. DEFENDANT:
+2. DEFENDANT:
+3. DEFENDANT:
+4. DEFENDANT:
+5. DEFENDANT:
+6. DEFENDANT:
+7. DEFENDANT:
+8. DEFENDANT:
+9. DEFENDANT:
+I0.DEFENDANT:
+IN THE
+COURT
+AL DIVISION OF THE CORONE
+FIFTEENTH JUDICIAL CIRCUIT.
+IN AND FOR PALM BEACH COUNTY. FLORIDA
+CASE NUMBERS 50 4/F01411AKXM
+PLEA IN THE CIRCUIT COURT
+I am the defendant in the above-mentioned matters), and I am represented by the attorney indicated below. I
+understand I have the right to be represented by an attomey at all stages of the proceeding until the case is terming i
+and if I cannot afford an attorney, one will be appointed free of charge.
+I understand I have the right to a spedy and public rial either by jury or by court. Thereby waive and give ughis
+I understand I have the righe to be confronted by the witnesses agains me and to cross examine them by myA f
+through my attorney. I hereby give up these rights.
+I understand have the righe lo testify on my own behalf, but 1 canoe be compelled to be a witness agains, VA T
+and may remain silent if I so choose. I hereby give up these rights.
+I understand I have the right to call witnesses to testify in my behalf and to invoke the compulsory process of the
+Court to subpoena those witnesses. I hereby give up these rights.
+NAI
+I understand s have the right to appeal all matters relating to the charges) and, unless 2 plea Guilty or No CV fi
+specifically reserving my right to appeal, I will give up such right of appeal.
+I understand that if I am not a United States Citizen, my plea may subject me to deportation pursuant to the laws and
+regulations goveming the tinited Stutes Immigration and Naturalization Service; and, this Court has no junis% A l
+(authority) in such matters.
+I have not received any promises from anyone, including my attorney, concerning eligibility for any form of carly
+release authorized by law and further no promises have been made to me as to the actual amount of time that I will
+serve us r the seen ce to even ted, friers understand that this plea may be used to enhance future it A
+penalties in any court system, even if adjudication of guilt is withheld.
+I offer my plea freely and voluntarily and of my own accord, with full understanding of all matters set for 14t
+pleadings and this waiver.
+I have personally placed my initials in each bracket above, and I undersiand each and every one of the rights outlined
+above. I hereby waive and give up each of them in order to enter my plea to the within charge(s). I understand that
+even though the Court may approve the agreement of sentence, the Court is not bound by the agreement, the Court
+may withdraw its approval at any time before pronouncing judgment, in which case I shall be able to withdraw my
+plea should I desire to do so.
+II. DEFENDANT:
+Choose one:
+If applicable, I choose a program which is or may he spiritually based.
+If applicable, 1 choose a program which is NOT spiritually based.
+If applicable, I have no preference if the program is or may be spiritually based
+FILED
+Circuit Criminal Departmen 34 - 07
+DEGENDANT
+JAN 3 1 2007
+DATE
+DEFENDANT'S ATTORNEY ONLY:
+SHARON R. BOCK
+Cierk. & Comptroller
+I am attorney of record. I have explained each of the above rigalor defehd noanathave explored the facts with him/her and studied his/her
+ATTORNEY
+FOR THE DEFENDANT
+Original - Clerk
+- State Attorney
+Form Circuit 1 (rev 8/2000)
+Page 1 of
+Yellow - Defense Attorney
+3 / JIn07
+DATE
+Pink - Defendant Goldenrod - Probation
+BCH FEB 0 5 2007
+Form 002
+
+
+Case 9:08-cV-80119-KAM Document 291-14
+Entered on FLSD Docket 09/08/2009 Page 5 of
+10
+4050
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+EFFECTIVE JULY 1, 2005
+JUDICIAL CIRCUIT, CRIMINAL DIVISION,
+IN AND FOR PALM BEACH COUNTY, FLORIDA.
+CASEND: OteCF01ATT AMB O6CF014I7/AXX
+STATE OF FLORIDA
+VS.
+Defendant:
+Social Security No.:
+Date of Birth:
+RECORDER'S SPACE
+ORDER ASSESSING ADDITIONAL, CHARGES, COSTS AND FINES AND ENTERING JUDGEMENT (IF INDICATED)
+the Defendant is hereby ordered so Pay and a judgement is hereby entered on behalf of Pairs Beach Courty, Palm Beach County Administrative Complex, Palm Beach Cousty, Florida 33401 and d
+tate of Flovida, Florida Departreet of Financial Services, Talishasso, Florida 32399 in the following suma as indicate
+INITIAL
+LE WAIVED
+3.
+Total of fines sssessed in sentence.
+Plaeg
+(Crimes Compasties Trust Fuad) pursutat to Sectica 938.04, Florida States (statutorily mandated 5% surcharge/cost on any
+fine entered la line 1).
+(Crime Stoppers Trast Fund) 520.00 punuent to Sectien 938.06(1), Flerida States (statutorily mandated cost to be added If any
+fine imposed).
+4.
+6.
+7.
+50.09
+1.00
+50.00
+2.00
+9.
+I0.
+200,00
+65.00
+3.00
+11.
+12.
+13.
+.00
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Mandatary Crate
+(Coenty Crime Prevention Fead) pursuast to Section 775.083(2). Florida Statutes (rataterily mandsted). Strike out if not a negotiated sentlement and
+not imposed by the Court.
+(Additional Court Cost Clearing Trust Fund) pursuant to section 938.01(i), Floride Statutes (atatutorily mandated).
+(Crimes Compeasation Trast Fund) pursuant to Section 938.03(I), Florida Statutes (statutorily mandated).
+(Criminal Justice Edacation by Municipalites and Costles) pursuant to Section 938.15, Florida Statutes to be paid to:
+Palra Beach Cousty, Florids. (sututorily mandated where locally authorized).
+he City/Town/Village of.
+(Addital Coot Cort) persent to Sectio 938.0(1), Florida Sauce (riu only randy nandited where localy echories)
+(Additional Coort Costs far local requiresents and other Casaty fuaded programs) parrunt to Sectica 939.185(1X(a), Florida Statutes (statutorily
+mandated where locally authorized).
+(Teen Court) pursuent to Sectica 938.19(2), Florida Statutes (atstuterily mandsted where locally autherized).
+Discretionary or Specifie Offense/Regaired Casts
+(Publie Defesder Application Fee) purruant to Sections 27.52(2X(a) and 938.29, Florida Statutes (a $40.00 foo shall be imposed if not previously
+collected of waived). Strike out if prevlowly paid or represested by private counsel.
+(Publie Defender's Fees and Coats) pursusat to Sectico 938.29, Flerida Statutes and Fla. R. Crim. P. 3.720(d)1) and Local Administrative Order.
+oat if represented by private counsel.
+(Minimum foe of $150.00 is statutorily mandated following notice of imposition and right to contest amount, additional ssout is discretionary). Strike
+(Additfonal fees and costs of publicly appointed coussil) purrusnt to Section 938.29, Florida Statutes and Fla. R. Crim. P. 3.720(dXI) (notice of
+imposition and right to contest amount required).
+(County Alesbol and Ober Drog Abuse Trest Fuad) pursuant to Sections 938.21 and 938.23, Florida Statutes (may be imposed for any criminal
+violation of s.316.193, s.856.011, 3.856.015, or Chapters 562, 567, 568, or 893, but may mot exceed the amount of any fine imposed for the offense)
+(DUI Court Cost) 5135.00 pursuast to Section 938.07, Flerida Statutes for any violation of Sections 316.193 or 327.35 (statutorily mandated).
+(Chlid Advocacy Cester) $101.00 pursuant to Section 938.10, Florida Statutes for any violatica of Sections 784.085, 796.03, 800.04, 847.0145.
+985.4045, or Chapters 787, 794, or 827, Florida Statutes (statutorily mandated).
+(Domestie Violence Surcharge) $201.00 pursuant to Section 938.08, Florida Statutes for any violatioo of Sections 784.011, 784.021, 784.03, 784.041,
+784.045, 784.048, 784.07, 784.08, 784.081, 784.082, 784.083, 784.08S, 794.011, and any offense of Domestic Violence as described in Section 741.28,
+Florida Statues (statutorily mandated).
+(Rape Crisla Center Trust Fund) $151.00 pursuast to Sectioo 938.085, Florida Statutes for any violation of Sections 784.011, 784.021, 784 03,
+784.041, 784.045, 784.048, 784.07, 784.08, 784.081, 784.082, 784.083, 784.0B5, or 794.011 (statutorlly mandated).
+(Operating Trust Fund of the FDLE) 5100.00 pursuant to Section 938.25, Florida Statutes (may be imposed for any criminal violatica of's 893.13 if
+entitled to costs of prosecution requests and documents specific costs).
+21.
+Total:
+673.08 othere-
+"ayment of charges, costs,
+and fines are:
+a condition of probation
+JAN 3 1 2007
+SHARON R. BOCK
+to be paid IN FULL. TODAY Defeat to reced indisely to the Clerk and Comptroller's Office to pay the fall arnowat die Clerk & Comptroller
+to be paid by he defendan performing: (circle ose) community service or AVNA meetings, at a rate ofS...___/per hour/meeting, due within —
+lieu of schul payment.
+AILURE TO PAY YOUR FINES AND COURT COSTS WILL RESULT IN YOUR DRIVER'S LICENSE BEING SUSPENDED AND/OR A WARRANT BEING ISSUED FOR YOUR ARREST
+ONE AND ORE
+# Bust-o
+of
+Ten 308 Palm Beach Coury, Forida
+GOLD: State Antoney
+INK: Defense Counsel
+LOW: Probation
+Defendant
+BLUE: Administrative Office of the Court
+BCH FER 0520 men 8er 62003 22
+Form 004-B
+
+
+| Document 291-14
+Entered on FLSD Docket 09/08/2009 Page 6 of
+OGCF 014I7IHXY
+PLEA IN THE CIRCUIT COURT
+THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT
+Name:
+Plea: Guilty X Bumy/sest Interest
+_ Nolo Contendere
+Case No.
+Charge
+06CF01417
+bulary of teelug
+AMB
+sT tom baesus
+Count
+Lesser
+Degree
+NO
+207f1
+2
+NO
+30 ter
+FILED
+Circuit CriminaLDepartment
+JAN 3 1 2007
+SHARON R. BOCK
+State to Nolle Prosse the following at sentencing: -
+clerk & Comptrolle
+alm Beach County
+PSI: Waived/Not Required X. Required/Requested
+ADJUDICATION: Adjudicate [ ]
+Withhold IX I Court's Discretion|!
+f the Defendant is convicted of possession, sale, traficking or conspiracy 10 pat
+155, sell or traffic in any controlled substance, the Court direcis the Department
+of Motor Vehicles and Highway Safety to revoke the Defendant's driver's licofise for Iwo (2) years. If the Defendant is convicted of grand theit of a motor vehicte:
+theft of motor vehicle parts; or, any felony in the commission of which a motor vehicle was used, the Court directs the Department of Motor Vehicles and Highway
+Safety to revoke the Defendant's driver's license as mandated by law. The Clerk is directed to make the proper notifications.
+SENTENCE:
+_ Fine $
+Court Costs §
+Drug Trust Fund
+$
+Cost of Prosecution
+Public Defender Fees/Costs
+Incarceration:
+Days
+Months
+with credit for time served; which is.
+days.
+PROBATION:
+Ments/ Years - Drug Offender if checked
+ALL CONDITIONS OF PROBATION MUST BE SUCCESSFULL)
+COMPLETED NO LESS THAN 30 DAYS BEFORE
+PROBATION IS SCHEDULED TO TERMINATE UNLESS STATED BELOW.
+STANDARD ON DAON HAVE BEEN EXPLANED BY DEFENSE use toshausion
+SPECIAL CONDITIONS OF PROBATION:
+Restitution as per the accompanying order.
+gourt Costs: S
+heck it ordered
+Drug Trust Eund:
+Cost of Prosecution $
+Public Defender Fees/Costs §
+Substance abuse eval alien and succestl completion of recommended treatment I (check ir
+ordered) (enroll within 30 days) If in custody, re ease only to
+Random Drug Testing at Defendant's expense X (check if ordered)
+hours of community service at a rate of no less than
+Incarceration:
+_ hours per mont DWIt
+with credit for time served; which is
+ope
+OTHER COMMENTS OR CONDITIONS:
+morons CCT
+Restitution #350 to be fail in 30 days
+LU(V
+SENTENCING IS DEFERRED UNTIL
+IN COURT ROOM
+THE DEFENDANT UNDERSTANDS IF S/HE FAILS TO APPEAR OR IS ARRESTED ON NEW CHARGES, A CAPIAS WILL
+BE ISSUED-AND THE COURT-WILL IMPOSE ANY LAWFUL SENTEN
+Assistant State Attorne
+631-0
+Date of Plea
+Attorney for #*
+he matandan.
+Defendan
+BCH FFR 05 7007
+2°
+Form 005
+
+
+Entered on FLSD Docket 09/08/2009 Page 7 of
+4050
+IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA,
+IN AND FOR PALM BEACH COUNTY
+CASENO. OUCE 01417/AMP
+OBTS NUMBER
+STATE OF FLORIDA
+DIV.
+R
+CFN 20070062199
+OR BK 21388 PG 1325
+RECORDED 82/87/2807 11:42:47
+Pala Beach County, Florida
+Sharon R. Bock, CLERK & CONPTROLLER
+Pg 1325; (1pg)
+V:
+COMMUNITY
+CONTROL
+VIOLATOR
+PROBATION
+VIOLATOR
+DEFENDANT
+DATE OF BIRTH
+RACE
+GENDER
+SOCIAL SECURITY NUMBER
+JUDGMENT
+The above Defendant, being personally before this Court represented by
+a stine
+11
+Having been tried and found
+Xi
+Having entered a plea of guilty
+guilty of the following crime(s):
+to the following crime(s):
+(attorney)
+Having entered a plea of nolo
+contendere to the following
+crime(s):
+COUNT
+CRIME
+OFFENSE STATUTE NUMBER(S)
+DEGREE
+(
+2
+Burglary of adwelling
+Grand theft from a
+810•02/183
+812.014/1 8(2(d)
+2FEL
+3FEL
+dwelling
+and no cause having been shown why the Defendant should not be adjudicated guilty, IT IS ORDERED THAT the Defendant is
+hereby ADJUDICATED GUILTY of the above crime(s).
+and having been convicted or found guilty of, or having entered a plea of nolo contendere or guilty, regardless of adjudication,
+to attempts or offenses relating to sexual battery (ch. 794), lewd and lascivious conduct (ch. 800), or murder (s. 78204), aggravated
+battery (s, 784.045), burglary (s. 810.02), carjacking (s. 812.133), or home invasion robbery (s. 812.135), or any other offense
+specified in section 943.325, the defendant shall be required to submit blood specimens.
+XI
+and gourd cause being shown: IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHEL FILED
+SENTENCE
+The Court hereby stays and withholds imposition of sentence as to counts CirQyil GriminAL Renartment
+• STAYED
+X Probation and/or | | Community Control under the supervision of the Dept. of Corrections (conditions of
+JAN 3 1 2007
+probation set forth in separate order).
+SENTENCE
+DEFERRED
+| 1 The Court hereby defers imposition of sentence until
+SHARON R. BOCK
+Clerk & Comptroller
+The Defendant in Open Court was adrised of his right to appeal from the Judgment by filing notice FalGeech Coüntyof Court
+within thirty days following the dote sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also
+surised of his right to thy ssistance of counsel in taking said appeal at the expense of the Sitate upon showing of indigony:
+AND ORDER in open Court at Palm teach County: Horida this 38 day of Junuary 2m 7.
+Form 009A
+7
+
+
+Entered on FLSD Docket 09/08/2009 Page 8 of
+10
+IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICAL CIRCUIT OF FLORIDA,
+IN AND FOR PALM BEACH COUNTY
+CASE NO. 502006CF014171AXXXMB DIV.R
+OBTS NUMBER: 5003197309
+* STATE OF FLORIDA
+[ 1 COMMUNITY
+CONTROL
+VIOLATOR
+DEFENDANT
+I ]PROBATION
+VIOLATION
+W
+H
+DATE OF BIRTH
+I
+RACE
+E
+The fingerprints below are those of said Defendant taken by Deputy Sheriff
+1. R. THUMB
+2. R. INDEX
+3. R. MIDDLE
+F
+GENDER
+4. R. RING
+SOCIAL SECURITY NUMBER
+9. Corse Ruber 14457
+Deputy Steriff
+Sato Beach County, IS
+5. R. LITTLE
+6. L. THUMB
+7. L. INDEX
+B. L. MIDDLE
+9. L. RING
+10. L. LITTLE
+CRC_INT_FPRINT
+FILED
+Circuit Criminal Department
+JAN 3 1 2007
+SHARON R. BOCK
+Clerk & Comptroller
+Palm Beach County
+
+
+Document 291-14
+Entered on FLSD Docket 09/08/2009 Page 9 of
+10
+1.
+ATTOF SENTENC
+131/8'
+5. NAME (LAST, FIRST, MI.I.)
+O6CF014I7IAXX
+RULE 3.992(a) CRIMINAL PUNISHMENT CODE SCORESHEET
+2. PREPARER'S NAME •oC SAO
+3. COUNTY
+4. SENTENCING JUDGE
+PB
+LABARGA
+6. DOB
+9.3.90
+DC #
+8. RACE
+•BXW MOTHER
+9. GENDER
+/ 12.
+PLEA DE
+11. PRIMARY DOCKET #
+TRIAL O
+OQCFO14ITAMB
+-
+PRIMARY OFFENSE: If Qualifier. please check —
+_R (A=Attempt, S=Solicitation, C=Conspiracy, R«Reclassificaton)
+FELONY
+DESCRIPTION
+DEGREE
+3)
+2
+OFFENSE
+LEVEL
+810.02(0
+Leval - Points: 1=4, 2=10, 3=16, 4=22, 5-28, 6=36, 7=58, 8=74, 9-92, 104116) /
+Burglary y Darling
+Prior capital falony triples Primary Offense points
+POINTS
+, Sle
+II. ADDITIONAL OFFENSE(S): Supplemental page attached O
+DOCKET#
+FEL/MM
+F.S.#
+DEGREE
+OFFENSE
+LEVEL
+QUALIFY COUNTS
+A5 CR
+0000
+1
+POINTS
+TOTAL
+× 12=1.2
+swellig
+0000
+x
+=
+Description
+0000
+- ×
+=
+Description
+(Level - Points: M=0.2, 1=0.7, 2-1.2, 3=2.4, 4-3.6, 5=5.4, 8u18, 7-28, 8=37, 9=46, 10-58)
+Prior capital falony triples Additional Offense points L
+III.
+VICTIM INJURY:
+Number
+Total
+Number Total
+2ª Degree Murder
+Death
+Severe
+Moderate
+240 X
+120 X
+40 X
+18 X
+Slight
+Sex Penetration
+Sex Contact
+4X
+80 X
+40 X
+Supplemental page points,
+FILED 1.2
+Circuit Criminal Department
+JAN 3 1 2007
+SHARON R. BOCK
+Clerk & Comptroller
+Palm Beach County
+Ill.
+IV. PRIOR RECORD: Supplemental page attached L
+FEL/MM
+DEGREE
+3F
+F.S.#
+OFFENSE
+790.115
+LEVEL
+QUALIFY DESCRIPTION
+NUMBER
+POINTS
+A SCR
+TOTAY
+0000
+possweapunschal l
+- × 24.2/
+0000
+0000
+0000
+0000
+0000
+{Level - Points: M=0.2, 1=0.5. 2=0.8. 3=1.6, 4=2.4, 5=3.6. 6-9, 7=14, 8=19, 9-23, 10=29)
+Supplamental page points.
+~. 2.4
+DISTRIBUTION:
+/ Original / Clark
+/DC Data
+Canary / State Attornay
+Pink / Defonsa Attornay
+Geldenrod / DC Offender Fllo
+Page 1 Subtotal:
+BCA FE3 05 6*17
+Effective Date: For offenses committed under the Criminal Punishment Code effective on or after October 1, 1998.
+
+
+Entered on FLSD Docket 09/08/2009 Page 10 of
+O6CF0/4I 7IAX gago 1 Subtotal.
+V. Legal Status violation = 4 Points
+Vl. Community Sanction violation before the court for sentencing
+6 points x each successive violation OR
+New felony conviction = 12 points x each successive violation
+VIl. Firearm/Semi-Automatic or Machine Gun = 18 or 25 Points
+VIll. Prior Serious Felony = 30 Points
+IX.
+Enhancements (only if the primary offense qualifies for enhancement)
+Lew Enforcament Prolaction
+Drug TraMoking
+Grand That Actor Veracia
+-1.5_×20_x 2.5
+_x 1.5
+-* 1.5
+V.
+VI.
+VIl.
+VIII.
+Subtotal Sentence Points
+Street Dang
+-X 1.5
+-* 1.5
+Enhanced Subtotal Sentence Points IX.
+TOTAL SENTENCE POINTS
+59, 60
+SENTENCE COMPUTATION
+If total sentence points are loss than or equal to 44, the lowest permissible sentence is any Dan-state prison sanction.
+If total sentence points are greater than 44:
+59.60
+tatal sentence points
+minus 28 =
+31.l
+x.75 =
+$ 23.7
+lowest permissible prison
+sentence In months
+The maximum sentence is up to the statutory maximum for the primary and any additional offenses as provided in s. 775.082,
+F.S., unless the lowest permissible sentence under the code, exceeds the statutory maximum. Such sentences may be impose
+concurrently or consecutively. If total sentence points are greater than or equal to 363, a life sentence may be imposed
+20 years
+maximum sentence
+in years
+TOTAL SENTENCE IMPOSED
+Years
+Months
+Days
+• State Prison
+O Life
+• County Jail
+• Time Served
+• Community Control
+• Probation
+2
+Please check if sentenced as
+reoffender, or a [ mandatory minimum applies.
+• habitual offender. habitual violent offender, violent career criminal, l prison releasee
+• Mitigated Departure /
+A Plea Bargain
+Other Reason
+CLASSiFiCO
+FUL OFFENDER
+JUDGE'S SIGNATURE
+11ol07
+L-87822 g
\ No newline at end of file
diff --git a/vision-fixhub/court-01/ede6dbc6259c895366c9e719c6412c96ad9a16625a8f48b534dfdb692b7701a6.receipt.json b/vision-fixhub/court-01/ede6dbc6259c895366c9e719c6412c96ad9a16625a8f48b534dfdb692b7701a6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f8e8fcffdfb3b6a99749ad366add14f16e306601
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+++ b/vision-fixhub/court-01/ede6dbc6259c895366c9e719c6412c96ad9a16625a8f48b534dfdb692b7701a6.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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diff --git a/vision-fixhub/court-01/edf1ee2bdca0bfdc499e0d53fa3a7f22b55cbe245fb605fd9c2755fc01eec683.md b/vision-fixhub/court-01/edf1ee2bdca0bfdc499e0d53fa3a7f22b55cbe245fb605fd9c2755fc01eec683.md
new file mode 100644
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+++ b/vision-fixhub/court-01/edf1ee2bdca0bfdc499e0d53fa3a7f22b55cbe245fb605fd9c2755fc01eec683.md
@@ -0,0 +1,459 @@
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+MARY DOE,
+Plaintiff,
+-V-
+DARREN K. INDYKE and RICHARD D. KAHN,
+as Executors of the Estate of Jeffrey E. Epstein,
+and
+Defendants.
+19 Civ. 10758 (PAE)
+OPINION & ORDER
+PAUL A. ENGELMAYER, District Judge:
+In this diversity action, plaintiff Mary Doe' brings tort claims under New York law
+against, inter alia, Darren K. Indyke and Richard D. Kahn, the executors of the estate of Jeffrey
+Epstein ("Indyke and Kahn" or "the executor defendants"). The executor defendants now move
+to dismiss Doe's claim against them for punitive damages, on the grounds that, as a matter of
+New York law, such damages are categorically unavailable in a personal injury action against the
+personal representative of an estate.? For the reasons that follow, the Court grants that motion.
+L.
+Background
+A.
+Doe's Complaint
+Doe's Complaint, filed on November 20, 2019, alleges a horrific course of sexual and
+psychological abuse at Epstein's hands during 2004 and 2005. Cmplt. 11l 1-15 (summary
+account); id. 11 38-106 (detailed account). It alleges that Doe came to the United States with her
+' Doe has been granted leave to proceed pseudonymously. Dkt. 21.
+" Doe also sues
+. who is alleged to have served as Epstein's scheduler and assistant.
+See Dkt. 1 (Complaint, or "Cmplt.") 1| 19. Doe's bid for punitive damages against |
+is not
+implicated by this motion.
+
+
+parents as a young refugee from a war-torn country, and was working in pursuit of a promising
+career as a model when, in 2004, at age 16, she met Epstein through another model. Id. 12.
+Epstein made clear to Doe how important and powerful he was and promised to help her with her
+modeling career and college admissions. Id. 9 3. Doe, in turn, "believed she could trust him"
+and "that he could change her life." Id. 1|4. Epstein, however, "used his power over Mary to
+sexually abuse her, viciously and repeatedly." Id. 9 5. Aided by defendant
+Epstein's scheduler and assistant, Epstein "would summon Mary to his Manhattan townhouse,
+order her to give him massages, and then subject her to sexual acts, the severity of which
+increased over time." Id.; see also id. 9| 19. The Complaint graphically chronicles Epstein's acts
+of sexual abuse in the townhouse, which included forcing Doe to perform oral sex on him and
+later raping her. Id. 11 7-9; 56-105.
+In late 2005, the Complaint alleges, Doe—as a result of an incident at the townhouse
+"suddenly saw the truth: she was not even a human being to Epstein, she was an object," and
+Epstein was treating her as a prostitute, "one of many girls he treated as sexual objects." Id.
+• 11. Doe had a breakdown, almost immediately thereafter left New York City, returned to her
+parents' home across the country, and never saw Epstein again. Id. 9| 12. Epstein's abuse caused
+Doe to abandon her modeling career and left her humiliated, angry, and suicidal, with debilitating
+panic attacks and "dramatic psychological scars." Id. 911 13-14. Epstein's arrest in July 2019
+gave Doe "brief|] hope that he might finally face consequences," but his death in August 2019 at
+a federal jail in Manhattan "left Mary with the desolate sense that he has evaded justice yet
+again." Id. 9 15.
+In this action, Doe brings claims, under New York law, of battery, id. 11 108-13, assault,
+id. "il 114-19, and the intentional infliction of emotional distress, id. 99| 120-27, against Indyke
+2
+
+
+and Kahn, solely in their capacities as executors of Epstein's estate, id. 1 18, and against |
+for her "integral role in operating Epstein's operation of sex trafficking Mary and other girls," id.
+1 19. As its basis for personal jurisdiction over the executors, it alleges that "Epstein was subject
+to personal jurisdiction at the time of his death," id. ° 22, "because the tortious acts giving rise to
+Plaintiff's claims took place in New York State," id. 1 23. The Complaint seeks, in addition to
+compensatory damages and attorneys' fees and costs, "punitive damages in an amount to be
+determined at trial." Id. p. 19.
+B. The Executors' Partial Motion to Dismiss
+On January 21, 2020, the executor defendants filed a partial motion to dismiss, Dkt. 17,
+and a supporting memorandum of law, Dkt. 18 ("Def. Mem."). It sought dismissal of the prayer
+for punitive damages on the ground that such damages cannot, as a matter of New York law, be
+sought against the personal representatives of an estate. On March 3, 2020, Doe filed a
+memorandum of law in opposition, Dkt. 28 ("Doe Opp'n"), and a supporting declaration by
+Daniel Mullkoff, Esq., Dkt. 29 ("Mullkoff Decl."), which attached Epstein's will. On March 20,
+2020, the executor defendants filed a reply. Dkt. 33 ("Def. Reply").
+II. Applicable Legal Standards Under Rule 12(b)(6)
+To survive a motion to dismiss under Rule 12(b)(6), a complaint must plead "enough
+facts to state a claim to relief that is plausible on its face." Bell Atl. Corp. v. Twombly,
+550 U.S. 544, 570 (2007). A claim will only have "facial plausibility when the plaintiff pleads
+factual content that allows the court to draw the reasonable inference that the defendant is liable
+for the misconduct alleged." Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). A complaint is
+properly dismissed where, as a matter of law, "the allegations in a complaint, however true,
+could not raise a claim of entitlement to relief." Twombly, 550 U.S. at 558. When resolving a
+motion to dismiss, the court must accept as true all well-pled factual allegations in the complaint
+3
+
+
+and draw all reasonable inferences in the plaintiff's favor. Steginsky v. Xcelera Inc.,
+741 F.3d 365, 368 (2d Cir. 2014). That tenet, however, "is inapplicable to legal conclusions."
+Iqbal, 556 U.S. at 678. Pleadings that offer only "labels and conclusions" or "a formulaic
+recitation of the elements of a cause of action will not do." Twombly, 550 U.S. at 555.
+I. Discussion
+In moving to dismiss Doe's prayer for punitive damages against them, the executor
+defendants argue that New York law applies to this personal injury action and categorically
+prohibits an award of punitive damages against the personal representatives of an estate.
+Specifically, they note, § 11-3.2(a)(1) of New York's Estates, Powers and Trusts Law ("EPTL")
+provides:
+No cause of action for injury to person or property is lost because of the death of
+the person liable for the injury. For any injury, an action may be brought or
+continued against the personal representative of the decedent, but punitive
+damages shall not be awarded nor penalties adjudged in any such action brought
+to recover damages for personal injury.
+EPTL § 11-3.2(a)(1) (emphasis added).
+Applying this statute, courts have held punitive damages unavailable in personal injury
+actions against executors or administrators of estates. These include federal courts determining
+the damages available for constitutional-tort claims under New York law, see, e.g., Graham v.
+, 224 F.R.D. 59, 63 (N.D.N.Y. 2004) (precluding, based on EPTL § 11-3.2(a)(1),
+punitive damages claims in § 1983 action against estate administrators, and noting that New
+York law is "very clear" on this point); Blissett v. Eisensmidt, 940 F. Supp. 449, 457 (N.D.N.Y. 1996)
+(overturning, based on EPTL § 11-3.2(a)(1), jury's punitive damages award in § 1983 case
+against estate, and noting "strong policy against the assessment of punitive damages against an
+estate on account of wrongful conduct of the decedent"), and state courts in personal injury
+actions governed by New York law, see, e.g.,
+v. Nathan, 352 N.Y.S.2d 464, 464
+4
+
+
+(Ist Dep't. 1974) (affirming dismissal of punitive damages claim because, under EPTL
+§ 11-3.2(a)(1), defendant's death precluded recovery of punitive damages from personal
+representatives of estate); cf. Flaum v. Birnbaum, 582 N.Y.S.2d 853, 857 (4th Dep't. 1992)
+(affirming denial of punitive damages in case against deceased executor; citing EPTL
+§ 11-3.2(a)(1) and the "strong policy against the assessment of punitive damages against an
+estate on account of the wrongful conduct of the decedent").
+The law of a majority of states is in accord with EPTL § 11-3.2(a)(1), as reflected in the
+Restatement (Second) of Torts. See Restatement (Second) of Torts § 908 cmt. a (1979) ("Punitive
+damages are not awarded against the representatives of a deceased tortfeasor|-]"); see also Doe
+Opp'n at 12 (acknowledging that "a majority of states do not permit punitive damages against
+estates"). This majority rule aligns with "[Jhe general rule under federal common law," that "an
+action survives the death of a party insofar as it is remedial[.] and not penal[.] in nature." See, e.g.,
+Official Comm. of Unsecured Creditors of Exeter Holdings, Ltd. v. Haltman, No. 13 Civ. 5475
+(JS) (AKT), 2017 WL 9485707, at *7 (E.D.N.Y. Aug. 3, 2017) (collecting cases), report and
+recommendation adopted, 2017 WL 3981299 (E.D.N.Y. Sept. 11, 2017).
+The justification commonly given for precluding punitive damage awards against estates
+is that punishment and deterrence-
+- the recognized bases for imposing punitive damages on a
+tortfeasor—are not advanced by imposing punitive damages on his or her estate. As the New
+Mexico Supreme Court explained in adopting the majority rule: "[P]unishment and deterrence
+are not accomplished by enabling recovery of punitive damages from the estate of deceased
+tortfeasors"; "[w]hen the tortfeasor cannot be punished for his culpable behavior, punitive
+damages no longer have the desired effect and, therefore, the victim loses the legal entitlement to
+5
+
+
+recover those damages." Jaramillo v. Providence Wash. Ins. Co., 871 P.2d 1343, 1351
+(N.M. 1994) (canvassing laws of other states).
+Doe does not dispute that EPTL § 11-3.2(a)(1) precludes punitive damages in a personal
+injury action under New York law. Instead, Doe makes three arguments: (1) that defendants'
+motion is premature, Doe Mem. at 4; (2) that defendants' motion is improperly styled as a
+motion to dismiss, id. at 3; and (3) that the law of the United States Virgin Islands ("USVI"), not
+New York law, applies, and permits punitive damages against an estate, id. at 4-13.
+Doe's first argument is quickly dispatched. Doe cites cases where courts have declined
+to resolve motions to dismiss aimed at prayers for relief, finding such motions premature. See id.
+at 4 (citations omitted). But a review of these cases reflects that the motions in those cases were
+not based on categorical preclusions of punitive damages. In contrast, where punitive damages
+have been unavailable as a matter of law, courts have not hesitated to dismiss prayers for such
+damages at the threshold. See, e.g., Murtha v. N.Y. State Gaming Comm'n, No. 17 Civ. 10040
+(NSR), 2019 WL 4450687, at *19 (S.D.N.Y. Sept. 17, 2019) (dismissing demand for punitive
+damages under the New York State Human Rights Law ("NYSHRL"*) because it "does not
+provide for punitive damages");
+v. N.Y.C. Dep't of Educ., No. 18 Civ. 6670 (AT),
+2019 WL 4039958, at *9 (S.D.N.Y. Aug. 27, 2019) (granting motion to dismiss demand for
+punitive damages under the Age Discrimination in Employment Act and the New York City
+Human Rights Law ("NYCHRL") where neither statute permitted a plaintiff to recover punitive
+damages); Talarico v. Port Auth. of N.Y. d N.J., 367 F. Supp. 3d 161, 172 (S.D.N.Y. 2019)
+(dismissing demand for punitive damages against Port Authority where "the Third Circuit and
+the overwhelming majority of district courts within this Circuit have held that punitive damages
+are not available against" that defendant (internal quotation marks and citation omitted)); Canete
+6
+
+
+v. Metro. Transp. Auth., No. 17 Civ. 3961 (PAE), 2018 WL 4538897, at *9
+(S.D.N.Y. Sept. 20, 2018) (dismissing demand for punitive damages where such relief was
+"precluded as a matter of law"); Roman Catholic Diocese of Rockville Ctr. v. Gen. Reins. Corp.,
+No. 16 Civ. 2063 (CM), 2016 WL 5793996, at *6 (S.D.N.Y. Sept. 23, 2016) ("In this case, the
+circumstances surrounding the denial of the insurance indemnification claim do not warrant the
+rare exception provided for punitive damages under a breach of contract claim. For this reason,
+the Court grants Defendant's motion to dismiss the punitive damages claim."); SJB ex rel. Berkhout
+v. N.Y.C. Dep't of Educ., No. 03 Civ. 6653 (NRB), 2004 WL 1586500, at *8 (S.D.N.Y. July
+14, 2004) (dismissing punitive damages claim because such damages are unavailable in § 1983
+actions against municipalities). Provided that New York law applies to this action, this case, too,
+involves a categorical preclusion of such damages, under EPTL § 11-3.2(a)(1), that can be
+adjudicated at the threshold.
+Doe's second argument is that the defendant-executors' challenge is improperly brought
+as a motion to dismiss. Doe Mem. at 3 & n.3. There is divided case authority on this point.
+Courts, including in the cases cited above, have granted motions to dismiss prayers for such
+relief. But others have declined to entertain such motions, stating that, "[bJecause punitive
+damages are a form of damages, not an independent cause of action, a motion to dismiss a prayer
+for relief in the form of punitive damages is 'procedurally premature.'" Farina v. Metro. Transp.
+Auth., 409 F. Supp. 3d 173, 220 (S.D.N.Y. 2019) (quoting Hunter v. Palisades Acquisition XVI,
+LLC, No. 16 Civ. 8779 (ER), 2017 WL 5513636, at *9 (S.D.N.Y. Nov. 16, 2017)); see also, e.g.,
+Wiederman v. Spark Energy, Inc., No. 19 Civ. 4564 (PGG), 2020 WL 1862319, at *9-10
+(S.D.N.Y. Apr. 14, 2020);
+v. City of New York, No. 18 Civ. 1937 (VSB), 2020 WL 1644009,
+at *17 (S.D.N.Y. Apr. 2, 2020); Range v. 535 Broadway Grp. LLC, No. 17 Civ. 423 (WHP),
+7
+
+
+2019 WL 4182966, at *7 n.4 (S.D.N.Y. Nov. 16, 2017); Okyere v. Palisades Collection, LLC,
+961 F. Supp. 2d 522, 536 (S.D.N.Y. 2013).
+The Court has no occasion to resolve this conceptual debate, because the executors'
+motion to dismiss under Rule 12(b)(6) alternatively can be treated as a motion to strike under
+Federal Rule of Civil Procedure 12(f). See C.
+& A.
+, 5C Federal Practice and
+Procedure § 1380 (3d ed.) (IT]he technical name given to a motion challenging a pleading is of
+little importance inasmuch as prejudice to the nonmoving party hardly can result from treating a
+motion that has been inaccurately denominated a motion to strike as a motion to dismiss the
+complaint."). And under Rule 12(f), on a motion or sua sponte, a court may strike from a
+pleading an "insufficient defense or any redundant, immaterial, impertinent, or scandalous
+matter." Fed. R. Civ. P. 12(f). Although motions to strike under Rule 12(f) are generally
+"disfavored and granted only if there is a strong reason to do so,"
+News, L.L.C. v. Am.
+Media, Inc., No. 09 Civ. 2227 (PAC), 2013 WL 1746062, at *3 (S.D.N.Y. Apr. 23, 2013)
+(internal quotation marks omitted) (citing Roe v. City of New York, 151 F. Supp. 2d 495, 510
+(S.D.N.Y. 2001)); see also Lipsky v. Commonwealth United Corp., 551 F.2d 887, 893 (2d
+Cir. 1976)), ample authority permits striking prayers for punitive damages where such relief is
+unavailable as a matter of law. See, e.g., In re Merrill
+Auction Rate Sec. Litig.,
+851 F. Supp. 2d 512, 544 (S.D.N.Y. 2012) (granting motion to strike sections of complaint
+asserting punitive damages, because pleadings did not meet high bar for punitive damages in
+non-fraud case of breach of fiduciary duty), aff'd sub nom. La. Pac. Corp. v. Merrill
+& Co.,
+571 F. App'x 8 (2d Cir. 2014); Cerveceria Modelo, S.A. de C.V. v. USPA Accessories LLC,
+No. 07 Civ. 7998 (HB), 2008 WL 1710910, at *5-9 (S.D.N.Y. Apr. 10, 2008) (granting motion
+to strike prayer for punitive damages for failure to allege level of high moral culpability
+8
+
+
+necessary to sustain punitive damages award in case involving fraud and deceit); Ladenburg
+Thalmann & Co. v. Imaging Diagnostic Sys., Inc., 176 F. Supp. 2d 199, 207 (S.D.N.Y. 2001)
+(granting motion to strike punitive damages because complaint did not allege, inter alia, egregious
+conduct sufficient to sustain such an award); Brady v. Port. Auth. of N.Y. d N.J., No. 93 Civ. 1679
+(NG) (CLP), 1998 WL 724061, at *2-3 (E.D.N.Y. Oct. 15, 1998) (granting motion to strike
+punitive damages claims on grounds that Port Authority was immune from such damages); Nash v.
+Coram Healthcare Corp., No. 96 Civ. 0298 (LMM), 1996 WL 363166, at *4 (S.D.N.Y. June 28, 1996)
+(granting motion to strike prayer for punitive damages because complaint did not allege facts
+sufficient to support such damages in breach of contract case).
+Here, there is practical wisdom in treating defendant's motion as one to strike, if doing so
+is necessary to enable the Court to resolve at the jump the viability of Doe's prayer for punitive
+damages. With numerous personal injury actions pending against the Epstein estate as a result of
+the recent enactment of the New York Child Victims Act, there is value in clarifying-for the
+parties and settlors—the damages available in actions where the law permits a sure answer on
+this point.
+Doe's final argument is that USVI, not New York, law governs whether punitive
+damages are available. Because this Court sits in New York, it applies a New York choice of
+law analysis to that question. See Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496
+(1941); Md. Cas. Co. v. Cont'l Cas. Co., 332 F.3d 145, 151 (2d Cir. 2003) ("A federal court
+sitting in diversity applies the choice-of-law rules of the forum state."). "Where, as here, the
+claims sound in tort, New York courts apply an 'interest analysis' to determine choice-of-law
+issues." Golden v. Wyeth, Inc., No. 04 Civ. 2841 (JS), 2013 WL 4500879, at *1 (E.D.N.Y.
+Aug. 20, 2013). Under that analysis, punitive damages are considered to be conduct-regulating,
+9
+
+
+and "the law of the jurisdiction where the tort occurred will generally apply." See, e.g., Starr
+Indem. & Liab. Co. v. Am. Claims Mgmt., Inc., No. 14 Civ. 0463 (JMF), 2015 WL 2152816, *3
+(S.D.N.Y. May 7, 2015) (quoting Guidi v. Inter-Cont'l Hotels Corp., No. 95 Civ. 9006 (LAP),
+2003 WL 1907901, at *1 (S.D.N.Y. Apr. 16, 2003)); Bauta v. Greyhound Lines, Inc., No. 14 Civ. 3725
+(RER), 2019 WL 8060183, at *10 (E.D.N.Y. Jan. 4, 2019). Here, the torts alleged occurred
+entirely in New York. The personal injury claims which Doe's Complaint brings arise from
+sexual assaults and related conduct that, as alleged, occurred exclusively within New York
+City—in and around Epstein's Manhattan townhouse.
+Doe counters by noting that, while this rule applies as a general matter, it may be overcome
+if there is good reason not to apply it. Doe Mem. at 5 (citing Nat'l Jewish Democratic Council v.
+Adelson, 417 F. Supp. 3d 416, 424-25 (S.D.N.Y. 2019)). In arguing that there is reason not to
+apply New York law to the punitive damages question here, Doe relies on the doctrine of dépeçage,
+under which courts may treat the choice of law analysis for one (or more) issues in a case—in
+this instance, the availability of punitive damages —as distinct from the rest of its analysis, here
+the applicability of New York law to Doe's tort claims for compensatory damages. Id.; see also
+2002
+R. Buchalter Alaska Tr. v. Phila. Fin. Life Assurance Co., 96 F. Supp. 3d 182,
+200 (S.D.N.Y. 2015); Fed. Hous. Fin. Agency v. Ally Fin. Inc., No. 11 Civ. 7010 (DLC),
+2012 WL 6616061, at *5 (S.D.N.Y. Dec. 19, 2012).
+Doe argues that, although New York may have the greater interest in resolving issues
+relating to compensatory damages, the USVI, where the executors are domiciled and where
+Epstein's will is to be probated, has the greater interest as to punitive damages, which, unlike
+compensatory damages, are defendant-focused. Doe Mem. at 7-8. Doe does not argue that the
+executor-defendants themselves merit punishment or are in need of deterrence. Instead, Doe
+10
+
+
+argues that Epstein's decision to alter his will shortly before his suicide to provide that it would
+be probated in the USVI was strategically motivated. She argues that his executors "should not
+be permitted to selectively avail themselves of certain benefits of USVI law but avoid those
+aspects of USVI law that they do not like." Id. at 7.
+The Court is unpersuaded. Whatever benefits Epstein envisioned for his estate by virtue
+of probating his will in the USVI, Doe does not articulate any relevant to this litigation. Other
+than conclusorily, Doe does not argue that the decision to probate Epstein's will in the USVI will
+have any adverse bearing on a personal injury action brought against the estate in New York that
+involves tortious conduct in New York. Doe does not argue, for example, that the probating of
+Epstein's will in the USVI stands to insulate his assets from recovery from such a plaintiff, or
+otherwise impede her or others victimized in New York from recovering on meritorious claims.
+Doe's point that the estate may prosper from being probated in the USVI is disconnected from
+her claims.
+More fundamentally, Doe does not articulate any concrete interest that the USVI has in
+either vindicating the rights of a victim sexually abused in a Manhattan townhouse in 2004 and
+2005 or, specially relevant to punitive damages, in assuring that the perpetrator of that abuse is
+adequately punished and deterred. In contrast, the Second Circuit has noted the strong interest
+that New York has with respect to "conduct-regulating" rules, including regarding damages, with
+respect to unlawful behavior within its borders:
+"If conflicting conduct-regulating laws are at issue, the law of the jurisdiction
+where the tort occurred will generally apply because that jurisdiction has the
+greatest interest in regulating behavior within its borders." Cooney v. Osgood
+" If anything, the probating of the estate in the USVI may stand to benefit the estate's creditors,
+and thereby potentially Doe, to the extent that an estate probated in the USVI may avoid the high
+estate-tax rates imposed by New York State.
+
+
+Mach., Inc., 81 N.Y.2d 66, 72 (1993). In Licci ex rel. Licci v. Lebanese Canadian
+Bank, SALL] ... we observed that, under New York law, when the jurisdictions of
+the conduct and injury are distinct, it is the place of the allegedly wrongful
+conduct that generally has superior "interests in protecting the reasonable
+expectations of the parties who relied on the laws of that place to govern their
+primary conduct and in the admonitory effect that applying its law will have on
+similar conduct in the future." [739 F.3d 45, 50-51 (2d Cir. 2013)] (quoting
+[v. Boy Scouts of Am., Inc., 65 N.Y.2d 189, 198 (1985)]) (alterations
+omitted). Here, the allegedly wrongful conduct ... took place in New York ....
+We therefore conclude that New York's rules on fraud damages and negligent
+misrepresentation apply.
+AHW Inv. P'ship, MFS v. Citigroup, Inc., 661 F. App'x 2, 5 (2d Cir. 2016). New York's interest
+is also reinforced by the fact that Doe's suit is timely only by virtue of the state's recent
+enactment of the New York Child Victims Act, which temporarily revived time-barred suits. See
+Cmplt. 1 107.
+That New York law governs the availability of punitive damages is further reinforced by
+Doe's having sued the executor defendants under EPTL § 11-3.2(a)(1). It is problematic for her
+to cherrypick within that provision, invoking the part that authorizes a personal injury suit
+against an executor while disclaiming the balance, which delimits the recovery available in such
+a suit." See Blissett, 940 F. Supp. at 457 ("[I]t would be an anomalous situation indeed if
+plaintiff were allowed to proceed with this [§] 1983 action against the estate of
+because of
+[8] 11-3.2(a)(1), while at the same time he was allowed to recover relief in the form of punitive
+damages, which clearly is beyond the scope of relief which that statute authorizes."). Such a
+result is also inconsistent with the doctrine of dépeçage, where one forum's law is "applied to
+regulate certain issues arising from a given transaction or occurrence, while those of another
+system regulate the other issues."
+v. Twin City Fire Ins. Co., 492 F. Supp. 2d 308, 328
+* Doe's claims undisputedly all qualify as personal injury claims. See N.Y. Gen. Constr. Law
+§ 37-a. (defining "personal injury" as including "an assault, battery, false imprisonment, or other
+actionable injury to the person either of the plaintiff, or of another"). Doe does not argue
+otherwise.
+12
+
+
+n. 11 (S.D.N.Y. 2007) (emphasis added), aff'd sub nom.
+v. Liberty Mut. Ins. Co.,
+539 F.3d 135 (2d Cir. 2008). Here, Doe, in selectively drawing upon EPTL § 11-3.2(a)(1), seeks
+to invoke dépeçage to apply two different sets of laws to a single issue. The doctrine does not
+invite such a result.
+Finally, Adelson, on which Doe relies in claiming that USVI law governs punitive
+damages, is inapposite. Adelson had brought an earlier action in this District for defamation, in
+breach of Nevada law, against the National Jewish Democratic Council and its chair (together,
+"NJDC"). Adelson, 417 F. Supp. 3d at 420-21. That action had been dismissed pursuant to
+Nevada's anti-SLAPP statute. NJDC then sued Adelson, seeking punitive damages under that
+same Nevada statute. Id. On Adelson's motion to dismiss the punitive damages prayer, Judge
+Oetken held that Nevada's interest was stronger than New York's as to punitive damages,
+because Adelson had brought the initial suit under Nevada law and because it had been
+dismissed under the Nevada SLAPP statute on which the NJDC now pursued punitive damages.
+He reasoned that "because the litigant has attempted to use Nevada's defamation law to chill
+First Amendment rights, Nevada has a corresponding interest in punishing the litigant for
+maliciously invoking Nevada law and in deterring future litigants from doing the same."
+Adelson, 417 F. Supp. 3d at 426 (citing |
+65 N.Y.2d at 198). Noting that "[p]unitive
+damages are designed to punish the defendant, not to compensate the plaintiff," Judge Oetken
+explained that "the choice-of-law inquiry for punitive damages provisions is necessarily
+defendant-focused" in this way. Id. (internal quotation marks omitted) (citing Golden,
+2013 WL 4500879, at *3). By contrast, Judge Oetken concluded that New York's interest in the
+dispute was "relatively attenuated" and effectively limited to the fact that the suit was filed in
+federal district court in Manhattan where, notably, the claims were brought under Nevada
+13
+
+
+defamation law. "After all, New York lacks a particularized interest either in protecting
+defendants from liability under Nevada defamation law or in controlling the behavior of litigants
+who file in the federal courts. And where the locus jurisdiction has a merely fortuitous
+relationship with the case, that jurisdiction's interest in the case is minimal." Id. at 426-27
+(internal quotation marks and alterations omitted). Doe's case in this District, in contrast to
+Adelson, does not build on a prior litigation in, or based on the law of, the USVI.
+In any event, the choice of law debate here appears academic. That is because, while the
+USVI does not have a statute on point and USVI courts have not squarely resolved the issue, it is
+likely that USVI common law would not permit an award of punitive damages against an estate.
+In 2011, the USVI Supreme Court instructed courts to apply what it terms a "Banks analysis" to
+determine USVI common law. This entails consideration of "three non-dispositive factors":
+(1) whether any USVI court has previously adopted a particular rule; (2) the position taken by a
+majority of courts of other jurisdictions; and (3) most importantly, which rule represents the
+soundest rule for the USVI. See Gov't of Virgin Islands v.
+60 V.I. 597, 600 (2014);
+Matthew v. Herman, 56 V.I. 674, 680 (2012); Banks v. Int'l Rental & Leasing Corp., 55 V.I. 967,
+979 (2011). The parties differ as to how these factors apply, but the executors' assessment is the
+more persuasive.
+As to the first Banks factor, USVI courts have repeatedly cited the Restatement (Second)
+of Torts § 908 favorably. Twice, albeit in dicta, they have expressly quoted the language in
+comment (a) to § 908 that bars an award of punitive damages against the estate of a decedent
+tortfeasor.
+See
+v. Dowson Holding Co., 51 V.I. 619, 628 (D.V.I. 2009) ("Punitive
+damages are not awarded against the representatives of a deceased tortfeasor nor, ordinarily, in
+an action under a death statute." (quoting Restatement (Second) of Torts § 908 cmt. a (1979))
+14
+
+
+(citing
+v. Atlas Motor Inn, Inc., 16 V.I. 367, 368-69 (D.V.I. 1979) (interpreting the Virgin
+Island's wrongful death statue, 5 V.I.C. § 76, to preclude punitive damages)); Booth v. Bowen,
+Civ. No. 2006-217 (CVG), 2008 WL 220067, at *5 (D.V.I. Jan. 10, 2008) (same)'; see also
+Pappas v. Hotel on the Cay Time-Sharing Ass'n, 69 V.I. 3, 15 n.8 (V.I. Super. Ct. 2015) (applying
+Banks analysis to hold that USVI courts would adopt Restatement (Second) of Torts § 908, and
+citing five USVI cases in accord); Powell v. Chi-Co's Distrib. Ine., No. ST-13-TOR-14,
+2014 WL 1394183, at *2 n.13 (V.I. Super. Ct. Apr. 3, 2014) (Applying a Banks analysis, the
+Court finds that Restatement (Second) of Torts § 908(2) reflects the common law of this
+jurisdiction .... [C]onsidering the longstanding application of the Restatement (Second) of
+Torts § 908(2) in this jurisdiction and the apparent widespread application of this rule in a
+majority of jurisdictions, the Court finds that the Restatement (Second) of Torts § 908(2)
+represents the soundest rule for the Virgin Islands, and is in accord with local public policy.").
+Doe has not cited any contrary authority.
+As to the second Banks factor, the parties agree that, consistent with the Restatement,
+most U.S. jurisdictions do not permit an award of punitive damages against a tortfeasor's estate.
+See, e.g., Crabtree ex rel. Kemp v. Estate of Crabtree, 837 N.E.2d 135, 138 (Ind. 2005) ("[tJhe
+majority view denies punitive damages" from a deceased tortfeasor's estate); Jay Zitter, Annotation,
+Claim for punitive damages in tort action as surviving death of tortfeasor or person wronged, 30
+A.L.R. 4th 707 (2020); 1 Punitive Damages: Law and Prac. 2d § 9:8 (2019 ed.) ("The prevailing
+view appears to be that punitive damages may not be recovered against the estate of a deceased
+wrongdoer."). Doe notes that some jurisdictions (like New York) have adopted this result by
+" The decisions in
+case was the plaintiff, not the defendant.
+and Booth were dicta on this point, because the executor in each
+15
+
+
+statute while others have done so by court decision. Doe Mem. at 12. This distinction, however,
+does not appear germane to the Banks inquiry.
+As to the third Banks factor, the parties have not cited any evidence beyond USVI
+courts having repeatedly cited Restatement § 908 with favor, including in the course of a Banks
+analysis-
+-as to which rule would most soundly fit the USVI's interests. Beyond recognizing
+that USVI courts appear comfortable with the majority rule, the Court therefore cannot assign
+significant independent weight to this factor. Doe notes that the USVI's attorney general, in a
+separate lawsuit, is pursuing punitive damages against the Epstein estate based on alleged
+predations by Epstein in the USVI. See Mullkoff Decl. Ex. B 11 307-10. Doe further argues
+that because the only heir listed in Epstein's will—his brother Mark Epstein—-allegedly knew or
+had constructive knowledge of Epstein's pattern of sexual abuse, it is just to deny him recovery
+from the estate by exposing the estate to punitive damages awards in cases such as hers. Doe
+Mem. at 11. But the decision by a government lawyer to attempt to obtain such damages in a
+high-profile case involving allegations of extreme conduct, or the alleged guilty knowledge of an
+heir in this case, do not speak to the question that the third Banks factor assays: which rule of law
+best durably serves the USVI's interests. The Court therefore has no basis to treats this Banks
+factor as countervailing, let alone outweighing, the first two.
+CONCLUSION
+For the reasons above, the Court grants the defendant-executors' motion to dismiss the
+prayer for punitive damages against them. The Clerk of Court is respectfully directed to
+terminate the motion pending at docket 17.
+16
+
+
+SO ORDERED.
+Panl A. Englangu
+Paul A. Engelmayer
+United States District Judge
+Dated: April 28, 2020
+New York, New York
+17
diff --git a/vision-fixhub/court-01/edf1ee2bdca0bfdc499e0d53fa3a7f22b55cbe245fb605fd9c2755fc01eec683.receipt.json b/vision-fixhub/court-01/edf1ee2bdca0bfdc499e0d53fa3a7f22b55cbe245fb605fd9c2755fc01eec683.receipt.json
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diff --git a/vision-fixhub/court-01/edf31015bfd280e65c1671d71bdf738e4e9e3a0b73f2fff55620b5dc8a96da31.md b/vision-fixhub/court-01/edf31015bfd280e65c1671d71bdf738e4e9e3a0b73f2fff55620b5dc8a96da31.md
new file mode 100644
index 0000000000000000000000000000000000000000..c13c62c51ea4398e2fee6246759f28c4b66f842d
--- /dev/null
+++ b/vision-fixhub/court-01/edf31015bfd280e65c1671d71bdf738e4e9e3a0b73f2fff55620b5dc8a96da31.md
@@ -0,0 +1,62 @@
+Case 1:20-cv-00484-JGK-DCF Document 99 Filed 03/11/21 Page 1 of 2
+PANISH
+SHEA &
+BOYLE
+LLP
+March 11, 2021
+VIA ECE
+Hon. John G. Koeltl
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl Street
+New York, NY 10007
+Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF
+Dear Judge Koeltl:
+Plaintiff Jane Doe hereby responds to the Court's Memorandum Opinion and Order
+("Opinion") dated March 8, 2021 (ECF 98). As the Court indicated in its Opinion, Defendant
+Ghislaine Maxwell refused to sign the proposed stipulation to dismiss this action with prejudice
+following Plaintiff's acceptance of the Epstein Victims' Compensation Program's offer of
+compensation'. Plaintiff was then compelled to file her motion to dismiss with prejudice
+pursuant to FRCP Rule 41(a)(2).
+The U.S. Court of Appeals for the Second Circuit, in the case of Paysys Int'l, Inc. v. Atos
+IT Servs. Ltd., 901 F.3d 105, 108 (2d Cir. 2018), as cited to by this Court in its Opinion, states
+that once the district court articulates its terms for dismissal, "plaintiff... has the choice
+between accepting the conditions and obtaining dismissal and, if [the plaintiff) feels that the
+conditions are too burdensome, withdrawing [the plaintiff's] dismissal motion and proceeding
+with the case on the merits." Paysys, 901 F.3d at 109 (emphasis added). Indeed, that was the
+recent choice Judge Schofield gave another Epstein/Maxwell sex abuse victim plaintiff in the
+v. Indyke et al., 19-cv10475-LGS-DCF, following a nearly identical motion to
+dismiss filed by the plaintiff after Ms. Maxwell refused to stipulate to a dismissal in that case as
+well. In her Opinion and Order, Judge Schofield stated that:
+"Plaintiff shall file a letter no later than February 12, 2021, stating
+whether she consents to the Court's entry of the Proposed Order
+modified by striking the language "with each party to bear its own
+' Defendant Maxwell is a willing and compulsory "Releasee" in the general release
+agreement executed by Plaintiff in connection to this action.
+11111 Santa Monica Boulevard, Suite 700 • Los Angeles, California 90025 • 310.477.1700 phone • 310.477.1699 fax • www.psblaw.com
+
+
+Case 1:20CV-00484-JGK-DCF Document 99 Filed 03/11/21 PARISHI
+SHEA &
+BOYLE™
+Hon. John G. Koelti
+Daniel 1
+Moynihan
+United States Courthouse
+March 11, 2021
+Page 2
+attorneys' fees and costs," or wishes to withdraw her motion for
+voluntary dismissal." (19-cv-10475, ECF 118).
+control and influence over whether Plaintiff may dismiss her own case, the Court's Opinion may
+lead to inconsistent results and, if the case is not dismissed, will cause significant and undue
+prejudice to Plaintiff.
+Plaintiff agrees to and accepts the additional conditions regarding the dismissal specified
+by the Court in its March 8, 2021 Memorandum Opinion and Order. Accordingly, and pursuant
+to the foregoing reasons, Plaintiff respectfully requests that the Court enter the dismissal of her
+case forthwith regardless of whether defendants intend to agree or not to the Court's additional
+conditions.
+Respectfully submitted,
+PANISH SHEA & BOYLE
+Is/ Robert Glassman
+Robert Glassman
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diff --git a/vision-fixhub/court-01/ee0ab34ae5c8d741e5cf13530a1af42308f1b0c8396f47c95bc8480b30c53faa.md b/vision-fixhub/court-01/ee0ab34ae5c8d741e5cf13530a1af42308f1b0c8396f47c95bc8480b30c53faa.md
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@@ -0,0 +1,176 @@
+Case 9:08-cv-80119-KAM Document 445 Entered on FLSD Docket 01/12/2010 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/| |
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+NOTICE OF WITHDRAWAL OF DEFENDANT EPSTEIN'S MOTION TO
+COMPEL PRESEDENTIAL WOMEN'S CENTER TO COMPLY WITH
+SUBPOENA DUCES TECUM (DE 421) AND DEFENDANT EPSTEIN'S
+MOTION TO COMPEL PRESIDENTIAL WOMEN'S CENTER TO
+COMPLY WITH SUBPOENA DUCES TECUM AS TO JANE FOE NO.4 (DE 443)
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby files his Notice of Withdrawal of Defendant, EPSTEIN'S,
+Motion to Compel Presidential Women's Center to Comply with Subpoena Duces
+Tecum (DE 421) and Defendant, EPSTEIN'S, Motion to Compel Presidential Women's
+Center to Comply with Subpoena Duces Tecum as to Jane Doe no. 4, and state:
+On December 2, 2009, Epstein filed a Motion to Compel Presidential
+Women's Center to Comply with Subpoena Duces Tecum ("Motion to Compel") (DE
+#431).
+
+
+Case 9:08-cv-80119-KAM Document 445 Entered on FLSD Docket 01/12/2010 Page 2 of 5
+Since the filing of the Motion to Compel (DE #431), Presidential
+Women's Center notified undersigned counsel that it does not have any records for Jane
+Doe Nos 2, 3, 5, 6 and 8.
+Thus, unless circumstances change in the future, the issues in Epstein's
+Motion to Compel and the subpoenas to Presidential Women's Center regarding Jane
+Doe Nos. 2, 3, 5, 6 and 8 are moot at the current time.
+4.
+On December 29, 2009, Epstein filed a Motion to Compel ("Motion to
+Compel") (DE #443) Presidential Women's Center to Comply with Subpoena Duces
+Tecum as to Jane Doe No. 4.
+5.
+Since the filing of the Motion to Compel (DE #443) Epstein has been
+provided copies of the records in the possession of Presidential Women's Center related
+to Jane Doe No. 4.
+By:
+ROBERT D.
+CRITTON, JR., ESQ.
+Florida Bar#224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+
+
+Case 9:08-cv-80119-KAM Document 445 Entered on FLSD Docket 01/12/2010 Page 3 of 5
+Certificate of Service
+THEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CM/ECF on this 12" day of January. 20910.
+Respectfully submited.
+By: _
+ROBERT/D CRITTON, JR., ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+(Counsel for Defendant Jeffrey Epstein)
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Brad
+Esq.
+Jaffe, Weissing,
+Fistos
+424 N. Andrews Avenue, Suite #2
+Ft. Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2833
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No.
+
+
+Case 9:08-cv-80119-KAM Document 445 Entered on FLSD Docket 01/12/2010 Page 4 of 5
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+Paul G. Cassell, Esq.
+08-80232, 08-80380, 08-80381, 08-80993,
+Pro Hac Vice
+08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A.
+801-585-6833 Fax
+2290 10* Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M. L
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A
+Counsel for Plaintiff in Related Case No.
+08-80811
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Jack Scarola, Esq.
+Counsel for Plaintiff in Related Case No.
+Jack P.
+, Esq.
+08-80469
+Searcy Denney Scarola Barnhart & Shipley,
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx(@)searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+5 West Flagler Street, Suite 80
+Miami, FL 3313
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Jack Alan Goldberger, Esq
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jages @bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cV-80119-KAM Document 445 Entered on FLSD Docket 01/12/2010 Page 5 of 5
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+}
diff --git a/vision-fixhub/court-01/ee11b0afa24865e60cef6a907ef37836741ac792f7143a7beb53a1a6e9ae1129.md b/vision-fixhub/court-01/ee11b0afa24865e60cef6a907ef37836741ac792f7143a7beb53a1a6e9ae1129.md
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@@ -0,0 +1,86 @@
+Case 9:08-cv-80119-KAM Document 474 Entered on FLSD Docket 02/23/2010 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFES JANE DOE NOS. 2-8'S NOTIFICATION
+OF 90 DAYS EXPIRING ON MOTION TO COMPEL
+Plaintiffs Jane Doe Nos. 2-8, by and through undersigned counsel and pursuant to Local
+Rule 7.1.B.3, hereby give notice that a motion in this case has been pending and fully briefed for
+a period of ninety (90) days, as follows:
+1.
+On September 30, 2009, Plaintiffs Jane Doe Nos. 2-8 filed a Motion to Compel
+Responses to Requests for Net Worth Discovery and Incorporated Memorandum of Law (D.E.
+333).
+on November 2, 2009 (D.E. 390).
+November 23, 2009 (D.E. 426).
+Defendant Jeffrey Epstein filed his response to the Plaintiffs' Motion to Compel
+Plaintiffs Jane Doe Nos. 2-8 filed their reply to Defendant Epstein's response on
+1
+
+
+Case 9:08-cv-80119-KAM Document 474 Entered on FLSD Docket 02/23/2010 Page 2 of 3
+4.
+5.
+No hearing has been held or scheduled on the Motion.
+Plaintiffs calculate that the applicable ninety day period expired on February 22,
+2010.
+Plaintiffs' counsel file this Notification for purposes of compliance with the duty
+of movant's counsel set forth in S.D.Fla.L.R. 7.1 B.3.
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on February 23, 2010, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Stuart S. Mermelstein
+2
+
+
+Case 9:08-cv-80119-KAM Document 474 Entered on FLSD Docket 02/23/2010 Page 3 of 3
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+brad@pathtojustice.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+3
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new file mode 100644
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+  "input_sha256": "3b7ae9aba28f4faf5a25070ae752bd9ef35578a853d2623bdf68a50be023d9f7",
+  "output_sha256": "0e424806f098fdf021c393c223ac0517cb3469c51f4e4fbfb7c9aff4f20ded3b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee2739e2e54fd5d120b008a6c32260bebf7fe58fa553f52d04deb32cc8bd3818.md b/vision-fixhub/court-01/ee2739e2e54fd5d120b008a6c32260bebf7fe58fa553f52d04deb32cc8bd3818.md
new file mode 100644
index 0000000000000000000000000000000000000000..6a2eea710783c7821333375adb15244cc6649cb9
--- /dev/null
+++ b/vision-fixhub/court-01/ee2739e2e54fd5d120b008a6c32260bebf7fe58fa553f52d04deb32cc8bd3818.md
@@ -0,0 +1,154 @@
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 2 of 6
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/_
+JANE DOE,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRAJ
+DOE II,
+VS.
+CASE NO.: 08-CV- 80469-MARRA/
+Plaintiff,
+2
+
+
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 3 of 6
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 08- CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA
+PLAINTIFFS' JANE DOES 2-7 MOTION FOR ENLARGEMENT
+OF TIME TO RESPOND TO DEFENDANT'S MOTION TO COMPEL
+AND/OR IDENTIFY JANE DOE IN THE STYLE ET AL.
+Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this
+Motion for Enlargement of Time to Respond to Defendant's Motion to Compel and/or Identify
+Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third Party Subpoenas for
+Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and state as follows:
+Defendant Epstein filed his Motion to Compel and/or Identify Jane Doe in the
+Style, et al., in the cases brought by Jane Does No. 2-7 ("Does 2-7") on May 5 and 6, 2009.
+Under S.D.Fla.L.R. 7.1(C), Does No. 2-7' response is due on May 22, 2009.
+2.
+Plaintiffs request an additional twenty (20) days to respond to the Motion to
+3
+
+
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 4 of 6
+Compel and/or Identify Jane Doe in the Style, et al. This request for enlargement of time of
+twenty (20) days is necessitated primarily by Plaintiffs desire to have the psychiatric expert who
+examined the Plaintiffs consider the issue of their public identification and, if appropriate, submit
+an expert declaration in response to the relief sought in the Defendant's Motion. The
+enlargement of time requested is sought to provide the expert with adequate time to perform this
+work.
+3.
+Additionally, Plaintiffs' counsel has conflicts with other cases and matters which
+necessitate additional time for a response, including, without limitation, a special set hearing and
+upcoming trial in John Doe 6 v. Diocese of Orlando, case no. 48-2005-010138-0, Ninth Judicial
+Circuit for Orange County, Florida; and an upcoming deadline to file Appellant's initial Brief in
+Jane Doe v. Florida International University Board of Trustees, case no. 3D09-414, Florida Third
+District Court of Appeals.
+4.
+Plaintiffs' counsel has conferred with Defendant's counsel, Robert Critton and
+Michael Pike, regarding this request for extension of time. While Defendant's counsel
+represented that Defendant would consent to an extension of time of one (1) week, until May 29,
+2009, Defendant opposes any further extension of time. The grounds stated by Defendant's
+counsel for opposing the extension of time requested concern the relief sought in Defendant's
+Motion to Strike Cases from the Current Trial Docket, filed on May 19, 2009.
+WHEREFORE, Plaintiffs Jane Doe Nos. 2-7 respectfully request an enlargement of time
+until June 11, 2009 to file their response to Defendant's Motion to Compel and/or Identify Jane
+Doe in the Style, et al., and for such other and further relief this Court deems just and proper.
+Dated: May 21, 2009
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+4
+
+
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 5 of 6
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on May 21, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+5
+
+
+Case 9:08-cv-80119-KAM Document 111 Entered on FLSD Docket 05/21/2009 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Stuart S. Mermelstein
+6
diff --git a/vision-fixhub/court-01/ee2739e2e54fd5d120b008a6c32260bebf7fe58fa553f52d04deb32cc8bd3818.receipt.json b/vision-fixhub/court-01/ee2739e2e54fd5d120b008a6c32260bebf7fe58fa553f52d04deb32cc8bd3818.receipt.json
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.md b/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.md
new file mode 100644
index 0000000000000000000000000000000000000000..b0ea12c28a944c4ada4b6d06314b10297253fd03
--- /dev/null
+++ b/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.md
@@ -0,0 +1,68 @@
+**** CASE NUMBER: 502019CA014681XXXXMB Div: AG ****
+Filing # 98869063 E-Filed 11/14/2019 11:06:37 AM
+IN THE CIRCUIT COURT, 15th
+JUDICIAL CIRCUIT, IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CASE NO.:
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida, SHARON
+OCK, as Clerk and Comptroller of Pali
+Defendants.
+COPY
+DEFENDANT:
+SUMMONS
+Is Calm Bed Cour Fr
+Horid
+05 N. Dixie Highwa
+'est Palm Beach, Florida 334(
+hear your side of the case. If you do not file your response on time, you may lose the
+case, and your wages, money, and property may thereafter be taken without further
+arning from the Court. There are other legal requirements. You may want to call :
+torney right away. If you do not know an attorney, you may call an attorney referr
+rvice or a legal aid office (listed in the phone book). If you choose to file a writt
+ELEA
+sponse yourself, at the same time you file your written response to the Court you mu
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/14/2019 11:06:37 AM
+
+
+THE STATE OF FLORIDA
+TO EACH SHERIFF OF THE STATE: You are commanded to serve this Summons and
+a copy of the Complaint in this lawsuit on the above named Defendant.
+DATED on November , 2019 NOV 15 2019 9
+AMI
+Sharon R. Bock
+As Clerk & Comptroller of the Court
+By:
+Rela
+Deputy Clerk
+DOLLY
+IMPORTANTE
+Usted ha sido demandado legalmente. Tiene 20 Dias, contados a partir del recibo de esta
+notificacion, para contestar la demanda adjunta, por escrito, y presentarla ante este tribunal. Una llamada
+telefonica no lo protegera. Si usted desca que el tribunal considere su defensa, debe presentar su respuesta
+por escrito, incluyendo el numero del caso y los nombres de las partes interesadas. Si usted no contesta la
+demanda a tiempo, pudiese perder el caso y podria ser despojado de sus ingresos y propiedades, o privado
+de sus derechos, sin previo aviso del tribunal. Existen otros requisitos legales. Si lo desea, puede usted
+consultar a un abogado inmediatamente. Si no conoce a un abogado, puede lamar a una de las oficinas de
+Si desca responder a la demanda por su cuenta, al mismo tiempo en que presenta su respuesta ante
+el tribunal, debera usted enviar por correo o entregar una copia de su respuesta a la persona denominada
+abajo como "Plaintiff/Plaintiff's Attorney" (Demandante o Abogado del Demandante).
+IMPORTANT
+Des poursuites judiciares ont ete entreprises contre vous. Vous avez 20 jours consecutifs a partir
+de la date de l'assignation de cette citation pour deposer une reponse ecrite a la plainte ci-jointe aupres de ce
+tribunal. Un simple coup de telephone est insuffisant pour vous proteger. Vous etes oblige de deposer
+votre reponse ecrite, avec mention du numero de dossier ci-dessus et du nom des parties nommees ici, si
+vous souhaitez que le tribunal entende votre cause. Si vous ne deposez pas votre reponse ecrite dans le
+relai requis, vous risquez de perdre la cause ainsi que votre salaire, votre argent, et vos biens peuvent etre
+saisis par la suite, sans aucun preavis ulterieur du tribunal. Il y a d'autres obligations juridiques et vous
+pouvez requerir (les services immediats d'un avocat. Si vous ne connaissez pas d'avocat, vous pourriez
+telephoner aun service de reference d'avocats ou a un bureau d'assistance juridique (figurant a l'annuaire de
+telephones).
+Si vous choisissez de deposer vous-meme une reponse ecrite, il vous faudra egalement, en meme
+temps que cette formalite, faire parvenir ou expedier une copie de votre reponse cerite au
+"Plaintiff/Plaintiff's Attorney" (Plaignant ou a son avocat) nomme ci-dessous.
+2
diff --git a/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.receipt.json b/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0d4a16cd4d11d62ec56cf51e3d29b8b7c7600afe
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+++ b/vision-fixhub/court-01/ee282cc5d30cccfd07d634a8cad7088605f567d5ea92d76c75021b1e5e55dd5c.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d5589e1d4b14358afde0dbd32c5afed9ac3b820f9a4e8bfb224beedc529113e4",
+  "output_sha256": "16dce93e028b0ab76b5910e011d9eaa39915f04ff88af2b49027b9815ee7dd0c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee4b496e76fc1b0d3b9e87ca49996e11956a962f5922c06c4572d4df57fd897e.md b/vision-fixhub/court-01/ee4b496e76fc1b0d3b9e87ca49996e11956a962f5922c06c4572d4df57fd897e.md
new file mode 100644
index 0000000000000000000000000000000000000000..a6fb93c86a23c5c8b0c3925e3343868ceddae665
--- /dev/null
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@@ -0,0 +1,138 @@
+Case 9:08-cv-80804-KAM Document 17 Entered on FLSD Docket 09/03/2008 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80804-CIV-MARRA.
+seated
+JANE DOE, a/k/a
+JANE DOE NO. 1,
+Plaintiff,
+FRIED DOC.
+JUL 2 5 2008
+STEVEN M. LARIMOR
+CLERK U.S. DIST C
+S.D. OF FLA. MIAMI
+VS.
+JEFFREY EPSTEIN,
+and
+Defendants.
+FILED UNDER SEAL
+DEFENDANTS JEFFREY EPSTEIN AND |
+MOTION TO FILE UNDER SEAL
+Tis Teinn.
+3059 GRAND AVENUE. SUITE 140, COCONUT GROVE, FLORIDA 33133
+
+
+Case 9:08-cv-80804-KAM Document 17 Entered on FLSD Docket 09/03/2008 Page 2 of 5
+CASE NO.: 08-80804-CIV-MARRA/
+Pursuant to Rule 5.4 of the Local Rules of the United States District Court
+for the Southern District of Florida, defendants Jeffrey Epstein and
+hereby move to file their motion for stay, as well as this motion, under seal, stating
+as follows:
+1.
+In their motion for stay, defendants Jeffrey Epstein and
+refer to a confidential agreement between the United States Attorney's Office for
+the Southern District of Florida and Jeffrey Epstein.
+2.
+The information contained in the confidential agreement is material to
+this Court's consideration of the defendants' motion for stay.
+To avoid disclosure of confidential material, the defendants request
+leave to file their motion for stay, and this motion, under seal.
+4.
+We recognize that this Court has previously unsealed documents
+referring to this same agreement. We mean in no way to disregard that order, but
+seek merely to comply with the confidentiality clause in that agreement for this
+new and independent filing, in an abundance of caution, until directed otherwise by
+the Court.
+The undersigned are authorized to represent that defendant
+joins in this motion.
+2
+I Tein.
+3059 GRAND AVENUE, SUTTE 340, COCONUT GROVE, FLORIDA 33133
+
+
+Case 9:08-cv-80804-KAM Document 17 Entered on FLSD Docket 09/03/2008 Page 3 of 5
+CASE NO.: 08-80804-CIV-MARRA/
+WHEREFORE, defendants Jeffrey Epstein and
+respectfully
+request leave to file this motion and their motion for stay, under seal.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By:
+Willrei
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By:
+Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+3
+Tein"
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133
+
+
+Case 9:08-cv-80804-KAM Document 17 Entered on FLSD Docket 09/03/2008 Page 4 of 5
+CASE NO.: 08-80804-CIV-MARRA/.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Undersigned counsel has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+tillite:
+Michael R. Tein
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that the foregoing document is being served this day,
+July 25, 2008, on counsel of record identified on the service list by U.S. Mail.
+Wilh Toi
+Michael R. Tein
+4
+Tein n.
+3059 GRAND AVENUE. SUITE 340, COCONUT GROVE, FLORIDA 33133
+
+
+Case 9:08-cv-80804-KAM Document 17 Entered on FLSD Docket 09/03/2008
+
+CASE NO.: 08-80804-CIV-MARRAJ
+Service List
+Theodore J. Leopold, Esq.
+Ricci-Leopold, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+Fax: 561 697 2383
+Counsel for Plaintiff Jane Doe
+Douglas M. McIntosh, Esq.
+Jason A.
+,, Esq.
+McIntosh, Sawran, Peltz & Cartaya, P.A.
+Centurion Tower
+1601 Forum Place, Suite 1110
+West Palm Beach, Florida 33401
+Fax. 561 682-3206
+Counsel for Defendant
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+Fax. 561 828 0983
+Counsel for Defendant
+Robert D. Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier &
+Coleman, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, Florida 33401
+Fax. 561 515 3148
+Co-Counsel for Jeffrey Epstein
+5
+Tein m
+3059 GRAND AVENUE, SUITE 340, COCONUT GROVE, FLORIDA 33133
diff --git a/vision-fixhub/court-01/ee4b496e76fc1b0d3b9e87ca49996e11956a962f5922c06c4572d4df57fd897e.receipt.json b/vision-fixhub/court-01/ee4b496e76fc1b0d3b9e87ca49996e11956a962f5922c06c4572d4df57fd897e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..da9d7b39635444d5662fde57bca5e17a3271c4e4
--- /dev/null
+++ b/vision-fixhub/court-01/ee4b496e76fc1b0d3b9e87ca49996e11956a962f5922c06c4572d4df57fd897e.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "8de669d91bdde89117bb37420d9fde5bafb43f09a18131f8ccd652fe431dcc97",
+  "output_sha256": "df745ed3880f563961780e8bea43e007f6413579733c145fabe340822ac68da8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee4b71205882d039a4e445f2d327375ed98cb4f5cdad2f38de7b12cd8aeb9a14.md b/vision-fixhub/court-01/ee4b71205882d039a4e445f2d327375ed98cb4f5cdad2f38de7b12cd8aeb9a14.md
new file mode 100644
index 0000000000000000000000000000000000000000..4b3b02d04dc8c170202cb2d329273c330af6afe6
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@@ -0,0 +1,96 @@
+Case 9:08-cv-80232-KAM Document 9 Entered on FLSD Docket 06/20/2008 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT'S MOTION FOR ENLARGEMENT OF
+TIME TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
+Defendant Jeffrey Epstein moves, pursuant to S.D. Fla. L.R. 7.1(A), for an
+enlargement of time to answer or otherwise respond to the complaint until ten days
+after his motion for a mandatory stay, filed contemporaneously with this motion, is
+decided, and as grounds for this relief respectfully states as follows:
+This civil action is a private counterpart to two ongoing criminal
+actions, one in Palm Beach state court, the other in the Southern District of Florida.
+2.
+These cases purport to arise from the same occurrence: the alleged
+sexual assault of a minor, Jane Doe No. 3.
+3.
+On June 20, 2008, Mr. Epstein filed a motion seeking a stay of this
+action under 18 U.S.C. § 3509. Under that section, when an alleged sexual assault
+
+
+Case 9:08-cv-80232-KAM Document 9 Entered on FLSD Docket 06/20/2008 Page 2 of 4
+involving a child victim results in a "criminal proceeding," a commonly derived
+civil suit "shall be stayed until the end of all phases of the criminal action." 18
+U.S.C. § 3509(k) (emphasis added).
+4. If Mr. Epstein's stay motion is granted, he will not be required to
+respond to the Complaint or otherwise litigate this action until the two pending
+criminal matters are resolved.
+WHEREFORE, Defendant Jeffrey Epstein respectfully requests an
+enlargement of time to answer or otherwise respond to the complaint until ten days
+after his motion for a stay is decided.
+Respectfully submitted,
+ATTERBURY, GOLDBERGER &
+WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel: 561 659 8300
+Fax: 561 835 8691
+By: Is/ Jack A. Goldberger
+Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+2
+
+
+Case 9:08-cV-80232-KAM Document 9 Entered on FLSD Docket 06/20/2008 Page 3 of 4
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7
+Counsel for defendant has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+/s/ Jack A. Goldberger
+Jack A. Goldberger
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 20, 2008, I electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that
+the foregoing document is being served this day on counsel of record identified
+below by facsimile and U.S. Mail.
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+/s/ Jack A. Goldberger
+Jack A. Goldberger
+3
+
+
+Case 9:08-cV-80232-KAM Document 9 Entered on FLSD Docket 06/20/2008 . Page 4 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-1
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE having come to be heard on the Defendant's Motion for An
+Enlargement of Time to Answer or Otherwise Respond to the Complaint, and this
+Court being fully advised, it is hereby:
+ORDERED AND ADJUDGED that the Motion is hereby granted.
+of
+DONE AND ORDERED in Miami-Dade County, Florida this
+, 2008.
+day
+Copies furnished to:
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
+Jack A. Goldberger, Esq.
+Jeffrey M. Herman, Esq.
diff --git a/vision-fixhub/court-01/ee4b71205882d039a4e445f2d327375ed98cb4f5cdad2f38de7b12cd8aeb9a14.receipt.json b/vision-fixhub/court-01/ee4b71205882d039a4e445f2d327375ed98cb4f5cdad2f38de7b12cd8aeb9a14.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..125e91b133988e20340741d448c99aadf23e7503
--- /dev/null
+++ b/vision-fixhub/court-01/ee4b71205882d039a4e445f2d327375ed98cb4f5cdad2f38de7b12cd8aeb9a14.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ed92258598c7ad31db6229699e669ce8f5c847f12430b5c73af80e4931979181",
+  "output_sha256": "0f07fcaed484495e7b222700650698fabe422816cc850eb7ae1dbb7745ccd18f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.md b/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.md
new file mode 100644
index 0000000000000000000000000000000000000000..398643310193b0fc3f8b7428fcdf8878fa869d5f
--- /dev/null
+++ b/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.md
@@ -0,0 +1,64 @@
+Case 9:08-cv-80381-KAM Document 25 Entered on FLSD Docket 07/16/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80381-CIV-MARRA/
+JANE DOE NO. S,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER DENYING MOTION TO SEAL
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File Ex
+Parte and Under Seal, filed July 10, 2008. Defendant seeks to file a Notice of Continued
+Pendency of Federal Criminal Action under seal.' The Court has carefully considered the motion
+and the record and is otherwise fully advised in the premises.
+As stated in the Local Rules for the Southern District of Florida, 'proceedings in
+the United States District Court are public and Court filings are matters of public record." S.D.
+Fla. L.R. 5.4(A). It is well settled that the media and the public in general possess a common-law
+right to inspect and copy judicial records. See Nixon v. Warner Communications, Inc., 435 U.S.
+589, 597 (1978). "The right to inspect and copy records is not absolute, however. As with other
+forms of access, it may interfere with the administration of justice and hence may have to be
+curtailed."
+v. Graddick, 696 F.2d 796, 803 (11th Cir. 1983). This right of access creates
+'All documents filed conventionally shall henceforth be filed directly with the Office of
+the Clerk in West Palm Beach, Florida. The parties shall not file documents conventionally in
+any other division of the Southern District of Florida.
+1
+
+
+Case 9:08-cv-80381-KAM Document 25 Entered on FLSD Docket 07/16/2008 Page 2 of 3
+a presumption in favor of openness of court records, which "must be balanced against any
+competing interest advanced." United States v. Noriega, 752 F. Supp. 1037, 1040 (S.D.
+Fla. 1990). For example, courts may look to see whether the records sought are for illegitimate
+purposes.
+696 F.2d at 803. Likewise, the Court may consider whether "the press has
+already been permitted substantial access to the contents of the records." Id.
+In his motion to seal, Defendant has made no argument as to why his Notice of Continued
+Pendency of Federal Criminal Action should not be made available to the public. Defendant
+states only that he wishes "[t]o avoid disclosure of confidential material." (Def. Mot. 2.) The
+Court finds this justification insufficient to justify keeping this document (filed ex parte) under
+seal. The Court is supported in this conclusion by its decision in a similar case, In re: Jane Doe,
+No. 08-80736-CIV (S.D. Fla. July 11, 2008), in which the Court unsealed, over the objection of
+the United States Attorney, documents containing similar information regarding Defendant's
+criminal plea agreement. Thus, any argument regarding confidentiality is vitiated by the fact that
+information regarding Defendant's criminal plea arrangement is already a matter of public
+record. See, e.g., Sally Apgar, Victims Object to Palm Beach Billionaire's Plea Deal in
+Underage Sex Case, S. Fla. Sun-Sentinel, July 12, 2008. Similarly, Defendant has not justified
+the necessity of filing his Notice ex parte. As such, Defendant's Motion to Seal shall be denied.
+Accordingly, it is ORDERED AND ADJUDGED that Defendant's Motion to File Ex
+Parte and Under Seal is DENIED. The Clerk shall UNSEAL docket entries 23 and 24 and make
+them available for public inspection through CM/ECF at the earliest possible time. Defendant is
+further ORDERED to serve a copy of his Notice on Plaintiff within five (5) days of the date of
+2
+
+
+Case 9:08-cv-80381-KAM Document 25 Entered on FLSD Docket 07/16/2008 Page 3 of 3
+entry of this Order.
+DONE AND ORDERED in
+Florida, this 16" day of July, 2008.
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+3
diff --git a/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.receipt.json b/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..043d08893dc8d6521a70d4518ec14962801f2177
--- /dev/null
+++ b/vision-fixhub/court-01/ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "ee5e6e6a32a92e3b0aa2e9ecc7d11ef78156ec502ec414a35374e88bb9a65e20",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9db17cbf8c96175e149748119230b34933c1ca77da3a5e9d4e14a00f439d6d7e",
+  "output_sha256": "bb9be1008f18cc3403e58a3a86beb47c38570cc65a01644c7e27c671f3d1df47",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9.md b/vision-fixhub/court-01/ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9.md
new file mode 100644
index 0000000000000000000000000000000000000000..b436711b940c29ee558ee4713719c421b3d0bcd0
--- /dev/null
+++ b/vision-fixhub/court-01/ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9.md
@@ -0,0 +1,212 @@
+Case 9:08-cv-80119-KAM Document 158 Entered on FLSD Docket 06/17/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-c7-80119-MARRA/JQ
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/J_
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/JOHNSON
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 158 Entered on FLSD Docket 06/17/2009 Page 2 of 6
+CASE NO.: 08-CV-80381-MARRA/J
+JANE DOE NO. 5,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80994-CIV-MARRA/J
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80993-CIV-MARRA/JOHNSON
+JANE DOE NO. 7,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/J
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 158 Entered on FLSD Docket 06/17/2009 Page 3 of 6
+JANE DOE,
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/J
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-JL
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 09-80591-CIV-MARRA-JL
+JANE DOE NO. 102,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-80656-CIV-MARRA/JL
+DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
+OF TIME IN WHICH TO REPLY TO PLAINTIFES JANE DOES 2-7
+RESPONSE TO DEFENDANT'S MOTION TO COMPEL IDENTITY
+IN THE STYLE OF THE CASE AND IN THRID PARTY SUBPOENAS (DE 144)
+
+
+Case 9:08-cv-80119-KAM Document 158 Entered on FLSD Docket 06/17/2009 Page 4 of 6
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves
+this Court for an extension of time until June 29, 2009, to file a Reply to Plaintiffs Jane
+Does 2-7 Response to Defendant's Motion to Compel Identity in the Style of the Case
+and in Third Party Subpoenas, pursuant to Local Rule 7.1 A.1(j) (S.D. Fla. 2008). As
+good cause for the requested extension, Defendant states:
+1. Counsel for Defendant communicated with Counsel for the Plaintiff, and
+Plaintiff's Counsel agrees to the requested extension of June 29, 2009, to file a Reply to
+Reply to Plaintiffs Jane Does 2-7 Response to Defendant's Motion to Compel Identity in
+the Style of the Case and Third Party Subpoenas.
+Rule 7.11.3. Certification of Pre-Frifs Conference
+Counsel for Defendant conferred with | Counsel for Plaintiff's counsel, by
+Robert D. Critton, Esq.
+Attorney for Defendant
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Respectfully submitted,
+
+
+Case 9:08-CV-80119-KAM Document 158 Entered on FLSO Docket 06/17/2009 Page 5 of 6
+By:
+ROBERT B.
+CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A
+8205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+Brad
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993, Paul G. Cassell, Esq.
+08-80994
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+Hide MaN
+_Esq.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+
+
+Case 9:08-cv-80119-KAM Document 158 Entered on FLSD Docket 06/17/2009 Page 6 of 6
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.|
+Esq-
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+Bruce Reinhart, Esq.
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A.
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+Theodore J. Leopold, Esq.
+agesq@bellsouth.ne
+Spencer T. Kuvin, Esq.
+ounsel for Defendant Jeffrey Epstei
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
diff --git a/vision-fixhub/court-01/ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9.receipt.json b/vision-fixhub/court-01/ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7831b748ad587edd6d7cbf85b860c9904b82c7fa
--- /dev/null
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@@ -0,0 +1,14 @@
+{
+  "byte_delta": -72,
+  "dataset": "marble-joined",
+  "doc_id": "ee6de5c6701c8180d33063db793a626873a46316493099dfb77122e586de45c9",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ac56e8857c6d062cfa25d50a4a35672d18c15ffa438200417eb1300ce4bc7b72",
+  "output_sha256": "5f26ff3094ecd136752d900c82369760b956a3d0c31fcf8e0ba4f849e98bace1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.md b/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.md
new file mode 100644
index 0000000000000000000000000000000000000000..3487159f2c568eab0574f942609966d4a01e8377
--- /dev/null
+++ b/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.md
@@ -0,0 +1,151 @@
+Filing # 141227338 E-Filed 01/03/2022 02:11:56 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIRCUIT CIVIL DIVISION: AG
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+3OCK, as Clerk and Comptroller of Paln
+COPY
+Defendants.
+CLERK OF THE CIRCUIT COURT & COMPTROLLER'S
+MOTION TO AMEND FINAL JUDGMENT
+Defendant,
+Abruzzo, in his official capacity as Clerk of the Circuit Court and
+Comptroller, Palm Beach County (Clerk"), by and through undersigned counsel and pursuant to
+Florida Rule of Civil Procedure 1.530(g), hereby moves to amend the Final Judgment [DE 78]
+with respect to the reference that the Clerk "zealously advocated the position against disclosure of
+the grand jury records based upon grand jury secrecy and confidentiality" and in support thereof
+states:
+Florida Rule of Civil Procedure 1.530(g) permits a party to file a motion to amend
+a final judgment within fifteen (15) days from the issuance of the judgment. Soldatich v. |
+290 So. 3d 497, 500 (Fla. 4th DCA 2020) ("A motion to alter or amend the judgment shall be
+served not later than 15 days after entry of the judgment...") (citing Fla. R. Civ. P. 2.530(g)); see
+also PLCA Condo. Ass'n v. AmTrust-NP SIR Venture, L.L.C, 182 So. 3d 668, 670 (Fla. 4th DCA
+*** FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK. 01/03/2022 02:11:56 PM ***
+
+
+2015) (same); Commonwealth Land Title Ins. Co. v. Freeman, 884 So. 2d 164, 168 (Fla. 2d DCA
+2004) ("As a result, the Trustees' time for filing the motion pursuant to rule 1.530(g) ran from the
+date of original final judgment."). The Final Judgment was entered on December 20, 2021, and
+this motion is therefore timely filed.
+2.
+The Clerk seeks to amend the Final Judgment - specifically page 3 - to reflect that
+the arguments made, and the defenses taken, were not done to shield the release of the grand jury
+materials but rather to ensure that (1) the law was followed with regard to the procedure used to
+seek such records and that (2) any confidential record(s) be released upon order of the court.
+As the Court noted in the Final Judgment, the Clerk's position is that he is "merely
+the custodian of the Materials and as such he has no real interest in the issues before the court as
+identified." Final Judgment [DE 78], p. 3. The Couft further stated that the "clerk's role in this
+proceeding has been complicated, or expanded, because the Newspaper filed this action as a civil
+declaratory judgement action and has moved for a motion for summary judgment under Rule of
+Civil Procedure 1.510" rather than filing a motion under Rule of General Practice and Judicial
+Administration 2.420(j). See id
+The Clerk has continuously maintained, notwithstanding his personal belief that in
+this particular case the grand jury records should be released, that under Rule of General Practice
+and Procedure 2.420 and Florida law, that he is required to maintain the confidentiality of grand
+jury records absent a court order. See, e.g., Clerk's Response to Plaintiff's Motion for Summary
+Judgment [DE 75], p. 2 ("Several statutes enforceable through criminal penalties... forbid clerks
+of Florida's circuit courts from releasing grand jury materials except...on order of the court
+pursuant to s. 905.27.") (internal quotes omitted).
+
+
+
+As was stated in the Order, "[t]he clerk's role in this proceeding has been
+complicated, or expanded, because the Newspaper filed this action as a civil declaratory judgment
+action and has moved for summary judgment ... [while] the proper procedure for obtaining
+disclosure of confidential court records is set forth in Florida Rule of General Practice and Judicial
+administration 2.420(i), which only requires the filing of a 'motion' seeking disclosure". See Final
+Judgment [DE 78], p. 3. Because the Clerk was forced to take on a more complicated and
+"expanded" role, the office had to retain counsel to defend this action. By allowing a seeker of
+grand jury records to file a lawsuit against a clerk, rather than simply filing a motion under Rule
+2.420(), a clerk would be required to expend funds defending matters to which he or she has no
+real interest. Allowing such a tactic could expose a clerk to -and what was referred to at the
+hearing as - a floodgate of unnecessary litigation at public expense. Thus, it was necessary for the
+Clerk to advocate for the proper procedure to be followed when confidential records in the
+possession of a clerk are sought.
+6.
+Clerk Abruzzo agrees with the Plaintiff to the extent that releasing the records
+would be of public interest and would further justice especially because the records were
+previously released to the United States Government prior to him taking office in January 2021.
+See id. at p. 4, n.3.
+Any position that could be perceived to be against the release, however, was
+simply due to the constraints of a clerk's role as the custodian of the materials and the existing
+confidentiality requirements of the Rules of General Practice and Judicial Administration as well
+as Florida law.
+Based upon the above, the Clerk seeks to have page three of the Final Judgment
+amended for the narrow purpose of clarifying that the Clerk did not advocate against disclosure of
+the grand jury records, but that he was merely without authority to release the records absent a
+
+
+
+court order. To have the Final Judgment include language that implies that the Clerk was zealously
+advocating against the release of records - rather than simply that he was required to maintain the
+confidentiality absent a court order - would be a mischaracterization of his position.
+WHEREFORE, based upon the foregoing,
+Abruzzo, in his official capacity as
+Clerk of the Circuit Court and Comptroller, Palm Beach County, respectfully moves this Court to
+amend page three of the Final Judgment to reflect that the Clerk advocated that a court order would
+be necessary to release the confidential records under Rule of General Practice and Judicial
+Administration 2.420.
+Dated: January
+/ 3, 2022
+NOT A CE
+Respectfully submitted,
+CLERK OF THE CIRCUIT COURT &
+COMPTROLLER, PALM BACH COUNTY
+s/ Collin D.
+Collin D
+Esq. (FL Bar No. 1018081)
+Clerk of the Circuit Court & Comptroller,
+Palm Beach County
+P.O. Box 229
+West Palm Beach, FL
+Tel.: (561) 355-2983
+E-mail: eservice@mypalmbeachclerk.com
+
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on January 3, 2022 the foregoing document was furnished upon the
+following via the Florida ePortal System:
+Stephen A. Mendelsohn
+Kenneth G. Turkel
+Shane B. Vogt
+James C. Mooney
+Bajo Cuva Q
+_ & Turkel, P.A.
+100 North Tampa Street, Suite 1900
+Tampa, Florida 33602
+E-mails: kturkel@bajocuva.com;
+svogt@bajocuva.com;
+jmooney@bajocuva.com
+Attorneys for Defendant,
+Clerk and Comptroller of Palm Beach
+County, Florida
+Michael J. Grygiel
+Greenberg Traurig, P.A.
+54 State St., 6th Floor
+Albany, NY 12207
+E-mail: grygielm@gtlaw.com
+Nina D. Boyajian
+Greenberg Traurig, P.A.
+1840 Century Park East,
+, Ste. 1900
+Los Angeles, CA 90067
+E-mails: boyajiann@gtlaw.com;
+riveraal@gtlaw.com
+Attorneys for Plaintiff.
+CA Florida Holdings, LIC
+Abruzzo, as
+NOT
+By:
+s/ Collin D.
+Collin D.
+1. Esq.
+
diff --git a/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.receipt.json b/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..220a864a3602d2a1f6dd664e2de22e71712a7270
--- /dev/null
+++ b/vision-fixhub/court-01/ee7b9594a3ab26f1950628acfd2f8425fc70ac4ea044098a3884f36b4b5b364f.receipt.json
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.md b/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.md
new file mode 100644
index 0000000000000000000000000000000000000000..d668b248181f898e4e06f37f9e9bb6e408abb630
--- /dev/null
+++ b/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.md
@@ -0,0 +1,191 @@
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+REPLY IN SUPPORT OF MOTION TO INTERVENE OF
+Roy BLACK,
+WEINBERG, AND JAY LEFKOWITZ
+Jane Doe 1 and Jane Doe 2 oppose intervention because according to them, proposed
+intervenors Black, Weinberg and Lefkowitz do not have a claim of privilege or confidentiality. Jane
+Doe 1 and Jane Doe 2 contend that all the correspondence at issue was already turned over to them.
+They are mistaken.
+Undersigned counsel spoke with Paul Cassell, one of the lawyers representing Jane Doe 1
+and Jane Doe 2, and he confirmed that he and his clients do not have any of the negotiation and
+settlement letters prepared by the defense attorneys. Additionally, while the settlement and
+negotiation letters prepared by the government have been turned over to Mr. Cassell and his clients
+pursuant to the Magistrate Judge's Order in the related case, that Order specifically maintains the
+confidentiality of those letters and prohibits Jane Doe 1 and Jane Doe 2 from filing them in the
+public record of any proceeding, disclosing them to the media, or otherwise disclosing them to the
+public. Finally, the Magistrate Judge's Order specifically does not rule on whether these settlement
+negotiations are admissible as evidence in any case, holding instead that the ultimate question of
+their admissibility must be put before the judge in each proceeding. [Doe v. Epstein, Case No. 9:08-
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 2 of 7
+CV-80893, DE 226 at 4].
+Jane Doe 1 and Jane Doe 2 now request discovery of the settlement letters that have not yet
+been turned over during discovery [DE S0]; they seek to overturn the Court's previous ruling
+maintaining the confidentiality of the letters that have been turned over to them [DE 51]; and they
+ask the Court to rule on the admissibility of those letters to be used in open court. [DE 51].
+Accordingly, attorneys Black, Weinberg and Lefkowitz properly move to intervene for the limited
+purpose of seeking a protective order, and to respond to the motions of Jane Doe 1 and Jane Doe 2.
+COLORABLE CLAIMS OF PRIVILEGE ARE A TEXTBOOK EXAMPLE OF AN
+ENTITLeMeNT To InTERVEnTION As Of Right
+Jane Doe 1 and Jane Doe 2's attacks on the merits of the privilege and confidentiality claims
+are premature. In ruling on a motion to intervene to protect privileged or confidential information,
+the Court's role is limited to determining whether the proposed intervenor has raised a colorable
+claim of privilege. "Colorable claims of attorney-client and work product privilege [are] ... a
+textbook example of an entitlement to intervention as of right." El-Ad Residences at Miramar
+Condo. Ass'n, Inc. v. Mt. Hawley Ins. Co., 716 F. Supp. 2d 1257, 1262 (S.D. Fla. 2010), quoting In
+re Grand Jury Subpoena (Newparent Inc.), 274 F.3d 563, 570 (Ist Cir. 2001). As Magistrate Judge
+McAliley held in the context of the attorney-client privilege, "[t]he law in this Circuit, and others,
+is clear, that this Court must allow intervention... "in the first instance ... as soon as the [attorneyclient] privilege issue is raised.'" El-Ad Residences, 716 F. Supp. 2d at 1262. Determination of the
+merits of the claim, including the extent of the privilege and its applicability in the underlying action,
+are not appropriately addressed until after intervention. Id. "In this and other circuits," the proposed
+intervenors "need not set forth th[eir] proof before they intervene." Id. Because the motion to
+intervene raises colorable claims of privilege and confidentiality, intervention is appropriate under
+2
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 3 of 7
+Rule 24(a)(2).
+2.
+INTERVENTION Is APPROPRIATE To PROTECT GRAND JURY MATTERS THAT ARE
+NeITHEr DISCOVERABLE Nor ADMISSIBLE
+For these same reasons, Jane Doe 1 and Jane Doe 2's attack on the merits of a claim of
+confidentiality under Federal Rule of Criminal Procedure 6(e), and their complaint that a privilege
+log has not been provided, are premature. If intervention is granted, proposed intervenors will then
+prepare a privilege log. The claim of Jane Doe 1 and Jane Doe 2 that Rule 6(e) extends only to
+matters that occurred inside the grand jury room is off the mark. See Fund for Constitutional Gov't
+v. Nat'l Archives & Records Serv., 656 F.2d 856, 869 (D.C. Cir. 1981) (identity of witnesses,
+substance of testimony, strategy, and direction of the investigation properly protected by Rule 6(e)).
+Jane Doe 1 and Jane Doe 2 contend that attorneys Black, Weinberg, and Lefkowitz could not
+possess any protected grand jury information because that would mean that the U.S. Attorney's
+Office violated Federal Rule of Criminal Procedure 6(e). To the contrary, both the U.S. Attorney's
+Office and defense counsel relied on the ordinary practice of receiving and responding to information
+derived from the grand jury investigation to attempt to resolve a potential future prosecution or threat
+of prosecution, and further relied upon the ordinary protection conferred on such exchange of
+information by Federal Rule of Evidence 410.
+This case is the anomaly. Defense lawyers have a constitutional obligation to explore the
+option of a non-criminal disposition of criminal (or potential criminal) charges. "The plea bargaining
+process is so important in our criminal justice system that a defense lawyer who refuses to negotiate
+with the government will often fail to provide the effective assistance required by the Sixth
+Amendment." United States v. Wells, 394 F.3d 725, 737-38 (9th Cir. 2005). The U.S. Attorney's
+Office regularly discusses with defense counsel information obtained by an investigating grand jury
+3
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 4 of 7
+in order to incentivize plea agreements and other non-criminal dispositions, including deferred
+prosecution agreements and non-prosecution agreements.
+Jane Doe 1 and Jane Doe 2 misunderstand the reach of Rule 6(e). It is not limited to
+transcripts; its ambit includes information derived from grand jury subpoenas and testimony and
+related information. "Courts have interpreted the secrecy requirement imposed by Rule 6(e) to apply
+not only to information drawn from transcripts of grand jury proceedings, but also to anything which
+"may tend to reveal what transpired before the grand jury."" In re Grand Jury Investigation (Lance),
+610 F.2d 202, 216 (5th Cir. 1980). To put in the hands of an adversary who was not involved in the
+settlement negotiations correspondence that by its nature includes a
+discussion of the nature
+of the grand jury's investigation is to upset the expectations of confidentiality possessed by
+prosecutors and defense counsel who regularly engage in |
+open discussions of such matters
+without apprehension that their discussions will end up in the hands of litigants seeking to exploit
+them for purposes extrinsic to Federal Rule of Evidence 410.
+3.
+AN INTEREST IN THE DISPUTE OVER THE CRIME VICTIMS RIGHTS AcT Is NOT
+REQUIRED To INTERVENE To PROTECT PRIVILEGED AND CONFIDENTIAL
+INFORMATION
+Jane Doe 1 and Jane Doe 2 also oppose intervention because they claim that attorneys Black,
+Weinberg, and Lefkowitz do not have an interest "in" the underlying action against the U.S.
+Attorney's Office. They claim that to intervene to assert a claim of privilege or confidentiality, the
+lawyers must show that they have "a direct, substantial, and legally protected interest in the
+enforcement of the Crime Victims Rights Act." [DE 78 at 3] (emphasis added). This is incorrect and
+a strained reading of Rule 24(a) that would defeat the purpose of intervention in almost every case
+and would leave third parties with a claim of privilege or confidentiality with no remedy or redress.
+Rule 24(a) does not require an interest "in" the underlying action; it only requires an interest
+4
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 5 of 7
+"relating to" the underlying action such that disposition of the action may impair or impede the
+movant's ability to protect his interest (a classic case when a claim of privilege is involved):
+RuLe 24. InTERVEnTION
+(a) Intervention of Right.
+On timely motion, the court must permit anyone to intervene who:
+(2) claims an interest relating to the property or transaction that is the
+subject of the action, and is so situated that disposing of the action
+may as a practical matter impair or impede the movant's ability to
+protect its interest, unless existing parties adequately represent that
+interest.
+FED. R. CIv. P. 24(a) (emphasis added).
+Proposed intervenors seek a limited intervention to protect against the dissemination of
+clearly protected correspondence exchanged with the government during plea negotiations. Proposed
+intervenors have an interest in protecting their work product and the privileged and confidential
+settlement negotiations with the U.S. Attorney's Office. This interest will be forever impaired if
+intervention is denied and the correspondence and plea negotiations are subject to discovery,
+evidentiary use, and dissemination to the media and the public. Without the right to intervene in the
+underlying action to assert the privilege, third parties like proposed intervenors would suffer the
+injustice of having their privilege and confidentiality claims erased without ever having been heard.
+For these reasons, numerous courts have held that non-parties, including attorneys, must be
+allowed to intervene in litigation to protect claims of privilege and confidentiality. See In re Grand
+Jury Matter (ABC Corp.), 735 F.2d 1330, 1331 (11th Cir. 1984); Appeal of Hughes, 633 F.2d 282,
+286 (3d Cir. 1980) ("The governing rule in these circumstances is that the possessor of the claimed
+privilege or right may intervene to assert it"); Sackman v. Liggett Group, Inc., 167 F.R.D. 6, 20-21
+5
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 6 of 7
+(E.D.N.Y. 1996).
+4.
+CONCLUSION
+The Court should grant the motion to intervene because proposed intervenors have made
+colorable claims of privilege and confidentiality concerning correspondence exchanged with the
+government during plea negotiations.
+
+
+Case 9:08-cv-80736-KAM Document 80 Entered on FLSD Docket 05/12/2011 Page 7 of 7
+We certify that on May 12, 2011, the foregoing document was filed electronically with the
+Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office: (305) 371-6421
+Fax: (305) 358-2006
+By -
+/S/
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+JACKIE PERCZEK, ESQ.
+Florida Bar No. 0042201
+On Behalf of Intervenor Roy Black
+G. WEINBERG, P.C.
+20 Park Plaza
+Suite 1000
+Boston, 02116
+Office: (617) 227-3700
+Fax: (617) 338-9538
+By,
+/S/
+G. WEINBERG, ESQ.
+Massachusetts Bar No. 519480
+On Behalf of Intervenor
+Weinberg
+KIRKLAND & ELLIS, LLP
+601 Lexington Avenue
+New York, New York 10022
+Office: (212) 446-4970
+Fax: (212) 446-4900
+By
+/S/
+JAY P. LEFKOWITZ, ESQ.
+New York Bar No. 2192425
+On Behalf of Intervenor Jay Lefkowitz
+7
diff --git a/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.receipt.json b/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a6a371f12174b9f743ec4e64f2c51beb6ad2a6d0
--- /dev/null
+++ b/vision-fixhub/court-01/eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "eecf7820056006952ed24d9557d5282bce03c195b6b89b084d3a9fbb470292cb",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "ece3065656ffce5f47b9264e2202d333b62dbd2afcd75d9369ee11d07ea47ffb",
+  "output_sha256": "cbf57998071ca6c86b7cbad52f1f9239416b614e0f078ee53900e6ede5aba61d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/eef2f688df6f88c99c584ed67d941c4b30eda7ad65cd5b1d9528823ccb2851d7.md b/vision-fixhub/court-01/eef2f688df6f88c99c584ed67d941c4b30eda7ad65cd5b1d9528823ccb2851d7.md
new file mode 100644
index 0000000000000000000000000000000000000000..baad7f37583f9c440f608408ac8e24bb43415d8f
--- /dev/null
+++ b/vision-fixhub/court-01/eef2f688df6f88c99c584ed67d941c4b30eda7ad65cd5b1d9528823ccb2851d7.md
@@ -0,0 +1,182 @@
+Case 9:08-cv-80381-KAM Document 45
+Entered on FLSD Docket 09/04/2008 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+/
+MOTION TO DISMISS
+Defendant Jeffrey Epstein, pursuant to Rule 12(b) of the Federal Rules of
+Civil Procedure and Rule 7.1(A) of the Local Rules for the Southern District of
+Florida, moves to dismiss Count I of plaintiff's complaint,' and states as follows:
+' The time to answer the remaining allegations of the complaint is tolled pending the Court's
+ruling on the present motion. See Beaulieu v. Bd. of Trustees of Univ. of W. Fla., No.
+3:07cv30/RV/EMT, 2007 WL 2020161, * 2 (N.D. Fla. July 9, 2007) (holding that defendant's
+partial motion to dismiss "automatically extends its time to answer ... until after the court has
+ruled on [its] motion to dismiss"); Finnegan v. Univ. of Rochester Med. Ctr., 180 F.R.D. 247,
+249 (W.D.N.Y. 1998) (concluding "that the filing of a motion that only addresses part of a
+complaint suspends the time to respond to the entire complaint, not just to the claims that are the
+subject of the motion");
+Iv. Berry College, Inc., No. Civ.A. 4:96CV338-HLM, 1997 WL
+579166, *1 (N.D. Ga. July 3, 1997) (noting that there is significant case law to support the
+position that "when a defendant files a Rule 12(b) motion to dismiss, addressing only some of
+the claims contained in the plaintiff's complaint, the defendant is not required to file an answer
+until the court rules on the motion to dismiss").
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 2 of 7
+ALLEGATIONS IN PLAINTIFF'S COMPLAINT
+This action arises out of the alleged assault of the plaintiff. According to the
+allegations in her complaint, the plaintiff went to Mr. Epstein's house to give him
+"a massage for monetary compensation" (Compl. 9| 12), where Mr. Epstein
+allegedly assaulted her "in violation of Chapter 800 of the Florida Statutes."
+(Compl. 118).
+The plaintiff tries to assert a claim for sexual assault (Compl. 911 15-19.)
+This theory of liability, however, cannot be supported by the allegations in the
+complaint. In fact, even if everything in the complaint were true, recovery against
+Jeffrey Epstein, for Count I, under any formulation, is impossible under Florida
+law. Accordingly, this count must be dismissed.
+ARGUMENT
+A motion to dismiss under Fed. R. Civ. P. 12(b)(6) should be granted when a
+court cannot identify "each of the material elements necessary to sustain a
+recovery under some viable legal theory." Snow v. DirectTV, Inc., 450 F.3d 1314,
+1320 (11th Cir. 2006) (quoting Roe v. Aware Woman Ctr. For Choice, Inc., 253
+F.3d 678, 684 (11th Cir. 2001)). Moreover, a court should dismiss a complaint
+"when, on the basis of a dispositive issue of law, no construction of the factual
+allegations will support a cause of action." Marshall County Bd. of Educ. v.
+Marshal County Gas Dist., 992 F.2d 1171, 1174 (11th Cir. 1993). "[To survive a
+2
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 3 of 7
+motion to dismiss, plaintiffs must do more than merely state legal conclusions;
+they are required to allege some specific factual bases for those conclusions ....."
+Holt v. Crist, No. 06-14617, 2007 WL 1156938, *2 (11th Cir. Apr. 19, 2007). As
+such, "conclusory allegations, unwarranted deductions of facts or legal conclusions
+masquerading as facts will not prevent dismissal." Snow, 450 F.3d at 1320.
+I.
+Count I Fails to State a Cause of Action For Assault Recognized by
+Florida Law.
+The plaintiff attempts to plead a cause of action against Mr. Epstein for
+"sexual assault" based on a "violation of Chapter 800 of the Florida Statutes'? for
+the "lewd and lascivious acts committed by Epstein upon Jane Doe." (Compl. 9
+18.) Plaintiff cannot assert a cause of action for "violation of Chapter 800, Florida
+Statutes" because there is no private right of action under that Chapter. See
+generally Am. Home Assurance Co. v. Plaza Materials Corp.., 908 So. 2d 360, 374
+(Fla. 2005) (observing that "not every statutory violation carries a civil remedy")
+(citing Villazon v. Prudential Health Care Plan, Inc., 843 So. 2d 842, 852 (Fla.
+2003)). See also, e.g., Miami Herald Publ'g Co. v. Ferre, 636 F. Supp. 970 (S.D.
+Fla. 1985) (
+C.J.) (holding that violation of Florida's criminal extortion
+statute does not give rise to a civil cause of action for damages).
+2 Chapter 800, Florida Statutes, is entitled, "Lewdness; Indecent Exposure."
+3
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 4 of 7
+CASE NO.: 08-80381-CIV-MARRA1
+Where a plaintiff brings a civil action pursuant to a criminal statute that
+provides no civil remedy, her complaint is properly dismissed for failure to state a
+cause of action. See Mantooth v. Richards, 557 So. 2d 646, 646 (Fla. 4th DCA
+1990) (per curiam) (affirming dismissal of plaintiff's claim for parental kidnapping
+where "the mentioned statutes concern only criminal violations and do not afford
+a civil remedy") (citation omitted) (emphasis added). Accordingly, the plaintiff's
+claim for sexual assault against Mr. Epstein, pursuant to a violation of Chapter
+800, Florida Statutes, must be dismissed.
+Should the Court look beyond the plain language of the plaintiff's complaint
+and construe Count I as a claim for common-law assault, that claim would also
+fail. As the court explained in Lay v. Kremer, 411 So. 2d 1347, 1349 (Fla. Ist
+DCA 1982), an assault is "an intentional, unlawful offer of corporal injury to
+another by force, or force unlawfully directed toward another under such
+circumstances as to create a fear of imminent peril, coupled with the apparent
+present ability to effectuate the attempt." An assault thus requires "an affirmative
+act—a threat to use force, or the actual exertion of force."
+v. Atl. Fed.
+Sav. & Loan Assoc., 454 So. 2d 52, 54 (Fla. 4th DCA 1984) (affirming dismissal of
+assault claim where there was no affirmative act).
+In this case, there is no such affirmative act. The only thing that Mr. Epstein
+is alleged to have said to Jane Doe is to "remove [her] clothes and give him a
+4
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 5 of 7
+CASE NO.: 08-80381-CIV-MARRA
+massage." (Compl. 1| 12.) These allegations fall far short of an "offer of corporal
+injury by force." There are no allegations that Jane Doe was placed in any fear of
+imminent peril.
+Gatto v. Publix Supermarket, Inc., 387 So. 2d 377, 379 (Fla. 3d
+DCA 1980) (holding that where there was no evidence to show that Gatto was
+placed in fear of imminent peril, there was no assault). Thus, there was no assault.
+Accordingly, because the plaintiff has failed to plead a cause of action for
+assault recognized in Florida, Count I against Mr. Epstein must be dismissed.
+Conclusion
+For the reasons set forth herein, Defendant Jeffrey Epstein respectfully
+requests that Count I of the plaintiff's complaint be dismissed.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By:
+/s/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+5
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 6 of 7
+ATTERBURY, GOLDBERGER &
+WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN, LLP
+15 N. Flagler Drive, Suite 40(
+Vest Palm Beach, Florida 3340
+Tel. 561 842 2820
+Fax. 561 515 3148
+By: Robert D. Critton, Esq.
+Fla. Bar No. 224162
+critton@bclclaw.con
+Michael J. Pike, Esc
+Fla. Bar No. 617296
+mpike@bclclaw.com
+Attorneys for Defendant Jeffrey Epstein
+6
+
+
+Case 9:08-cv-80381-KAM Document 45 Entered on FLSD Docket 09/04/2008 Page 7 of 7
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1
+Undersigned counsel has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+/s/ Michael R. Tein
+Michael R. Tein
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on September 4, 2008, I electronically filed the
+foregoing document with the Clerk of Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all individuals on the following
+service list via transmission of Notices of Electronic Filing generated by CM/ECF.
+Is/ Michael R. Tein
+Michael R. Tein
+Service List
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+7
\ No newline at end of file
diff --git a/vision-fixhub/court-01/eef2f688df6f88c99c584ed67d941c4b30eda7ad65cd5b1d9528823ccb2851d7.receipt.json b/vision-fixhub/court-01/eef2f688df6f88c99c584ed67d941c4b30eda7ad65cd5b1d9528823ccb2851d7.receipt.json
new file mode 100644
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+  "engine": "marble-apple-vision",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.md b/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.md
new file mode 100644
index 0000000000000000000000000000000000000000..d58fa053a91d7e18413352d76d1e38af761bbbf5
--- /dev/null
+++ b/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.md
@@ -0,0 +1,35 @@
+Case 1:20-cv-02365-LJL-DCF Document 24 Filed 05/03/21 Page 1 of 1
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+Sanders LLP
+troutman.com
+troutman"
+pepper
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+May 3, 2021
+VIA ECF
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re:
+Jane Doe v. Darren . Indyke and Richard D. Kahn, in their capacities as
+the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF
+Dear Judge Freeman:
+Pursuant to the Court's September 4, 2020 Order (ECF No. 15), Plaintiff and
+Defendants Darren |. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein, jointly submit this status report.
+Plaintiff has submitted her claim to the Epstein Victims' Compensation Program
+(the "Program"), which is currently being considered. Should Plaintiff resolve her claims
+against Defendants via the Program, the parties will thereafter promptly discontinue this
+action with prejudice.
+To preserve the parties' resources and in the interests of judicial economy, the
+parties respectfully request that this case remain stayed at this time.
+Respectfully submitted,
+/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)
diff --git a/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.receipt.json b/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5d24303cf1d65293539883eaa6a2f8c2cb5eaf05
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+++ b/vision-fixhub/court-01/ef0e832f877bec04655d36efaf6222c76cde918fb87f81881798772ea89baed2.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "fc3892bcb2c0ea82150729098725d1d564e240870e1af38e25fdec6bbee3bf53",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69.md b/vision-fixhub/court-01/ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69.md
new file mode 100644
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+++ b/vision-fixhub/court-01/ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69.md
@@ -0,0 +1,272 @@
+From:
+Subjecti
+Fling 167810548 Processed - Appelate Courts
+Wadrenday, March 1, 2023 3:20:43 PM
+This Message Is From an External Sender
+This message came from cutside your arganization.
+Dear Cristina Riosa:
+All electronic filers are obligated to register as eDCA users and are responsible for ensuring their email
+addresses are current in their eDCA accounts. The six District Courts of Appeal use eDCA to serve all acknowledgment
+letters, orders, opinions, mandates, and other outgoing filings on electronic filers through a link provided by eDCA Casemail.
+To register or update your email address please visit eDCA through court's website.
+This email verifies the processing of your MOTIONS New Notice of Appeal by the Office of the Clerk, Fourth District Court of
+Appeal.
+Status: Docketed
+Florida Courts E-Filing Portal Reference Number: 167810948
+Filing Date/Time: 03/01/2023 01:56:35 PM
+Case Number:
+Case Name: DAVE ARONBERG, as State Attorney of Palm Beach County, Florida vs. CA FLORIDA HOLDINGS, LLC, Publisher
+of THE PALM BEACH POST
+Documents
+#
+1
+Fees
+Document Type
+MOTIONS New Notice of
+Appeal
+Status
+Accepted
+Filing Date Not Docketed Reason
+03/01/2023
+Your Attachment
+2019CA014681.pdf
+#
+2
+Description
+APPEAL Regarding Civil Matters Other
+Notice, New Notice Of Appeal
+Amount
+$00
+$.00
+Memo:
+Statutory Convenience Fee: $0.00
+Total Paid: $0.00
+Fee Status: Processed
+Paid By: Fee Owed
+Order $:
+Financial ID:
+This is a non-monitored email. If you have questions about this filing, please contact the Office of the Clerk, Fourth District
+Court of Appeal, at (561) 242-2000.
+Thank you,
+Office of the Clerk
+Fourth District, Court of Appeal
+FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK 03/01/2023 03:46:31 PM
+
+
+Fourth District Court of Appeal
+110 South Tamarind Avenue
+West Palm Beach, Florida 33401
+(561) 242-2000
+ACKNOWLEDGMENT OF NEW CASE
+DATE: March 03, 2023
+STYLE:
+DAVE ARONBERG, as State
+Attorney of Palm Beach
+County, Florida
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH
+POST
+4DCA#: 23-0536
+The Fourth District Court of Appeal has received the Notice Of Appeal reflecting a filing date of March 1, 2023.
+The county of origin is Palm Beach.
+The lower tribunal case number provided is 502019CA014681.
+Fee Status: Not Required
+Civil
+Other
+Final
+Case Type:
+The Fourth District Court of Appeal's case number must be utilized on all pleadings and correspondence filed
+in this cause. Moreover, ALL PLEADINGS MUST INCLUDE THE ATTORNEY'S FLORIDA BAR NUMBER
+and a physical address.
+ELECTRONIC FILING IS MANDATORY FOR ALL ATTORNEYS
+Incoming filings must be submitted through the Florida Courts E-Filing Portal.
+Outgoing filings will be sent by the Court through eDCA Casemail (https://edca.4dca.org).
+Attorneys who have not registered for eDCA will not receive paper documents from the court.
+NEW FONT REQUIREMENTS EFFECTIVE JANUARY 1, 2021
+All computer-generated documents are required to be filed in either Arial 14-point font or Bookman Old Style 14-
+point font. See Fla. R. App. P. 9.045(b).
+FILING FEES MAY NOW BE PAID ELECTRONICALLY THROUGH THE FLORIDA COURTS E-FILING PORTAL - SEE
+THE COURT'S WEBSITE FOR INSTRUCTIONS
+CC:
+Arthur
+Michael J. Grygiel
+Stephen A. Mendelsohn
+Douglas Wyler
+Nina D. Boyajian
+Clerk Palm Beach
+Lauren R. Whetstone
+Richard J. Scholz
+
+
+tw
+NOT A CERTIFIED COPY
+
+
+FOURTH DISTRICT COURT OF APPEAL
+SA CETO SINCE
+OF
+NOTICE TO ATTORNEYS AND TO PARTIES REPRESENTING THEMSELVES
+REVISED OCTOBER 1, 2022
+Please read the following court policies and requirements concerning the case you have filed
+IMPORTANT REMINDERS
+•
+FILING FEES MAY NOW BE PAID ELECTRONICALLY THROUGH THE FLORIDA COURTS E-
+FILING PORTAL - SEE THE COURT'S WEBSITE FOR INSTRUCTIONS.
+• PURSUANT TO ADMINISTRATIVE ORDER 2014-1, ALL EMERGENCY FILINGS MUST BE
+ACCOMPANIED BY A SEPARATELY FILED REQUEST FOR EMERGENCY TREATMENT.
+• Electronic filing is mandatory for all attorneys. Incoming filings must be submitted through the Florida
+Courts E-Filing Portal. Outgoing filings will be sent by the court through eDCA Casemail. Please visit
+edca.4dca.org to register for eDCA. The court will not send paper documents to non-registered
+attorneys.
+• Parties representing themselves without
+a
+lawyer may file electronically. Please visit
+www.myflcourtaccess.com to register.
+• Parties representing themselves withouta lawyer who are not in custody and have not been excused
+from e-mail service pursuant to Florida Rule of General Practice and Judicial Administration
+2.516(b)(1(D) must register for eDCA/to receive filings issued by this court by e-mail using their
+designated primary e-mail address. Please visit edca.4dca.org to register for eDCA.
+ELECTRONIC FILING TIPS, COMPUTER GENERATED DOCUMENTS, AND APPENDICES
+• All electronic filings are required to be "filed in a format capable of being electronically searched." Fla.
+R. Gen. Prac. & Jud. Admin. 2.520(b). Searchable PDFs may be created by:
+• For documents composed using a word processing application, using the "Save As" function to save
+the document directly to PDF format. There is no need to run Optical Character Recognition
+T'OCR*) to make the document searchable - it is done automatically.
+• For Scanned documents, use the Adobe Acrobat "Text Recognition" function. Adobe Acrobat can
+also be used to check and fix suspected OCR errors.
+• Computer-generated documents which do not comply with the font requirements of Florida Rule of
+Appellate Procedure 9.045(b) and electronically filed appendices which do not comply with Florida
+Rule of Appellate Procedure 9.220(c) will be stricken.
+NOTICES
+1. MOTIONS (Fla. R. App. P. 9.300)
+• Excessive motion practice is strongly discouraged.
+• Any record material supporting a motion shall be contained in an appendix with the motion.
+
+
+• Motions concerning preparation of the record or brief, extensions of time (see paragraph 2
+below), or to reschedule oral argument, shall contain a certificate that opposing counsel has
+been consulted and shall state whether opposing counsel has an objection to the motion.
+Attempts to contact opposing counsel are not sufficient.
+• Any response to a motion shall be promptly served, and in any case not later than 15 days after
+service of the motion.
+• Motions for extension of time or to supplement the record may be ruled on without waiting for
+a response.
+• No reply to the response will be considered unless specifically authorized by this Court.
+Any unauthorized reply will be stricken without consideration.
+2. EXTENSIONS OF TIME
+• Limited extensions for briefs can be granted by the Clerk, unless the motion certifies that the
+opposing party opposes the motion and the opposing party files a response which contains a
+valid opposition to the motion.
+• The court may limit extensions in any appeal. See paragraph 1 above for motion requirements.
+• In lieu of an agreed motion for extension of time to file an initial, answer, or reply brief, the
+court will accept a notice from a party that the parties have agreed to a specific extension of
+time. An agreed notice will be accepted for up to a total of 90 days for an initial or answer brief,
+and 15 days for a reply brief. The notice need not be signed by both parties. No order will issue
+from the court: please check the docket entry This procedure shall not apply to appeals from
+adoptions, dependency, termination of parental rights, nonfinal orders, or any expedited or
+emergency appeal. See Administrative Order No. 2018-1 on the court's website for details as to
+the form of the notice.
+•
+Extension requests beyond the time framés set forth above, whether the prior extensions
+were by agreed notice or by order granting an extension, are disfavored and will not be
+granted absent a detailed explanation for why the brief was not filed and a showing of
+extraordinary circumstances.
+3.
+SERVICE OF FILINGS (Fla. R. App. P. 9.420)
+• All filings, e.g., motions, petitions, notices, briefs, appendices, etc., must contain a certificate of
+service. All certificates of service, including those on notices of appeal, must contain the name
+and physical address of the attorney or party served, not just the e-mail address. Certificates of
+service must comply with Florida Rule of General Practice and Judicial Administration 2.516(f).
+4. STATUS INQUIRIES
+• Any request for the status of a pending case must be made to the Clerk's Office and may not be
+de to a judge of the court or the personal staff of any judge. Attorneys and parties
+representing themselves may access case documents and dockets for their own cases via eDCA
+Public case dockets for all cases are available online at 4dca.flcourts.gov.
+RELATED CASES - NOTICE OF RELATED CASE
+• All parties shall promptly bring to the court's attention the pendency in this court of any related
+case, or any case involving related issues.
+• In criminal cases where multiple defendants participated in a joint trial, the parties shall notify
+the court of any other appeals, whether pending or concluded, from the same trial.
+
+
+6. TRANSCRIPTS
+• All transcripts submitted as part of the record must appear as one page of transcript per page.
+Four pane transcripts (four pages of transcript on a page) will be rejected.
+7. PHYSICAL EXHIBITS
+• No physical evidence (excluding documents) or outsized exhibits shall be included in the record
+on appeal without the party first requesting permission of the court. It is the responsibility of
+the party to ensure that the lower tribunal clerk has included any relevant documentary
+evidence introduced at trial in the record on appeal.
+8. SUPPLEMENTAL AUTHORITY (Fla. R. App. P. 9.225)
+• A copy of the newly discovered authority should be attached to the notice. The notice should
+also designate clearly the issue to which the supplemental authority is pertinent. The notice
+shall not contain argument, but may identify briefly the issues argued on appeal to which the
+supplemental authorities are pertinent.
+9. ORAL ARGUMENT (Fla. R. App. P. 9.320)
+• A request for oral argument shall be a separate filing, clearly designated as such, and shall
+contain no other subject. It shall not be made as part of a brief or appendix. The request must
+contain a specific but brief reason as to why oral argument is necessary. A request to
+participate in oral argument through communication technology must be included within the
+request for oral argument and must state the reason why oral argument through
+communication technology is requested‹
+• The request for oral argument may contain a designation of 10, 15 or 20 minutes as the amount
+of time requested for oral argument. Oral argument for each side shall not exceed 20 minutes.
+• At any time before oral argument the court in its discretion may dispense with, limit or expand
+the time for oral argument asit deems appropriate to the issues raised.
+• Cases without oral argument are subject to the same review, analysis and consideration by a
+three judge panel as are cases that are orally argued.
+10. SCHEDULING CONFLICTS
+• Calendar conflicts shall be resolved in accordance with Florida Rule of General Practice and
+Judicial Administration 2.550. "Notices of Unavailability" are unauthorized and will be
+automatically stricken. Requests for continuances of oral argument must be based on either a
+substantial commitment preexisting the receipt of the oral argument calendar or an emergency
+situation.
+11. REHEARING
+• Although motions for rehearing are permitted by Florida Rule of Appellate Procedure 9.330,
+they should be rare. See Lawyers Title Ins. Corp. v. Reitzes, 631 So. 2d 1100, 1100-01 (Fla. 4th DCA
+1993).
+• The court strongly discourages the practice of routinely filing such motions or the filing of those
+which merely re-argue the merits or question the court's decision. Where there has been an
+award of attorney's fees on appeal in connection with our decision on the merits, additional fees
+will be awarded upon a denial of a motion for rehearing.
+
+
+12. RIGHTS OF CHILDREN (Fla. R. App. P. 9.146)
+• Cases involving adoption, termination of parental rights, and those involving families and
+children in need of services are expedited. Consult the rule for the time and procedure
+requirements. Cases relating to child custody, visitation privileges, or other substantial interests
+of children will be expedited upon proper motion.
+13. ATTORNEYS NOT LICENSED IN FLORIDA
+• Attorneys who are members in good standing in other jurisdictions may be granted permission
+by court order to appear in proceedings in this court. See Fla. R. App. P. 9.440(a); Fla. R. Gen.
+Prac. & Jud. Admin. 2.510.
+• Pursuant to Section 35.22(3)(a), Florida Statutes, the Clerk is required to collect a $100 filing fee
+from each attorney appearing pro hac vice, an order for the payment of which will be issued
+when and if the motion to appear is granted. An additional fee of $250 is required by the
+Florida Bar.
+14. MAINTENANCE OF EDCA EMAIL ADDRESSES AND CHANGES OF ADDRESS
+• eDCA users must ensure that their primary and secondary email addresses are up to date.
+• Parties representing themselves who receive paper filings must promptly notify this court of
+any change of address.
+15. DROP BOX
+• The Court does not maintain a physical drop box.
+If you are representing yourself or an
+attorney exempt from electronic filing and would like your paper filing to be clocked-in and
+filed for the previous business day, you must file the document at the Clerk's Office BEFORE
+9:00 A.M. If it is after 9:00 A.M., no filings will be clocked-in for the previous business day.
+• IMPORTANT: The drop box does not extend jurisdictional time limits. See Capone v. Fla. Board
+of Regents, 774 So. 2d 825 (Fla. 4th DCA 2000). Petitions for original writs, notices of appeal, and
+notices to invoke discretionaty jurisdiction will be clocked-in for the date they are electronically
+filed or received as a paper filing in the Clerk's Office.
+16. AMERICANS WITH DISABILITIES ACT
+• If you are a person with a disability who needs any accommodation in order to participate in
+this proceeding, you are entitled, at no cost to you, the provision of certain assistance.
+• At least 2 days before your scheduled court appearance, or immediately upon receiving this
+notification if the time before the scheduled appearance is less than 7 days, please contact:
+Marshal Daniel DiGiacomo
+Fourth District Court of Appeal
+110 South Tamarind Ave.
+West Palm Beach, FL 33401
+Telephone (561) 242-2000; (800) 955-8771 (TDD) or (800) 955-8770 (V) via Florida Relay Service
+If you are hearing or voice impaired, call 711.
diff --git a/vision-fixhub/court-01/ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69.receipt.json b/vision-fixhub/court-01/ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6a61152cc458d7226a440c398350b9e7e1791732
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@@ -0,0 +1,14 @@
+{
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+  "doc_id": "ef103be0676ee7a38d43d4f1ac5ce5f8cd44a3425ee3cd4d7ca3d13cfad75f69",
+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9804555adaa37b9ad9e79e76a909151b0957b38872cc8fdc0821ec12b2cc26ed",
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ef256821d49f587594303018327dfaded68c59c8f8da1ca84d3227008e3c8780.md b/vision-fixhub/court-01/ef256821d49f587594303018327dfaded68c59c8f8da1ca84d3227008e3c8780.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c638a8d9b6a132f5f1af8bfab4714b4d669be3a
--- /dev/null
+++ b/vision-fixhub/court-01/ef256821d49f587594303018327dfaded68c59c8f8da1ca84d3227008e3c8780.md
@@ -0,0 +1,53 @@
+Case 9:08-cv-80232-KAM Document 71-1 Entered on FLSD Docket 04/17/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80119-MARRA
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80232-KAM Document 71-1 Entered on FLSD Docket 04/17/2009 Page 2 of 2
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- 80993-CIV-MARRA/
+ORDER
+Upon Plaintiffs' Unopposed Motion for Enlargement to Time to File Memorandum in
+Opposition to Motions to Compel Plaintiffs to Respond to Defendant's First Request to Produce and
+First Set of Interrogatories, et al., and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+until April 29, 2009, to respond to the Defendant's Motions to Compel, et al.
+DONE AND ORDERED in
+in Ft. Lauderdale, Broward County, Florida, this
+day of
+_ 2009.
+DISTRICT COURT JUDGE
diff --git a/vision-fixhub/court-01/ef256821d49f587594303018327dfaded68c59c8f8da1ca84d3227008e3c8780.receipt.json b/vision-fixhub/court-01/ef256821d49f587594303018327dfaded68c59c8f8da1ca84d3227008e3c8780.receipt.json
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ef44fc21730b6c31c2929ca86fed0215719209a9e0a60bf346f0039954fddaa1.md b/vision-fixhub/court-01/ef44fc21730b6c31c2929ca86fed0215719209a9e0a60bf346f0039954fddaa1.md
new file mode 100644
index 0000000000000000000000000000000000000000..c4689daf91ce2dc5f395d4d46851a9326c190869
--- /dev/null
+++ b/vision-fixhub/court-01/ef44fc21730b6c31c2929ca86fed0215719209a9e0a60bf346f0039954fddaa1.md
@@ -0,0 +1,189 @@
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA-|
+JANE DOE NO. 4,
+V.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR
+PROTECTIVE ORDER AGAINST PIECEMEAL DEPOSITIONS OF
+JANE DOE NO.4, MOTION TO CONSOLIDATE CASES FOR PURPOSES
+OF DISCOVERY, AND INCORPORATED MEMORANDUM OF LAW IN
+SUPPORT
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his
+Response to Plaintiff's Motion for Protective Order Against Piecemeal Depositions of Jane Doe
+No.4, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated Memorandum
+of Law (hereinafter, the Motion"), with incorporated memorandum of law. In support,
+Defendant states:
+RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO
+DEPOSITION OF JANE DOE. NO. 4 AND MOTION TO CONSOLIDATE
+a. The Depositions
+Plaintiff, Jane Doe No. 4, filed this federal lawsuit against Defendant, Jeffrey Epstein. In
+other separate matters, Plaintiffs, Jane Does, Nos. 2, 3, 5-7, filed their own separate lawsuits
+against Defendant, Jeffrey Epstein. Plaintiff's counsel represents all Jane Does in cases Jane
+Doe Nos. 2 through 7 before this court.
+
+
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 2 of 7
+Page 2
+Plaintiff, Jane Doe. No. 4, served answers to interrogatories wherein she lists certain
+witness that may have knowledge regarding the facts and allegations alleged in her complaint.
+See page three of Plaintiff's Motion wherein she admits that two of the other Plaintiff's in related
+cases talked to her about giving massages. In particular, the response to interrogatory number 16
+states that Jane Doe numbers 3 and 7 talked about giving massages. Defendant seeks to take the
+deposition of Jane Doe. No. 4 as a witness in those matter (or any other matter she has
+knowledge of) and as a party in her own case, which she is an unidentified Plaintiff traveling
+under Jane Doe. No. 4.
+In an attempt to resolve this matter by letter correspondence, Defendant agreed and
+offered only to take the deposition of Jane Doe. No. 4 as a witness in all Jane Doe 2-7 cases only
+one time and separately one time as a Party Plaintiff in this matter in which Jane Doe No. 4 filed
+against Jeffrey Epstein. While this is a reasonable compromise in that Defendant has agreed not
+to take her deposition three (3) times as Plaintiff suspected, Plaintiff's counsel refused to agree.
+Plaintiff cannot file a lawsuit and then expect this court to protect her from being deposed as a
+party for the time period proscribed under the federal rules while at the same time asking this
+court to limit or prevent her deposition testimony as a witness in the instant matter or other Jane
+Doe matters where she has been identified as a witness.
+It is well settled that a Defendant may take the deposition of a party and/or a witness
+before trial. Rule 26, Fed.R.Civ. P.., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp.,
+43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2-7 commenced separate civil actions upon the
+filing of same against Jeffrey Epstein. Therefore, Defendant is entitled to depose Jane Doe Nos.
+2 - 7 in their own cases at least one time for the proscribed time periods and then as a witness in
+the instant matter or any matter they have knowledge of as reflected in the interrogatory
+
+
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 3 of 7
+Page 3
+responses or the pleadings. Therefore, Defendant has a right to depose each party-plaintiff
+separately and then as a witness at least once. Deposing Jane Doe No. 4 as a witness in the other
+matters is necessary as that deposition will be tailored toward facts known by Jane Doe. No. 4 as
+those facts pertain to Jane Doe. Nos. 2, 4-7 claims in their complaints as opposed to the facts
+alleged by Jane Doe. No. 4 in this individual action.
+Plaintiff's attorneys claim that sitting for more than one deposition will be traumatizing
+does not modify the rules and/or the law with regard to the right to take party and witness
+depositions. Plaintiff offers no expert medical or psychological support, by an affidavit of an
+expert or the Plaintiff herself, to support her position. In almost all instances, none of the
+Plaintiff's sought or received any psychological counseling until the concept of a lawsuit and
+money was introduced. A party may, by oral questions take the deposition of any person,
+without leave of court. Rule 30, Fed.R. Civ.,P. Conducting these depositions separately will
+allow for the proper preparation as to each deponent's knowledge as that knowledge pertains to
+the specific case at hand (i.e., whether the deponent is a witness and/or a party plaintiff). Again,
+Defendant is willing to conduct one (1) deposition in connection with each matter before this
+court wherein a party to one matter is listed as a "witness" in another. That is, if Jane Doe No. 4
+has knowledge as a witness to one or more matters, one "witness" deposition will be held.
+However, Defendant is also permitted to separately take a party-plaintiff deposition of any partyplaintiff that happens to be a witness of and/or have knowledge of any other party-plaintiff's
+deposition. As such, only two depositions will occur.
+There is no legal basis supporting Plaintiff's proposition that Defendant not be allowed to
+take the deposition of Jane Doe. No. 4 as a witness in the other matters and as a party-plaintiff in
+Jane Doe. No. 4's separately filed action. In fact, Plaintiff's theory flies in the face of the
+
+
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 4 of 7
+Page 4
+Federal Rules.
+Despite Plaintiff's contention, Defendant is not attempting to depose or call a
+witness for a second deposition without leave of court. Quite the opposite, Plaintiff is simply
+doing what the rules allow for - the taking of a deposition of a party and a witness.
+b. Consolidation For Discovery Is Not Practical
+Next, if this case is consolidated for discovery purposes and depositions are limited only
+to one (1) deposition for a party plaintiff and for a witness that happens to be a party plaintiff in
+another matter, then confusion will result and motions in limine will undoubtedly be filed at a
+later date preventing the use of certain testimony at particular hearings and ultimately at trial.
+Further, since there remain separate party-plaintiffs, admissions or answers to discovery by one
+party, arguably, cannot be used by the Defendant in a consolidated discovery matter against
+another party-plaintiff. As such, consolidation in the instant matter is not warranted in that not
+all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911
+F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of
+convenience of some witnesses, actions did not share all witnesses and parties were not
+identical); Borough of Olyphant v. PPL Corporation et al., 153 Fed.Appx. 80, 2005 WL 2673489
+(C.A.3 (P.A.));
+Motor Credit Company v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008).
+Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery
+is not mandatory but that decision remains within the sound discretion of the court. In this
+instance, various Jane Does seek to consolidate the cases for discovery purposes. Very clearly,
+the facts and circumstances, as pled and as is reflected in answers to interrogatories, are different
+for each individual, i.e. the dates, the ages, the events, their experiences, witnesses, medical
+and/or psychological treatment, etc. Each of the Plaintiffs alleged incident history and post
+incident history and background is unique to those individuals. While the Jane Doe Plaintiffs
+
+
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 5 of 7
+Page 5
+may wish to serve a "standard" set of interrogatories, request for production, or any other type of
+discovery, the Defendant's discovery to the individual Plaintiffs, and certainly their responses, is
+unique to that individual. There will be multiple instances where the discovery is applicable only
+to a specific Jane Doe and not all, such as, physicians, psychologists, parents, siblings, friends,
+employers, teachers, individuals with whom the Plaintiff has had relationships - many of these
+depositions will go to damage related issues wherein the Plaintiffs seek millions of dollars in the
+form of compensation.
+There are some instances where the deposition of a particular individual may be
+applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
+Plaintiff's counsel that that particular deposition be used in all cases. However, in a vast
+majority of the instances where discovery, deposition and/or paper discovery is being utilized,
+including subpoena which will be sent to many different sources for each of the six Jane Does,
+consolidation serves no purpose.
+Even if this court consolidated the matters requested by Plaintiff, the undersigned would
+still be entitled to additional time to depose any party-plaintiff that is also listed or who has
+knowledge of any aspect of any other party-plaintiff's claim against Jeffrey Epstein. In addition,
+this Court has before it each of the cases filed by certain Plaintiffs against Jeffrey Epstein.
+Therefore, there is no chance of "conflicting results" as to rulings made by the same court and
+the same judge.
+As such, no true need exists for consolidation. Under Fed.R.Civ.Pro. 42,
+consolidation for discovery is not required, but remains within the sound discretion of the court.
+
+
+Case 9:08-cv-80380-KAM Document 86
+Entered on FLSD Docket 04/17/2009 Page 6 of 7
+Page 6
+Il. Conclusion
+In sum, if Jane Doe No. 4 has knowledge as a witness to one or more matters, one
+"witness" deposition will be held as to her witness knowledge. However, Defendant is also
+permitted to separately take Jane Doe. No. 4's deposition as a party-plaintiff.
+WHEREFORE, Defendant requests that this Court deny the Motion, enter an order
+allowing for the relief requested herein and for such other relief as this court deems just and
+proper.
+OBERT D. CRITTON, JR., ESQ
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+cleo not cout us nec fer: alon the is that the freice Lid cumen a heir specied by
+CM/ECE on this / Zday of Upe
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssmn@sexabuseattorney.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #4
+Respectfully submitted,
+
+
+Case 9:08-cv-80380-KAM Document 86 Entered on FLSD Docket 04/17/2009 Page 7 of 7
+Page 7
+By:
+ele
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
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+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-MARRA/||
+C.M. A.,
+V.
+Plaintiff,
+Defendants,
+Defendant, Jeffrey Epstein's Motion To Stay And Or Continue Action For Time Certain Based On
+Parallel Civil And Criminal Proceedings With Incorporated Memorandum Of Law
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby moves this Court for the entry of an order staying or continuing
+this action for a time certain (i.e., until late 2010 when the NPA expires), pursuant to the
+application of the Fifth Amendment of the U.S. Constitution and the fact that a parallel
+proceeding is ongoing and being investigated. In support of his motion, EPSTEIN states:
+I.
+Introduction
+At the outset, EPSTEIN notes this Court's prior Order, dated December 16, 2008,
+(Document 28), in which this Court denied a motion for stay brought by Defendant's prior
+counsel. In that instance, Defendant's counsel requested a mandatory stay under 18 U.S.C.A.
+§3509(k) which the court denied. In denying the request for the stay, this Court stated that a
+discretionary stay was not appropriate at the time the order was entered but also stated, in part,
+that "Any such issues shall be resolved as they arise in the course of litigation.". As discussed
+herein, "special circumstances" now exist which, in the "interests of justice," merit the entry of a
+stay of this civil action until the criminal matter in the 15th Judicial Circuit is "closed" in
+
+
+Page 2
+accordance with the United States Attorney's Office ("USAO") Non-Prosecution Agreement
+("NPA") and until the NPA expires.
+Moreover, EPSTEIN was indicted by a grand jury in or around July 2006. See Exhibit
+"A". The Non-Prosecution Agreement is part of the record in connection with that indictment,
+which is signed by the State Attorney of the 15" Judicial Circuit in and for Palm Beach County,
+Florida ("SAO"). In fact, the NPA acknowledges the investigation performed by the SAO.
+Further, the USAO was present at the Plea hearing whereby the NPA was made part of the
+record. Thus, there is no question that a parallel criminal matter exists in that the SAO's case
+remains open and the NPA lives along side it, which places EPSTEIN under great scrutiny by the
+USAO. The NPA actually places an affirmative duty upon EPSTEIN to undertake discussions
+with the SAO to ensure compliance with the NPA. That check and balance, therefore, remains in
+the hands of the SAO, which has a parallel criminal proceeding. Here, the threat of prosecution
+is real, substantial, and present should the USAO determine that EPSTEIN somehow violated the
+NPA. As discussed below, because the NPA fails to define what constitutes a breach, the USAO
+has apparently taken it upon itself to determine whether a breach has occurred and whether to
+seek criminal prosecution. In fact, the USAO has already attempted to claim violations of the
+NPA due to, among other things, EPSTEIN defending the civil actions against him. Clearly, it is
+NOT simply EPSTEIN's choice as to whether he violates the NPA - that discretion apparently
+lies with the USAO. For this reason alone, a stay is required until the NPA expires.
+The difference between this Motion and the prior motion to stay is solely due to the
+ripeness of the issues discussed herein.
+2
+
+
+Cas@a9:08:08-80801-KAMAMD@oument5b9-1Emere&@nF|SBD0k9t@33422099 Bage 3 8* 27
+Page 3
+Il.
+THE NPA
+By its terms, the NPA took effect on June 30, 2008 and expires by those same terms in
+late 2010 so long as EPSTEIN complies with the terms and conditions - violations of which
+remain undefined. The NPA, which remains under seal, outlines various obligations on the part
+of EPSTEIN including, but not limited to, pleading guilty to the Indictment and Information
+before the 15" Judicial Circuit, recommendations for his sentencing before the 15"* Judicial
+Circuit, waiver of challenges to the Information filed by the SAO, waiver of right to appeal his
+conviction, agreement not be afforded benefits for gain time, and the agreement to not prosecute
+others listed thereon so long as EPSTEIN does not breach and fulfills the requirements of the
+NPA.
+What the NPA does not outline or define is what constitutes a breach or what act or
+mission constitutes a breach thereof. Therefore, the USAO apparently believes it has the
+discretion to make that unwritten and undefined determination, which places an unreasonable
+burden upon EPSTEIN in defending the civil claims in that he has no idea what the USAO will
+define as a breach in the event he does not assert his 5'* Amendment Rights. As an example, the
+USAO has already claimed that EPSTEIN violated the NPA by:
+1.
+investigating the Plaintiffs (by and though his attorneys) whom brought civil suits
+against him for purposes of defending those civil actions;
+contesting damages in this action and in the other civil actions;
+making statements to the press about this Plaintiff or other Plaintiffs by and
+though his attorneys; and
+3
+
+
+Caspa8:08:08-808301KAMAMD@ument 5199-1EmteredonFESS Dockete 3/84/20009 Page 4 of 15l
+Page 4
+4.
+using the word "jail" instead of "imprisonment" in the plea agreement with SA's
+office.
+See Exhibit "B" Goldberger Affidavit - EPSTEIN's criminal counsel.
+These allegations are silly, unfounded and alleged violations which are not defined as
+violations under the NPA but arrived at by the USAO. Thus, EPSTEIN is left with "Morton's
+Fork" in his side - the undesirable choice of taking the 5"h Amendment and having a judgment
+(summary or otherwise) entered against him in the civil action or the undesirable choice of
+subjecting himself to discovery in the civil action before the NPA expires and, thus, face the
+possibility of criminal prosecution by the USAO based upon some illusory breach deemed by the
+USAO by way of information obtained through civil discovery proceedings. This is inherently
+unfair, the danger is clear, and the playing field is not level in light of the NPA language or lack
+thereof.
+As a result, the threat of criminal prosecution against EPSTEIN by the USAO continues
+presently and through late 2010.
+III. Justice Requires The Entry of A Stay Because Defendant Is Being
+Forced To Choose Between Waiving His 5'h
+Losing This Civil Case And Forfeiting Other Constitutional Guarantees Of
+Due Process And Effective Assistance Of Counsel
+Once the NPA expires, EPSTEIN fully intends to testify to all relevant and nonobjectionable inquiries made to him in discovery be it a deposition, in interrogatories or in
+production requests. (Emphasis Added) However, the current circumstances are such that by
+testifying or responding to discovery, EPSTEIN will be required to waive his constitutional
+privileges, thereby subjecting himself to criminal prosecution and scrutiny by the USAO as a
+4
+
+
+Page 5
+result of matters alleged in this civil action (and others before this Court and in the State of
+Florida 15'" Judicial Circuit Court, Palm Beach County).
+The special circumstances of this action are such that a stay or continuance for a time
+certain is NOT prejudicial and is required to be entered so that:
+(1) EPSTEIN is not required to waive his Fifth Amendment right against selfincrimination under the United States Constitution resulting in severe prejudice to EPSTEIN in
+pending criminal matters; and
+(2) EPSTEIN is not forced to choose between waiving his Fifth Amendment right against
+self-incrimination or losing the civil case.
+Here, in asserting his Fifth Amendment Privilege, the Plaintiff is afforded an opportunity
+rarely given - that is, to put on only her evidence without any counterevidence from Defendant
+resulting in a judgment of liability against EPSTEIN. This is inherently unfair and precisely the
+special circumstances where "in the interests of justice" a stay is required. Ventura v. Brosky,
+2006 WL 3392207 (S.D. Fla. 2006), citing, United States v. Lot 5, Fox Grove, 23 F.3d 359 (11"
+Cir. 1994). In Ventura, a stay was entered where a Defendant was confronted with issue of
+waiving his 5t Amendment Privilege or to loose a civil case by way of motion for summary
+judgment. Id. Here, EPSTEIN is not requesting a mandatory stay. EPSTEIN only asks that this
+court recognize that "special circumstances" exists in this matter and enter a stay in the "interests
+of justice" and only for a specified period of time (i.e., after the NPA expires). See also
+Securities and Exchange Commission, 755 F.Supp. 1018, 1019 (S.D. Fla. 1990) (Defendant was
+in precarious position while being subject to criminal investigation and reasoning that
+compelling Defendant to speak by ordering an accounting of alleged illicit funds would directly
+5
+
+
+Case 9:08-08-808b-KAMAM Document 5 D9-1 EatemeonFESDDDeR0334/20099 Page 6 of 25
+Page 6
+impinge his right against self-incrimination). The court found it appropriate to grant the request
+for stay. (Emphasis Added).
+Citing to U.S. v. Lot 5, Fox Grove, supra, the Southern District Court, Florida, in
+Ventura v. Brosky, 2006 WL 3392207 (S.D. Fla. 2006), stated -
+The Eleventh Circuit has also created a test for these circumstances, stating that
+where there exists a concurrent civil and criminal proceeding, a court must stay
+a civil proceeding pending resolution of a related criminal prosecution when
+"special circumstances" so require in the "interests of justice."
+(Bold emphasis added). See also United States v. Kordel, 397 U.S. 1, 12 & n. 27, 90 S.Ct. 763,
+769-70 & n.27 (1970). The Ventura Court went on to state that "situations where a defendant in
+both criminal and civil proceedings must choose whether to waive his privilege against selfincrimination or to lose the civil case in summary or default judgment proceedings have met this
+test's burden and warrant a stay." Id. The Ventura court granted the stay. Here, the 15t* Judicial
+Circuit action lives along with the NPA.
+In making a decision to enter such a stay, the court may consider the following factors:
+(I) the interests of the Plaintiffs in proceeding expeditiously with litigation, or any
+aspect of it, and the potential prejudice of Plaintiff to the delay;
+(2)
+the burden which any particular aspect of the proceedings may impose on the
+defendant;
+(3)
+of judicial resources;
+(4)
+(5)
+the convenience of the court in the management of its cases, and the efficient use
+the interests of persons not parties to the civil litigation; and
+the interest of the public in the pending civil and criminal litigation.
+6
+
+
+Page 7
+See U.S. v. Pinnacle Quest International, 2008 WL 4274498 (N.D. Fla. 2008).
+First, in applying the above factors, the Plaintiff in the instant matter will not be
+prejudiced simply by claiming a delay in time. Second, the burden is far greater on the
+EPSTEIN if he is forced to waive his 5" Amendment Privilege or remain silent and have a
+judgment entered against him or choose to testify and face criminal prosecution. Third, efficient
+use of judicial resources would be rendered upon a stay by way of preventing an appeal if such a
+stay is not entered. The Court has broad discretion to enter such a stay. Fourth, the interests of
+the individuals outlined in the NPA will be served because EPSTEIN's fulfillment of NPA
+alleged obligations is determinative upon whether the USAO prosecutes those individuals or
+whether the claims will be dropped upon the expiration of the NPA. Finally, the interest of the
+public in the pending civil and criminal cases will not be prejudiced as EPSTEIN is already
+serving his term whereby a plea was entered in the 15 Judicial Circuit action.
+a.
+Application of the 5"h Amendment
+Next, the Fifth Amendment privilege against self-incrimination "permits a person not to
+answer official questions put to him in any other proceeding, civil or criminal, formal or
+informal, where the answers might incriminate him in future criminal proceedings." Edwin v.
+Price, 778 F.2d 668, 669 (11" Cir. 1985), citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C.
+316, 322 (1973). See also Ohio v. Reiner, 532 U.S. 17, 21, 121 S.Ct. 1252 (2001)(The Fifth
+Amendment privilege is also available to those who claim innocence. One of the Fifth
+Amendment's "basic functions ... is to protect innocent men ... 'who otherwise might be
+ensnared by ambiguous circumstances."); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the
+Fifth Amendment's Self-Incrimination Clause applies to the states through the Due Process
+7
+
+
+Cas@a9:08:08-80801-KAMAMD@aument@09-1Entered@0F4S@Doket@33422099 Bage 8 0f 27
+Page 8
+Clause of the Fourteenth Amendment - "[i]t would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution, depending
+on whether the claim was asserted in state or federal court."); Kastigar v. U.S., 406 U.S. 441,
+444-45, 92 S.Ct. 1653 (1972)(The Fifth Amendment privilege "can be asserted in any
+proceeding, civil or criminal, administrative or judicial, investigatory or adjudicatory; and it
+protects against any disclosures which the witness reasonably believes could be used in a
+criminal prosecution or could lead to other evidence that might be so used. This Court has been
+zealous to safeguard the values which underlie the privilege." (Emphasis added)).
+The United States Supreme Court made it clear that the scope of the Fifth Amendment
+Privilege includes the circumstances as here "the act of producing documents in response to a
+subpoena (or production request) has a compelled testimonial aspect." United States v. Hubbell,
+530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S. 391
+(1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against Self-Incrimination,
+§138 (6" Ed.). The privilege against self-incrimination may be asserted during discovery when a
+litigant has "reasonable grounds to believe that the response would furnish a link in the chain of
+evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is
+entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the
+answer to a question could be used in anyway to convict the witness of a crime or could aid in
+the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company
+v. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983).
+Certainly, if the USAO decides to prosecute EPSTEIN for an alleged violation of the
+NPA, it would undoubtedly be able to use information obtained during discovery against him or
+8
+
+
+Casa9:09:08-808b1-KAMAм Document $ b9-1 Emterad@nFL SDDpckRt0324/80099 Page 9 of 25
+Page 9
+use that information to aid in the development of other evidence against him at a criminal trial.
+The USAO is already claiming violations of the NPA based upon EPSTEIN defending the civil
+actions and, at the same time, while EPSTEIN asserts the s"' Amendment. Imagine, because that
+is all we can do based on the lack of wording in the NPA, what violations the USAO will assert
+if EPSTEIN is forced to waive his 5" Amendment privilege to defend himself in this and the
+other civil actions.
+The Fifth Amendment provides, in relevant part, that "No person ... shall be compelled
+in any Criminal Case to be a witness against himself." Hoffman v. United States, 341 U.S. 479,
+486, 71 S.Ct. 814 (1951), citing
+_v. United States, 1944, 322 U.S. 487, 489, 64 S.Ct.
+1082, 1083, 88 L.Ed. 1408." The Fifth Amendment's privilege against self-incrimination is
+"accorded liberal construction in favor of the right it was intended to secure." 'The immediate
+and potential evils of compulsory self-disclosure transcend any difficulties that the exercise of
+the privilege may impose on society in the detection and prosecution of a crime." Id., at 490;
+and In re
+Financial Svcs. of Fla., Inc., 259 B.R. 391, 399 (M.D. Fla. 2000). The privilege
+not only extends to answers that would in themselves support a conviction under a criminal
+statute but likewise embraces those which would furnish a link in the chain of evidence needed
+to prosecute the claimant for a crime. Id, citing Blau v. United States, 1950, 340 U.S. 159, 71
+S.Ct. 223. The Fifth Amendment privilege against self-incrimination "permits a person not to
+answer official questions put to him in any other proceeding, civil or criminal, formal or
+informal, where the answers might incriminate him in future criminal proceedings." Edwin v.
+Price, 778 F.2d at 669, citing Lefkowitz v. Turley, 414 U.S. 70, 77, 94 S.C. 316, 322 (1973). As
+EPSTEIN is here, "the claimant must be 'confronted by substantial and 'real,' and not merely
+9
+
+
+Case 0800808801KANtANDabument 519b-IEnteneden LSDs Daskek 030841200909 Ragge 10095f154
+Page 10
+trifling or imaginary, hazards of incrimination.'" See generally, United States v. Apfelbaum, 445
+U.S. 115, 128, 100 S.Ct. 948, 956, 63 L.Ed.2d 250 (1980)). See also, United States v. Neff, 615
+F.2d 1235, 1239 (9th Cir.), cert. denied, 447 U.S. 925, 100 S.Ct. 3018, 65 L.Ed.2d 1117
+(1980)(Information is protected by the privilege not only if it would support a criminal
+conviction, but even if "the responses would merely "provide a lead or clue' to evidence having a
+tendency to incriminate."). EPSTEIN falls under each of the above category of cases.
+The United States Supreme Court has made clear that the scope of the Fifth Amendment
+Privilege also encompasses the circumstance where "the act of producing documents in response
+to a subpoena (or production request) has a compelled testimonial aspect." United States. V.
+Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000); see also Fisher v. United States, 425 U.S.
+391 (1976). In explaining the application of the privilege, the Supreme Court stated:
+We have held that "the act of production" itself may implicitly communicate
+"statements of fact." By "producing documents in compliance with a subpoena,
+the witness would admit that the papers existed, were in his possession or control,
+and were authentic." Moreover, as was true in this case, when the custodian of
+documents responds to a subpoena, he may be compelled to take the witness stand
+and answer questions designed to determine whether he has produced everything
+demanded by the subpoena. The answers to those questions, as well as the act of
+production itself, may certainly communicate information about the existence,
+custody, and authenticity of the documents. Whether the constitutional privilege
+protects the answers to such questions, or protects the act of production itself, is a
+question that is distinct from the question whether the unprotected contents of the
+documents themselves are incriminating.
+"The issue presented in those cases was whether the act of producing subpoenaed
+documents, not itself the making of a statement, might nonetheless have some
+rotected testimonial aspects. The Court concluded that the act of production coul
+onstitute protected testimonial communication because it might entail implici
+statements of fact: by producing documents in compliance with a subpoena, the
+witness would admit that the papers existed, were in his possession or control, and
+were authentic. United States v. Doe, 465 U.S., at 613, and n. 11, 104 S.Ct. 1237;
+Fisher, 425 U.S., at 409-410, 96 S.Ct. 1569; id. at 428, 432, 96 S.Ct. 1569
+10
+
+
+Case9:08:08-80801-KAMAMD@rumentri09-1Entered 00 FL SBDockat033422099 Page 11 07 25
+Page 11
+(concurring opinions). See Braswell v. United States, [487 U.S..] at 104, 108 S.Ct.
+2284; [id.] at 122, 108 S.Ct. 2284 (dissenting opinion). Thus, the Court made
+clear that the Fifth Amendment privilege against self-incrimination applies to acts
+that imply assertions of fact."
+... An examination of the Court's application of these
+principles in other cases indicates the Court's recognition that, in order to be
+testimonial, an accused's communication must itself, explicitly or implicitly, relate
+a factual assertion or disclose information. Only then is a person compelled to be a
+'witness' against himself." Doe v. United States, 487 U.S., at 209-210, 108 S.Ct.
+2341 (footnote omitted).
+Finally, the phrase "in any criminal case" in the text of the Fifth Amendment might
+have been read to limit its coverage to compelled testimony that is used against the
+defendant in the trial itself. It has, however, long been settled that its protection
+encompasses compelled statements that lead to the discovery of incriminating
+evidence even though the statements themselves are not incriminating and are not
+introduced into evidence. Thus, a half century ago we held that a trial judge had
+erroneously rejected a defendant's claim of privilege on the ground that his answer
+to the pending question would not itself constitute evidence of the charged offense.
+As we explained:
+"The privilege afforded not only extends to answers that would in themselves
+support a conviction under a federal criminal statute but likewise embraces those
+which would furnish a link in the chain of evidence needed to prosecute the
+claimant for a federal crime." Hoffman v. United States, 341 U.S. 479, 486, 71
+S.Ct. 814, 95 L.Ed. 1118 (1951).
+Compelled testimony that communicates information that may "lead to
+incriminating evidence" is privileged even if the information itself is not
+inculpatory. Doe v. United States, 487 U.S. 201, 208, n. 6, 108 S.Ct. 2341, 101
+L.Ed.2d 184 (1988).
+It's the Fifth Amendment's protection against the
+prosecutor's use of incriminating information derived directly or indirectly from
+the compelled testimony of the respondent that is of primary relevance in this case.
+The privilege against self-incrimination may be asserted during discovery when a litigant
+has "reasonable grounds to believe that the response would furnish a link in the chain of
+evidence needed to prove a crime against a litigant." A witness, including a civil defendant, is
+entitled to invoke the Fifth Amendment privilege whenever there is a realistic possibility that the
+answer to a question could be used in anyway to convict the witness of a crime or could aid in
+11
+
+
+Case 9:08.08-80811-KAMAM Document 5 D9-1 Eatereddo FESDIDDoket 03624/20009 Page 12 of 28
+Page 12
+the development of other incriminating evidence that can be used at trial. Id; Pillsbury Company
+y. Conboy, 495 U.S. 248, 103 S.Ct. 608 (1983). See also, Hubbell, supra, as to what is
+encompassed by the phrase "in any criminal case" contained in the Fifth Amendment.
+As noted, the Fifth Amendment privilege against self-incrimination is broad. Hoffman;
+In re ! | | Financial Svcs., supra. To deny a witness the right to invoke the privilege, the judge
+must be perfectly clear, from a careful consideration of all the circumstances in the case, that the
+witness is mistaken, and that the answers cannot possibly have such tendency to incriminate. Id
+at 488, 399. Recognizing the breadth and magnitude of this constitutional privilege, the United
+States Supreme Court in discussing how a court is to analyze the application of the privilege
+stated -
+... It is for the court to say whether his silence is justified, Rogers v. United States,
+1951, 340 U.S. 367, 71 S.Ct. 438, and to require him to answer if 'it clearly appears
+to the court that he is mistaken.? Temple v. Commonwealth, 1880, 75 Va. 892, 899.
+However, if the witness, upon interposing his claim, were required to prove the
+hazard in the sense in which a claim is usually required to be established in court, he
+would be compelled to surrender the very protection which the privilege is designed
+to guarantee. To sustain the privilege, it need only be evident from the implications
+of the question, in the setting in which it is asked, that a responsive answer to the
+question or an explanation of why it cannot be answered might be dangerous because
+injurious disclosure could result. The trial judge in appraising the claim "must be
+governed as much by his personal perception of the peculiarities of the case as by the
+facts actually in evidence?
+Hoffman, supra at 486-487.
+Hoffman and its progeny establish that "in view of the liberal construction of the
+provision [protecting against self-incrimination], after a witness has asserted the privilege, he
+should be compelled to provide the requested information only if it "clearly appears" to the court
+12
+
+
+Casea:@8:00808101KAMAMDqooment 5199-1Enteredean F4S Dokat& 3/BA/20009 Pagee 130ff151
+Page 13
+that the witness was mistaken in his invocation of the privilege." (Emphasis added). In re
+Financial Svcs., supra at 399, citing Hoffman, at 486.
+In the instant case, the privilege applies as Defendant EPSTEIN "has reasonable cause to
+apprehend danger from a direct answer." The risk of incrimination resulting from being subject
+to discovery or to testify in his own defense while the NPA exists is "substantial and real" and
+"not trifling or imaginary haphazards of communication." See generally, In re ]
+Financial
+Svcs., supra at 400. Based on the nature of Plaintiff's claims, along with the ongoing scrutiny
+of the USAO in the criminal matters, EPSTEIN has "reasonable grounds to believe that his
+responses to the discovery would furnish a link in the chain of evidence needed to prove a crime
+against him. Finally, in order to preserve the privilege, the privilege must be asserted or one
+risks the loss or waiver of this liberty ensuring protection. See generally, U.S. v.
+846
+F.2d 678, 690 (11" Cir. 1988)("First, it ignores the settled principle which requires a witness to
+assert his Fifth Amendment rights. A witness who testifies at any proceeding, instead of asserting
+his Fifth Amendment rights, loses the privilege. ... A civil deponent cannot choose to answer
+questions with the expectation of later asserting the Fifth Amendment.").
+Also applicable in upholding the assertion of the Fifth Amendment privilege is the
+guarantee of effective assistance of counsel by the Sixth Amendment of the U.S. Constitution.
+See Yarborough v. Gentry, 124 S.Ct. 1, 540 U.S. 1, 157 L.Ed.2d 1 (2003)(Sixth Amendment
+guarantees criminal defendants effective assistance of counsel.), on remand 381 F.3d 1219. The
+United States Constitutional guarantees are applicable to the states through the Fourteenth
+Amendment. Obviously, EPSTEIN's assertion of his constitutional privileges and protections is
+on the advice of counsel. Again, EPSTEIN continues to face criminal prosecution by the USAO
+13
+
+
+Casea:08:0080810 KAMAMDocument 5199-1Enteredan F4S D@okat 3/84/40009 Page 1410f1 151
+Page 14
+until the expiration of the NPA; under the constitutional guarantee of effective assistance of
+counsel, he is entitled to follow the recommended advice of his criminal defense attorney. See
+Goldberger Affidavit attached hereto.
+EPSTEIN's invocation of his constitutional protections of the Fifth, Sixth and Fourteenth
+Amendments must be upheld for the reasons set forth herein; otherwise such constitutional
+protections would be rendered meaningless. Already and recently, Defendant EPSTEIN in his
+Response and Objections to discovery, attached hereto as Exhibit "C", has been required to
+assert, on advice of counsel, his Fifth Amendment privilege against self-incrimination, along
+with his constitutional rights afforded under the Sixth and Fourteenth Amendments of the United
+States Constitution. Thus, EPSTEIN's entitlement to a stay is ripe for determination.
+Based upon the foregoing, a stay is warranted in this action as the Defendant is being
+forced to choose between the assertion of his Fifth Amendment right or losing this case by
+judgment (summary or otherwise) or waiver of his 5'" Amendment right and face potential
+criminal prosecution.
+rerit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+14
+
+
+Case 8:08:08808301KAMAMD @aument 5199-1Enteredar FUSS Dookete 3/84 20099 Page 150f 151
+Page 15
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 24" day of March, 2009
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff C.M.A.
+reelrhw@hotmail.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Jack Scarola, Esq.
+Bruce Reinhart, Esq.
+Jack P.. Esq.
+Bruce E. Reinhart, P.A
+Searcy Denney Scarola Barnhart & Shipley,
+250 S. Australian Avenue
+Suite 1400
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33401
+West Palm Beach, FL 33409
+561-202-6360
+561-686-6300
+Fax: 561-828-0983
+Fax: 561-383-9424
+ecf@brucereinhartlaw.com
+jsx@searcylaw.com
+iph@searcylaw.com
+Counse
+Jefendant
+Co-Counsel for Plaintiff
+ROBERTS. CRITTON,
+Florida Bar No. 224(62
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant, Jeffrey Epstein)
+
+
+• Casese 0808 8080115ALAM Document 59921 EnterestionFUSEDocket 03|21/2009 Page160f124
+INDICTMENT
+A TRUE BILL 06-94.54 IF
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA S
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
+CIRCUIT OF THE STATE OF FLORIDA
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:
+The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their
+oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State
+aforesaid,
+COUNT ONE
+FELONY SOLICITATION OF PROSTITUTION
+on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31,
+2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to
+Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005,
+contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+against the form of the statute, to the evil example of all others, and against the peace and dignity of the State
+of Florida.
+I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+quillin
+• Assistant State Atforey of the
+Fifteenth Judicial Circuit of the State
+of Florida, prosecuting for the said
+State
+GRAND JURY FOREPERSON
+JATE
+leffrey E. Epstein, Race:
+ЕНІВІТ"Д",
+Sex: Male, DOB: January 20, 1953, SS#: 090-44-3348; Issue Warrant
+
+
+, 'Casas2: 0800V6808U IIANAM Deaument 59931 Enterestiom 4SD Racket BPAROO Page1791324
+*.
+AFFIDAVIT OF JACK A. GOLDBERGER, ESQUIRE
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+BEFORE ME, the undersigned authority, personally appeared
+having personal knowledge and being duly sworn, deposes and says:
+1.
+1, Jack A. Goldberger, have personal knowledge of the matters set
+forth herein. I am an attorney licensed to practice in the State of Florida since
+1978. I am a partner with the law firm of Atterbury Goldberger & Weiss, P.A.,
+located at One Clearlake Centre, Suite 1400, 250 Australian Avenue South, West
+Palm Beach, FL 33401.
+2.
+My practice includes and specializes in the defense of criminal
+matters. I am board certified in criminal law. I have been and currently am the
+criminal defense attorney for JEFFREY EPSTEIN.
+1 represented Mr. EPSTEIN in the negotiation of and entering into a
+Non-Prosecution Agreement with the United States Attorney's Office (USAO) for
+the Federal Southern District of Florida. The terms and conditions of the Non-
+Prosecution Agreement also entailed the entering of a Plea Agreement with the
+State Attorney's Office, Palm Beach County, State of Florida. (The Non-
+Prosecution Agreement shall hereinafter be referred to as the "NPA").
+4.
+By its terms, the NPA took effect on June 30, 2008. Also, pursuant
+to the terms of the NPA, any criminal prosecution against EPSTEIN is deferred
+as long as the terms and conditions of the NPA are fulfilled by EPSTEIN.
+
+
+
+Case 8:98848081115A0AM Deaument5b3 Entered om FISD Docket 03/24/2009 PRggel8 of 34
+The criminal matters against EPSTEIN remain ongoing until the
+NPA expires by its terms in late 2010, and as long as the USAO determines
+EPSTEIN has complied with those terms and conditions. The threat of criminal
+prosecution against EPSTEIN by USAO in the Southern District of Florida
+continues presently and through late 2010.
+6.
+Pursuant to the terms of the NPA, the USAO possesses the right to
+declare that the agreement has been breached, give EPSTEIN's counsel notice,
+and attempt to move forward with a prosecution. As of the date of this Affidavit,
+the USAO has taken the position on a number of occasions that it might consider
+the following actions by EPSTEIN to be a breach of the NPA.
+• Investigation by EPSTEIN (by and through his attorneys) of this Plaintiff
+and the other Plaintiffs in other pending civil cases for purposes of
+defending the civil actions;
+• EPSTEIN's contesting damages in this action and other civil actions.
+• EPSTEIN or his legal representatives making statements to the press
+about this Plaintiff or the other Plaintiffs.
+• Using the word "jail" instead of "imprisonment" in the plea agreement with
+the Palm Beach County State Attorney's Office.
+7.
+EPSTEIN, through counsel, submitted a Freedom of Information
+Act request to the Federal Bureau of Investigation (FBI) for documents relating to
+this and the other cases; the FBI denied the request stating the materials are at
+this time exempt from disclosure because they are in an investigative file, i.e. the
+matter is still an ongoing criminal investigation.
+Page - 2 -
+
+
+•...Cases:0808 808011MALAM Dosument 59931 Enterestion FUSE Dakat OB/RAROND Rage 130011324
+8.
+The NPA expires in late 2010.
+FURTHER THE AFFIANT SAYETH NAUGHT,
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to
+administer oaths
+and take acknowledgments,
+personally
+appeared
+Jack A. Goldberger, Esquire, known to me to be the person described in and who
+executed the foregoing Affidavit, who acknowledged before me that he/she
+executed the same, that! relled upon the following form of identification of the
+_, and that an oath was/was
+not taken.
+this
+MINE and and falsene County and State last aforesaid
+February
+(SEAG)
+NatE RoBin: Suare of Floris
+LE Rosin
+My Commission DD489790
+Expires 11/13/2009
+NAME:
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.: DD 489790
+MY COMMISSION EXPIRES:
+11/13/2009
+Page - 3 -
+
+
+Cases: 0808/ 8081115A1AM Desument 59941 Enterestion FLSD) Desket: 08/PAIRS PageD 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-MARRAJ.|
+C.M. A.,
+Plaintiff,
+JEFFREY EPSTEIN and
+Defendants,
+DEFENDANT JEFFREY EPSTEIN'S RESPONSE & OBJECTIONS
+TO PLAINTIFF'S FIRST REQUEST FOR PRODUCTION
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+hereby responds to Plaintiff's First Request For Production To Defendant, served
+January 8, 2009 and states:
+Request No. 1: Any and all evidence required to be maintained by Epstein
+and the United States Attorney for the Southern District of Florida, specifically evidence
+requested by or directly related to the grand jury subpoenas that have been issued in
+connection with the investigation referenced in the Non-Prosecution Agreement, and
+including certain computer equipment.
+Response:
+Defendant is asserting specific legal objections to the production
+request as well as his U.S. constitutional privileges. I intend to produce all relevant
+documents regarding this lawsuit, however, my attorneys have counseled me that at the
+present time I cannot select, authenticate, and produce documents relevant to this
+
+C"
+JEDE
+
+
+Cases: 0898v 8080116ALAM Document 59941 Enteresom#USD00032MR PAg240124
+Page 2
+lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution. Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution. In addition to and without
+waiving his constitutional privileges, the information sought is privileged and
+confidential, and inadmissible pursuant to the terms of the deferred prosecution
+agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further, the
+request may include information subject to work product or an attorney-client privilege.
+Request No. 2: Any and all documents reflecting or relating to the identity of,
+the scheduling of, and/or the payment of any female compensated by or on behalf of
+Epstein for providing any service to Epstein that required, contemplated, or included in
+the provisions of such service, any physical contact between Epstein and the female,
+any act or prostitution, any illicit sexual conduct, the exposure of breast, buttocks or
+genitalia, or any commercial sex act as defined in 18 U.S.C. §1591 (c)(1).
+Response: Defendant is asserting specific legal objections to the production
+request as well as his U.S. constitutional privileges. I intend to produce all relevant
+documents regarding this lawsuit, however, my attorneys have counseled me that at the
+present time I cannot select, authenticate, and produce documents relevant to this
+lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+
+
+• Cases:08084 8080115ALAM Document 69941 BEterestonFUSED 00ket033211RDO FRage 2201124
+Page 3
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution. Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution. In addition to and without
+waiving his constitutional privileges, the information sought is privileged and
+confidential, and inadmissible pursuant to the terms of the deferred prosecution
+agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further
+Defendants objects to the production as overly broad and seeking information that is
+neither relevant to the subject matter of the pending action nor does it appear to be
+reasonably calculated to lead to the discovery of admissible evidence. The Plaintiff in
+this instance has alleged in her complaint that she was sexually abused by the
+Defendant on one occasion sometime in the year 2004. The documents requested
+herein have no time period provided, and therefore the information sought is grossly
+overbroad.
+Request No. 3: Any and all documents reflecting or relating to the identity of
+and/or the nature and extent of any other person's participation in the communication
+with and/or the scheduling of and/or the payment of any person who participated in any
+conduct described in Request #2.
+Response: Defendant is asserting specific legal objections to the production
+request as well as his U.S. constitutional privileges. I intend to produce all relevant
+documents regarding this lawsuit, however, my attorneys have counseled me that at the
+present time I cannot select, authenticate, and produce documents relevant to this
+
+
+•Case≤9@809808011KA\AM Dooumeeh59941 Entered FLODD∞ke#3712299 Page 2305524
+Page 4
+lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution. Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution. In addition to and without
+waiving his constitutional privileges, the information sought is privileged and
+confidential, and inadmissible pursuant to the terms of the deferred prosecution
+agreement, Fed. Rule of Evidence 410 and 408, and §90.410, Fla. Stat. Further
+Defendants objects to the production as overly broad and seeking information that is
+neither relevant to the subject matter of the pending action nor does it appear to be
+reasonably calculated to lead to the discovery of admissible evidence. The Plaintiff in
+this instance has alleged in her complaint that she was sexually abused by the
+Defendant on one occasion sometime in the year 2004. The documents requested
+herein have no time period provided, and therefore the information sought is grossly
+overbroad.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was sent by U.S. mail to
+the following addressees, on this _6th day of _February. 2009
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10" Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+
+
+:::Casas:08038080115A1AM Documesh 59941 Enteredon FID Docket:03623122093 1ge 3400524
+Page 5
+Fax: 561-588-8819
+Counsel for Plaintiff C.M.A.
+reelrhw@hotmail.com
+Jack Scarola, Esq.
+Jack P.
+Esq.
+Searcy
+Denney
+Scarola Barnhart
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx@searcylaw.com
+iph@searcylaw.com
+Co-Counsel for Plaintiff
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendants Jeffrey Epstein
+and
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+& 250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bciclaw.com
+MICHAEL J. PIKE, ESQ
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.md b/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.md
new file mode 100644
index 0000000000000000000000000000000000000000..d60dc9562d5a6d3cd6e984a28eade176a504ab67
--- /dev/null
+++ b/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.md
@@ -0,0 +1,129 @@
+-
+GT GreenbergTraurig
+Fax 561.659.9115
+nendelsohns@gtlaw.com
+August 27, 2019
+VIA EMAIL and OVERNIGHT MAIL
+State Attorney Dave Aronberg
+Email: daronberg@sa15.state.fl.us
+Dear State Attorney Aronberg:
+Greenberg Traurig, P.A. represents The Palm Beach Post in connection with its public records
+requests for Jeffrey Epstein documents compiled during your predecessor Barry Krischer's tenure:
+You may not be aware that on July 15, 2019, The Palm Beach Post reporter Jane Musgrave
+submitted an initial Florida Public Records Law request for Epstein documents to the Office of
+State Attorney. A copy of her request is enclosed. Also on July 15, 2019, Lulu Ramadan, who is
+also a reporter for the newspaper, made a second request, which is enclosed as well.
+We understand that on July 22, 2019, your office provided a thumb drive to The Palm Beach Post
+containing 24 numbered files. After a review of these documents, the newspaper determined that
+certain documents responsive to its reporters' requests have not been produced, although your
+office has not asserted a statutory exemption. On August 6, 2019, Ms. Musgrave emailed Public
+Information Officer Mike Edmondson and advised that specific documents in your files have not
+been produced. Her email is enclosed. Unfortunately, she has not received a response. On
+August 14, 2019, Ms. Musgrave emailed Mr. Edmondson and asked for copies of (1) a memo
+purportedly written by Epstein attorney Alan Dershowitz to Mr. Krischer or his assistants, and
+(2) a "close-out-memo" in reference to Jane Doe 3
+A copy of this
+email is enclosed. On August 19, 2019, your office sent Ms. Musgrave a form letter indicating
+that it was "diligently" working on her August 14th request, and assigned it the above number.
+Because of the public importance of this matter, we reiterate The Palm Beach Post's request that
+the following documents be produced as expeditiously as possible:
+PartyJOINT
+ID#. J01_ EV#J01
+DATE ADMITTED: 9/6/2022
+Case No. 2019-CA-014681
+ABRUZZO CLERK
+CIRCUIT COURT
+Greenberg Traurig, P.A. | Attorncys at Law
+5100 Town Center Circle | Suite 400 | Boca Raton, Florida 33486 | T +1 561.955.7600 | F +1 561.338.7099
+Albany. Amsterdam, Atlanta. Anstin. Berlin Boca
+- Boston. Chicago. Dallas, Delavare. Demer. Fort Lauderdale. Houston. Las Vegas. li KG
+Mexiro City' Miami, Milan" Minneapolis, Nashville. New.Jerscy: New York. Northern Virginin, Ofinge County: Orlando. Philadelphia. Phoé
+Son Francisco. Scoul". Shanghai. Silicon Valley: Tallahassce. Tamja. Tel Aviv Tokyo; Warsiw: Washingion, D.C. West Palm Beach. Westchester County.
+Joint Exhibit
+J01
+CA/AronbergOBOO BEACH COUNTY, FL,
+ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
+
+
+State Attorney Dave Aronberg
+August 27, 2019
+Page 2
+• Memos, emails, communications in any form from the State Attorney's Office
+describing a plea offered to Epstein in April 2006.
+• Memo from Alan Dershowitz to Barry Krischer that alleges that most men in South
+Florida charged with crimes similar to Jeffrey Epstein have received probation.
+• Emails exchanged between Barry Krischer, Assistant State Attorneys and the attorneys
+within the office of the United States Attorney for the Southern District of Florida or
+the United States Department of Justice concerning Jeffrey Epstein.
+•
+Deposition transcripts of
+and Britanny
+Moreover, the following documents were not part of your office's production, but we have reason
+to believe that they should be in its files:
+• Notes, records and related correspondence of February 6, 2006, February 16, 2006 and
+June 1, 2006 meetings with attorneys from Barry Krischer's office and Jeffrey
+Epstein's defense attorneys.
+• Notes, records and related correspondence concerning the FBI's visit to Barry Krischer
+in November or December 2007 where the FBI purportedly sought to have
+Mr. Krischer take steps to render Epstein ineligible for work release.
+• Notes and records of meetings and communications concerning Jeffrey Epstein with
+Palm Beach Police Chief Michael Reiter, Palm Beach Detective
+Recarey, and
+Epstein defense attorneys including but not limited to Guy Fronstin, Alan Dershowitz,
+Jack Goldberger, Roy Black, Jay Lefkowitz and Gerald Lefcourt.
+• Notes and records of meetings and communications concerning Jeffrey Epstein with
+AUSA
+Villafana, AUSA Matthew Menchel, AUSA Andrew Lourie and US
+Attorney Alex Acosta.
+• Notes and records of meetings and communications with Epstein victims and/or
+Communications between Barry Krischer and Assistant State Attorney Lanna
+Belohlavek and other State Attorneys concerning plea negotiations and a possible plea
+deal with Jeffrey Epstein, as well as communications concerning the submission of the
+• Copies of drafts of Palm Beach Detective
+Epstein.
+Recarey's arrest warrants for Jeffrey
+:
+Greenherg Traurig, P.A. | Attorneys at Law
+www.gtlaw.com
+CA/Arohber@0BO00X BEACH COUNTY, FL,
+ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
+
+
+-
+:
+•
+State Attorney Dave Aronberg
+August 27, 2019
+Page 3
+• Correspondence or documents pertaining to Mr. Krischer's' knowledge of and/or
+participation in the Epstein non-prosecution agreement negotiated by federal
+prosecutors.
+• Correspondence or documents concerning communications between the State
+Attorney's Office and Kirkland & Ellis attorneys pertaining to the investigation,
+prosecuțion, and sex offender classification of Jeffrey Epstein.
+• Correspondence or documents concerning communications between the State
+Attorney's Office and Manhattan (New York) prosecutors Jennifer Gaffney and
+Jeffrey Epaning to the invesigation, prosecution, and sex offender classification of
+Finally, The Palm Beach Post has also asked for the age of the victim who was the basis for the
+charge against Epstein of solicitation of a minor for prostitution. The newspaper was told by your
+office that her date of birth is in the records produced, but a careful search by our client has not
+uncovered that date. As we understand that your office gave this date to the Washington Post, we
+request that it be provided to our client as well.
+We thank your office for the effort it has made in producing the documents to date, but are
+compelled to reiterate the newspaper's request for the remaining documents and ask that they be
+produced as soon as practicable given the important public issues they implicate and, presumably,
+will illuminate.
+We appreciate your cooperation.
+Very truly yours,
+Stephen Mendelsohn
+Enclosures
+ce:
+Mr. Joel Engelhardt
+Investigative Team Editor
+The Palm Beach Post
+Ms. Holly Baltz
+Senior Editor, Investigations
+The Palm Beach Post
+Greenherg Traurig, P.A. | Attorneys at Law
+www.gtlaw.com
+CA/Aronbergoodas BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 2:57:43 PM
diff --git a/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.receipt.json b/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7d6d7ca803614ab9c3fa72fb3e5f8e35c397ffc1
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+++ b/vision-fixhub/court-01/ef535536bae6fee4461835b8594cfc3a45f49be8df2f6731b285d7545d6e2bce.receipt.json
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diff --git a/vision-fixhub/court-01/ef6a9f8d0b5b3f90542a85b09ccba05e596717090d5da474b8f5e9dd2059978e.md b/vision-fixhub/court-01/ef6a9f8d0b5b3f90542a85b09ccba05e596717090d5da474b8f5e9dd2059978e.md
new file mode 100644
index 0000000000000000000000000000000000000000..e5fe6c7e5838b1cdf0b2556768e900b67d4d5877
--- /dev/null
+++ b/vision-fixhub/court-01/ef6a9f8d0b5b3f90542a85b09ccba05e596717090d5da474b8f5e9dd2059978e.md
@@ -0,0 +1,106 @@
+Case 9:08-cv-80381-KAM Document 137 Entered on FLSD Docket 12/17/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CIV-80119-MARRAI
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEC 16 2009
+CLEARS DET
+50. OF FL •
+OMNIBUS ORDER
+THIS CAUSE is before the Court on the following motions: (1) Defendant's
+Unopposed Motion for Extension of Time to File Response to Plaintiff's Motion to Compel
+filed March 6, 2009 (D.E. #54 in Case No. 08-80232 and D.E. #64 in Case No. 08-80381);
+(2) Defendant's Motion for Leave to File Excess Pages with Proposed Order filed March
+18, 2009 (D.E. #55 in Case No. 08-80232 and D.E. #65 in Case No. 08-80381); (3)
+Defendant's Unopposed Motion for Extension of Time to File Reply to Response to Motion
+to Compel (D.E. #62 in Case No. 08-80232 and D.E. #72 in Case No. 08-80381); (4)
+Plaintiff's Motion to Compel Answers to Interrogatories and Requests for Production filed
+March 2, 2009 (D.E. #61 in Case No. 08-80381); (5) Plaintiff's Unopposed Motion for
+Extension of Time to File Response to Defendant's Motion to Compel filed April 17, 2009
+
+
+Case 9:08-cv-80381-KAM Document 137 Entered on FLSD Docket 12/17/2009 Page 2 of 4
+(D.E. #71 in Case #08-80232 and D.E. #75 in Case #08-80381); (6) Plaintiff's Unopposed
+Motion for Extension of Time to File Response to Defendant's Motion to Compel filed April
+29, 2009 (D.E. #79 in Case #08-80232; D.E. #79 in Case #08-80381; D.E. # 43 in Case
+#08-80993; and, D.E. #33 in Case #08-80994); (7) Defendant's Motion to File Reply to
+Response to Motion to Compel filed May 18, 2009 (D.E. #92 in Case #08-80232; D.E. #94
+in Case #08-80381; and, D.E. #49 in Case #08-80994); (8) Third Party Zinoview's Motion
+for Protective Order filed November 9, 2009 (D.E. #131 in Case #08-80232; D.E. #132 in
+Case #08-80381; and, D.E. #84 in Case #08-80994); (9) Defendant's Motion to Compel
+Response to First Request for Production filed April 2, 2009 (D.E. #59 in 08-80232; D.E.
+#69 in 08-80381; D.E. #26 in 08-80993; and, D.E. #24 in 08-80994); and (10) Defendant's
+Motion to Compel Response to First Set of Interrogatories filed April 2, 2009 (D.E. #60 in
+08-80232; D.E. #70 in 08-80381; D.E. #27 in 08-80993; and, D.E. #25 in 08-80994).
+Having reviewed the pleadings filed incident to these matters, and being otherwise
+duly advised in the premises, it is hereby
+ORDERED AND ADJUDGED as follows:
+(1)
+Defendant's Unopposed Motion for Extension of Time to File Response to
+Plaintiff's Motion to Compel filed March 6, 2009 (D.E. #54 in Case No. 08-
+80232 and D.E. #64 in Case No. 08-80381) is GRANTED nunc pro tunc;
+(2)
+(3)
+Defendant's Motion for Leave to File Excess Pages with Proposed Order
+filed March 18, 2009 (D.E. #55 in Case No. 08-80232 and D.E. #65 in Case
+No. 08-80381) is GRANTED nunc pro tunc;
+Defendant's Unopposed Motion for Extension of Time to File Reply to
+2
+
+
+Case 9:08-cv-80381-KAM Document 137 Entered on FLSD Docket 12/17/2009 Page 3 of 4
+Response to Motion to Compel (D.E. #62 in Case No. 08-80232 and D.E.
+(4)
+#72 in Case No. 08-80381) is GRANTED nunc pro tunc;
+Plaintiffs Motion to Compel Answers to Interrogatories and Requests for
+Production filed March 2, 2009 ( D.E. #61 in Case No. 08-80381) is DENIED
+AS MOOT;
+(5)
+Plaintiff's Unopposed Motion for Extension of Time to File Response to
+Defendant's Motion to Compel filed April 17, 2009 (D.E. #71 in Case #08-
+80232 and D.E. #75 in Case #08-80381) is GRANTED nunc pro tunc;
+(6)
+Plaintiff's Unopposed Motion for Extension of Time to File Response to
+Defendant's Motion to Compel filed April 29, 2009 (D.E. #79 in Case #08-
+80232; D.E. #79 in Case #08-80381; D.E. # 43 in Case #08-80993; and,
+D.E. #33 in Case #08-80994) is GRANTED nunc pro tunc;
+(7)
+Defendant's Motion to File Reply to Response to Motion to Compel filed May
+18, 2009 (D.E. #92 in Case #08-80232; D.E. #94 in Case #08-80381; and,
+D.E. #49 in Case #08-80994) is GRANTED nunc pro tunc;
+(8) Third Party Zinoview's Motion for Protective Order filed November 9, 2009
+(D.E. #131 in Case #08-80232; D.E. #132 in Case #08-80381; and, D.E. #84
+in Case #08-80994) is DENIED AS MOOT;
+(9)
+Defendant's Motion to Compel Response to First Request for Production
+filed April 2, 2009 (D.E. #59 in 08-80232; D.E. #69 in 08-80381; D.E. #26 in
+08-80993; and, D.E. #24 in 08-80994) is STRICKEN as a duplicate filing as
+the identical Motion has been filed correctly in the lead case file of 08-80119
+3
+
+
+Case 9:08-cv-80381-KAM Document 137 Entered on FLSD Docket 12/17/2009 Page 4 of 4
+at D.E. #210. An order on D.E. #210 shall be issued shortly; and,
+(10)
+Defendant's Motion to Compel Response to First Set of Interrogatories filed
+April 2, 2009 (D.E. #60 in 08-80232; D.E. #70 in 08-80381; D.E. #27 in 08-
+80993; and, D.E. #25 in 08-80994) is STRICKEN as a duplicate filing as the
+identical Motion has been filed correctly in the lead case file of 08-80119 at
+D.E. #212. An order on D.E. #212 shall be issued shortly.
+DONE AND ORDERED this December 16, 2009 in
+, at West Palm Beach,
+Florida.
+Lined to inson
+LINNEA R. JOHNSON
+UNITED STATES MAGISTRATE JUDGE
+CC: The Honorable Kenneth A. Marra
+All Counsel of Record
+4
diff --git a/vision-fixhub/court-01/ef6a9f8d0b5b3f90542a85b09ccba05e596717090d5da474b8f5e9dd2059978e.receipt.json b/vision-fixhub/court-01/ef6a9f8d0b5b3f90542a85b09ccba05e596717090d5da474b8f5e9dd2059978e.receipt.json
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+}
diff --git a/vision-fixhub/court-01/ef7e39a018a51dfa8cb4e11fe53b04887978f8d57c33eaaebc0d283faa3d6c51.md b/vision-fixhub/court-01/ef7e39a018a51dfa8cb4e11fe53b04887978f8d57c33eaaebc0d283faa3d6c51.md
new file mode 100644
index 0000000000000000000000000000000000000000..30a67e30dcf5ab0762055e1c6104834f600077d3
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+++ b/vision-fixhub/court-01/ef7e39a018a51dfa8cb4e11fe53b04887978f8d57c33eaaebc0d283faa3d6c51.md
@@ -0,0 +1,95 @@
+Case 9:08-cv-80736-KAM Document 233 Entered on FLSD Docket 09/06/2013 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/_
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR EXTENSION OF
+TIME IN LIGHT OF GOVERNMENT'S EXTENSION OF TIME
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court for a ten-day extension of time in which to file
+their reply in support of their Renewed Motion for an Order Directing the U.S. Attorney's Office
+Not to Withhold Relevant Evidence (DE 226). Yesterday the Court granted the Government's
+motion for a ten-day extension in which to file its declaration in support of its assertion of a
+deliberative process privilege (an extension to which the victims did not object). Because that
+declaration may be relevant to the victims' reply, they respectfully request that the time for filing
+their reply also be extended ten days to give them an opportunity to review the Government's
+declaration.
+The Court extended the Government's time for filing this declaration to September 13,
+2013. The victims request that their reply be due ten days later, on or before September 23,
+2013.
+The Government does not oppose this motion.
+A proposed order to this effect is attached to this motion.
+1
+
+
+Case 9:08-cv-80736-KAM Document 233 Entered on FLSD Docket 09/06/2013 Page 2 of 3
+For all these reasons, the Court should extend the victim's time for filing a reply for ten
+days.
+DATED: September 6, 2013
+Respectfully Submitted,
+/s/
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+2
+
+
+Case 9:08-cv-80736-KAM Document 233 Entered on FLSD Docket 09/06/2013 Page 3 of 3
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on September 6, 2013, on the following
+using the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+Assistant U.S. Attorneys
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoi.gov
+E-mail:
+Attorneys for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+Email: pleading@royblack.com
+(305) 37106421
+(305) 358-2006
+Jay P. Lefkowitz
+Kirkland & Ellis, LLP
+601 Lexington Avenue
+New York, NY 10022
+Email: lefkowitz@kirkland.com
+(212) 446-4970
+G. Weinberg, P.C.
+20 Park Plaza
+Suite 1000
+Boston, L
+02116
+Email: owlmgw@att.net
+(617) 227-3700
+(617) 338-9538
+Criminal Defense Counsel for Jeffrey Epstein
+Is/
+3
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diff --git a/vision-fixhub/court-01/efec8969c24c20d97d01ee867cf0b51e546328eff81cc7bfa4dce2fb42db34bb.md b/vision-fixhub/court-01/efec8969c24c20d97d01ee867cf0b51e546328eff81cc7bfa4dce2fb42db34bb.md
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index 0000000000000000000000000000000000000000..ccd0c09ef2eae8cecc729cd135a98eeb8bf04c4c
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@@ -0,0 +1,225 @@
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-cv-80119-MARRA/.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 2 of 6
+CASE NO.: 08-CV-80381-MARRA/J
+JANE DOE NO. 5,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80994-CIV-MARRA/J
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80993-CIV-MARRA/.
+JANE DOE NO. 7,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/.
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 3 of 6
+JANE DOE,
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/S
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-,
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 09-80591-CIV-MARRA-
+JANE DOE NO. 102,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-80656-CIV-MARRA/.
+DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
+OF TIME IN WHICH TO RESPOND TO PLAINTIFF JANE DOE'S MOTION
+FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFERS OF ASSESTS,
+APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF
+EPSTEIN AND TO POST A $15 MILLION BOND TO SECURE
+POTENTIAL JUDGEMENT (DE 165)
+
+
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 4 of 6
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, moves
+this Court for an extension of time until July 16, 2009, to file a Response to Plaintiffs
+Jane Doe's Motion
+for Injunction Restraining Fraudulent Transfers of Assets,
+Appointment of a Receiver to Take Charge of Property of Epstein and to Post a $15
+Million Bond to Secure Potential Judgment (DE 165), pursuant to Local Rule 7.1 A.1(j)
+(S.D. Fla. 2008). As good cause for the requested extension, Defendant states:
+1. Counsel for Defendant communicated with Counsel for the Plaintiff, and
+Plaintiff's Counsel agrees to the requested extension of July 16, 2009, to file a Response
+to Plaintiffs Jane Doe's Response to Plaintiffs Jane Doe's Motion for Injunction
+Restraining Fraudulent Transfers of Assets, Appointment of a Receiver to Take Charge
+of Property of Epstein and to Post a $15 Million Bond to Secure Potential Judgment (DE
+165).
+Rule 7.1 A. 3. Certification of Pre-Filing Conference
+Counsel for Defendant conferred with Counsel for Plaintiff's counsel, by
+telephone, and Counsel for Plaintiff is in agreement with the requested extension.
+водоусто.
+
+
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 5 of 6
+Certificate of Service
+HEREBY CERTIFY that a true copy of the foregoing was electronically file
+rith the Clerk of the Court using CM/ECF. I also certify that the foregoing document i
+being served this day on all counsel of record identifjed on the following Service List in
+the manner specified by CM/ECF on this 6™ day of July, 2009
+Respectfully submited,
+By: _
+ROBERTD. CRITTON, JR, ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+08-80994
+Brad
+, Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+
+
+Case 9:08-cv-80119-KAM Document 188 Entered on FLSD Docket 07/06/2009 Page 6 of 6
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10*h Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Paul G. Cassell, Esq.
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+• Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+Jack Scarola, Esq.
+West Palm Beach, FL 33401
+Jack P. Esq.
+561-832-7732
+Searcy Denney Scarola Barnhart & Shipley,
+561-832-7137 F
+2139 Palm Beach Lakes Boulevard
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+West Palm Beach, FL 33409
+08-80469
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esg.
+Ricci-Leopold, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesg@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/efec8969c24c20d97d01ee867cf0b51e546328eff81cc7bfa4dce2fb42db34bb.receipt.json b/vision-fixhub/court-01/efec8969c24c20d97d01ee867cf0b51e546328eff81cc7bfa4dce2fb42db34bb.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7eb25418b333c00d744bd7f1f95ca441ccca9145
--- /dev/null
+++ b/vision-fixhub/court-01/efec8969c24c20d97d01ee867cf0b51e546328eff81cc7bfa4dce2fb42db34bb.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e80497cce7d13be7cefaaf46e4c9e7c03b25361936d975511b82d8d95343a60d",
+  "output_sha256": "cae8952d8897b40009a786d9c2c7319c1b5dab34f150634d7348bb2edd3c57a1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.md b/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.md
new file mode 100644
index 0000000000000000000000000000000000000000..98508113fe73682457599f4ab00d35ee7adf70a9
--- /dev/null
+++ b/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.md
@@ -0,0 +1,28 @@
+Case 1:19-cv-08673-KPF-DCF Document 15
+Filed 11/01/19 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN •. INDYKE and RICHARD D. KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendants.
+Case No. 19 Civ. 8673
+NOTICE OF APPEARANCE
+To the Clerk of this court and all parties of record:
+Please enter my appearance as counsel in this case for Plaintiff Jane Doc. I certify
+that I am admitted to practice in this Court.
+Dated: November 1, 2019
+New York, New York
+Is/ Kyla Magun
+Kyla Magun
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Telephone: (212) 763-0883
+Facsimile: (212) 564-0883
+kmagun@kaplanhecker.com
+Counsel for Plaintiff Jane Doe
+1
diff --git a/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.receipt.json b/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7511ea008aa23df4eeae99c88ae22cc0e503169e
--- /dev/null
+++ b/vision-fixhub/court-01/efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "efed88219ff413ff6fccd7e38cd96c7fd0a93444d5179a2e62cad2b0604118e1",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "edc3a789fe850bdca424457951d058c99a1ac23d022bd03ba9ece49b622cdd6b",
+  "output_sha256": "109961e2b83cd1a4530ca81411f9f3b1c179bfcc01ae05d20709ae8a0335e5d8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3.md b/vision-fixhub/court-01/f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3.md
new file mode 100644
index 0000000000000000000000000000000000000000..d21829e36f7a92a6cd9ff3d19678f1d62f299fcb
--- /dev/null
+++ b/vision-fixhub/court-01/f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3.md
@@ -0,0 +1,151 @@
+Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 1 of 5
+IN THE UNITED STATES DISTRICT COURT
+FOR THE SOUTHERN DISTRICT OF FLORIDA
+JANE DOE No. 101,
+Civil Action No.
+Plaintiff,
+VS.
+JEFFREY EPI
+Defendant.
+/
+MOTION TO PROCEED ANONYMOUSLY
+AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 101, by and through her undersigned counsel, moves this Court to
+enter an Order granting Plaintiff permission to proceed in this action under the pseudonym "Jane
+Doe No. 101" and, as grounds, states as follows:
+1.
+As outlined in detail in the Complaint, Jane Doe No. 101 was sexually abused by
+Defendant, Jeffrey Epstein, when she was under the age of 18.
+As a result of Defendant's sexual abuse, Plaintiff has in the past suffered, and will
+in the future suffer, physical injury, pain and suffering, emotional distress, psychological and/or
+psychiatric trauma, mental anguish, humiliation, confusion, embarrassment, loss of educational
+opportunities, loss of self-esteem, loss of dignity, invasion of her privacy, and other damages
+associated with Defendant's manipulating and leading her into a perverse and unhealthy way of
+life.
+Disclosure of Plaintiff's name would cause her much additional embarrassment,
+humiliation, and psychological trauma.
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-CV-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 2 of 5
+4.
+The subject matter of the Complaint clearly contains highly sensitive and intimate
+information about Plaintiff.
+5.
+Plaintiff was an identified victim by the FBI and the U.S. Attorney's Office in a
+criminal investigation against Defendant, Jeffrey Epstein.
+During the related criminal investigation, and up and to this point in time,
+Plaintiff's identity has been sealed, as all parties recognize the highly sensitive subject matter of
+the charges and the need to protect the privacy interest of Plaintiff's identity.
+In this civil action, Defendant, Jeffrey Epstein, already knows Plaintiff's identity
+and will be privy to the sealed document containing Plaintiff's name. Therefore, he knows the
+identity of Plaintiff and will not be prejudiced by public non-disclosure of Jane Doe No. 101's
+identity.
+8.
+There is great need, in this case, to protect intimate information about Plaintiff,
+Jane Doe No. 101, and to protect her privacy interest.
+Memorandum of Law
+The general presumption against anonymous or pseudonymous pleadings is commonly
+overcome in certain types of cases, and courts have discretion to permit such pleading in
+appropriate circumstances. "[P]rivacy or confidentiality concerns are sometimes sufficiently
+critical that parties or witnesses should be allowed this rare dispensation." James v. Jacobson, 6
+F.3d 233, 238 (4th Cir. 1993). As is ordinarily the case where trial courts have discretion,
+judicial guidelines exist for the exercise of such discretion in the form of factors that courts
+should consider in deciding whether to grant anonymity requests. They are not many, for the
+question happily is one that is seldom raised. Nevertheless, some guidelines can be gleaned from
+the relatively few cases—both at the trial and appellate levels that have wrestled with the
+problem. Among them are the following that have relevance to this case: whether the
+2
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 3 of 5
+justification asserted by the requesting party is merely to avoid the annoyance and criticism that
+may attend any litigation or to preserve privacy in a matter of sensitive and highly personal
+nature; whether identification poses a risk of retaliatory physical or mental harm to the
+requesting party or, even more critically, to innocent non-parties; the ages of the persons whose
+privacy interests are sought to be protected; and, relatedly, the risk of unfairness to the opposing
+party from allowing an action against it to proceed anonymously. See id. (internal citations
+omitted).
+In deciding whether to permit pseudonymous pleadings, courts must balance "the
+plaintiff's right to privacy and security against the dual concerns of (1) public interest in
+identification of litigants and (2) harm to the defendant stemming from [suppression] of
+plaintiff's name." Doe v.
+105 F. Supp. 2d 40, 44 (E.D.N.Y. 1999) (internal citation
+omitted). The ultimate test for permitting a plaintiff to proceed anonymously is whether the
+plaintiff has a substantial privacy right that outweighs the customary presumption of openness in
+judicial proceedings. See Doe v. Stegall, 653 F.2d 180, 185-86 (5th Cir. August 10, 1981).
+Courts typically accept pseudonym filing in cases where the nature of the pleading unveils highly
+sensitive information and detail about the plaintiff, such that the non-disclosure of the party's
+name is necessary to protect her from harassment, injury, ridicule, or personal embarrassment.
+See United States v. Doe, 655 F.2d 920, 922 n. 1 (9th Cir. 1981); see also Doe v.
+429 F.3d
+706 (7th Cir. 2005) (court required to consider whether the interests of justice required adult
+woman, who was videotaped having consensual sex with her boyfriend when she was a minor, to
+disclose her name as plaintiff in lawsuit against boyfriend alleging that boyfriend illegally
+distributed videotape); Does I Thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1067-68
+(9th Cir. 2000) (district court abused its discretion in denying permission to proceed
+anonymously to Chinese employees working in garment industry in Mariana Islands where
+3
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 4 of 5
+employees were vulnerable to retaliation); Stegall, 653 F.2d at 185-86 (anonymity warranted to
+protect minor plaintiffs against risk of violence from revelation of unpopular personal beliefs);
+Doe v. United Servs. Life Ins. Co., 123 F.R.D. 437 (S.D.N.Y. 1988) (anonymity allowed because
+of sensitive privacy and retaliation concerns in suit by homosexual against insurance company
+alleging discriminatory practices; no unfairness to defendant, who was aware of claimant's
+identity); Candy H. v. Redemption Ranch, 563 F. Supp. 505 (M.D. Ala. 1983) (anonymity
+allowed in suit by pregnant 19-year-old alleging fraudulent inducement to enter defendant's
+Home for Girls).
+It is clear from the allegations of sexual abuse of a minor in the Complaint that the
+information is of a highly sensitive nature. Jane Doe No. 101's name remained anonymous in
+the related criminal case, and Defendant's attorneys, as well as the United States government,
+redacted all documents containing her name. The present case is not one in which permitting
+Plaintiff to proceed anonymously will disadvantage Defendant in any way. Defendant already
+knows Plaintiff's identity and will be privy to the sealed document containing Plaintiff's name.
+While the public normally has a right to the openness of judicial proceedings, the victim's
+privacy interest greatly outweighs the right to know the identity of a victim of child sex abuse.
+Other than the identity of Plaintiff, the aspects of this case will be available to the public.
+Evidently, the balance weighs overwhelmingly in favor of allowing Plaintiff to proceed
+anonymously.
+This Court recently has allowed at least ten other plaintiffs who were underage sex abuse
+victims of Defendant, Jeffrey Epstein, to proceed anonymously. See C.M.A. v. Epstein et al.,
+Case No. 9:08-cv-80811-KAM; Jane Doe No. 1 v. Epstein, Case No. 9:08-cv-80069-KAM;
+Jane Doe No. 2 v. Epstein, Case No. 9:08-cv-80119-KAM; Jane Doe No. 3 v. Epstein, Case No.
+9:08-Cv-800232; Jane Doe No. 4 v. Epstein, Case No. 9:08-cv-80380-KAM; Jane Doe No. 5 v.
+4
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 14-1 Entered on FLSD Docket 05/06/2009 Page 5 of 5
+Epstein, Case No. 9:08-cv-80381-KAM; Jane Doe No. 6 v. Epstein, Case No. 9:08-cv-80994-
+KAM; Jane Doe No. 7 v. Epstein, Case No. 9:08-cv-80993-K.AM; Jane Doe v. Epstein, Case No.
+9:08-cv-80893-KAM; Jane Doe v. Epstein et al., Case No. 9:08-cv-80804-KAM; Jane Doe v.
+Epstein, Case No. 9:08-cv-80469-KAM. Accordingly, this Court should likewise permit Jane
+Doe No. 101 to proceed anonymously.
+WHEREFORE, Plaintifi, Jane Doe No. 101, moves this Court to enter an Order granting
+this Motion, thus allowing her to proceed in this litigation under the Jane Doe No. 101
+pseudonym.
+Date: April 17, 2009
+Robert L. braufstes bo
+Robert C. Josefsberg, Bar No. 040856'
+Katherine W. Ezell, Bar No. 114771
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+(305) 358-2800
+(305) 358-2382 (fax)
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Attorneys for Plaintiff
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+On April 1, 2009, undersigned counsel conferred with counsel for Defendant in a good
+faith effort to resolve the issues raised in this motion, and Defendant's counsel advised that
+Defendant opposes this motion.
+Date: April 17, 2009
+Robert Cerateg by Kur
+ROBERT C. JOSEYSBERG
+Florida Bar No. 040856
+5
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305358.2800 Fax 305.258.2382 • Fort Lauderdale 54.4634346 T
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3.receipt.json b/vision-fixhub/court-01/f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..07c731a2a1c8dae6dfdc376a6057d28d113b4dc2
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@@ -0,0 +1,14 @@
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+  "doc_id": "f021c361c7eadc5314218c3a74f44c7e90f5ec5ebcd52c28120330d852565ae3",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "eda6dfe12fd8cd362cee6cc561cebfd8ac3b75e9d5cf94ec1b027379fd708d5b",
+  "output_sha256": "46a29aeab9f8ecdaa74a7df6930672b6507aa1d9c342776269544d82fb7141ea",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f0260b1d7a90bcc4d7b053cfb994fcc452c341b51013544317755921e63afcea.md b/vision-fixhub/court-01/f0260b1d7a90bcc4d7b053cfb994fcc452c341b51013544317755921e63afcea.md
new file mode 100644
index 0000000000000000000000000000000000000000..058a1f805c4d0f6f3e1208cb0b60dd283eba3947
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@@ -0,0 +1,53 @@
+Case 9:08-cv-80119-KAM Document 305-7
+Entered on FLSD Docket 09/17/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-:
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF MARK T. LUTTIER
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+) SS
+)
+BEFORE ME, the undersigned authority, personally appeared Mark T. Luttier., having
+personal knowledge and being duly sworn, deposes and says:
+I am counsel for Jeffrey Epstein in the above-styled matter and other civil
+lawsuits.
+The information contained in motion, paragraphs 1 through 10, 11, 13, 14 and 16
+is true and accurate based on my personal knowledge.
+FURTHER THE AFFIANT SAYETH NAUGHT.
+Mach Si Cutter
+Mark T. Luttier
+
+7
+
+
+Case 9:08-cv-80119-KAM Document 305-7 Entered on FLSD Docket 09/17/2009 Page 2 of 2
+Jane Doe No. 4 v. Epstein
+Page 2
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+oaths and take acknowledgments, personally appeared Mark T. Luttier, known to me to be the
+person described in and who executed the foregoing Affidavit, who acknowledged before me
+that he/she executed the same, that I relied upon the following form of identification of the above
+named person: Del Sonally Known, and that an oath was/was not taken.
+VINESS m
+hand and official seal in the County and State last aforesaid this /77
+_ 2009.
+JESSICA CADWELL
+MY COMMISSION # DD 853528
+EXPIRES: April 19,2013
+Bonded Thru Notary Public Underwriten
+lessin Indwell
+/ PRINT NAME: JESSICA CADETERIC
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO: 35853529
+MY COMMISSION EXPIRES: 04/19/13
diff --git a/vision-fixhub/court-01/f0260b1d7a90bcc4d7b053cfb994fcc452c341b51013544317755921e63afcea.receipt.json b/vision-fixhub/court-01/f0260b1d7a90bcc4d7b053cfb994fcc452c341b51013544317755921e63afcea.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..26ea09ee208b14c210855e61792592493d19a9e6
--- /dev/null
+++ b/vision-fixhub/court-01/f0260b1d7a90bcc4d7b053cfb994fcc452c341b51013544317755921e63afcea.receipt.json
@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.md b/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.md
new file mode 100644
index 0000000000000000000000000000000000000000..c9160d44608131e5268efbfb1f6fac8fdc981cb5
--- /dev/null
+++ b/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.md
@@ -0,0 +1,141 @@
+Case 9:08-cv-80736-KAM Document 82 Entered on FLSD Docket 05/16/2011 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION TO SUPPLEMENT AUTHORITIES IN
+SUPPORT OF THEIR MOTION FOR AN ORDER DIRECTING THE U.S.
+ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move to supplement their authorities in support of their Motion
+for an Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE #50)
+with a letter just received from the Justice Department's Office of Professional Responsibility.
+As the Court is aware, briefing on the victims' motion for an order directing the
+government not to withhold evidence was completed when the victims filed their reply
+memorandum on May 2, 2011. On May 10, 2011, however, victims' counsel received a letter
+from the Justice Department's Office of Professional Responsibility (attached as exhibit 1) that
+they wish to have the Court consider along with their pleading. This letter makes clear that the
+Government has in its possession information that will be helpful to the victims' case and further
+that the Government is not currently investigating these issues. Because this letter arrived only
+after the filing of their reply, the victims request leave to supplement their pleadings with this
+letter.
+1
+
+
+Case 9:08-cv-80736-KAM Document 82 Entered on FLSD Docket 05/16/2011 Page 2 of 5
+A bit of context may be useful. On December 10, 2010, Jane Doe #1 and her legal
+counsel, Brad
+and Paul Cassell, met in Miami with Wilfredo Ferrer, United States
+Attorney for the Southern District of Florida; Ben Greenburg, First Assistant U.S. Attorney;
+Dexter Lee, Assistant U.S. Attorney; and A.
+Villafaña, Assistant U.S. Attorney and line
+prosecutor on the Epstein matter. Without going into the details of that settlement discussion,
+the result of that meeting was a few days later, Mr. Ferrer sent a request to the Justice
+Department's Office of Professional Responsibility to investigate and determine whether any
+misconduct had occurred during the Epstein investigation and prosecution. Victim's counsel
+thereafter repeatedly requested information about the status of the investigation and received no
+information.
+On May 10, 2011, however, victims' counsel received a letter from OPR concluding that
+OPR had "completed an inquiry" into the issue and had decided not to investigate. The letter
+acknowledged that the Office had made an inquiry into the facts, but explained that it is "the
+policy of this Office to refrain from investigating issues or allegations that were, are being, or
+could have been addressed in the course of litigation ...." The letter noted that because the
+issues surrounding the Office's negotiation of the NPA were being litigated in this very case, it
+was not consistent with OPR policy to further investigate.
+The victims wish to include this letter as supplemental authority in support of their
+motion for an order directing the U.S. Attorney's Office not to withhold relevant information.
+The letter makes clear that it is only before this Court that such issues can be adjudicated. The
+letter further makes clear the stark bottom line of the pending motion - at least two Justice
+Department components (the U.S. Attorney's Office for the Southern District of Florida and the
+2
+
+
+Case 9:08-cv-80736-KAM Document 82 Entered on FLSD Docket 05/16/2011 Page 3 of 5
+Office of Professional Responsibility) have both reviewed the issues surrounding the Epstein
+case and have bundled together information regarding the case. And yet, on the basis that the
+victims are litigating before this Court, the Justice Department refuses to conduct its own
+investigation into what happened and refuses to provide that information to the victims. The
+letter thus makes clear that if the Government is allowed to withhold relevant evidence from the
+victims' in this case, there will never a full understanding of why the Government violated the
+victims' rights and why it offered such an extraordinarily lenient non-prosecution agreement to
+Epstein without the victims' knowledge. For all these reasons, the letter strongly supports the
+victims' motion that the Court should enter an order directly the Government not to withhold
+evidence.
+The Government opposes the motion.
+In light of the foregoing, the Court should allow the victims' to supplement the
+authorities in support of their motion for an order directing the Government not to withhold
+evidence with the attached letter from OPR.
+DATED: May 16, 2011
+Respectfully Submitted,
+s/l
+J.
+JAFFE, WEISSING,
+|. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+3
+
+
+Case 9:08-cv-80736-KAM Document 82 Entered on FLSD Docket 05/16/2011 Page 4 of 5
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on May 16, 2011, on the following using the Court's
+CM/ECF system:
+Dexter Lee
+A.
+[Villafaña
+Assistant U.S. Attorneys
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoj.gov
+A tomeys for the Covemment
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+(305) 37106421
+(305) 358-2006
+4
+
+
+Case 9:08-cv-80736-KAM Document 82 Entered on FLSD Docket 05/16/2011 Page 5 of 5
+G. Weinberg, P.C.
+20 Park Plaza
+Suite 1000
+Boston,
+02116
+(617) 227-3700
+(617) 338-9538
+L. Ackerman, Jr.
+Burnett PA
+777 S. Flagler Drive, West Tower, Suite 901
+West Palm Beach, FL 33401
+Criminal Defense Counsel for Jeffrey Epstei
+(courtesy copy of pleading via U.S. mail)
+Bruce E. Reinhart
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Breinhart@ BruceReinhartLaw.com
+(via U.S. mail)
+5
diff --git a/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.receipt.json b/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..663c43675f32fee6e09a5199cc6adb7a0abdf4a7
--- /dev/null
+++ b/vision-fixhub/court-01/f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "f029dca6e769c29aecb6e03c4995f1d64e58fcb0c3fe81187f80de6298a49fa2",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.md b/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.md
new file mode 100644
index 0000000000000000000000000000000000000000..ceb5ef3d93328269c977936bf64b56e9c2679ebe
--- /dev/null
+++ b/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.md
@@ -0,0 +1,169 @@
+Case 9:08-cv-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80380-CIV-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+OPINION AND ORDER ON MOTION TO SET ASIDE
+CLERK'S ENTRY OF DEFAULT
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to Set
+Aside Clerk's Default (DE 11), filed June 13, 2008. The motion is now fully briefed and is ripe
+for review. The Court has carefully considered the motion and is otherwise fully advised in the
+premises.
+On April 14, 2008, Plaintiff Jane Doe No. 4 ("Plaintiff") filed the instant action against
+Jeffrey Epstein ("Defendant"), alleging claims of sexual assault and intentional infliction of
+emotional distress. (DE 1.) Plaintiff's process server attempted to deliver a copy of the
+summons and complaint to Defendant personally on April 23, April 24, and May 1, 2008, at his
+residence in New York City. (DE 6.) None of these attempts were successful. On May 7, 2008,
+the process server left a copy of the summons and complaint with "John
+' Assistant &
+House Staff Employee who refused true name." (DE 6.) The process server also mailed a copy
+of the summons and complaint to Defendant on May 12, 2008, via first class mail. (DE 6.) The
+1
+
+
+Case 9:08-cv-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 2 of 6
+envelope was marked "personal and confidential" and did not indicate that the envelope was
+from an attorney or related to a legal action. (DE 6.)
+Standard of Review
+Rule 55(c) of the Federal Rules of Civil Procedure states that a "court may set aside an
+entry of default for good cause." Fed. R. Civ. P. 55(c). The Court is vested with considerable
+discretion in ruling on a motion to set aside an entry of default, and the Court's decision will only
+be reviewed for abuse of discretion.
+v. US, 734 F.2d 735, 739 (11" Cir. 1984); Baez v.
+S.S. Kresge Co., 518 F.2d 349, 350 (5' Cir. 1975).' "[DJefaults are seen with disfavor because
+of the strong policy of determining cases on their merits." Florida Physicians Insurance Co. v.
+Ehlers, 8 F.3d 780, 783 (11" Cir. 1993). To obtain relief under Rule 55(c), the movant must only
+make a "bare minimum showing" to support her claim for relief.
+v. Harrell, 858 F.2d 667,
+669 (11" Cir. 1988).
+In evaluating whether a movant has demonstrated "good cause," courts have considered
+several potential factors: whether the default was culpable or willful; whether setting the default
+aside would be prejudicial to the opposing party; whether the defaulting party presents a
+meritorious defense; whether public interests have been implicated; whether the defaulting party
+has suffered significant financial losses; and whether the defaulting party acted promptly to
+correct the default. Compania Interamericana Export-Import, S.A. v. Compania Dominicana de
+Aviacion, 88 F.3d 948, 951 (11" Cir. 1996). These factors are simply guidelines and are not
+"talismanic." Id. While willfulness, prejudice, and a meritorious defense are the most often
+'In Bonner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11" Cir. 1981) (en banc),
+the Eleventh Circuit adopted as binding precedent the decisions of the Fifth Circuit rendered
+prior to October 1, 1981.
+2
+
+
+Case 9:08-cV-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 3 of 6
+considered factors, "the failure of a district court to expressly consider them does not necessarily
+constitute an abuse of discretion." KPS & Associates, Inc. v. Designs by FMC, Inc., 318 F.3d 1,
+12 (1" Cir. 2003).
+Discussion
+Rule 4(e) of the Federal Rules of Civil Procedure states that an individual may be served
+by "following state law for serving a summons in an action brought in courts of general
+jurisdiction in the state where the district court is located or where service is made." Fed. R. Civ.
+P. 4(e)(1). Alternatively, service may be made by leaving a copy of the summons and complaint
+at the individual's place of abode "with someone of suitable age and discretion who resides
+there." Fed. R. Civ. P. 4(e)(2)(B).
+Plaintiff claims that service in this case is valid pursuant to either Fed. R. Civ. P.
+4(e)(2)(B) or Florida law. Like the Federal Rules, Florida law requires that process be left at the
+individual's usual place of abode "with any person residing therein who is 15 years of age or
+older." Fla. Stat. § 48.031(1)(a). The affidavit of service (DE 6) states that the summons and
+complaint were left with "John
+at Defendant's usual place of'abode. From this
+declaration, the Court cannot determine whether "John
+resides at the Manhattan
+apartment. Further, Defendant has submitted the affidavit of Richard Barnett, who avers that he
+received copies of the summons and complaint on May 7, 2008, from the process server. (DE 11
+Ex. A.) Because Plaintiff has provided no indication to suggest that "John
+resides at the
+apartment, the Court concludes that Plaintiff did not effect valid service on Defendant under Fed.
+R. Civ. P. 4(e)(2)(B) or Fla. Stat. § 48.031(1)(a).
+The Court does not believe that Plaintiff's request for discovery on the issue of service is
+3
+
+
+Case 9:08-cV-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 4 of 6
+necessary, because service of process was made pursuant to New York law. Under New York
+law, personal service may be made on an individual by
+delivering the summons within the state to a person of suitable age and
+discretion at the actual place of business, dwelling place or usual place of
+abode of the person to be served and by either mailing the summons to the
+person to be served at his or her last known residence or by mailing the
+summons by first class mail to the person to be served at his or her actual
+place of business in an envelope bearing the legend "personal and
+confidential" and not indicating on the outside thereof, by return address
+or otherwise, that the communication is from an attorney or concerns an
+action against the person to be served, such delivery and mailing to be
+effected within twenty days of each other.
+N.Y. C.P.L.R. § 308(2) (McKinney 2008) (emphasis added). New York law does not require
+the person receiving the summons and complaint at the individual's place of abode to reside at
+that location. See, e.g., Boston Safe Deposit and Trust Co. v. Morse, 779 F. Supp. 347, 350
+(S.D.N.Y. 1991); Al Fayed v. Barak, 833 N.Y.S. 2d 500, 501 (N.Y. App. Div. 2007).
+In this case, the affidavit of service states that "John
+was a person of suitable age
+and discretion who accepted a copy of the summons and complaint at Defendant's actual
+apartment. (DE 6.) Thus, under New York law, delivery of the summons and complaint to
+"John
+was appropriate. Because the summons and complaint were mailed to Defendant
+and delivered to his residence within twenty days of each other, Plaintiff took all necessary steps
+to serve Defendant under New York law.
+As Defendant recognizes, New York law also requires that proof of service be "filed with
+the clerk of the court designated in the summons within twenty days of either such delivery or
+mailing, whichever is effected later." N.Y. C.P.L.R. § 308(2). Here, Plaintiff is in compliance
+with this requirement as well: delivery was made on May 7, 2008, and proof of service was filed
+4
+
+
+Case 9:08-cv-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 5 of 6
+with the Clerk of the Court on May 27, 2008. (DE 4.) Thus, service was deemed complete as of
+June 6, 2008, under New York law. See N.Y. C.P.L.R. § 308(2) (stating "service shall be
+complete ten days after" filing of proof of service).
+Nevertheless, Defendant's analysis is not entirely correct. In calculating when
+Defendant's response was due, the Court turns to Fed. R. Civ. P. 12(a), which states that a
+defendant must serve an answer within twenty days of being served with the summons and
+complaint. Fed. R. Civ. P. 12(a)(1)(A)(i). Under this rule, Defendant was required to respond to
+the Complaint within twenty days from the receipt of the summons; the rule does not suggest a
+longer period of time is available when substituted service is used to serve a defendant. While
+Rule 4(e)(1) allows Plaintiff to serve process on Defendant in the method permitted by New
+York, Rule 4(e)(1) does not alter the twenty day period specified by Rule 12(a). In other words,
+under Rules 4(e)(1) and 12(a), the Court is not bound by New York's proof of service filing
+requirement nor New York's "completion" date in determining when Defendant's answer needed
+to be filed. Beller &
+v. Tyler, 120 F.3d 21, 25-26 (2d Cir. 1997) (reconciling the deadlines
+imposed by Rule 12(a) and N.Y. C.P.L.R. § 308). Instead, once Defendant received a copy of the
+summons and complaint, Defendant had twenty days to respond. Id. ("[A] defendant has twenty
+days from the receipt of the summons to file an answer ... This is so even if ... the defendant
+is served pursuant to a state law method of service and the state law provides a longer time in
+which to answer."). Thus, Defendant's response was due on May 27, 2007.?
+"In Tyler, the court acknowledged that, because service was made in part by mail, the
+defendant may have the benefit of three extra days to respond per Fed. R. Civ. P. 6(e). Tyler, 120
+F.3d at 26. In this case, Plaintiff's server mailed the summons and complaint on May 12, 2008.
+Thus, under this scheme, Defendant would have had until June 4, 2008, to respond. Either way,
+Defendant failed to appear int his case until June 13, 2008.
+
+
+Case 9:08-cv-80380-KAM Document 28 Entered on FLSD Docket 07/16/2008 Page 6 of 6
+The Court is forced to conclude that Defendant, at this juncture, has not demonstrated
+"good cause" to vacate the default. Defendant incorrectly argued that he timely responded to the
+Complaint. Since he was mistaken in his position, he limited his argument to this point of law
+and did not address the other requirements for setting aside a default, where a defendant's
+appearance is, in fact, untimely. See, e.g.. United Coin Meter Co., Inc. v. Seaboard Coastline
+RR, 705 F.2d 839, 845 (6" Cir. 1983). Accordingly, it is ORDERED AND ADJUDGED that
+Defendant's Motion to Set Aside Default (DE 11) is DENIED WITHOUT PREJUDICE.
+Because Defendant did not address his motion to the issue of "good cause," and because it is the
+policy of this Court to rule on the merits of a case whenever possible, see, e.g.,
+IT Media,
+Inc. v. Intelligentz Corp., No. 07-80535-CIV, 2008 WL 162754 (S.D. Fla. Jan. 16, 2008), the
+Court grants Defendant leave to file a second motion to vacate the default. Defendant shall have
+ten (10) days from the date of entry of this Order to file a second motion to vacate the Clerk's
+entry of default.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 16" day of July, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+Jeffrey Epstein, pro se
+6
diff --git a/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.receipt.json b/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a61b6d1482795523a2bed9c3cabb103b8c9c0def
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+++ b/vision-fixhub/court-01/f050eac53e92ff0c4b63b9306b0de875c0d068314a6b4e07e9e634cac77b5839.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/f064affcf56a5e62f5587dd63ca6d68cadd0d0ab39b8ab8198f44434e1c5c29f.md b/vision-fixhub/court-01/f064affcf56a5e62f5587dd63ca6d68cadd0d0ab39b8ab8198f44434e1c5c29f.md
new file mode 100644
index 0000000000000000000000000000000000000000..b081ba56aefac3278e19099fd1a854c92b7b2234
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+++ b/vision-fixhub/court-01/f064affcf56a5e62f5587dd63ca6d68cadd0d0ab39b8ab8198f44434e1c5c29f.md
@@ -0,0 +1,181 @@
+Case 9:08-cv-80119-KAM Document 113-1 Entered on FLSD Docket 05/22/2009 Page 1 of 4
+
+to
+Plaintiffs Jane Doe 101 and Jane Doe 102's
+Motion for No-Contact Order
+
+
+: "
+Case 9:08-cv-80119-KAM Document 113-1 Entered on FLSD Docket 05/22/2009 Page 2 of 4
+1
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CRIMINAL DIVISION
+STATE OF FLORIDA
+VS
+CASE NO.
+06 CF9454AMB
+0 8
+9381CFAMB
+JEFFREY EPSTEIN
+Defendant.
+• PLEA CONFERENCE
+PRESIDING: HONORABLE DEBORAH DALE PUCILLO
+APPEARANCES:
+ON BEHALF OF THE STATE:
+BARRY E. KRISCHER, ESQUIRE
+State Attorney
+401 North Dixie Highway
+West Palm Beach, Florida 33401
+By:
+LANNA BELOHLAVEK, ESQUIRE
+Assistant State Attorney
+ON BEHALF OF THE DEFENDANT:
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, Florida 33401
+By: JACK GOLDBERGER, ESQUIRE
+CERTIFIED COPY
+June 30, 2008
+Palm Beach County Courthouse
+West Palm Beach, Florida 33401
+Beginning at 8:40 o'clock, a.m.
+--
+PHYLLIS A. DAMES,
+OFFICIAL COURT REPORTER
+
+
+Case 9:08-cv-80119-KAM Document 113-1 Entered on FLSD Docket 05/22/2009 Page 3 of 4
+20
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+regularly congregate?
+MS. BELOHLAVEK: I personally do not
+know.
+THE COURT: Neither do I, which is
+why I'm asking. Has that been
+investigated?
+MR. GOLDBERGER: We have done our due
+diligence, for what it's worth, there is a
+residential street.' There are not children
+congregating on that street. We think the
+address applies, if it doesn't, we fully
+recognize that he can't live there.
+THE COURT: Okay. Dis, you shall
+not have any contact with the victim, are
+there more than one victim?
+MS. BELOHLAVEK: There's several.
+THE COURT: Several, all of the
+victims. So this should be plural. I'm
+making that plural. You are not to have
+any contact direct or indirect, and in this
+day and age I find it necessary to go over
+exactly what we mean by indirect. By
+indirect, we mean no text messages, no
+e-mail, no Face Book, no My Space, no
+telephone calls, no voice mails, no
+PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
+
+
+Case 9:08-cv-80119-KAM Document 113-1 Entered on FLSD Docket 05/22/2009 Page 4 of 4
+1
+2
+3
+4
+5
+6
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+21
+messages through carrier pigeon, no
+messages through third parties, no hey
+would you tell so and so for me, no having
+a friend, acquaintance or stranger approach
+any of these victims with a message of any
+sort from you, is that clear?
+THE DEFENDANT: Yes,
+THE COURT: And then it states,
+unless approved by the victim, the
+therapist and the sentencing court. Okay.
+THE DEFENDANT: I understand.
+THE COURT: And the sentencing court.
+So, if there is a desire which, I would
+think would be a bit strange to have
+contact with any of the victims the court
+must approve it.
+MS. BELOHLAVEK: Correct.
+THE COURT: If the victim was under
+the age of 18, which was the case, you
+shall not until you have successfully
+attended and completed the sex offender
+program. So, is this sex offender program
+becoming a condition of probation?
+MS. BELOHLAVEK: That is not. I
+don't believe I circled that one.
+.
+PHYLLIS A. DAMES, OFFICIAL COURT REPORTER
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diff --git a/vision-fixhub/court-01/f0697b9b925d4aa177aa5d29eac40b7318988fb70400a99ae1581ba577198f22.md b/vision-fixhub/court-01/f0697b9b925d4aa177aa5d29eac40b7318988fb70400a99ae1581ba577198f22.md
new file mode 100644
index 0000000000000000000000000000000000000000..ea19999ee79034fe24d139a7bf7b354cdb1a384d
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+++ b/vision-fixhub/court-01/f0697b9b925d4aa177aa5d29eac40b7318988fb70400a99ae1581ba577198f22.md
@@ -0,0 +1,1639 @@
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 1 of 26
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintitt,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+THIRD PARTY WITNESS, IGOR ZINOVIEW'S,
+MOTION FOR PROTECTIVE ORDER AND
+INCORPORATED MEMORANDUM OF LAW
+Third Party Witness, Igor Zinoview's, ("Mr. Zinoview") by and through his
+undersigned attorney, moves this Court pursuant to Fed. R. Civ. P. 26(c) for a protective
+order regarding his deposition and as grounds therefore would state:
+As reflected on the affidavit of Igor Zinoview, attached as Exhibit A, he
+works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did
+not know Mr. Epstein before November of 2005. He first became employed by Mr.
+Epstein in November of 2005.
+2.
+Additionally, Mr. Zinoview would testify as set forth on his affidavit, that
+at no time has he discussed with Mr. Epstein any issues involving Mr. Epstein's criminal
+case nor any of the cases or issues involved with civil plaintiffs.
+1
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 2 of 26
+3.
+In many of the depositions, counsel for L.M. and E.W., has asked them as
+witnesses to assume certain facts about which they have no knowledge, and he then asks
+their opinions about certain facts. See Exhibit B -Epstein's Motion for Protective Order
+to Prohibit Inappropriate Deposition Questions.
+4.
+There is no information which Mr. Zinoview has relating to the facts and
+circumstances surrounding any of the pending civil cases, in that none of their allegations
+directed to Mr. Epstein extend beyond September of 2005. Therefore whatever
+information Mr. Zinoview may have, postdates that time.
+5.
+Regarding the scope of discovery, Judge Linnea
+noted in her
+October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it
+is not without limits. Washington v.
+& Williamson Tobacco, 959 F.2d 1566,
+1570 (11th Cir. 1992)... Courts have long held that '[w]hile the standard of relevancy
+[in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow
+zones of relevancy and to explore matter (sic) which does not presently appear germane
+on the theory that it might conceivably become so.' Food Lion, Inc. y. United Food &
+Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string
+cite omitted)."
+6.
+Rule 26(c), Federal Rules of Civil Procedure, provides that, "[a] party or
+any person from whomn discovery is sought may move for a protective order in the court
+where the action is pending.... The court may, for good cause, issue an order to protect
+a party or person from annoyance, embarrassment, oppression, or undue burden or
+expense, including
+one or more of the following: (A) forbidding the disclosure or
+discovery;"
+2
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 3 of 26
+7.
+As set forth in his affidavit, Mr. Zinoview cannot possibly have any
+knowledge or information that is presently germane to this action. Accordingly, the
+Court should enter a protective order prohibiting his deposition.
+WHEREFORE, third-party witness moves this court for a protective order
+pursuant to Rule 26(c), Federal Rules of Civil Procedure, that his deposition not take
+place or the questioning be limited.
+BACK ALAN GOLDBEROER ESO.
+Florida Bar No. 262013
+jagesq@bellsouth.net
+Rule 7.1 Certification
+I hereby certify that counsel for the movant has conferred or attempted to confer
+with opposing counsel in a good faith effort to resolve the discovery issues prior to the
+filing of this motion for protective order but has been unable to do so.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+vith the Clerk of the Court using CM/ECF. I also certify that the foregoing document i
+he manter spectay by Conf record iden November lowing Service List i
+_ day of November, 2009
+Respectfully submitted,
+By:
+JACK ALAN GOLDBERGER ESQ.
+Florida Bar No. 262013
+agesq@bellsouth.ne
+terbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+(Counsel for Defendant Jeffrey Epstein)
+3
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 4 of 26
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, Paul G. Cassell, Esq.
+08-80232, 08-80380, 08-80381, 08-80993,
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A.
+801-585-6833 Fax
+229010 Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+1 Esq.
+Fax: 561-588-8819
+Law Firm, P.A.
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.|
+, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+Bruce Reinhart, Esq.
+kezell@podhurst.com
+Bruce E. Reinhart, P.A.
+Counsel for Plaintiffs in Related Cases
+250 S. Australian Avenue
+Nos. 09-80591 and 09-80656
+Suite 1400
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+4
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 5 of 26
+561-202-6360
+Fax: 561-828-0983
+ccf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL. 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+5
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 6 of 26
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-J
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF IGOR ZINOVIEV
+) SS
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+BEFORE ME, the undersigned authority, personally appeared Igor Zinoviev
+having personal knowledge and being duly sworn, deposes and says:
+1.
+My name is Igor Zinoview.
+2.
+I began working for Mr. Epstein in November of 2005.
+3.
+I did not know him until I began working for him.
+I have never discussed nor has he ever attempted to discuss with me any facts or
+information relating to any legal matters in which he is involved.
+I work for Mr. Epstein as his driver, bodyguard and trainer.
+EXHIBIT_A
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 7 of 26
+Page 2
+FURTHER THE AFFIANT SAYETH NAUGHT.
+gor novie
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+named person: Ijor Zinoview
+WITNESS my hand and official seal in the County and State last aforesaid this
+day of Ma. 9
+- 2009.
+CL MAHONE
+NOTARY
+C: My Comm. Expires
+May 28, 2010
+No. DD519867
+Set Make
+NAME
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.:
+MY COMMISSION EXPIRES:
+(SEAL)
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 8 of 26
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA028051XXXXMB AB
+L.M.,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO
+PROHIBIT INAPPROPRIATE DEPOSITION QUESTIONS
+Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 1.280(c), Florida
+Rules of Civil Procedure, moves for a protective order to prohibit argumentative,
+harassing and inappropriate questions in depositions, and states:
+At numerous depositions, Plaintiff's counsel has repeatedly asked
+argumentative and harassing questions that are irrelevant and not reasonably
+calculated to lead to the discovery of admissible evidence.
+2.
+In particular, Plaintiff's counsel has asked questions that improperly
+sought to illicit lay opinions from fact witnesses, asked questions regarding witnesses'
+feelings towards Mr. Epstein and their beliefs regarding media reports of this case,
+asked whether they would leave their children with Mr. Epstein and asked whether they
+would go back to work for Mr. Epstein assuming the media reports were accurate,
+among other things.
+These questions and the responses thereto will never be
+admissible. They are argumentative, irrelevant and seek speculative answers and
+inadmissible lay opinions.
+EXHIBIT_B
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 9 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+3.
+For example, in the deposition of Larry Visoski, one of Mr. Epstein's pilots,
+Plaintiff's counsel asked the following questions seeking to obtain Mr. Visoski's beliefs
+and opinions on Plaintiff's allegations:
+Q.
+All right.
+When you read in the newspapers
+allegations that Mr. Epstein was involved with
+underage girls for sexual reasons, were you surprised?
+the
+numerous
+A. I didn't believe it.
+Q. Do you believe it today?
+A. I don't believe it.
+Q. You don't believe that Jeffrey Epstein was involved with
+underage girls in a sexual way?
+MR. CRITTON: Form.
+THE WITNESS: You're asking for my opinion, and I don't
+think my opinion is relevant in that matter.
+BY MR.
+Q. I think it's relevant. Can you just tell me whether today
+you believe that Jeffrey Epstein has engaged in sex with
+underage girls?
+MR. CRITTON: Form; speculation, irrelevant, always.
+THE WITNESS: It's irrelevant.
+BY MR.
+Q. I need an answer.
+A. I don't believe he had sex with underage women.
+Q. Or engaged in any sexual acts with underage women?
+MR. CRITTON: Form.
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 10 of 26
+LM V. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+THE WITNESS: No.
+BY MR.
+Q.
+You think that this is just a story that a bunch of
+underage women have made up?
+A.
+Speculation.
+** * *
+Q. Then we'll handle the question this way: If you were to
+believe based on information and evidence that Mr. Epstein
+engaged in sex or some form of sex acts with people of the
+age range of 12, 13, 14, 15 years old, would you continue
+your employment with Mr. Epstein?
+MR. CRITTON: Form; speculation.
+THE WITNESS:
+I would certainly be speculating
+and I have to discuss it with my wife long and hard. I don't
+think I could give you a correct and honest answer at this
+time.
+See Excerpts of Deposition of Larry Visokski at 66-67; 181-82 (attached as
+composite Exhibit A). Other examples of similar improper questions are included in
+
+4.
+Not only do these questions seek improper lay opinions, Plaintiff's counsel
+asked Mr. Visoski his belief as to the truth of hearsay newspaper articles. The
+foregoing questions are obviously irrelevant, argumentative and not reasonably
+calculated to lead to the discovery of admissible evidence.
+5.
+Moreover, whether Mr. Visoski would continue working for Mr. Epstein if
+Plaintiff's allegations are true has absolutely no relevance to any claim or defense in this
+case.
+The questions are simply improper and meant to harass and embarrass the
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 11 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+witness.
+6.
+Mr. Visoski was questioned for over four hours and much of the time was
+wasted on irrelevant and harassing questions.
+7.
+Plaintiff's counsel asked similar questions at the deposition of Larry
+Eugene
+another one of Mr. Epstein's pilots:
+Q. Certainly you've read certain newspaper articles about
+the allegations, police reports, otherwise, the allegations that
+occurred or have been alleged to have occurred at his Palm
+Beach mansion, correct?
+A. Uh-huh.
+Q. Correct?
+A. Correct.
+Q. Given the nature of those allegations, would you leave
+your daughter of 17, 16, 15 years old with Mr. Epstein
+alone?
+MR. PIKE: Form. Move to strike.
+A. Yes.
+****
+Q. And despite pleading guilty to procuring underage girls
+for the purposes of sex, you still feel comfortable leaving a
+13, 14, 15-year-old girl around him?
+MR. PIKE: Form. Move to strike.
+A.
+Yes. I mean, with my daughter, yes. I don't know how
+he behaves around anybody else.
+I just know that the
+respect that he showed me, I feel safe with my daughter.
+And have you read in detail the reports as to what
+happened at his house with the girls?
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 12 of 26
+L-M v. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+A. Only -
+MR. PIKE: Form.
+A.
+- what's been in the newspapers and published.
+Q.
+if you read and hear testimony given - well, I can tell
+you now - testimony has been given in this case that what
+happens is: A 13 or 14 year old is led upstairs by herself,
+told to get naked, he lays down on his back, there is a brief
+• he turns over, exposes himself erect,
+masturbates while he tells this 13 or 14 year old to pinch his
+nipples as hard as she can while he inserts his fingers into
+their vagina and ejaculates all over them before saying,
+"Take your money and leave."
+MR. PIKE: Form. Move to strike.
+BY MR.
+Q. Okay? Then, "You can continue to come back for $200
+every time or every girl you bring me within your age group
+and | get to do this again, I pay you $200 per person." If that
+is the testimony -
+MR. PIKE: Form.
+Q. - that what happens behind closed doors with him, do
+you still feel comfortable leaving a 13 or 14 year old in a
+room with Jeffrey Epstein?
+MR. PIKE: Form.
+A.
+If that, in fact, is what actually happened, no.
+****
+Q. [Would you] go back - considering what you've read and
+hat you may or may not believe - would you go back
+orking for Jeffrey Epstein
+MR. PIKE: Form.
+A. I can't say. I still work for him on a maintenance - to
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 13 of 26
+_M v. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+maintain the airplanes and stuff like that, so.
+See Excerpts of Deposition of Larry Eugene L
+(attached as composite Exhibit B).
+at 135-36; 175-76; 184
+8.
+Again, whether Mr.
+Ili would work for Mr. Epstein "considering what
+[he has] read and what [he] may or may not believe" (i.e. considering hearsay media
+accounts and inadmissible lay opinion) has no bearing on the instant case.
+would leave his
+9. In addition, questions regarding whether Mr.
+children alone with Mr. Epstein could have only been meant to harass and embarrass
+I testified that he would leave his children with
+Mr.
+Nevertheless, Mr.
+Mr. Epstein. As Plaintiff's counsel was obviously not happy with the answer to this
+question, he proceeded to press Mr.
+I with inflammatory statements until he got
+the answer he wanted.
+10.
+Plaintiff's counsel has also asked the same improper line of questions in
+other witnesses' depositions.
+11.
+The above-cited questions exceed the bounds of permissible discovery;
+they have absolutely no relevance to this case. Accordingly, the Court should enter a
+protective order prohibiting such questions and should sanction Plaintiff's counsel if
+such inappropriate questions are asked at future depositions.
+12.
+Regarding the scope of discovery, Judge Linnea
+noted in her
+October 28, 2009 Omnibus Order,' "while the scope of discovery is broad, it is not
+The Omnibus Order (DE #377) was entered in the federal companion case Jane Doe No. 2 V. Epstein
+Case No. 08-CIV-80119 MARRA L
+I in the U.S. District Court, Southern District of Florida
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 14 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+without limits. Washington v.
+& Williamson Tobacco, 959 F.2d 1566, 1570 (11th
+Cir. 1992). ... Courts have long held that "[while the standard of relevancy [in
+discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow
+zones of relevancy and to explore matter (sic) which does not presently appear
+germane on the theory that it might conceivably become so.' Food Lion, Inc. V. United
+Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)
+(string cite omitted)." See also Capco Properties, LLC v. Monterry Gardens of Pinecrest
+Condo., 982 So. 2d 1211, (Fla. 3d DCA 2008) (holding that discovery in civil cases must
+be relevant to the subject matter of the case and must be admissible or reasonably
+calculated to lead to admissible evidence); Morton Plant Hospital Ass'n, Inc. v.
+Shahbas, 960 So. 2d 820, 824 (Fla. 2d DCA 2007) (holding that "discovery should be
+denied when it has been established that the information requested is neither relevant
+to any pending claim or defense nor will it lead to the discovery of admissible evidence,"
+citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)).
+13. As illustrated above, the questions are simply not germane to any pending
+claim or defense nor will they lead to the discovery of admissible evidence. Whether
+Mr. Visoski believes or disbelieves the media accounts of this case, or whether Mr.
+would leave his children with Mr. Epstein is not relevant and cannot
+conceivably lead to the discovery of admissible evidence.
+14.
+The Court should curtail these inappropriate lines of questions and enter a
+protective order prohibiting them.
+15. Rule 1.280(c), Florida Rules of Civil Procedure, provides the Court with
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 15 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+the power to "make any order to protect a party or person from annoyance,
+embarrassment, oppression or undue burden or expense that justice requires including
+... (4) that certain matter not be inquired into, or that the scope of the discovery be
+limited to certain matters."
+16.
+Accordingly, Epstein requests the Court enter a protective order
+prohibiting Plaintiff's counsel from asking witnesses' questions regarding opinions and
+beliefs regarding media articles and the allegations in this case and whether they would
+leave their children with Epstein or questions of a similar nature, and limiting the scope
+to the witnesses personal knowledge regarding matters relevant to the claims and
+defenses in this case. See Shahbas, 960 So. 2d at 824.
+WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests the Court
+enter a protective order prohibiting Plaintiff's counsel from asking witnesses' questions
+regarding opinions and beliefs regarding media articles and the allegations in this case
+and whether they would leave their children with Epstein or questions of a similar
+nature, and limiting the scope to the witnesses personal knowledge regarding matters
+relevant to the claims and defenses in this case and grant any additional relief the Court
+deems just and proper.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
+Mail to the following addressees on this 3rd day of November, 2009:
+Brad
+Esq.
+Jack Alan Goldberger, Esq.
+Rothstein Rosenfeldt Adler
+Atterbury Goldberger & Weiss, P.A.
+401 East Las Olas Boulevard
+250 Australian Avenue South
+Suite 1650
+Suite 1400
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 16 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+Fort Lauderdale, FL 33301
+954-522-3456 Phone
+954-527-8663 Fax
+Counsel for Plaintiff
+West Palm Beach, FL 33401-5012
+Fax: 561-835-8691
+Co-Counsel for Defendant Jeffrey Epstein
+Jay Howell, Esq.
+Jay Howell & Associates, P.A.
+644 Cesery Boulevard
+Suite 250
+Jacksonville, FL 32211
+904-680-1234 Phone
+904-680-1238 Fax
+Co-counsel for Plaintiff
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+(561) 842-2820
+(561) 844-6929 Fax
+By: —
+12497
+Robert B. Critton, Jr.
+Ar Fforida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 17 of 26
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM DEACH COUNTY, PLORIDA
+CASE NO. 502008CA028051XXXXHAD
+L, H.,
+Plaintite,
+-vs-
+JEVEREY EPSTEIN,
+Detendant.
+DEPOSTTION OF TARRY VISDERI
+ThursdaTe 1037
+F 18. 200%
+15 N. Plogler Drive
+inste 7200
+lest Palm Beach, Florida 33401
+eported By:
+Notary Public,
+Esquire Deposition Services
+West Palm Beach Office
+Job #127542
+7
+9
+10
+11
+12
+13
+2
+401 East Las Olas Boulevard
+Suile 1660
+Fort Lauderdale, Florida 33394
+On behalf of the Defendant:
+ROBERT D. CRITTON, JR., ESQUIRE
+BURMAN, CRITTON & LUTTIER
+303 Banyan Boulevard, Suile 400
+West Pain Beach, Florida 39401
+250 South Australlan Avenue
+Suite 1400
+West Palm Beach, Florida 33401
+ALSO PRESENTiNg ESQUIRE
+CARA L.
+1220 N.W. (570h Avenue
+Pembroke Pines, Florida 33028
+ADAM D. HOROWITZ, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard, Sulle 2218
+Miami, Florida 33160
+ICHARD H. WILLITS, ESQUIRE (VIA TELEPHON
+ICHARD H. WILLITS, P.
+2290 10th Avenue North, Suite 404
+Lake Worth, Florida 33461
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+9
+10
+11
+12
+13
+14
+15
+16
+| 17
+118
+/19
+120
+121
+- 22
+23
+124
+25
+ALL-STATE LEGAL®
+DEFENDANT'S
+
+3
+INDEX
+• ..
+WITNESS:
+LARRY VISOSKI
+BY MR.
+BY MR. CRITTON:
+BY MR.
+BY MR CRITON
+DIRECT CROSS REDIRECT RECROSS
+214
+220
+221
+EXHIBITS
+NUMBER
+DESCRIPTION
+PAGE
+PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
+(MARKED IN PREVIOUS DEPO)
+PLAINTIFF'S EX. 2
+MESSAGE PAD
+PLAINTIFF'S EX. 3
+MESSAGE PAD
+PLAINTIFF'S EX. 4
+COMPLAINT
+119
+119
+139
+PLAINTIFF'S EX. 5 INMATE VISITOR LOG
+161
+4
+PROCEEDINGS
+Deposition taken before. Wendy Beath
+Certified Reallime Reporter and Notary Public in and for
+the State of Florida al Large, in the above cause.
+MR.
+I We're going to put something on
+the record about - well, we'll do it this way -
+MR. REINHART: Do it at the end, after we get
+him - whatever you want. It's your show.
+MR.
+: Okay. There were - I don't
+even think Mr. Willits is aware of this. There was
+a subpoena duces fecum for this witness, as well as
+the previous witness, which was another pilot, Dave
+Rogers, and that duces fecum was to bring the
+flight logs related from 1998 through 2005. What
+was produced at the previous deposition were flight
+logs from 2002 through 2005, and now Mr. Reinhart
+has agreed to produce the remainder of the flight
+logs requested, those going from 1998 through 2002.
+MR. REINHART: Correct. They're pilot logs,
+not flight logs. There are other records we
+Indicated are corporate records, and with those you
+have to deal with Mr. Critton.
+MR. CRITTON: However, with the proviso, too
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 18 of 26
+1
+2
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+66
+Q. All right. When you read in the newspapers
+the allegations that Mr. Epstein was involved with
+numerous underage giris for sexual reasons, were you
+surprised?
+A. I didn't believe it.
+Q. Do you believe it today?
+A. I don't belleve it.
+Q. You don't believe that Jeffrey Epstein was
+involved with underage girls in a sexual way?
+MR. CRITTON: Form.
+THE WITNESS: You're asking for my opinion,
+and I don't think my opinion is relevant in that
+matter.
+BY MR.
+Q. I think it's relevant. Can you just tell me
+whether today you belleve that Jeffrey Epstein has
+engaged in sex with underage girls?
+MR. CRITTON: Form; speculation, irrelevant,
+always.
+THE WITNESS: It's irrelevant.
+BY MR.
+Q. I need an answer.
+A. I don'i believe he had sex with underage
+women.
+Q. Or engaged in any sexual acts with underage
+67
+women?
+MR. CRITTON: Form.
+THE WITNESS: No.
+BY MR
+Q. You think that this Is Just a story that a
+bunch of underage women have made up?
+?
+A Speculation.
+,8
+MR. CRITTON: Objection. Now it's
+9
+argumentative. Who gives a darn what he thinks one
+10
+way or angther? If he has personal knowledge -
+11
+MR
+3: You're objecting to the form?
+12
+MR. CRITTON: It's argumentative.
+13
+14
+MR.
+5: You're objecting to the form?
+MR. CRITTON: Yes.
+'15
+MR
+8: Okay.
+'16
+BY MR.
+17
+Q. Is that something that you believe that a
+18
+bunch of women - some of which know each other, some
+19% don't, some of which have been on the airplane and some
+20
+which haven" - made this up, that Jeffrey Epstein
+21
+engaged in some sexual conduct with them?
+22
+MR, CRITTON: Form.
+23
+THE WITNESS: What I believe doesn't matter in
+24
+this case, does it?
+25
+68
+1 BY MR.
+2
+3
+4
+5
+6
+7
+฿
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. I need an answer. Do you believe it? Do you
+belleve these girls made this up?
+MR. CRITTON: Form.
+MR. REINHART: I'm going to instruct him not
+to answer. Move on.
+MR.
+: is there a privilege that we're
+asserting?
+MR. REINHART: No, It's irrelevant. It's
+harassment and not likely to lead to discoverable
+evidence
+MR
+: I'm going to put on the record
+right now that it is - we are allowed discovery
+into a RICO count. We are also allowed discovery
+Into the intent of Mr. Epsten in developing a
+criminal enterprise designed to sexually exploit
+and sexually abuse underage girls. We belleve that
+in doing so, he associated intentionally with
+people of similar belief's that sex with underage
+girls is okay, and that there have been many
+discussions with this witness, as weli as many
+other witnesses with -- to insure his protection
+from law enforcement that they not answer these
+specific questions. And thus, the opinions and
+bellefs of all of these witnesses that we are
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 19 of 26
+2
+5
+6
+7
+B
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+6
+7
+8
+69
+alleging associated with this criminal enterprise
+are certalnly reasonably calculated to lead to the
+discovery of admissible evidence. And if you're
+still instructing the witness, based on that
+proffer, not to answer any of these questions, I'm
+going to continue to ask the questions and you can
+instruct him not to answer and we can go to the
+71
+A. It's an opinion, and 1 believe that he has
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. REINHART: My response is to his opinion
+whether people making allagations in this case are
+colluding or making up a story is irrelevant to
+what you just said. So l am going to instruet him
+not to answer any question that goes to his opinion
+of someone else's motivation or the truth of facts
+to which he has no knowledge.
+So yes, I'm instructing him not to answer,
+MR. CRITTON: Let me add in my pari, is that I
+think - you're certainly not only capable to ask
+questions with regard to what his personal
+knowledge is, and if he knows something or he has
+reasonable basis for it; certainly you are entitled
+to that information. I think you've asked those
+questions and he's given you straightforward
+answers as to what he knew or what he didn't know
+under those circumstances. And as to what his
+70
+thoughts are on something which he has no factual
+basis or even an assumption to know one way or
+anolher is irrelevant. That's ultimately for a
+fact-finder in this case.
+While it's interesting, it's argumentative and
+I don't think he's -- I mean, do it on a
+question-by-question basis, If he has knowledge,
+that's great, but to argue your case with this
+witness or any olher witness doesn't serve a
+purpose and | think is, you know - I think it's
+not a good use of our time, I'll put it that way.
+But you know, you can go ahead and ask.
+MR.
+* I can ask the question and if
+the witness is being instructed not lo answer,
+we'll let a judge decide whether he needs lo answer
+the question and whether it's discoverable or not.
+MR. REINHART: Absolutely. Make your record.
+BY MR.
+Q. Do you have any reason to believe that Jeffrey
+Epstein engaged in sexual activity with underage women?
+A. I have no reason lo believe.
+Q.
+Okay. So as you sit here today, based on your
+18 years of knowledge, experience and observation of
+Jeffrey Epstein, is it your belief that he has not had
+sex or engaged in sexual activity with underage women?
+2
+3
+4
+5
+not.
+Q. Okay. Isn't it true that at some point in
+lime you leamed that Jeffrey Epstein has - strike
+that.
+6
+MR. CRITTON: When you ullimately get to a
+7
+good place to break, will you let us know?
+8
+MR.
+Let's break now.
+9
+(A break was had at 11:28 a.m.)
+10
+BY MR.
+11
+Q. All right. Eighteen years of being a pilot
+12
+for Jeffrey Epstein and in terms of being able to name
+13
+somebody that you would say you've observed with Jeffrey
+14
+Epstein and would classify that person as Jeffrey
+15
+Epstein's friend, can you name anybody?
+16
+A Nadia, Sarah; just people that we see
+17
+routinely on the airplane.
+18
+Q. That's people you see routinely in the last
+/19
+five to ten years, right?
+120
+A. Yes.
+21
+Q. Prior to that time, anybody that you've
+22
+noliced as Jeffrey Epstein's friend may be Chislaine
+23
+Maxwell?
+24
+A What time frame?
+25
+Q. Is that a person that at some point in time
+72
+1 you word classify as Jeffrey Epstein's friend?
+A. I would classify it. I don't know If it's
+3
+true.
+Q. But thal's only because they were on the
+6
+airplane together?
+A. Yes.
+Q. Do you know what Jeffrey Epstein does for a
+ving in your 18 years of observing and talking with
+Jeffrey Epstein?
+10
+A No.
+11
+Q. No Idea?
+/12
+A. No.
+/13
+14
+Q. Ever asked him?
+A. No, actually.
+15
+Q. Ever been curious?
+16
+A. Sure.
+17
+Q. Everdone anything to satisfy that curiosity?
+18
+A. If you mean Google it, not really, actually.
+119
+I mean, I really have not.
+20
+Q Okay. So in 1B years of traveling and being
+21
+The pilot and driving -- and taking this person, Jeffrey
+22
+Epsteln, from one property in New York to New Mexico and
+23
+Florida and around the world, you have no idea what he
+24
+does in terms of how he makes money?
+25
+A No, sir.
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 20 of 26
+156
+1
+MIR. CRITTON: Form.
+THE WITNESS: No.
+BY MR.
+Q. If you had been aware that Mr. Epstein was --
+• B
+and by this - this is more in the form of a
+9
+hypothetical, and that I'm not going.to suggest to you
+10
+It's a fact that he was. But if you had been aware that
+11
+every single day Jeffrey Epstein's goal was to locate
+12
+underage girls for the purposes of sex, and either have
+13
+sex with them on the airplane or at some other
+14
+designation that you were destination that you were
+15
+traveling him to, would you have continued to pliot
+16
+those planes?
+MR. CRITTON: Form.
+THE WITNESS: You said it was hypothetical?
+18
+19
+20
+21
+22
+13
+14
+15
+BY MR.
+Q. Right, If is a hypothetical.
+A. Why would I want to answer that? Because
+you're being hypothetical. I mean, it would obviously
+be wrong.
+Q. Sure. Well, a hypothetical question is a
+legal question that I'm allowed to ask.
+i
+
+
+Case 9:09-CV-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 21 of 26
+10
+11
+12
+13
+14
+15
+16
+20
+21
+22
+23
+24
+25
+1
+2
+157
+A. Okay.
+Q. And I'm just asking you if you did have
+knowledge that Jefirey Epslein was having sex with
+little girls either on the plane or at a piace that you
+were taking him to or from on a daily basis, that's what
+he did, would you have continued to be his pilol?
+MR. CRITTON: Lel me object. Object to the
+form, It's argumentative. It has no more value
+than assuming he was chopping up bodies or anybody
+was chopping up bodies in the plane you're flying.
+What difference does it make? Form.
+MR.
+What difference does it make in
+a case about him having sex with little girls? I'm
+not going to argue with you about it. You've
+stated your objection.
+MR. CRITTON: Exactly, Il's an argumentative
+question.
+MR.
+I'm not going lo argue with you
+about it.
+MR. CRITTON: Youre arguing with him about
+now.
+MR.
+No, I'm asking him the
+hypothetical.
+BY MR.
+158
+9
+10
+11
+12
+13
+girls?
+MR. CRITTON: Form.
+THE WITNESS: It could be any person. It
+doesn't have to be Jeffrey Epstein, then, right?
+BY MR.
+Q. True.
+A. No, I wouldn't pilot an airplane if there was
+wrongdoing going on.
+Q. That you knew about?
+A. That! knew you about, sure.
+first time you've heard these allegations --
+A. Yes.
+Q.
+- against Mr. Epstein?
+A
+Yes.
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 22 of 26
+2
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+7
+10
+11
+12
+13
+14
+15
+16
+=
+18
+19
+21
+22
+23
+24
+25
+181
+which he pled guilty to -
+MR. CRITTON: Form.
+MR. REINHART: Can we - for purposes of your
+hypothetical, what facts do you want him to assume
+are true? You said the facts to which he pled
+guilty, but the witness already said he doesn't
+know what he pled guilty to. He knows the charge
+he doesn't know the facts.
+BY MR.
+Q. Solicitation of prostitution of a minor,
+somebody under the age of 18.
+MR.
+That's the charge, right,
+solicitation of prostitution of a minor?
+MR. CRITTON: No. I think you've got it
+wrong. I'll object to the form.
+MR.
+BY MR.
+Q. Then we'll handle the question this way: If
+you were to believe based on information and evidence
+that Mr. Epslein engaged in sex or some form of sex act
+with people of the age range of 12, 13, 14, 15 years
+old, would you continue your employment with
+Mr. Epstein?
+MR. CRITTON: Form; speculation.
+THE WITNESS: 1 would certainly be speculating
+182•
+and 1 have to discuss it with my wife long and •
+hard. I don't think I could give you a correct and
+honest answer at this time.
+BY MR.
+Q. Okay. Given the allegations that have been
+made in this case, is this something that you have
+discussed with anyone other than your attorney?
+A. No, not really. Only from the fact that
+theyre allegations and there's still a lot more work,
+I'm sure, to be discovered
+MR. CRITTON: Let me put on there, for the -
+If this deposition Is not typed - and we request
+it - I'd like at least this portion where
+Mr.
+last question back about five pages
+worth, so just if you could mark it from this
+page back about five pages.
+If nobody requests the deposition, Id just
+like those five pages.
+: I'm going to request the
+deposition, so...
+MR. CRITTON: Okay. Well mark this then, so
+you could tell me where it is, approximately.
+BY MR. MAM
+2. Is there a reason why you have not discusse
+vith Jeffrey Epstein the allegations that have been :
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 23 of 26
+Larry Eugene
+- Volume I
+1
+IN THE CIND FOR PALM DERCE GOTH TADATACUT IN
+VOLNE I
+Pages 1 to 200
+Plaintitt,
+V8.
+JEPFREY EPSTEIN,
+Case No. 50200BCA028051
+і ХХХхНа л
+Defendant.
+LARRY BOSE
+TAKEN ON DEHALT OF THE PLAINTIFT
+October 6, 2009
+10:55 a.m. - 2:20 p.m.
+Weat Bai: Ph tE 95401-9322
+Jennifer Dilorenzo, court reporter
+4
+5
+10
+111
+12
+13
+114
+15
+16
+17
+23
+25
+October 6, 2009
+3
+APPEARANCE OF COUNSEL
+On behalf of the Defendant:
+ATTERBURY, GOLDBERGER & WEISS
+BY: JACK ALAN GOLDBERGER, ESQ.,
+250 Australan Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-659-8300
+igoldbergen@agwpa.com
+On behalf of the Defendant by telephone:
+BURMAN, CRITTON, LUTTER & COLEMAN
+BY: MICHAEL J. PIKE, ESQ.,
+515 N. Flagler Drivo
+Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+mpike@bolelaw.com
+On behalf of the witness:
+LAW OFFICE OF BRUCE E. REINHART
+BY: BRUCE E. REINHART, ESQ.,
+One Clearlake Center
+250 8, Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6380
+BReinhart@BruceREinhartLaw.com
+4
+/12
+==
+15
+16
+17
+20
+21
+22
+23
+24
+25
+2
+APPEARANCES OF COUNSEL
+On behalf of the Plainlf L.M.:
+ENEFITS ADLER
+ESQ.
+and MICHAEL W
+401 Easl Las Olas Boulevard
+Sulle 1850
+Fert Louderdalo, FL 33394
+954-522-3458
+bechwards@rra-iaw.com
+mahesler@ra-law.com
+On bahalf of Plainlits Jane Doe 2 through 0;
+ME. JESSICAD, ANOUR AT PANEYAT-LAW,
+18205 Biscayne Soulevard
+Sulle 2218
+Maml, FL 33100
+305-931-2200
+jarbour@soxabusesliornay.com
+near lanet an on 101 an 10207
+DHURST ORSECK, P
+KATHERINE W. EZELL, ATTORNEY-AT-L
+25 W. Flaglor Street
+Miami, FL 33130
+305-355-2000
+kozelk@podhurst.com
+On behalf of Uhe Plainilf C.M.A. by lelephone:
+LAW OFFICE OF RICHARD WILLITS, P.A.
+BY: RICHARD WAITS, E5G.,
+2290 100 Avenue N.
+Sule 404
+Lako Worth, FL 33461
+561-562-7500
+luwyarwifts@aol.com
+4
+INDEX OF EXAMINATION
+WITNESS:
+LARRY EUGENE
+Page
+BYRE TEAMINATION
+$5
+CROSS-EXAMINATION
+By Ms. Ezi
+• CROSS-EXAMINATIO
+By Mr. Willts
+#190
+#195
+10
+CROSS-EXAMINATION
+12
+By Mr. Pike
+FURTHER REDIRECT EXAMINATION
+By Mr.
+#199
+25
+INDEX TO EXHIBITS
+Passenger Manifest."
+22
+125
+9 DEFENDANT'S
+EXHIBIT.
+TTU
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 24 of 26
+October 6, 2009
+135
+1
+A I have no Idea. I don't know.
+Q. When you say tha
+was just
+3
+coming in the picture, what's your understanding as lo
+who
+a is relative 1o Mr. Epsteln?
+5
+A I don't know. I don't understand. I
+don't know. I didn' know if maybe she was like an
+exchange - Jeffrey always appeared to be very
+8
+involved in education and philanthropy. I didn't
+know if she was an exchange-type student or something
+10
+or what. I don't know.
+11
+Q. When you say he appeared to be Involved in,"
+12
+what do you mean?
+13
+A. Educational things, foundations, science
+11
+foundations, and things.
+15
+Q. Speaking of - the Flonda Science Foundation
+16
+Is a place where, when he was on work release, he spent a
+17
+lot of time there, you're aware of thal?
+1B
+A That's what /ve heard, yeah.
+18%
+Q. What does that place do?
+20
+A I have no idea.
+21
+Q. Does it do anything?
+22
+A I dont know. I don't know anything about
+23
+24
+25
+Q. Cartainly you've read certain newspaper
+articles about the allegations, police reports,
+136
+1
+:
+2
+otherwise, the allegations that occurred or have been
+alleged to have occurred at his Palm Beach mansion,
+3 correct?
+4
+A. Uh-huh.
+5
+Q. Correct?
+6
+A. Correct.
+7
+Q. Given the nature of those allegations, would
+you leave your daughter of 17,16, 15 years old with Mr.
+9
+Epstein alone?
+,10
+11
+MR. PIKE: Form. Move to strike.
+12
+A. Yes.
+Q. You would?
+13
+14
+A. (Witness nods head.)
+15
+Q. And why?
+16
+A. Because I don" fear that he would try
+17
+anything with my daughter. He showed - When
+worked for him he showed me respect. He never -
+• 18
+never - He never showed me disrespect. He would ask
+19
+how the family is. 1 mean, not on a personal level,
+20
+but an employer/employee.
+21
+Q. Right. Okay.
+22
+A. He never showed me any reason not to trust
+23
+him.
+24
+Q. But you're not a 13-year old girl, so.
+25
+A. No, but, like I say, he never showed me
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 25 of 26
+october 6, 2009
+175
+1°
+3
+4
+Q. And despite pleading guilty to procuring
+underage girls for the purposes of sex, you still feel
+comfortable leaving a 13, 14, 15-year-old girl around
+him?
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+1 14
+19
+20
+21
+22
+23
+24
+25
+MR. PIKE: Form. Move to sirike.
+A. Yes. I mean, with my daughter, yes. I
+don't know how he behaves around anybody else. !
+just know that the respect that he showed me, I feel
+safe with my daughter.
+Q. And have you read in detail the reports as to
+what happened at his house with the glris?
+A. Only -
+MR. PIKE: Form.
+A. - what's been in the newspapers and
+Q. If you read and hear testimony given - well, I
+can tell you now - lestimony has been given in this case
+that what happens is: A 13 or 14 year old is led
+upstairs by herself, told to get naked, he lays down on
+his back, there is a brief massage before he turns over,
+exposes himself erect, masturbates while he tells this 13
+or 14 year old to pinch his nipples as hard as she can
+while he Inserts his fingers into their vagina and
+ejaculates all over them before saying, "Take your money
+176
+MR. PIKE: Form. Move to strike.
+1
+2 BY MR.
+3
+Q. Okay? Then, "You can continue to come back
+4
+for $200 every time or every girl you bring me within
+5
+your age group and | get to do this again, I pay you $200
+per person." If that is the testimony -
+MR. PIKE: Form.
+Q. - that what happens behind closed doors with
+him, do you still feel comfortable leaving a 13 or 14
+10
+year old in a room with Jeffrey Epstein?
+11
+MR. PIKE: Form.
+12
+A. If that, in fact, is what actuaily
+13 happened, no.
+
+
+Case 9:09-cv-80591-KAM Document 80 Entered on FLSD Docket 11/09/2009 Page 26 of 26
+1
+2
+3
+4
+5
+7
+9
+10
+11
+12
+13
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+184
+you witnessed Jeffrey Epstein committing?
+A. No.
+Q. Would you -
+A. No.
+Q. - go back - considering what you've read and
+what you may or may not believe - would you go back to
+working for Jeffrey Epstein?
+MR. PIKE: Form.
+A. I can't say. I still work for him on a
+maintenance - fo maintain the airplanes and stuff
+ike that, so.
+Q. You're on his payroll?
+A. Salaried, yes.
+Q. Do you know who else Is on hls payroll?
+A. Well, Dave and Larry.
+Q. Cerfainly, ifI want to know more about his
+private life - do you know who's at his house?
+A. No.
+Q. Do you know who his housekeeper Is?
+A. No.
+Q. Do you know who his architect is?
+A. No, no.
+Q. Does Larry visit him at his house?
+A. I would assume so.
+Q. Why do you say you would assume so? That
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f0697b9b925d4aa177aa5d29eac40b7318988fb70400a99ae1581ba577198f22.receipt.json b/vision-fixhub/court-01/f0697b9b925d4aa177aa5d29eac40b7318988fb70400a99ae1581ba577198f22.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..35d28b916bcaea9a222550be0167679b73cfd3e2
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f08e5d8a693cd02e29184751fab9f568776a04fdd0a177cd59d9883a5f413b5e.md b/vision-fixhub/court-01/f08e5d8a693cd02e29184751fab9f568776a04fdd0a177cd59d9883a5f413b5e.md
new file mode 100644
index 0000000000000000000000000000000000000000..b841c894b3350a3357a3f469ad390eb16bdf7d42
--- /dev/null
+++ b/vision-fixhub/court-01/f08e5d8a693cd02e29184751fab9f568776a04fdd0a177cd59d9883a5f413b5e.md
@@ -0,0 +1,161 @@
+Case 9:08-cv-80119-KAM Document 518 Entered on FLSD Docket 04/06/2010 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+MOTION FOR LEAVE TO FILE REDACTED VERSIONS OF
+SENSITIVE FIFTH AMENDMENT ARGUMENTS AND
+SUBMIT UN-REDACTED ARGUMENTS TO THE COURT
+Defendant, JEFFREY EPSTEIN ("Epstein"), moves for leave to file redacted versions of
+sensitive Fifth Amendment arguments and submit original, un-redacted arguments to the Court
+for in-camera inspection, and in support states:
+1.
+Epstein intends to file a Request for Rule 4 Review and Appeal of Portions of the
+Magistrate's Orders Dated February 4, 2010 (DE #462), March 4, 2010 (DE #480) and April 1,
+2010 (DE #513).
+2.
+In the Request for a Rule 4 Review and Appeal, Epstein intends to make
+arguments regarding sensitive Fifth Amendment issues, which have been provided, in pertinent
+part, to the magistrate by way of in camera submissions and filed electronically in redacted form.
+3.
+Epstein moves for leave to file such sensitive Fifth Amendment arguments in
+redacted form and provide the original, un-redacted versions for the Court to consider in-camera.
+
+
+Case 9:08-cv-80119-KAM Document 518 Entered on FLSD Docket 04/06/2010 Page 2 of 4
+4. As set forth in DE #s 282 and 283, Epstein cannot provide information related to
+his financial history and condition without waiving his Fifth, Sixth and Fourteenth Amendments
+as guaranteed by the U.S. Constitution.
+The Court has previously permitted Epstein to file redacted versions of such
+sensitive Fifth Amendment arguments and provide un-redacted versions for in-camera
+inspection. See DE #s 282, 283. Indeed, the Court considered the in-camera submissions in DE
+#s 282 and 283 in vacating portions of its August 4, 2009 Order (DE #242) and sustaining
+Epstein's Fifth Amendment objections to six requests for production (objections that were
+initially overruled in DE #242). See DE #293; see also U.S. v. Baez-Alcaino, 718 F. Supp. 1503,
+1505-06 (M.D. Fla. 1989) (affirming lower court's decision to file redacted plea agreements to
+serve compelling government interests); In re Duque, 134 B.R. 679, 687 (S.D. Fla. 1991)
+(finding that court's procedure requiring attorneys to provide privileged documents to court for
+in-camera inspection while providing redacted versions to the bankruptcy trustee was proper).
+It is critical that the Court allow Epstein to effectively assert his Constitutional
+rights under the Fifth, Sixth and Fourteenth Amendments without the risk of waiving such rights.
+7.
+The importance of permitting Epstein to file redacted arguments and provide unredacted versions for in-camera inspection is underscored by the Court's September 9, 2009
+Order (DE #293), in which it reversed portions of its prior Order (DE #242) that initially
+overruled Epstein's Fifth Amendment objections. When Epstein filed his Rule 4 Appeal (DE
+#282) and provided the sensitive Fifth Amendment arguments in-camera, the Court vacated
+portions of its prior Order (DE #242) and sustained Epstein's Fifth Amendment objections to six
+production requests.
+2
+
+
+Case 9:08-cv-80119-KAM Document 518 Entered on FLSD Docket 04/06/2010 Page 3 of 4
+WHEREFORE, Defendant, JEFFREY EPSTEIN, requests the Court grant him leave to
+file redacted versions of sensitive Fifth Amendment arguments and provide the un-redacted
+versions to the Court for in-camera inspection and grant any additional relief the Court deems
+just and proper.
+Respectfully submitted,
+By: _
+_s/Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECE. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 6th day of April, 2010.
+By: _
+s/Michael J. Pike.
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+3
+
+
+Case 9:08-cv-80119-KAM Document 518 Entered on FLSD Docket 04/06/2010 Page 4 of 4
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/T
+Stuart S. Mermelstein, Esq.
+Brad
+Adam D. Horowitz, Esq.
+1, Fistos &
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+1, Esq.
+i, Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue
+Suite 2
+Fort Lauderdale, FL 33301
+Phone: 954-524-2820
+Fax: 954-524-2822
+rad @pathtojustice.com
+Counsel for Plaintiff in Related Case No. 08-
+80893
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232, 08-80380, 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Estein
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M.
+I. Esq.
+1L| Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-
+80469
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+tjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Case
+4
diff --git a/vision-fixhub/court-01/f08e5d8a693cd02e29184751fab9f568776a04fdd0a177cd59d9883a5f413b5e.receipt.json b/vision-fixhub/court-01/f08e5d8a693cd02e29184751fab9f568776a04fdd0a177cd59d9883a5f413b5e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..aa42ce3e038ff92f819fff4029da24aad30bfb93
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diff --git a/vision-fixhub/court-01/f11823d22ba7b79a5fbb9de7512e283ea0cdaa595da7e500830218fb726d4d3c.md b/vision-fixhub/court-01/f11823d22ba7b79a5fbb9de7512e283ea0cdaa595da7e500830218fb726d4d3c.md
new file mode 100644
index 0000000000000000000000000000000000000000..26a222d9f9540fc6be31b4caa31d18b3c544d4f8
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+++ b/vision-fixhub/court-01/f11823d22ba7b79a5fbb9de7512e283ea0cdaa595da7e500830218fb726d4d3c.md
@@ -0,0 +1,33 @@
+Case 9:08-cv-80232-KAM Document 126-2 Entered on FLSD Docket 07/29/2009 Page 1 of 2
+DECLARATION OF JANE DOE NO. 4
+1, 1
+, state as follows:
+2.
+I am the Plaintiff identified as Jane Doe No. 4 in this lawsuit.
+During the past week, three investigators working on behalf of Jeffrey Epstein
+contacted the office of my former employer, Florida Realty, on three separate occasions.
+During the contacts, the investigators asked my former employer personal
+questions about me, including whom I am dating and how they can contact my ex-boyfriend.
+The investigators obtained the name of my ex-boyfriend from my former employer and have
+been repeatedly contacting a former co-worker to get the telephone number of my ex-boyfriend.
+Once they obtained the number of my ex-boyfriend, they have repeatedly contact him, asking
+very personal questions about my relationship with him, as well as my current relationship,
+employment, and residence.
+4. None of the individuals whom the investigators have contacted or attempted to
+contact knew that I am a plaintiff in a childhood sexual abuse lawsuit against Jeffrey Epstein, but
+now they are asking me questions about it.
+5.
+I am worried that Jeffrey Epstein will continue to send investigators to speak with
+people I know who do not know that I am a Plaintiff in this lawsuit. I am concerned that the
+investigators will ask these people very personal questions about my life and disclose that I am a
+Plaintiff in a sexual abuse lawsuit against Jeffrey Epstein. It could cause problems in my social
+circle and with my future employment and educational opportunities if people find out that I am
+a plaintiff in a childhood sexual abuse suit against Jeffrey Epstein.
+I declare under penalty of perjury the foregoing to be true and correct.
+
+B
+
+
+Case 9:08-cv-80232-KAM Document 126-2 Entered on FLSD Docket 07/29/2009 Page 2 of 2
+Dated this 1] day of _July, 2009
+D alkal Jane Doe No. 4
diff --git a/vision-fixhub/court-01/f11823d22ba7b79a5fbb9de7512e283ea0cdaa595da7e500830218fb726d4d3c.receipt.json b/vision-fixhub/court-01/f11823d22ba7b79a5fbb9de7512e283ea0cdaa595da7e500830218fb726d4d3c.receipt.json
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diff --git a/vision-fixhub/court-01/f141ca2fbe3be8553a65ca4f96ab4f86e5efccdcfc3d8eb1a79a06e8dd70d821.md b/vision-fixhub/court-01/f141ca2fbe3be8553a65ca4f96ab4f86e5efccdcfc3d8eb1a79a06e8dd70d821.md
new file mode 100644
index 0000000000000000000000000000000000000000..c80b8acc932d38bca3966332705d16a641c83c52
--- /dev/null
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@@ -0,0 +1,53 @@
+Case 9:08-cv-80119-KAM Document 75-1 Entered on FLSD Docket 04/13/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80119-MARRA
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 75-1 Entered on FLSD Docket 04/13/2009 Page 2 of 2
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- 80993-CIV-MARRA/
+ORDER
+Upon Plaintiffs' Unopposed Motion for Enlargement of Time to File Memorandum in
+Opposition to Motion to Stay and/or Continue Action, and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+ten (10) days, until April 23, 2009, to file a reply memorandum in opposition to the Defendant's
+Motion to Stay and/or Continue Action.
+DONE AND ORDERED in
+in Ft. Lauderdale, Broward County, Florida, this
+day of
+_ 2009.
+DISTRICT COURT JUDGE
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diff --git a/vision-fixhub/court-01/f14b0addc6d7febdf761979077f2a2b98f83dcb9dd7d56f9603384c11354943a.md b/vision-fixhub/court-01/f14b0addc6d7febdf761979077f2a2b98f83dcb9dd7d56f9603384c11354943a.md
new file mode 100644
index 0000000000000000000000000000000000000000..94089aedc57bf25dd6b83d7b9d2e73b0a9e989f0
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@@ -0,0 +1,70 @@
+Case 9:08-cv-80736-KAM Document 12 Entered on FLSD Docket 07/15/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+FILED by IRS D.C.
+IN RE: JANE DOE,
+JUL. 0 9 2008
+Petitioner.
+S.D. OF FLA. - W.P.B
+UNITED STATES' MOTION TO FILE RESPONSE TO VICTIM'S EMERGENCY
+PETITION FOR ENFORCEMENT OF VICTIM RIGHTS ACT
+AND DECLARATION OF A.
+VILLAFAÑA UNDER SEAL
+The United States of America, by and through its undersigned counsel, files its Motion to File
+Response to Victim's Emergency Petition for Enforcement of Victim Rights Act and Declaration
+Villafaña Under Seal, pursuant to S.D. Fla. L.R. 5.4 and 18 U.S.C. § 3509(d)(2), and
+of A.
+states:
+On July 7, 2008, petitioner filed her Emergency Victim's Petition for Enforcement of Crime
+Victim Rights Act, 18 U.S.C. § 3771. Petitioner did not disclose her name, and alleges that she was
+a minor child when she was the victim of federal crimes committed by Jeffrey Epstein. Petition, 4 1.
+On July 7, 2008, the Court directed the Government to file a response to the Petition by July
+9,2008, at 5:00 p.m.
+The Government has prepared its Response, which is attached as Exhibit A, and the
+Declaration of Assistant United States Attorney A.
+Villafaña, as well as correspondence with
+several individuals who were minors when the relevant events occurred. Additionally, the
+Government's Response also refers to actions taken by the United States Attorney's Office with an
+interested party which was done in confidence. The Government believes that its Response should
+
+
+Case 9:08-cv-80736-KAM Document 12 Entered on FLSD Docket 07/15/2008 Page 2 of 3
+be filed under seal, in order to protect the minor victims' privacy, as well as to maintain the
+confidentiality of the agreement reached with an interested party.
+The Government requests that its Response and the Declaration be sealed until the
+termination of the instant litigation, or five years from the date of filing, whichever occurs first.
+Upon the expiration of the time period for sealing, the Government requests the documents be
+returned to the United States Attorney's Office.
+WHEREFORE, the government respectfully requests that its Response to Victim's
+Emergency Petition for Enforcement of Crime Victim Rights Act, 18 U.S.C. § 3771, and the
+Declaration of A.
+Villafaña be filed under seal.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4'* Street
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Attorney for Respondent
+2
+
+
+Case 9:08-cv-80736-KAM Document 12 Entered on FLSD Docket 07/15/2008 Page 3 of 3
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via facsimile
+transmission and U.S. Mail, this 1 day of July, 2008, to: Brad
+Esq., The Law Offices
+of Brad
+& Associates, L.I.C, (954) 924-1530, 2028 |
+Street, Suite 202, Hollywood,
+Florida 33020.
+DEXTER A. LEE
+Assistant U.S. Attorney
+3
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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index 0000000000000000000000000000000000000000..148a01eb2ff4cc7f0c1f5e9660b45ff9ca7de838
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@@ -0,0 +1,431 @@
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 1 of 15
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAJ
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRAJT
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 2 of 15
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80811 -MARRA/
+JANE DOE,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+VS.
+CASE NO.: 08-CV- 80469-MARRA/
+Plaintiff,
+2
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 3 of 15
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOES 2-7'S RESPONSE TO DEFENDANT'S MOTION TO
+COMPEL AND/OR IDENTIFY PLAINTIFFS IN THE STYLE OF THIS CASE AND
+MOTION TO IDENTIFY JANE DOE IN THIRD-PARTY SUBPOENAS FOR
+PURPOSES OF DISCOVERY, OR ALTERNATIVELY, MOTION TO DISMISS
+"SUA SPONTE", WITH INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, JANE DOES 2-7, hereby serve their Response to Defendant's Motion to
+Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane Doe in
+Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss "Sua
+Sponte", With Incorporated Memorandum of Law, and state as follows:
+The lawsuits filed by JANE DOES 2-7 involve private, intimate facts pertaining
+to their own childhood sexual abuse and exploitation by Defendant Jeffrey Epstein.
+3
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 4 of 15
+2.
+Jane Does 2-7 filed their suits under a pseudonym' to prevent public disclosure of
+the private, highly sensitive and intimate facts pertaining to their sexual assaults, and the public
+association of their identities with Defendant Epstein and these assaults.
+Dr. Gilbert Kliman," a well-known forensic psychiatrist with an expertise in the
+field of child trauma, has met with and evaluated each of Jane Does 2-7 and opined that public
+disclosure of their real names would create a substantial risk to them of further psychological
+harm. See Exhibit "A", Declaration of Gilbert Kliman, M.D.
+Dr. Kliman opines as follows:
+Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis
+of posttraumatic stress disorder trauma. In effect, release of their identity and
+public intrusion into their personal life represents a reenactment of the shame of
+sexual traumatization. Repetition and reenactment are central pathologies that
+afflict sexual trauma survivors.
+Victims of sexual abuse often rely upon some form of dissociation, splitting or
+denial, as a defensive means to manage overwhelming affects associated with the
+sexual trauma. Each of the plaintiff girls has employed some variation of this
+defense, both during the massages and then subsequently following disclosure of
+the abuse. Primitive, maladaptive responses of this nature will become
+additionally reinforced as a result of public disclosure.
+Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR,
+is that the trauma was associated with human design factors (such as cruel
+intention to do harm, rape, torture). Trauma of this origin has a tendency to
+produce more "severe or long lasting" posttraumatic stress disorder than natural
+events (DSM IV TR p. 464). À policy of deliberate revelation of the names of the
+victims would reinforce the sense of design, pattern and policy of human
+intentions.
+It is my opinion, with a reasonably high degree of medical certainty that the
+defense motion to allow public disclosure of the plaintiffs' identity is clinically
+" Defendant and his counsel are aware of the real names of Jane Does 2-7.
+" A copy of the curriculum vitae of Dr. Gilbert Kliman is attached hereto as Exhibit "B".
+4
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 5 of 15
+and ethically a wrongful plan. The act of revealing their identity against their
+wishes places the plaintiffs at risk, in the best of circumstances, of suffering an
+aggravation of existing diagnostic concerns. It is more probable than not that
+releasing personal identities will
+an exacerbation and magnification of
+symptoms lending to increased risk of revictimization and retraumatization.
+See Exhibit "A", 99l 13-15, 21
+Given the private nature of the allegations in this lawsuit and the serious risk of
+harm to the mental health of Jane Does 2-7 if a public disclosure of their identities were required,
+Jane Does 2-7 should be permitted to continue using a pseudonym in this lawsuit.
+6.
+Notably, in one of the cases consolidated for purposes of discovery, Jane Doe v.
+Jeffrey Epstein, Case No. 08-80893, this Court recognized the harm likely to result from public
+disclosure of the victims' identities in these cases, and allowed the Plaintiff in that case to
+"proceed in this action under the pseudonym Jane Doe'", by Order dated October 6, 2008.
+Jeffrey Epstein sets forth no facts to support his bare contention that Jane Does 2-
+7 use of a pseudonym in these proceedings interferes with his "constitutional due process right."
+See Motion to Compel, p. 3. Defendant and his counsel know the identities of these Plaintiffs.
+8.
+Defendant also requests the Court's permission to use the real names of Jane Does
+2-7 in various third-party subpoenas for discovery purposes. Defendant does not identify any of
+the entities or persons to whom he intends to send subpoenas. An order granting the relief
+requested without limitations would essentially nullify Jane Does 2-7's right to proceed
+anonymously. Jane Does 2-7 therefore object to the issuance of third-party subpoenas, and
+submit that Defendant can obtain the discovery he seeks by alternative means that will preserve
+the confidentiality of the Jane Does 2-7's identities.
+9.
+If this Court were to permit third party subpoenas or records custodian
+depositions using the existing captions and identifying Jane Does 2-7 in the body of the
+5
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 6 of 15
+subpoena by their names, due to publicity surrounding the Defendant's crimes, then Jane Does 2-
+7 would effectively be revealed as abuse victims in these cases against Defendant Epstein. Any
+subpoenas or notices to third parties therefore should not disclose the type of action or the
+Defendant's identity. There are alternatives which would preserve Jane Does 2-7's anonymity
+and be more efficient and cost-effective at the same time. For instance, Defendant can obtain
+records from various non-party sources through Plaintiffs' counsel, who can certify that they
+have obtained the records through authorizations signed by Jane Does 2-7. Another means to
+obtain non-party records concerning Plaintiffs is the appointment of a special
+who would
+verify authenticity and completeness of the records.
+10.
+Finally, Jeffrey Epstein's request that this Court order a "sua sponte" dismissal is
+illogical. Sua sponte means "[w]ithout prompting or suggestion; on its own motion." Black's
+Law Dictionary 1437 (7th ed.1999). Thus, the definition of sua sponte does not fit these
+circumstances, because the Court is being prompted by Epstein's Motion. Velchez v. Carnival
+Corp, 331 F.3d 1207 (11th Cir. 2003). In any event, there is no basis or authority to support a
+dismissal of these cases.
+WHEREFORE, Plaintiffs Jane Does 2-7 respectfully request that (i) this Court deny
+Defendant's Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to
+Identify Jane Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion
+to Dismiss "Sua Sponte", in its entirety; (ii) Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation; (ill) this Court order that records from non-parties
+relating to Jane Does 2-7, including medical and employment records, only be obtained through
+Plaintiffs' counsel by means of signed authorizations that do not include the caption or identify
+Epstein as the party seeking records, or alternatively, appoint a special
+to obtain the
+6
+
+
+Case 9:08-cv-80380-KAM
+Document 130 Entered on FLSD Docket 06/08/2009 Page 7 of 15
+records, who would verify authenticity and completeness of the records; and (iv) all other relief
+this Court deems just and appropriate.
+MEMORANDUM OF LAW
+PLAINTIFFS JANE DOES 2-7 SHOULD BE PERMITTED
+TO PROCEED ANONYMOUSLY IN THIS CASE DUE TO THE
+SENSITIVE, PRIVATE NATURE OF THE UNDERLYING FACTS
+AND THE RISK OF PSYCHOLOGICAL HARM TO THE PLAINTIFFS
+Federal courts permit a party to proceed under a pseudonym when special circumstances
+warrant anonymity. See, e.g., Roe v. Aware Woman Ctr. for Choice, Inc., 253 F.3d 678, 685-87
+(11th Cir.2001); Does / thru XXIII v. Advanced Textile Corp., 214 F.3d 1058, 1068-69 (9th
+Cir.2000); James v. Jacobson, 6 F.3d 233, 238-39 (4th Cir. 1993); EW v. New York Blood Center,
+213 F.R.D. 108, 110-12 (E.D.N.Y.2003); Javier v.
+-Botello, 211 F.R.D. 194, 196
+(W.D.N.Y.2002); Doe v. |
+105 F.Supp.2d 40, 43-44 (E.D.N.Y.1999); Doe v. United Servs.
+Life Ins. Co., 123 F.R.D. 437, 439 (S.D.N.Y.1988). Sexual assault victims are a paradigmatic
+example of those entitled to a grant of anonymity. See Doe No. 2 v. Kolko, 242 F.R.D. 193 (E.D.
+N.Y. 2006); Doe v. Blue Cross & Blue Shield United of Wisc., 112 F.3d 869, 872 (7th Cir.1997)
+("fictitious names are allowed when necessary to protect the privacy of ... rape victims, and other
+particularly vulnerable parties or witnesses"); see also Doe v. City of Chicago, 360 F.3d 667, 669
+(7th Cir. 2004).
+The decision whether to allow a plaintiff to proceed anonymously is within the court's
+discretion. See Aware Woman Ctr., 253 F.3d at 684; Javier, 211 F.R.D. at 195; EW, 213 F.R.D.
+at 110. As set forth above, this Court exercised its direction in one of the consolidated cases,
+Jane Doe v. Jeffrey Epstein, Case No. 08-80893, to allow a plaintiff to proceed under the
+pseudonym "Jane Doe" in an Order dated October 6, 2008.
+7
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 8 of 15
+Courts will permit a party to proceed under a pseudonym where "the party's need for
+anonymity outweighs prejudice to the opposing party and the public's interest in knowing the
+party's identity." Does I Thru XXIII, 214 F.3d at 1068; see Javier, 211 F.R.D. at 195; EW, 213
+F.R.D. at I11; As set forth herein, the balancing test in this case weighs in favor of permitted
+plaintiff to continue to proceed anonymously:
+In undertaking this balance, courts have considered such facts as
+(1) whether the plaintiff is suing the government or a private
+person; (2) whether the plaintiff would be compelled to disclose
+intimate information; (3) whether plaintiff would be compelled to
+under a pseudonym would thereby be prejudiced; (6) the ages of
+the parties whose identity is to be suppressed; (7) the extent to
+which the identity of the litigant has been kept confidential; (8)
+whether, because of the purely legal nature of the issues presented
+or otherwise, there is an atypically weak public interest in knowing
+the litigants' identities; and (9) the public interest in guaranteeing
+open access to proceedings without denying litigants access to the
+justice system.
+Doe v. Del Rio, 241 F.R.D. 154, 157 (S.D. N.Y. 2006)
+The public has a strong interest in protecting the identities of sexual assault victims so
+that other victims will not be deterred from reporting such crimes. See Doe v.
+, 202 F.R.D.
+173, 176 (E.D.Pa.2001) (granting anonymity to sexual assault victim); Doe No. 2 v. Kolko, 242
+F.R.D. 193 (E.D. N.Y. 2006). That is particularly true in these consolidated cases where there
+are numerous victims with similar claims. Although these cases have gained considerable media
+attention, there appears to be little public interest in knowing the specific identity of each of the
+victims.
+With regard to the second factor, courts have granted anonymity to protect against
+disclosure of a wide range of issues involving matters of the utmost intimacy, including sexual
+8
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 9 of 15
+assault. See, e.g., Aware Woman Cir., 253 F.3d at 685 (abortion); EW, 213 F.R.D. at 111
+(infection with hepatitis B); Doe v. L
+•. 202 F.R.D. 173, 176 (E.D.Pa.2001) (sexual assault
+victim); [
+, 105 F.Supp.2d at 42 (sexual assault victim); WGA v. Priority Pharmacy, Inc., 184
+F.R.D. 616, 617 (E.D.Mo.1999) (status as AIDS patient); Doe v. United Servs. Life Ins. Co., 123
+F.R.D. 437, 439 (S.D.N.Y.1988) (sexual orientation); see also Blue Cross, 112 F.3d at 872
+(recognizing rape victims as entitled to anonymity). It cannot be reasonably denied that a
+person's sexual history - especially during their childhood - is an intimate fact. When the
+childhood sexual history includes criminal sexual contact by an adult, the facts are even more
+intimate and personal. In the electronic age in which we live, these concerns are heightened. As
+federal courts have recognized in this context, it is now possible to "determine whether a given
+individual is a party to a lawsuit in federal court anywhere in the country by the simplest of
+computer searches, to access the docket sheet of any such case electronically, and ... that entire
+case files will be accessible over the Internet." Doe v. City of New York, 201 F.R.D. 100, 102
+(S.D.N.Y.2001) (denying anonymity where any injury was purely reputational and case did not
+involve private or intimate matter); see EW, 213 F.R.D. at 112-13.
+As Dr. Kliman explains in his Declaration, disclosure of Jane Does 2-7's identities will
+place these Plaintiffs "at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media and
+general public. This type of exposure humiliates many victims and represents another betrayal of
+trust. Public exposure places the plaintiff's at further risk of stigmatization, shame and
+retraumatization." See Exhibit "A" at 9l 3. Dr. Kliman also finds it of no consequence that some
+of the plaintiffs are now legally adults in that "[dJue to traumatization the plaintiffs are arrested
+in their development, and even those who are now legally adult are arrested in part to adolescent
+9
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 10 of 15
+aspects of psychology." Id. at 9 4
+The policy of protecting victims of sexual misconduct from undue embarrassment and
+disclosure of their private affairs is firmly established in Fed.R.Evid. 412. The protections of
+Rule 412 are designed to "encourage victims of sexual misconduct to institute and participate in
+legal proceedings against alleged offenders." (Committee Notes to 1994 Amendment).
+Likewise, many states in this country, including Florida and New York, have similarly enacted
+laws to protect the anonymity of sexual assault victims. See Fla. Stat. $$794.024, 794.026
+(2008); N.Y. Civil Rights Law § 50-b (McKinney 2009). In 1994, the Florida Legislature passed
+The Crime Victims Protections Act. The legislative stated purpose for the Act was "to protect
+the identity of victims of sexual crimes." Fla. AGO, 2003-56, 2003 WL 22971082 (Dec. 15,
+2003). Under §794.024, Florida Statutes, court records that identify the name and/or address of a
+victim of a sexual crime are presumed to be confidential and exempt from public access. Id.
+Similarly, upon approving New York's rape shield law, then Governor Mario
+stated,
+"sexual assault victims have unfortunately had to endure a terrible invasion of their physical
+privacy. They have a right to expect that this violation will not be compounded by a further
+invasion of their privacy." 1991 McKinney's Sessions Laws of N.Y., at 2211-2212 (quoted in
+Deborah S. v. Diorio, 153 Misc.2d 708, 583 N.Y.S.2d 872 (N.Y.City Civ. Ct.1992)); see also
+Coker v. Georgia, 433 U.S. 584, 597, 97 S.Ct. 2861, 53 L.Ed.2d 982 (1977) ("Short of homicide,
+[rape] is the ultimate violation of self").
+As to the fourth factor of risk injury, Dr. Kliman has evaluated Jane Does 2-7, and has
+concluded that the childhood sexual abuse at issue has caused features of post-traumatic stress
+disorder (PTSD), including shame, guilt, helplessness, and powerlessness. See Exhibit "A" at TYl
+4-7. Dr. Kliman further states,
+"it is more probable than not that releasing personal identities
+10
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 11 of 15
+will
+an exacerbation and magnification of symptoms lending to increased risk of
+revictimization and retraumatization." Id. at 9| 21. Thus, this is not a case analogous to those
+cited by defendant in which the plaintiffs were merely at risk of "personal embarrassment."
+Instead, there is a genuine and immediate risk of psychological harm.
+None of the cases cited by Defendant where courts denied a plaintiff's request for
+anonymity involved victims of childhood sexual assault or evidence of emotional or
+psychological harm that would result from disclosure of the plaintiff's identity. See Doe v. Hartz,
+52 F.Supp.2d 1027 (N.D.Iowa 1999); Doe v. Shakur, 164 F.R.D. 359 (E.D.N.Y.1996); Doe v.
+Bell Atlantic Bus. Sys. Servs., 162 F.R.D. 418 (D.Mass.1995); Doe v. Univ. of Rhode Island, 28
+Fed.R.Serv.3d 366, 1993 WL 667341 (D.R.I. Dec. 28, 1993).
+As to the factor of prejudice, the Defendant does not identify how his ability to conduct
+discovery or impeach Jane Does 2-7's credibility has been or will be impaired if these Plaintiffs
+are permitted to proceed under a pseudonym. See EW, 213 F.R.D. at 112,
+105 F.Supp.2d
+at 44-45. Other than the need to make redactions and take measures not to disclose these
+Plaintiffs' identities, Defendant will not be hampered or inconvenienced merely by Plaintiffs'
+anonymity in court papers. As set forth above, Defendant already knows their true identities. See
+Aware Woman Center, 253 F.3d at 687 (no prejudice where plaintiff offered to disclose her name
+to defendant); EW, 213 F.R.D. at 112;
+105 F.Supp.2d at 44-45.
+Il.
+DEFENDANT SHOULD NOT BE PERMITTED TO USE
+THE REAL NAMES OF JANE DOES 2-7 IN THIRD-PARTY
+SUBPEONAS EXCEPT FOR THOSE ISSUED TO PERSONS WHOM
+PLAINTIFES HAVE ALREADY DISCLOSED THEIR SEXUAL ABUSE
+As for the use of Jane Does 2-7's real names in subpoenas issued to non-parties, a party
+may obtain discovery of any non-privileged matter that is relevant to a claim or defense of any
+party. Fed.R.Civ.P. 26(b)(I). However, a district court may limit discovery "for good cause
+11
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 12 of 15
+shown" by making "any order which justice requires to protect a party or person from
+annoyance, embarrassment, oppression, or undue burden or expense," including that the
+discovery not be had or that it be had only by a method other than that selected by the party
+seeking discovery. Fed.R.Civ.P. 26(c). Jane Does 2-7 have articulated a specific and substantial
+harm from disclosure of their identities.
+If this Court were to permit Defendant to issue third-party subpoenas containing Jane
+Doe 2-7's real names, the identity of the Defendant, and/or facts pertaining to the nature of the
+case to whomever Defendant wants, it would be akin to requiring these Plaintiffs to use their real
+name in the pleadings.
+Instead, Jane Does 2-7 propose to voluntarily execute authorizations
+(which would not contain the case names or the identity of the Defendant) to allow Defendant to
+obtain education, employment, and medical records to be used for purposes of this litigation
+only. Alternatively, Defendant can obtain the records through a special
+who would
+verify authenticity and completeness of the records. Either of these approaches would not only
+place Jane Does 2-7 at less risk of psychological harm, but would also be more cost-effective and
+efficient.
+CONCLUSION
+Based on the foregoing, Plaintiffs Jane Does 2-7 respectfully request that Defendant's
+Motion to Compel and/or Identify Plaintiffs in the Style of this Case and Motion to Identify Jane
+Doe in Third-Party Subpoenas for Purposes of Discovery, or Alternatively, Motion to Dismiss
+"Sua Sponte" be denied in its entirety, and that Plaintiffs Jane Does 2-7 be permitted to continue
+using their pseudonyms in this litigation. Additionally, to avoid public disclosure of the
+Plaintiff's identities in non-party records discovery, Plaintiffs Jane Does 2-7 request that such
+3 Defendant and Plaintiff have previously agreed that education records can be obtained in this
+12
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 13 of 15
+discovery be obtained either through Plaintiffs' counsel by means of written authorizations, or by
+the appointment of a special
+Dated: June 8, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs Jane Doe Nos. 2-7
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+manner in lieu of subpoenas.
+13
+
+
+Case 9:08-cv-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 14 of 15
+CERTIFICATE OF SERVICE
+I hereby certify that on June 8, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+14
+
+
+Case 9:08-cV-80380-KAM Document 130 Entered on FLSD Docket 06/08/2009 Page 15 of 15
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Adam D. Horowitz
+15
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+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 1 of 13
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S OPPOSITION TO PETITIONERS' MOTION TO COMPEL
+PRODUCTION OF DOCUMENTS THAT ARE NOT PRIVILEGED
+Respondent, by and through its undersigned counsel, files its Opposition to Petitioners"
+Motion to Compel Production of Documents That Are Not Privileged (D.E. 225), and state:
+THE GOVERNMENT HAS ASSERTED VALID PRIVILEGES TO
+DISCLOSURE OF THE REQUESTED DOCUMENTS
+The government has provided adequate privilege logs which inform petitioners and the
+Court of the privilege being asserted, as well as the nature of the documents, in accordance with
+Fed.R.Civ.P. 26(b)(5)(A)(ii).
+Petitioners argue that the privilege log is inadequate, and that
+"[a]s a result of the Government's failures, it is impossible to even begin to determine which of
+the Government's assertions of privilege are valid." D.E. 225 at 1.
+Petitioners' complaints about the privilege log are baseless "[bjecause the adequacy of
+privilege log entries depends on whether the other parties will be able to assess the validity of the
+privilege claim, the entries should be evaluated not in a vacuum, but in light of information that
+the parties can be presumed to possess." In re Methyl Tertiary Butyl Ether Products Liability
+Litigation, 898 F.Supp.2d 584, 590 (S.D.N.Y. 2012)(footnote omitted). Petitioners object to
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 2 of 13
+every item on the privilege log on the grounds of "Inadequate Log," and "No Factual
+Underpinnings." D.E. 224-1. This rote invocation of objections should be rejected because
+petitioners can be presumed to know what these documents are. The government invoked the
+work product doctrine for a number of documents, including a file folder entitled, "
+Act/Travel to Have Sex w/minor," containing attorney research and handwritten notes. D.E.
+224-1 at 32. Petitioner's objections include an "Inadequate Log," and "No Factual
+Underpinnings." Petitioners' attorneys are presumed to know that the criminal case involving
+Jeffrey Epstein involved allegations that Epstein had improper sexual contact with minors, since
+their two clients were sexually abused by Epstein. Further, they are presumed to know what the
+Act prohibits, and how a federal prosecutor might conduct research to determine if a
+Act violation could be successfully prosecuted against Epstein. Such legal research and
+handwritten notes, would reflect the mental impressions and strategies of the prosecutor.
+The Government's use of categorical privileges, to cover broad classes of documents, is
+also permitted. In Federal Deposit Ins. Corp. v. Fidelity and Deposit Company of Maryland,
+2013 WL 2421770 (S.D.Ind. 2013), the Court stated that "it agrees with FDIC that individually
+logging and listing the 12,000 electronic documents is unduly burdensome and unlikely to yield
+additional information as to whether the documents are protected." Id. at *8.
+Attorney-Client Privilege
+Petitioners' argument that the attorney-client privilege is inapplicable because the
+government owes a fiduciary duty to the crime victims under 18 U.S.C. § 3771(c)(1), is also
+incorrect. First, petitioners provide no authority for their claim that the CVRA creates a
+fiduciary relationship between the government and a crime victim. Second, in United States v.
+Jicarilla Apache Nation, 131 S.Ct. 2313 (2011), the Supreme Court reversed the Court of Federal
+2
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 3 of 13
+Claims' finding that the government was required to produce documents in litigation involving
+the Jicarilla Apache Nation. The Tribe had instituted a breach of trust action against the United
+States, claiming the government had mismanaged funds held in trust for the Tribe. The Tribe
+sought various documents in discovery, which included materials for which the government
+claimed were protected by the attorney-client privilege. The Court of Federal Claims applied the
+fiduciary exception to the attorney-client privilege, applied in the context of common law trust,
+and found the documents were not privileged. 131 S.Ct. at 2319.
+The Supreme Court reversed, finding the government is not a private trustee, and the trust
+defined between the government and the Tribe was governed by statutes, rather than the common
+law. Id. at 2323. Further, the United States did not obtain legal advice as a "mere
+representative" of the Tribe, nor was the Tribe the "real client" for whom that advice was
+intended. Id. at 2326. Assuming any fiduciary relationship exists between the government and
+a crime victim, such a relationship would be based on the CVRA, not the common law. Further,
+the government would be managing any trust relationship as a sovereign function, pursuant to
+the plenary authority of Congress, not as a private trustee. Therefore, the fiduciary exception
+does not apply.
+Also inapplicable is the crime-fraud exception to the attorney-client privilege, invoked by
+petitioners. D.E. 225 at 2.
+The courts apply a two-part test to determine if the crime-fraud
+exception applies to a communication between a lawyer and his client. In re Grand Jury
+Investigation (Schroeder), 842 F.2d 1223 (11" Cir. 1987). First, there must be a prima facie
+showing that the client was engaged in criminal or fraudulent conduct when he sought the advice
+of counsel, that he was planning such conduct when he sought the advice of counsel, or that he
+committed a crime or fraud subsequent to receiving the benefit of counsel's advice. Second,
+3
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 4 of 13
+there must be a showing that the attorney's assistance was obtain in furtherance of the criminal
+or fraudulent activity or was closely related to it. Id. at 1226(citations omitted).
+In this case, the counsel are Assistant U.S. Attorneys, supervisory Assistant U.S.
+Attorneys, the United States Attorney, and Department of Justice attorneys. At issue are
+confidential communications occurring during the criminal investigation of Epstein conducted by
+the FBI and the U.S. Attorney's Office. The exception does not apply since neither the U.S.
+Attorney's Office nor the DOJ were "retained" in furtherance of a crime or fraud. Federal law
+enforcement agencies do not retain attorneys to prosecute cases they investigate. U.S. Attorneys
+are appointed and have the duty to "prosecute for all offenses against the United States." 28
+U.S.C. § 547(1).
+Further, it is not a crime to fail to afford a crime victim a right provided under 18 U.S.C.
+§ 3771(a), nor is it a fraud. Section 3771(d)(6) provides that "InJothing in this chapter shall be
+construed to authorize a cause of action for damages or to create, to enlarge, or to imply any duty
+or obligation to any victim or other person for the breach of which the United States or any of its
+officers or employees could be held liable in damages." Since the deprivation of any right under
+the CVRA cannot be the basis of a claim for damages, there is no monetary value attached to
+such rights.
+Without actual injury, petitioners cannot establish a claim for fraud in the
+inducement. PVC Windoors, Inc. v. Babbitbay Beach Construction, N.V., 598 F.3d 802, 808-09
+(11" Cir. 2010).
+The United States Government is entitled to assert evidentiary privileges like any other
+litigant, in both criminal and civil litigation. In United States v. Zingsheim, 384 F.3d 867 (7"
+Cir. 2004), a district court had a standing order requiring the government to provide extra details
+whenever it requested that a defendant receive a lower sentence due to substantial assistance in
+4
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 5 of 13
+the apprehension or prosecution of other offenders. These extra details included
+c) a copy of a recommendation approved and signed by an
+individual holding a supervisory position in a the law enforcement
+agency with whom the defendant cooperated (multiple agencies
+require multiple submissions), d) a written recommendation of a
+supervisor in the office of the prosecutor (e.g. United States
+Attorney, local district attorney or state attorney general), and e) a
+written report from the downward departure committee which shall
+include the names and signatures of the committee members who
+considered the matter, the date(s) the matter was considered, and
+the recommendations(s) of the committee together with any
+dissenting view(s). Failure to adhere to this policy will result in
+the motion being summarily denied without prejudice.
+Id. at 869.
+The Seventh Circuit observed that, "filudges may not demand that litigants surrender
+evidentiary privileges as a condition of adjudication: what a privilege' means is an entitlement
+to withhold information even if it would bear on the merits of a disputed issue." Id. at 87l. As
+to specific privileges, the appellate court noted that, "It]he attorney-client privilege covers
+conversations between the prosecutors (as attorneys) and client agencies within the government."
+Id. 871-72(citations omitted). Thus, e-mails between the FBI and the U.S. Attorney's Office, in
+the Epstein case, are privileged.
+In his affidavit, petitioners' counsel assails the adequacy of the privilege log, and
+contends that the attorney-client privilege has been waived in certain instances. D.E. 225-1 at
+13-14. As an example, petitioners contend that the attorney-client privilege has been waived as
+to the 7/08/08 email from A.
+Villafana to A. Acosta, J. Sloman, Ki. Atkinson, and FBI re
+proposed response to Goldberger's letter re victim notification. D.E. 225-1 at 14, 9[71. He
+claims the emails were not internal to the U.S. Attorney's Office, but were also sent to the FBI,
+and concludes, "[b]ut the FBI is a law enforcement investigative agency, not an agency that
+provides legal advice." Petitioners do not appear to understand that the U.S. Attorney's Office
+5
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 6 of 13
+is rendering legal advice to a client agency, the FBI, who investigated Epstein and brought the
+case to the U.S. Attorney's Office for potential prosecution. Zingsheim, 384 F.3d at 871-
+72("[tJhe attorney-client privilege covers conversations between the prosecutors (as attorneys)
+and client agencies within the government."). Similarly, the 9/17/07 e-mail from A.
+Villafana to J. Richards and N. Kuyrkendall re status update, is protected by the attorney-client
+privilege. D.E. 225-1 at 14-15, 9| 73. Petitioners recognize that Richards and Kuyrkendall are
+FBI agents, but apparently believe that communications between the U.S. Attorney's Office,
+regarding a case brought by the FBI, to the FBI agents investigating the case, are not privileged
+communications. Petitioners' view is incorrect since the FBI is a client agency in the
+prosecution of Epstein, and the communication was made to the client agency.
+B.
+Attorney Work-Product
+As to work-product, the Zingsheim court noted that, "It]he work-product privilege
+applies to many other discussions between prosecutors and investigating agents, both state and
+federal. Id. at 872, citing FTC v. Grolier, Inc., 462 U.S. 19 (1983). Therefore, the government is
+entitled to invoke the work product privilege for written documents and communications
+prepared in anticipation of the criminal prosecution of Jeffrey Epstein, which contain mental
+impressions, theories, opinions, factual information, and conclusions regarding the case.
+Petitioners erroneously maintain that documents not prepared in anticipation of the
+CVRA litigation do not enjoy the protection of the work-product doctrine. D.E. 225 at 3. In
+FTC v. Grolier, supra, the Supreme Court examined Fed.R.Civ.P. 26(b)(3) and remarked that,
+"the literal language of the Rule protects materials prepared for any litigation or trial as long as
+they were prepared by or for a party to the subsequent litigation." 462 U.S. at 25(emphasis in
+original). Frontier Refining, Inc. v. Gorman-Rupp Company, Inc., 136 F.3d 695, 703 (9" Cir.
+6
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 7 of 13
+1998)("Based on the compelling dicta in Grolier and the reasoning set out in the circuit court
+opinions cited above, we conclude that the work product doctrine extends to subsequent
+litigation."). Therefore, materials prepared in anticipation of the Epstein criminal case are
+covered by the work product doctrine.
+Similarly unavailing is petitioners' contention that the work product doctrine is
+inapplicable because they are making a claim that public prosecutors violated their public
+responsibilities under the CVRA. D.E. 225 at 5. They rely upon U.S. v. Arthur Young &
+Company, 465 U.S. 805 (1984), a case involving a summons served by the IRS upon an
+accounting firm. The IRS summons was issued pursuant to authority granted by 26 U.S.C. §
+7602, which authorizes the Secretary of the Treasury to summon and "examine any books,
+papers, records, or other data which may be relevant or material" to a particular tax inquiry. Id.
+at 813. The court of appeals found that the tax accrual workpapers prepared by Arthur Young
+were exempt from disclosure under a work-product immunity.
+The Supreme Court reversed as to the work-product immunity. As to § 7602, the Court
+observed that, "[w]e are unable to discern the sort of 'unambiguous directions from Congress'
+that would justify a judicially created work-product immunity for tax accrual workpapers
+summoned under § 7602." Id. at 816. The Court also found no "fitting analogue" to the attorney
+work-product doctrine because an independent certified public accountant performs a different
+role than a private attorney. "By certifying the public reports that collectively depict a
+corporation's financial status, the independent auditor assumes a public responsibility
+transcending any employment relationship with the client." Id. at 817.
+Arthur Young is inapplicable because a public prosecutor occupies a different role than
+the independent auditor. Under 28 U.S.C. § 516, "[e]xcept as otherwise provided by law, the
+7
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 8 of 13
+conduct of litigation in which the United States, an agency, or officer thereof is a party, or is
+interested, and securing evidence therefor, is reserved to officers of the Department of Justice,
+under the direction of the Attorney General." A Department of Justice attorney takes direction
+from the Attorney General and his delegates, in the conduct of litigation, rather than serving
+some abstract public responsibility. The Attorney General determines how to serve the public
+interest. The work product privilege exists to provide a working attorney with a "zone of
+privacy" within which to think, plan, weigh facts and evidence, candidly evaluate a client's case,
+and prepare legal theories. Coastal States Gas Corp. v. Department of Energy, 617 F.2d 854, 864
+(D.C. Cir. 1980). The purpose of the doctrine is to protect the adversary trial process itself, by
+preventing adversaries from probing each other's thoughts and plans concerning a case. Id.
+Communications regarding a case by DOJ attorneys are protected by the work product
+doctrine. In Menasha Corporation v. U.S. Department of Justice, 707 F.3d 846 (7" Cir. 2013),
+the Seventh Circuit held that communications between DOJ attorneys from the Environmental
+Enforcement Section and the Environmental Defense Section, both subcomponents of the DOJ's
+Environment and Natural Resources Division, were exempt from disclosure under the FOIA
+because they were covered by the attorney work product doctrine. In doing so, the appellate
+court rejected Menasha's claim that, because the Environmental Enforcement Section and
+Environmental Defense Section were representing federal agencies with conflicting interests, the
+work product privilege was forfeited. Id. at 848-850. The Environmental Enforcement Section
+represented the interests of the Environmental Protection Agency, which seeks to enforce
+environmental laws, while the Environmental Defense Section, which defends the United States
+from suits to enforce environmental laws, represented the interests of the Corps of Engineers.
+The Seventh Circuit found this to be "of no moment" since the United States was the only
+8
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 9 of 13
+federal party and was represented by the Justice Department. Id. at 850. Any conflicts between
+the two sections within the Environment and Natural Resources Division would be resolved by
+the Assistant Attorney General heading the Environment and Natural Resources Division. Id. at
+850-52.
+Noteworthy for this case is the Seventh Circuit's observation that, "[a]ll this is irrelevant
+to work product privilege, which shields the wrangles within the client's legal team from the
+opposing party." Id. at 852. Petitioners are not entitled to peek at the discussions within the
+U.S. Attorney's Office regarding the potential prosecution of Epstein, or communications within
+the U.S. Attorney's Office, or between components of the DOJ and the U.S. Attorney's Office,
+about the appropriate application of the CVRA.
+Il.
+THE LAW ENFORCEMENT INVESTIGATIVE PRIVILEGE APPLIES
+The government has asserted the law enforcement investigative privilege in response to
+petitioners' request for documents from the FBI case file in the Epstein investigation, and
+investigative materials from the U.S. Attorney's Office for the Epstein matter. Petitioners
+dispute the applicability of this privilege in the declaration of one of their attorneys. D.E. 225-1
+at 21-23.
+The investigation into Jeffrey Epstein was called Operation Leap Year. Exhibit A,
+Declaration of FBI Special Agent E. Nesbitt Kuyrkendall, I 2. Contrary to petitioners' assertion
+(D.E. 225-1 at 22, 9| 112), Operation Leap Year remains an open case. Kuyrkendall Decl., I 7.
+Further, disclosure to third parties of the interview reports of the young women sexually abused
+by Mr. Epstein would cause embarrassment to the young women. Id., I| 3. These young women
+suffered emotionally, and some were referred by the FBI to mental health professionals to assist
+them. Id., I5.
+9
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 10 of 13
+The disclosure of information contained in the FBI investigative file, to third parties,
+would not merely cause further embarrassment, but could result in additional psychological
+trauma, disruption of family relationships, disruption of professional careers, and possible public
+release of personal information. Id., I6.
+Disclosure of information from the FBI investigative file would also reveal sensitive FBI
+investigative and operational methods, procedures, and techniques. Id., 1[4. Information
+contained within an FBI investigative file, if revealed, might compromise the effective use of
+such methods in future cases. Id. The FBI's investigative tools must remain confidential so that
+law enforcement can retain an element of surprise, and prevent the use of countermeasures by
+targets and suspects to thwart effective law enforcement. Id.
+The purpose of the law enforcement privilege "is to prevent disclosure of law
+enforcement techniques and procedures. to preserve the confidentiality of sources, to protect
+witness and law enforcement personnel, to safeguard the privacy of individuals involved in an
+investigation, and otherwise to prevent interference with an investigation." In re Department of
+Investigation of the City of New York, 856 F.2d 481, 484 (2"d Cir. 1988)(citations omitted). In
+this action under the CVRA, the government's interest in confidentiality far outweighs
+petitioners need for the information. In re United States Department of Homeland Security, 459
+F.3d 565, 570 (5' Cir. 2006). Therefore, the law enforcement investigative privilege applies.
+III.
+DELIBERATIVE PROCESS PRIVILEGE
+The government has invoked the deliberative process privilege for a number of
+documents because they are pre-decisional, and are the recommendations, opinions, or
+deliberations of government officials. "The purpose of this privilege is to allow agencies to
+freely explore possibilities, engage in internal debates, or play devil's advocate without fear of
+10
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 11 of 13
+public scrutiny." Moye.
+: O'Rourke, Hogan & Pickert v. National Railroad Passenger
+Corp., 376 F.3d 1270, 1277 (11" Cir. 2004), citing Department of Interior v. Klamath Water
+Users Protective Ass'n, 532 U.S. 1, 8-9 (2001).
+Government counsel has been working with the Office of the Deputy Attorney General to
+obtain the appropriate declaration invoking the deliberative process privilege. By separate
+motion, the government will be requesting an enlargement of time of ten (10) days, to obtain and
+file this declaration.
+IV. THE PRIVACY ACT, 5 U.S.C. § 552a(b)(11), REQUIRES A COURT TO
+ENGAGE IN A BALANCING TEST BEFORE DISCLOSURE CAN BE
+ORDERED
+Petitioners contend that the Privacy Act does not apply in the context of court-compelled
+disclosures for discovery. D.E. 225 at 7. They cite to 5 U.S.C. § 552a(b)(11), which provides
+that permits an agency to disclose a record "pursuant to the order of a court of competent
+jurisdietion." In
+v. State Farm Fire & Casualty Company, 734 F.2d 1441 (11" Cir. 1984),
+the Eleventh Circuit observed that, "[r]elease is allowed when a court of competent jurisdiction
+so orders." Id. at 1447, citing 5 U.S.C.A. § 552a(b)(11). Continuing, the Court stated,
+"[r]equests for court orders under § 552a(b)(11) should be evaluated by balancing the need for
+the disclosure against the potential harm to the subject of the disclosure." Id. (citations omitted).
+A court order compelling disclosures for discovery does not qualify as a § 552a(b)(11)
+order unless the court has engaged in the balancing described in
+Since this required
+balancing has not been done, the Privacy Act applies and precludes disclosure by the
+government.
+CONCLUSION
+The government has validly asserted privileges that preclude disclosure of the requested
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 12 of 13
+documents to petitioners.
+Therefore, petitioners' motion to compel production should be denied.
+DATED: September 3, 2013
+Respectfully submitted,
+WILFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4th Street, Suite 300
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+ATTORNEY FOR RESPONDENT
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on September 3, 2013, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Jaffe, Weissing,
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Fistos & Lehrman, P.L.
+Paul G. Cassell
+S.J. Quinney College of Law at the
+12
+
+
+Case 9:08-cv-80736-KAM Document 229 Entered on FLSD Docket 09/03/2013 Page 13 of 13
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+Roy Black
+Jackie Perezek
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+(305) 371-6421
+Fax: (305) 358-2006
+E-mail: rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+13
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new file mode 100644
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d.md b/vision-fixhub/court-01/f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d.md
new file mode 100644
index 0000000000000000000000000000000000000000..0b32a74a3e54c4963e6ae18c27f0873edc6e95ae
--- /dev/null
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@@ -0,0 +1,115 @@
+Case 9:09-cv-80591-KAM Document 33 Entered on FLSD Docket 05/29/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff.
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/C_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80591-KAM Document 33 Entered on FLSD Docket 05/29/2009 Page 2 of 4
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-CV-80811-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/_
+vS.
+JEFFREY EPSTEIN et al,
+Defendants.
+-2-
+
+
+Case 9:09-cv-80591-KAM Document 33 Entered on FLSD Docket 05/29/2009 Page 3 of 4
+DOE II,
+Plaintiff,
+CASE NO.: 09-CV-80469-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+/
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+UNITED STATES' NOTICE OF LIMITED APPEARANCE
+AS AMICUS CURIAE TO FILE RESPONSE TO COURT'S ORDER
+REQUESTING POSITION ON DEFENDANT'S MOTION TO STAY [DE 99]
+Comes now the United States, by and through the undersigned Assistant United States
+Attorney, and makes this limited appearance to file via CM/ECF its response to the Court's
+Order requesting the position of the United States on Defendant Jeffrey Epstein's Motion to
+Stay Proceedings [DE 99]. By filing this notice of limited appearance and its response, the
+United States does not make itself a party to this litigation and takes no position with respect
+-3-
+
+
+Case 9:09-cv-80591-KAM Document 33 Entered on FLSD Docket 05/29/2009 Page 4 of 4
+to the outcome of any of the civil suits. By filing this notice of limited appearance and
+response, the United States also does not waive any procedural or statutory bars to suit.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+S/A
+A.
+Villafaña
+VILLAFAÑA
+Assistant United States Attorney
+Florida Bar No. 0018255
+500 East Broward Boulevard, 7th Floor
+Ft. Lauderdale, FL 33394
+Telephone: 954-356-7255
+Facsimile: 954-356-7230
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on May 28, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. According to the Court's website, counsel
+for all parties are able to receive notice via the CM/ECF system.
+S/A.
+Villafaña
+A.
+VILLAFAÑA
+Assistant United States Attorney
+-4-
diff --git a/vision-fixhub/court-01/f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d.receipt.json b/vision-fixhub/court-01/f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..53fe569d52b211fe622d3b9647eee8ea0246d718
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+++ b/vision-fixhub/court-01/f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "f1d70eed55c395996c18deb9a2ae54d18311663a86d60738d432f919f0096e1d",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d5f0c31104605cfeb1be08dfd1aafb747bd118d5b334641e5e8b70688cd66f2c",
+  "output_sha256": "08db2077ed43b89dc77b799e97ebc7b784cffcf6f3476ec68a44a1da67fc43a2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f1ede028dc2003124aebe1122aec0ac44f89f64c3a2320759f30dad00df154b8.md b/vision-fixhub/court-01/f1ede028dc2003124aebe1122aec0ac44f89f64c3a2320759f30dad00df154b8.md
new file mode 100644
index 0000000000000000000000000000000000000000..e70c2e89e1ba29db4f98a62050a3aa86b61071a0
--- /dev/null
+++ b/vision-fixhub/court-01/f1ede028dc2003124aebe1122aec0ac44f89f64c3a2320759f30dad00df154b8.md
@@ -0,0 +1,520 @@
+Entered on FLSD Docket 05/20/2009 Page 1 4 tdg t
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA|
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+PLAINITFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES
+Plaintiff, JANE DOE 2, by and through her undersigned counsel, and pursuant to
+Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+1.
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law. Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+Comp Ex "A"
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 2 of 16
+Doe No. 2 v. Epstein
+Page 8
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury, and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+Answer:
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation, anxiety, low self-esteem, feelings of guilt,
+self-blame,
+distrustfulness, burdened often by sadness and depression, suicidal thoughts,
+difficulty trusting others (particularly men), irritability, anger, feeling helpless and
+powerless, escapism through excessive partying, lack of confidence, loss of
+innocence.
+Plaintiff's psychological and emotional injuries will be analyzed by a forensic
+expert, whose opinions and related information will be disclosed in accordance
+with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff
+reserves the right to supplement this response in accordance with the Federal
+Rules of Civil Procedure.
+10.
+Please state each item of damage that you claim, and include in your answer:
+the count to which the item of damages relates; the factual basis for each item of
+damages; and an explanation of how you computed each item of damages,
+including any mathematical formula used.
+Answer:
+Plaintiff objects to this interrogatory as calling for an expert opinion and
+calculation. Subject to said objection, Plaintiff states that she seeks damages
+arising from her psychological and emotional injuries. These damages include
+pain and suffering, costs of psychological care and treatment, and loss of earning
+capacity.
+The pecuniary elements of these damages will be analyzed and
+computed by an appropriate expert.
+11.
+List the names and business addresses of each physician (including psychiatrist,
+psychologist, etc.) or medical provider (including chiropractors) who has treated
+or examined you, and each medical facility where you have received any
+treatment or examination for the injuries for which you seek damages in this
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 3 of 16
+VERIFICATION
+being duly sworn, deposes and says that the
+foregoing answers to interrogatories are true and correct to the best of her knowledge,
+information and belief.
+STATE OF FLORIDA
+)
+) ss
+)
+COUNTY OF PALM BEACH
+SWORN TO AND SUBSOR ED before me this and to easy a ty
+following identification
+_ which is current or has been issued
+within the past five years and bears a serial or other identifying number.
+Evelyn G. GoeNs
+Print Name
+Evelyn D. Sons
+Signature
+NOTARY PUBLIC - STATE OF FLORIDA
+Commission Number:
+My commission expires:
+(Notarial Seal)
+state
+of ViRginia
+
+
+
+Emered on FLSO Docker 0si2a12009 Page 4 offagt
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+PLAINTIFF JANE DOES AROGATORE DEFENDANT'S FIRST
+Plaintiff, JANE DOE 3, by and through their undersigned counsel, and pursuant
+to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law.
+Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+2.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+CO-MATE,
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 5 of 16
+Doe No. 3 v. Epstein
+Page 8
+No.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury, and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+Answer:
+Plaintiff has suffered severe psychological, emotional and psychical injuries,
+including without limitation, anxiety, depression, suicidal ideation, guilt, selfblame, feelings of being degraded, feeling unattractive, diminished sense of
+teminity, fluctuations in weight/appetite, sexual/intimacy problems, flashbacks,
+disturbing memories, stress, irritability, feelings of being isolated and trapped,
+diminished trust, social
+problems, problems in personal relationships,
+indecisiveness, lower energy, lower ambition and initiative, headaches, back
+pain, feels stress (particularly around men), obsessive thoughts, problems
+concentrating, alcohol abuse, corruption of morals and values, loss of innocence.
+and cries alot.
+Plaintiff's psychological and emotional injuries will be analyzed and explained by
+a forensic expert, whose opinions and related information will be disclosed in
+accordance with the expert discovery rules of the Federal Rules of Civil
+Procedure.
+Plaintiff reserves the right to supplement this response in
+accordance with the Federal Rules of Civil Procedure.
+10.
+Please state each item of damage that you claim, and include in your answer:
+the count to which the item of damages relates; the factual basis for each item of
+damages; and an explanation of how you computed each item of damages,
+including any mathematical formula used.
+Answer:
+Plaintiff objects to this interrogatory as calling for an expert opinion and
+calculation. Subject to said objection, Plaintiff states that she seeks damages
+arising from her psychological and emotional injuries. These damages include
+pain and suffering, costs of psychological care and treatment, and loss of earning
+capacity. The pecuniary elements of these damages will be analyzed and
+computed by an appropriate expert.
+Discovery is ongoing and will be supplemented in accordance with the Federal
+Rules of Civil Procedure.
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 6 of 16
+VERIFICATION
+being duly sworn, deposes and says that the
+foregoing answers to interrogatories are true and correct to the best of her knowledge,
+information and belief.
+STATE OF FLORIDA
+) ss
+COUNTY OF PALM BEACH
+MORN AND SUBSCRIBED te personali an day of Januany weed the
+_ who is personally known to me or has produced the
+hollowing identification
+rivers hicews which is current or has been issued
+within the past five years and bears a serial or other identifying number.
+Elizabeth guteenez
+Print Name
+Signatúre
+Elizabeth filez
+NOTARY PUBLIC - STATE OF FLORIDA
+Commission Number:
+My commission expires:
+(Notarial Seal)
+Wonde
+Notary Public State of Florida
+Elizabeth Gutierrez-
+My Commission DD440926
+Expires 06/14/2009
+
+
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80994-MARRA-|
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S ANSWERS TO DEFENDANT'S FIRST INTERROGATORIES
+Plaintiff, JANE DOE 6, by and through her undersigned counsel, and pursuant to
+Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law. Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+(a -
+doc.
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 8 of 16
+Doe No. 6 V. Epstein
+Page 5
+7.
+9.
+Discovery is ongoing and will be supplemented in accordance with the Federal
+Rules of Civil Procedure.
+Please state the specific nature and substance of the knowledge that you believe
+the person(s) identified in your response to interrogatory no. 5 may have.
+Answer:
+See Plaintiff s Answer to Interrogatory No. 5.
+Were you suffering from physical infirmity, disability, disease, sickness, or
+sychiatric/psychological condition at the time of the incident/s) described in th
+omplaint? If so, what was the nature of the infirmity, disability, or sickness'
+Answer:
+Plaintiff was diagnosed with PTSD following a car accident in 2003.
+Did you consume any alcoholic beverages or take any drugs or medications
+within 12 hours before the time of each incidents) described in the complaint? If
+so, state the type and amount of alcoholic beverages, drugs, or medication which
+were consumed, and when and where you consumed them.
+Answer:
+No.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury, and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation,
+anxiety, anger, distorted and disrupted development,
+restlessness, distrust, self destructive behaviors, suicidal behavior, substance
+abuse, severe Xanax addiction beginning after her encounter with Epstein,
+corruption of morals, antisocial behaviors, premature teenage pregnancy, loss of
+normal adolescent ideals, loss of innocence.
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 9 of 16
+Page 6
+10.
+11.
+Plaintiff's psychological and emotional injuries will be analyzed by a forensic
+expert, whose opinions and related information will be disclosed in accordance
+with the expert discovery rules of the Federal Rules of Civil Procedure.
+Plaintiff
+reserves the right to supplement this response in accordance with the Federal
+Rules of Civil Procedure.
+Please state each item of damage that you claim, and include in your answer:
+the count to which the item of damages relates; the factual basis for each item of
+damages; and an explanation of how you computed each item of damages,
+including any mathematical formula used.
+Answer:
+Plaintiff objects to this interrogatory as vague, overly broad, unduly burdensome,
+calling for speculation, and calling for an expert opinion. Subject to said
+objections, Plaintiff states:
+Discovery is ongoing and will be supplemented in accordance with Federal Rules
+of Civil Procedure.
+List the names and business addresses of each physician (including psychiatrist,
+psychologist, etc.) or medical provider (including chiropractors) who has treated
+or examined you, and each medical facility where you have received any
+treatment or examination for the injuries for which you seek damages in this
+case; and state as to each the date of treatment or examination and the injury or
+condition for which you were examined or treated.
+Answer:
+12.
+List the names and business addresses of all other physicians, medical facilities,
+rehab facilities (drug, alcohol or psychiatric) or other health care providers
+(nion or a which you have been examined a read in the past 10 year ly
+state as to each the dates of examination or treatment and the condition or injury
+for which you were examined or treated.
+Answer:
+
+
+Case 9:08-Cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 10 of
+Page 11
+VERIFICATION
+being duly sworn, deposes and says that the
+foregoing answers to interrogatories are true and correct to the best of her knowledge,
+information and belief.
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+SWORN TO AND RURACRIBED before me this jit day of January, 2009 by
+#who is personally known to me or has produced the
+fonowing identification
+_ which is current or has been issued
+within the past five years and bears a serial or other identifying number.
+Deborah DíFloria
+Print Name
+Signature
+NOTARY PUBLIC - STATE OF FLORIDA
+Commission Number:
+My commission expires: Norenbe 5, 2010
+(Notarial Seal)
+DEBORAH DIFLORIA
+MY COMMISSION • DD 613353
+EXPIRES: November 8, 2010
+Bonded Thru Notary Pable Underwaters
+By:
+Adam Horowitz
+Jeffrey M. Herman
+Stuart Mermelstein
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+(305) 931-2200
+Fax: (305) 931-0877
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 11 of
+Page 13
+Certificate of Service
+Mail any facsite to the folley nata tresses of 2 foregoing nary an sent via U.S.
+Robert D. Critton, Jr, Esq.
+Burman, Critton, Luttier & Coleman
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+rcrit@bclclaw.com
+Co-Counsel for Defendant Jeffrey Epstein
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Michael R. Tein, Esq.
+Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+305-442-1101
+Fax: 305 442 6744
+Co-Counsel for Defendant Jeffrey Epstein
+tein@lewistein.com
+Mapu
+
+
+G
+Case 9.03-C-80119 KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 720g
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80993-MARRA-|
+JANE DOE NO. 7,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+PLAINTIFF JANE DOE 7'S ANSWERS TO
+DEFENDANT'S FIRST INTERROGATORIES
+Plaintiff, JANE DOE 7, by and through their undersigned counsel, and pursuant
+to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law. Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+2.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+
+
+Case 9:08-Cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 13 of
+Doe No. 7 v. Epstein
+Page 6
+Jane Doe 1 (who is not represented by the undersigned attorneys)
+Hayley
+Plaintiff's classmate who brought Plaintiff to Defendant's estate on 2 occasions
+Plaintiff's classmate who accompanied Plaintiff to Defendant's estate on at lest
+one occasion
+Either
+accompanied Plaintiff to Defendant's estate
+on at least one occasion, but Plaintiff is unable to recall which sister it was.
+Discovery is ongoing and may be supplemented in accordance with the Federal
+Rules of Civil Procedure.
+Please state the specific nature and substance of the knowledge that you believe
+the person(s) identified in your response to interrogatory no. 5 may have.
+Answer:
+See Plaintiff's Answer to Interrogatory No. 5.
+7.
+Were you suffering from physical infirmity, disability, disease, sickness, or
+psychiatric/psychological condition at the time of the incidents) described in the
+complaint? If so, what was the nature of the infirmity, disability, or sickness?
+Answer:
+No.
+8.
+9.
+Did you consume any alcoholic beverages or take any drugs or medications
+within 12 hours before the time of each incidents) described in the complaint? If
+so, state the type and amount of alcoholic beverages, drugs, or medication which
+were consumed, and when and where you consumed them.
+Answer:
+No.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 14 of
+Doe No. 7 V. Epstein
+Page 7
+nature of the injury, and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+Answer:
+Plaintiff has suffered severe psychological and emotional injuries, including
+*without limitation, anxiety, disturbed sleep, depression, alcohol abuse, panicky,
+hypersexuality/promiscuity, inability to trust, diminished judgment regarding
+others, diminished sense of future prospects, corruption of morals, distorted and
+disrupted development, loss of normal adolescent ideals.
+Plaintiff's psychological and emotional injuries will be analyzed by a forensic
+expert, whose opinions and related information will be disclosed in accordance
+with the expert discovery rules of the Federal Rules of Civil Procedure. Plaintiff
+reserves the right to supplement this response in accordance with the Federal
+Rules of Civil Procedure.
+10.
+11.
+Please state each item of damage that you claim, and include in your answer:
+the count to which the item of damages relates; the factual basis for each item of
+damages; and an explanation of how you computed each item of damages,
+including any mathematical formula used.
+Answer:
+Plaintiff objects to this interrogatory as calling for an expert opinion and
+calculation. Subject to said objection, Plaintiff states that she seeks damages
+arising from her psychological and emotional injuries. These damages include
+pain and suffering, costs of psychological care and treatment, and loss of earning
+capacity.
+The pecuniary elements of these damages will be analyzed and
+computed by an appropriate expert.
+Discovery is ongoing and will be supplemented in accordance with the Federal
+Rules of Civil Procedure.
+List the names and business addresses of each physician (including psychiatrist,
+psychologist, etc.) or medical provider (including chiropractors) who has treated
+or examined you, and each medical facility where you have received any
+reatment or examination for the injuries for which you seek damages in th
+ase; and state as to each the date of treatment or examination and the injury c
+condition for which you were examined or treated.
+Answer:
+
+
+Case 9:08-cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 15 of
+01/23/2009
+20:20
+FEDEX KINKDS
+Jane Doe No. 7 v. Epsteln
+Page 15
+against Mr. Epstein and regarding whether there would be: any benefit from your
+voluntary cooperation with law enforcement.
+VERIFICATION
+_being duly sworn, depose: and says that the
+foregoing answers to interrogatories are true and correct to the best of her knowledge.
+information and belief.
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Tonowing identication
+CORN TO AND I BE bo me thy 52 in Jas any 200
+which is current or has been issued
+within the past five years and bears a serial or other identifying number.
+Juan
+Femalez
+Print Name
+BECERER:
+Signatur
+NOTARY PUBLIC - STATE OF FLORIDA
+Commission Number: D130715801
+My commission expires: 9/18/2011
+(Natarial Seal).
+JUAN FERNANDI*
+Comm# DD0715802
+Expires 9/18/2011
+Flanda Notary Assn., Ing
+MAs*****-***•*******
+
+
+Case 9:08-Cv-80119-KAM Document 110-1 Entered on FLSD Docket 05/20/2009 Page 16 of
+Doe No. 7 v. Epstein
+Page 15
+Certificate of Service
+WE HEREBY CERTIFY that a true copy of the foregoing has been sent via U.S.
+Mail and facsimile to the following addressees this 26 day of January, 2009.
+Robert D. Critton, Jr, Esq.
+Burman, Critton, Luttier & Coleman
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+rcrit@bclclaw.com
+Co-Counsel for Defendant Jeffrey Epstein
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Michael R. Tein, Esq.
+Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+305-442-1101
+Fax: 305 442 6744
+Co-Counsel for Defendant Jeffrey Epstein
+tein@lewistein.com
+MONE
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f1ede028dc2003124aebe1122aec0ac44f89f64c3a2320759f30dad00df154b8.receipt.json b/vision-fixhub/court-01/f1ede028dc2003124aebe1122aec0ac44f89f64c3a2320759f30dad00df154b8.receipt.json
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diff --git a/vision-fixhub/court-01/f1f07c1e542c721d2243c8bd387f584eb15b4e3fa3ce3ebd733b490d689d6779.md b/vision-fixhub/court-01/f1f07c1e542c721d2243c8bd387f584eb15b4e3fa3ce3ebd733b490d689d6779.md
new file mode 100644
index 0000000000000000000000000000000000000000..def3ff5b8a904eda459b22866922a48d7d52c424
--- /dev/null
+++ b/vision-fixhub/court-01/f1f07c1e542c721d2243c8bd387f584eb15b4e3fa3ce3ebd733b490d689d6779.md
@@ -0,0 +1,33 @@
+Case 1:19-cv-08673-KPF-DCF Document 9 Filed 10/04/19 Page 1 of 1
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman"
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz(@troutman.com
+October 4, 2019
+ECF
+Hon. Katherine Polk Failla
+Thurgood Marshall
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re:
+Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as the
+Executors of the Estate of Jeffrey E. Epstein, 1:19-cv-08673-KPF
+Dear Judge Failla:
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E.
+Epstein (together, "Defendants"), in the referenced action. We write to respectfully request the
+Court's approval of the parties' agreement described below.
+On September 24, 2019, subject to the Court's approval: (1) we agreed to accept service of
+Plaintiff's Complaint (ECF #1) on Defendants' behalf; (2) Plaintiff consented to Defendants
+having through November 15, 2019 to answer, move or otherwise respond to Plaintiff's
+Complaint; and (3) Plaintiff consented to Defendants having through November 15, 2019 to
+answer, move or otherwise respond to Plaintiff's Motion to Proceed Under Pseudonym (ECF
+There have been no other requests for adjournments or extensions of time in this action.
+Thank you for your attention to this matter.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
diff --git a/vision-fixhub/court-01/f1f07c1e542c721d2243c8bd387f584eb15b4e3fa3ce3ebd733b490d689d6779.receipt.json b/vision-fixhub/court-01/f1f07c1e542c721d2243c8bd387f584eb15b4e3fa3ce3ebd733b490d689d6779.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..103afbea684388019b3709c2d54b36c31683350b
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f1fe11b4dbd8dced540bb89e58559d74dbcc73ee1805e9b94387125eecbe8adf.md b/vision-fixhub/court-01/f1fe11b4dbd8dced540bb89e58559d74dbcc73ee1805e9b94387125eecbe8adf.md
new file mode 100644
index 0000000000000000000000000000000000000000..2f40964949adbf7e71c1ad4d66d4ecf16f75e45b
--- /dev/null
+++ b/vision-fixhub/court-01/f1fe11b4dbd8dced540bb89e58559d74dbcc73ee1805e9b94387125eecbe8adf.md
@@ -0,0 +1,62 @@
+Case 1:19-cv-08673-KPF-DCF Document 91 Filed 07/29/20 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the ESTATE
+OF JEFFREY E. EPSTEIN,
+Defendants.
+Case No. 1:19-cv-08673-KPF-DCF
+JOINT STIPULATION AND [PROPOSED| ORDER STAYING ACTION
+IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel
+for the Parties, that:
+The captioned action is hereby stayed pending Plaintiff's participation in the
+Epstein Victims' Compensation Program (the "Program").
+2.
+Should the Plaintiff cease her participation in the Program for any reason (including
+but not limited to by declining any monetary settlement offered by the Program), the stay will be
+lifted within one week (seven calendar days) after Plaintiff provides Defendants with written notice
+of her intent not to participate in the Program.
+After the lifting of the stay, if any, the Parties will confer on a schedule for the
+remaining discovery in this action.
+
+
+
+Case 1:19-cv-08673-KPF-DCF Document 91 Filed 07/29/20 Page 2 of 2
+Dated: July 29, 2020
+New York, New York
+Respectfully submitted,
+TROUTMAN PEPPER
+SANDERS LLP
+By: _/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+875 Third Avenue
+New York, NY
+212.704.6000
+Bennet.moskowitz@troutman.com
+Attorneys for Darren K. Indyke and D. Richard
+Kahn, as Co-Executors of the Estate of Jeffrey
+E. Epstein
+KAPLAN HECKER & FINK, LLP
+By:_/s/ Roberta A. Kaplan
+Roberta A. Kaplan
+Julie E. Fink
+Kate L. Doniger
+Alexandra K. Conlon
+350 Fifth Avenue, Suite 7110
+New York, NY 10118
+212.763.0883
+rkaplan@kaplanhecker.com
+jfink@kaplanhecker.com
+kdoniger@kaplanhecker.com
+aconlon@kaplanhecker.com
+Attorneys for Plaintiff
+Date:
+, 2020
+New York, New York
+HON. DEBRA C. FREEMAN
+United States Magistrate Judge
+2
+
diff --git a/vision-fixhub/court-01/f1fe11b4dbd8dced540bb89e58559d74dbcc73ee1805e9b94387125eecbe8adf.receipt.json b/vision-fixhub/court-01/f1fe11b4dbd8dced540bb89e58559d74dbcc73ee1805e9b94387125eecbe8adf.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.md b/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.md
new file mode 100644
index 0000000000000000000000000000000000000000..bc6b193bf30f084d51afa451ecd1c04834082045
--- /dev/null
+++ b/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.md
@@ -0,0 +1,58 @@
+Case 1:19-CV-09610-PAE-DCF Document 1-1 Filed 10/17/19 Page 1 of 2
+
+
+
+Case 1:19-cv-09610-PAE-DCF Document 1-1
+Filed 10/17/19
+Page 2 ot 2
+U.S. v. Jeffrey Epstein, 19-Cr-490 (RMB)
+ASSET SUMMARY - JUNE 30, 2019
+Asset
+Cash
+*
+Fixed Income
+*
+Equities
+*
+**
+Hedge Funds & Private Equity
+| Properties
+***
+9 East 71st Street, New York, NY 10021
+49 Zorro Ranch Road, Stanley New Mexico 87056
+358 El Brillo Way, Palm Beach, FL 33480
+22 Avenue Foch, Paris France 75116
+Great St James Island No. 6A USVI 00802 (parcels A,B,C)
+****
+Little St James Island No. 6B USVI 00802 (parcels A,B,C)
+$
+$
+$
+$
+$
+$
+$
+6/30/19
+Value
+56,547,773
+14,304,679
+112,679,138
+194,986,301
+55,931.000
+17,246,208
+12,380,209
+8,672,823
+22.498,600
+63,874,223
+Total Assets
+$
+559,120,954
+*
+Values reflect gross numbers that are not net of tax
+** All properties are valued at assessed values as per the most recent
+property tax bills
+*** Note the United States Attomey's office for the Souther District of New York
+has stated that the value of this home is $77,000,000 as compared to the
+market value shown above per the June 1, 2019 property tax bill
+**** Note this property is valued at cost basis, however the assessment on
+the most recent tax bill is $4,857,500
diff --git a/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.receipt.json b/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..15740b9221ab9540ec3c7e1506791a0955183b88
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+++ b/vision-fixhub/court-01/f21a99d680b8545ce387e139448b5895aefca577f06f19abf462b42bef1f748e.receipt.json
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diff --git a/vision-fixhub/court-01/f21bfd4928dde015ff1b620d308bc75381c4802cd5e068bd1a344f097575abc5.md b/vision-fixhub/court-01/f21bfd4928dde015ff1b620d308bc75381c4802cd5e068bd1a344f097575abc5.md
new file mode 100644
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@@ -0,0 +1,376 @@
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 1 of 12
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-
+JANE DOE NO. 2
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO COMPEL PLAINTIFF, JANE DOE NO.
+2, TO RESPOND TO DEFENDANT'S FIRST REQUEST TO PRODUCE & TO
+OVERRULE OBJECTIONS, & FOR AN AWARD OF DEFENDANT'S
+REASONABLE EXPENSES
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order compelling Plaintiff, JANE DOE No. 2 To respond to
+specified production requests and to overrule her objections asserted in Plaintiff's
+Responses To Defendant's First Request To Produce, dated January 26, 2009.
+Defendant further seeks an award of his reasonable expenses, including expenses,
+associated with the making of this motion. Rule 37, Fed.R.Civ.P. (2008); Local Gen.
+Rules 7.1 and 26.1 H (S.D. Fla. 2008). In support of his motion, Defendant states:
+Introduction
+Prior to the filing of this motion, counsel for Defendant and counsel for Plaintiff
+corresponded with each other and were able to resolve some of the discovery issues
+related to Defendant's First Request to Produce and Plaintiff's Response thereto. By
+letter, dated March 3, 2009, the Plaintiff agreed to withdraw her "General Objections"
+set forth in her response. As well, issues as to production request no. 14 are presently
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 2 of 12
+Page No. 2
+resolved. This motion addresses those requests on which the parties were unable to
+come to an agreement.
+Also, Defendant has filed simultaneously with this motion a Motion To Compel
+directed to certain of Plaintiff's Answers to Defendant's First Set of Interrogatories, also
+dated January 26, 2009, and which addresses identical discovery issues. Both motions
+should be determined at the same time.
+Motion To Compel Responses to Nos. 1, 10, 11, 17, & 18
+Production Request No. 1
+1.
+Individual and/or joint income tax returns and supporting documentation
+including W-2 and 1099 forms for 2002-2007 and, as well as all records or
+documentation relative to the Plaintiff's earnings for the current year.
+Response:
+Plaintiff objects to this request as overbroad, unduly burdensome, and not reasonably
+calculated to lead to the discovery of admissible evidence. Without waiving this
+objection, copy of Plaintiff's 2006 and 2007 1040 forms are attached.
+Legal Argument Supporting Entitlement to Discovery Sought in No. 1
+Plaintiff does not make a relevancy objection, but instead claims that the request
+is "not reasonably calculated to lead to the discovery of admissible evidence." Plaintiff
+also claims that the request is "overbroad" and "unduly burdensome," but fails to make
+any showing whatsoever how the request is overbroad or unduly burdensome as
+required under Rule 26(c) and Local Gen. Rule 26.1 H (S.D. Fla. (2008). On its face,
+the six year time period of 2002-2007 for Plaintiff's tax return's and supporting
+documentation is reasonable. Plaintiff's Second Amended Complaint alleges that the
+alleged sexual abuse and exploitation of her by Defendant occurred in "in 2004-2005."
+2d Am. Complaint, 18. (Plaintiff did produce copies of her 2006 and 2007 1040 forms,
+but nothing else.)
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 3 of 12
+Page No. 3
+Also, such information is both relevant and reasonably calculated to lead
+to the discovery of admissible evidence. It is well settled that relevant information is
+discoverable, even if not admissible at trial, so long as the discovery is reasonably
+calculated to lead to the discovery of admissible evidence. Rule 26(b)(1), Fed.R.Civ.P.;
+Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla. 2007).
+Discoverability of such information is governed by Rule 26, Fed.R.Civ.P., pursuant to
+which the scope of discovery is broad. Donahay, supra, at 686, and cases cited therein.
+"Parties may obtain discovery regarding any matter, not privileged, which is relevant to
+the claims or defense of any party involved in the pending action." Id.
+Plaintiff's tax returns, along with the requested supporting documentation, for the
+six year period are relevant to Plaintiff's damages claims detailed below herein. Such
+information would show Plaintiffs employment and earning history, as well as provide
+evidence as to how Plaintiff has been able to function in her daily life before, during and
+after the alleged incident. Was she self-sufficient? Was she able to get out of bed each
+morning and support herself? What type of job did she hold? One's ability to earn a
+living and be self-supporting has not only a financial component, but also an
+emotional/psychological/mental component.
+In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I
+for "Sexual Assault and Battery," Count II for "Intentional Infliction of Emotional
+Distress," and in Count Ill for "Coercion and Enticement to Sexual Activity in Violation of
+18 U.S.C.A. §2422," and seeks damages pursuant to 18 U.S.C. §2255(a). (Plaintiff
+alleges diversity of citizenship as a basis for this Court's jurisdiction. 2d Am. Complaint,
+15). Counts I and Il are brought pursuant to state law.
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 4 of 12
+Page No. 4
+In her complaint, Plaintiff alleges that "she has suffered and will continue to suffer
+severe and permanent traumatic injuries, including mental, psychological and emotional
+damages," and "severe mental anguish and pain." In her answers to interrogatories
+nos. 9 and 10, Plaintiff further states that:
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation, anxiety, low self-esteem, feelings of guilt, self-blame,
+distrustfulness, burdened often by sadness and depression, suicidal thoughts,
+difficulty trusting others (particularly men), irritability, anger, feeling helpless and
+powerless, escapism through excessive partying, lack of confidence, loss of
+innocence. (Interrog. No. 9).
+... she seeks damages arising from her psychological and emotional
+injuries. These damages include pain and suffering, costs of psychological care
+and treatment, and loss of earning capacity.... (Interrog. No. 10).
+As discussed above, the tax returns, and supporting documentation, will provide
+direct evidence as to Plaintiff's claimed damages, not only her loss of earning capacity
+claim, but also her emotional/psychological/mental health type damages. The time
+period will allow Defendant to compare how Plaintiff was doing in her life prior to, during,
+and after the alleged incident. Accordingly, Plaintiff's objection is required to be
+overruled, and Defendant is entitled to the documents requested for each of the years
+2002-2007.
+Production Requests Nos. 10, 11, 17, & 18
+10.
+All photographs, movies, dvds, and videotapes in which you performed
+sexual acts or simulated sexual acts.
+11.
+All photographs, movies, dvds, and videotapes in which you performed
+sexual acts or simulated sexual acts in exchange for money or other consideration.
+All documents reflecting the names and addresses of other individuals
+with whom you have had sexual activity from January 1, 2000 - December 31, 2005.
+with whom you have had exel acing the om an any , rests ought venicer s
+2008.
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 5 of 12
+Page No. 5
+Plaintiff asserted the identical answer to each of the above stated interrogatories:
+Response:
+Plaintiff objects to this request as harassing and not reasonably calculated to lead to
+discovery of admissible evidence.
+More over, this interrogatory [sic] is outrageous,
+offensive and is apparently posed for the purpose of intimidating the Plaintiff. Any
+evidence that could conceivably be obtained through this request would not be
+admissible under Fed.R.Evid. 412. Without waiving this objection, none to Plaintiff's
+knowledge.
+Legal Argument Supporting Entitlement to Discovery Sought in 10, 11, 17, & 18
+Plaintiff does not make a relevancy objection, but instead claims that the
+requests are "not reasonably calculated to lead to the discovery of admissible
+evidence," claiming that such "evidence ... would not be admissible under Fed.R.Evid.
+412." Plaintiff further claims, without making any showing in her answer and without
+moving for a protective order in accordance with Rule 26(c) and Local Gen. Rule 26.1 H
+(S.D. Fla. 2008), that the interrogatory is "harassing,' "outrageous, offensive and is
+apparently posed for the purpose of intimidating Plaintiff." See Defendant's Motion to
+Compel directed to Plaintiff's Answers to Defendant's First Set of Interrogatories,
+addressing identical discovery issues. Both Defendant's interrogatories and production
+requests seek information regarding Plaintiff's sexual conduct and history; Plaintiff
+raised the same objections.
+In each of her responses, Plaintiff also states that - "Without waiving this
+objection, none to Plaintiff's knowledge." Plaintiff's response is evasive - either the
+requested items exist or do not exist.
+• Defendant is entitled to a better response
+specifically indicating whether the items requested in each of the production requests
+nos. 10, 11, 17, and 18 - (1) exist or do not exist; (2) are in the possession or control of
+Plaintiff or some other person that Plaintiff is able to identify; and (3) why Plaintiff
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 6 of 12
+Page No. 6
+qualifies her answer of "none" with the phrase "to Plaintiff's knowledge." (Did such
+items exist and Plaintiff destroyed or deleted them?)
+As to the relevance of the information sought, it is well settled that relevant
+information is discoverable, even if not admissible at trial, so long as the discovery is
+reasonably calculated to lead to the discovery of admissible evidence. Rule 26(b)(1),
+Fed.R.Civ.P.; Donahay v. Palm Beach Tours & trans., Inc., 242 F.R.D. 685 (S.D. Fla.
+2007). Contrary to Plaintiff's assertion, Rule 412 does not automatically result in a
+determination that such sexual history and sexual activity/behavior information is never
+admissible. In fact, written into the Rule are the procedures to follow in determining
+when such information is admissible at trial. The Advisory Committee Notes to Rule
+412, Fed.R.Evid, makes clear that the procedures to determine admissibility of an
+alleged victim's/plaintiff's sexual conduct or activity in civil cases does not apply to
+discovery of such information. Rather, discoverability of such information is governed
+by Rule 26, Fed.R.Civ.P., pursuant to which the scope of discovery is broad. Donahay,
+supra, at 686, and cases cited therein. "Parties may obtain discovery regarding any
+matter, not privileged, which is relevant to the claims or defense of any party involved in
+the pending action." Id.
+Rule 412, entitled "Sex Offense Cases; Relevance of Alleged Victim's Past
+Sexual Behavior or Alleged Sexual Predisposition," provides in relevant part -
+(a) Evidence generally inadmissible.--The following evidence is not admissible
+in any civil
+proceeding involving alleged sexual misconduct except as
+provided in subdivisions (b) and (c):
+(1) Evidence offered to prove that any alleged victim engaged in other sexual
+behavior.
+(2) Evidence offered to prove any alleged victim's sexual predisposition.
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 7 of 12
+Page No. 7
+(b) Exceptions.—
+(2) In a civil case, evidence offered to prove the sexual behavior or sexual
+predisposition of any alleged victim is admissible if it is otherwise admissible
+under these rules and its probative value substantially outweighs the danger of
+harm to any victim and of unfair prejudice to any party. Evidence of an alleged
+victim's reputation is admissible only if it has been placed in controversy by the
+alleged victim.
+(c) Procedure to determine admissibility.-
+(1) A party intending to offer evidence under subdivision (b) must—
+(A) file a written motion at least 14 days before trial specifically describing
+the evidence and stating the purpose for which it is offered unless the court, for
+good cause requires a different time for filing or permits filing during trial; and
+(B) serve the motion on all parties and notify the alleged victim or, when
+appropriate, the alleged victim's guardian or representative.
+(2) Before admitting evidence under this rule the court must conduct a
+nearing in camera and afford the victim and parties a right to attend and be
+heard. The motion, related papers, and the record of the hearing must be
+sealed and remain under seal unless the court orders otherwise.
+In confirming that Rule 412 does not control the discoverability of such
+information, the Advisory Committee Notes (1994 Amendments) state -
+The procedures set forth in subdivision (c) do not apply to discovery of a
+victim's past sexual conduct or predisposition in civil cases, which will be
+continued to be governed by Fed. R. Civ. P. 26. In order not to undermine the
+rationale of Rule 412, however, courts should enter appropriate orders pursuant
+to Fed. R. Civ. P. 26 (c) to protect the victim against unwarranted inquiries and
+to ensure confidentiality. Courts should presumptively issue protective orders
+the evidence sought to be discovered would be relevant under the facts
+through discovery. In an action for sexual harassment, for instance, while
+some evidence of the alleged victim's sexual behavior and/or predisposition in
+the workplace may perhaps be relevant, non-work place conduct will usually be
+irrelevant. Cf.
+v. McGregor Electronic Industries, Inc.., 989 F.2d 959, 962-
+63 (8th Cir. 1993) (posing for a nude magazine outside work hours is irrelevant
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 8 of 12
+Page No. 8
+to issue of unwelcomeness of sexual advances at work). Confidentiality
+orders should be presumptively granted as well.
+(Emphasis added).
+In accordance with Rule 412 and Rule 26, the discovery sought regarding any
+photos, movies, dvds, and videotapes as described in requests nos. 10 and 11, and
+Plaintiff's sexual activity with males, as described in nos. 17 and 18, including whether
+she received any compensation or consideration therefore, are all relevant to Plaintiff's
+damages claims and the type of injury she claims she has suffered. Defendant has no
+other means of obtaining such information and obtaining such information through
+Plaintiff will better protect the confidentiality until the Court can make a determination in
+accordance with the procedures under Rule 412(c) whether such information will be
+admissible at trial. See Rule 412(c) quoted above. Defendant will agree to an order
+keeping the confidentiality of the information obtained through discovery.
+The evidence sought is relevant based on the facts and theories of this action.
+In her Second Amended Complaint, Plaintiff attempts to allege claims in Count I for
+"Sexual Assault and Battery," Count Il for "Intentional Infliction of Emotional Distress,"
+and in Count Ill for "Coercion and Enticement to Sexual Activity in Violation of 18
+U.S.C.A. §2422," and seeks damages pursuant to 18 U.S.C. §2255(a). (Plaintiff alleges
+diversity of citizenship as a basis for this Court's jurisdiction. 2d Am. Complaint, 15).
+Counts I and Il are brought pursuant to state law.
+In her complaint, Plaintiff alleges that "she has suffered and will continue to suffer
+severe and permanent traumatic injuries, including mental, psychological and emotional
+damages," and "severe mental anguish and pain." In her answers to interrogatories
+nos. 9 and 10, dated January 26, 2009, Plaintiff further states that:
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 9 of 12
+Page No. 9
+Plaintiff has suffered severe psychological and emotional injuries, including
+without limitation, anxiety, low self-esteem, feelings of guilt, self-blame,
+distrustfulness, burdened often by sadness and depression, suicidal thoughts,
+difficulty trusting others (particularly men), irritability, anger, feeling helpless and
+powerless, escapism through excessive partying, lack of confidence, loss of
+innocence. (Interrog. No. 9).
+... she seeks damages arising from her psychological and emotional injuries.
+These damages include pain and suffering, costs of psychological care and
+treatment, and loss of earning capacity. ... (Interrog. No. 10).
+Plaintiff also alleges that
+), Epstein's assistant" was a part of "Epstein's
+plan and scheme (which) reflected a particular pattern and method" in the alleged
+recruiting of girl's to come to EPSTEIN's Palm Beach mansion and give him "massages"
+in exchange for money. 2^d Am. Complaint, 1111-12. According to the complaint
+allegations - "Upon information and belief Epstein has a sexual preference and
+obsession for underage minor girls." 178.
+" would "bring the girl up a flight
+of stairs to a bedroom that contained a massage table ...." The girl would be alone with
+EPSTEIN. EPSTEIN would lie naked on the massage table, and direct the girl to
+remove her clothes." "Epstein would then perform one or more lewd, lascivious and
+sexual acts, including masturbation and touching the girl's vagina." 2^d Am. Complaint,
+111. Plaintiff alleges that "in 2004-2005," she, "then approximately 16 years old, fell into
+Epstein's trap and became one of his victims." 78. Plaintiff alleges that Epstein
+exposed himself to her and "sexually assaulted" her. 112 Plaintiff further alleges that
+"Epstein committed willful acts of child sexual abuse" on her, which resulted in "mental
+or sexual injury," and "caused or likely to cause Jane Doe's mental or emotional health
+to be significantly impaired." 2d Am. Complaint, 125.
+The items sought are clearly relevant to the injuries and damages claimed by
+Plaintiff. The nature of her claimed injuries and damages are such that Defendant is
+
+
+Case 9:08-cV-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 10 of 12
+Page No. 10
+entitled to evidence which would show the nature of her relationship with males,
+whether she has suffered other acts of sexual misconduct, including exploitation and
+abuse, as alleged in her complaint, whether she suffered injury and damages as a result
+of the other claimed sexual misconduct with males, and whether she has willingly or not
+willingly engaged in sexual activity that has been photographed, or filmed by means of
+movie, dvd or videotapes. See United States v. Bear Stops, 997 F.2d 451 (8" Cir.
+1993)(Defendant charged with sexual abuse of six year old boy was entitled to
+admission of evidence relating to victim's sexual assault by 3 older boys to establish
+alternative explanation for why victim exhibited behavioral manifestations of sexually
+abused child.).
+In further support of Defendant's motion, a copy of Balas v. Ruzzo, 703 So.2d
+1076 (Fla. 5'" DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), is attached hereto as
+Exhibit A as it is on point to the discovery issues in this action, and the relevancy and
+discoverability of Plaintiff's history of sexual activity and any payment, therefore. See
+interrogatories 8, 22 and 30 propounded in the Balas case and footnote 1 herein. '
+Additionally and significantly, in other pending state court civil actions against Defendant
+EPSTEIN attempting to assert similar claims and damages, the Circuit Court Judges
+have already ruled that such information is discoverable as it is relevant to the damages
+claims of Plaintiff. See Composite Exhibits B and C hereto. Composite Exhibit B
+are the Orders, dated February 23, 2009, entered in the case of A.C. v. Epstein, and
+" In Balas y. Ruzzo, supra, the Plaintiffs alleged a multicount complaint including claims
+and offensive touching of petitioners' bodies; false imprisonment for physically confining
+the petitioners against their will; invasion of privacy; and intentional infliction of
+emotional distress.
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 11 of 12
+Page No. 11
+Case No. 502008CA025129 MB Al, 15" Judicial Circuit, In and For Palm Beach
+County, State of Florida, which granted Defendant's motion to compel therein directed
+to discovery identical to interrogatory no. 18 above, and to requests for production nos.
+17 and 18 addressed below herein. (In the A.C. case, the Plaintiff answered without
+objection interrogatories identical to nos. 19, 20, and 21 herein.) Composite Exhibit C
+is a portion the transcript from a March 3, 2009 hearing on Defendant's motion to
+compel discovery in the case of Jane Doe II v. Epstein, and
+Case No.
+502008CA020614 MB AF, 15" Judicial Circuit Court, In and For Palm Beach County,
+State of Florida. Again, the Circuit Court Judge determined that the information sought
+is relevant to the issue of damages and, thus, discoverable.
+WHEREFORE, Defendant requests that this Court enter an order granting
+Defendant's motion to compel, overruling Plaintiff's objections, and compelling Plaintiff
+be to produce the items sought and/or to better respond to the requests as specified
+above. Defendant further requests that this Court award his attorney's fees and costs,
+associated with this motion, in accordance with Rule 37, Fed.R.Civ.P., and applicable
+Local Rules.
+Rule 7.1 Certification
+I hereby certify that counsel for the respective parties communicated by letters in
+a good faith effort to resolve the discovery issues prior to the filing of this motion to
+compel. Some of the issues were resolved.
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+
+
+Case 9:08-cv-80119-KAM Document 67 Entered on FLSD Docket 04/02/2009 Page 12 of 12
+Page No. 12
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record jdentified on the following Service List in the
+manner specified by CM/ECF on this day of April, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+By: .
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.con
+MICHAEL J. PIKE, ESQ
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
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+ABRUZZO
+THE CIRCUIT COURT & COMPTROLLER
+PALM BEACH COUNTY
+INVOICE
+Circuit Civil Division
+PO Box 4667
+West Palm Beach, FL 33402
+P: (561) 355-2986 | F: (561) 355-4643
+MIM REACH COUNT
+DATE: 04/17/2024
+TO: STEPHEN ARTHUR MENDELSOHN mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+FLService@gtlaw.com
+FROM: BRENT ROBBINS
+APPELLATE DIVISION
+Circuit Court Case Numbers: 50-2019-CA-014681-XXXX-MB
+OPY
+District Court Case Number: 4D2024-0681
+A Notice of Appeal was received for filing in the above referenced action on
+March 14, 2024. Please be advised, however, that payment for Preparation of
+the Record on Appeal in the amount of $357.00 is required pursuant to F.S.
+28.24(2).
+Please forward your payment of $357.00 payable to: Clerk & Comptroller
+Palm Beach County, to my attention at the following address:
+_ABRUZZO, Clerk of the Circuit Court & Comptroller Palm Beach County
+Post Office Box 4667
+West Palm Beach, FL 33402
+The invoice fee can be paid by credit card online via Paylt Express page which
+can be accessed at the link below. Please note that there is a process fee
+attached to this service.
+https://pay-payitgov.com/clerkpbc-courts or QR code below:
+FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK.04/17/2024 03:01:19 PM
+
+
+CLERK OF
+ABRUZZO
+HE CIRCOIT COURT & COMPTROLLER
+PALM BEACH COUNTY
+Circuit Civil Division
+PO Box 4667
+West Palm Beach, FL 33402
+P: (561) 355-2986 | F: (561) 355-4643
+MIM REACH COUNT
+No further action will be taken on this Appeal until payment is received.
+Sincerely.
+THE CIRC
+OF
+ABRUZZO
+SETONLAN
+Clerk of the Circuit Court & Comptroller
+By:
+Bent their
+Robbins, Brent T as Deputy Clerk
+NOT A CER
+FILED: PALM BEACH COUNTY, FLI
+ABRUZZO, CLERK.04/17/2024 03:01:19 PM
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+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 1 of 20
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D. KAHN, in
+their capacities as the executors of the Estate of
+Jeffrey E. Epstein,
+Defendants.
+Case No. 19 Civ. 8673 (KPF) (DCF)
+MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANTS' MOTION TO
+DISMISS
+Roberta A. Kaplan, Esq.
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Telephone: (212) 763-0883
+Facsimile: (212) 564-0883
+Attorneys for Plaintiff
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 2 of 20
+PRELIMINARY STATEMENT
+For decades, Jeffrey Epstein used his vast wealth to sustain a massive enterprise for the
+sexual abuse of young girls and to evade justice for his heinous crimes. But even the richest and
+most powerful men cannot treat the law as a restaurant menu, picking and choosing among its
+provisions to suit their interests. Although he owned properties all over the world, Jeffrey
+Epstein chose the United States Virgin Islands as his domicile, establishing an island retreat there
+where he could sexually abuse children in secret. He secured his enormous wealth in a byzantine
+network of corporations, limited liability companies, trusts, and other entities established under
+Virgin Islands law. And, in August 2019, two days before he committed suicide in a federal jail,
+Epstein executed a Will that expressly provides for his estate to be probated in the Virgin
+Islands. Despite Epstein's decision to subject his Estate to Virgin Islands probate law, the
+Executors now ask this Court to give them the benefit of a provision of New York probate law
+that would exempt them from paying punitive damages for Epstein's heinous crimes. But that is
+not how it works.
+This Court should deny Defendants" motion to dismiss Plaintiff's claim for punitive
+damages.' First, under New York choice-of-law rules, the Court must endeavor to achieve
+"justice, fairness, and the best practical result" by giving controlling effect to the law of the
+jurisdiction with the "greatest concern with the specific issue raised in the litigation."
+V.
+Philip Morris Inc., 124 F. Supp. 2d 46, 55 (E.D.N.Y. 2000). The circumstances of this case are
+as shocking as they are unique: Jeffrey Epstein, who chose to organize his estate under the laws
+Defendants' motion is properly denominated a motion to strike under Federal Rule of Civil Procedure
+12(f). (Dkt. 36.) Defendants' motion does not seek dismissal of any of Plaintiff's four causes of action. Instead, it
+merely seeks to excise Plaintiff's demand for punitive damages. Such a motion is better characterized as a Rule 12(f)
+motion to strike. See, e.g., Rapay v. Chernov, No. 16 Civ. 4910, 2017 WL 892372, at *1, 8 (S.D.N.Y. Mar. 6, 2017);
+Com-Tech Assocs. v. Comput. Assocs. Int'l, Inc., 753 F. Supp. 1078, 1093 (E.D.N.Y. 1990) (denying Rule 12(f)
+motion to strike punitive damages).
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 3 of 20
+of the Virgin Islands, committed suicide just as he became aware of the full scope of civil and
+criminal claims against him. See infra at 5-6. The pending motion now presents the question of
+whether his Estate should be liable for a punitive damages verdict that would have clearly been
+available against him if he were still alive. The Virgin Islands has a strong interest in applying
+its own law to its domiciliaries and in ensuring that an individual who chose to probate his estate
+under Virgin Islands law is subject to that law's burdens along with its benefits. New York, on
+the other hand, has no conceivable interest in applying its ban on punitive damages —which
+reflects a policy decision to protect innocent heirs from suffering for the wrongs of the
+decedent—to a non-domiciled estate in a case where there are no "innocent heirs" and where the
+decedent purposefully evaded liability of all kinds for his heinous acts by taking his own life.
+The most just, fair, and practical result is to apply Virgin Islands estates law to this question.
+Second, contrary to Defendants' arguments (Dkt. 4-6), Virgin Islands common law does
+permit punitive damages against Epstein's Estate. This is made especially clear by the fact that
+the Government of the Virgin Islands is currently seeking punitive damages against Epstein's
+Estate in a pending lawsuit. See infra at 7. Any reasonable analysis of the factors that this Court
+must consider in assessing questions of Virgin Islands common law leads to the same
+conclusion. Permitting punitive damages against Epstein's Estate clearly represents the
+"soundest rule" for the Virgin Islands, where punitive damages are viewed as a mechanism to
+punish wrongdoers and deter others from engaging in similar misconduct, and where the
+Attorney General of the Virgin Islands herself likewise seeks punitive damages against the
+Estate. See id. Indeed, given these facts and circumstances, it is impossible to conceive of a case
+where the need for deterrence is greater.
+2
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 4 of 20
+STATEMENT OF FACTS
+Decedent Jeffrey Epstein was a prolific and notorious pedophile who subjected dozens, if
+not hundreds, of young girls to sexual and psychological abuse. Compl. 1 1. He was also one of
+the wealthiest individuals in the United States. Id. 9 17. While the total scope of his assets
+remains unknown, his estate has a current estimated value of at least $600 million, Ex. 1 91 10-
+11, and he is believed to have owned, among other properties, a private island in the U.S. Virgin
+Islands; the largest private home in Manhattan; a 7,500 acre ranch in New Mexico; a mansion in
+Palm Beach, Florida; and an apartment in Paris. Id. 9 17. Epstein leveraged this prodigious
+wealth to create a vast enterprise for the sexual exploitation and abuse of children, whether on
+his private island in the U.S. Virgin Islands, or at his homes in New York City or Palm Beach.
+Id. " 18. For decades, he perpetrated these heinous acts without legal consequence, which he
+accomplished by targeting the most vulnerable victims he could find: young girls from
+impoverished backgrounds who would silently suffer his abuse in exchange for money they
+desperately needed. Id. 111 1, 22. Plaintiff Jane Doe in this case was one of these girls.
+A. Epstein's Abuse of Doe
+Doe met Epstein when she was fourteen years old, in or around 2002. Id. 1 3. For the
+next three years, Epstein repeatedly abused and exploited her. Id. He regularly forced Doe to
+give him massages while she was completely naked, and during these massages, he touched
+Doe's breasts with his hands, lips and tongue. Id. 9 35. Over time, the abuse worsened. He
+touched Doe's vagina with his fingers and forcefully and painfully penetrated her. Id. | 38. He
+made Doe watch while he masturbated and forced her to help him masturbate. Id. 1 33, 39. He
+even recruited other adults to abuse Doe: on one occasion, Epstein and an adult woman sexually
+In support of this memorandum, Plaintiffs submit the Declaration of Roberta A. Kaplan ("Kaplan
+Declaration"), which collects other supporting exhibits referred to herein as "Ex. ".
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 5 of 20
+abused Doe together. Id. 9|40. Epstein gave Doe cash at each of these encounters, money that
+she desperately needed to support her sister, who suffered from a serious medical condition, and
+her mother, who was unable to financially sustain their family. Id. 9| 22-24. Epstein's relentless
+abuse persisted until Doe was seventeen years old, when she finally managed to slip his grasp.
+Id. 154.
+Doe suffered serious and foreseeable consequences as a result of Epstein's sexual abuse
+during her formative years. She dropped out of high school and, as a result, has been forced to
+take on dangerous and degrading work to make ends meet. Id. Ml 41, 55. More than fifteen years
+after Epstein's abuse ended, Doe still suffers from extreme anxiety and depression. Id. 1 56.
+She has been diagnosed with Post-Traumatic Stress Disorder, which causes her to endure
+disruptive flashbacks to Epstein's abuse, forcing her to live through some of the worst moments
+of her life over and over again. Id. 9 57. She suffers from debilitating panic attacks and has
+difficulty sleeping and eating. Id. 911 56-57. The continuing effects of Epstein's sexual abuse
+make the basic and essential tasks of Doe's daily life-going to work, parenting her young
+daughter, and caring for her ailing mother-nearly impossible. Id. 911 57-60.
+But while Doe suffered and struggled to survive, Epstein flourished. Before his death,
+Epstein was believed to be one of the wealthiest people in the United States, and he owned vast
+estates around the world. Id. | 17. He used this incredible wealth to facilitate his sexual abuse of
+young girls. Id. 9 17. He employed people to find children for him to abuse. He used that staff
+to schedule appointments for girls to visit him in his many homes, so that he could abuse them.
+He used that staff to maintain contact with girls he liked, so that he could summon them for more
+abuse at his whim. And he used that money to pay the children he abused, buying their silence
+along with their young bodies. Id. 9| 32, 47.
+4
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 6 of 20
+B. The 2008 Non-Prosecution Agreement
+Despite the size and reach of his pedophilic enterprise, Epstein avoided criminal and civil
+consequences for his heinous conduct for most of his life. In 2008, his flagrantly illegal
+activities caught the attention of law enforcement, and he was investigated for sexually abusing
+minors. Id. 1|20. But, somehow, Epstein still managed to avoid facing any meaningful
+consequences: for his years-long scheme of sexually abusing and exploiting children, Epstein
+was allowed to plead guilty to two counts of solicitation of prostitution under Florida state law
+and entered into a non-prosecution agreement with the United States Attorney's Office for the
+Southern District of Florida. Id. 9| 20. He was "incarcerated" for a year in a local jail, during
+which time he was afforded extraordinary privileges, including being allowed to leave the jail
+twelve hours per day, six days per week. Id.
+C. Epstein's Will, Suicide, and Evasion of Liability
+In 2019, Epstein finally seemed poised to face real consequences for sexually abusing
+Doe and countless other girls. In July 2019, he was indicted by the United States Attorney's
+Office for the Southern District of New York on serious sex trafficking charges. Id. 9| 62. For
+Doe in particular, who was identified as "Minor Victim-|" in the indictment, it was extremely
+significant that Epstein would, at last, be criminally prosecuted for what he did to her. But on
+August 10, 2019, before he could be tried for his crimes, Jeffrey Epstein committed suicide in a
+federal jail in Manhattan. Id. 4 63
+Two days before he took his own life, on August 8, 2019, Epstein amended his estate
+plan, executing a Will while in federal custody that identifies him as a domiciliary of the Virgin
+Islands and that names Defendants, Darren Indyke and Richard Kahn, as the executors of his
+estate. Id. 9| 65; Ex. 2. The Will identified Mark Epstein, his brother, as his heir, but directed the
+5
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 7 of 20
+executors to give all of his property, after paying his debts, to the then-acting Trustees of his
+"1953 Trust," thereby effectively transferring all of his property and money to "The 1953 Trust."
+Id. | 66; see also Ex. 2. Defendants Indyke and Kahn are also the Trustees of the 1953 Trust.
+Compl. 167. On August 15, 2019, Defendants filed Epstein's Will with the Probate Division of
+the Superior Court of the Virgin Islands. Id. 9 64.
+Epstein's suicide took place as he faced significant potential civil liability in addition to
+the pending criminal charges against him. Indeed, before Epstein's suicide, one of his victims
+filed an application for pre-action discovery in New York state court.. See
+v. Epstein et
+al., No. 156728/2019 (Sup. Ct., New York Cty., Doc No. I). Further, six months earlier, on
+February 14, 2019, New York passed the Child Victim's Act, N.Y. C.P.L.R. § 214-g, which
+provided that starting on August 14, 2019 (just days after Epstein's suicide), the civil claims of
+child sexual abuse victims would be revived for a one-year period, regardless of any previously
+applicable statutes of limitations. Consequently, before Epstein's suicide, it would have been
+obvious to him—given the scope of his crimes and number of his victims that he would likely
+soon face a flood of civil litigation and considerable liability.
+D. The Present Action against the Estate
+On September 18, 2019, Doe filed this diversity action against the Epstein Estate for
+sexual assault, sexual battery, intentional infliction of emotional distress, and negligent infliction
+of emotional distress. She seeks actual, compensatory, statutory, consequential, and punitive
+damages for her substantial injuries. Id. 9|88.
+On January 15, 2020, Defendants filed the instant motion to dismiss Plaintiff's claim for
+punitive damages, arguing that they should be exempt from paying punitive damages by virtue of
+a provision of the New York State Estates, Powers, and Trust Law ("NY EPTL"). Defendants
+6
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 8 of 20
+argue that New York State law should apply to the question of whether Plaintiff may pursue
+punitive damages against an estate, and that, in the alternative, Virgin Islands law, even if it were
+to be applied, does not provide for punitive damages against an estate. (Dkt. 46.) On the same
+day Defendants filed their motion, the Attorney General of the United States Virgin Islands filed
+an action in Virgin Islands Superior Court against the Epstein Estate (the "Virgin Islands
+Action") alleging myriad violations of the Virgin Islands' Criminally Influenced and Corrupt
+Organizations Act ("CICO") and other Virgin Islands laws. See Ex. 1. Of most relevance here,
+the Virgin Islands Action seeks punitive damages against Epstein's Estate under Virgin Islands
+law because "economic damages are simply not sufficient" given Epstein's "egregious,
+persistent, and injurious" conduct and "money, assets, and power." Id. at 1 276.
+ARGUMENT
+Defendants' argument is as simple as it is incorrect. They ask this Court to find that
+because the acts giving rise to Plaintiff's cause of action occurred entirely in New York, "New
+York law ….. applies to the issue of punitive damages." (Dkt. 47 at 3.) But Defendants ignore
+that New York courts long ago eschewed this mechanical application of the "place of the injury"
+rule in favor of the "more just, fair, and practical result that may best be achieved by giving
+controlling effect to the law of the jurisdiction which has the greatest concern with, or interest in,
+the specific issue raised in the litigation." Neumeier v. Kuehner, 31 N.Y.2d 121, 127 (1972).
+This motion raises one specific issue: whether Plaintiff, a victim of child sexual abuse by
+Jeffrey Epstein, may seek punitive damages against his Estate. Just as Epstein once used his vast
+wealth to evade responsibility for his horrific crimes, the Executors of his Estate now seek to use
+his death— and a New York estate law proscribing punitive damages against a dead tortfeasor's
+estate as a tool to protect that wealth from the valid civil claims of Plaintiff and Epstein's many
+7
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 9 of 20
+other victims. But only two days before his death, Epstein chose to make himself a domiciliary
+of the Virgin Islands, and he chose to avail himself of the benefits of its estate law by probating
+his estate there, giving the Virgin Islands a significant interest in applying its estate law to this
+question. On the other hand, no interest of the State of New York is furthered by applying its
+punitive damages exemption for estates to the non-domiciled estate of a tortfeasor who
+committed suicide with knowledge of the scope of the potential civil claims pending against him.
+Accordingly, the Virgin Islands has the greatest concern with the specific issue raised in this
+litigation, and its estate law, which permits punitive damages against an Estate, must govern.
+PLAINTIFF IS AUTHORIZED TO SEEK PUNITIVE DAMAGES AGAINST THE
+ESTATE UNDER U.S. VIRGIN ISLANDS LAW
+A.
+USVI Law Governs Whether Punitive Damages Are Available in This Action
+It is well settled that a federal court must look to the choice-of-law rules of the forum
+state in resolving conflicts of law. See Klaxon Co. v. Stentor Elec. Mfg. Co., 313 U.S. 487, 496
+(1941); Int'l Bus. Machs. Corp. v. Liberty Mut. Ins. Co., 363 F.3d 137, 143 (2d Cir. 2004).
+When a choice-of-law issue arises in a tort action, New York courts apply a flexible "interest
+analysis," which "eschew[s] mechanical rules in favor of a practical analysis of the interests of
+the various states involved."
+124 F. Supp. 2d at 54. New York's interest analysis aims to
+achieve "li]ustice, fairness, and the best practical result ... by giving controlling effect to the law
+of the jurisdiction which, because of its relationship or contact with the occurrence or the parties,
+has the greatest concern with the specific issue raised in the litigation." Id. at 55 (quoting
+Babcock v. L
+,, 12 N.Y.2d 473, 481 (1963));
+_H. Lee Equity Fund V, L.P. v. Mayer
+& Maw LLP, 612 F. Supp. 2d 267, 283-84 (S.D.N.Y. 2009).
+Typically, to determine which jurisdiction has the prevailing interest in a conflict-of-law
+question arising in a tort action, New York courts consider whether the purpose of the rule in
+8
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 10 of 20
+question is to regulate conduct or to allocate loss. Padula v. Lilarn Props. Corp., 84 N. Y.2d 519,
+521-22 (1994). Here, Defendants argue in conclusory fashion that because punitive damages are
+"conduct-regulating," the law of the place of the tort controls. (Dkt. 47 at 3.) This argument
+vastly oversimplifies the analysis called for under New York law. It is settled that punitive
+damages rules are conduct-regulating: however, that means only that "as a general matter ... the
+law of the place of the tort governs unless there is good reason not to apply the rule of lex loci
+delecti." Nat'l Jewish Democratic Council v. Adelson, No. 18 Civ. 8787 (JPO), 2019 WL
+4805719 at *6 (S.D.N.Y. Sept. 30, 2019) (emphasis added). In other words, the fact that punitive
+damages are conduct-regulating does not end the inquiry: "for punitive damages in particular ...
+a court must consider the object or purpose of the wrongdoing to be punished and give
+controlling weight to the law of the jurisdiction with the strongest interest in the resolution of the
+particular issue presented." Id. (internal quotations and citations omitted).
+The unique circumstances presented here clearly give this Court "good reason" not to
+apply New York estate law. This case raises the question not of whether punitive damages
+should be available to punish perpetrators of sexual assault in New York (they are), but of
+whether the estate of a deceased tortfeasor should be obligated to pay such claims. The Virgin
+Islands clearly has the strongest interest in applying its law to resolve this issue. First,
+Defendants are domiciliaries of the Virgin Islands, which counsels in favor of applying Virgin
+Islands estate law. Id. at *5-6 (that defendant is a domiciliary of Nevada "points in favor" of
+applying Nevada punitive damages law); see also, e.g., Stevens v. Shields, 499 N.Y.S.2d 351,
+353 (Sup. Ct., Ulster Cty. 1986) (applying Florida law to a New York accident because
+9
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 11 of 20
+defendant's "liability as a parent of a negligent minor driver is cast upon her by virtue of her
+choice to be a domiciliary of Florida" regardless of where the minor drove.) 3
+Second, the Virgin Islands has an overwhelming interest in preventing Epstein and his
+Estate from availing themselves of the benefits, but not the burdens, of Virgin Islands estate law.
+Epstein, who owned residences and property all over the world, chose to identify the U.S.
+Virgins Islands as his domicile and to probate his Estate in that jurisdiction. This was a
+deliberate choice to avail himself of the benefits of Virgin Islands probate law, which he
+presumably viewed as advantageous to his estate. Compl. 19 11, 65; see also Ex. 1 989 ("Two
+days before his death, Epstein amended the Trust and his Last Will and Testament. Upon
+information and belief, he did so as part of a pattern and ongoing effort to conceal and shield his
+assets from potential recovery by claimants.").* As a result, the Virgin Islands has a significant
+interest in applying all the provisions of its probate law to questions regarding Epstein's estate.
+Adelson, 2019 WL 4805719, at *6; see also, e.g.,
+v. Boy Scouts of Am., Inc., 65 N.Y.2d
+189, 201 (1985) (deferring to state's interest in forcing litigant to accept "the burdens as well as
+the benefits" of that state's tort rules). Neither Epstein nor his Estate could have reasonably
+expected a different result. See Stevens, 499 N.Y.S.2d at 353; see also
+v. Car Rentals, Inc.,
+29 A.D.3d 205, 212 (2d Dep't 2006) (noting the relevance in choice-of-law analysis of the
+"parties' expectations" about what law would govern).
+The Virgin Islands' interest in applying its estate law to Jeffrey Epstein's estate is only enhanced by the
+profoundly detrimental impact on the U.S. Virgin Islands of the decedent's connection with that jurisdiction. See
+Ex. 1 11 15, 68-69 (Epstein formed a "deliberately complex web of Virgin Islands corporations, limited liability
+companies, foundations, and other entities... through which he carried out and concealed his criminal conduct,"
+"used the Virgin Islands' land, resources, people, and laws for [his enterprise's] illicit purposes," and "subjected the
+Virgin Islands to public portrayals as a hiding place for human trafficking and sex crimes.")
+The Court may take judicial notice of this pleading, even at the motion to dismiss stage, as it is in the public
+record. See 2002
+R. Buchalter Alaska Tr. v. Philadelphia Fin. Life Assur: Co., 96 F. Supp. 3d 182, 206
+(S.D.N.Y. 2015).
+10
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 12 of 20
+Together, these two factors counsel incontrovertibly in favor of applying Virgin Islands
+estate law. Indeed, when courts in this State and in this District have declined to apply the rule
+of lex loci delecti to the availability of punitive damages, they have done so in deference to
+precisely these interests. In Adelson, for example, the defendant filed a defamation suit under
+Nevada law in the Southern District of New York, and plaintiffs sought punitive damages for a
+violation of Nevada's anti-SLAPP statute. The district court concluded that Nevada law, rather
+than New York law, should determine the availability of punitive damages for two reasons: first,
+because the defendant was a domiciliary of Nevada, which "points in favor of applying Nevada
+law," and second, because the defendant had attempted to avail himself of the benefits of Nevada
+defamation law, giving Nevada "a corresponding interest" in ensuring the application of its
+defamation law's punitive damages provision. Adelson, 2019 WL 4805719, at *6; see also
+Beasock v. Dioguardi Enters., Inc., 100 A.D.2d 50, 52-54 (4th Dep't 1984) (concluding that the
+law of two of defendants' respective domiciles should govern whether punitive damages were
+available in a survivorship action).
+In contrast to the Virgin Islands' strong interest in applying its estate law to this question,
+New York's interest in applying its own estate law is extremely attenuated. The Epstein Estate is
+not domiciled in New York and it is not being probated here. Moreover, even if New York has a
+policy interest in prohibiting the levying of punitive damages against an estate, that interest is
+clearly not furthered in the unique circumstances presented here.
+Generally, the prohibition on punitive damages against an estate exists because a dead
+tortfeasor cannot be punished by the judicial system and so courts or legislatures have made a
+policy decision to protect the decedent's "innocent heirs" from being punished for the wrongs
+they did not personally commit. See, e.g., Flaum v. Birnbaum, 177 A.D.2d 170 177 (4th Dep't
+11
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 13 of 20
+1992); Lohr v. Byrd, 522 So. 2d 845, 846-47 (Fla. 1988). There can be no question that this
+policy interest is irrelevant where, as here, Epstein had no "innocent" heirs who will be unjustly
+punished by the levying of punitive damages against his Estate. Epstein reportedly had no
+children, and his Will identifies only his brother, Mark Epstein, who is widely reported to have
+considerable financial resources of his own, as his heir. Ex. 2 at 3.S Importantly, Mark Epstein
+has been on notice of his brother's heinous crimes for—at a minimum—more than a decade,
+since Jeffrey Epstein's guilty plea in Florida in 2008. Compl. 9| 20. What Jeffrey Epstein does
+leave behind is countless women whose lives have been deeply impacted by the sexual,
+emotional, and psychological abuse he wrought on them. Prohibiting punitive damages in this
+case would not protect innocent heirs; it would punish traumatized victims deserving of adequate
+compensation.
+More importantly, where a tortfeasor commits suicide to avoid imposition of punitive
+damages, considerations of fairness no longer counsel in favor of protecting his estate. Here,
+Jeffrey Epstein committed suicide while he was awaiting trial on serious federal sex trafficking
+charges. A high-profile civil case had already been initiated against him, see supra at 7, and,
+since Epstein was well aware of the full scope of his own misconduct, he was equally aware of
+the potential scope of his civil liability. His suicide appears designed, at least in part, to avoid
+the civil and criminal consequences of his heinous acts. In this unique situation, New York has
+no conceivable policy interest in permitting Epstein's continued efforts to evade justice. Indeed,
+some courts have commented that they would decline to apply a bar on punitive damages against
+an estate should they ever encounter the extreme and unusual circumstances presented here. See
+Jeffrey Epstein's Will, which is attached as Exhibit 1 to the Kaplan Declaration, is both incorporated by
+reference and integral to the Complaint in this action. See
+v. Time Warner, Inc., 282 F.3d 147, 152-53
+(2d Cir. 2002).
+12
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 14 of 20
+Crabtree ex rel. Kemp v. Estate of Crabtree, 837 N.E.2d 135, 139 (Ind. 2005) (Indiana Supreme
+Court may decline to apply its normal bar on punitive damages "where a tortfeasor seems to have
+considered his own death as an escape from punitive damages incident to some intentional tort"
+by committing suicide); see also Estate of Mayer v. Lax, Inc., 998 N.E.2d 238, 259 (Ind. Ct.
+App. 2013) (noting a "possible exception" to the rule proscribing punitive damages against an
+estate "if the tortfeasor committed suicide to attempt to escape such damages").
+B. l
+Virgin Islands Law Permits Recovery of Punitive Damages against an Estate
+Defendants argue that even if Virgin Islands law applies to the question here, this Court
+should conclude that Virgin Islands law does not permit the recovery of punitive damages
+against an estate. That is plainly incorrect. In deciding how to apply Virgin Islands' common
+law, courts must consider what are known as the Banks factors: "(1) whether any Virgin Islands
+courts have previously adopted a particular rule; (2) the position taken by a majority of courts
+from other jurisdictions; and (3) which approach represents the soundest rule for the Virgin
+Islands." Gov't of the V.I. v.
+60 V.I. 597, 600 (V.I. 2014)). An accurate assessment of
+these three factors makes clear that punitive damages are available in this case.
+The third factor—which approach represents the soundest rule for the Virgin Islands—is
+the "most important" of the three. Antilles Sch., Inc. v. Lembach, 64 V.I. 400, 428 (V.I. 2016).
+Here, the "soundest rule" for the Virgin Islands is to permit punitive damages against Jeffrey
+Epstein's Estate. But this Court need not decide this question in a vacuum: the Virgin Islands
+Attorney General has articulated this very position on behalf of the Virgin Islands in her pending
+lawsuit against the Estate. The Attorney General states that, under Virgin Islands common law,
+the purpose of punitive damages is "to punish the defendant for outrageous conduct that is
+reckless or intentional and to deter others from engaging in such conduct in the future," and she
+13
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 15 of 20
+further notes that "[p]unitive damages are especially important in the case of persons or
+companies that have money, assets, and power that mere fines, penalties, and economic damages
+are simply not sufficient." Ex. 1 91 274, 276. The Attorney General states that Epstein engaged
+in "intentional conduct so egregious, persistent, and injurious that it shocks the conscience and
+offends a civilized society" and that therefore, the Government of the U.S. Virgin Islands seeks
+punitive damages against the Estate. Id. 11l 275, 277.
+The Attorney General's view that punitive damages are available against Epstein's Estate
+should dispose of the question for this Court, but any reasonable independent analysis of the
+interests of the Virgin Islands leads to the same conclusion. Punitive damages in the Virgin
+Islands are designed to both punish wrongdoers and to deter others from engaging in similar
+conduct. See, e.g., Guardian Ins. Co. v. Gumbs, No. ST-15-CV-195, 2016 WL 9525609, at *10
+(V.I. Super. Aug. 22, 2016). It is hard to imagine a case where the need to deter others from
+engaging in similar misconduct is more significant than here. This is particularly true in the
+Virgin Islands, where Epstein not only abused countless girls and young women, but also
+"abused [the] privileges of residency," specifically choosing the Virgin Islands as the location for
+his heinous crimes because of its seclusion and isolation, and thereby contributing to a public
+perception that the Virgin Islands is "a hiding place for human trafficking and sex crimes." Ex.
+1 11 63, 69. The fact that Epstein would have been subject to punitive damages claims if he had
+not taken his own life-—and that he committed suicide knowing he was subject to such claims —
+further militates in favor of permitting punitive damages against his Estate: as discussed above,
+even in a jurisdiction where punitive damages against a deceased tortfeasor's estate are normally
+barred, courts have acknowledged that such egregious conduct by a tortfeasor may warrant a
+departure from that rule. See Crabtree, 837 N.E.2d at 139; Estate of Mayer, 998 N.E.2d at 259.
+14
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 16 of 20
+Defendants fail to offer any countervailing reason why their rule would be sounder for
+the Virgin Islands—or, indeed, any reason at all. Instead, they assert only that Virgin Islands
+courts "have favorably applied Restatement Section 908 to questions regarding punitive
+damages." (Dkt. 47 at 6.) But none of the seven cases cited by Defendants address the question
+of whether punitive damages are available against an estate, nor do they even consider the
+Restatement's position on that question. That courts have favorably cited portions of the
+Restatement in considering other questions regarding punitive damages does not suffice to show
+that the Restatement's position on punitive damages against an estate is the rule in the Virgin
+Islands. Regardless, the Restatement is nothing more than non-binding secondary authority.
+See, e.g., Gov't of Virgin Islands v.
+1. No. Sup. Ct. Civ. No. 2013-0095, 2014 WL 702639,
+at *1 (V.I. Feb. 24, 2014) (noting that the Supreme Court of the Virgin Islands has instructed that
+courts should not "mechanistically follow[] the Restatements" in determining common law); see
+also Thorn v. Stephens, 646 N.Y.S.2d 597, 599 n.2 (Sup. Ct., Westchester Cty. 1995)
+("The Restatement of Law is not binding."); Bellino v. JPMorgan Chase Bank, N.A., No. 14-CV-
+3139 (NSR), 2015 WL 4006242, at *5 (S.D.N.Y. June 29, 2015)
+("IT]he Restatement is not binding on the Court."); Alain Ellis Living Tr. v. Harvey D. Ellis
+Living Tr., 308 Kan. 1040, 1055-58 (2018) (noting the Restatement's view on whether punitive
+damages are available against an Estate and declining to follow it).
+Nor do the other Banks factors provide any reason to adopt Defendants' view that
+punitive damages should not be permitted against Epstein's Estate. Regarding factor one, which
+asks whether Virgin Islands courts have previously adopted a particular rule, Plaintiff is not
+aware of any Virgin Islands decision on the question of whether to permit punitive damages
+against an estate, nor have Defendants cited any such case. The fact that, as Defendants point
+15
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 17 of 20
+out, a Virgin Islands court has recited the Restatement rule on punitive damages against an estate
+while deciding a different question of law does not come close to showing that a court has
+considered and decided the precise question at issue here." (Dkt. 47 at 5.) And Defendants
+exaggerate the degree to which Banks factor two—which weighs the position taken by the
+majority of other jurisdictions favors prohibiting punitive damages against an estate. While it
+is true that this is the majority view, a considerable minority has reached the opposite conclusion:
+ten' of the approximately 35 jurisdictions to address the question have decided that punitive
+damages should be allowed against an Estate, including for reasons that are especially salient
+here: adequate compensation for victims, punishment of wrongdoers, deterrence of other future
+wrongdoers, and social condemnation of uniquely abhorrent behavior. Haralson v. Fisher
+Surveying, Inc., 201 Ariz. 1, 3-4 (2001) (en banc); see also generally Zitter, 30 A.L.R.4th 707;
+Barry A. Lindahl, 2 Modern Tort Law: Liability and Litigation § 20:24 (2d ed., June 2019
+Update). And notably, most of the jurisdictions adopting the majority rule have-unlike the
+Virgin Islands—passed a statute codifying a prohibition on punitive damages against an estate.
+See Alain Ellis Living Tr., 308 Kan. at 1046 ("[A]t least 14 of the cases adopting the position that
+an injured party cannot recover punitive damages from the estate of a tortfeasor—the majority
+rule-reached that conclusion because their respective state legislatures had passed a statute
+stating that position.").
+The cases Defendants cite do not address the question at issue here-namely, whether punitive damages are
+available against an Estate. Instead, both cases address the separate question of whether punitive damages are
+available in survival actions for wrongful death. See
+v. Dowson Holding Co., No. CIV. 2008-2, 2009 WL
+723134, at *5-6 (D.V.I. Mar. 17, 2009), and Booth v. Bowen, No. CIV. 2006-217, 2008 WL 220067, at *5 (D.V.I.
+Jan. 10, 2008). Defendants themselves point out this distinction, conceding that these cases address the "the inverse
+of the issue here" (Dkt. 47 at 5), rather than the actual question before the Court.
+Arizona, Delaware, Indiana, Ohio, Pennsylvania, South Carolina, Alabama, Montana, New Hampshire, and
+West Virginia all permit punitive damages against a decedent's Estate. See Jay M. Zitter, Claim for punitive
+damages in tort action as surviving death of tortfeasor or person wronged, 30 A.L.R.4th 707 (1984 cd., 2019
+16
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 18 of 20
+Thus, the most important Banks factor weighs strongly in favor of allowing punitive
+damages, and the other two factors are indeterminate. The Banks analysis therefore clearly
+counsels in favor of adopting the same position taken by the USVI Attorney General: that under
+USVI law, punitive damages are available against Jeffrey Epstein's Estate.®
+I1.
+PLAINTIFF HAS A STATUTORY RIGHT TO SUE THE ESTATE UNDER
+EITHER U.S. VIRGIN ISLANDS OR NEW YORK LAW.
+Defendants' argument that Plaintiff is "only permitted to bring her causes of action
+against the Estate" under NY EPTL § 11-3.2(a)(1), and therefore is subject to that statute's
+prohibition on punitive damages, is a red herring. (Dkt. No. 47 at 3.) First, the Complaint does
+not identify NY EPLT Section 11-3.2(a)(1), which provides that a cause of action for personal
+injury survives the death of the person liable, as the source of law enabling Plaintiff to bring her
+causes of action against the Estate. Virgin Islands law also expressly provides that personal
+injury claims against a tortfeasor survive his or her death. 15 V.I.C. § 601. Thus, whether
+Virgin Islands law or New York law applies to the Plaintiff's ability to sue the Estate of her
+deceased abuser, it is indisputable that Plaintiff' is authorized to bring this action under the law of
+either jurisdiction. 15 V.I.C. § 601; N.Y. EPTL § 11-3.2(a)(1).
+Second, even if NY EPTL were the authorizing source of law, Defendants' argument that
+Plaintiff's punitive damages claim must therefore also be governed by the NY EPTL is
+In the alternative, Plaintiff respectfully requests that the Court certify the question whether punitive
+damages are available against Epstein's Estate in the U.S. Virgin Islands to the Supreme Court of the Virgin Islands.
+Rule 38 of the Virgin Islands Rules of Appellate Procedure provides that the Supreme "Court may answer a question
+certified by a court of the United States "if there is involved in any proceeding before the certifying court a question
+of law which may be determinative of the cause then pending in the certifying court.'"
+V.
+1. S. Ct. Civ. No.
+2018-0036, 2018 WL 1888496, at *1 (V.I. Apr. 18, 2018) (emphasis in original) (quoting V.I. R. APP. P. 38(a)).
+In the Second Circuit, questions about the availability of punitive damages are appropriate for certification
+to a jurisdiction's highest court, assuming that jurisdiction provides for such a procedure. See, e.g., Riordan v.
+Nationwide Mut. Fire Ins. Co., 977 F.2d 47, 56-57 (2d Cir. 1992) (certifying to New York Court of Appeals
+question of whether provision of state insurance law preempts common law right to punitive damages standard),
+certified question withdrawn after settlement, 984 F.2d 69, 70 (2d Cir. 1993)). The U.S. Virgin Islands" certification
+procedure thus provides an alternative means by which the Court could, in its discretion, resolve this question of
+Virgin Islands' law.
+17
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 19 of 20
+incompatible with New York's established choice-of-law rules, as the Court recognized at its last
+conference in this case on December 11, 2019 (Tr. at 17:23-18:4; 26:13-17). It is well-settled
+that "in a single action[,] different states may have different degrees of interests with respect to
+different operative facts and elements of a claim or defense." 2002|
+R. Buchalter
+Alaska Tr., 96 F. Supp. 3d at 200. This doctrine, known as dépeçage, expressly permits different
+jurisdictions' laws to govern the availability of punitive damages and the availability of a cause
+of action. Adelson, 2019 WL 4805719, at *6 ("Although it is clear that the measure of
+compensatory damages is determined by the same law under which the cause of action arises,
+this is not necessarily true with regard to [punitive] damages."); Fed. Hous. Fin. Agency v. Ally
+Fin. Inc., No. 11 Civ. 7010 (DLC), 2012 WL 6616061, at *5 (S.D.N.Y. Dec. 19, 2012) ("The
+New York Court of Appeals has recognized that the doctrine [of dépeçage] may sometimes
+require that a plaintiff's demand for punitive damages be analyzed under the law of a state other
+than the one under whose law the cause of action arises."); In re Air Crash Near Clarence Ctr.,
+New York, 798 F. Supp. 2d 481, 488 n.6 (W.D.N.Y. 2011) (*[T]he possibility that one state's law
+could apply to punitive damages and another's to compensatory damages is permitted under the
+doctrine of depecage.").?
+In short, it is indisputable that Plaintiff is authorized to bring this action under Virgin
+Islands law or New York law, regardless of which jurisdiction's law authorizes Plaintiff to sue
+the Estate of her deceased abuser. 15 V.I.C. § 601; N.Y. EPTL § 11-3.2(a)(1). And even if New
+9
+Defendants ask this Court to interpret a single line of dicta from Blissett v. Eisensmidt, 940 F. Supp. 449,
+457 (N.D.N.Y. 1996) as supporting a position that would be entirely inconsistent with this well-settled principle of
+law. Blissett has no bearing on this case there, the claims arose under Section 1983, and different principles of law
+govern choice of law questions in federal civil rights cases. Id. In any event, whatever the Blissett court meant
+when it stated that it would be "incongruous" to allow the plaintiff in Blissett to rely on one part of the NY EPTL
+and not another, it cannot possibly have the meaning Defendants give it. As the foregoing case law on dépeçage
+demonstrates, it is indisputable that a cause of action and a claim for punitive damages can be governed by two
+different bodies of law.
+18
+
+
+Case 1:19-cv-08673-KPF-DCF Document 51 Filed 02/14/20 Page 20 of 20
+York law is the source authorizing Plaintiff's cause of action, well-established choice-of-law
+principles make clear that a different jurisdiction's law may apply to the question of punitive
+damages.
+CONCLUSION
+For the foregoing reasons, the Court should deny Defendants' motion to dismiss
+Plaintiff's claim for punitive damages.
+Dated: New York, New York
+February 14, 2020
+By:
+Rodn
+Roberta A. Kaplan
+Kate L. Doniger
+Alexandra Conlon
+Louis W. Fisher
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Tel: (212) 763-0883
+Fax: (212) 564-0883
+rkaplan@kaplanhecker.com
+Counsel for Plaintiff Jane Doe
+19
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@@ -0,0 +1,58 @@
+Case 9:08-cv-80381-KAM Document 32 Entered on FLSD Docket 07/25/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER VACATING ENTRY OF DEFAULT
+THIS CAUSE comes before the Court sua sponte.
+On July 16, 2008, the Court issued an Order (DE 26) denying without prejudice
+Defendant's motion to set aside the Clerk's entry of default.' The Court reasoned that Defendant
+had let more than twenty days elapse after service of process before attempting to respond to the
+Complaint. As the Court explained, under New York law, personal service may be made on an
+individual by
+delivering the summons within the state to a person of suitable age and
+effected within twenty days of each other.
+'The Court presumes familiarity with the contents of this Order.
+
+
+Case 9:08-cv-80381-KAM Document 32 Entered on FLSD Docket 07/25/2008 Page 2 of 3
+N.Y. C.P.L.R. § 308(2) (McK inney 2008) (emphasis added). Based on the Court's reading of the
+Affidavit of Service (DE 4), it appeared that Plaintiff's process server had mailed a copy of the
+Summons and Complaint to Defendant on May 12, 2008. What appeared to be a distortion in the
+document due to its electronic upload into the Court's CM/ECF system, however, was apparently
+a line striking the language from the affidavit regarding the mailing of the Summons and
+Complaint. (See DE 30.) Plaintiff brought this error to the Court's attention after the Court
+issued its Order to Show Cause.
+Because the Summons and Complaint were not mailed to Defendant, service was not
+accomplished under New York law.? See N.Y. C.P.L.R. § 308(2). Further, as the Court has
+already explained, service was not effective under either the Federal Rules of Civil Procedure or
+Florida law.? Accordingly, it is ORDERED AND ADJUDGED as follows:
+1. The Court's Order (DE 26) of July 16, 2008, is VACATED.
+2. Defendant's Motion to Set Aside Default (DE 9) is GRANTED. The Clerk's Entry of
+Default (DE 6) is VACATED.
+3. Plaintiff shall have forty-five (45) days from the date of entry of this Order to serve a copy of
+the Summons and Complaint on Defendant. Failure to serve Defendant within forty-five days
+shall result in dismissal of the above-styled action pursuant to Fed. R. Civ. P. 4(m).
+"Interestingly, Plaintiff did not bring this issue to the Court's attention in its response
+Defendant in accordance with ev Yok law, hatingst cal che serough he mail.
+"The Court again declines to allow discovery on whether Richard Barnett resides at
+Jefendant's New York home. Mr. Barnett submitted an affidavit sworn under penalty of perjur
+hat he does not reside at that address. (See Barnett Aff.) Plaintiff has not submitted an
+evidence to suggest that Mr. Barnett is not credible, so allowing discovery on this point would
+simply be a waste of resources.
+2
+
+
+Case 9:08-cv-80381-KAM Document 32 Entered on FLSD Docket 07/25/2008 Page 3 of 3
+DONE AND ORDERED in
+Florida, this 25" day of July, 2008.
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+3
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diff --git a/vision-fixhub/court-01/f2a506d37a36e09ff1fcbcd32a9d359459be53a91496ded406c14f8fb73d1617.md b/vision-fixhub/court-01/f2a506d37a36e09ff1fcbcd32a9d359459be53a91496ded406c14f8fb73d1617.md
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index 0000000000000000000000000000000000000000..59cc891f969a65ca577df75d4556d25275fb72ae
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@@ -0,0 +1,546 @@
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+CASE NO: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 2 of 16
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+2
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 3 of 16
+CASE NO: 08-CV-80811-MARRA/
+C.M.A.,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/_
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/
+Plaintiff
+VS.
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 4 of 16
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/|
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTFF'S FIRST
+REQUEST FOR PRODUCTION
+Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant,
+Jeffrey Epstein, to answer her first request for production or, in the alternative, to prove
+that his invocation of his Fifth Amendment privilege is proper. Jane Doe also requests
+production of a privilege log.
+Jane Doe has propounded 16 requests for production, including such
+straightforward requests as requests for production of:
+4
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 5 of 16
+Request No. 1: Copies of all telephone records;
+Request No. 2: Photos of the inside of your home located at 358 El Brillo Way,
+Palm Beach, Florida, that depict the rooms) where massages took place (including
+massage table).
+Request No. 10: Correspondence between Epstein and federal prosecutors;
+Request No. 12: Personal tax returns;
+Request No. 13: Photocopies of Epstein's passport;
+Request No. 14: A statement of net worth; and
+Request No. 16: Medical records.
+In response to each and every one of these requests, Epstein has given the
+following response (with only minor variations here and there):
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+This Court should order Epstein to provide all of the requested information or, in
+the alternative, prove that his Fifth Amendment invocations are valid. It is for the court,
+not the claimant, to determine whether the hazard of incrimination is justified. United
+States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a
+particularized inquiry, deciding, in connection with each specific area that the
+5
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 6 of 16
+questioning party wishes to explore, whether or not the privilege is well-founded." Id.
+Typically this is done in an in camera proceeding wherein the person asserting the
+privilege is given the opportunity "to substantiate his claims of the privilege and the
+district court is able to consider the questions asked and the documents requested by
+the summons." Id.
+Here Epstein has made boilerplate invocation of the Fifth Amendment to each
+and every request propounded by Jane Doe, including for example the request for
+correspondence with federal prosecutors and for production of federal tax returns. This
+obviously is not a request with Fifth Amendment implications, as the information has
+already been fully disclosed to the Government.
+For all these reasons, the Court should compel Epstein to answer the requests or
+provide a particularized justification for his Fifth Amendment invocation with regard to
+each request.
+Epstein's "cut and paste" response to the request for production also blatantly
+disregards the requirements for invoking privilege under the Court's local rules. Local
+rule 26.1.G very specifically requires the preparation of a privilege log with respect to all
+documents and oral communications (among other things) that are withheld on the
+basis of privilege. Epstein has failed to prepare such a log, making it impossible for
+Jane Doe to effectively challenge his generic assertions. Indeed, with respect to a few
+requests, Epstein has stated: "Further, the request may include information subject to
+work product or an attorney-client privilege." Of course, the whole purpose of forcing a
+defendant to prepare a privilege log is to force the defendant to decide whether or not
+6
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 7 of 16
+information is privileged. An assertion that something "may" be privileged is obviously
+woefully deficient. The Local Rules do not permit this tactic, and Epstein should be (at a
+minimum) promptly required to produce a privilege log.
+For all these reasons, the Court should compel Epstein to provide a privilege log
+and to answer the interrogatories or provide a particularized justification for his Fifth
+Amendment invocation with regard to each request.
+It should be noted that (with minor exceptions) the only grounds on which Epstein
+can refuse to answer the request for production is proof of a valid Fifth Amendment
+privilege. This the only objection Epstein has asserted (with minor exceptions). As a
+result, any other objections to production are deemed waived. See Local Rule
+26.1G.3.(a) ("Any ground [for an objection] not stated in an objection within the time
+provided by the Federal Rules of Civil Procedure, or any extensions thereof, shall be
+waived.").
+SPECIFIC REQUESTS FOR PRODUCTION
+For the convenience of the court - and in compliance with Local Rule 26.1 H
+(party filing motion to compel shall list specific requests in succession) - Jane Doe's
+requests for production and Epstein's objections are as follows:
+Request No. 1: Copies of all telephone records in your or your attorney's possession
+from 2002 through 2005 that in any way relate to you (including all phone lines owned
+by you or that were used to contact girls for the purposes of scheduling massages for
+you.)
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+7
+
+
+Case 9:08-cV-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 8 of 16
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 2: All massage appointment books, diaries, computer calendars or
+scheduling entities, scheduling books or any other writing or correspondence that
+contains the names of any of the girls that were called, contacted, scheduled or who
+otherwise went to your home located at 358 El Brillo Way, Palm Beach, Florida, for the
+purpose of giving you a massage.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 3: Any and all documentation in your possession that contains Plaintiff's
+name or that refers to Plaintiff, directly or indirectly, (includes e-mails, letters, message
+pads, diaries, appointment books, computer print outs).
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Filth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 4: Any and all photos, videos, downloaded digital prints or any other visual
+depiction of Plaintiff, or of any other known or suspected minor females introduced to
+you, directly or indirectly, by Plaintiff.
+8
+
+
+Case 9:08-cV-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 9 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 5: Photos of the inside or your home located at 358 El Brillo Way, Palm
+Beach, Florida, that depict the rooms) where the massages too place (including
+massage table).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 6: Any and all documentation of cancelled checks or evidence of payment
+to Plaintiff of any kind and for any reason whatsoever.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time | cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+9
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 10 of 16
+Request No. 7: All discovery information obtained by you or your attorneys as a result
+of the exchange of discovery in the State criminal case against you or the Federal
+investigation against you.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse
+inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible to the terms of the deferred prosecution agreement, Federal
+Rule of Evidence 410 and 408, and § 90.410, Fla. Stat.'
+Further, the
+request may including information subject to work product or an attorneyclient privilege.
+Request No. 8: All financial documents evidencing asset transfers from 2005 to present
+for you personally or any company or corporation owned by you.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+"Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+the non-prosecution agreement, nothing in that agreement bars discovery of information relevant to this
+10
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 11 of 16
+Request No. 9: Any documents or other evidentiary materials provided to local, state,
+or federal law enforcement investigators or local, state or federal prosecutors
+investigating your sexual activities with minors.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution. Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. 2
+Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 10: All correspondence between you and your attorneys and state or
+federal law enforcement or prosecutors (includes, but not limited to, letters to and from
+the States Attorney's office or any agents thereof).
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing
+an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+In addition to and without waiving his constitutional
+privileges, the information
+sought is privileged and confidential, and
+inadmissible pursuant to the terms of the deferred prosecution agreement,
+* Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of plea discussions, but rather for other purposes.
+These materials are also likely to lead to the
+discovery of other admissible evidence.
+To the extent that Epstein relies on the non-prosecution
+agreement, nothing in that agreement bars discovery of information relevant to this lawsuit.
+11
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 12 of 16
+Fed. Rule of Evidence 410 and 408, and § 90.410, Fla. Stat. Further,
+the request may include information subject to work product or an
+attorney-client privilege.
+Request No. 11: Any and all documents reflecting your current net worth.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+Request No. 12: Personal tax returns for all years from 2002 through the present.
+Defendant is asserting his U.S. constitutional privileges. | intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States
+Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 13: A photocopy of your passport, including any supplemental pages
+reflecting travel to locations outside the 50 United States between 2002 and 2008,
+including any documents or records regarding plane tickets, hotel receipts, or
+transportation arrangements.
+" Jane Doe does not intend to use these materials to draw a forbidden inference of guilt from the mere
+fact of correspondence in connection with plea discussions, but rather for other purposes. These
+naterials are also likely to lead to the discovery of other admissible evidence. To the extent that Epstein
+relies on the non-prosecution agreement, nothing in that agreement bars discovery of information relevant
+to this lawsuit.
+12
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 13 of 16
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, 1 assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution. In addition to and without waiving his constitutional
+protections and privileges, the scope of information is so overbroad that it
+seeks information that is neither relevant nor reasonably calculated to lead
+to the discovery of admissible evidence; compiling such information over a
+six year period would be unduly burdensome and time consuming.*
+Request No. 14: A sworn statement of your net worth (including a detailed financial
+statement depicting all current assets and liabilities).
+Defendant is asserting his U.S. constitutional privileges. I intend to respond to all
+relevant questions regarding this lawsuit, however, my attorneys have counseled me
+that at the present time I cannot select authenticate, and produce documents relevant to
+this lawsuit and I must accept this advice or risk losing my Sixth Amendment right to
+effective representation. Accordingly, I assert my federal constitutional rights under the
+Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United States
+Constitution.
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights, would be
+unreasonable, and would therefore violate the Constitution.
+Request No. 15: All financial statements or affidavits produced by you for any reason,
+to any person, company, entity or corporation since 2005.
+Defendant is asserting his U.S. constitutional privileges. 1 intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+* Jane Doe believes that Epstein used overseas travel as a means of obtaining underage girls for sexual
+purposes and for avoiding criminal prosecution for such activities. Also, providing a copy of a passport is
+hardly "burdensome." Also, given the fact that Epstein is likely to have used the services of a travel agent
+or another intermediary, it should not be difficult for him to provide evidence of his overseas travels from
+such intermediaries.
+13
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 14 of 16
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution; overly broad.
+Request No. 16: All medical records of Defendant Epstein from Dr. Stephan Alexander.
+Defendant is asserting his U.S. constitutional privileges. I intend to
+respond to all relevant questions regarding this lawsuit, however, my
+attorneys have counseled me that at the present time I cannot select
+authenticate, and produce documents relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, I assert my tederal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+CONCLUSION
+For all these reasons, the Court should compel Epstein to answer the request for
+production, or provide a particularized justification for his Fifth Amendment invocation
+with regard to each request. Epstein should also be required to provide a privilege log.
+Counsel for Jane Doe have conferred with opposing counsel on the issues raised in this
+motion, and no resolution was possible.
+DATED July 10, 2009
+Respectfully Submitted,
+J.l
+J.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 54207:
+E-mail: bedwards@rra-law.com
+14
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 15 of 16
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 10, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+S/
+J.
+J.
+15
+
+
+Case 9:08-cv-80994-KAM Document 73 Entered on FLSD Docket 07/10/2009 Page 16 of 16
+SERVICE LIST
+Jane Doe V. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+16
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f2a506d37a36e09ff1fcbcd32a9d359459be53a91496ded406c14f8fb73d1617.receipt.json b/vision-fixhub/court-01/f2a506d37a36e09ff1fcbcd32a9d359459be53a91496ded406c14f8fb73d1617.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..16f8f5eba6c21544ecab302d434a26edace54fab
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 18,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
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+}
diff --git a/vision-fixhub/court-01/f2a706777115e2a903439188376071a93e3ffa6728a800f3c69bf13dbfc7202e.md b/vision-fixhub/court-01/f2a706777115e2a903439188376071a93e3ffa6728a800f3c69bf13dbfc7202e.md
new file mode 100644
index 0000000000000000000000000000000000000000..35c6ac0031f3720a0a1616a2599c0f3b6878eef6
--- /dev/null
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@@ -0,0 +1,84 @@
+' Case 9:08-cv-80994-KAM Document 10 Entered on FLSD Docket 11/10/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 6,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S RESPONSE TO
+DEFENDANT'S MOTION TO DISMISS & FOR MORE DEFINITE STATEMENT
+Defendant, JEFFERY EPSTEIN, (EPSTEIN), by and through his undersigned
+attorneys, files his reply to Plaintiffs' Memorandum Of Law In Opposition To Motions To
+Dismiss, dated October 31, 2008, and states:
+Although Plaintiffs, Jane Doe Nos. 2 through 7, are separate and distinct
+persons, in separate and distinct actions, with separate and distinct facts and
+circumstances pertaining to the claims each is attempting to allege, Plaintiffs' counsel
+has filed a broad brush, identical response to Defendant's motions to dismiss and for
+more definite statement which were filed in each of the actions. As pointed out in
+Defendant's previously filed motions, there are factual distinctions in the actions and the
+allegations in Plaintiffs' attempts to assert the claims labeled as Count | - "Sexual
+Assault and Battery," and Count III - "Coercion and Enticement to Sexual Activity In
+Violation of 18 U.S.C. §2422." It is essential that each of the actions and the respective
+complaints filed therein are examined and treated as separate and distinct actions in
+deciding the respective legal issues and positions asserted.
+
+
+'Case 9:08-CV-80994-KAM Document 10 Entered on FLSD Docket 11/10/2008 Page 2 of 3
+Jane Doe No. 6 v. Epstein
+Page 2
+As noted, Defendant's motion is directed to Count I and Ill of the respective
+complaints. Contrary to each Plaintiff's assertion, Defendant does not concede that
+Plaintiff has sufficiently plead the elements required to assert claims in Count I for
+"Sexual Assault and Battery" and in Count III pursuant to 18 U.S.C.§2422, and
+Defendant has not "misconstrued" the pleading standard formulated by the United
+States Supreme Court in Bell Atlantic Corp. v. Twombly, 127 S.Ct. 1955 (2007). In
+discussing Iwombly, the Eleventh Circuit in
+v. Fla. International Univ., 495 F.3d
+1289, 1295 (11" Cir. 2007), noted - "The Supreme Court's most recent formulation of
+the pleading specificity standard is that 'stating such a claim requires a complaint with
+enough factual matter (taken as true) to suggest' the required element." In order to
+sufficiently allege the claim, the complaint is required to identify "facts that are
+suggestive enough to render [the element] plausible."
+495 F.3d at 1296 (quoting
+Twombly, 127 S.Ct. at 1965). As stated in Defendant's motion to dismiss, Plaintiff has
+not met this standard requiring the pleading of facts to suggest the elements of the
+claims she is attempting to assert. In other words, Plaintiff is required to plead facts that
+suggest each element of the claim she is attempting to assert, as opposed to a
+generalized pleading.
+Accordingly, Defendant relies on the legal positions and
+argument in his motion, rather than reargue what has already been stated.
+Finally, the letter attached as an Exhibit to Plaintiff's response is not dispositive of
+the issue of whether the Plaintiff has sufficiently alleged a claim in Count Ill pursuant to
+18 U.S.C. §2422.
+
+
+Case 9:08-CV-80994-KAM Document 10 Entered on FLSD Docket 11/10/2008 Page 3 of 3
+Jane Doe No. 6 v. Epstein
+Page 3
+Wherefore, Defendant requests that this Court grant his motion to dismiss and for
+more definite statement directed to Plaintiff's Complaint.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of recard identified on the following Service List in the
+manner specified by CM/ECF on this (0'day of
+Novender, 2008:
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #6
+Respectfuly submitted,
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/f2a706777115e2a903439188376071a93e3ffa6728a800f3c69bf13dbfc7202e.receipt.json b/vision-fixhub/court-01/f2a706777115e2a903439188376071a93e3ffa6728a800f3c69bf13dbfc7202e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6d93d55a0950b3d62063b830f7cea2b5651dc117
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "output_sha256": "6b4ccdf544101d57967008148348d5b594663df92fa3da6caeebfdc22a467d67",
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+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/f2b1189c8ded8bddd085339a9607d35b20a7872ab6a29cd35b5278fa4b546c6f.md b/vision-fixhub/court-01/f2b1189c8ded8bddd085339a9607d35b20a7872ab6a29cd35b5278fa4b546c6f.md
new file mode 100644
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@@ -0,0 +1,45 @@
+Case 9:08-cv-80381-KAM Document 16 Entered on FLSD Docket 07/07/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRA-JOHNSON
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+NOTICE OF APPEARANCE AS CO-COUNSEL
+NOTICE IS HEREBY GIVEN that the law firm of _
+as co-counsel for Defendant Jeffrey Epstein in these proceedings.
+Tein, P.L. enters its appearance
+Respectfully submitted,
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By: Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+
+
+Case 9:08-cv-80381-KAM Document 16 Entered on FLSD Docket 07/07/2008 Page 2 of 2
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 7, 2008, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day on all counsel of record identified on the following service list via transmission of
+Notices of Electronic Filing generated by CM/ECF.
+Is/ Michael R. Tein
+Michael R. Tein
+SERVICE LIST
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz,
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+Jack A. Goldberger, Esq.
+Address
diff --git a/vision-fixhub/court-01/f2b1189c8ded8bddd085339a9607d35b20a7872ab6a29cd35b5278fa4b546c6f.receipt.json b/vision-fixhub/court-01/f2b1189c8ded8bddd085339a9607d35b20a7872ab6a29cd35b5278fa4b546c6f.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f2c6f77d709c6ec78069a75832fad78573ba71c00f08d57fce72a50edc51efe5.md b/vision-fixhub/court-01/f2c6f77d709c6ec78069a75832fad78573ba71c00f08d57fce72a50edc51efe5.md
new file mode 100644
index 0000000000000000000000000000000000000000..8e7c86aee38cbefdd3e3d8a733d420d64b02bfe0
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@@ -0,0 +1,267 @@
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2.
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFE,
+L, RESPONSE TO THIRD PARTY WITNESS,
+IGOR ZINOVIE'S, MOTION FOR PROTECTIVE ORDER AND INCORPORATED
+MEMORANDUM OF LAW
+Plaintiff,
+_, by and through her undersigned counsel, hereby
+files her Response Third Party Witness, Igor Zinoview's, Motion For Protective Order
+and Incorporated Memorandum of Law (D.E. 402), and in support thereof states as
+follows:
+Third party witness, Igor Zinoview, seeks to have this Court enter an order
+preventing his deposition from going forward at all, or, in the alternative, limiting the
+scope of permissible questioning during same. Mr. Zinoview's deposition is presently
+scheduled to be taken on December 18, 2009.
+Mr. Zinoview has been employed by Defendant, Jeffrey Epstein, as his
+"driver, bodyguard, and trainer" since November of 2005. See Affidavit of Igor Zinoview
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 2 of 8
+(D.E. 402) dated November 9, 2009. Mr. Zinoview argues that his deposition should not
+go forward as scheduled because Defendant Epstein has never discussed nor
+attempted to discuss with him "any facts or information related to any legal matters in
+which he [Jeffrey Epstein] is involved." Id. From Mr. Zinoview's vague assertion springs
+the bold yet erroneous argument that "Mr. Zinoview cannot possibly have any
+knowledge or information that is presently germane to this action."
+3.
+It should initially be noted that a "complete prohibition of a deposition is an
+extraordinary measure which should be resorted to only in rare occasions." Jennings v.
+Family Management, 201 F.R.D. 272 (D.D.C. 2001); See also, Salter v. Upjohn Co.,
+593 F.2d 649, 651 (5" Circ. 1979)(It is very unusual for trial court to prohibit the taking
+of a deposition altogether, and absent extraordinary circumstances, such order would
+likely be in error.); Inv. Properties Intern., Ltd. v. IOS, Ltd., 459 F.2d. 705, 708 (2d Circ.
+1972)("an order to vacate a notice of taking deposition is generally regarded as both
+unusual and unfavorable ... "). Neither Mr. Zinoview's conclusory affidavit nor his
+Motion provide anything even approaching the "extraordinary circumstances" necessary
+to justify the entry of order precluding his deposition from going forward at all.
+4.
+Additionally, Mr. Zinoview's vague assertion that he and Defendant
+Epstein have never discussed any facts or information related to any legal matters that
+Mr. Epstein is involved in does not give rise to requisite "extraordinary circumstances"
+either. Detweiler Bros, Inc. v John Graham and Company, 412 F.Supp. 416 (E.D. Wash,
+1976)(Plaintiff could not properly seek to prohibit defendant from deposing plaintiff's
+employee via a protective order on grounds that employee had no knowledge of matters
+at issue.) See also, 8 Fed. Prac. & Proc. Civ. §2037,
+and
+("A witness
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 3 of 8
+ordinarily cannot escape examination by denying knowledge of any relevant facts, since
+the party seeking to take the deposition is entitled to test the witness's lack of
+knowledge.")
+5.
+The undersigned, as well as counsel for all of the other victims of Jeffrey
+Epstein, are entitled to question and challenge Mr. Zinoview on his purported lack of
+knowledge. Mr. Zinoview and plaintiffs' counsel very well might have a difference of
+opinion on what constitutes "facts and information related to any legal matters" in which
+Defendant Epstein is involved. The victims of Jeffrey Epstein ought not to be forced to
+accept Mr. Zinoview's opinion as to what constitutes "facts and information related to
+any legal matters" involving Jeffrey Epstein. Instead, plaintiffs should be able to explore
+these relevant matters directly with Mr. Zinoview, rather than being forced to rely on his
+twenty seven (27) word claim of lacking any knowledge.
+6.
+Additionally, Mr. Zinoview worked for Defendant Epstein during portions of
+the Palm Beach Police Department's months' long investigation which spanned from
+March 15, 2005 through February 2006 into the illegal sexual contact committed by
+Defendant Epstein against these minor plaintiffs. Accordingly, Mr. Zinoview certainly
+might have direct knowledge about what was going on in and around the Epstein
+residence during the time period in which he was employed by Defendant Epstein as his
+"driver, bodyguard, and trainer" while his employer was being investigated by law
+enforcement. Given the Defendant's voracious invocation of his Fifth Amendment
+privilege, the plaintiffs have consistently been denied the opportunity to seek any
+relevant information directly from Defendant Epstein himself. Rather, plaintiffs have
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 4 of 8
+been forced to build their cases against Mr. Epstein by other discovery methods,
+including deposing his employees who may have relevant information.
+7. Third party witness Igor Zinoview has failed to meet his very high burden
+of establishing "extraordinary circumstances." Mr. Zinoview has failed to demonstrate
+the "good cause" required by Rule 26(c) to protect a person from "annoyance,
+embarrassment, oppression, or undue burden or expense" to overcome the liberal
+scope of permissible discovery. The above proposed lines of inquiry of Mr. Zinoview
+are certainly reasonably calculated to lead to the discovery of admissible evidence.
+Accordingly, to the extent that it seeks to preclude his deposition from going forward at
+all, Mr. Zinoview's Motion should be denied
+Next, Mr. Zinoview also seeks to prevent questions being posed to him
+wherein he is first asked to "assume certain facts about which he has no knowledge,"
+and then be asked about his "opinions about certain facts." First, it remains to be seen
+exactly what facts about which Mr. Zinoview has no knowledge. Second, Mr. Zinoview's
+opinions and beliefs about the factual matters surrounding plaintiffs' claims are relevant
+to exploring any potential bias and prejudice in favor of his employer and against
+Defendant Epstein's victims. For example, if Mr. Zinoview believes that these plaintiffs
+are simply inventing their claims against his employer that they were sexually victimized
+by Defendant Epstein while they were minor children, it very well might impact his
+impartiality as a witness. Third, the undersigned has no present intention of engaging in
+this line of questioning unless the proverbial "door" has been opened by Mr. Zinoview
+first. Lastly, counsel for Mr. Zinoview is certainly free to invoke the privileges afforded to
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 5 of 8
+him by the applicable procedural rules should he feel that his client is being asked
+inappropriate questions during the deposition.
+9.
+In conclusion and for the reasons cited above, Mr. Zinoview's Motion For
+Protective Order should be denied in its entirety.
+WHEREFORE, Plaintiff,
+respectfully requests that
+this Court deny Third Party Igor Zinoview's Motion For Protective Order.
+Respectfully submitted,
+Is/Jack P.
+JACK SCAROLA
+Florida Bar No. 169440
+JACK P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9456
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 6 of 8
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on November 28'h
+, 2009, I electronically filed the
+foregoing document with the Clerk of Court using CM/ECF. I also certify that the
+foregoing document is being served this day on all counsel of record identified below via
+transmission of Notices of Electronic Filing generated by CM/ECF.
+Ls/Jack P.
+Jack Scarola
+Florida Bar No.: 169440
+Jack P.
+Florida Bar No.: 0547808
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9424
+Attorneys for Plaintiff
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 7 of 8
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Brad
+, Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Co related Cases Nos. 08-80069, 08-30119, Paul O. Casell, Bs.
+08-80232, 08-80380, 08-80381, 08-80993,
+Pro Hac Vice
+08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A.
+801-585-6833 Fax
+2290 104 Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+_, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barhart & Shipley,
+P.A.
+08-80469
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+isx@searcylaw.com
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+jph(@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+
+
+Case 9:08-cv-80994-KAM Document 88 Entered on FLSD Docket 11/28/2009 Page 8 of 8
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer I. Kuvin, Esq.
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Ayenue South
+Suite 1400
+West Palm Beach, PL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesg@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/f2c6f77d709c6ec78069a75832fad78573ba71c00f08d57fce72a50edc51efe5.receipt.json b/vision-fixhub/court-01/f2c6f77d709c6ec78069a75832fad78573ba71c00f08d57fce72a50edc51efe5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e5c0391b770b9a4daa2a266cb12938b6619adc5a
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+++ b/vision-fixhub/court-01/f2c6f77d709c6ec78069a75832fad78573ba71c00f08d57fce72a50edc51efe5.receipt.json
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e.md b/vision-fixhub/court-01/f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e.md
new file mode 100644
index 0000000000000000000000000000000000000000..91bf4b8843404f3905f8bc9e67ce4bf5db4eaf52
--- /dev/null
+++ b/vision-fixhub/court-01/f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e.md
@@ -0,0 +1,66 @@
+Case 9:08-cv-80119-KAM Document 39 Entered on FLSD Docket 08/27/2008 Page 1 of 2
+JANE DOE NO. 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-J
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+NOTICE OF APPEARANCE
+Burman, Critton, Luttier & Coleman, LLP file their appearance as co-counsel for
+Defendant, JEFFREY EPSTEIN, in the above-styled matter.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this _27th_ day of August
+_. 2008:
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Michael R. Tein, Esq.
+I Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+305-442-1101
+
+
+Case 9:08-cv-80119-KAM Document 39 Entered on FLSD Docket 08/27/2008 Page 2 of 2
+Jane Doe No. 2 v. Epstein
+Page 2
+Fax: 305 442 6744
+Counsel for Defendant Jeffrey Epstein
+tein@lewistein.com
+Respectfully submitted,
+BURMAN, CRITTON, LUTTIER
+& COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(561) 842-282C
+By:
+Mulao fire
+Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+Co-counsel for Defendant Jeffrey Epstein
+rcrit@bclclaw.com
+mpike@bclclaw.com
diff --git a/vision-fixhub/court-01/f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e.receipt.json b/vision-fixhub/court-01/f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..faa8920fc60aff5c7c6ae07d892fb9ae24f6ce5a
--- /dev/null
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@@ -0,0 +1,14 @@
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+  "doc_id": "f2cece025d65bdad832167ed85928435a414f7c56b38ab3da0f98941b3a4263e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2f4334fe668379bd1493a9905d5730f24b3462e7197b8a4de88559a9714da549",
+  "output_sha256": "b385b3e816aaebf0e92fb95003e27fd55d380aff712da632c4b1a174e0073289",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.md b/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.md
new file mode 100644
index 0000000000000000000000000000000000000000..7c45ee605509f44aa14120f13416b1c40b5c6cd5
--- /dev/null
+++ b/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.md
@@ -0,0 +1,163 @@
+Filing # 107874932 E-Filed 05/22/2020 03:27:48 PM
+IN THE CIRCUIT COURT IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CIRCUIT CIVIL DIVISION: "AG"
+CASE NO.:50-2019-CA-014681-XXXX-MB
+CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner
+VS.
+DAVE ARONBERG,
+SHARON R BOCK,
+Defendant/Respondents.
+THIS MATTER came before this Court and is specially set for hearing before KRISTA
+MARX in Courtroom 10C at the 205 N. Dixie Highway, West Palm Beach, FL 33401, as
+follows:
+DATE OF HEARING:
+June 3, 2020
+TIME OF HEARING:
+10:00 am
+TIME RESERVED:
+30 minutes ^
+MOTION TO BE HEARD: Motion to Dismiss
+Chief Judge Krista Marx is inviting you to a scheduled Zoom meeting.
+Topic: Mot. to Dismiss Hrg 19CA14681 Palm Beach Post v Aronberg, Bock
+Time: Jun 3, 2020 10:00 AM Eastern Time (US and Canada)
+Join Zoom Meeting
+https://z00mus/j97999766656?pwd=bGYIVOcxUjZkWG9NSzBvMWpsU0E3UT09
+Meeting ID: 979 9976 6656
+Password: 232880
+Dial by your location
+877 853 5257 US Toll-free
+888 475 4499 US Toll-free
+Meeting ID: 979 9976 6656
+Password: 232880
+Find your local number: https://zoom.us/w/afmeKARkc
+*No amended pleadings shall be filed without leave of court.
+THIS MATTER HAS BEEN SPECIALLY SET BY COURT ORDER AND
+
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/22/2020 03:27:48 PM
+
+
+CANNOT BE CANCELED OR RESET EXCEPT BY FURTHER ORDER OF THE
+COURT.
+All memo randa and/or case authority must be submitted to the Court and opposing counsel
+at least five (5) business days before the hearing and the transmittal document must designate the
+date and time of the hearing for which they are submitted.
+All cases and legal authorities submitted to the court must be tabbed, with pertinent
+sections highlighted.
+All exhibits must be clearly marked before the hearing is set to begin. Exhibits shall be
+marked by a numbered sticker on the top right-hand corner of the front of each exhibit clearly
+Copies of the cents in and portal and an Exile bit be preit co i Cout No.
+LATER than 48 hours prior to the hearing and must be numbered chronologically.
+If the issue is resolved less than twenty-four (24) hours prior to the hearing (excluding
+weekends), the moving party shall appear for the Zoom hearing at the scheduled time of hearing
+with their proposed order ready to submit via OLS.
+DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida, this 22nd
+day of May, 2020.
+Krista Marx_ Chief Judge
+05/22/2020
+50-2019-CA-014681-XXXX-MB
+Krista Marx
+Chief Judge
+COPIES TO:
+No Address Available
+DOUGLAS A. WYLER
+961687 GATEWAY BLVD
+SUITE 201-1
+FERNANDINA BEACH, FL
+32034
+HAMPTON C. PETERSON
+POST OFFICE BOX 229
+WEST PALM BEACH, FL
+33402
+MICHAEL GRYGIEL
+54 STATE STREET
+6TH FLOOR
+ALBANY, NY 12207
+
+No E-mail Address Available
+doug.wyler@comcast.net
+CLERK_E-
+SERVICE@MYPALMBEACH
+CLERK.COM
+peterson@mypalmbeachclerk.
+com
+GRYGIELM@GTLAW.COM
+
+
+MICHAELJ. GRYGIEL
+NINA D. BOYAJIAN
+No Address Available
+No Address Available
+NINA D. BOYAJIAN
+grygielm@gtlaw.com
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+No E-mail Address Available
+STEPHEN A.
+MENDELSOHN, ESQ
+1840 CENTURY PARK
+EAST
+SUITE 1900
+LOS ANGELES, CA 90067
+5100 TOWN CENTER CIR
+SUITE 400
+BOCA RATON, FL 33486
+mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+INTERPRETERS: It is the responsibility of the party needing an interpreter to bring to
+o urt an interpreter who is certified, language skilled, provisionally approved or who i
+egistered with the Office of State Court Administrator, as required by Rule 2.560 an
+Rule 2.565 of the Florida Rules of Judicial Administration. For further information or
+http://15theircuit.co.palm-beach.fl.us/web/guest/court-interpreters. Persons unable to
+obtain an interpreter may bring someone to assist. The Court shall determine if they are
+qualified to interpret the proceedings.
+INTÉRPRETES: Si una parte litigante necesita un intérprete, es su responsabilidad traer
+consigo al tribunal un intérprete certificado, aprobado provisionalmente, capacitado en
+idiomas, o que este registrado con la Oficina Administrativa del Tribunal Estatal,
+conforme a la Regla 2.560, y la Regla 2.565, de las Reglas Judiciales Administrativas de
+la Florida. Si requiere más información o necesita ayuda para localizar un intérprete, por
+favor visite nuestro sitio web en hıftp://15theircuit.co.palm-beach.fl.us/web/guest/courtinterpreters. Las personas que no puedan obtener un intérprete, pueden traer una
+persona que les pueda asistir. El Juez determinará si la persona está calificada para
+interpretar en dicho procedimiento.
+ENTEPRET: Selon Règleman 2.560 and Règleman 2.565 Administrasyon Jidisyè Florid,
+se responsablite moun ke bezwen entèprèt la ki sipoze mennen yon entèprèt sètifye.
+kalifye, aprouve provizwaman, oswa anrejistre ak Biro Administrasyon Tribinal Leta.
+Pou plis enfomasyon sou asistans lokalize yon entèprèt, tanpri vizite sit Entènèt
+http:/15thcireuit.co.palm-beach.fl.us/web/guest/court-interpreters. Moun ki pa kapab
+iwenn yon entèprèt gendwa mennen yon moun pou ède. Tribinal la va detèmine si moul
+sa a kalifye pou entèprete nan prosedi yo.
+
+
+
+This notice is provided pursuant to Administrative Order No. 2.207
+"If you are a person with a disability who needs any accommodation
+in order to participate in this proceeding, you are entitled, at no cost to
+you, to the provision of certain assistance. Please contact Tammy Anton,
+Americans
+with Disabilities Act Coordinator, Palm Beach County
+Courthouse, 205 North Dixie Highway West Palm Beach, Florida 33401;
+telephone number (561) 355-4380 at least 7 days before your scheduled
+court appearance, or immediately upon receiving this notification if the
+time before the scheduled appearance is less than 7 days; if you are
+hearing or voice impaired, call 711."
+"Si usted
+es
+una persona minusválida que
+necesita algún
+acomodamiento para poder participar en este procedimiento, usted tiene
+derecho, sin tener gastos propios, a que se le provea cierta ayuda. Tenga la
+amabilidad de ponerse en contacto con Tammy Anton, 205 N. Dixie
+Highway, West Palm Beach, Florida 33401; teléfono número (561) 355-
+4380, por lo menos 7 días antes de la cita fijada para su comparecencia en
+los tribunales, o inmediatamente después de recibir esta notificación si el
+tiempo antes de la comparecencia que se ha programado es menos de 7
+días; si usted tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka
+patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye,
+gen pwovizyon pou jwen kèk èd. Tanpri kontakte Tammy Anton,
+kòòdonatè pwogram Lwa pou ameriken ki Enfim yo nan Tribinal Konte
+Palm Beach la ki nan 205 North Dixie Highway, West Palm Beach, Florida
+33401; telefòn li se (561) 355-4380 nan 7 jou anvan dat ou gen randevou
+pou parèt nan tribinal la, oubyen imedyatman apre ou fin resevwa
+bungekeyon en pil o aet po yen påt maete tinal la mens ke 7 jou; st
diff --git a/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.receipt.json b/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e207760ca9aade1b3732e212b7524c0920477268
--- /dev/null
+++ b/vision-fixhub/court-01/f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "f2d88050cd42d07f59147e107110b4d63fb2d2387abdcfaf63ccc5affe18bf87",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "291a72dc97894b0da32d860e80f910b9958205ea53713cea8815f1b521585323",
+  "output_sha256": "0ce35f5ebfde2d1e7212351e9d24a4cad93b7c5caef7861e9e82bb50abee447b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f2dbcef12f5ed6740a69e7456d60f01cce87e2080b2684b85970caa91a5f8cd5.md b/vision-fixhub/court-01/f2dbcef12f5ed6740a69e7456d60f01cce87e2080b2684b85970caa91a5f8cd5.md
new file mode 100644
index 0000000000000000000000000000000000000000..13b316af7b3e9cdadaa3fe32d443fcdb4655fa49
--- /dev/null
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@@ -0,0 +1,93 @@
+Case 9:08-cv-80232-KAM Document 81 Entered on FLSD Docket 05/05/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-|
+JANE DOE NO. 3,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION FOR EXTENSION OF TIME IN WHICH TO FILE REPLY
+TO PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT'S MOTION TO STAY
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+file his Reply to Plaintiff's Response in Opposition to Defendant's Motion to Stay
+Complaint.
+1. On April 23, 2009 Plaintiff filed a Response [DE 74] in Opposition to Defendant's
+Motion to Stay [DE 57]. Defendant's reply would be due on May 5, 2009 (5 days to
+reply excluding weekends + mailing). Defendant is requesting a fifteen (15) day
+extension to May 20, 2009 to reply.
+2. There are several other cases filed with this Court in which Jeffrey Epstein is
+named a Defendant. In those cases, the undersigned has been handling other matters
+associated therewith.
+3. Additionally, Defendant's counsel is in the midst of preparing for a state court
+trial, CARDIOPULMONARY & PRIMARY CARE ASSOC. OF TREASURE COAST, P.A
+V.
+M.D., Case No. 562008CA001726, specially set for trial beginning May 13
+
+
+Case 9:08-cv-80232-KAM Document 81 Entered on FLSD Docket 05/05/2009 Page 2 of 3
+Jane Doe No. 3 v. Epstein
+Page 2
+through 15, 2009). Discovery in that case is ongoing with several depositions set to
+prepare for trial.
+4. The requested extension is fair and reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately reply.
+5. An extension until May 20, 2009, is fair and reasonable under the circumstances.
+The undersigned is in need of the additional time in order to fully and adequately
+prepare a response on behalf of EPSTEIN.
+6. As certified below, counsel for Defendant conferred with counsel by e-mail, and
+Plaintiff's counsel is in agreement with the requested extension.
+WHEREFORE Defendant respectfully requests that this Court enter an order
+granting an extension until May 20, 2009, to file a Reply to Plaintiff's Response in
+Opposition to Defendant's Motion to Stay Complaint.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by e-mail with counsel for the Plaintiff and
+Counsel for Plaintiff is in agreement with the requested extension until May 20, 2009 for
+Defendant to reply to Plaintiff's Response to Defendant's Motion to Stay Complaint.
+Robert D. Critton, Jr. Attorney for
+Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 5th
+day of May. 2009:
+
+
+Case 9:08-cv-80232-KAM Document 81 Entered on FLSD Docket 05/05/2009 Page 3 of 3
+Jane Doe No. 3 v. Epstein
+Page 3
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/f2dbcef12f5ed6740a69e7456d60f01cce87e2080b2684b85970caa91a5f8cd5.receipt.json b/vision-fixhub/court-01/f2dbcef12f5ed6740a69e7456d60f01cce87e2080b2684b85970caa91a5f8cd5.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/f2efbd3517a354b8656da588746ffd259e20386f67dfa6a6270713ab20419914.md b/vision-fixhub/court-01/f2efbd3517a354b8656da588746ffd259e20386f67dfa6a6270713ab20419914.md
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+++ b/vision-fixhub/court-01/f2efbd3517a354b8656da588746ffd259e20386f67dfa6a6270713ab20419914.md
@@ -0,0 +1,49 @@
+Case 1:19-CV-10577-LJL-DCF Document 18 Filed HUSBC SENE TOLI
+DOCUMENT
+ELECTRONICALLY FILED
+DOC #:
+DATE FILED:January 2, 2020
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000
+-x
+Plaintiffs),
+-against-
+INDYKE, et al.
+19 Civ. 10577
+_ (LGS)
+Amended
+ORDER OF REFERENCE
+TO A
+MAGISTRATE JUDGE
+Defendant(s).:
+LORNA G. SCHOFIELD, District Judge:
+The above entitled action is referred to the Hon. Kevin N. Fox
+United States Magistrate Judge, for the following purpose(s):
+GENERAL PRE-TRIAL (includes
+scheduling, discovery, non-dispositive pre-trial
+motions and settlement)
+GENERAL PRE-TRIAL &
+DISPOSITIVE MOTION (all purposes except
+trial)
+DISPOSITIVE MOTION (i.e., a motion
+requiring a Report & Recommendation)
+SPECIFIC NON-DISPOSITIVE
+MOTION / DISPUTE (including discovery
+dispute) *
+HABEAS CORPUS
+INQUEST AFTER DEFAULT /
+DAMAGES HEARING
+SOCIAL SECURITY
+SETTLEMENT
+CONSENT UNDER 28 U.S.C. 636(c)
+FOR ALL PURPOSES (including trial)
+CONSENT UNDER 28 U.S.C. 636(c)
+FOR LIMITED PURPOSE OF
+JURY SELECTION
+SO ORDERED.
+Dated: January 2, 2020
+New York, New York
+* Do not check if already referred for General Pre-Trial.
+Au A
+UNITED STATES DISTRICT JUDGE
diff --git a/vision-fixhub/court-01/f2efbd3517a354b8656da588746ffd259e20386f67dfa6a6270713ab20419914.receipt.json b/vision-fixhub/court-01/f2efbd3517a354b8656da588746ffd259e20386f67dfa6a6270713ab20419914.receipt.json
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f2f222f1a5bd49530dac4137f07f397e16883e133eeb61a7d79fed9749e14c3e.md b/vision-fixhub/court-01/f2f222f1a5bd49530dac4137f07f397e16883e133eeb61a7d79fed9749e14c3e.md
new file mode 100644
index 0000000000000000000000000000000000000000..a22c4d4c06e34935aaf52d8915547035489c7f6b
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@@ -0,0 +1,197 @@
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CV-80802-MARRA-
+JANE DOE NO. 8
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S MOTION TO DISMISS PLAINTIFF'S COMPLAINT
+Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his attorneys, moves
+to dismiss Counts I and III of Plaintiff's Complaint as the causes of action are barred by
+the applicable statute of limitations. and 2 Rule 12(b)(6); Local Gen. Rule 7.1 (S.D. Fla.
+2009). In support of dismissal, Defendant states:
+Plaintiff's Complaint attempts to allege three Counts; the first two counts are
+pursuant to state common law, and the third count is brought pursuant to 18 U.S.C.
+§2255. Civil remedy for personal injuries. Count I attempts to allege a cause of action
+for "Sexual Assault and Battery," Count I for "Intentional Infliction of Emotional
+1
+Plaintiff's Complaint attempts to assert both state common law claims and a claim pursuant to 18
+U.S.C. §2255. Since Jane Doe 8 did not relinquish her state claims and correspondingly did not file her
+complaint relying, exclusively, on 18 USC 2255, she is not entitled to the litigation benefits including
+certain waivers that directly or indirectly accrue to other civil plaintiffs from the defendant's fulfilling
+obligations resulting from his separate confidential agreement with the United Staes Attorney's Office
+Plaintiff's counsel conceded that the provisions of the NPA are not implicated where a plaintiff brings
+additional causes of action and does not proceed exclusively under §2255. See June 12, 2009, Hearing
+Transcript in Jane Doe, et al v. Epstein, Case No. 08-80119-Civ-Marra, p. 29, line 19-25, p. 30, line 1.
+2
+Undersigned counsel provided the United States Attorneys' Office a copy of this Motion on July 9,
+2009. We requested confirmation that this motion did not involve any aspect of the Non Prosecution
+Agreement and advised of our required filing date. No response was received from the USAO.
+
+
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 2 of 6
+Page 2
+Distress;" and Count III for "Coercion and Enticement to Sexual Activity in Violation of
+18 U.S.C. §2422," pursuant to 18 U.S.C. §2255.
+Pursuant to the allegations on the face of Plaintiff's complaint, Count I, based on
+Florida's common law of assault and battery, and Count III, brought pursuant to 18
+U.S.C. §2255, are barred by the applicable statute of limitations. Although a statute of
+limitations bar to a claim is an affirmative defense, and a plaintiff is not required to
+negate an affirmative defense in her complaint, a Rule 12(b)(6) dismissal on statute of
+limitations grounds is appropriate where, as here, "it is 'apparent from the face of the
+complaint' that the claim is time-barred." See generally, La Grasta v. First Union
+Securities, Inc., 358 F.3d 840, 845-846 (11" Cir. 2004).
+Count I is barred by the applicable statute of limitations.
+As to Count I, which is plead pursuant to state law, it is well settled that this Court
+is to apply Florida law. Erie R.Co. v. Tompkins, 58 S.Ct. 817 (1938). Pursuant to
+Florida law, the statute of limitations for assault and battery is four years, §95.11(3)(o).,
+Fla. Stat. §95.11(3)(o), Fla. Stat., provides -
+Actions other than for recovery of real property shall be commenced as
+follows:
+*
+(3) Within four years.—
+(o) An action for assault, battery, false arrest, malicious prosecution,
+malicious interference, false imprisonment, or any other intentional tort,
+except as provided in subsections (4), (5), and (7).
+In her Complaint, Plaintiff alleges in relevant part that -
+9.... In or about 2001, Jane Doe, then approximately 16 years old, fell
+into Epstein's trap and became one of his victims.
+
+
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 3 of 6
+Page 3
+According to the allegations of the Complaint, Jane Doe had one encounter with
+Defendant at his Palm Beach mansion in or about 2001 when Jane was approximately
+16 years old. See Complaint, 113, endnote 1 hereto.' Based on the allegations of the
+Complaint, it has been at least 8 years since the alleged conduct by EPSTEIN, well past
+the four year statute of limitations, thus requiring dismissal of Count I. Based on the
+allegations, Plaintiff is now at least 24 years old.
+Subsections (4) and (5) referenced in §95.11(3)(o) are not applicable. Plaintiff
+may attempt to argue that subsection (7) of §95.11, Fla. Stat. applies. See endnote 2
+hereto for statutory text of subsection (7), including statutes referenced therein?
+However, a review of Plaintiff's allegations in Count I establish that Plaintiff is attempting
+to assert a cause of action based on the elements of Florida's common law assault and
+battery to which a four year statute of limitation applies. (Compare Count II, T24,
+wherein Plaintiff tracks the language §39.01(2), Fla. Stat. (2001), pertaining to "abuse.").
+Pursuant to Florida law, although the term "assault and battery" is most
+commonly referred to as if it were a legal unit, or a single concept, "assault and battery
+are separate and distinct legal concepts, assault being the beginning of an act which, if
+consummated, constitutes battery." 3A Fla.Jur.2d Assault §1. An assault and battery
+are intentional acts. See generally, Spivey v. Battaglia, 258 So.2d 815 (Fla. 1972); and
+Travelers Indem. Co. v. PCR, Inc., 889 So.2d 779 (Fla. 2004).
+On the face of the Complaint, the applicable four year statute of limitations has
+expired, and accordingly, Count I is barred an required to be dismissed.
+
+
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 4 of 6
+Page 4
+Count III - 18 U.S.C. §2255
+As to the applicable statute of limitations for Count Ill which is brought pursuant to
+18 U.S.C. §2255, §2255(b), (both the 2001 version, which Defendant asserts is the
+applicable statute, and the amended version, effective July 27, 2006), provides:
+(b) Statute of limitations.-Any action commenced under this section
+shall be barred unless the complaint is filed within six years after the right
+of action first accrues or in the case of a person under a legal disability,
+not later than three years after the disability.
+As noted above, according to the allegations of the Complaint, Jane Doe had one
+encounter with Defendant at his Palm Beach mansion in or about 2001 when Jane was
+approximately 16 years old. See Complaint, 113, endnote 1 hereto. Based on the
+allegations of the Complaint, it has been at least 8 years since the alleged conduct by
+EPSTEIN, well past the six year statute of limitations, thus requiring dismissal of Count
+III. Based on the allegations, Plaintiff is now at least 24 years old, well pass the age of
+majority. (The age of majority under both federal and state law is 18 years old. See 18
+U.S.C. §2256(1), defining a "minor" as "any person under the age of eighteen years;"
+and §1.01, Definitions, Fla. Stat., defining "minor" to include "any person who has not
+attained the age of 18 years."). Thus, on the face of the Complaint, Count III is timed
+barred and required to be dismissed.
+Conclusion
+Accordingly, Counts I and III of Plaintiff's Complaint are subject to dismissal. On
+the face of the Complaint, the causes of action which Plaintiff attempts to allege are
+barred by the applicable statute of limitations of 4 and 6 years, respectively.
+
+
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 5 of 6
+Page 5
+WHEREFORE, Defendant requests that this Court dismiss Counts I and III of
+Plaintiff's Complaint with prejudice.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 14*
+_day of _
+July, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+Irivera@hermanlaw.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Counsel for Plaintiff Jane Doe #8
+Respectfully submitted,
+BURMAN, CRITTON, LUTTIER
+& COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+(561) 842-2820
+By:
+Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+Counsel for Defendant Jeffrey Epstein
+rcrit@bclclaw.com
+mpike@bclclaw.com
+'Complaint, 113 alleges in relevant part -
+... Jane Doe was recruited by another girl, who told her that she could make some
+money, but did not tell her what was involved. At all relevant times, the girl who
+
+
+Case 9:09-cv-80802-KAM Document 8 Entered on FLSD Docket 07/14/2009 Page 6 of 6
+Page 6
+recruited Jane Doe was acting on behalf of and as an agent for Epstein. Jane was
+contacted by this giri by telephone. Jane was then picked up and brought to
+Epstein's mansion in Palm Beach. Once there, she was lead up a flight of stairs to
+the room with the massage table. Epstein came into the room and directed Jane
+to remove her clothes and give him a massage. Jane was frightened and felt
+trapped. As directed by Epstein, Jane removed her clothes. Epstein then during
+the massage touched Jane on her breasts and vagina, and he grabbed her hand
+and placed it on his penis. Epstein masturbated himself during the massage.
+Epstein then left money for Jane.
+2 §95.11(7), Fla. Stat. -
+(7) For intentional torts based on abuse.--An action founded on alleged abuse,
+as defined in s. 39.01, s. 415.102, or s. 984.03, or incest, as defined in s. 826.04,
+may be commenced at any time within 7 years after the age of majority, or within 4
+years after the injured person leaves the dependency of the abuser, or within 4
+years from the time of discovery by the injured party of both the injury and the
+causal relationship between the injury and the abuse, whichever occurs later.
+§39.01(2), Fla. Stat. (2001) -
+(2) "Abuse" means any willful act or threatened act that results in any physical,
+mental, or sexual injury or harm that causes or is likely to cause the child's
+physical, mental, or emotional health to be significantly impaired. Abuse of a child
+includes acts or omissions. Corporal discipline of a child by a parent or legal
+custodian for disciplinary purposes does not in itself constitute abuse when it does
+not result in harm to the child.
+§415.102(1), Fla. Stat. (2001) -
+(1) "Abuse" means any willful act or threatened act that causes or is likely to cause
+significant impairment to a vulnerable adult's physical, mental, or emotional
+health. Abuse includes acts and omissions.
+§984.03 (2), Fla. Stat. (2001) -
+"Abuse" means any willful act that results in any physical, mental, or sexual injury
+that causes or is likely to cause the child's physical, mental, or emotional health to
+be significantly impaired. Corporal discipline of a child by a parent or guardian for
+disciplinary purposes does not in itself constitute abuse when it does not result in
+harm to the child as defined in s. 39.01.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f2f222f1a5bd49530dac4137f07f397e16883e133eeb61a7d79fed9749e14c3e.receipt.json b/vision-fixhub/court-01/f2f222f1a5bd49530dac4137f07f397e16883e133eeb61a7d79fed9749e14c3e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9d3d3418e4c86d7d8f7f41fa560e074228475bba
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 7,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f305037d443abaf255942a8265c5d2059daa12c382d698e1ab64b022ef28d5d9.md b/vision-fixhub/court-01/f305037d443abaf255942a8265c5d2059daa12c382d698e1ab64b022ef28d5d9.md
new file mode 100644
index 0000000000000000000000000000000000000000..0b1f29e857bf9db792f073e3999af9a8c0e72bce
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@@ -0,0 +1,229 @@
+Case 1:19-cv-09610-PAE-DCF Document 9 Filed 10/23/19 Page 1 of 9
+CASE NO. 19-cv-9610
+JANE DOE 17,
+Plaintiff,
+V.
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+UNOPPOSED MOTION TO ADMIT COUNSEL PRO HAC VICE
+PURSUANT TO RULE 1.3(c) of the Local Rules of the United States District Courts for
+the Southern and Eastern Districts of New York, I, Andrew S. Buzin, a member in good standing
+of the bar of this Court, hereby move for an Order allowing the admission pro hac vice of:
+Laura J. Starr, Esq., FBN 0491888
+1301 N. Federal Highway
+Lake Worth, FL 33460
+Telephone: (561) 588-9500
+Facsimile: (561) 588-9500
+Email: Istarr@yourfloridacounsel.com
+Ms. Starr is a member in good standing of the Florida Bar. There are no pending
+disciplinary proceedings against Ms. Starr in any State or Federal court.
+I have consulted with counsel for Defendants, Bennet Moskowitz, Esq.. of Troutman
+Sanders LLP, who has advised that Defendants do not oppose this Motion.
+
+
+
+Case 1:19-cv-09610-PAE-DCF Document 9 Filed 10/23/19 Page 2 of 9
+Dated:
+New York, New York
+October 23, 2019
+By:
+Respectfully Submitted,
+Is/ Andrew S. Buzin
+Andrew S. Buzin
+BUZIN LAW, P.C
+111 Broadway, Suite 1204
+New York, NY 10006
+Tel: (646) 470-4878
+Fax: (347) 736-9490
+abuzin@buzinlaw.com
+Attorneys for Plaintiff, Jane Doe 17
+
+
+
+Case 1:19-CV-09610-PAE-DCF Document 9 Filed 10/23/19 Page 3 of 9
+CERTIFICATE OF SERVICE
+I hereby certify that on October 23, 2019, I caused true and correct copies of the foregoing
+Motion to Unopposed Motion To Admit Counsel Pro Hac Vice, Affidavit of Laura J. Starr, Esq.
+in Support of Motion to Admit Counsel Pro Hac Vice, and Order for Admission Pro Hac Vice on
+Written Motion to be served by electronic mail on defense counsel listed below:
+Bennet J. Moskowitz
+Troutman Sanders
+875 Third Avenue
+New York, NY 10022
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+By:
+ANDREWS. BUZN
+abuzin@buzinlaw.com
+
+
+
+Case 1:19-CV-09610-PAE-DCF Document 9 Filed 10/23/19 Page 4 of 9
+CASE NO. 19-cv-9610
+JANE DOE 17,
+Plaintiff,
+V.
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+DECLARATION OF LAURA J. STARR, ESQ.
+IN SUPPORT OF MOTION TO ADMIT COUNSEL PRO HAC VICE
+1, Laura J. Starr, Esq., declare under penalty of perjury as follows:
+Pursuant to Rule 1.3 of the Local Rules of the United States Courts for the Southern
+and Eastern Districts of New York, I hereby seek admission from this Court to practice Pro Hac
+Vice to appear as counsel for Plaintiff JANE DOE 17 in the above-captioned action.
+I am in good standing of the bar of the State of Florida and there are no pending
+disciplinary proceedings against me in any state or federal court. I have never been convicted of a
+felony. I have never been censured, suspended, disbarred or denied admission or readmission by
+any court. I have attached the affidavit pursuant to Local Rule 1.3.
+I have consulted with counsel for Defendants, Bennet Moskowitz, Esq., of
+Troutman Sanders LLP, who has advised that Defendants do not oppose this Motion.
+
+
+
+Case 1:19-cV-09610-PAE-DCF Document 9 Filed 10/23/19 Page 5 of 9
+Dated: Lake Worth, Florida
+October 23, 2019
+Respectfully submitted,
+WEISMAN, BRODIE, STARR
+& MARGOLIES, P.A.
+Is/ Laura J. Starr
+Laura J. Starr, Esq., FBN 0491888
+1301 N. Federal Highway
+Lake Worth, FL 33460
+Telephone: (561) 588-9500
+Facsimile: (561) 588-9500
+Email: Istarr@yourfloridacounsel.com
+Attorney for Plaintiff, Jane Doe 17
+
+
+
+Case 1:19-cv-09610-PAE-DCF Document 9
+Filed 10/23/19 Page 6 of 9
+CASE NO. 11:19-CV-09610-PAE
+JANE DOE 17,
+Plaintiff,
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+I, Laura J. Starr, hereby declare as follows:
+I make this Affidavit in connection with my Motion for Admission Pro Hac
+Vice in the above-captioned matter as co-counsel for Plaintiff, Jane Doe 17.
+2.
+I am a partner with the law firm of Weisman, Brodie, Starr & Margolies, P.A.
+I am a member of good standing of the bar of the state of Florida. (Exhibit A.)
+4.
+I have never been convicted of a felony.
+I have never been censured, suspended, disbarred or denied admission or
+readmission by any court.
+6.
+Federal Court.
+There are no pending disciplinary proceedings against me in any state or
+
+
+
+Case 1:19-CV-09610-PAE-DCF Document 9 Filed 10/23/19 Page 7 of 9
+FURTHER AFFIANT SAYETH NAUGHT.
+-
+Lama Starn
+LAURA J. STARR
+STATE OF FLORIDA
+) 55.:
+COUNTY OF PALM BEACH
+The foregoing instrument was acknowledged before me this 16 day of October, 2019, by
+LAURA J. STARR, who is [°] personally known to me or [ ] has produced the following
+identification
+which is current or
+has been issued within the past five years and bears a serial or other identifying number, and who
+did take an oath.
+Notary Public
+(
+Printed Notary Nar
+My Commission Expires: 3/18 2023
+CHRISTY BRADY JANSSEN
+MY COMMISSION # GG 290033
+EXPIRES: March 18, 2023
+Bonded Thru Notary Public Undenerlo
+
+
+
+Case 1:19-cv-09610-PAE-DCF
+Document 9
+Filed 10/23/19
+
+The Florida Bar
+651 East Jefferson Street
+Tallahassee, FL 32399-2300
+Joshua E.
+Executive Director
+State of Florida
+County of
+850/561-5600
+www.FLORIDABAR.org
+)
+)
+In Re: 0491888
+Laura Jane Starr
+1301 N Federal Hwy
+Lake Worth, FL 33460-1940
+I CERTIFY THE FOLLOWING:
+I am the custodian of membership records of The Florida Bar.
+Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to
+practice law in the state of Florida on July 20, 2001.
+The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to
+practice law in the state of Florida.
+Dated this 18th day of October, 2019.
+Cipithia de. Jackon
+Cynthia B. L
+, CFO
+Administration Division
+The Florida Bar
+FLORIDE
+PG:R10
+CTM-61088
+1950
+
+
+Case 1:19-cv-09610-PAE-DCF Document 9 Filed 10/23/19 Page 9 of 9
+CASE NO. 1:19-cv-09610-PAE
+JANE DOE 17,
+Plaintiff,
+V.
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+Upon motion, for an order permitting her to appear and practice pro hac vice in the
+within action on behalf of Plaintiff, Jane Doe 17, it is hereby
+ORDERED that the Motion for Laura J. Starr to Appear Pro Hac Vice be GRANTED.
+UNITED STATES DISTRICT JUDGE
+Dated: October
+_ 2019
diff --git a/vision-fixhub/court-01/f305037d443abaf255942a8265c5d2059daa12c382d698e1ab64b022ef28d5d9.receipt.json b/vision-fixhub/court-01/f305037d443abaf255942a8265c5d2059daa12c382d698e1ab64b022ef28d5d9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..48f13b0bbd7ab6276f544e8580d41e84fc09c436
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+++ b/vision-fixhub/court-01/f305037d443abaf255942a8265c5d2059daa12c382d698e1ab64b022ef28d5d9.receipt.json
@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/f3095c923a368a86adafb627e3dcad45ec6f9f76fee848e399bb216d8dc837c9.md b/vision-fixhub/court-01/f3095c923a368a86adafb627e3dcad45ec6f9f76fee848e399bb216d8dc837c9.md
new file mode 100644
index 0000000000000000000000000000000000000000..30a542432a418ef5e6588bbf5d86d9ce7b860de1
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@@ -0,0 +1,74 @@
+Case 9:08-cv-80232-KAM Document 26 Entered on FLSD Docket 07/29/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80119-CIV-KAM-LRJ
+JANE DOE NO. 2,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 3,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 4,
+VS.
+JEFFREY EPSTEIN.
+JANE DOE NO. 5,
+VS.
+JEFFREY EPSTEIN.
+CASE NO.: 08-80232-CIV-KAM-LRJ
+CASE NO.: 08-80380-CIV-KAM-LRJ
+CASE NO.: 08-80381-CIV-KAM-LRJ
+DEFENDANT'S NOTICE OF FILING EXHIBITS
+Defendant Jeffrey Epstein hereby files the following two exhibits to his Reply in Support
+of Motion to Stay, filed under seal on July 28, 2008:
+A.
+Exhibit "A" is the July 9, 2008 Declaration of Assistant United States Attorney Ann
+C. Villafana, previously filed by the United States in In re: Jane Doe, Case No. 08-
+80736-CIV-Marra/
+(S.D. Fla.) (DE 14).
+Teinn.
+
+
+Case 9:08-cv-80232-KAM Document 26 Entered on FLSD Docket 07/29/2008 Page 2 of 3
+B.
+Exhibit "B" is a copy of Title 18, United States Code, section 1595.
+These exhibits were inadvertently omitted from the reply memorandum.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101 Fax: 305 442 6744
+By:
+Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300 Fax. 561 835 8691
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 29, 2007, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing document
+is being served this day on all counsel of record on the attached service list by transmission of
+Notice of Electronic Filing generated by CM/ECF.
+Is/ Michael R. Tein
+2
+Tein..
+
+
+Case 9:08-cv-80232-KAM Document 26 Entered on FLSD Docket 07/29/2008 Page 3 of 3
+SERVICE LIST
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, Florida 33160
+3
+Tein..
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f3095c923a368a86adafb627e3dcad45ec6f9f76fee848e399bb216d8dc837c9.receipt.json b/vision-fixhub/court-01/f3095c923a368a86adafb627e3dcad45ec6f9f76fee848e399bb216d8dc837c9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9c120fb2e5b1aec526ec802ef159041213365770
--- /dev/null
+++ b/vision-fixhub/court-01/f3095c923a368a86adafb627e3dcad45ec6f9f76fee848e399bb216d8dc837c9.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "6c7e822bdade090a0e5dff0de9871023bed0948f24745fcbcb0262fcba76c8c8",
+  "output_sha256": "6778140d9311861ec505a263afc8b7a6ec8c5c0babb52140f5cba76820ef8859",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.md b/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.md
new file mode 100644
index 0000000000000000000000000000000000000000..fb2f9a3c69194b3664a1bb7b4ccdcd3991171fd1
--- /dev/null
+++ b/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.md
@@ -0,0 +1,152 @@
+Case 9:10-cv-80309-KAM Document 12 Entered on FLSD Docket 04/01/2010 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 103
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S MOTION TO TRANSFER
+Plaintiff, Jane Doe No. 103, by and through her undersigned counsel, moves this Court for
+the entry of an order transferring this case to Judge Marra so that it may be consolidated with Jane
+Doe No. 2 vs. Jeffrey Epstein, Case No. 08-80119-MARRA/
+, on the following grounds:
+1.
+On February 23, 2010, Plaintiff filed Complaint and Demand for Jury Trial and
+attached a list of Related Pending Cases to the Civil Cover Sheet (Exhibit"A"). As was clearly
+indicated by the attachment this case is similar and related to at least 11 other cases that have been
+transferred to Judge Marra's division and consolidated.
+On May 14, 2009, Judge Marra entered an Order Consolidating Cases For Purposes
+of Discovery and Procedural Motions that Relate to Multiple Cases in Case No. 08-80119-
+MARRA/
+[D.E. 98].
+Transfer of this matter to Judge Marra and consolidation with the other pending Jane
+
+
+Case 9:10-cv-80309-KAM Document 12 Entered on FLSD Docket 04/01/2010 Page 2 of 5
+doe cases against Jeffrey Epstein will serve the interests of judicial economy and efficiency.
+WHEREFORE, Plaintiff, Jane Doe No. 103, respectfully requests that this Court grant
+Plaintiff's motion, and enter an order transferring this case to Judge Marra's division where it can
+be consolidated with the numerous other similar and related cases pending before Judge Marra.
+DATED this 1st day of April, 2010.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff Jane Doe No. 103
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+- 2 -
+
+
+Case 9:10-cv-80309-KAM Document 12 Entered on FLSD Docket 04/01/2010 Page 3 of 5
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this Ist day of April, 2010, a copy of the foregoing was
+served this day on all counsel of record on the attached Service List via e-mail transmission.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff Jane Doe No. 103
+By:
+s/Katherine W. Ezel
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+- 3 -
+
+
+Case 9:10-cv-80309-KAM Document 12 Entered on FLSD Docket 04/01/2010 Page 4 of 5
+SERVICE LIST
+JANE DOE NO. 103 v. JEFFREY EPSTEIN
+Case No.: 10-80309
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820/Fax: (561) 515-3148
+rcrit@bclelaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300/Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360/Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300/Fax: (561) 383-9456
+jsx@searcylaw.com
+- 4-
+
+
+Case 9:10-cv-80309-KAM Document 12 Entered on FLSD Docket 04/01/2010 Page 5 of 5
+jph@searcylaw.com
+Counsel for Plaintiff in related Case No. 08-80811
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200/Fax: (305) 931-0877
+ahorowitz(@sexabuscattorney.com
+smermelstein(@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-80381,
+08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400/Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Brad
+Esq.
+_ Jaffe, Weissing,
+Fistos & Lehrman, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820/Fax: (954) 524-2822
+brad@pathtojustice.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+, Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033/Fax: (561) 832-7137
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
+- 5-
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.receipt.json b/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2f549bd574466a165c7d4e5ef39b9ab375edec15
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+++ b/vision-fixhub/court-01/f36f81a4c92545867ea560e40bfcc652ff26e7fc51f29bbaa197f2fbc28493d2.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "ed92069289bebaf9c4907e266f8d4dbb2115d5cc7e17674aa2ab362dc34b056f",
+  "output_sha256": "d3063ea096ead50595e93fcbd21940227fb28d0390e746fd294cbfdb40c86ef8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f384cf6ff98d4f14198a0cb3b5e50432cd5d3e321a055cce54ae2aa53f575b04.md b/vision-fixhub/court-01/f384cf6ff98d4f14198a0cb3b5e50432cd5d3e321a055cce54ae2aa53f575b04.md
new file mode 100644
index 0000000000000000000000000000000000000000..39c7356325ab4b7b93868c1187b28c34dfbde21d
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@@ -0,0 +1,256 @@
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 3,
+Plaintiff
+CASE NO: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 4,
+Plaintiff
+CASE NO: 08-CV-80380-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 2 of 10
+JANE DOE NO. 5,
+Plaintiff
+CASE NO: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 6.
+Plaintiff
+CASE NO: 08-CV-80994-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 7,
+Plaintiff
+CASE NO: 08-CV-80993-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant
+2
+
+
+Case 9:08-cV-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 3 of 10
+CASE NO: 08-CV-80811-MARRA/
+C.M.A.,
+Plaintiff
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/_
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+DOE II,
+CASE NO: 09-CV-80469-MARRA/
+Plaintiff
+VS.
+JEFFREY EPSTEIN, et al.
+Defendants.
+3
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 4 of 10
+JANE DOE NO. 101,
+Plaintiff
+CASE NO: 09-CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+JANE DOE NO. 102,
+Plaintiff
+CASE NO: 09-CV-80656-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant
+PLAINTIFF JANE DOE'S MOTION TO COMPEL ANSWERS TO PLAINTEF'S
+FIRST REQUEST FOR ADMISSIONS TO DEFENDANT
+Plaintiff Jane Doe, hereby moves this Court for an order compelling defendant,
+Jeffrey Epstein, to answer her first requests for admissions or, in the alternative, to
+prove that his invocation of his Fifth Amendment privilege is proper.
+Jane Doe has propounded 23 requests for admission to Epstein, including such
+straightforward requests as:
+• Your net worth is greater than $1 billion.
+4
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 5 of 10
+• You own or control, directly or indirectly, real estate property in foreign
+countries.
+• You are moving significant financial assets overseas, outside of the direct
+territorial reach of the U.S. and Florida Courts.
+• You currently have the ability to post a bond of $15 million to satisfy a
+judgment in this case without financial or other difficulty.
+In response to each and every one of these questions, Epstein has given the
+following response.
+In response, Defendant asserts his U.S. constitutional privileges as
+specified herein. I intend to respond to all relevant discovery regarding
+this lawsuit, however, my attorneys have counseled me that I cannot
+provide answers to any discovery relevant to this lawsuit and I must
+accept this advice or risk losing my Sixth Amendment right to effective
+representation. Accordingly, 1 assert my federal constitutional rights under
+the Fifth, Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Drawing an adverse inference under these
+circumstances would unconstitutionally burden my exercise of my
+constitutional rights, would be unreasonable, and would therefore violate
+the Constitution.
+This Court should order Epstein to answer all of the requests for admission or, in
+the alternative, prove that his Fifth Amendment invocations are valid. It is for the court,
+not the claimant, to determine whether the hazard of incrimination is justified. United
+States v. Argomaniz, 925 F.2d 1349, 1355 (11th Cir. 1991). "A court must make a
+particularized inquiry, deciding, in connection with each specific area that the
+questioning party wishes to explore, whether or not the privilege is well-founded." Id.
+Typically this is done in an in camera proceeding wherein the person asserting the
+privilege is given the opportunity "to substantiate his claims of the privilege and the
+5
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 6 of 10
+district court is able to consider the questions asked and the documents requested by
+the summons." Id
+Here Epstein has made boilerplate invocation of the Fifth Amendment to each
+and every question propounded by Jane Doe, including for example a request that he
+admit that his net worth is more than $500 million. It is not apparent how admitting his
+net worth is incriminating in the circumstances of this case. In any event, the Fifth
+Amendment does not operate in this fashion. It is Epstein's obligation to explain his
+claims on a "question-by-question basis." Id.
+The only issue before the Court is Epstein's Fifth Amendment privilege. Epstein
+has only asserted a Fifth Amendment objection to production. As a result, any other
+objections to production are deemed waived. See Local Rule 26.1G.3.(a) ("Any ground
+[for an objection] not stated in an objection within the time provided by the Federal
+Rules of Civil Procedure, or any extensions thereof, shall be waived.").
+SPECIFIC REQUESTS FOR ADMISSION
+For the convenience of the court - and in compliance with Local Rule 26.1 H
+(party filing motion to compel shall list specific requests in succession) - Jane Doe's
+requests for admission are as follows:
+1. Your net worth is greater than $10 million.
+2. Your net worth is greater than $50 million.
+3. Your net worth is greater than $100 million.
+4. Your net worth is greater than $500 million.
+5. Your net worth is greater than $1 billion.
+6
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 7 of 10
+6. Since being incarcerated you have, directly or indirectly (through the services
+or assistance of other persons), conveyed money or assets in an attempt to insulate or
+protect your money or assets from being captured in any civil lawsuits filed against you.
+7. You own or control, directly or indirectly, real estate property in the Caribbean.
+8. You own or control, directly or indirectly, real estate property in foreign
+countries.
+9. In the last 2 years you have transferred assets and/or money and/or financial
+instruments to countries outside the United States.
+10. You have provided financial support to the modeling agency MC2.
+11. You have committed sexual assault against Plaintiff, a minor.
+12. You committed battery against Plaintiff.
+13. You digitally penetrated Plaintiff when she was a minor.
+14. You offered Plaintiff more money contingent upon her having sex with your
+or giving you oral sex.
+15. You intended to harm Plaintiff when you committed these sexual acts
+against her.
+16. You knew Plaintiff was under the age of 16 when you sexually touched and
+fondled her.
+17. You intend to hire investigators to intimidate and harass Plaintiff during this
+litigation.
+18. You were engaged in the act of trafficking minors across state or country
+borders for the purposes of sex or prostitution between 2000 and the present.
+7
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 8 of 10
+19. You coerced Plaintiff into being a prostitute and remaining in prostitution.
+20. You are guilty of the following offenses against Jane Doe:
+A. Procuring a minor for the purpose of prostitution as defined in F.S. 796.03;
+B. Battery as defined by Florida Statutes.
+C. Sexual Battery.
+21. You are moving significant financial assets overseas, outside of the direct
+territorial reach of the U.S. and Florida Courts.
+22. You are making asset transfers with the intent to defeat any judgment that
+might be entered against you in this or similar cases.
+23. You currently have the ability to post a bond of $15 million to satisfy a
+judgment in this case without financial or other difficulty.
+CONCLUSION
+For all these reasons, the Court should compel Epstein to answer the requests
+for admission or provide a particularized justification for his Fifth Amendment invocation
+with regard to each request. Counsel for Jane Doe have conferred with opposing
+counsel on the issues raised in this motion, and no resolution was possible.
+DATED July 20, 2009
+Respectfully Submitted,
+S/
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 542075
+E-mail: bedwards@rra-law.com
+8
+
+
+Case 9:08-cv-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 9 of 10
+and
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile:
+801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that on July 20, 2009, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+receive electronically filed Notices of Electronic Filing.
+J.
+9
+
+
+Case 9:08-cV-80119-KAM Document 211 Entered on FLSD Docket 07/20/2009 Page 10 of 10
+SERVICE LIST
+Jane Doe v. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@bclclaw.com
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+William J. Berger
+wberger@rra-law.com
+10
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f384cf6ff98d4f14198a0cb3b5e50432cd5d3e321a055cce54ae2aa53f575b04.receipt.json b/vision-fixhub/court-01/f384cf6ff98d4f14198a0cb3b5e50432cd5d3e321a055cce54ae2aa53f575b04.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..68c7cca9f466d56d12d8044a3bd6bc8a7df44af1
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@@ -0,0 +1,14 @@
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
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+  "output_sha256": "ff3d45ce772548ec4e7c6f6d9f26ff55070e5063ab01e1712b46051a228f855b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.md b/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.md
new file mode 100644
index 0000000000000000000000000000000000000000..d294c52093d6f0af79f6d47cba8d2717291542bf
--- /dev/null
+++ b/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.md
@@ -0,0 +1,236 @@
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 1 of 9
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRAJ_
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+- 1-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 2 of 9
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA
+JANE DOE NO. 7,
+CASE NO.: 08- 80993-CIV-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' MEMORANDUM IN OPPOSITION
+TO MOTION TO STAY AND OR CONTINUE ACTION
+Plaintiffs, JANE DOES 2-7, by and through undersigned counsel, file this Memorandum in
+Opposition to Stay and or Continue Action, as follows:
+I.
+Introduction
+In moving for stay, Defendant has the burden of demonstrating that, due to a parallel criminal
+proceeding, if he exercises his right against self incrimination he will certainly lose on summary
+judgment unless a stay is granted. Defendant has failed to satisfy this burden. There is no pending
+motion for summary judgment.
+There is also no criminal proceeding at this time arising from
+Epstein's acts against the Plaintiffs or other victims. Indeed, whether such a criminal proceeding is
+ever commenced is entirely within the Defendant's control, by complying with the terms of his
+Non-Prosecution Agreement with the U.S. Attorney's Office. Defendant relies upon an amorphous
+- 2-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 3 of 9
+possible breach of his Non-Prosecution Agreement with the U.S. Attorney, which does not give rise
+to the "special circumstances" necessary to warrant a stay. Finally, even if there were grounds for a
+stay, it would not be appropriate in these cases because Plaintiffs would be severely prejudiced by
+the delay occasioned by a stay.'
+II. Argument
+A.
+Defendant Has Not Demonstrated that He Faces a Certain
+Loss on Summary Judgment If a Stay Is Not Granted
+The Constitution doe not require a stay of civil proceedings pending the outcome of criminal
+proceedings involving a common defendant. Shell Oil Co. v. Altina Associates, Inc.., 866 F.Supp.
+536, 540 (M.D. Fla. 1994). A stay pending resolution of related criminal proceedings is warranted
+only when the defendant demonstrates that " "special circumstances" so require in the 'interests of
+justice.' " United States v. Lot 5, Fox Grove, 23 F.3d 359, 365 (11th Cir. 1994).
+In the Eleventh Circuit, the "special circumstances" which may support a stay are limited.
+The fact that the Defendant may "risk a non-criminal disadvantage by remaining silent for fear of
+self incrimination in a parallel criminal proceeding does not rise to the level of an unconstitutional
+infringement." Shell Oil, 866 F.Supp. at 540. Accordingly, the Defendant's right to silence is not
+a basis to stay the civil case pending resolution of a criminal action. Id. There is one exception
+applicable where a stay would be necessary to prevent an unconstitutional infringement of the
+' Defendant Epstein filed an identical Motion to Stay in the case Jane Doe v. Epstein, case no. 08-
+CIV 80893 MARRA/
+Plaintiffs concur in the arguments made by Jane Doe's counsel in
+that case in opposition to Defendant's Motion. (Case no. 08-CIV 80893, DE 31). The same
+reasoning and arguments apply in the instant cases. Plaintiffs in this Memorandum will attempt to
+stream line and limit its arguments to avoid unnecessary repetition and duplication with the response
+in Jane Doe.
+" In this regard, The Defendant's silence by invoking the Fifth Amendment does not prohibit adverse
+inferences against him in the civil case. Shell Oil, 866 F.Supp. at 40.
+- 3-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 4 of 9
+defendant's right against self incrimination: "IT]he law in the Eleventh Circuit requires
+consideration of whether, as a result of invoking the privilege, the defendant faces certain loss of the
+civil proceeding on summary judgment if the civil proceeding were to continue." In re Financial
+Federation Title & Trust, Inc.., 252 B.R. 834, 837 (Bankr. S.D. Fla. 2000) (citing United States v.
+Lot 5. 23 F.3d at 364); accord Shell Oil, 866 F.Supp. at 540 (noting that there is a "recognized
+exception to this general rule: the Fifth Amendment is violated when a person, who is a defendant in
+both a civil and criminal case, is forced to choose between waiving his privilege against selfincrimination or losing the civil case in [summary proceedings]").
+The cases relied upon by Defendant are consistent with these authorities. In Ventura v.
+Brosky, 2006 WL 3392207 (S.D. Fla. 2006), the Court stated the rule that a stay is warranted to
+avoid a situation "where a defendant in both criminal and civil proceedings must choose between
+whether to waive his privilege against self-incrimination or to lose the civil case in summary or
+default judgment proceedings." Id. at *1. Moreover, the stay in Ventura was granted on motion of
+the defendant Miami-Dade County Police Department because it would be prejudiced by its
+codefendant, a former police officer, asserting the Fifth Amendment and refusing to answer 'in
+response to the civil Complaint and any discovery directed at him in the case." Id. Such concerns
+involving prejudice to a codefendant are not present here. In Securities and Exchange Comm'n v.
+Rehtorik, 755 F.Supp. 1018 (S.D. Fla. 1990), another case relied upon by Defendant, the Court
+denied a stay of the case, and made clear in its holding that the defendant had not demonstrated that
+it would be subject to "automatic liability" on a motion for summary judgment:
+"The Court in Financial Federation Title & Trust noted that the standard in the Eleventh Circuit
+is "more narrow and less subjective" than in other Circuits where a multi-factor test is used. Id.
+at 837.
+- 4-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 5 of 9
+The defendants can exercise their Fifth Amendment rights in the face
+of the S.E.C.'s summary judgment motion by not presenting evidence
+which would implicate them in the alleged securities fraud. Though
+an adverse inference may be drawn due to their silence, the S.E.C.
+must still carry its burden of proving fraud committed by the
+defendants; their silence alone will not give rise to automatic liability.
+As such, the defendants would not be compelled to speak. To speak
+or not to speak becomes, in such a case, a question of strategy rather
+than one of unconstitutional compulsion.
+Id. at 1020.
+Accordingly, the Defendant's Motion to Stay is, at best, premature. Defendant Epstein fails
+to demonstrate that he is certain to lose on summary judgment if he exercises his constitutional right
+against self-incrimination. Indeed, there is no summary judgment motion pending. Defendant's
+Motion to Stay must accordingly be denied.
+B.
+This Court Has Previously Made It Clear That a Stay is
+Not Warranted, and Circumstances Have Not Changed
+Defendant previously moved for a mandatory stay pursuant to 18 U.S.C. §3509(k). This
+Court denied that Motion on the grounds that there was no criminal action pending, a requirement
+for a stay under §3509(k). (DE 33). The Court in its Opinion also stated that a discretionary stay
+was not warranted:
+it is up to him (and him alone) whether the plea agreement reached
+with the State of Florida is breached. If Defendant does not breach
+the agreement, then he should have no concerns regarding his Fifth
+Amendment right against self-incrimination. The fact that the U.S.
+Attorney (or other law enforcement officials) may object to some
+discovery in these civil cases is not, in an of itself, a reason to stay
+the civil action. Any such issues shall be resolved as they arise in the
+course of this litigation.
+(Order Denying Motion to Stay, p. 4). In again seeking a stay, Defendant seized on the last sentence
+- 5-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 6 of 9
+quoted above and takes it out of context in contending that the time is now ripe for a stay. The Court
+stated that issues arising in the event that the U.S. Attorney or other law enforcement officials object
+to discovery can be resolved during the course of the litigation. (DE 33, p. 4). The Court was not
+inviting the Defendant to file another motion for stay later in the course of discovery. In any event,
+there are no changed circumstances which would warrant a different analysis and conclusion from
+that reached by the Court last August.
+C.
+The Defendant Cannot Meet His Burden of Demonstrating Grounds
+for a Stay on the Basis of Vague Assertions of the Position of the USAO
+There is no criminal prosecution pending for the acts of Epstein against any of the Plaintiffs
+in these civil cases. Epstein's Motion thus fails at the outset because there is no parallel criminal
+action.* In any event, the Defendant vaguely asserts, without supporting documentation, that the
+"USAO has already attempted to claim violations of the Non-Prosecution Agreement." (Motion to
+Stay (DE 57), p. 2). The Defendant submits the Affidavit of his criminal attorney, Jack Goldberger,
+who asserts that "the USAO has taken the position on a number of occasions that it might consider"
+various actions by Epstein to be a breach of the Non-Prosecution Agreement. Nowhere does the
+Motion or this supporting Affidavit assert that the USAO has declared a breach of the Non-
+Prosecution Agreement, nor does it indicate that the issue of breach has been raised by either party
+in any court. It is therefore difficult to understand how this can be grounds for a stay. Defendant
+does nothing more than speculate on the intentions of the USAO. The Motion to Stay is therefore, at
+best, premature.
+D.
+Plaintiffs Would Be Prejudiced by a Stay
+*The cases discussing the stay issues are premised on a pending criminal action parallel to the civil
+proceeding. See, e.g., Rehtorik, 755 F.Supp. at 1019-1020; United States v. Lot 5, 23 F.3d at 364
+(quoting United States v. Little Al, 712 F.2d 133, 136 (5th Cir. 1983)).
+- 6-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 7 of 9
+Because Defendant has failed to set forth circumstances that would support a stay, there is no
+need to proceed further. Nonetheless, Plaintiffs note that they will be severely prejudiced if a stay is
+granted. First, the stay requested is a lengthy one, to the end of 2010. Such a delay is simply unfair
+to the Plaintiffs, who are entitled to civil remedies for the wrongs that were committed by Epstein.
+Additionally, the delay in discovery will be prejudicial to Plaintiffs. Investigation and
+discovery will become more difficult with the passage of time. The bulk of the allegations occurred
+in 2004-05, when the Plaintiffs were minors. Plaintiffs should not have to wait to engage in
+discovery. Finally, the delay occasioned by a stay would prejudice these Plaintiffs vis-à-vis other
+victims of Epstein who brought their claims in state court and would not be stayed, particularly if
+these other victims recover punitive damage judgments against Epstein before Plaintiffs have even
+had an opportunity to litigate their claims.
+Conclusion
+Based on the foregoing, Plaintiffs respectfully request that Defendant's Motions to Stay
+and/or Continue Action be denied in their entirety.
+Dated: April 23, 2009
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 7-
+
+
+Case 9:08-cv-80380-KAM Document 89 Entered on FLSD Docket 04/23/2009 Page 8 of 9
+CERTIFICATE OF SERVICE
+I hereby certify that on April 23, 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+- 8-
+
+
+Case 9:08-cv-80380-KAM Document 89
+Entered on FLSD Docket 04/23/2009 Page 9 of 9
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+/s/ Stuart S. Mermelstein
+- 9 -
diff --git a/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.receipt.json b/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a391026b986a8f4808b2ec5c49f905f748e9ae5f
--- /dev/null
+++ b/vision-fixhub/court-01/f397a57bbbcc10c8dc4f49235e71c95eac577e39fb289063fa6d2956d510dd7e.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "29c0edbdce537af44de9951b2b0bcad4f1f2c9172757306ac765542522a025d5",
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+}
diff --git a/vision-fixhub/court-01/f3a03137fdb1fa37d04fadf651fd2e621141f98932b4f9a341f5e53f0b9d532d.md b/vision-fixhub/court-01/f3a03137fdb1fa37d04fadf651fd2e621141f98932b4f9a341f5e53f0b9d532d.md
new file mode 100644
index 0000000000000000000000000000000000000000..8d041e80851c837d16ba5c2140836f0137ea2da0
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@@ -0,0 +1,190 @@
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE,
+Plaintiff,
+CASE NO. 08-CV-80893-CIV-MARRA/
+Vs.
+JEFFREY EPSTEIN, et al.
+Defendant.
+Related Cases:
+08-80119, 08-80232, 08-80380, 08-80381,
+08-80994, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFF JANE DOE'S MOTION FOR COURT ORDER RELEASING FBI
+RECORDS REGARDING JEFFREY EPSTEIN
+Plaintiff, Jane Doe, seeks a court order releasing FBI records about Jeffrey
+Epstein. Under the Privacy Act, 5 U.S.C. § 552a(b)(11), this Court is authorized to
+release these material. The FBI has advised Jane Doe that it will release the materials
+if this Court enters an appropriate order. Jane Doe seeks such an order.
+A brief bit of background may be in order. As the Court is well aware, Jane Doe
+has filed a civil damage action against Jeffrey Epstein for sexual abuse he inflicted upon
+her when she was child.
+To prove her case, Jane Doe has been attempting to
+undertake discovery from Epstein, only to be rebuffed at almost every turn by Epstein's
+invocation of his Fifth Amendment privilege against self-incrimination. See, e.g., No.
+
+
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 2 of 7
+9:08-CV-80893, Motion to Compel Answers to Plaintiff's First Request for Production,
+Dkt. #97 (listing discovery requests blocked by Fifth Amendment invocations).
+Because Epstein has been unwilling to answer questions, Jane Doe has been
+forced to search for other means of discovery. She understands, on information and
+belief, that the FBI gathered significant information about Epstein during the course of
+its criminal investigation of him for sexually abusing children. She seeks that
+information to help support her case against him. Accordingly, she has sent the
+attached subpoena to the FBI (Exhibit A).
+Jane Doe understands that some of the information that the FBI has gathered
+might contain the names of other young girls whom Epstein sexually abused and who
+are relevant witnesses to Jane Doe's case. Jane Doe has no wish to make the names
+of these potential witnesses public and will instead not disseminate those names to
+anyone outside of the undersigned's law office. For purposes of this specific motion
+only, Jane Doe identifies two persons as immediate employees (or co-conspirators as
+labeled in the Non-Prosecution agreement) of Epstein:
+and
+Both of these individuals have been directly and significantly involved in
+assisting Epstein abuse minor girls and therefore any related investigation into these
+individuals should also be made available. See Case No. 9:08-CV-80893, Civil RICO
+Case Statement,
+Dkt. #14, Attachment 1 (recounting Kellyn and
+involvement in the scheme).
+Because Jane Doe's request is narrowly circumscribed, it is clear that her
+interests in disclosure outweigh whatever limited privacy interests Jeffrey Epstein might
+2
+
+
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 3 of 7
+CASE NO: 08-CV-80119-MARRA/S
+have. Jane Doe needs the information to help prove her claims against Epstein. On
+the other hand, Epstein has no legitimate privacy interests in the records. The records
+simply chronicle the FBI's criminal investigation of Epstein for sexually abusing minor
+girls. Epstein has, in fact, entered a guilty plea to a related sex crime in a state criminal
+case. To further protect Epstein's privacy, Jane Doe has no objection to the materials
+being provided to counsel under a protective order, barring disclosure to any person
+other than attorneys and support staff working directly on the case. A proposed order to
+that effect is attached.
+CONCLUSION
+The Court should order release of FBI information about its criminal investigation
+of Jeffrey Epstein to Jane Doe and order a protective order limiting further disclosure of
+the materials.
+DATED: March 10, 2010
+Respectfully Submitted,
+S/
+J.
+J
+. JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-282
+Facsimile (954) 524-282
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+and
+3
+
+
+Case 9:08-cv-80119-KAM
+Document 486 Entered on FLSD Docket 03/10/2010 Page 4 of 7
+Paul G. Cassell
+Pro Hac Vice
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail:
+cassellp@law.utah.edu
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on March 10, 2010, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF. I also certify that the foregoing
+document is being served this day on all parties on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by
+CM/ECF or in some other authorized manner for those parties who are not authorized to
+J.
+SERVICE LIST
+Jane Doe V. Jeffrey Epstein
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+Jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Isidro Manual
+isidrogarcia@bellsouth.net
+Jack
+iph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+4
+
+
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 5 of 7
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerswillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Adam D. Horowitz
+ahorowitz@sexabuseattorney.com
+Stuart S. Mermelstein
+ssm@sexabuseattorney.com
+5
+
+
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 6 of 7
+CASE NO: 08-CV-80119-MARRA
+
+
+
+Case 9:08-cv-80119-KAM Document 486 Entered on FLSD Docket 03/10/2010 Page 7 of 7
+AO 88A (Rev. 01/09) Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of Florida
+Jane Doe
+Plaintiff
+V.
+Jeffrey Epstein
+Civil Action No. 08-80893CIV-MARRA/JOHNSO
+(If the action is pending in another district, state where:
+Defendant
+SUBPOENA TO TESTIFY AT A DEPOSITION
+OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION
+To: Records Custodian, Fedeal Bureau Investigators,
+C/OL
+n Coulter, 16320 Northwest 2nd Avenue, North Miami Beach, FL 33169
+• Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a
+deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate
+one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf
+about the following matters, or those set forth in an attachment:
+Place: Esquire Court Reporters, 44 West Flager Street
+14th Floor, Miami, FL 33130
+Date and Time:
+11/09/2009 1:00 am
+The deposition will be recorded by this method: _Recorded
+• Production: You, or your representatives, must also bring with you to the deposition the following documents,
+electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the
+material:
+Provide any and all evidence involving the Jeffrey Epstein investigation obtained by the FBI or taken from the Palm
+Beach Police Department and the Palm Beach County Sheriffs Office to include all videos, compact discs, DVD's,
+photographs, documentary evidence and any other evidence that the FBI seized from the Palm Beach P.D.or in any
+way relating to any investigation of Jeffrey Epstein
+The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule
+45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequence
+s of not doing so, are
+attached.
+Date:
+October 15, 2009
+CLERK OF COURT
+OR
+Signature of Clerk or Deputy Clerk
+Attorney's signature
+The name, address, e-mail, and telephone number of the attorney representing (name of party)
+Jane Doe
+Seth on rman
+, who issues or requests this subpoena, are:
+Brad
+Rothstein Rosenfeldt Adler, Suite 1650, 401 E. Las Olas Blvd. Fort Lauderdale, FL 33301.
+954 522 3456. Bedwards@RRA-law.com.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f3a03137fdb1fa37d04fadf651fd2e621141f98932b4f9a341f5e53f0b9d532d.receipt.json b/vision-fixhub/court-01/f3a03137fdb1fa37d04fadf651fd2e621141f98932b4f9a341f5e53f0b9d532d.receipt.json
new file mode 100644
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+}
diff --git a/vision-fixhub/court-01/f3a0ca50aa1e02fd3e5c6c4a815bee9dcf977723642b83c0edc29bf5d42c3144.md b/vision-fixhub/court-01/f3a0ca50aa1e02fd3e5c6c4a815bee9dcf977723642b83c0edc29bf5d42c3144.md
new file mode 100644
index 0000000000000000000000000000000000000000..e359bf019632883271cdd1d9bcceecd8e5ecc617
--- /dev/null
+++ b/vision-fixhub/court-01/f3a0ca50aa1e02fd3e5c6c4a815bee9dcf977723642b83c0edc29bf5d42c3144.md
@@ -0,0 +1,197 @@
+Case 9:08-CV-80232-KAM Document 113-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpsuchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans de Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. 1, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents another
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
+shame and retraumatization.
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintiffs do not hold their heads high with pride for having been sexually
+controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
+typical adolescent, into late adolescence and early adult years in the best of
+circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+
+
+Case 9:08-CV-80232-KAM Document 113-1 Entered on FLSD Docket 06/08/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintiffs as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+2
+
+
+Case 9:08-CV-80232-KAM Document 113-1 Entered on FLSD Docket 06/08/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a defensive means to manage overwhelming affects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+(C7) in their social, educational, vocational, relational plans. They are hypervigilant
+(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
+Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims'
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
+residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:08-CV-80232-KAM Document 113-1 Entered on FLSD Docket 06/08/2009 Page 4 of 5
+plaintiffs" identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:08-CV-80232-KAM Document 113-1 Entered on FLSD Docket 06/08/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely,
+Babel Kina 1D
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN <
+Сомм.# 1791115
+NOTARY PUBLIC-CALIFORNIA
+Or & COUNTY OF SAs FRANCISCO
+Mr CoNs. EXP. FEE. 27. 2012 T
+State of California, City & County of San Francisco
+Subscribed and sworn to (or affirmed) before me on this
+do o more, by Gilbert Kinceeu
+proved to me on the basis of sailstactory evidence
+I so so pace locker.
+5
diff --git a/vision-fixhub/court-01/f3a0ca50aa1e02fd3e5c6c4a815bee9dcf977723642b83c0edc29bf5d42c3144.receipt.json b/vision-fixhub/court-01/f3a0ca50aa1e02fd3e5c6c4a815bee9dcf977723642b83c0edc29bf5d42c3144.receipt.json
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diff --git a/vision-fixhub/court-01/f3ed2ac4be4aaa668203cb0e7882365739b5939adfbc0c4535d9f97ebf0f4902.md b/vision-fixhub/court-01/f3ed2ac4be4aaa668203cb0e7882365739b5939adfbc0c4535d9f97ebf0f4902.md
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@@ -0,0 +1,27 @@
+Case 9:08-cv-80994-KAM Document 69-2 Entered on FLSD Docket 06/09/2009 Page 1 of 1
+May 29, 2009
+Page 2
+Written Consent to Amendment
+I hereby consent to Defendant EPSTEIN's request to amend his affirmative
+defenses as set forth in his proposed Defendant EPSTEIN's First Amended Answer &
+Affirmative Defenses to Plaintiff's Second Amended Complaint in each of Plaintiffs,
+Jane Doe No.2, Jane Doe No.3, Jane Doe No.4, and Jane Doe No.5; and as set forth in
+Defendant EPSTEIN's First Amended Answer & Affirmative Defenses to Plaintiff's
+(First) Amended Compaint in Jane Doe No.6, and Jane Doe No.7.
+suite
+Counsel for each of the Plaintiffs
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+Jane Doe No. 2 v. Epstein, Case No. 08-80119
+Jane Doe No. 3 v. Epstein, Case No. 08-80232
+Jane Doe No. 4 v. Epstein, Case No. 08-80380
+Jane Doe No. 5 v. Epstein, Case No. 08-80381
+Jane Doe No. 6 v. Epstein, Case No. 08-80994
+Jane Doe No. 7 v. Epstein, Case No. 08-80993
+Dated:
+June 5, 2009
+
diff --git a/vision-fixhub/court-01/f3ed2ac4be4aaa668203cb0e7882365739b5939adfbc0c4535d9f97ebf0f4902.receipt.json b/vision-fixhub/court-01/f3ed2ac4be4aaa668203cb0e7882365739b5939adfbc0c4535d9f97ebf0f4902.receipt.json
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diff --git a/vision-fixhub/court-01/f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f.md b/vision-fixhub/court-01/f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f.md
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@@ -0,0 +1,129 @@
+Case 9:09-cv-80469-KAM Document 3 Entered on FLSD Docket 03/25/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case #09-80469-CIV-RYSKAMPIVITUNAC
+Jane Doe II
+Plaintiff
+VS.
+Jeffrey Epstein &
+Defendant
+ORDER OF PRETRIAL PROCEDURES
+This Order has been entered upon the filing of the Complaint. Plaintiff's counsel is hereby
+ORDERED to forward to all defendants, upon receipt of a responsive pleading, a copy of this Order.
+The Court directs the parties to review and comply with all Federal Rules of Civil Procedure
+governing pretrial procedures, and with all relevant general rules promulgated in the Southern
+District of Florida, including S.D. Fla. LR 26.1 and 16.1. The parties shall hold a scheduling
+meeting within twenty (20) days after the filing of the first responsive pleading by the last
+responding defendant, or within ninety (90) days after the filing of a complaint, whichever shall first
+occur, and prepare a scheduling report (that complies with Rule 16.1(B)(2)) and a joint proposed
+Scheduling Order (sample attached), which shall be submitted to the court. A copy of the joint
+proposed Scheduling Order shall also be submitted in Word or WordPerfect format to
+Ryskamp@flsd.uscourts.gov (see the Court's internet site, CM/ECF Administrative Procedures).
+At the aforementioned scheduling meeting the parties shall fulfill all the purposes and requirements
+of the discovery planning meeting required by Fed. R. Civ. P. 26(f), as amended.
+FAILURE OF COUNSEL TO FILE A SCHEDULING REPORT WILL RESULT IN
+DISMISSAL, DEFAULT AND THE IMPOSITION OF OTHER SANCTIONS INCLUDING
+ATTORNEYS FEES, COSTS AND EXPENSES. See S.D. Fla, LR 16.1(M)
+DONE AND ORDERED in
+at West Palm Beach, Florida, this 25th day of March,
+2009.
+JS/ Kenneth L. Ryskamp
+KENNETH L. RYSKAMP
+UNITED STATES DISTRICT JUDGE
+CC: Counsel of Record
+
+
+Case 9:09-cv-80469-KAM Document 3 Entered on FLSD Docket 03/25/2009 Page 2 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case #09-80469-CIV-RYSKAMP
+Jane Doe II
+Plaintiff
+VS.
+Jeffrey Epstein &
+Defendant
+SAMPLE
+SCHEDULING ORDER
+Pursuant to Local Rule 16.1(b)(7), IT IS ORDERED AND ADJUDGED as follows:
+1. No pretrial conference shall be held in this action, unless the parties so request or the
+Court determines, sua sponte, that a pretrial conference is necessary. Should a pretrial conference
+be set, the compliance deadlines as set forth in the remainder of this Order shall remain unaltered.
+2. Counsel shall meet at least ONE MONTH prior to the beginning of the trial calendar to
+confer on the preparation of a pretrial stipulation.
+3. The joint pretrial stipulation shall be filed on or before the date set forth in the attached
+Notice of Trial and shall conform to Local Rule 16.1(e). The Court will not allow unilateral pretrial
+stipulations.
+4. In cases tried before a jury, each party shall file the proposed jury instructions at least
+ONE WEEK prior to the beginning of the trial calendar. Additionally, one copy of the proposed jury
+instructions shall be sent in Word or WordPerfect format to Ryskamp@flsd.uscourts.gov. Each jury
+instruction shall be typed on a separate sheet and must be supported by citation of authority. In
+preparing their requested jury instructions, the parties shall utilize as a guide the Pattern Jury
+Instructions for civil cases approved by the United States Eleventh Circuit, including the Directions
+to Counsel contained therein. At the close of the evidence, a party may file additional instructions
+covering matters occurring at the trial that could not reasonably be anticipated, and with the Court's
+permission, file untimely requests for instructions on any issue.
+1
+
+
+Case 9:09-cv-80469-KAM Document 3 Entered on FLSD Docket 03/25/2009 Page 3 of 4
+5. In cases tried before the Court, each party shall file the proposed findings of fact and
+conclusions of law at least ONE WEEK prior to the beginning of the trial calendar. Proposed
+conclusions of law shall be supported by citations of authority.
+6. All exhibits must be pre-marked. The plaintiff and defendant shall both mark their
+exhibits numerically. A typewritten exhibit list setting forth the number, and description of each
+exhibit shall be submitted at the time of trial. The parties shall submit said exhibit list on Form AO
+187, which is available from the Clerk's office. All electronically filed exhibits should be listed as
+one attachment unless over 5mb (100 pages).
+7. A motion for continuance shall not stay the requirement for the filing of a pretrial
+stipulation and, unless an emergency situation arises, a motion for continuance will not be considered
+unless it is filed at least twenty (20) days prior to the date on which the trial calendar is scheduled
+to commence.
+8. Non-compliance with any provision of this order may subject the offending party to
+sanctions or dismissal. It is the duty of all counsel to enforce the timetable set forth herein in
+order to insure an expeditious resolution of this cause.
+9. The following timetable shall govern the pretrial procedure in this case. This schedule
+shall not be modified absent compelling circumstances.
+*
+Joinder of additional parties and amended pleadings
+*
+Plaintiff shall furnish opposing counsel with a written list containing
+the names and addresses of all expert witnesses intended to be called
+at trial and only those expert witnesses listed shall be permitted to
+testify. Within the 14 day period following this disclosure, the
+plaintiff shall make its experts available for deposition by the
+defendant. The experts' depositions may be conducted without
+further order from the Court.
+Defendant shall furnish opposing counsel with a written list
+containing the names and addresses of all expert witnesses intended
+to be called at trial and only those expert witnesses listed shall be
+permitted to testify. Within the 14 day period following this
+disclosure, the defendant shall make its experts available for
+deposition by the plaintiff. The experts' depositions may be
+2
+EFTA02750321R
+
+Case 9:09-cv-80469-KAM Document 3 Entered on FLSD Docket 03/25/2009 Page 4 of 4
+Parties shall furnish opposing counsel with a written list containing
+the names and addresses of all witnesses intended to be called at trial
+and only those witnesses listed shall be permitted to testify.
+All discovery must be completed.
+All pretrial motions and memoranda of law must be filed.
+(No later than one month after the close of discovery)
+*(insert a specific date -- e.g. "October 1, 2009" -- not "30 days prior to ete.")
+Pretrial Stipulation required by Local Rule 16.1.E shall be filed by
+This case is assigned to the
+This is a
+. track.
+_trial.
+(Jury or Non-Jury)
+10. Trial date and calendar call will be set by separate notice.
+11. If this case is settled, counsel are directed to inform the Court promptly by calling
+_and submitting an appropriate order for dismissal, within ten (10) days of notification of
+settlement to the Court, pursuant to Fed. R. Civ. P. 41(a)(1).
+Dated this
+_ day of
+, 2009.
+KENNETH L. RYSKAMP
+United States District Judge
+copies provided:
+3
diff --git a/vision-fixhub/court-01/f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f.receipt.json b/vision-fixhub/court-01/f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..78a8b9c42f1b5e945238a1e51d3a08c45fb78810
--- /dev/null
+++ b/vision-fixhub/court-01/f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f.receipt.json
@@ -0,0 +1,14 @@
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+  "dataset": "marble-joined",
+  "doc_id": "f403a0cc9dae47ceac4fbc2cd4f262150eeef83bf8d25c5ad1d52582d981532f",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d537606218b80498adb3b0697cb0161cedb54a33d3d0606844fc267d1411e83d",
+  "output_sha256": "4f8d054b167194f29ef1f080ab5a8077733f44a3ef49d11439dde92abda21ca1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.md b/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.md
new file mode 100644
index 0000000000000000000000000000000000000000..e15e259a4dd9dd2672136be8c1b3f0790d4589bb
--- /dev/null
+++ b/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.md
@@ -0,0 +1,278 @@
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 101,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF JANE DOE NO. 101'S RESPONSE TO DEFENDANT'S
+MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED COMPLAINT AS MODIFIED
+BY DEFENDANT'S NOTICE OF WITHDRAWAL OF ARGUMENTS I THROUGH VII
+OF DEFENDANT'S MOTION TO DISMISS PLAINTIFF'S FIRST AMENDED
+COMPLAINT
+Plaintiff, Jane Doe No. 101, by and through her undersigned attorneys, hereby responds
+to Defendant's Motion to Dismiss Plaintiff's First Amended Complaint [D.E. 29] ("Motion"), as
+modified by Defendant's Notice of Withdrawal [D.E. 53] ("Notice of Withdrawal") of
+Arguments I Through VII of Defendant's Motion to Dismiss Plaintiff's First Amended
+Complaint and, as grounds, states as follows:
+Pleading Standard & Summary of Argument
+It is well settled in the context of a civil action that a valid complaint requires only "a short and
+plain statement of the claim showing that the pleader is entitled to relief." Fed. R. Civ. P.
+8(a)(2). Defendant improperly attempts to heighten this standard through his characterization of
+this action as one that is essentially criminal and punitive in nature. Such a characterization is
+inappropriate, as this is a civil action that seeks only compensatory damages for the violation of
+certain of the predicate offenses of Section 2255 of Title 18 of the U.S. Code as set forth in the
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 2 of 10
+First Amended Complaint ("FAC'") [D.E. 9]. Accordingly, notice pleading is all that is required.
+Lombard's, Inc. v. Prince Mfg., Inc., 753 F.2d 974, 975 (11th Cir. 1985).
+Under notice pleading, the plaintiff need only provide the defendant fair notice of his
+claim and the grounds upon which it rests. See Erickson v. Pardus, 127 S. Ct. 2197, 2200
+(2007). As this is a liberal pleading requirement, "Is]pecific facts are not necessary; the
+statement need only 'give the defendant fair notice of what the...claim is and the grounds upon
+which it rests."" Id. (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 545 (2007)) (internal
+citation omitted). In considering a motion to dismiss, a court places a "very high burden" on a
+defendant to show that a "plaintiff cannot conceivably prove any set of facts that would entitle
+him to relief."
+v. Deloitte & Touche et al., 144 F.3d 732, 735-36 (11th Cir. 1998); accord
+H.J. Inc. v. Nw. Bell Tel. Co., 492 U.S. 229, 249-50 (1989). The FAC satisfies the
+aforementioned pleading requirements.
+I.
+REQUIRING MERGER OF EACH SEPARATE STATUTORY PREDICATE
+OFFENSE INTO ONE SINGLE COUNT WOULD BE IMPROPER.
+A. Pleading of Multiple Counts Under 18 U.S.C. § 2255 Is Proper.
+In his motion, Defendant argues that the multiple counts of the FAC should be merged
+into a single count. Defendant improperly asserts:
+Contrary to Plaintiff's attempt to multiply her recovery by asserting
+six separate counts, [18 U.S.C.] § 2255, creates a single cause of action with a single penalty for all violations of a predicate offense, not
+separate causes of action and separate recoveries on a "per violation"
+basis.
+(Motion 34). In so contending, Defendant both confuses and incorrectly advances two distinct
+propositions: first, that pleading a separate count for each violation of a predicate offense as set
+2
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+www.padhurst.com
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 3 of 10
+forth in Section 2255 of Title 18 is improper; and second, that all violations of a particular
+predicate offense must be pled as a single cause of action to provide for a single recovery, even
+where multiple violations of that particular predicate offense may exist.
+In connection with Defendant's first proposition, a plain reading of Section 2255
+demonstrates that this civil remedies statute applies individually to each numerated predicate
+offense and establishes the minimum amount of civil damages available to a qualifying victim
+for each violation. Specifically, 18 U.S.C. Section 2255 provides:
+(a) In General. - Any person who, while a minor, was a victim of a
+violation of section 2241(c), 2242, 2243, 2251, 2251A, 2252, 2252A,
+2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a
+result of such violation, regardless of whether the injury occurred while
+such person was a minor, may sue in any appropriate United States
+District Court and shall recover the actual damages such person sustains
+and the cost of the suit, including a reasonable attorney's fee. Any person
+as described in the preceding sentence shall be deemed to have sustained
+damages of no less than $150,000 in value.'
+18 U.S.C. § 2255(a) (2008). Nowhere does the above statutory text require that the violation of
+the specified federal statutes be pled as a single count. Section 2255 provides a civil remedy for
+a violation of each of the predicate offenses, and does not, as Defendant maintains, preclude
+multiple counts from being pled pursuant to its terms. For each predicate offense that Defendant
+committed, Section 2255 should apply independently and uniquely to properly determine the
+minimum amount of civil damages to be awarded for such offense. To adopt the contrary
+approach is to suggest that a victim of a violation of a single predicate offense receive the same
+compensation as a victim of multiple enumerated predicate offenses. The statute's language, as
+'July 27, 2006, approximately two years before Defendant pled guilty to state criminal offenses and signed the
+Non-Prosecution Agreement, Public Law 109-248, the Adam Waish Child Protection and Public Safety Act, became
+law and raised the statutory minimum for damages under 18 U.S.C. Section 2255 from $50,000.00 to $150,000.00.
+3
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 4 of 10
+well as principles of equity, provide for recovery for each separate predicate offense; to interpret
+the statute as Defendant proposes would mean that Congress granted defendants who violate a
+predicate offense the ability to violate additional predicate offenses without any accountability.
+This was not Congress' intent.
+The underlying approach to statutory interpretation or construction in Florida is set forth
+in A.R. Douglass, Inc., v. McRainey, 137 So. 157 (Fla. 1931):
+The intention and meaning of the Legislature must primarily be
+determined from the language of the statute itself and not from
+conjectures aliunde. When the language of the statute is clear and
+unambiguous and conveys a clear and detinite meaning, there is no
+occasion for resorting to the rules of statutory interpretation and
+construction; the statute must be given its plain and obvious
+meaning.
+Id. at 159. A review of the wording of Section 2255 unambiguously demonstrates that the
+statute provides damages for both multiple violations of a single predicate act as well as
+multiple violations of separate predicate acts. In its current form, the statute allows "[a]ny
+person who, while a minor, was a victim of a violation of section 2241(c), 2242, 2243, 2251,
+2251A, 2252, 2252A, 2260, 2421, 2422, or 2423 of this title and who suffers personal injury as a
+result of such violation" to recover damages in an amount of not less than $150,000.00. 18
+U.S.C. § 2255(a) (emphasis added). This statute is properly read to apply the damage floor of
+Section 2255 to each violation of a predicate offense. Defendant's assertion that the above
+statute only permits a single recovery based on a single cause of action would require that the
+statute be rewritten to eliminate the use of the article "a" and to make plural all singular usages
+of the word "violation."
+'See Section I. B. of this Reply in support of the pleading of multiple violations of a predicate offense.
+4
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 5 of 10
+The statute, however, was not written in this manner, and where the statute as currently
+constructed is unambiguous in its meaning, judicial interpretation of the statute would be
+improper. See Heredia v. Allstate Insurance Company, 358 So.2d 1353 (Fla. 1978) (explaining
+that "[w]here the words selected by the Legislature are clear and unambiguous..judicial
+interpretation is not appropriate to displace the expressed intent").
+In the instant case, where Defendant violated multiple predicate offenses in his sexual
+exploitation of Plaintiff, it is proper to plead each violation as a separate count and seck damages
+under each count in accordance with Section 2255.
+B. Pleading of Multiple Violations of a Predicate Offense Under 18 U.S.C. § 2255 Is
+Proper.
+Defendant continues his self-serving interpretation of Section 2255 through the
+advancement of his second proposition. Similar to the above argument that the violation of
+several predicate offenses should be pled as one count, Defendant argues that, when multiple
+violations of a single predicate offense occur, a victim's recovery on a "per violation" basis is
+prohibited. Again, Defendant's contention fails on the basis of a common sense reading of the
+statute and principles of fairness. Just as it makes no sense to compensate a victim of a violation
+of a single predicate offense with exactly the same amount as a victim of a violation of multiple
+predicate offenses, it is equally unsustainable to argue that a victim of multiple violations of a
+predicate offense should receive the same damage award as a victim of only a single violation of
+that same offense. To maintain otherwise is to eliminate the deterrent value of the statutory
+scheme by allowing a defendant to continue to victimize a child without any additional
+consequences subsequent to such defendant's first violation of the relevant predicate act.
+5
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 6 of 10
+Defendant argues that, "where actual damages were less than [the threshold amount] or
+otherwise impossible to prove, the statute would guarantee a lump-sum, make-whole penalty of
+[the threshold amount] for all injuries sustained as a result of the predicate acts." (Motion 35).
+Defendant fails to provide any support for this contention, either in the case law, legislative
+history, or otherwise.
+First, Defendant incorrectly states the amount of the "make-whole"
+penalty. The statute unambiguously provides that "[a]ny person as described in the preceding
+sentence shall be deemed to have sustained damages of no less than [the threshold amount]. " 18
+U.S.C. § 2255(a) (2008). As such, the threshold amount is a floor, and not a ceiling, on the
+amount of damages that can be awarded for a violation of each predicate offense. Consequently,
+in the instant case, even if all violations of the predicate offenses, as well as all violations of a
+single predicate offense, were merged into a single cause of action, the recovery would not be
+limited to the minimum threshold damage award.
+Relevant case law provides support for holding Defendant accountable for each time he
+violated any of the enumerated predicate offenses. In United States v. Esch, 832 F.2d 531, 541
+(10th Cir. 1987), the court established that a determination of the correct unit of prosecution for
+violation of a statute "focuses in part on the identification of the key element of the federal
+offense." In Esch, the defendants were convicted on sixteen counts of sexual exploitation of
+children for photographs taken in violation of Title 18, Section 2251 of the U.S. Code. Id. at
+533. The court held that the indictment properly charged separate counts' for each of the
+photographs produced. Id. at 533, 542. Specifically, the court noted that the charging of
+'Note that although Defendant contends that all predicate violations of predicate offenses, as well as multiple
+violations of a single predicate offense, should be pled as a single cause of action with only a single recovery, Esch
+stands for the contrary view.
+6
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miam: 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 7 of 10
+separate offenses was warranted where "[elach photograph depended upon a separate and
+distinct use of the children" in violation of the key element of the offense. Id. at 542; see also
+Ebeling v.
+237 U.S. 625, 629 (1915) (charging the defendant with a separate count for
+each mail bag cut open in violation of the statutory offense, despite the transaction being "in a
+sense continuous"); United States v. Gallardo, 915 F.2d 149, 151 (5th Cir. 1990) (explaining that
+"each separate use of the mail to transport or ship child pornography should constitute a separate
+crime because it is the act of either transporting or shipping that is the central focus of [18
+U.S.C. § 2252(a)(1)(A), a predicate] statute").
+Notwithstanding that the foregoing jurisprudence involved criminal prosecution for the
+violation of predicate offenses, because Section 2255 exists to provide civil remedies for those
+predicate offenses, Defendant's contention that a plaintiff seeking recourse under Section 2255
+cannot assert a claim on a "per violation" basis is without merit. It is simply illogical to assert,
+as Defendant does, that multiple counts and violations can be charged in the criminal context,
+but that, in a civil action under Section 2255 for those same violations, all counts and violations
+must be lumped together as one with a single penalty.
+Multiple counts are proper, as shown, for example, in Tilton v. Playboy Entertainment
+Group, Inc., 554 F.3d 1371, 1375 (11th Cir. 2009), on which Defendant relies in his Motion.
+(Motion 34). In Tilton, the court did not prohibit the plaintiff from seeking separate damages
+against several defendants based on a single incident for violations of three predicate offenses
+under Section 2255: §§ 2251(a), 2252(a), and 2252(A)(a). Id. Although the counts brought
+under Sections 2252(a) and 2252(A) were deemed to be duplicative by the court and thus were
+merged, the plaintiff was, nevertheless, able to recover on the two remaining counts and was
+7
+25 West Flagler Street, Suite 800, Miami, FL. 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 8 of 10
+awarded civil damages for each pursuant to 18 U.S.C. Section 2255. Furthermore, Defendant's
+reliance on Tilton to claim that multiple alleged violations of a single predicate offense have
+never been allowed is misplaced; this case involved only a single violation of a predicate statute.
+Moreover, Defendant's reliance on its own Doe vs. Epstein line of cases is, at a minimum,
+premature.
+Accordingly, in the instant case, not only was it proper for Plaintiff to plead multiple
+counts in the FAC for the violation of cach predicate statute identified therein, but also, this
+Court should assess civil damages under Section 2255 for each violation of a particular predicate
+statute. Defendant's argument is unsupported by case law and is nothing more than a blatant
+attempt to limit Plaintiff's potential recovery as a victim of Defendant's multiple acts of sexual
+exploitation and abuse.
+Dated this 26 day of June, 2009.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By: s/Katherine W. Ezell
+Robert C. Josefsberg,
+Fila. Bar No. 040856
+tjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+25 West Flagler Street, Suite 800
+Miami, Florida 33130
+(305) 358-2800
+(305) 358-2382 (fax)
+8
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 305.358.2800 Fax 305.358.2382 • Fort Latderdale 954.463.4346
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 9 of 10
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this 26th day of June, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the
+foregoing document is being served this day on all counsel of record identified on the attached
+Service List either via transmission of Notices of Electronic Filing generated by CM/ECF or in
+some other authorized manner for those counsel or parties who are not authorized to receive
+electronically Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiff
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+josefsberg@podhurst.con
+Catherine W. Ezel
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+9
+25 West flagler Stret, Suite 80, Miami, F1. 3130, Miami 305.582800 Rax 305.358.2382 • Fort Lauderdale 514634346 T
+
+
+Case 9:09-cv-80591-KAM Document 56 Entered on FLSD Docket 06/26/2009 Page 10 of 10
+SERVICE LIST
+JANE DOE NO. 101 v. JEFFREY EPSTEIN
+Case No. 08-CV-80591-MARRA/
+United States District Court, Southern Distriet of Florida
+Robert Critton Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+rcrit@bclclaw.com
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+jagesq@bellsouth.net
+10
+25 West Flagler Street, Suite 800, Miami, FL 33130, Miami 306.358.2800 Fax 305.358.2382 • Fort Lauderdale 954.463.4346
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.receipt.json b/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..50ec366575a5bf0b7af502dbf0637a6709622d50
--- /dev/null
+++ b/vision-fixhub/court-01/f4210318e130d9ac559f42b74cb830068f16a4bfa5491a50830608675012fef6.receipt.json
@@ -0,0 +1,14 @@
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+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
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+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.md b/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.md
new file mode 100644
index 0000000000000000000000000000000000000000..ecda9f848361821204309565c50290ea58ec8b0a
--- /dev/null
+++ b/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.md
@@ -0,0 +1,77 @@
+Case 1:20-cv-00484-JGK-DCF Document 109 Filed 05/27/21 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+X
+JANE DOE,
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as executors of
+the ESTATE OF JEFFREY E. EPSTEIN,
+GHISLAINE MAXWELL, an individual,
+Defendants.
+20-cv-00484-JGK
+X
+DEFENDANT GHISLAINE MAXWELL'S NOTICE OF APPLICATION
+FOR COSTS SOUGHT AGAINST PLAINTIFE
+PLEASE TAKE NOTICE that, upon Defendant Ghislaine Maxwell's Bill of Costs, the
+exhibits annexed thereto, the Affidavit of Laura A. Menninger dated May 27, 2021, and all other
+pleadings and proceedings herein, the Defendant will move this Court before the Orders and
+Judgment Clerk, at the United States Courthouse for the Southern District of New York, located
+at 500 Pearl Street, Room 250, New York, NY 10007 on June 11, 2021 at 11:30 am, or as soon
+thereafter as counsel may be heard, at a time and date to be determined as convenient for the
+Court, for an order pursuant to Rule 54 of the Fed. R. Civ. P., Local Civil Rule 54.1, and 28
+U.S.C. §§ 1920 and 1923, granting fees and costs sought by Ms. Maxwell and granting such
+other relief that this Court deems proper.
+Dated: May 27, 2021
+New York, New York
+
+
+Case 1:20-cv-00484-JGK-DCF Document 109 Filed 05/27/21 Page 2 of 3
+Respectfully submitted,
+s/ Laura A. Menninger
+Laura A. Menninger (LM-1374)
+HADDON,
+AND
+150 East 10"" Avenue
+Denver, CO 80203
+Phone: 303.831.7364
+Fax:
+303.832.2628
+Imenninger@hmflaw.com
+Attorneys for Ghislaine Maxwell
+P.C.
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 109 Filed 05/27/21 Page 3 of 3
+CERTIFICATE OF SERVICE
+I certify that on May 27, 2021, I electronically filed the foregoing Defendant Ghislaine
+Maxwell's Notice of Application for Costs Sought Against Plaintiff on with the Clerk of Court
+using the CM/ECF system which will send notification of such filing to the following:
+Kevin Boyle
+Robert Glassman
+Panish, Shea & Boyle
+11111 Santa Monica Blvd., Ste 700
+Los Angeles, CA 90025
+boyle@psblaw.com
+glassman@psblaw.com
+Bennet J. Moskowitz
+Charles L. Glover
+Mary L
+W. Metcalfe
+Troutman Pepper
+Sanders LLP
+875 Third Avenue
+New York, NY 10022
+bennet.moskowitz@troutman.com
+charles.glover@troutman.com
+marygrace.metcalfe@troutman.com
+Molly S. DiRago
+Troutman Pepper
+Sanders LLP
+227 W. Monroe Street, Suite 3900
+Chicago, IL 60606
+molly.dirago@troutman.com
+s/ Nicole
+2
diff --git a/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.receipt.json b/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..896c14ca5635abae9dc980eb566a30e3519643f0
--- /dev/null
+++ b/vision-fixhub/court-01/f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "f42328ea866f0bfb710c27394468d25bfdb3c31a8af3629ef0828a566a7d7622",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cdf6e393bb904454254ae1269128720a2f5e9b81b2f6654f565d92890571f3d3",
+  "output_sha256": "4c08b12d2e5f5872e15c80f012c28ac7fef9fd2bc023eb8287422d4f3ad95b2a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.md b/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.md
new file mode 100644
index 0000000000000000000000000000000000000000..e807cff96876f20efc6571d0c9a8403042bdc152
--- /dev/null
+++ b/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.md
@@ -0,0 +1,279 @@
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+CASE NO.: 08-CV-80119-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+CASE NO.: 08-CV-80380-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 2 of 10
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 3 of 10
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 09-CV-80591-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 128 |
+Entered on FLSD Docket 05/29/2009 Page 4 of 10
+JANE DOE NO. 102,
+CASE NO.: 09-CV-80656-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOE NO. 101 AND JANE DOE NO. 102's MOTION FOR
+LEAVE TO FILE UNDER SEAL RESPONSE IN OPPOSITION TO
+DEFENDANT'S MOTION TO STAY OR. IN THE ALTERNATIVE, TO UNSEAL
+THE NONPROSECUTION AGREEMENT
+Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the
+Southern District of Florida, Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together,
+the "Plaintiffs") by and through their undersigned attorneys, hereby file this Motion For
+Leave to File Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Response in
+Opposition to Defendant's Motion to Stay and/or Continue Action for Time Certain
+Based on Parallel Civil and Criminal Proceedings With Incorporated Memorandum of
+Law Under Seal, and, as grounds, state as follows:
+Undersigned counsel seek to file this Response in Opposition to Defendant
+Jeffrey Epstein's Motion to Stay under seal in order to abide by this Court's August 21,
+2008 Order to Compel Production and Protective Order entered in Case No. 08-80736-
+CIV-MARRA
+(the "Protective Order"). The Protective Order prohibits
+Plaintiffs from disclosing the Non-Prosecution Agreement (the "NPA") or its terms to
+any third party.
+The sealed document should be maintained under seal for the duration
+of this Court's August 21, 2008 Protective Order.
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 5 of 10
+2.
+Undersigned counsel recognize that this Court has previously unsealed
+documents referring to the NPA. We seek to comply with the Protective Order for this
+new and independent filing in an abundance of caution, until directed otherwise by the
+Court.
+3.
+If this Court denies Plaintiffs' instant motion, Plaintiffs seek appropriate
+disclosure of the NPA pursuant to this Court's recent order in Case No. 08-80736-CIV-
+MARRA
+(DE #36) denying Plaintiffs Jane Doe No. 1 and Jane Doe No. 2's
+motion to unseal the NPA. As stated in that Order, the NPA has not been filed with the
+Court. Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 would then have "a specific
+tangible need to be relieved of the restrictions" of the Protective Order because
+consideration of the terms of the NPA is necessary for this Court to resolve Defendant's
+Motion to Stay.
+WHEREFORE,
+1. Plaintiffs respectfully request this Court to enter an Order granting
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 the right to file under seal their
+Response in Opposition to Defendant's Motion to Stay and/or Continue Action for Time
+Certain Based on Parallel Civil and Criminal Proceedings With Incorporated
+Memorandum of Law.
+In the alternative, Plaintiffs respectfully request this Court to unseal the
+Non-Prosecution Agreement in order to allow Plaintiffs to concretely respond to
+Defendant's Motion to Stay.
+3.
+Finally, Plaintiffs respectfully request this Court to grant such other and
+further relief to which this Court finds the Plaintiff otherwise entitled.
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 6 of 10
+Date: May 29, 2009
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+On May 29, 2009, undersigned counsel conferred with counsel for Defendant in a
+good faith effort to resolve the issues raised in this motion, and Defendant's counsel
+advised that Defendant opposes this motion.
+Date: May 29, 2009
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 7 of 10
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that, on this 29th day of May, 2009, we electronically
+filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify
+that the foregoing document is being served this day on all counsel of record identified on
+the attached Service List either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those counsel or parties who are not
+authorized to receive electronically Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:08-cv-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 8 of 10
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:08-cV-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 9 of 10
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10" Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards @rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+
+
+Case 9:08-cV-80119-KAM Document 128 Entered on FLSD Docket 05/29/2009 Page 10 of 10
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.receipt.json b/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..07007bba701251e12f39da7688b84145c923b509
--- /dev/null
+++ b/vision-fixhub/court-01/f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -375,
+  "dataset": "marble-joined",
+  "doc_id": "f43d0685f5f7d6e6495c3237dccdfeb811583b2a9652c79aef8b69222125c5f2",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "72194a38f40a4f1ee7f236e493a13ae312e9671abd15f0654f257814d91f7cb4",
+  "output_sha256": "3c193f91a92d5fd3f176ae339ccb3b05cc00e8279444db12ef28af70f81a89f3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.md b/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.md
new file mode 100644
index 0000000000000000000000000000000000000000..f01690ba97469594770313baac53bb41a7bfa41e
--- /dev/null
+++ b/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.md
@@ -0,0 +1,177 @@
+Filing # 150271584 E-Filed 05/25/2022 11:16:54 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+CIRCUIT CIVIL DIVISION: AG
+CA FLORIDA HOLDINGS LLC PUBLISHER OF THE PALM BEACH POST,
+Plaintiff/Petitioner
+VS.
+DAVE ARONBERG,
+SHARON R BOCK,
+Defendant/Respondents.
+ORDER RESETTING LENGTHY HEARING ON NON-JURY DOCKET
+THIS CAUSE came before the Court upon the lengthy hearing on the Evidentiary Hearing
+on Dave Aronberg's Amended Motion for Attorneys' Fees not getting reached on a previous
+docket. After review it is
+ORDERED AND ADJUDGED that the hearing is rescheduled to be held sometime
+betweenJULY 5, 2022 AND SEPTEMBER. 9, 2022 (10-WEEK DOCKET).
+CALENDAR CALL is set for JUNE 10, 2022 at 09:00 AM. APPEARANCE AT
+CALENDAR CALL IS REQUIRED. The court will be moving forward with
+this calendar call via phone/video conference. At 9:00 a.m., please dial in using the
+following conference call information.
+YOU SHOULD NOT COME TO THE COURTHOUSE.
+The Calendar Call will be conducted via PHONE/VIDEO conference (ZOOM).
+Zoom Meeting Link:
+https://us02webzoom.us/j/85056337361
+Meeting ID: 85056337361
+Dial-in Information
++1 8884754499 US Toll-Free
++1 8778535257 US Toll-Free
+To Join Zoom Hearing: Download the Zoom app https://zoom.us/ on your device, prior to
+the hearing. At the time of hearing, log in to Zoom from your device. The 10-Week
+Docket will be posted on the Court's website (15thcircuit.com) on the Division AG online
+Time reserved for hearing: 2 hours.
+FILED: PALM BEACH COUNTY, FL,
+
+| ABRUZZO, CLERK, 05/25/2022 11:16:54 AM
+
+
+The trial will be scheduled sometime during the calendar, at a date and time to be
+provided at the calendar call, subject to the court's ordering a later case setting.
+DONE AND ORDERED in
+Florida.
+at West Palm Beach, Palm Beach County,
+50-2019-CA:01468)
+DONE 225203RCUIT
+Donald Hatele. Circuit Judge-
+ARMINI
+IVF. OFFICE OF THE GOIRT
+50-2019-CA-014681-XXXX-MB
+05/25/2022
+Donald Hafele
+Circuit Judge
+COPIES TO:
+COLLIN D.
+No Address Available
+P.O. BOX 229
+WEST PALM BEACH, FL
+33401
+No E-mail Address Available
+clerk_e-
+service@mypalmbeachclerk.co
+m
+eservice@mypalmbeachclerk.c
+om
+cdjackson@mypalmbeachclerk.
+com
+Clerk e-
+service@mypalmbeachclerk.co
+m
+doug.wyler@comcast.net
+CYNTHIA M GUERRA
+No Address Available
+DOUGLAS A. WYLER
+961687 GATEWAY BLVD
+SUITE 201-1
+FERNANDINA BEACH, FL
+32034
+JAMES CULLEN MOONEY No Address Available
+JESSICA NEER
+MCDONALD
+POST OFFICE BOX 229
+WEST PALM BEACH, FL
+33401
+KENNETH G. TURKEL
+No Address Available
+jmooney@tcb-law.com
+garold@tcb-law.com
+service@tcb-law.com
+CLERK_E-
+SERVICE@MYPALMBEACH
+CLERK.COM
+jnmedonald@mypalmbeachclerk
+.com
+kturkel@tcb-law.com
+garold@tcb-law.com
+service@tcb-law.com
+
+
+
+LAUREN R. WHETSTONE 777 S FLAGLER DR
+STE 300 E
+WEST PALM BEACH, FL
+33401
+MARK F. BIDEAU
+No Address Available
+MICHAEL GRYGIEL
+MICHAELJ. GRYGIEL
+NINA D. BOYAJIAN
+NINA D. BOYAJIAN
+SHANE B. VOGT
+54 STATE STREET
+6TH FLOOR
+ALBANY, NY 12207
+No Address Available
+1840 CENTURY PARK
+EAST
+SUITE 1900
+LOS ANGELES, CA 90067
+No Address Available
+No Address Available
+STEPHEN A.
+MENDELSOHN, ESQ
+5100 TOWN CENTER CIR
+SUITE 400
+BOCA RATON, FL 33486
+NOT A
+
+WHETSTONEL@GTLAW.CO
+M
+flservice@gtlaw.com
+sandra.famadas@gtlaw.com
+bideaum@gtlaw.com
+thomasd@gtlaw.com
+FLService@gtlaw.com
+GRYGIELM@GTLAW.COM
+grygielm@gtlaw.com
+No E-mail Address Available
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+svogt@tcb-law.com
+garold@tcb-law.com
+service@tcb-law.com
+mendelsohns@gtlaw.com
+smithl@gtlaw.com
+flservice@gtlaw.com
+
+
+This notice is provided pursuant to Administrative Order No. 2.207
+"If you are a person with a disability who needs any accommodation
+in order to participate in this proceeding, you are entitled, at no cost to
+you, to the provision of certain assistance. Please contact the Disabilities
+Act Coordinator at the Palm Beach County Courthouse, 205 North Dixie
+Highway West Palm Beach, Florida 33401; telephone number (561) 355-
+4380 at least 7 days before your scheduled court appearance, or
+immediately upon receiving this notification if the time before the
+scheduled appearance is less than 7 days. If you are hearing or voice
+impaired, call 711."
+"Si usted es una Persona con una discapacidad que necesita algún
+tipo de asistencia para poder participar en este proceso judicial, usted tiene
+derecho, sin costo alguno, a que se le provea cierta asistencia. Por favor
+póngase en contacto con el Coordinador del programa de la Ley para
+Personas con Discapacidades, ubicado en el Tribunal del Condado de Palm
+Beach, 205 North Dixie Highway, West Palm Beach, Florida 33401; su
+número telefónico es (561) 355-4380, por lo menos 7 días antes de su
+comparecencia, o inmediatamente después de recibir esta notificación, si la
+fecha de su comparecencia es en menos de 7 días. Si usted tiene
+discapacidad para oír o hablar, Hame al 711. "
+"Si ou se yon moun ki enfim ki bezwen aranjman espesyal pou w
+kapab patisipe nan seyans sa a, ou gen dwa, san w pa peye senk kob, pou w
+resevwa èd. Tanpri kontakte Kòdonatris pwogram Lwa Ameriken pou
+Moun ki Enfim yo nan Tribinal Rejyon Palm Beach ki nan adrès 205
+North Dixie Highway, West Palm Beach, Florida 33401; telefòn li se (561)
+355 4380, fè sa omwen 7 jou anvan dat ou gen randevou pou parèt nan
+Tribinal la, oswa fè sa imedyatman apre ou fin resevwa konvokasyon an si
+dat ou gen pou w parèt nan tribinal la mwens pase 7 jou. Si ou soud oswa
+ou pa ka pale klè, rele 711."
diff --git a/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.receipt.json b/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7bb3791470f4331c186f57fb357b5815edcb938c
--- /dev/null
+++ b/vision-fixhub/court-01/f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "f44564cec6490270cdd8eede7c7363bd1421100fbebd1b0a748b92c1b7254a28",
+  "engine": "marble-apple-vision",
+  "event_count": 9,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "f87c4d130c2797a6a40c0379fc04350a6d78a49122c2249a1571bf51f5a4e93d",
+  "output_sha256": "d6c29f05ba60b996c4d365368ff04ce92b585e342c42335da11331ed08d99d39",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4463f5e5d26644a7208e99e7038df18a5a120b8cb8c474f879dd8d5e33f85ea.md b/vision-fixhub/court-01/f4463f5e5d26644a7208e99e7038df18a5a120b8cb8c474f879dd8d5e33f85ea.md
new file mode 100644
index 0000000000000000000000000000000000000000..fd6025b8f9290abdd7427b9b7f0eb1daf8932dcd
--- /dev/null
+++ b/vision-fixhub/court-01/f4463f5e5d26644a7208e99e7038df18a5a120b8cb8c474f879dd8d5e33f85ea.md
@@ -0,0 +1,105 @@
+Case 9:08-cv-80994-KAM Document 95 Entered on FLSD Docket 06/14/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFE, C.L.'S NOTICE OF WITHDRAWING SUBPOENA SERVED
+ON MARITZA MILAGROS VASQUEZ AND CANCELLING DEPOSITION
+SCHEDULED FOR JUNE 15. 2010
+Plaintiff, C.L., by and through her undersigned counsel, hereby gives notice of
+withdrawing the Subpoena for Deposition directed to Maritza Milagros Vasquez and, further,
+gives notice of canceling the deposition of Maritza Milagros Vasquez scheduled for June 15,
+2010 in the C.L. v. Epstein, Case No. 10-80447-CIV-Marra/Johnson pending in the United States
+District Court, Southern District of Florida.
+CERTIFICATE OF SERVICE
+I hereby certify that on June 14, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day on all counsel of record or pro se parties identified on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF
+or in some other authorized manner for those counsel or parties who are not authorized to receive
+electronically.
+S/SPENCER T. KUVIN
+SPENCER T. KUVIN (Florida Bar No.: 089737)
+Email: skuvin@leopoldküvin.com
+Leopold~Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+(561) 515-1400; (561) 515-1401 (facsimile)
+Attorneys for Plaintiff, C.L.
+
+
+Case 9:08-cv-80994-KAM Document 95 Centfiealet Servile Docket 06/14/2010 Page 2 of 2
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA
+Stuart S. Mermeistein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattomney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+Paul G. Cassell, Esq.
+08-80232, 08-80380, 08-80381, 08-80993,
+Pro Hac Vice
+08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Jack Alan Goldberger, Esq.
+801-585-5202
+Atterbury Goldberger & Weiss, P.A.
+801-585-6833 Fax
+250 Australian Avenue South
+cassellp@law.utah.edu
+Suite 1400
+Co-counsel for Plaintiff Jane Doe
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469
+Robert D. Critton, Jr., Esq.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+Michael J. Pike, Esq.
+Florida Bar No. 617296
+mpike@bclclaw.com
+Burman, Critton, Luttier & Coleman
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL: 33401
+561-842-2820
+561-515-3148 Fax
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/f4463f5e5d26644a7208e99e7038df18a5a120b8cb8c474f879dd8d5e33f85ea.receipt.json b/vision-fixhub/court-01/f4463f5e5d26644a7208e99e7038df18a5a120b8cb8c474f879dd8d5e33f85ea.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e741f03f65df227e60ebf80a7639606283b0f062
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.md b/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.md
new file mode 100644
index 0000000000000000000000000000000000000000..c834dd5f6f471645528aab19338fe80d3ab6ee16
--- /dev/null
+++ b/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.md
@@ -0,0 +1,17 @@
+Case 9:08-cv-80380-KAM Document 143-3 l
+Entered on FLSD Docket 07/29/2009 Page 1 of 1
+DECLARATION OF JANE DOE NO. 6
+state as follows:
+I am the Plaintiff identified as Jane Doe No. 6 in this lawsuit.
+On July 9, 2009, an investigator came to the office of my former employer, A
+Affordable Auto Insurance, in Lake Worth, Florida.
+After the investigator left, I was contacted by my former employer and told that
+the investigator was asking personal questions about me.
+I am worried that Jeffrey Epstein will continue to send investigators to speak with
+other people I know who do not know that I am a Plaintiff in this lawsuit. I am concerned that
+the investigators will ask these people very personal questions about my life and disclose that I
+am a Plaintiff in a sexual abuse lawsuit against Jeffrey Epstein.
+I declare under penalty of perjury the foregoing to be true and correct.
+Dated this 22 day of July
+→ 2009
+mika line Doc Nigo
diff --git a/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.receipt.json b/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cb7b9519af8144675db25ce6063c82b7caffed63
--- /dev/null
+++ b/vision-fixhub/court-01/f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f46b35d6f6e628fb164367bea0b1dad870f5136102c5775d7ff9b8a8c6d1b2d7",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ec18c9343b8bd10c24102e76753bda676e130b044e0bb90ed51c725c7ed41c5f",
+  "output_sha256": "0ac2044b3634b4f014cb9a93a4c8fea97830ea9174152c542d2b3d7c9e34c369",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.md b/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.md
new file mode 100644
index 0000000000000000000000000000000000000000..449f0a891434a6447f7dfd9e622ad0685e985ec0
--- /dev/null
+++ b/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.md
@@ -0,0 +1,217 @@
+Entered on FLSD Docket 07/29/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/_
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRAJ
+1
+
+
+Entered on FLSD Docket 07/29/2009 Page 2 of 8
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA1
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA/C
+2
+
+
+Entered on FLSD Docket 07/29/2009 Page 3 of 8
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOES' 2- 7 MOTION FOR PROTECTIVE
+ORDER AND INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, Jane Does 2-7 ("Plaintiffs" or individually, "Plaintiff"), by and through
+undersigned counsel, hereby file Plaintiffs' Motion for Protective Order, pursuant to
+S.D.Fla.L.R. 7.1, and state as follows:
+1.
+Plaintiffs Jane Does 2-7 are proceeding with a Jane Doe pseudonym as this case
+involves facts of the utmost intimacy and there is a genuine risk of psychological harm if their
+identities are disclosed. See Exhibit "A" (Declaration of Gilbert Kliman, M.D.) (See also DE
+144, Jane Does' 2-7 Response to Defendant's Motion to Compel Identity, et al.).
+3
+
+
+Case 9:09-cv-80656-KAM Document 44 Entered on FLSD Docket 07/29/2009 Page 4 of 8
+2.
+Despite the obvious need for Plaintiffs to have their identities protected,
+Defendant Jeffrey Epstein has employed investigators who have made repeated contacts with exboyfriends, former employers, and others who know nothing of the underlying facts of the case.
+These investigators have contacted such nonparties asking them for extensive personal
+information about a Plaintiff, such as names and contact information of former boyfriends and
+other friends and acquaintances in the Plaintiff's community.
+3.
+The Defendant's repeated contacts with these nonparties is harassing and
+designed to intimidate the Plaintiffs. The purpose and intent of these contacts is to brand the
+Plaintiffs as alleged sexual abuse victims to their families, friends and communities.
+4.
+A Motion is pending in which this Court is being asked to determine whether and
+how Defendant may obtain discovery from nonparties. (DE 91, 144). Defendant's investigative
+efforts improperly circumvent the issues in the pending Motion, and only serve to highlight the
+need for this Court to implement appropriate protective measures to prevent Defendant from
+harassing, intimidating, and intruding unnecessarily into the personal lives of the Plaintiffs.
+5.
+While it is not unusual for a defendant to use appropriate means to obtain records
+from former employers and others referenced in a plaintiff's discovery responses, it is not
+customary for a defendant to retain private investigators to make personal contact with these
+individuals. Indeed, this practice is particularly inappropriate in a sexual abuse case where these
+nonparties are unaware of the underlying abuse. Plaintiffs have a well-grounded fear that the
+investigators will use the opportunity of their contacts with these nonparties to "out" the
+Plaintiffs' as alleged childhood sexual abuse victims of Jeffrey Epstein. (See Kliman Decl., Exh.
+"A" hereto).
+4
+
+
+Case 9:09-cv-80656-KAM Document 44 Entered on FLSD Docket 07/29/2009 Page 5 of 8
+6.
+As an example of the investigators' intimidation tactics, three of Defendant's
+investigators recently called the former employer of Jane Doe 4 on repeated occasions over a
+two-day period, asking personal questions about her, including the name and telephone number
+of her ex-boyfriend. See Exhibit "B", Declaration of Jane Doe 4.
+7.
+Similarly, one of Defendant's investigators contacted the former employer of Jane
+Doe 6. See Exhibit "C", Declaration of Jane Doe 6.
+8.
+There is no basis for Defendant or his multiple investigators to make repeated
+personal contacts with former employers and ex-boyfriends to ask personal questions about a
+Plaintiff. It is apparent that these contacts are not designed to obtain relevant information, but
+rather are intended to intimidate the Plaintiffs and to reveal that they are childhood sexual abuse
+victims.
+9.
+Accordingly, Plaintiffs request the entry of a protective order that would prevent
+Defendant, his attorneys and investigators from making ex parte contacts concerning this
+litigation with nonparties who have no knowledge that a Plaintiff was a childhood sexual abuse
+victim of Jeffrey Epstein.
+10. This Court has discretion to enter a protective order designed to protect a party
+from, among other things, annoyance or embarrassment. Fed.R.Civ.P. 26(c). As set forth above,
+given the investigators' conduct, a protective order is appropriate to prevent unnecessary
+intrusion into the Plaintiffs' personal lives and divulgation of Plaintiffs in their communities as
+childhood sexual abuse victims.
+WHEREFORE, Plaintiffs Jane Does 2-7, respectfully request that this Court grant
+Plaintiffs' Motion for Protective Order, as follows: (i) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties identified in plaintiffs" discovery
+5
+
+
+Case 9:09-cv-80656-KAM Document 44 Entered on FLSD Docket 07/29/2009 Page 6 of 8
+responses, such as, for example, former employers; (ii) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties found during the course of
+discovery or investigation who know the Plaintiff or live in her community, such as, for example,
+current and former boyfriends and family friends of the Plaintiffs; (il) order Defendant, his
+attorneys and investigators to cease making ex parte contacts with nonparties who otherwise
+know one of the Plaintiffs personally but who are unaware that she is an alleged victim of
+childhood sexual abuse by Jeffrey Epstein; and (iv) grant all such other relief this Court deems
+just and appropriate.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: July 29, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+6
+
+
+Case 9:09-cv-80656-KAM Document 44 Entered on FLSD Docket 07/29/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on July 29, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+7
+
+
+Entered on FLSD Docket 07/29/2009 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Is/ Adam D. Horowitz
+8
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.receipt.json b/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2e5fca1ff45782d462e9e2486b259a1617a7fbf8
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+++ b/vision-fixhub/court-01/f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177.receipt.json
@@ -0,0 +1,14 @@
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+  "byte_delta": -239,
+  "dataset": "marble-joined",
+  "doc_id": "f47a0aca9d8451f32e05163c83c37a900f669c40a854c8149c72d585a78ea177",
+  "engine": "marble-apple-vision",
+  "event_count": 10,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "98ef48b811413195042944533087e7f3d6b53c19ff1193b89e3ef4d88243593d",
+  "output_sha256": "044df7b7b1e1bcfbd77e02881c34cc4466e660a2653a890f10a41af49199eaf0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.md b/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.md
new file mode 100644
index 0000000000000000000000000000000000000000..f88be5d12ce071f5f110e153fab5f54470061561
--- /dev/null
+++ b/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.md
@@ -0,0 +1,299 @@
+Case 1:19-cv-10577-LJL-DCF Document 2 Filed 11/14/19 Page 1 of 2
+JS 44C/SDNY
+REV. 06/01/17
+CIVIL COVER SHEET
+The JS-44 civl cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
+other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
+United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civil docket sheet
+PLAINTIFFS
+JANE DOE 1000
+DEFENDANTS
+DARREN K. INDYKE and RICHARD D. KAHN, in their capacities as the
+executors of the ESTATE OF JEFFREY EDWARD EPSTEIN
+ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
+ATTORNEYS (IF KNOWN)
+Joshua I. Schiller
+Bennet J. Moskowitz
+Boles Schiller Flexner LLP
+875 Third Avenue
+55 Hudson Yards, New York, NY 10001 (212) 446-2300
+New York, NY 10022
+CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
+(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+28 U.S.C. § 1332; New York causes of action
+Judge Previously Assigned
+Has this action, case, or proceeding, or one essentially the same been previously filed in SDNY at any time? No Yes •
+If yes, was this case Vol. • Invol. • Dismissed. No • Yes • if yes, give date
+& Case No.
+IS THIS AN INTERNATIONAL ARBITRATION
+No X Yes O
+NATURE OF SUIT
+(PLACE AN [x] IN ONE BOX ONLY)
+TORTS
+ACTIONS UNDER STATUTES
+CONTRACT
+INSURANCE
+112
+113
+1147
+I 1150
+ACT
+NEGOTABLE
+INSTRUMENT
+RECOVERY OF
+OVERPAYMENT &
+ENFORCEMENT
+OF JUDGMENT
+11152
+MEDICARE ACT
+RECOVERY OF
+DEFAULTED
+STUDENT LOANS
+(EXCL VETERANS)
+[ 1153
+RECOVERY OF
+OVERPAYMENT
+OF VETERANS
+BENEFITS
+[1160
+[1190
+|] 195
+STOCKHOLDERS
+SUITS
+OTHER
+CONTRACT
+CONTRACT
+PRODUCT
+LIABILITY
+[1196 FRANCHISE
+PERSONAL INJURY
+1310 AIRPLAN
+] 315 AIRPLANE PRODUC
+LIABILITY
+I 1320 ASSAULT, LIBEL &
+SLANDER
+I 1330 FEDERAL
+EMPLOYERS
+LIABILITY
+| 1340 MARINE
+) 345 MARINE PRODUCT
+LIABILITY
+1 355 MOTOR VEHICLE
+PRODUCT LIABILITY
+[* 360 OTHER PERSONAL
+INJURY
+[ 1362 PERSONAL INJURY
+MED MALPRACTICE
+PERSONAL HERE
+FORFEITURE/PENALTY
+PHARMACEUTICAL PERSONAL [ 1625 DRUG RELATED
+INJURY/PRODUCT LIABILITY
+SEIZURE OF PROPERTY
+[ 1365 PERSONAL INJURY
+21 USC B81
+PRODUCT LIABILITY
+| 1369 ASBESTOS PERSONAL | 1690 OTHER
+INJURY PRODUCT
+LIABILITY
+PROPERTY RIGHTS
+PERSONAL PROPERTY
+BANKRUPTCY
+11422 APPEAL
+28 USC 158
+1 1423 WTHDRAWAL
+28 USC 157
+] 370 OTHER FRAUE
+§ 371 TRUTH IN LENDING
+1820 COPYRIGHT:
+1830 PATENT
+I 1835 PATENT-ABBREVIATED NEW DRUG APPLICATION
+[ 1840 TRADEMARK
+SOCIAL SECURITY
+OTHER STATUTES
+I 1375 FALSE CLAIMS
+| 1376 QUI TAM
+1] 400 STATE
+REAPPORTIONMENT
+| 1410 ANTITRUST
+i 430 BANKS & BANKING
+1450 COMMERCE
+] 450 DEPORTATION
+[ ] 470 RACKETEER INFLU-
+ENCED & CORRUPT
+ORGANIZATION ACT
+(RICO)
+| 1480 CONSUMER CREDIT
+1490 CABLE/SATELLITE TV
+REAL PROPERTY
+11210
+LAND
+11230
+CONDEMNATION
+FORECLOSURE
+RENT LEASE &
+EJECTMENT
+EMPLOYMENT
+TORT PRODUCT 11448 AMERICANS WITH
+TORT PRODUCT
+LIABILITY
+DISABILITIES -OTHER
+I 1290
+ALL OTHER
+[ 1448 EDUCATION
+REAL PROPERTY
+[ ] 380 OTHER PERSONAL
+PROPERTY DAMAGE
+I 1385 PROPERTY DAMAGE
+PRODUCT LIABILITY
+LABOR
+| 1710 FAIR LABOR
+STANDARDS ACT
+I 1720 LABOR/MGMT
+1861 HIA (139511)
+862 BLACK LUNG (923)
+1863 DIVC/DIV (405(g)
+1864 SSID TITLE XVI
+| 865 RSI (405 (g1)
+PRISONER PETITIONS
+1463 ALIEN DETAINEE
+RELATIONS
+I 1740 RAILWAY LABOR ACT
+j510 MOTIONS TO
+[1 751 FAMILY MEDICAL
+FEDERAL TAX SUITS
+ACTIONS UNDER STATUTES
+CIVIL RIGHTS
+VACATE SENTENCE
+LEAVE ACT (FMLA)
+28 USC 2255
+[ 1870 TAXES (U.S. Plaintiff or
+) 530 HABEAS CORPUS
+| 1790 OTHER LABOR
+1535 DEATH PENALTY
+LITIGATION
+Defendant)
+| 1871 IRS-THIRD PARTY
+[ 1440 OTHER CIVIL RIGHTS
+- I 1540 MANDAMUS & OTHER
+I 1 791 EMPL RET INC
+25 USC 7609
+(Non-Prisoner)
+SECURITY ACT (ERISA)
+[ 1441 VOTING
+IMMIGRATION
+| 1442 EMPLOYMENT
+443 HOUSING
+PRISONER CIVIL RIGHTS
+1482 NATURALIZATIO
+ACCOMMODATIONS | ] 550 CIVIL RIGHTS
+APPLICATIO
+I 1445 AMERICANS WTH
+1 555 PRISON CONDITION
+11465 OTHER IMMIGRATION
+[ ] 560 CIVIL DETAINEE
+ACTIONS
+CONDITIONS OF CONFINEMENT
+I 1850 SECURITIES/
+COMMODITIES/
+EXCHANGE
+| ] 890 OTHER STATUTORY
+ACTIONS
+I 1891 AGRICULTURAL ACTS
+I 1893 ENVIRONMENTAL
+MATTERS
+I ] 895 FREEDOM OF
+INFORMATION ACT
+11189 AMSTRAVE
+PROCEDURE ACT/REVIEW OR
+APPEAL OF AGENCY DECISION
+STATE STATUTUSTIONALITY OF
+Check if demanded in complaint:
+CHECK IF THIS IS ACLASS ACTION
+UNDER F.R.C.P. 23
+DEMAND S
+OTHER
+Check YES only if demanded in complaint
+JURY DEMAND: EYES LNO
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y
+AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 137
+IF SO, STATE:
+JUDGE
+DOCKET NUMBER
+NOTE: You must also submit at the time of filing the Statement of Relatedness form (Form IH-32).
+
+
+Case 1:19-CV-10577-LJL-DCF Document 2 Filed 11/14/19 Page 2 of 2
+(PLACE AN x IN ONE BOX ONLY)
+ORIGIN
+X 1 Original
+Proceeding
+L2 Removed from
+•3 Remanded • 4 Reinstated or
+State Court
+from
+Reopened
+Appellate
+• a. all parties represented Court
+• b. At least one party
+is pro se.
+(PLACE AN x IN ONE BOX ONLY)
+BASIS OF JURISDICTION
+• 1 U.S. PLAINTIFF •2 U.S. DEFENDANT • 3 FEDERAL QUESTION
+X14 DIVERSITY
+(U.S. NOT A PARTY)
+CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
+(Place an [X] in one box for Plaintiff and one box for Defendant)
+PTF DEF
+CITIZEN OF THIS STATE
+[11 [11
+PTF DEF
+1130 13
+CITIZEN OR SUBJECT OF A
+FOREIGN COUNTRY
+CITIZEN OF ANOTHER STATE [x|2 2 INCORPORATED or PRINCIPAL PLACE [ 14[14
+OF BUSINESS IN THIS STATE
+FOREIGN NATION
+Litigation
+• 7 Appeal to District
+Judge from
+(Transferred)
+Magistrate Judge
+• 8 Multidistrict Litigation (Direct File)
+IF DIVERSITY, INDICATE
+CITIZENSHIP BELOW.
+PTF DEF
+[1s 116
+PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
+Jane Doe 1000
+New Jersey
+c/o Boies Schiller Flexner LLP
+55 Hudson Yards, New York, NY 10001
+DEFENDANT (S) ADDRESS(ES) AND COUNTY(IES)
+Darren K. Indyke
+Richard D. Kahn
+U.S. Virgin Islands
+DEFENDANT(S) ADDRESS UNKNOWN
+REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
+THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS
+Defendants are sued as executors of the Estate of Jeffrey Epstein. Per 28 U.S.C. § 1332, Defendants are
+deemed citizens of the U.S. Virgin Islands (USVI), decedent Epstein's domicile. Defendants' residential
+addresses are unknown to Plaintiff. Defendants' counsel is listed above.
+COURTHOUSE ASSIGNMENT
+I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
+PLAINS
+X MANHATTAN
+ADMITTED TO PRACTICE IN THIS DISTRICT
+& YES (DATE ADMITTED MoO
+_ Yr. 2009
+itorey Bar Code # JS331
+Check one:
+THIS ACTION SHOULD BE ASSIGNED TO:
+DATE 11/14/2019
+SIGNATURE OF ATTORNEY OF RECORD
+RECEIPT #
+Magistrate Judge is to be designated by the Clerk of the Court.
+Magistrate Judge
+Ruby J. Krajick, Clerk of Court by
+Deputy Clerk, DATED
+UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
+is so Designated.
diff --git a/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.receipt.json b/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f6bb714dc7702e052113847985e7c76c4ef25f93
--- /dev/null
+++ b/vision-fixhub/court-01/f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "f4800e33a002c576fa78402e924dba126a40a7fd6dd7cace0c87d9d5b953f4e2",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c43718c0f0164b02a35e8772050d1ecdd55995ab87fde73bdcd596f85d86c32e",
+  "output_sha256": "75c56ca876c3d87b93e1343ef503f306f933923deeba658d80d4fa0d2016c5e1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.md b/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.md
new file mode 100644
index 0000000000000000000000000000000000000000..ec28a2abf46c6e3fbd129f5ef97474883c2f7bc5
--- /dev/null
+++ b/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.md
@@ -0,0 +1,81 @@
+Filing # 141226534 E-Filed 01/03/2022 02:05:58 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIRCUIT CIVIL DIVISION: AG
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+NOTICE OF APPEARANCE AND DESIGNATION OF E-MAIL ADDRESS
+PLEASE TAKE NOTICE that the undersigned counsel hereby appears in the above-styled
+action on behalf of defendant,
+ABRUZZO, AS CLERK & COMPTROLLER OF PALM
+BEACH COUNTY, FLORIDA, and requests that all papers in this action be served upon Collin
+D.
+, Esq. at Clerk of the Circuit Court & Comptroller, Palm Beach County, P.O. Box 229,
+West Palm Beach, FL 33401.
+PLEASE TAKE FURTHER NOTICE that pursuant to Fla. R. Jud. Admin. 2.516(b) (1)(A),
+the undersigned counsel hereby designates the following primary e-mail address for the purpose
+of service of all documents required to be served in this proceeding:
+Attorney
+Collin D.
+1, Esq.
+Primary E-mail Address
+Eservice@mypalmbeachclerk.com
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 01/03/2022 02:05:58 PM
+
+
+Dated: January 3, 2022
+Respectfully submitted,
+CLERK OF THE CIRCUIT COURT &
+COMPTROLLER, PALM BACH COUNTY
+By:
+Esq. (FL Bar No. 1018081)
+Clerk of the Circuit Court & Comptroller,
+Palm Beach County
+P.O. Box 229
+West Palm Beach, FL
+Tel.: (561) 355-2983
+E-mail:
+NOT A CERTIFIED
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on January 3, 2022 the foregoing document was furnished upon the
+following via the Florida ePortal System:
+Stephen A. Mendelsohn
+Kenneth G. Turkel
+Shane B. Vogt
+James C. Mooney
+100 North Tampa Street, Suite 190(
+Tampa, Florida 33602
+Michael J. Grygiel
+Greenberg Traurig, P.A.
+54 State St., 6th Floor
+Albany, NY 12207
+E-mail: grygielm@gtlaw.com
+Nina D. Boyajian
+Greenberg Traurig, P.A.
+1840 Century Park East, Ste. 1900
+Los Angeles, CA 90067
+E-mails: boyajiann@gtlaw.com;
+riveraal@gtlaw.com
+Attorneys for Plaintiff,
+CA Florida Holdings, LLC
+Attorneys for Defendant, |
+Clerk and Comptroller of Palm Beach
+County, Florida
+Abruzzo, as
+NOT A
+By:
+s/ Collin D.
+Collin D.
+, Esq.
diff --git a/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.receipt.json b/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eff4ed2475ace30fd3df58069f3fb016d0337de9
--- /dev/null
+++ b/vision-fixhub/court-01/f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "f4c6421eaa12346dde85014f09913a0a5eccf12ba4a92a9c0809443a1852efa8",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "04400497d73894877b5139dcd8282267c1bdf345a17355eed28fd5268134f165",
+  "output_sha256": "6d684c1c2efa9577b72fc8a6bd01253f637906a071250f387b1d242ac7600a11",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8.md b/vision-fixhub/court-01/f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8.md
new file mode 100644
index 0000000000000000000000000000000000000000..35fa5960543a3ac10ccc77a0ae982f0a905b6522
--- /dev/null
+++ b/vision-fixhub/court-01/f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8.md
@@ -0,0 +1,189 @@
+Case 9:08-cv-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+EPSTEIN'S REPLY TO JANE DOE H3'S
+RESPONSE TO EPSTEIN'S MOTION FOR SANCTIONS
+Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Reply to Plaintiff's, Jane Doe
+#3, Response to Epstein's Motion for Sanctions and states:
+On January 13, 2010, Epstein filed a Motion for Sanctions (DE #450) against Jane
+Doe #3 for unilaterally terminating her Rule 35 IME on November 24, 2009.
+On February 1, 2010, Jane Doe #3 filed her Memorandum in Response to
+Defendant's Motion for Sanctions ("Response") (DE #456).
+3.
+Jane Doe #3's Response is based, in part, on the demonstrably false assertion that
+her counsel did not know Epstein kept an office in the building where the IME took place.
+4.
+As set forth in Epstein's Motion and in Jane Doe #3's Response (Exhibit A),
+Epstein's maintained an office on the 14" floor of the building located at 250 Australian Avenue,
+in West Palm Beach, Florida. Indeed, the Court's October 23, 2009 Order (DE #369) clearly
+
+
+Case 9:08-cv-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 2 of 6
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+provides that Epstein will view the depositions from his office, "in a separate room on the 14"h
+floor...."
+5.
+Jane Doe #3's assertions that the Florida Science Foundation is not listed on the
+building's directory or that the company was administratively dissolved in September, 2009 for
+failure to file an annual report do not controvert the fact that Jane Doe #3's counsel knew
+Epstein maintained an office at 250 Australian Avenue.
+6.
+On November 10, 2009, two weeks before Jane Doe #3's IME, Adam Horowitz
+attended the deposition of
+at 250 Australian Avenue in which Epstein viewed the
+deposition from his office on the 14* floor. Thus, any argument that counsel did not know
+Epstein still maintained an office at 250 Australian Avenue, either because the Florida Science
+Foundation's name was not on the building directory or because the company was
+administratively dissolved in September 2009 should fall on deaf ears. It is clear that Mr.
+Horowitz knew, two weeks before Jane Doe #3's IME, that Epstein's office was located at 250
+Australian Avenue.!
+Just as the Florida Science Foundation is not listed on the building's directory,
+neither is Jessica Arbour, counsel who attended the subject IME, listed as an attorney on the
+Mermelstein & Horowitz, P.A. (M&H) website. Attached as Exhibit A is the "Attorneys"
+section of the M&H website, which noticeably fails to list Ms. Arbour. In addition, Ms.
+Arbour's page on Martindale.com (attached as Exhibit B) does not indicate any affiliation with
+' In addition, counsel for Jane Doe #3 attended the following depositions at 250 Australian Ave., which Epstein
+viewed from a video feed to his: LM on September 24, 2009, Jane Doe on September 30, 2009, Jane Doe #4 or
+October 27, 2009, as well as others. There is no question Jane Doe #3's counsel knew Epstein maintained an office
+in the building.
+
+
+Case 9:08-cv-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 3 of 6
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+M&H. It merely provides a Miami address (different from M&H's office address) and states that
+she attended DePaul law school and was admitted to practice in 2009.
+8.
+Although it is uncertain exactly when Ms. Arbour joined M&H, the Florida Bar
+News announced that she joined the firm in its October 15, 2009 edition of "On the Move"
+(attached as Exhibit C), which was just over one month before the subject IME. Thus, it is
+likely that Ms. Arbour joined M&H sometime in late 2009.
+9. If Ms. Arbour did not know Epstein maintained an office at the building, it is only
+because M&H failed to advise her of this fact.
+10. That
+| not have known that Epstein maintained an office at 250
+Australian Avenue is inapposite since knowledge by any member of a law firm is imputed to all
+attorneys in the firm. See e.g. In re Mortgage & Realty Trust, 195 B.R. 740, 754-55 (Bankr.,
+C.D. Cal. 1996) (noting that the imputed knowledge theory holds that knowledge by any member
+of a law firm is knowledge by all of the attorneys in the firm, partners as well as associates);
+Westinghouse Elec. Corp. v. Kerr-
+• Corp., 50 F.2d 1311, 1318 (7th Cir. 1978) (holding
+that rule regarding imputation of knowledge applies equally to large firms as well as smaller
+firms).
+11.
+Thus, since Adam Horowitz knew that Epstein maintained an office in the
+building two weeks before the subject IME, this knowledge is imputed to Ms. Arbour and she is
+deemed to have knowledge of this fact.
+12.
+Moreover, the purpose behind the Court's October 23, 2009 Order (DE #369) was
+to provide a procedure to avoid Epstein crossing paths with the respective Plaintiffs at their
+
+
+Case 9:08-cv-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 4 of 6
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+depositions since Epstein maintained an office at the building where the depositions were to take
+place.
+13.
+M&H's failure to inform their associate, Ms. Arbour, that Epstein maintained an
+office in the building was likely the cause of the instant dispute. Had Ms. Arbour been told of
+this important fact, she likely would have made some arrangement or taken some precaution to
+avoid her client seeing Epstein. For example, Ms. Arbour could have called the undersigned the
+day before the IME and stated "I am attending the IME of my client tomorrow, is Epstein going
+to be at his office? If so, we should consult with each other about when our respective clients
+will be coming and going from the building to avoid a run-in." Or, once Ms. Arbour realized
+that her client would be going outside to take smoke breaks, she could have called the
+undersigned and said "my client is going to be outside taking smoke breaks from time to time
+throughout the day. Should we designate an area for the smoke breaks that Epstein will not walk
+by? Should we call you when we're going outside?" Ms. Arbour could have also followed the
+procedure outlined in DE #369 (assuming she knew of such procedure). There are a myriad of
+different things Ms. Arbour could have done, and may very well have done, had she been
+informed by M&H that Epstein maintained an office in the building.
+14.
+Because this alleged encounter, which Epstein denies because he did not see Jane
+Doe #3 or her counsel (see Epstein's Affidavit, Exhibit A to DE# 450), was wholly the fault of
+Jane Doe #3's counsel, the Court should grant Epstein's Motion for Sanctions.
+15.
+Jane Doe #3's unilateral cancellation of the IME was not justified and resulted in
+a substantial waste of physician time, attorney time, court reporter and videographer time. The
+costs associated with the court reporter and videographer currently totals $1,260.00 for Visual
+
+
+Case 9:08-cV-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 5 of 6
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+Evidence and $2,207.65 for Prose Court Reporting for a total amount of $3.467.65. See Exhibit
+B to DE #450.
+Now, Dr.
+will be required to travel back to West Palm Beach to complete
+Jane Doe #3's IME. Moreover, additional court reporter and videographer expenses will be
+incurred to complete the IME.
+17.
+Because of her unjustified cancellation of the IME, Jane Doe #3 should bear the
+foregoing costs.
+WHEREFORE, Defendant moves for an order granting sanctions against Jane Doe #3, to
+include attorneys fees and costs as set forth above and costs associated with the attendance of the
+court reporter, the transcript and the presence of the videographer and direction that Jane Doe #3
+appear for IME within fifteen (15) days from the date of the Court's order at the undersigned's
+office, and for such other and further relief as this court deems just and proper.
+Js/ Michael J. Pike
+Robert D. Critton Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+Attorneys for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 11* day of February, 2010:
+
+
+Case 9:08-cv-80119-KAM Document 467 Entered on FLSD Docket 02/11/2010 Page 6 of 6
+Epstein's Reply to Jane Doe #3's Response to Epstein's Motion for Sanctions
+
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #3
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By: _
+Is/ Michael J. Pike
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8.receipt.json b/vision-fixhub/court-01/f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0b6dcde8c6b9e196ed0cc634cc12d3c93f3d9851
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@@ -0,0 +1,14 @@
+{
+  "byte_delta": -343,
+  "dataset": "marble-joined",
+  "doc_id": "f4f32c0e0ce0f20e5c4ea31ca8575d77bffa946fe17f093402d03c413d13beb8",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "2451418a10ab47b3ae6b21252813e7cc144b3f3495ca130a91951248682fa8aa",
+  "output_sha256": "efce36e607ca7b0745dee08556115cfc91b60a3db81e941580046ae050db1277",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f4fbd9c38b363e3fd6c86d5e23e12a75c33597320d3676e508b8ef35e907f973.md b/vision-fixhub/court-01/f4fbd9c38b363e3fd6c86d5e23e12a75c33597320d3676e508b8ef35e907f973.md
new file mode 100644
index 0000000000000000000000000000000000000000..b3ce71c89838d39b29fe8ded6b73ab4dfa525caf
--- /dev/null
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@@ -0,0 +1,410 @@
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S MOTION TO COMPEL ANSWERS TO
+INTERROGATORIES AND PRODUCTION OF DOCUMENTS,
+AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT
+Plaintiff, by and through undersigned counsel, files this Motion to Compel Answers to
+Interrogatories and Production of Documents, and Memorandum of Law in Support, pursuant to
+Fed.R.Civ.P. 26 and 37 and S.D.Fla.L.R. 26.1(H)(2), as follows:
+INTRODUCTION
+Plaintiff in this case propounded 17 interrogatories and 24 documents requests. In response,
+Defendant has produced no information and no documents. Defendant's principal objection
+concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set
+forth a sufficient predicate in his responses to interrogatories or documents requests for his refusal to
+provide any responsive documents or information. Defendant, rather, repeats in each response an
+all-encompassing, blanket assertion of Fifth Amendment privilege.
+Defendant's responses also include a laundry list of objections to Plaintiff's interrogatories
+and documents requests, none of which serve as a basis for a denial of all discovery. For the reasons
+discussed below, Plaintiff requests an order compelling Defendant to answer interrogatories and
+- 1-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 2 of 16
+produce responsive documents.'
+Il.
+EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE
+AGAINST SELF-INCRIMINATION IN RESPONSES
+TO INTERROGATORIES IS INSUFFICIENT
+Defendant's response to each and every one of Plaintiff's Interrogatories contains the
+following privilege objection:
+1 intend to respond to all relevant questions regarding this lawsuit,
+however, my attorney has counseled me that I must accept this advice
+or risk losing my Sixth Amendment right to effective representation
+Accordingly, I assert my federal constitutional rights under the Fifth
+Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Defendant's canned objection represents a "blanket" refusal to answer questions in this civil
+case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a "blanket" refusal to
+testify as unacceptable). While Plaintiff' does not dispute that Defendant Epstein's Fifth Amendment
+privilege may be asserted in a civil case, the Fifth Amendment's "protection must be confined to
+instances where the witness has reasonable cause to apprehend danger from a direct answer."
+Hoffman v. United States, 341 U.S. 479, 486 (1951) (emphasis supplied).
+"[A] witness has some minimal burden to justify invocation of the privilege." In re J.M.V.,
+Inc., 90 F.R. 737, 739 (Bankr. E.D. Pa. 1988). The privilege must be asserted in response to a
+' This Motion addresses almost entirely general or blanket objections to discovery, which are
+repeated in multiple or all of the Defendant's responses to Plaintiff's discovery requests.
+Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2)
+in the interests of clarity and efficiency.
+" Attached as Exhibit "A" is Defendant's Response and Objections to Plaintiff' s Interrogatories.
+" This discussion addresses the Defendant's Fifth Amendment claim of privilege. Defendant also
+asserts a privilege under the Sixth and Fourteenth Amendments. The Sixth Amendment does not
+provide a basis to refuse to answer questions in a civil case as a means to preserve the Defendant's
+"right to effective representation", as Defendant asserts in his responses. The Fourteenth
+- 2-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 3 of 16
+particular question, and in each instance "Ti]t is for the court to decide whether a witness' silence is
+justified and to require him to answer if it clearly appears to the Court that the witness asserting the
+privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983)
+(holding that it was not sufficient for witness to answer every question with conclusory assertion of
+Fifth Amendment privilege). Accord Anglada, 822 F.2d at 1037 (noting that Court should not have
+to speculate as to which questions would tend to incriminate); See also Hoffman, 341 U.S. at 486
+(witness' "say-so does not of itself establish the hazard of self-incrimination"); In re Wincek, 202
+B.R. 161, 168 (Bankr. M.D. Fla. 1996) (rejecting assertion of Fifth Amendment privilege in "broad,
+unsupported fashion").
+The "reasonable cause" for invocation of the Fifth Amendment privilege is not self-evident
+from the interrogatories propounded by Plaintiff. For example, Interrogatory no. 1 asks the
+Defendant to identify employees who performed work or services at his Palm Beach residence. It is
+not apparent that identifying the chef, chauffeur, gardener, etc., would tend to incriminate the
+Defendant. The information sought in the bulk of the Plaintiff' s interrogatories may be categorized
+generally as follows:
+Type of Information
+Interrogatory No.
+identification of persons
+1, 2, 3, 4, 5, 6, 10, 17
+Defendant's travel schedule and
+locations
+7
+identification of health care providers
+telephone numbers used by Epstein
+and his employees
+8
+11,12
+Amendment likewise is inapposite, as state action is not at issue in this federal case.
+- 3-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 4 of 16
+general information based on Florida
+Standard Interrogatories, Fla.R.Civ.P.
+Form 2, nos. 7, 10, 12
+13, 14, 16ª
+These Interrogatories, on their face, do not infringe upon or otherwise implicate the
+Defendant's rights under the Fifth Amendment. It is, therefore, incumbent upon the Defendant to set
+forth reasonable cause for his invocation of the Fifth Amendment in response to each of these
+Interrogatories. Absent some interrogatory-by-interrogatory showing of reasonable cause, Plaintiff
+asks that Defendant's claims of privilege under the Fifth Amendment be rejected and overruled.
+III. DEFENDANT'S BLANKET ASSERTION OF
+FIFTH AMENDMENT PRIVILEGE IN RESPONSE
+TO REQUESTS FOR PRODUCTION IS INSUFFICIENT
+In response to Plaintiff's Requests for Production, Defendant has asserted an identical,
+"blanket" objection to each and every request, as follows:
+Initially, it is well established that the Fifth Amendment privilege may not apply to specific
+documents "even though they contain incriminating assertions of fact or belief because the creation
+of those documents was not 'compelled' within the meaning of the privilege." United States v.
+Hubbell, 530 U.S. 27, 35-36 (2000). Accordingly, a party cannot avoid discovery merely because
+demanded documents contain incriminating evidence, "whether written by others or voluntarily
+* Plaintiff does not challenge at this time Defendant's assertion of a Fifth Amendment privilege in
+response to interrogatory no. 9, which seeks information on Defendant's sexual aids.
+" Defendant's Response to Request for Production, which sets forth each Request and the
+-4-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 5 of 16
+prepared by himself." Id.
+Nonetheless, the act of procuring documents may be considered testimonial and protected by
+the Fifth Amendment privilege in two instances: (1) if the existence and location of the documents
+are unknown; or (2) where production would "implicitly authenticate" the documents. In re Grand
+Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410
+(1976) (issue expressed as whether compliance with a document request or subpoena "tacitly
+conceded" the item's authenticity, existence or possession by the defendant). It is the Defendant's
+burden to demonstrate that the act of producing any particular responsive documents would entail
+testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is
+not self-evident or apparent from the Plaintiff's requests that the act of producing responsive items
+would be protected under the Fifth Amendment. In particular, there is no reason to believe that
+production of documents in response to the following requests would compel testimonial selfincrimination:
+Types of Documents Requested
+Request Nos.
+Agreements with the U.S. Attorney
+and State Attorney, and documents
+exchanged between Defendant and
+the U.S. Attorney or State Attorney
+1-4
+Telephone records
+Videos, photographs of residence
+5-6
+7
+Documents relating to Plaintiff Jane Doe
+Air travel records
+8
+10
+Documents relating to modeling agencies
+Defendant's Response, is attached hereto as Exhibit "B".
+- 5-
+
+
+Case 9:08-CV-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 6 of 16
+Correspondence with other witnesses
+14, 15, 16, 17, 19
+Social networking documents
+18
+Gifts to minor females
+20
+Personal calendars, diaries
+Prescription medicines
+21,22
+23°
+As to the above-listed items, it is not possession or control of these items that would prove
+incriminating; rather, if anything,
+it is their contents, which are not protected by the Fifth
+Amendment privilege so long as they were created voluntarily. Fisher, 425 U.S. at 410; see also In
+156 B.R. 272, 177-78 (Bankr. D. Idaho 1993). Nor would production of items in response
+to these requests "implicitly authenticate" items that are themselves incriminating. See In re Grand
+Jury Subpoena, 1 F.3d at 93-94 (holding that defendant's calendar/diary not protected from
+discovery by "act of production" doctrine under the Fifth Amendment).
+Without more, therefore, Defendant's blanket claim of a Fifth Amendment privilege in
+response to all of Plaintiff's document requests should be rejected, and responsive documents
+ordered to be produced.
+IV. DEFENDANT'S OBJECTION AND STATEMENT CONCERNING
+ADVERSE INFERENCE IS INAPPROPRIATE AND INCORRECT
+Defendant makes the following self-serving and unnecessary assertion in response to each
+and every interrogatory and document request propounded by Plaintiff:
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights,
+would be unreasonable, and would therefore violate the Constitution.
+•Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness
+statements, and request nos. 12-13, concerning photographs or images of females, may implicate the
+Fifth Amendment.
+- 6-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 7 of 16
+Although a defendant's assertion of his Fifth Amendment privilege cannot be used against a
+criminal defendant, it is well established that "an adverse inference based on a refusal to testify in a
+civil case is an appropriate remedy as it provides some relief to the civil litigant whose case is
+unfairly prejudicial by a witness' assertion of the Fifth Amendment privilege..." United States v.
+Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Baxler v. Palmigiano, 425
+U.S. 408, 318 (1976) (*the Fifth Amendment does not forbid adverse inferences against parties to
+civil actions when they refuse to testify in response to probative evidence offered against them");
+Securities and Exhange Comm'n v. Graystone Nash, Inc., 25 F.3d 187, 190 (3d Cir. 1994) ("t]he
+[defendant's] dilemma of choosing between complete silence and presenting a defense [in a civil
+case] does not fatally infect the right against compelled self-incrimination")?
+In any event, the issue of adverse inference, at this juncture, is premature. It is first
+necessary to determine whether the Fifth Amendment privilege is validly asserted in response to
+particular questions. This issue is typically resolved on a motion to compel. Custer Battles, 415 F.
+Supp. 2d at 633. If it is determined that the privilege is properly asserted, then adverse inferences
+are admissible consistent with the Rules of Evidence, i.e., where they are relevant, reliable and not
+unfairly prejudicial, confusing or cumulative. Id. at 634. Such evidentiary issues concerning
+adverse inference are appropriately addressed at the time of summary judgment or trial. It is
+inappropriate and unnecessary to challenge the use of adverse inferences through self-serving
+statements in blanket objections to interrogatories.
+V. PLAINTIFF IS ENTITLED TO DEFENDANT'S
+HEALTH CARE INFORMATION IN DISCOVERY
+'Moreover, a defendant in a civil case may not manipulate his use of the Fifth Amendment privilege
+by shielding himself from inquiries during discovery, and then submitting surprise testimony in a
+summary judgment affidavit or at trial. Id. at 191.
+- 7-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 8 of 16
+A. Interrogatory at Issue
+"Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10)
+ten years, including without limitation, psychologists, psychiatrists, mental health counselors,
+physician, hospital and treatment facilities."
+B.
+Pertinent Portion of Defendant's Objection
+"... [s]uch information is privileged pursuant to Rule 501, Fed.Evid., and §90.503, Fla.Evd.
+Code. In addition, such information is protected by the provision of the Health Insurance Portability
+and Accountability Act (HIPAA)."
+C. Grounds for Objection and Reasons for Motion
+The substantive basis for Defendant's objection is a claim of privilege under state law,
+Florida Statute §90.503 (psychotherapist-patient privilege) and federal law, HIPAA, 42 U.S.C.
+§1320d et seq. Neither of these privilege claims are a basis to withhold relevant health care
+information in this case. Initially, Florida Statute §90.503 does not protect as privileged the identity
+of health care providers, which is all that is sought in Plaintiffs interrogatory. Rather, it protects
+"confidential communications" with a psychotherapist. Florida Statute $90.503(2). Further,
+Plaintiff is ultimately entitled to discovery from the Defendant's psychotherapists because §90.503
+does not apply to relevant documents in a case of child abuse under Florida Statute §39.204. This
+Statute abrogates the psychotherapist-patient privilege in cases involving child abuse:
+Abrogation of privileged communications in cases involving child
+abuse, abandonment, or negleet.- the privileged quality of
+communication ... between any professional person and his or her
+patient or client, and any other privileged communication except that
+between attorney and client or the privilege provided in s. 90.505, as
+such communication relates both to the competency of the witness
+and to the exclusion of confidential communications, shall not apply
+to any communication involving the perpetrator or alleged
+perpetrator in any situation involving known or suspected child
+- 8-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 9 of 16
+abuse....
+(Emphasis supplied).® "With the exceptions of the attorney-client privilege and the clergy
+communications privilege, section 39.204 abrogates the various evidentiary privileges in cases
+involving child abuse, abandonment or neglect." Nussbaumer v. State, 882 So.2d 1067 (Fla. 2d
+DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims
+of child abuse is more important than the protection of otherwise confidential psychotherapistpatient communications:
+Carson v.
+466 So.2d 1188, 1190 (Fla. 4th DCA 1985) (analyzing predecessor statute,
+§415.512, Fla. Stat.).
+Defendant also asserts HIPAA, the Health Insurance Portability and Accountability Act, 42
+U.S.C. §1320d et seq., as a ground for objection to Plaintiff's interrogatory. "HIPAA does not
+create substantive rights that act as a bar on discovery.... HIPAA regulations is (sic) purely
+procedural in nature and does not create a federal physician-patient or hospital-patient privilege."
+v. Woodford, 2007 WL 309485 *11 (E.D. Cal. 2007). Under HIPAA, health care information
+"The term "child abuse" is defined broadly in the Statute to encompass the acts and conduct alleged
+against Epstein in this case. A "child" is a person under the age of 18, and "abuse" means "any
+willful or threatened act that results in any physical, mental, or sexual injury or harm that causes or
+is likely to cause the child's physical, mental or emotional health to be significantly impaired."
+- 9-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 10 of 16
+may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing
+protected health care information for any purpose other than the litigation and requires return or
+destruction of the protected health care information. 45 C.F.R. §164.512(i)(e). Accordingly, there is
+no basis to withhold from discovery Epstein's health care information, particularly as it relates to
+Plaintiff's allegations of child abuse.
+VI.
+OTHER OBJECTIONS TO PLAINTIFF'S
+DISCOVERY REQUESTS ARE MERITLESS
+A. Overbroad; Relevance
+In response to each and every interrogatory propounded by Plaintiff, Defendant asserts in
+blanket and conclusory fashion that it is "overbroad and seeks information that is neither relevant to
+the subject matter of the pending action nor dies it appear reasonably calculated to lead to the
+discovery of admissible evidence." Defendant also objects to each and every document request as
+overbroad. These objections are groundless. Plaintiff's discovery requests fall within the scope of
+broad discovery and relevance under Fed.R.Civ.P. 26. All of Plaintiff's interrogatories and
+document requests are sufficiently narrow and tailored for Defendant to reasonably provide
+substantive responses. Defendant fails to indicate unfair prejudice or undue burden from any
+interrogatory or document request. Defendant provides no responsive information whatsoever, nor
+has he made any suggestion to reasonably narrow or limit any of the Plaintiff's discovery requests.
+Defendant complains that the time period covered in the interrogatories is too broad. The
+stated time period, applicable to Plaintiff's interrogatories and documents requests generally, as
+noted in Defendant's responses, is January 1, 2003 to present. This time frame is sufficiently
+narrow, especially since the plan and scheme alleged in the Complaint to lure girls to the
+Florida Statutes §39.201.
+- 10-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 11 of 16
+Defendant's Palm Beach mansion for "massages" has been in place since at least that date.
+Defendant's overbroad/relevance objections should, accordingly, be overruled.
+B.
+Work Product; Attorney-Client Privilege
+In response to various interrogatories and all of the documents requests, Defendant asserts in
+conclusory fashion objections based on the attorney work product and attorney-client
+communication privilege.? In making these privilege claims, Defendant failed to provide a privilege
+log as required by S.D.Fla.L.R. 26. 1(G)(3). These interrogatories and requests generally do not on
+their face implicate the work product or attorney client privileges. " These privilege claims should
+therefore be rejected and overruled.
+C.
+Plaintiff's Definitions of "Employee" is Reasonable
+Defendant contests the definition of "Employee" in Plaintiff's document requests and
+interrogatories, which states as follows:
+"Employee" shall mean any person employed to perform
+work for services for Defendant or by Defendant, either directly or
+indirectly, including without limitation:
+i.
+a limited partnership, corporation, limited liability
+company, or other company or entity in which Defendant is a
+member, director, officer or person in control; and
+ii. persons employed by a partnership or a subsidiary of a
+partnership in which Defendant is a general partner or person in
+control.
+"These privileges are asserted in response to Interrogatory nos. 13, 14, and 17, and each and every
+document request.
+'The only possible exception would be Plaintiff's Document Request no. 9, which seeks witness
+statements; nonetheless, Defendant is required to comply with the Local Rule and provide a
+privilege log in response to this request as well as the others.
+- 11 -
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 12 of 16
+The term "Employee" appears in Interrogatory nos. 1, 2, and Document Request no. 6. The
+breadth of this definition is reasonable under the circumstances of this case. Upon information and
+belief, Defendant Epstein conducted his business and personal affairs through a labyrinth of
+corporate entities and other business forms. This definition of "Employee" is reasonable to
+encompass responsive information and documents.
+D.
+Fed.R.Civ.P. 408 and 410 Do Not
+Create a Privilege in Discovery
+Defendant objects to Document Request nos. 1-5, which seek the Defendant's agreements
+with the U.S. Attorney and State Attorney, and documents exchanged with their offices, on the
+grounds of Fed.R.Evid. 408 and 410. These Rules cover the admissibility in evidence of
+compromises and plea agreements; they do not set forth a privilege applicable to such agreements in
+discovery. To the extent a protective order with regard to such documents is deemed appropriate,
+Plaintiff's counsel agrees to limit their use to this litigation, and not to disclose documents
+responsive to these requests to third parties.
+E. Third Party Privacy Rights
+Defendant broadly and vaguely asserts third party privacy rights in response to various
+document requests. To the extent that any such privacy rights are properly raised in this case,
+Plaintiff consents to the entry of an appropriate protective order under which such documents will
+not be disseminated to third parties and will be used only for purposes of this litigation.
+VII. Conclusion
+Based on the foregoing, Plaintiff respectfully requests that Defendant's assertions of
+privilege and objections be denied and overruled, and that an Order be entered directing Defendant
+to answer the Plaintiff's Interrogatories and produce documents responsive to Plaintiff's Requests
+- 12-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 13 of 16
+for Production, subject to such protective order as may be necessary and appropriate. Plaintiff
+further requests such other relief as this Court deems just and proper.
+Dated: March 2, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 13 -
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 14 of 16
+CERTIFICATE PURSUANT TO S.D.FLA.L.R. 7.1(A)(3)
+Counsel for Plaintiff has made reasonable efforts to confer with counsel for Defendant, by
+letter dated February 25, 2009, seeking in good faith to resolve or narrow the issues raised in the
+Motion, but Defendant's counsel failed to respond to Plaintiff's letter, and Plaintiff's counsel has
+been unable to resolve this dispute.
+s/ Adam D. Horowitz
+- 14-
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 15 of 16
+CERTIFICATE OF SERVICE
+I hereby certify that on March 2, 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+- 15 -
+
+
+Case 9:08-cv-80381-KAM Document 61 Entered on FLSD Docket 03/02/2009 Page 16 of 16
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+/s/ Adam D. Horowitz
+- 16-
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diff --git a/vision-fixhub/court-01/f4fc325db58437e680d0be8a3e68b2601326b3a655535c8273e164f7892a0b29.md b/vision-fixhub/court-01/f4fc325db58437e680d0be8a3e68b2601326b3a655535c8273e164f7892a0b29.md
new file mode 100644
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@@ -0,0 +1,79 @@
+Case 9:08-cv-80380-KAM Document 74-2 Entered on FLSD Docket 04/02/2009 Page 1 of 2
+34
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA025129XXXXMB Al
+A.C.,
+V.
+Plaintift,
+JEFFREY E. EPSTEIN, and
+Defendants.
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL RESPONSES TO
+FIRST REQUEST TO PRODUCE TO PLAINTIFF AND TO OVERRULE
+PLAINTIFF'S OBJECTIONS, & FOR DEFENDANT'S EXPENSES,
+INCLUDING ATTORNEYS' FEES
+THIS CAUSE came before the Court on Defendant Epstein's Motion To
+Compel Responses To First Request To Produce To Plaintiff And To Overrule
+Plaintiff's Objections, & For Defendant's Expenses, Including Attorneys' Fees
+and the Court having heard argument of counsel and being fully advised in these
+premises, it is hereby
+ORDERED and ADJUDGED that Defendant's Motion is hereby granted/
+deniedas
+to
+# 17 + 7/18
+→ and desced
+as to #22 as phrased.
+Responses to
+be fter semed w/in 10 dap.
+DONE AND ORDERED at Palm Beach County Courthouse, West Palm
+Beach, Florida, this 23 day of _
+FUB
+< 200€
+Edward A.
+Garrison
+Circuit Judge
+Copies furnished:
+ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESO., 515 North Flagler Drive, Suite 400, West Palm Beach,
+FL 33401; JACK SCAROLA, ESQ., AND JACK P.
+Shipley, P.A., 2139 Palm Beach Lakes Blvd.,
+ESQ., Searcy Denney Scarola Barnhart &
+West Palm Beach, FL 33409, and JACK A.
+Austrian ReSus a Fis, PA, One Clearake Centre, Suite 1400, 250%,
+Australian Avenue South, West Palm Beach, FL 33401
+EXHIBIT" B
+2/23/09-4
+
+
+Case 9:08-cv-80380-KAM Document 74-2 Entered on FLSD Docket 04/02/2009 Page 2 of 2
+35
+A.C.,
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA025129XXXXMB Al
+Plaintiff
+V.
+JEFFREY E. EPSTEIN, and
+Defendants.
+ORDER ON DEFENDANT EPSTEIN'S MOTION TO COMPEL ANSWERS TO
+INTERROGATORIES AND TO OVERRULE PLAINTIFF'S OBJECTIONS, & FOR
+DEFENDANT'S EXPENSES, INCLUDING ATTORNEYS' FEES
+THIS CAUSE came before the Court on Defendant Epstein's Motion To
+Compel Answers To Interrogatories And To Overrule Plaintiff's Objections, & For
+Defendant's Expenses, Including Attorneys' Fees, and the Court having heard
+argument of counsel and being fully advised in these premises, it is hereby
+ORDERED and ADJUDGED that Defendant's Motion is hereby granted/
+denled
+as to #5, 12$18, denied as
+to #2.
+Responses to be soned win
+10 dap.
+DONE AND ORDERED at Palm Beach County Courthouse, West Palm
+Beach, Florida, this 23 day of .
+Edward A. Garrison
+Circuit Judge
+Copies furnished:
+ROBERT D. CRITTON, JR., ESQ., and MICHAEL J. PIKE, ESO. 515 North Flagler Drive, Suite 400, West Palm Beach,
+, ESQ., Searcy Denney Scarola Barnhart &
+TENG, DE
diff --git a/vision-fixhub/court-01/f4fc325db58437e680d0be8a3e68b2601326b3a655535c8273e164f7892a0b29.receipt.json b/vision-fixhub/court-01/f4fc325db58437e680d0be8a3e68b2601326b3a655535c8273e164f7892a0b29.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4e551e8a59163985dee46467bfe0442516789a6c
--- /dev/null
+++ b/vision-fixhub/court-01/f4fc325db58437e680d0be8a3e68b2601326b3a655535c8273e164f7892a0b29.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.md b/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.md
new file mode 100644
index 0000000000000000000000000000000000000000..98f064710272efede8735dfca4644e3ce02aab4a
--- /dev/null
+++ b/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.md
@@ -0,0 +1,28 @@
+Case 9:08-cv-80119-KAM Document 549-1 Entered on FLSD Docket 05/26/2010 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+ORDER
+Upon Plaintiffs' Jane Doe Nos. 2-8' Unopposed Motion for Enlargement of Time to File
+Response to Defendant's Rule 4 Appeal of Portions of The Magistrate's Order Dated February 4,
+2010 (DE 462) and April 1, 2010 (DE 513), and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of
+time of two (2) days until May 28, 2010, to respond to the Defendant's Rule 4 Appeal.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this
+_ day of _
+-. 2010.
+DISTRICT COURT JUDGE
+Copies furnished to:
+Counsel of record
+1
diff --git a/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.receipt.json b/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b3e52e376b6f27e6c29b03024394637e44186908
--- /dev/null
+++ b/vision-fixhub/court-01/f51b34b1f7168fca845087ad6ad224e6e6354215b05cd560482dc6d2320108f6.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "0ddd6fdf3e270b8593d065e02123f123b36fa2f498dfedbd8f52949dd59aa85c",
+  "output_sha256": "2072d25981509a27f80c2971a5f3d23222e81cf5b52ea1629f398a97ea4a1817",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.md b/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.md
new file mode 100644
index 0000000000000000000000000000000000000000..2892b2715971bef92d4872f7c755b4600bd13d1b
--- /dev/null
+++ b/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.md
@@ -0,0 +1,89 @@
+Case 9:08-cv-80994-KAM Document 56-1 Entered on FLSD Docket 05/27/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80994-KAM Document 56-1 Entered on FLSD Docket 05/27/2009 Page 2 of 3
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/_
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRAJ
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al.,
+Defendant.
+CASE NO.: 08-CV- 80469-MARRA/_
+
+
+Case 9:08-cv-80994-KAM Document 56-1 Entered on FLSD Docket 05/27/2009 Page 3 of 3
+JANE DOE NO. 101,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80591-MARRA/
+JANE DOE NO. 102,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA/
+ORDER
+Upon Plaintiffs' Motion for Enlargement of Time to Respond to Defendant's Motion to
+Compel and/or Identify Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third
+Party Subpoenas for Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and
+good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+twenty (20) days until June 11, 2009, to respond to the Defendant's Motions to Compel and/or
+Identify Jane Doe in the Style, et al..
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this_
+day of
+• 2009.
+DISTRICT COURT JUDGE
diff --git a/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.receipt.json b/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..90131ebb0fd51e27e2ad5765c37490c5e0669542
--- /dev/null
+++ b/vision-fixhub/court-01/f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "f532b05fdc2b4d43d17ef9f0317b8d18f0c5d2bca90756acac41d490cb1b32ed",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bedf2a7183936acb2e0fe77530c27edb1d60d8262ae65d361da093893eb247fa",
+  "output_sha256": "91fb34f2ba66cd53508d2ae5e1b0509ff58a144076d7dd131f065ac2c7c3b58c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.md b/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.md
new file mode 100644
index 0000000000000000000000000000000000000000..5c604a03e1eb7362a32563b070ce43de31d1b5e3
--- /dev/null
+++ b/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.md
@@ -0,0 +1,20 @@
+Case 9:08-cv-80736-KAM Document 47 Entered on FLSD Docket 03/18/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/J
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+'MOTION FOR FILING OVERLENGTH STATEMENT OF FACTS IN SUPPORT OF
+MOTION FOR FINDING OF VIOLATIONS OF THE CRIME VICTIMS' RIGHTS ACT
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Filing an Overlength Statement of Facts in Support of Motion for Finding of
+Violations of the Crime Victims' Rights Act, filed March 18, 2011.
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims may file
+a statement of facts no longer than 18 pages in length in support of their motion.
+at West Palm Beach, Palm Beach County, Florida,
+DONE AND ORDERED in
+this 18 day of March, 2011.
+KENNETH A. MARRA
+United States District Judge
diff --git a/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.receipt.json b/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d38b93a81385ccf144730b7dd5ffe5844561c881
--- /dev/null
+++ b/vision-fixhub/court-01/f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f54b13235f9ad862e0423a96d79e225ee6c595f20b306cea5078a5afd388b1c1",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "cdbd89aecf9fb90de5a5430c799363cdb944a2808806e82bc3223b7361881ecb",
+  "output_sha256": "700a5fa77d01866fddb4f9ce91722dbcc32535b3c068f7d7398abff6153fa7f4",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f561e7675a8e8b89965c7e275e4d640d1c680490173f2fd064e522009bc690b5.md b/vision-fixhub/court-01/f561e7675a8e8b89965c7e275e4d640d1c680490173f2fd064e522009bc690b5.md
new file mode 100644
index 0000000000000000000000000000000000000000..eecc0e6a0c80b96dde379967a67406fcb7a132ac
--- /dev/null
+++ b/vision-fixhub/court-01/f561e7675a8e8b89965c7e275e4d640d1c680490173f2fd064e522009bc690b5.md
@@ -0,0 +1,279 @@
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+CASE NO.: 08-CV-80119-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+CASE NO.: 08-CV-80380-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 2 of 10
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-
+MARRA/
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80994-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 3 of 10
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:09-cv-80656-KAM Document 24
+• Entered on FLSD Docket 05/29/2009 Page 4 of 10
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-
+MARRA/
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOE NO. 101 AND JANE DOE NO. 102's MOTION FOR
+LEAVE TO FILE UNDER SEAL RESPONSE IN OPPOSITION TO
+DEFENDANT'S MOTION TO STAY OR. IN THE ALTERNATIVE, TO UNSEAL
+THE NONPROSECUTION AGREEMENT
+Pursuant to Rule 5.4 of the Local Rules of the United States District Court for the
+Southern District of Florida, Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 (together,
+the "Plaintiffs") by and through their undersigned attorneys, hereby file this Motion For
+Leave to File Plaintiffs Jane Doe No. 101 and Jane Doe No. 102's Response in
+Opposition to Defendant's Motion to Stay and/or Continue Action for Time Certain
+Based on Parallel Civil and Criminal Proceedings With Incorporated Memorandum of
+Law Under Seal, and, as grounds, state as follows:
+Undersigned counsel seek to file this Response in Opposition to Defendant
+Jeffrey Epstein's Motion to Stay under seal in order to abide by this Court's August 21,
+2008 Order to Compel Production and Protective Order entered in Case No. 08-80736-
+CIV-MARRA
+(the "Protective Order"). The Protective Order prohibits
+Plaintiffs from disclosing the Non-Prosecution Agreement (the "NPA") or its terms to
+any third party.
+The sealed document should be maintained under seal for the duration
+of this Court's August 21, 2008 Protective Order.
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 5 of 10
+2.
+Undersigned counsel recognize that this Court has previously unsealed
+documents referring to the NPA. We seek to comply with the Protective Order for this
+new and independent filing in an abundance of caution, until directed otherwise by the
+Court.
+3.
+If this Court denies Plaintiffs' instant motion, Plaintiffs seek appropriate
+disclosure of the NPA pursuant to this Court's recent order in Case No. 08-80736-CIV-
+MARRA
+(DE #36) denying Plaintiffs Jane Doe No. 1 and Jane Doe No. 2's
+motion to unseal the NPA. As stated in that Order, the NPA has not been filed with the
+Court. Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 would then have "a specific
+tangible need to be relieved of the restrictions" of the Protective Order because
+consideration of the terms of the NPA is necessary for this Court to resolve Defendant's
+Motion to Stay.
+WHEREFORE,
+1. Plaintiffs respectfully request this Court to enter an Order granting
+Plaintiffs Jane Doe No. 101 and Jane Doe No. 102 the right to file under seal their
+Response in Opposition to Defendant's Motion to Stay and/or Continue Action for Time
+Certain Based on Parallel Civil and Criminal Proceedings With Incorporated
+Memorandum of Law.
+In the alternative, Plaintiffs respectfully request this Court to unseal the
+Non-Prosecution Agreement in order to allow Plaintiffs to concretely respond to
+Defendant's Motion to Stay.
+3.
+Finally, Plaintiffs respectfully request this Court to grant such other and
+further relief to which this Court finds the Plaintiff otherwise entitled.
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 6 of 10
+Date: May 29, 2009
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+On May 29, 2009, undersigned counsel conferred with counsel for Defendant in a
+good faith effort to resolve the issues raised in this motion, and Defendant's counsel
+advised that Defendant opposes this motion.
+Date: May 29, 2009
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 7 of 10
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that, on this 29th day of May, 2009, we electronically
+filed the foregoing document with the Clerk of the Court using CM/ECF. We also certify
+that the foregoing document is being served this day on all counsel of record identified on
+the attached Service List either via transmission of Notices of Electronic Filing generated
+by CM/ECF or in some other authorized manner for those counsel or parties who are not
+authorized to receive electronically Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No.
+101 and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Bar No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 8 of 10
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:09-cV-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 9 of 10
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Case Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A
+2290 10" Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80871
+Brad
+Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards @rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+
+
+Case 9:09-cv-80656-KAM Document 24 Entered on FLSD Docket 05/29/2009 Page 10 of 10
+224 Datura Avenue, Suite 900
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f561e7675a8e8b89965c7e275e4d640d1c680490173f2fd064e522009bc690b5.receipt.json b/vision-fixhub/court-01/f561e7675a8e8b89965c7e275e4d640d1c680490173f2fd064e522009bc690b5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..64705a0aa6fb95d483b28c8fc726240549e12979
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diff --git a/vision-fixhub/court-01/f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82.md b/vision-fixhub/court-01/f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82.md
new file mode 100644
index 0000000000000000000000000000000000000000..efeedf7ad83c1c034b7c3e3d69b2c906b5ccd4c6
--- /dev/null
+++ b/vision-fixhub/court-01/f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82.md
@@ -0,0 +1,88 @@
+Case 1:20-cv-00484-JGK-DCF Document 46 Filed 06/16/20 Page 1 of 3
+PANISH
+SHEA &
+BOYLE
+LLP
+June 16, 2020
+VIA ECE
+Hon. Debra C. Freeman
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re:
+Jane Doe, 1:20-cv-00484-JGK-DCF
+Dear Judge Freeman:
+Pursuant to the Court's Text Order in the above-referenced case entered on June 15, 2020
+regarding Plaintiff's Motion to Approve Alternate Service on Defendant Ghislaine Maxwell,
+Plaintiff has served Ms. Maxwell with a copy of the Text Order by emailing it to Ms. Maxwell's
+counsel of record in the
+case, Laura Menninger, and is now hereby filing proof of such
+service on the Docket of this action. A copy of such proof of service is attached hereto.
+Very truly yours,
+Robert S. Glassman
+RSG
+11111 Santa Monica Boulevard, Suite 700 - Los Angeles, California 90025 - 310.477.1700 phone - 310.477.1699 fax - www.psblaw.com
+
+
+Case 1:20-cv-00484-JGK-DCF Document 46 Filed 06/16/20 Page 2 of 3
+Keilah Betts
+Sent:
+To:
+Cc:
+Subject:
+Attachments:
+Importance:
+Tuesday, June 16, 2020 7:05 AM
+Imenninger@hmflaw.com
+Robert Glassman; Nathan Werksman; Claudia Lomeli
+Doe v. Indyke et al: Ghislaine Maxwell
+Activity in Case 1:20-cv-00484-JGK-DCF Doe v. Indyke et al Order on Motion for
+Miscellaneous Relief
+High
+Dear Ms. Menninger - Please be advised that the Court has issued the attached minute order concerning service on your
+client Ghislaine Maxwell. Plaintiff was ordered to give notice to you of this order via e-mail.
+Docket Text:
+ORDER granting [43] Motion To Approve Alternate Service on Defendant Ghislaine Maxwell
+("Maxwell"). Plaintiff's motion is unopposed, and, based on Plaintiff's representations
+regarding her unsuccessful efforts to locate Maxwell's current residence, her fruitless
+attempts to serve Maxwell at multiple locations, her equally fruitless attempts to contact
+Maxwell via several email addresses publicly associated with Maxwell, and her rejected
+request to Maxwell's known litigation counsel to accept service on Maxwell's behalf, this Court
+finds that Plaintiff has adequately demonstrated that she has made diligent efforts to effect
+service, and that personal service would be impracticable. See
+IV. Epstein, No.
+17cv616 (JGK), 2018 WL 637421, at *1 (S.D.N.Y. Jan. 30, 2018); see also
+Iv. Indyke, No.
+19cv10475 (LGS)(DF) (Text Order, dated Feb. 12, 2020). This Court further finds that Plaintiff's
+provision of a copy of the Summons and Complaint by email to Maxwell's current counsel of
+record in the
+case (see Declaration of Robert S. Glassman, dated May 27, 2020 (Dkt.
+43-2), Ex. 3) was reasonably calculated to place Maxwell on notice of this suit and to
+constitute sufficient service under the circumstances presented here. No later than 6/18/20,
+Plaintiff is directed to serve Maxwell with a copy of this Text Order by the same means (i.e., by
+email to Maxwell's counsel of record in the
+case), and to file proof of such service on
+the Docket of this action. Maxwell may then have until 7/9/20 to move, answer, or otherwise
+respond to the Complaint. (HEREBY ORDERED by Magistrate Judge Debra Freeman)(Text
+Only Order) (Freeman, Debra)
+Keilah Betts
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: betts@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 46 Filed 06/16/20 Page 3 of 3
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+2
diff --git a/vision-fixhub/court-01/f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82.receipt.json b/vision-fixhub/court-01/f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bee9b411b50e19f358637020c37fc5f4fdbd5385
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+  "doc_id": "f5763d227e833a042a6d59bc88045323914908523fca96516482a255d61b7b82",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "da07d4b30ea06cc0c5fff1ed5e0cb2a08aeb4ec839bf8b5e81c1e0013ed0960a",
+  "output_sha256": "7180c76496bc6964ea52cddf0b8255132970bbd122f29614d21a572f9e10301a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f5a397bd97231a18b10b78553e0ab258c8b0b7a2660a5a924ae5fd2d446065f8.md b/vision-fixhub/court-01/f5a397bd97231a18b10b78553e0ab258c8b0b7a2660a5a924ae5fd2d446065f8.md
new file mode 100644
index 0000000000000000000000000000000000000000..81dc34e404efb5b39421d7d50150e79be0177e3d
--- /dev/null
+++ b/vision-fixhub/court-01/f5a397bd97231a18b10b78553e0ab258c8b0b7a2660a5a924ae5fd2d446065f8.md
@@ -0,0 +1,705 @@
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 1 of 22
+
+
+
+Case 9:08-CV-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 2 of 22
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+IN RE: JANE DOE,
+Petitioner.
+FILED by INS D.C.
+JUL 0 9 2008
+STEVEN M. LARIMOR:
+LERK U.S, DIST. CT
+S.D. OF FLA. - W.P.B.
+DECLARATION OF A.
+VILLAFANA
+IN SUPPORT OF UNITED STATES' RESPONSE
+TO VICTIM'S EMERGENCY PETITION FOR ENFORCEMENT
+OF CRIME VICTIM RIGHTS ACT, 18 U.S.C. § 3771
+I,A.
+Villafaña, do hereby declare that I am a member in good standing
+of the Bar of the State of Florida. I graduated from the University of California at Berkeley
+School of Law (Boalt
+in 1993. After serving as a judicial clerk to the Hon. David F.
+Levi in Sacramento, California, 1 was admitted to practice in California in 1995. I also am
+admitted to practice in all courts of the states of Minnesota and Florida, the Eighth, Eleventh,
+and Federal Circuit Courts of Appeals, and the U.S. District Courts for the Southern District
+of Florida, the District of Minnesota, and the Northern District of California. My bar
+admission status in California and Minnesota is currently inactive. I am currently employed
+as an Assistant United States Attorney in the Southern District of Florida and was so
+employed during all of the events described herein.
+
+
+Case 9:08-cv-80381-KAM : Document 35-1 Entered on FLSD Docket 07/29/2008 Page 3 of 22
+
+2.
+I am the Assistant United States Attorney assigned to the investigation of
+Jeffrey Epstein. The case was investigated by the Federal Bureau of Investigation ("FBI"').
+The federal investigation was initiated in 2006 at the request of the Palm Beach Police
+Department ("PBPD") into allegations that Jeffrey Epstein and his personal assistants had
+used facilities of interstate commerce to induce young girls between the ages of thirteen and
+seventeen to engage in prostitution, amongst other offenses.
+Throughout the investigation, when a victim was identified, victim notification
+letters were provided to her both from your Affiant and from the FBl's Victim-Witness
+Specialist. Attached hereto are copies of the letters provided to
+three
+clients, T.M., C.W., and S.R.' Your Affiant's letter to C.W. was provided by the FBI. (Ex.
+1). Your Affiant's letter to T.M. was hand-delivered by myself to T.M. at the time that she
+was interviewed (Ex. 2).? Both C. W. and T.M. also received letters from the FBI's Victim-
+Witness Specialist, which were sent on January 10, 2008 (Exs. 3 & 4). S.R. was identified
+via the FBI's investigation in 2007, but she initially refused to speak with investigators.
+S.R.'s status as a victim of a federal offense was confirmed when she was interviewed by
+'Attomey
+filed his Motion on behalf of "Jane Doe," without identifying which of
+his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R.
+All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when
+they were fifteen years old.
+"Please note that the dates on the U.S. Attorney's Office letters to C. W. and T.M. are not the
+dates that the letters were actually delivered. Letters to all known victims were prepared early in the
+investigation and delivered as each victim was contacted.
+-2-
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 4 of 22
+
+federal agents on May 28, 2008. The FBI's Victim-Witness Specialist sent a letter 1o S.R.
+on May 30, 2008 (Ex. 5).
+4.
+Throughout the investigation, the FBI agents, the FBI's Victim-Witness
+Specialist, and your Affiant had contact with C. W. and S.R. Atlorney |
+other client,
+T.M., was represented by counsel and, accordingly, all contact with T.M. was made through
+that attorney. That attorney was James Eisenberg, and his fees were paid by Jeffrey Epstein,
+the target of the investigation.?
+5.
+In the summer of 2007, Mr. Epstein and the U.S. Attorney's Office for the
+Southern District of Florida ("the Office") entered into negotiations to resolve the
+investigation. At that time, Mr. Epstein had been charged by the State of Florida with
+solicitation of prostitution, in violation of Florida Statutes § 796.07. Mr. Epstein's attorneys
+sought a global resolution of the matter. The United States subsequentiy agreed to defer
+federal prosecution in favor of prosecution by the State of Florida, so long as certain basic
+preconditions were met. One of the key objectives for the Government was to preserve a
+federal remedy for the young girls whom Epstein had sexually exploited. Thus, one
+condition of that agreement, notice of which was provided to the victims on July 9, 2008, is
+the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+"The undersigned does not know when Mr.
+T.M. ever formally terminated Mr. Eisenberg's representation.
+-3-
+began representing T.M. or whether
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 5 of 22
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+6. An agreement was reached in September 2007. The Agreement contained an
+express confidentiality provision.
+7.
+Although individual victims were not consulted regarding the agreement,
+several had expressed concerns regarding the exposure of their identities at trial and they
+desired a prompt resolution of the matter. At the time the agreement was signed in
+September 2007, T.M. was openly hostile to the prosecution of Epstein. The FBI attempted
+1o interview S.R. in October 2007, at which time she refused to provide any information
+regarding Jeffrey Epstein. None of Attorney
+clients had expressed a desire to be
+consulted prior to the resolution of the federal investigation.
+8. As explained above, one of the terms of the agreement deferring prosecution
+10 the State of Florida was securing a federal remedy for the victims. In October 2007,
+shortly after the agreement was signed, four victims were contacted and these provisions
+were discussed. One of those victims was C.W. who at the time was not represented, and she
+was given notice of the agreement. Notice was also provided of an expected change of plea
+in October 2007. When Epstein's attorneys learned that some of the victims had been
+-4.
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 6 of 22
+• Page 5 of 21
+notified, they corplained that the victims were receiving an incentive to overstate their
+involvement with Mr. Epstein in order to increase their damages claims. While your Affiant
+knew that the victims'
+statements had been taken and corroborated with independent
+evidence well before they were informed of the potential for damages, the agents and I
+concluded that informing additional victims could compromise the witnesses' credibility at
+trial if Epstein reneged on the agreement.
+9.
+After C. W. had been notified of the terms of the agreement, but before Epstein
+performed his obligations, C. W. contacted the FBI because Epstein's counsel was attempting
+1o take her deposition and private investigators were harassing her. Your Affiant secured pro
+bono counsel to represent C.W. and several other identified victims. Pro bono counsel was
+able to assist C.W. in avoiding the improper deposition. That pro bono counsel did not
+express to your Affiant that C. W. was dissatisfied with the resolution of the matter.
+10.
+In mid-June 2008, Attorney
+contacted your Affiant to inform me that
+he represented C.W. and S.R, and asked to meet to provide me with information regarding
+Epstein. I invited Attorney
+1o send to me any information that he wanted me to
+consider. Nothing was provided. I also advised Attorney
+that he should consider
+contacting the State Attorney's Office, if he so wished. I understand that no contact with that
+office was made.. Aftorney Edwards had alluded to T.M., so T advised him that, to iny
+knowledge, T.M. was still represented by Attorney James Eisenberg.
+-5-
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 7 of 22
+
+11.
+On Friday, June 27, 2008, at approximate 4:15 p.m., your Affiant received a
+copy of the proposed state plea agreement and learned that the plea was scheduled for 8:30
+a.m., Monday, June 30, 2008. Your Affiant and the Palm Beach Police Department
+attempted to provide notification to victims in the short time that Epstein's counsel had given
+us. Although all known victims were not notified, your Affiant specifically called attorney
+1|| to provide notice to his clients regarding the hearing. Your Affiant believes that
+it was during this conversation that Attorney
+notified me that he represented T.M.,
+and I assumed that he would pass on the notice to her, as well. Attorney
+informed
+your Affiant that he could not attend but that someone would be present at the hearing. Your
+A fiant attended the hearing, but none of Attorney|
+clients was present.
+12. On today's date, your Affiant provided the attached victim notifications to
+C.W. and S.R. via their attorney,
+(Exs. 6 & 7). A notification was not
+provided 1o T.M. because the U.S. Attorney's modification limited Epstein's liability to
+victims whom the United States was prepared to name in an indictment. In light of T.M.'s
+prior slatements to law enforcement, your Affiant could not in good faith include T.M. as a
+victim in an indictment and, accordingly, could not include her in the list provided to
+Epstein's counsel.
+13.
+Furthermore, with respect to the Certification of Emergency, Attorney
+did not ever contact me prior to the filing of that Certification to demand the relief that he
+requests in his Emergency Petition. On the afternoon of July 7, 2008, after your Affiant had
+-6-
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 8 of .22
+
+already received the Certification of Emergency and Emergency Petition, I received a letter
+from Attorney
+that had been sent, via Certified Mail, on July 3, 2008. While that
+Jetter urges the Attorney General and the United States Attorney to consider "vigorous
+enforcement" of federal laws with respect to Jeffrey Epstein, it contains no demand for the
+relief requested in the Emergency Petition.
+14.
+I declare under penalty of perjury, pursuant 1o 28 U.S.C. § 1746 that the
+foregoing is true and correct to the best of my knowledge and belief.
+Executed this 9th day of July, 2008.
+Villafaña, Esq
+-7-
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 9 of 22
+Entered on FLSD Docket 07/15/20@
+SOVERNNENT
+ТЕХНІВЛ
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave, Suite 400
+Wesi Palm Bench, FL 33401
+(561) 820-8711
+Focsimile: (561) 820-8777
+June 7, 2007
+DELIVERY BY HAND
+Miss C
+Re:
+Crime Victims' and Witnesses" Rights
+Dear Miss W
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those nghts are:
+(1)
+(2)
+The right to be reasonably protected from the accused.
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be exciuded from any public court proceeding, unless the court
+determines that your testimony may be materially altcred if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the casc.
+The right to full and limely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of ine U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at 56l
+209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561
+822-5946. You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attorney with respeci to the righis listed above and, if you
+believe that the rights ser forth above are being violated, you have the right to petition the Court for
+relief.
+
+
+Case 9:08-cv-80381-KAM : Document 35-1 Entered on FLSD Docket 07/29/2008 Page 10 of 22
+
+MIss CI
+JUNE 7, 2007
+PAGE 2
+In addition to these rights, you are enlitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassmeni, please contact Special Agent Kuyrkendal! or myself immediately. It is possible that
+someone working on behalf'of the targets of the investigation may contact you. Such contact does
+not violatibe lawe" However, if you are contacted, you have the choice of speaking to that person
+or refusing to"do so.' If you refuse and feel that you are being threatened or harassed, then plcase
+contact Special Agent Kuykendall or myself.
+You also are entitled to notification of upcoming case events. Atthis time, your case is under
+investigation! If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+R. Alexander Acosta
+United States Allorney
+or antillafara
+Villafaña
+Assistant United Stales Allomey
+Special Agent Nesbitt Kuyrkendall, F.B.L.
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 . Page 11 of 22
+U.S. Department of Justice
+United States Altorney
+• Southern District of Florida
+500 South Australian /Ive., Suite 400
+Wesi Palm Beuch. FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+August 11, 2006
+DELIVERY BY HAND
+Miss T
+Re: Crime Victims' and Witnesses' Rights
+Dear Miss M
+Pursuant to the Justice for All Act of 2004, as a victim and/or wilness of a federal offense,
+you have a number of rights. Those rights are:
+(1)
+(2)
+The right to be reasonably prolected from the accused.
+The right 1o reasonable, accurate, and timely nolice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+(5)
+(6)
+(7)
+(8)
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The righ! to proceedings free from unreasonable delay.
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy:
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts 1o make sure that these
+rights are prolected. If you have any concerns in this regard; please feel free to contact me at 561
+209-1047, or Special Agent Nesbit! Kuyrkendall from the Federal Bureau of Investigation at 561
+822-5946. You also can contact the Justice Depariment's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983: That Office has a website at www.ovc.gov.
+You can seek the advice of an allomey with respect to the righis listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+relief.
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 . Page 12 of 22
+
+MISS T
+AUGUST 11, 2006
+PAGE 2
+In addition to these rights, you are entitled to counseling and medical services, and .
+from intimidation and harassment. If the Court determines that you are a victim, you .....
+entitled to restitution from the perpetrator. A list of counseling and medical service pre:.
+be provided to-you, if you so desire. If you or your family is subjected to any inter •
+harassment; please contact Special Agent Kuyrkendall or myscif immediately. It is p' •
+someone working on behalf of the targets of the investigation may contact you. Such cur:"
+not violate the law. However, if you are contacted, you have the choice of speaking to in :
+or refusing to do so. If you refuse and feel that you are being threatened or harassed, In-
+contact Special Agent Kuyrkendall or myself.
+You also are entitled to notification of upcoming case events. At this lime, your ..1.:
+investigation. If anyone is charged in connection with the investigation, you will be rs!
+Sincerely,
+By:
+R. Alexander Acosta
+United States Allorney
+Mantillabore
+| Villafaña
+Assistant United States Attorney
+Special Agent Nesbitt Kuyrkendall, F.B.I.
+
+
+ase 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 13 ot 2
+Case 9:08-cy-80736-KAM
+entered on FLSD Docket 0761562008 Page 12of 2
+U.S. Department of Justice
+Federal Bureau of Investigation
+FBI - West Palm Beach
+Suite 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone: (581) 833-7517
+Fax: (561) 833-7970
+January 10, 2008
+Re: Case Number:
+Dear Q
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be rgasonably protected from the accused: (2) The right to reasonable, accurale, and tirely nolice of any
+publie court proceeding, or any parole proceeding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materialiy altered If
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, sentencing, or any parole proceeding; (5) The
+reasonable right to confer with the altomey for the Goverment in the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (B) The right.to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an Individual for the crime, and it will become the
+responsibilty of the prosecuting Unted States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attomay with respect to these rights.
+The Victim Notification System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtaln current information about this matter
+an the Internet at WWW.Notfy. USDOJ. GOV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (Interational: 1-502-213-2767), In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notification program. if you update your Information to include a ourrent emall address, VNS will send
+information to that address. You will need the fallowing Victim Identification Number (VIN) 1941737' ahd"
+Personal Identification Number (PJN) '5502' anytime you contact the Call Center and the first time you log on to
+VNS on the Internet. In addiion, the firet time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) es currentiy contained in VNS. The name you should enter Is V
+GOVERNMERI
+AND 08897365944
+
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 14 ot 22
+Entered on FLSD Docket 07/15/2008 * Page 43 of 21
+If you have additional questions which Involve this matter, please contact the office listed above. When
+you cal, please provide the fle number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary, In order to continue to receive notifications, it is your
+responsibility to keep your contact information current.
+Sincerely.
+LRA
+Sumito
+Twiler
+
+
+case 9:08-CV-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 15 ot 2.
+Case 9:08-cy-80736-KAM
+Document. 14
+Entered on FLSD Docket 0745/200831 Page 440f 2'
+U.S. Department of Justice
+Federal Bureau of investigation
+FBI - West Palm Beach
+Suite 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone: (561) 833-7517
+Fax: (561) 833-7970
+January 10, 200B
+James Elsenberg
+One Clearake Center Ste 704 Australlan South
+West Palm Beach, FL 33401
+Re:
+Dear James Elsanberg:
+You have requested to receive notifications for T
+This case is currenty under Investlgation. This can be a lengthy process and we request your
+continued patierice while we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United Stales Code § 3771: (1) The right to
+be reasonably protected from the accused; (2) The right to reasonable, accurate, and timely notice of any
+public court proceeding, or any parale procoding, Involving the crime or of any release or escape of the
+accused; (3) The right not to be axcluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materielly altered if
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any public
+proceeding in the district court involving release, plea, santencing, or any parole proceeding; (5) The
+reasonable right to confer with the atlamney for the Government in the case; (5) The right to fuli and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay: (8) The right to be
+treated with faimess and with respect for the victim'e dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or Indictment of an individual for the crime, and It will become the
+responsiblity of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attomay with respect to these rights.
+The Victim Notfication System (VNS) is designed to provide you with direct information regarding the
+case as it proceeds through the criminal justice system. You may obtain current information about this matter
+on the internet at WWW.Nallfy.USDOJ.GOV or from the VNS Call Center at 1-BB6-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4618) (Intemational: 1-502-213-2767). In addition, you may use the Call
+Center or Internet to update your contact information and/or change your decision about participation in the
+notificstion program, If you update your information to Include a current emall address, VNS will send
+information to that address. You will need the following Victim Identification Number (VIN) 1941741' and
+Personal Identification Number (PIN) '7750' anytime you contact the Call Center and the first time you log on to
+-VNS-on-the-Interet:-In addition, the-first time you access the:VNS-internet site, you will be prompted:to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is Eisenberg.
+COLA
+AMEN
+NO. 08-30136-CYMARR
+TEXHIBI
+NO:
+
+
+Case 9:08-ov-80736-KAM
+Entered on FLSD Docket 07*45/2008›: Page 48
+If you have additional questions which Invoive this matter, please contact the office listed above. When
+you call, please provide the fle number located at the top of this letler. Please remember, your participation
+in the notffication part of this program is voluntary. In order to continue to receive notifications, it is your
+respons bility to keep your contact information current.
+Sincerely.
+Duike Smito
+Twier:
+
+
+Case 9:08-cV-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 17 of 22
+Case 9:08-CV-80736-KAM
+. Document 14
+Entered on FLSD Docket 07115/20(
+•GOVERNMENT
+СЕХНІВП
+U.S. Department of Justice
+Federal Bureau of investigation
+FBI - West Palm Beach
+Sulte 500
+505 South Flagler Drive
+West Palm Beach, FL 33401
+Phone: (561) 833-7517
+Fax: (561) 833-7970
+BOASE
+May 30, 2008
+Re:
+Dear
+Your name was referred to the FBl's Victim Assistance Program as being a possible victim of a federal
+crime. We appreciate your assistance and cooperation while we are Investigating this case. We wouid like to
+make you aware of the victim services that may be available to you and lo answer any questions you may have
+regarding the criminal justice process throughout the investigation. Our program is part of the FBl's effort to
+ensure the victims are treated with respect and are provided information about their rights under federal law.
+These rights include notification of the status of the case. The enclosed brochures provide information about
+the FBl's Victim Assistance Program, resources and instructions for accessing the Victim Notification System
+(VNS). VNS is designed to provide you with information regarding the status of your case.
+This case is currently under Investigation. This can be a lengthy process and we request your
+continued patience whlle we conduct a thorough investigation.
+As a crime victim, you have the following rights under 18 United States Code § 3771: (1) The right to
+be reasonably protected from the accused; (2) The right.to reasonable, accurate, and timely notice of any
+public court proceeding, or any parole proceeding, involving the crime or of any release or escape of the
+accused; (3) The right not to be excluded from any such public court proceeding, unless the court, after
+receiving clear and convincing evidence, determines that testimony by the victim would be materially altered if
+the victim heard other testimony at that proceeding: (4) The right to be reasonably heard at any pubile
+proceeding in the district court involving release, ples, sentancing, or any parole proceeding; (5) The
+reasonable right to confer with the attorney for the Govemment in the case; (6) The right to full and timely
+restitution as provided in law; (7) The right to proceedings free from unreasonable delay; (8) The right to be
+treated with faimess and with respect for the victim's dignity and privacy.
+We will make our best efforts to ensure you are accorded the rights described. Most of these rights
+pertain to events occurring after the arrest or indictment of an individual for the crime, and it will become the
+responsibility of the prosecuting United States Attorney's Office to ensure you are accorded those rights. You
+may also seek the advice of a private attorney with respect to these rights.
+The Victim Notification System (VNS) Is designed to provide you with direct information regarding the
+case as it proceeds through the criminal-justice-system.-You-may-obtain-current-information about-this matter
+on the Internet at WWW.Notify.USDOJ. GDV or from the VNS Call Center at 1-866-DOJ-4YOU (1-866-365-
+4968) (TDD/TTY: 1-866-228-4619) (International: 1-502-213-2767). In addition, you may use the Call
+Center or intemet to update your contact information and/or change your decision about participation in the
+notification program. if you update your Information to include a current email address, VNS will send
+information to thal address. You will need the following Victim Identification Number (VIN) 2074381' and
+Personel Identification Number (PIN) '1816' enytime you contact the Call Center and the first time you log or. to
+VNS on the internet. In addition, the first time you access the VNS Internet site, you will be prompted to enter
+your last name (or business name) as currently contained in VNS. The name you should enter is R
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 . Page 18 of 22
+Case, 9:08-ev-80736-KAM Document 14
+Entered on FLSD Docket 07446/200831 Page 47 of 21
+If you have additional questions which involve this matter, please contact the office listed above. When
+you call, please provide the file number located at the top of this letter. Please remember, your participation
+in the notification part of this program is voluntary. In order to continue to receive notificalions, It is your
+responsibility to keep your contact information current.
+Sincerely,
+7 CCA.
+Twile!
+TOTAL P..87
+
+
+Case 9:08-cv-80381-KAM Document 35-1 Entered on FLSD Docket 07/29/2008 Page 19 of 22
+
+4000-0
+GOVERNMENT
+ЕХНІВП
+U.S. Department of Justice
+ND.08-80736-CV-MARRA|
+
+NO.
+6
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad 1
+Esq.
+The Law Offices of Brad I
+2028 1
+Street, Suite 202
+Hollywood, Florida 33020.
+& Associates, LLC
+Re:
+Jeffrey Epstein/C
+IDENTIFIED VICTIM
+NOTIFICATION OF
+Dear Mr.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client, G
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 15th Judicial Circuit in
+and for Palm Beach County (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control 1, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+"defer federal prosecution "in favor of this state plea and sentence, subject to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States-Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+BRAD
+EsQ.
+NOTIFICATION OF IDENTIFIED VICTIM CI
+JULY 9,2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of'implementing this paragraph, the United States shall provide Mr. Epslein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+less."
+Through this letter, this Office hereby provides Notice that your client, One W
+is an individual whom the United States was prepared to name as a victim of an enumerated
+offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of'her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for
+the health and well-being of Ms. WE
+By:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Plan illatara
+A.
+VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Jack Goldberger, Esq.
+
+
+Case 9:08-CV-80381-KAM Docmenen435-Entered on FLSD Docket 07152008 Page 200f24 °f 22
+U.S. Department of Justice
+GOVERNMENT
+
+NO.08-80736-CY-MARRA
+
+NO.
+7
+United States Allorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+July 9, 2008
+VIA FACSIMILE
+Brad
+5, Esq.
+The Law Offices of Brad
+2028
+n Street, Suite 202
+Hollywood, Florida
+33020.
+Associates, LLC
+Re: Jeffrey Epstein/S
+IDENTIFIED VICTIM
+• NOTIFICATION OF
+Dear Mr.
+By virtue of this letter, the United States Attorney's Office for the Southern District
+of Florida asks that you provide the following notice to your client, St
+On June 30, 2008, Jeffrey Epstein (hereinafter referred to as "Epstein) entered a plea
+of guilty to violations of Florida Statutes Sections 796.07 (felony solicitation of prostitution)
+and 796.03 (procurement of minors to engage in prostitution), in the 1 5th Judicial Circuit in
+and for Palm Beach County. (Case Nos. 2006-cf-009454AXXXMB and 2008-cf-
+009381AXXXMB) and was sentenced to a term of twelve months' imprisonment to be
+followed by an additional six months' imprisonment, followed by twelve months of
+Community Control I, with conditions of community confinement imposed by the Court.
+In light of the entry of the guilty plea and sentence, the United States has agreed to
+defer federal prosecution infavor of this state plea and sentence, subjeet to certain
+conditions.
+One such condition to which Epstein has agreed is the following:
+"Any person, who while a minor, was a victim of a violation of an offense
+enumerated in Title 18, United States Code, Section 2255, will have the same
+rights to proceed under Section 2255 as she would have had, if Mr. Epstein
+
+
+Case 9:08-CV-80381-KAM Document 35-Entered on FLSD Docket 071502008/2 Page 2 or 22 of 22
+BRAD
+ESQ.
+NOTIFICATION OF IDENTIFIED VICTIM SO
+JULY 9,2008
+
+had been tried federally and convicted of an enumerated offense. For purposes
+of implementing this paragraph, the United States shall provide Mr. Epstein's
+attorneys with a list of individuals whom it was prepared to name in an
+Indictment as victims of an enumerated offense by Mr. Epstein. Any judicial
+authority interpreting this provision, including any authority determining
+which evidentiary burdens if any a plaintiff must meet, shall consider that it is
+the intent of the parties to place these identified victims in the same position
+as they would have been had Mr. Epstein been convicted at trial. No more; no
+Through this letter, this Office hereby provides Notice that your client, St
+• is an individual whom the United Stales was prepared to name as a victim of an
+enumerated offense.
+Should your client decide to file a claim against Jeffrey Epstein, his attorney, Jack
+Goldberger, asks that you contact him at Atterbury Goldberger and Weiss, 250 Australian
+Avenue South, Suite 1400, West Palm Beach, FL 33401, (561) 659-8300.
+Please understand that neither the U.S. Attorney's Office nor the Federal Bureau of
+Investigation can take part in or otherwise assist in civil litigation; however, if you do file a
+claim under 18 U.S.C. § 2255 and Mr. Epstein denies that your client is a victim of an
+enumerated offense, please provide notice of that denial to the undersigned.
+Please thank your client for all of her assistance during the course of this examination
+and express the heartfelt regards of myself and Special Agents Kuyrkendall and Richards for
+the health and well-being of Ms. Ra
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+A.L
+|I VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Jack Goldberger, Esq.
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/f5ab413cf8db03d16b472ee0f0f5a79b70a1ac18813a73b038ef3ec89b63d8dd.md b/vision-fixhub/court-01/f5ab413cf8db03d16b472ee0f0f5a79b70a1ac18813a73b038ef3ec89b63d8dd.md
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@@ -0,0 +1,87 @@
+Case 9:08-cv-80119-KAM Document 133-2 Entered on FLSD Docket 06/03/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+WEST PALM BEACH DIVISION
+CASE NO.: 08-cv-80119-MARRA/,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80119-KAM Document 133-2 Entered on FLSD Docket 06/03/2009 Page 2 of 4
+CASE NO.: 08-CV-80381-MARRA/,
+JANE DOE NO. 5,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80994-CIV-MARRA/,
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80993-CIV-MARRA/_
+JANE DOE NO. 7,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+C.M.A.,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE,
+CASE NO.: 08-80811-CIV-MARRA/
+/
+CASE NO.: 08-80893-CIV-MARRA/_
+
+
+Case 9:08-cv-80119-KAM Document 133-2 Entered on FLSD Docket 06/03/2009 Page 3 of 4
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 09-80591-CIV-MARRA-|
+JANE DOE NO. 102,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-80656-CIV-MARRA/JOHNSON
+PROPOSED ORDER ON DEFENDANT'S MOTION FOR
+LIMITED APPEARANCE BY TELEPHONE
+
+
+Case 9:08-cv-80119-KAM Document 133-2 Entered on FLSD Docket 06/03/2009 Page 4 of 4
+This matter came before the Court on Defendant's, JEFFREY EPSTEIN, Motion For
+Limited Appearance By Telephone. Having considered Defendant's Motion, it is HEREBY
+ORDERED and ADJUDGED that:
+Defendant's motion is GRANTED. Attorney || | G. Weinberg shall appear by
+telephone for the hearing on the Defendant's Motion to Stay currently scheduled on June 12,
+2009 at 10:00 a.m.
+DONE and ORDERED this
+_day of
+_ 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record
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diff --git a/vision-fixhub/court-01/f5db509289857b868e6a127143c9fc59012216368c798c847f0e1a94ef037f0f.md b/vision-fixhub/court-01/f5db509289857b868e6a127143c9fc59012216368c798c847f0e1a94ef037f0f.md
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@@ -0,0 +1,67 @@
+Case 9:08-cv-80119-KAM Document 27 Entered on FLSD Docket 07/25/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80119-CIV-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+DEFENDANT'S REQUEST FOR ORAL ARGUMENT
+Pursuant to Rule 7.1(B)(1) of the Local Rules of the United States District
+Court for the Southern District of Florida, defendant Jeffrey Epstein respectfully
+requests oral argument in connection with his motion to stay.
+Defendant believes an opportunity to formally argue the motion would assist
+the Court in ruling on his motion, which seeks to stay this action until resolution of
+a pending criminal action.
+Defendant estimates that the time required for argument is one hour.
+& Teinr.
+
+
+Case 9:08-cv-80119-KAM Document 27 Entered on FLSD Docket 07/25/2008 Page 2 of 3
+CASE NO.: 08-80119-CIV-MARRA/
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101
+Fax: 305 442 6744
+By:
+Is/ Michael R. Tein
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300
+Fax. 561 835 8691
+By: Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+2
+
+
+Case 9:08-cv-80119-KAM Document 27 Entered on FLSD Docket 07/25/2008 Page 3 of 3
+CASE NO.: 08-80119-CIV-MARRA/JOHNSON
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 25, 2008, I electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that
+the foregoing document is being served this day on counsel of record identified
+below by U.S. Mail.
+Is/ Michael R. Tein
+Michael R. Tein
+Service List
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+3
+Teinr.
\ No newline at end of file
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+Case 1:19-cV-10577-LJL-DCF Document 46 Filed 05/07/20 Page 1 of 5
+| SCHILLER
+FLEXNER
+Sigrid S. McCawley
+Telephone: (954) 377-4223
+Email: smccawley@bsfllp.com
+May 7, 2020
+VIA ECE
+The Honorable Debra Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007-1312
+Re: Jane Doe 1000 v. Darren K. Indyke & Richard D. Kahn, 19-10577-LJL-DCF
+Dear Judge Freeman:
+We write on behalf of Plaintiff Jane Doe 1000 in the above-captioned litigation. Pursuant
+to Individual Rule II.A and Local Civil Rule 37.2, Plaintiff respectfully requests a pre-motion
+conference on Plaintiff's anticipated motion to compel Defendants Darren K. Indyke and Richard
+D. Kahn (1) to produce responsive documents from the Relevant Period as defined in Plaintiff's
+discovery requests; (2) to produce documents responsive to Plaintiff's requests, not simply
+documents that directly mention Plaintiff's name; and (3) to respond to Plaintiff's interrogatories.'
+The Court has made clear that discovery in this case would not be stayed pending the approval of
+the claims administration program or a motion to dismiss absent a contrary order from the Court.
+See Tr. of Nov. 21, 2019 Cont. at 26:10-12. Yet by failing to comply with their clear and
+unequivocal discovery obligations, including not producing a single document to date, Defendants
+are attempting to grant themselves a de facto stay of discovery. Defendants have provided no basis
+for their delay.
+I. Background
+Plaintiff alleges that Jeffrey Epstein and his co-conspirators operated a decades-long
+sex-trafficking scheme by which they recruited young women for sexual abuse. Compl. 19l 23-
+26. Plaintiff was one of those women. Epstein and his associates trafficked her after seeing her
+modeling work in 1999, housed her in Epstein's apartment building, and sexually abused her for
+several years. Id. Il 38-46. After years of suffering in silence due to fear, Plaintiff filed a
+complaint against Defendants on November 14, 2019.
+On January 28, 2020, Plaintiff sent Defendants a document preservation notice and
+identified various email accounts used by Jeffrey Epstein. Exhibit A, Jan. 28, 2020 Document
+Preservation Notice. Defendants responded on February 3, 2020, by stating that they were abiding
+by all of their discovery obligations, including their preservation obligations. Exhibit B, Feb. 3,
+1
+Pursuant to Individual Rule I.C., Plaintiff states that she conferred in good faith
+with Defendants about the issues raised in this letter by telephone on April 27, 2020.
+401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfllp.com
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 2 of 5
+2020 Letter from B. Moskowitz to S. McCawley. Yet on the very same day, Defendants sent
+Plaintiff completely vacuous Rule 26 Disclosures. Defendants provided the name of one witness—
+Plaintiff-and stated that they were not aware of any documents, ESI, or tangible things in their
+possession, custody, or control that they would use to support their defenses. Exhibit C, Feb. 3,
+2020 Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn.
+On March 10, 2020, Plaintiff served 79 Requests for Production ("RFPs") and 18
+Interrogatories on Defendants (collectively, Plaintiff's "discovery requests"). In Plaintiff's
+interrogatories, she again asked Defendants to identify potential witnesses, in addition to email
+accounts used by Epstein, telephone numbers used by Epstein, and other information to aid
+Plaintiff in identifying witnesses and the location of evidence necessary to prove her case. On
+April 16, 2020, after Plaintiff provided Defendants a week-long extension, Defendants served
+responses and objections in which they failed to respond to a single Interrogatory (aside from
+identifying Plaintiff as a witness to her own abuse) and failed to produce a single document.
+Exhibit D, Defendants' Apr. 16, 2020 Objections and Responses to Plaintiff's First Set of
+Interrogatories; Exhibit E, Defendants' Apr. 16, 2020 Objections and Responses to Plaintiff's First
+Request for Production of Documents.
+On April 27, 2020, after sending Defendants a letter regarding the clear deficiencies in their
+responses and objections, Plaintiff met and conferred with Defendants for an hour and a
+half. See Ex. F, Apr. 20, 2020 Letter from S. McCawley to B. Moskowitz. Defendants stated that
+they had not yet fully processed the ESI in their possession, had not run any searches on the ESI,
+and were not in a position to provide information about the ESI, despite having received Plaintiff's
+document retention notice in January and Plaintiff's discovery requests in March. During the meet
+and confer, Plaintiff also explained her position on the relevance and necessity of each of her
+discovery requests, and offered to answer any questions that Defendants had about the relevance
+of any of her requests. Defendants refused to accept the Relevant Period that Plaintiff defined in
+her discovery requests, and stated that they would only produce documents that reference Plaintiff.
+They also stated, without providing any legal basis for their position, that they would not produce
+anything relating to Epstein's sex trafficking or abuse of other victims.
+As of today, May 7, 2020, Plaintiff has yet to receive a single document or piece of
+information responsive to any of her discovery requests, including the documents that specifically
+II. Defendants' Objection to the Relevant Period is Improper.
+
+
+Case 1:19-cV-10577-LJL-DCF Document 46 Filed 05/07/20 Page 3 of 5
+position, Defendants contend that the relevant time period should be limited to the dates of
+Plaintiff's abuse as alleged in the Complaint.?
+Under Rule 26 of the Federal Rules of Civil Procedure, parties may obtain discovery
+"regarding any nonprivileged matter that is relevant to any party's claim or defense." Fed. R. Civ.
+P. 26(b)(I). "[R]elevance for the purposes of discovery is an extremely broad concept." Melendez
+v. Greiner, No. 01 CIV.07888 SAS DF, 2003 WL 22434101, at *1 (S.D.N.Y. Oct. 23, 2003)
+(Freeman, J.).
+This case turns on (1) whether Jeffrey Epstein sexually trafficked and sexually assaulted
+Plaintiff and (2) whether Plaintiff's claims are timely, an affirmative defense that Defendants have
+already raised in a motion to dismiss. ECF No. 34. Discovery from the Relevant Period as defined
+by Plaintiff is relevant to both Plaintiff's claims and Defendants' statute of limitations defense,
+and is reasonably calculated to lead to the discovery of admissible evidence.
+Epstein's sexual trafficking and assault of Plaintiff began in 1999 and lasted for several
+years. But Plaintiff has reason to believe, based on publicly available documents, that Epstein and
+his co-conspirators began trafficking and sexually abusing young girls and women in the same
+manner that he trafficked and abused Plaintiff in the mid-1990s, and continued to do so up until
+the date of Epstein's arrest on July 8, 2019. Documents relating to the sexual trafficking and/or
+sexual assault of others at any point during that period would make the fact that Epstein trafficked
+and sexually assaulted Plaintiff, the key fact that Plaintiff bears the burden of proving in this case,
+more probable than it would be without such evidence. See Fed. R. Evid. 401. Plaintiff also bears
+the burden of proving Epstein's intent to sexually assault her. See Cerilli v. Kezis, 16 A.D.3d 363,
+364 (2d Dep't 2005) ("The elements of battery are bodily contact, made with intent, and offensive
+in nature."). Evidence that he sexually trafficked and assaulted others would be directly relevant
+to proving such intent. Such evidence would also likely be admissible at trial. See Fed. R. Evid.
+415.
+Further, Defendants have raised a statute of limitations defense in this matter, ECF No. 34,
+and Plaintiff contends that they should be equitably estopped from doing so based on Epstein's
+misconduct. Compl. 9| 15. Although Plaintiff disagrees with Defendants' interpretation of the case
+law, Defendants contend that to invoke equitable estoppel, Plaintiff bears the burden of proving
+that Epstein's "conduct cause[d] her to delay bringing suit," that Epstein "made a definite
+misrepresentation of fact, and had reason to believe that the plaintiff would rely on it," and that
+"plaintiff reasonably relied on that misrepresentation." ECF No. 34 at 9-10. Documents relating
+to Epstein's misconduct after his abuse of Plaintiff ended could very well be relevant to equitable
+estoppel, including to whether Plaintiff reasonably relied on that misconduct in staying silent about
+her abuse until after Epstein's death.
+The fact that Epstein and his co-conspirators carried out a global sex-trafficking operation,
+which directly injured Plaintiff, for 20 years does not mean that Plaintiff is not entitled to discovery
+about that operation. Yet Defendants have taken that position and have not indicated any
+willingness to change it. The Court should direct Defendants to search documents within their
+2
+This is despite the fact that Defendants themselves served discovery requests on Plaintiff
+in which they defined the relevant time period as "the date on which you first learned of Decedent
+through the date of your responses to these requests."
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 4 of 5
+possession, custody, or control from the Relevant Period as described in Plaintiff's discovery
+requests—1999 to the present.
+III. Defendants Must Produce More than Documents That Explicitly Reference Plaintiff.
+In addition to their blanket objection to the production of documents from any year aside
+from the years during which Plaintiff was herself sexually assaulted, Defendants contend that they
+will only produce one category of documents: those that specifically mention Jane Doe 1000.
+Defendants have refused, without providing any legal basis for doing so, to produce any document
+that does not directly reference Plaintiff, regardless of the year.
+Defendant cannot broadly object to producing any documents that do not directly reference
+Plaintiff. Documents relevant to Plaintiff's claims and Defendants' defenses go well beyond
+documents that reference Plaintiff. The following is a small sampling of examples of relevant
+documents that would not necessarily mention Plaintiff:
+• As cp an ed alo at loch mots cvidencing persis, areficking and sexual
+whether he trafficked and sexually assaulted Plaintiff.
+• Epstein's communications with his co-conspirators are likely to evidence the
+scheme by which Epstein recruited and abused Plaintiff, even if they do not
+specifically mention Plaintiff. For example, documents in which Epstein and his
+co-conspirators discuss recruiting young models or arranging for their housing in
+Epstein's apartment complex would corroborate Plaintiff's allegations.
+• Documents relating to payments from Epstein to his employees are relevant to
+whether Epstein paid his employees to keep them quiet, and would be relevant in
+impeaching witnesses in this case.
+• Documents relating to Epstein's silencing, intimidation, and manipulation of
+victims other than Plaintiff is relevant to establishing whether Plaintiff reasonably
+feared Epstein, which is relevant to Defendants' statute of limitations defense and
+Plaintiff's equitable estoppel theory.
+Plaintiff explained these theories of relevance during a meet and confer call with
+Defendants. Without any legal basis, and while purporting to understand Plaintiff's position,
+Defendants consistently maintained that they would not produce any document that does not
+directly mention Jane Doe 1000. This position unwarranted, legally baseless, and unacceptable,
+and Defendants have not indicated that they are willing to change it. The Court should direct
+Defendants to search for documents within their possession, custody, or control and not allow
+Defendants to unilaterally and arbitrarily limit their search to documents that reference Plaintiff's
+name.
+IV. Defendants Must Respond to Plaintiff's Interrogatories.
+Plaintiff served 18 interrogatories on Defendants, and Defendants failed to answer a single
+one, aside from listing Plaintiff as an "individual who may have knowledge concerning the issues
+in this lawsuit." Ex. D at 3. Plaintiff asked Defendants to identify email accounts used by Epstein
+or his employees or agents on his behalf-Defendants provided no answer. Id. Plaintiff asked
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46 Filed 05/07/20 Page 5 of 5
+Defendants to identify telephone numbers used by Epstein or his employees or agents on his
+behalf—Defendants provided no answer. Id. at 4. Plaintiff asked Defendants to provide a list of
+Epstein's employees in an effort to identify potential witnesses to Epstein's abuse of Plaintiff and
+other victims-Defendants provided no answer. Id. This is despite the fact that Defendant Kahn
+was Epstein's longtime accountant and likely knows who was on Epstein's payroll. This total
+failure to answer even basic questions about the location of documents and potential witnesses is
+egregious.
+When asked about their failure to respond to any interrogatories, in addition to raising their
+meritless objections to the Relevant Period and to producing information that does not relate
+directly to Plaintiff, Defendants stated that they do not have responsive information because
+Epstein is dead and Defendants do not know where to look for responsive information. Defendants
+also drew a distinction between their capacities as Epstein's lawyer and accountant, as opposed to
+their capacities as executors of his Estate, but could not give Plaintiff a clear answer as to their
+position on how that distinction affects their discovery obligations. For example, Defendants'
+counsel could not tell Plaintiff whether Darren Indyke Epstein's longtime lawyer who has ties to
+Epstein's co-conspirators —or Richard Kahn—Epstein's longtime accountant who assisted him
+for years with both personal and professional accounting work-had ever been directly asked
+whether they know of any individuals who might have information about Plaintiff's claims.
+Plaintiff still has no understanding of how Defendants have attempted to fulfill their
+discovery obligations, or of what documents or information are within their possession, custody,
+or control. At this stage in the litigation, such opaqueness is unacceptable and a clear attempt by
+Defendants to avoid their discovery obligations in the hopes that the claims administration process
+comes to fruition. But Defendants cannot unilaterally decide to stay this case. The Court should
+direct Defendants to respond to Plaintiff's interrogatories.
+Respectfully submitted,
+/s/ Sigrid S. McCawley
+Sigrid S. McCawley, Esq.
+cc: Counsel of Record (via ECF)
+According to public records, Indyke, for example, helped Ghislaine Maxwell buy her
+townhouse, was listed on documents relating to one of Maxwell's nonprofits, held a power of
+attorney over one of Leslie Wexner's properties, and employed Lesley Groff as an executive
+assistant for his law practice. See Julia La Roche et al., Jeffrey Epstein's Lawyers Deeply Involved
+in His Business Dealings for Decades, Documents Show, Yahoo Finance (Aug. 13, 2019),
+https://finance.yahoo.com/news/jeffrey-epstein-lawyers-darren-indyke-jeffrey-schantz-
+164305188.html.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 1 of 4
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 2 of 4
+| SCHILLER
+FLEXNER
+Telephone: (954) 356-0011
+Email: smccawley @bstlip.com
+January 28, 2020
+VIA ELECTRONIC MAIL
+Bennet J. Moskowitz
+875 Third Avenue
+New York, New York 10022
+Re:
+Document Preservation Notice
+v. Darren K. Indyke and Richard D. Kahn, 19-10474;
+Annie Farmer v. Darren K. Indyke, Richard D. Kahn, and
+Ghislaine Maxwell, 19-10475;
+W. Darren K. Indyke and Richard D. Kahn, 19-10476;
+v. Darren K. Indyke and Richard D. Kahn, 19-10479;
+Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn, 19-10577;
+Dear Mr. Moskowitz:
+This is a document preservation notice issued in connection with the above-captioned civil
+actions. Please read this notice carefully and take all steps necessary to preserve all documents
+that might be relevant to this dispute. You should take affirmative steps to suspend any automated
+deletion. The documents covered by this notice are potentially subject to discovery and production
+in the above-captioned litigation and will be needed as evidence and/or to enable us to prepare
+fully to take your clients' sworn testimony in a deposition and/or at a trial
+Pursuant to Federal Rule of Civil Procedure 26, you were required to identify "all
+documents, electronically stored information, and tangible things that the disclosing party has in
+its possession, custody, or control and may use to support its claims or defenses." In your Initial
+Disclosures for
+and
+1. however, you stated that "[a]t
+present, the Co-Executors are not aware of any such documents, electronically stored information,
+and tangible things." I assume that you mean that you are not aware that any "documents,
+electronically stored information, [or] tangible things" that would be supportive of your clients'
+defenses. If instead you are taking the position that your clients do not have possession, custody,
+or control over Mr. Epstein's documents (including his electronically stored information), please
+state so in your reply so that we may bring that to the Court's attention immediately.
+At the November 21, 2019, conference Judge Freeman stated: "Counsel should know what
+their obligations are and those obligations are pretty clear under the law and counsel should take
+them seriously. If you do not preserve evidence that should be preserved that you had a reason to
+believe was relevant to claims or defense in the case and that you didn't take steps to preserve,
+there can be negative consequences down the road." Nov. 21, 2019, Hearing Tr. at 33:4-10. The
+Court instructed that your preservation efforts should be "broad enough" to documents located at
+Mr. Epstein's "multiple residences in multiple countries across the world."
+401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfllp.com
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 3 of 4
+Bennet J. Moskowitz
+January 28, 2020
+Page 12
+Effective immediately, you should ensure that your clients preserve all documents, whether
+they exist electronically or in paper files. This includes documents that presently exist, or that are
+created in the future, in your clients' possession, custody or control, including in common files
+maintained for your clients.
+Subject Matter
+Preserve all documents that refer to, relate to, mention, or discuss the allegations in Plaintiffs'
+complaints, including but not limited to any concerning the following subjects and found in the
+following repositories:
+1.
+The allegations in the Complaints filed in the above referenced matters;
+2.
+The Plaintiffs;
+Mr. Epstein's sex-trafficking conspiracy;
+Visitors and/or passengers at any of Mr. Epstein's multiple residences or aircraft where
+the sex trafficking occurred;
+5.
+6.
+7.
+Communications between Mr. Epstein and his co-conspirators;
+Communications between Mr. Epstein and his employees;
+Communications between Mr. Epstein and any government official regardless of
+country;
+8.
+9.
+10.
+11.
+12.
+13.
+14.
+Mr. Epstein's flight logs and helicopter logs;
+Video tapes and photographs taken at Mr. Epstein's properties or on his planes;
+Financial records;
+Mr. Epstein's message pads and any phone call logs or phone/contact directories;
+Amazon.com account details, including order history;
+Electronic files Mark Lumberg managed on behalf of Mr. Epstein;
+Mr. Epstein's email accounts, including but not limited to:
+a. "jeffreye@mindspring.com";
+b. "jeeproject@yahoo.com;
+c. "jeevacation@gmail.com":
+d. "zorroranch@aol.com"; and
+e. "epsteinj@wanadoo.fr";
+15.
+Email accounts under the following domains: @Mindspring.com; @earthlink.net;
+including those used by:
+a. Ghislaine Maxwell;
+b.
+c.
+; and
+d.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-1 Filed 05/07/20 Page 4 of 4
+Bennet J. Moskowitz
+January 28, 2020
+Page 13
+16.
+Email accounts for
+*cecilia@ellmax.com" and
+that Mr. Epstein controlled, including
+Please construe this notice as broadly as possible and carefully read the following
+descriptions.
+The definition of "document" is not limited to paper files. A document is literally any
+cind of record, whether stored electronically or in paper form, whether useful to you or not. se
+.D.N.Y. Local Civil Rule 26.3 ("Uniform Definitions in Discovery Requests"). A document i
+any object in your possession that relates to the subject matter identified in this notice, including:
+• Email. All of your clients' emails relating to the subject matter, both internal and external,
+whether in electronic or paper form; this includes anything created or stored on a wireless
+device or smart phone.
+• Computer Files. All other electronic records relating to the subject matter, including but
+not limited to documents created using Microsoft Office (Word, PowerPoint, Excel,
+Access, and Visio, for example), and stored anywhere; this includes files stored on your
+clients' computers, in shared or network drives, home computers, hard disks, CDs, DVDs,
+flash drives, or anywhere else.
+• Video and Audio. Microfilm, audio and video or other visual records, including voice
+mail, video tapes, DVDs, digital photographs, etc.
+• Paper Documents. All paper records presentations, notes, calendars, day planners, logs,
+lists, agendas, correspondence, photographs, facsimiles, data or other computer printouts
+and the like.
+• Text Messages. All text or SMS messages, messages sent via WhatsApp or other
+messaging services.
+Sincerely,
+/s/ Sigrid S. McCawley
+Sigrid S. McCawley, Esq.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-2 Filed 05/07/20 Page 1 of 2
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-2 Filed 05/07/20 Page 2 of 2
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman™
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+February 3, 2020
+E-MAIL
+Sigrid S. McCawley, Esq.
+Boies Schiller Flexner LLP
+401 East Las Olas Boulevard
+Suite 1200
+Fort Lauderdale, FL 33301
+Re:
+- 19-CV-10476;
+1, 19-CV-10479;
+j, 19-CV-10474; Jane Doe 1000, 19-cv-10577
+, 19-cV-
+10475;
+Dear Ms. McCawley:
+As you know, we represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of
+the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced actions
+(the "Actions"). We are writing in response to your letter dated January 28, 2020.
+You state: "If
+.•. you are taking the position that your clients do not have possession, custody, or
+control over Mr. Epstein's documents (including his electronically stored information), please
+state so in your reply so that we may bring that to the Court's attention immediately." We have
+never taken that position. Accordingly, there is nothing to raise with the Court.
+Separately, we confirm that our clients are abiding by all of their discovery obligations including
+preservation obligations. However, your list of subject matters is inappropriate because it is
+argumentative, assumes many unproven facts not in evidence and is overly broad.' Your
+interpretation of Local Rule 26.3 is likewise inappropriate; we defer to the rule itself.
+Very truly yours,
+Bennet J. Moskowitz
+Bennet J. Moskowitz
+"It bears mentioning that counsel in another action against the Co-Executors previously attempted to
+extract positions from us concerning a similar list and, failing that, to obtain relief from Magistrate
+Freeman. Such counsel obtained no such relief. Nor was any relief necessary given our identica
+presentation in that action that our clients are abiding by their preservation obligations
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 1 of 5
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 2 of 5
+JANE DOE 1000,
+X
+Plaintiff,
+V.
+DARREN K. INDYKE and RICHARD D.
+KAHN in their capacities as the executors of
+the ESTATE OF JEFFREY EDWARD
+EPSTEIN,
+Index No. 1:19-cv-10577-LGS-DCF
+Defendants.
+X
+INITIAL DISCLOSURES OF DEFENDANTS DARREN K. INDYKE AND RICHARD D.
+KAHN, CO-EXECUTORS OF THE ESTATE OF JEFFREY E. EPSTEIN
+Pursuant to Fed. R. Civ. P. 26(a)(1), Defendants Darren K. Indyke and Richard D. Kahn,
+Co-Executors of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), make the
+following initial disclosures to Plaintiff Jane Doe 1000. These disclosures are based on the
+information reasonably available to the Co-Executors at present. The Co-Executors reserve the
+right to supplement or modify these disclosures if additional, responsive information is obtained.
+The Co-Executors provide this information without any concession, agreement,
+admission or waiver of any ultimate determination of relevance or admissibility of particular
+information or testimony for any purpose. The Co-Executors reserve the right to, at trial, call
+any witness and present any exhibit or other evidence not listed here but identified through
+discovery or investigation during this action. The Co-Executors do not waive their rights to
+object to the production of any document or tangible thing based on the attorney-client privilege,
+the work-product doctrine, relevance, undue burden or any other valid objection.
+1
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 3 of 5
+INITIAL DISCLOSURES
+Rule 26(a)(1)(A)
+i.
+the name, and if known, the address and telephone number of each individual
+likely to have discoverable information - along with the subjects of that information -
+that the disclosing party may use to support its claims or defenses, unless the use would
+be solely for impeachment;
+Response: Plaintiff. Plaintiff is likely to have discoverable information
+concerning Jeffiey E. Epstein's alleged conduct and Plaintiff's claimed damages,
+which the Co-Executors may use to support their defenses.
+а copy - or a description by category and location - of all documents,
+electronically stored information, and tangible things that the disclosing party has in its
+possession, custody, or control and may use to support its claims or defenses, unless the
+use would be solely for impeachment;
+Response: At present, the Co-Executors are not aware of any such documents,
+electronically stored information, and tangible things.
+iii.
+a computation of each category of damages claimed by the disclosing party - who
+must also make available for inspection and copying as under Rule 34 the documents or
+other evidentiary material, unless privileged or protected from disclosure, on which each
+computation is based, including materials bearing on the nature and extent of injuries
+suffered; and
+Response: The Co-Executors do not claim damages.
+iv.
+for inspection and copying as under Rule 34, any insurance agreement under
+which an insurance business may be liable to satisfy all or part of a possible judgment in
+the action or to indemnify or reimburse for payments made to satisfy the judgment.
+Response: At present, the Co-Executors are unaware of any such insurance
+agreement.
+2
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 4 of 5
+February 3, 2020
+Respectfully submitted,
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+By: /s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+Attorneys for Defendants Darren K. Indyke and
+Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein
+3
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-3 Filed 05/07/20 Page 5 of 5
+The undersigned certifies that on February 3, 2020, I served a copy of the foregoing
+Initial Disclosures of Defendants Darren K. Indyke and Richard D. Kahn, Co-Executor of the
+Estate of Jeffrey E. Epstein, made pursuant to Fed. R. Civ. P. 26(a)(1), by sending them by email
+to:
+Sigrid McCawley
+Boies, Schiller & Flexner LLP
+401 E. Las Olas Blvd., Suite 1200
+Fort Lauderdale, FL 33301
+(954)-377-4223
+Fax: (954)-377-4223
+Email: smccawley@bsfllp.com
+s/Bennet .J. Moskowitz
+4
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 1 of 16
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 2 of 16
+JANE DOE 1000,
+Plaintiff,
+V.
+Case No. 1:19-cv-10577-LJL-DCF
+DARREN K. INDYKE and RICHARD D. KAHN
+in their capacities as the executors of the ESTATE
+OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+DEFENDANTS' OBJECTIONS AND RESPONSES TO PLAINTIFF JANE DOE 1000'S
+FIRST SET OF INTERROGATORIES TO DEFENDANTS
+Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey
+E. Epstein (the "Co-Executors"), by their attorneys, pursuant to Federal Rules of Civil Procedure
+26 and 33, provide the following responses to Plaintiff Jane Doe 1000's ("Plaintiff") First Set of
+Interrogatories to Defendants (the "Interrogatories").
+RESERVATION OF RIGHTS
+These responses are made solely for the purpose of and in relation to discovery in the
+above-captioned action. The Co-Executors submit these responses subject to, and without
+intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality,
+competency, privilege and admissibility of any documents and information produced in discovery,
+including without limitation herein; and (ii) the right to object to any other discovery requests. The
+Co-Executors reserve their right to amend these responses if and when appropriate. Further, these
+responses are neither an admission nor acceptance of any alleged facts, including without
+limitation those stated in the Interrogatories.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 3 of 16
+SPECIFIC OBJECTIONS TO DEFINITIONS
+The Co-Executors object to Plaintiff' s definition of the term "Jeffrey Epstein" or "Epstein"
+on the grounds that, insofar as it includes "any entities owned or controlled by Jeffrey Epstein, any
+employee, agent, attorney, consultant, or representative of Jeffrey Epstein," it is overbroad, unduly
+burdensome, vague and ambiguous.
+The Co-Executors will interpret "Jeffrey Epstein" or
+"Epstein" as Jeffrey E. Epstein.
+The Co-Executors also object to Plaintiff's definition of the term "Ghislaine Maxwell" or
+"Maxwell" on the grounds that, insofar as it includes "any entities owned or controlled by
+Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine
+Maxwell," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will
+interpret "Ghislaine Maxwell" or "Maxwell" as Ghislaine Maxwell.
+The Co-Executors also object to Plaintiff's definition of the term "Massage" on the grounds
+that it is more expansive than the common use of the term and is inconsistent with the term's usage
+in the Complaint.
+SPECIFIC OBJECTIONS AND RESPONSES TO INTERROGATORIES
+INTERROGATORY NO. 1
+List the names and addresses of all persons who are believed or known by You, You
+agents, or Your attorneys to have any knowledge concerning any of the issues in this lawsuit, and
+specify the subject matter about which the witness has knowledge.
+The Co-Executors object to Interrogatory No. I on the grounds and to the extent that it
+calls for the production of information protected by the attorney-client privilege, the attorney work
+product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors also object to Interrogatory No. 1 on the grounds that it seeks information that is neither
+relevant to Plaintiff's claims nor proportional to the needs of this case; it is also overly broad and
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 4 of 16
+unduly burdensome. Subject to and without waiving the foregoing objection, the Co-Executors
+identify the following individual who may have knowledge concerning the issues in this lawsuit:
+Plaintiff. The Co-Executors will supplement this response if any additional responsive information
+is ascertained.
+INTERROGATORY NO. 2
+Identify all email accounts used by Epstein or any of his employees or agents on his behalf.
+The Co-Executors object to Interrogatory No. 2 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on
+the grounds it seeks "discovery about discovery," which would result in unnecessary expense.
+Such matters are more appropriately and cost-effectively addressed in the context of the parties'
+discussions regarding document discovery. The Co-Executors also object to this Interrogatory on
+the grounds and to the extent that it calls for the production of information protected by the
+attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
+protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds
+and to the extent that it calls for the production of information outside their possession, custody,
+and control, and is unconstrained by time.
+INTERROGATORY NO. 3
+Identify all telephone numbers used by Epstein or any of his employees or agents acting
+on his behalf, including beepers, Blackberry or PDA devices, cellular phones and land lines in any
+of his residences, by stating the users name, complete telephone number(s), type of device and
+name of the service provider.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 5 of 16
+The Co-Executors object to Interrogatory No. 3 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+vague, overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory
+on the grounds and to the extent that it calls for the production of information outside their
+possession, custody, and control, and is unconstrained by time. The Co-Executors further object
+to this Interrogatory on the grounds it seeks "discovery about discovery," which would result in
+unnecessary expense. Such matters are more appropriately and cost-effectively addressed in the
+context of the parties' discussions regarding document discovery. The Co-Executors also object
+to this Interrogatory on the grounds and to the extent that it calls for the production of information
+protected by the attorney-client privilege, the attorney work product doctrine, and any other
+applicable privilege or protection from disclosure.
+INTERROGATORY NO. 4
+Identify all employees, including each employee's position and dates and locations of
+employment, who performed work or services in or on any property owned, leased, occupied, ot
+used by Epstein, including but not limited Epstein's homes in Palm Beach, Florida, New York
+City, the U.S. Virgin Islands, New Mexico, London and Paris, and provide the name and contact
+information of the individual who hired, trained and supervised each employee.
+The Co-Executors object to Interrogatory No. 4 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that it assumes facts not in evidence and that the phrase "performed work or services in
+or on any property" is vague and ambiguous. The Co-Executors also object to this Interrogatory
+on the grounds and to the extent that it calls for the production of information protected by the
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 6 of 16
+attorney-client privilege, the attorney work produet doctrine, and any other applicable privilege or
+protection from disclosure. The Co-Executors further object to this Interrogatory on the grounds
+and to the extent that it calls for the production of information outside their possession, custody,
+and control, and is unconstrained by time.
+INTERROGATORY NO. 5
+Identify all employees, including each employee's position and dates and location of
+employment, who performed work as an assistant, scheduler, secretary, masseuse or traveling
+masseuse for Epstein and provide the name and contact information of the individual who hired,
+trained and supervised each employee.
+The Co-Executors object to Interrogatory No. 5 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the terms "scheduler" and "traveling masseuse" are vague and ambiguous. The Co-
+Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the
+extent that it calls for the production of information protected by the attorney-client privilege, the
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to this Interrogatory on the grounds and to the extent that it calls
+for the production of information outside their possession, custody, and control, and is
+unconstrained by time.
+INTERROGATORY NO. 6
+Identify all companies and/or persons who provided transportation services to Epstein,
+whether as an employee or independent contractor, including without limitation drivers,
+hauffeurs, boat captains, pilots, and aircraft crew, and provide the contact information for eacl
+isted person or compan
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 7 of 16
+The Co-Executors object to Interrogatory No. 6 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory
+on the grounds and to the extent that it calls for the production of information protected by the
+attorney-client privilege, the attorney work product doctrine, and any other applicable privilege or
+protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds that
+the phrase "transportation services" is vague and ambiguous. The Co-Executors further object to
+this Interrogatory on the grounds and to the extent that it calls for the production of information
+outside their possession, custody, and control, and is unconstrained by time.
+INTERROGATORY NO.7
+Identify all females by name and age for whom Epstein or his employees or agents provided
+accommodations at 301 East 66'* Street, New York, New York for any period of time.
+The Co-Executors object to Interrogatory No. 7 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds and to the extent that it assumes facts not in evidence and on the grounds that the phrase
+"provided accommodations" is vague and ambiguous. The Co-Executors additionally object to
+this Interrogatory on the grounds and to the extent that it calls for the production of information
+protected by the attorney-client privilege, the attorney work product doctrine, and any other
+applicable privilege or protection from disclosure. The Co-Executors also object to this
+Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-
+Executors further object to this Interrogatory on the grounds and to the extent that it calls for the
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 8 of 16
+production of information outside their possession, custody, and control, and is unconstrained by
+time.
+INTERROGATORY NO. 8
+Identify by name and age all persons who gave a massage or were asked to give a massage
+to Epstein, Maxwell or a guest, or to whom Epstein or Maxwell gave a massage, at any of Epstein's
+residences and provide the location of each massage.
+The Co-Executors object to Interrogatory No. 8 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds and to the extent that it assumes facts not in evidence. The Co-Executors additionally
+object to this Interrogatory on the grounds and to the extent that it calls for the production of
+information protected by the attorney-client privilege, the attorney work product doctrine, and any
+other applicable privilege or protection from disclosure. The Co-Executors further object to this
+Interrogatory on the grounds and to the extent that it calls for the production of information outside
+their possession, custody, and control, and is unconstrained by time.
+INTERROGATORY NO. 9
+Identify all dates when Andrew Albert Christian Edward,
+of York (a/k/a Prince
+Andrew) was present in any of Epstein's residences from 1995 to the present, and provide the
+location and purpose of each visit.
+The Co-Executors object to Interrogatory No. 9 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors additionally object to this Interrogatory
+on the grounds and to the extent that it calls for the production of information protected by the
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 9 of 16
+attorney-client privilege, the attorney work produet doctrine, and any other applicable privilege or
+protection from disclosure. The Co-Executors also object to this Interrogatory on the grounds and
+to the extent that it assumes facts not in evidence. The Co-Executors additionally object to the
+time period stated in the Request, which is inconsistent with the time frame alleged in the
+Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
+that it calls for the production of information outside their possession, custody, and control.
+INTERROGATORY NO. 10
+Identify all dates when Alan Dershowitz was present in any of Epstein's residences from
+1995 to the present, and provide the location and purpose of each visit.
+The Co-Executors object to Interrogatory No. 10 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to
+this Interrogatory on the grounds and to the extent that it calls for the production of information
+protected by the attorney-client privilege, the attorney work product doctrine, and any other
+applicable privilege or protection from disclosure. The Co-Executors additionally object to the
+time period stated in the Request, which is inconsistent with the time frame alleged in the
+Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
+that it calls for the production of information outside their possession, custody, and control.
+INTERROGATORY NO. 11
+Identify all dates when William "Bill" J. Clinton was present in any of Epstein's residences,
+on any of Epstein's helicopters or planes, at any of Epstein's offices, or at any event hosted or
+affiliated with Epstein from 1995 to the present, and provide the location and purpose of each
+encounter.
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 10 of 16
+The Co-Executors object to Interrogatory No. 11 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the phrase "any event hosted or affiliated with Epstein" is vague and ambiguous. The
+Co-Executors additionally object to this Interrogatory on the grounds and to the extent that it calls
+for the production of information protected by the attorney-client privilege, the attorney work
+product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to the time period stated in the Request,
+which is inconsistent with the time frame alleged in the Complaint. The Co-Executors further
+object to this Interrogatory on the grounds and to the extent that it calls for the production of
+information outside their possession, custody, and control.
+INTERROGATORY NO. 12
+Identify any telecommunications, information technology, or audio-visual technology
+company that Epstein hired for work in any of his residences or offices and provide the name and
+contact information for each individual or company listed, in addition to the residence or office
+serviced.
+The Co-Executors object to Interrogatory No. 12 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the phrase "hired for work" is vague and ambiguous. The Co-Executors additionally
+object to this Interrogatory on the grounds and to the extent that it calls for the production of
+information protected by the attorney-client privilege, the attorney work product doctrine, and any
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 11 of 16
+other applicable privilege or protection from disclosure. The Co-Executors also object to this
+Interrogatory on the grounds and to the extent that it assumes facts not in evidence. The Co-
+Executors further object to this Interrogatory on the grounds and to the extent that it calls for the
+production of information outside their possession, custody, and control, and is unconstrained by
+time.
+INTERROGATORY NO. 13
+Identify the method or means in which Maxwell was paid by Epstein or any affiliated
+entities from 1995 to the present.
+The Co-Executors object to Interrogatory No. 13 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the phrases "method or means in which Maxwell was paid" and "affiliated entities"
+are vague and ambiguous. The Co-Executors also object to this Interrogatory on the grounds and
+to the extent that it assumes facts not in evidence. The Co-Executors also object to this
+Interrogatory on the grounds and to the extent that it calls for the production of information
+protected by the attorney-client privilege, the attorney work product doctrine, and any other
+applicable privilege or protection from disclosure. The Co-Executors additionally object to the
+time period stated in the Request, which is inconsistent with the time frame alleged in the
+Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
+that it calls for the production of information outside their possession, custody, and control.
+INTERROGATORY NO. 14
+Provide detailed quantification for all compensation Maxwell received for any services she
+performed for the benefit of Epstein or any of his affiliated entities, broken down by year from
+1995 to the present.
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 12 of 16
+The Co-Executors object to Interrogatory No. 14 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the phrase "services she performed for the benefit of Epstein or any of his affiliated
+entities" is vague and ambiguous. The Co-Executors also object to this Interrogatory on the
+grounds and to the extent that it assumes facts not in evidence. The Co-Executors also object to
+this Interrogatory on the grounds and to the extent that it calls for the production of information
+protected by the attorney-client privilege, the attorney work product doctrine, and any other
+applicable privilege or protection from disclosure. The Co-Executors additionally object to the
+time period stated in the Request, which is inconsistent with the time frame alleged in the
+Complaint. The Co-Executors further object to this Interrogatory on the grounds and to the extent
+that it calls for the production of information outside their possession, custody, and control.
+INTERROGATORY NO. 15
+Identify any loans or lines of credit issued to Maxwell from Epstein or any affiliated
+entities, including the amount of the loans, the term of the loans, the interest rate of the loans, and
+any payments made by Maxwell or on Maxwell's behalf to repay such loans.
+The Co-Executors object to Interrogatory No. 15 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors also object to this Interrogatory on the
+grounds that the terms "lines of credit" and "any affiliated entities" are vague and ambiguous. The
+Co-Executors also object to this Interrogatory on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors also object to this Interrogatory on the grounds and to the
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 13 of 16
+extent that it calls for the production of information protected by the attorney-client privilege, the
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+INTERROGATORY NO. 16
+Identify the dates, recipients, and purpose of the "two ... payments, one in the amount of
+$250,000 and another in the amount of $100,000 to ... two employees or associates of Mr.
+Epstein's" referenced by Assistant United States Attorney Alexander Rossmiller at Epstein's bail
+hearing on July 15, 2019. See Transcript of July 15, 2019 Bail Hearing at 9:15-20, United States
+v. Epstein, No. 19-cr-490 (RMB) (S.D.N.Y.).
+The Co-Executors object to Interrogatory No. 16 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case. The Co-
+Executors also object to this Interrogatory on the grounds and to the extent that it calls for the
+production of information protected by the attorney-client privilege, the attorney work product
+doctrine, and any other applicable privilege or protection from disclosure.
+INTERROGATORY NO. 17
+Identify all attorneys Epstein used from 1999 to 2002, including the attorney's name and a
+description of the work performed for Epstein, or any work performed for a third party paid for by
+Epstein.
+The Co-Executors object to Interrogatory No. 17 on the grounds that it is vague and seeks
+information that is neither relevant to Plaintiff's claims nor proportional to the needs of this case.
+The Co-Executors also object to this Interrogatory on the grounds and to the extent that it calls for
+the production of information protected by the attorney-client privilege, the attorney work product
+doctrine, and any other applicable privilege or protection from disclosure. The Co-Executors
+further object to this Interrogatory on the grounds and to the extent that it calls for the production
+of information outside their possession, custody, and control.
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 14 of 16
+INTERROGATORY NO. 18
+Identify all persons who have made a claim, complaint, demand or threat against Epstein
+relating to alleged sexual abuse or misconduct on a female, and for each provide the following
+information:
+a. The person's full name, last known address and telephone number;
+b. The person's attorney, if represented
+c. The date of the alleged incidents); and
+d. If a civil case has been filed by or on behalf of the person, the case number and
+identifying information.
+The Co-Executors object to Interrogatory No. 18 on the grounds that it seeks information
+that is neither relevant to Plaintiff's claims nor proportional to the needs of this case; it is also
+overly broad and unduly burdensome. The Co-Executors further object to this Interrogatory on the
+grounds and to the extent that it calls for the production of information protected by the attorneyclient privilege, the attorney work product doctrine, and any other applicable privilege or
+protection from disclosure. The Co-Executors object to this Interrogatory on the grounds that it
+seeks publicly available information and information already known to Plaintiff or her counsel.
+The Co-Executors also object to this Interrogatory on the grounds that the terms "claim, complaint,
+demand or threat" and "misconduct" are overly broad, vague and ambiguous. The Co-Executors
+further object to this Interrogatory on the grounds and to the extent that it calls for the production
+of information outside their possession, custody, and control.
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 15 of 16
+April 16, 2020
+TROUTMAN SANDERS LLP
+By: /s/Bennet Moskowitz
+Bennet Moskowitz
+875 Third Avenue
+New York, New York 10022
+Tel: (212) 704- 6087
+bennet.moskowitz@troutman.com
+Attorney for Darren K. Indyke and
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-4 Filed 05/07/20 Page 16 of 16
+The undersigned certifies that on April 16, 2020, I served a copy of the foregoing
+Defendants ' Objections and Responses to Plaintiff Jane Doe 1000's First Set of Interrogatories to
+Defendants, by sending them by email to:
+Sigrid McCawley
+Boies, Schiller & Flexner LLP
+401 E. Las Olas Blvd., Suite 1200
+Fort Lauderdale, FL, 33301
+Email: smccawley@bsfllp.com
+TROUTMAN SANDERS LLP
+By: /s/Mary
+W. Metcalfe
+Mary
+W. Metcalfe
+875 Third Avenue
+New York, New York 10022
+Tel: (212) 704-6029
+marygrace.metcalfe@troutman.com
+Attorney for Darren K. Indyke and
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 1 of 51
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 2 of 51
+JANE DOE 1000,
+Plaintiff,
+V.
+Case No. 1:19-cv-10577-LJL-DCF
+DARREN K. INDYKE and RICHARD D. KAHN
+in their capacities as the executors of the ESTATE
+OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+DEFENDANTS' OBJECTIONS AND RESPONSES TO PLAINTIFF JANE DOE 1000'S
+FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO DEFENDANTS
+Defendants Darren K. Indyke and Richard D. Kahn, as co-executors of the estate of Jeffrey
+E. Epstein (the "Co-Executors"), by their attorneys, pursuant to Federal Rules of Civil Procedure
+26 and 34, provide the following responses to Plaintiff Jane Doe 1000's ("Plaintiff") First Request
+for Production of Documents (the "Requests").
+RESERVATION OF RIGHTS
+These responses are made solely for the purpose of and in relation to discovery in the
+above-captioned action. The Co-Executors submit these responses subject to, and without
+intending to waive, and expressly preserving: (i) any objections as to relevancy, materiality,
+competency, privilege and admissibility of any documents and information produced in discovery,
+including without limitation herein; and (ii) the right to object to any other discovery requests. The
+Co-Executors reserve their right to amend these responses if and when appropriate. Further, these
+responses are neither an admission nor acceptance of any alleged facts, including without
+limitation those stated in the Requests.
+41990916v3
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 3 of 51
+SPECIFIC OBJECTIONS TO DEFINITIONS
+The Co-Executors object to Plaintiff's definition of the term "Jeffrey Epstein" or "Epstein"
+on the grounds that, insofar as it includes "any entities owned or controlled by Jeffrey Epstein, any
+employee, agent, attorney, consultant, or representative of Jeffrey Epstein," it is overbroad, unduly
+burdensome, vague and ambiguous.
+The Co-Executors will interpret "Jeffrey Epstein" or
+"Epstein" as Jeffrey E. Epstein.
+The Co-Executors also object to Plaintiff's definition of the term "Ghislaine Maxwell" or
+"Maxwell" on the grounds that, insofar as it includes "any entities owned or controlled by
+Ghislaine Maxwell, any employee, agent, attorney, consultant, or representative of Ghislaine
+Maxwell," it is overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will
+interpret "Ghislaine Maxwell" or "Maxwell" as Ghislaine Maxwell.
+The Co-Executors also object to Plaintiff's definition of the term '
+" or
+' on the grounds that, insofar as it includes "any entities owned or controlled by |
+, any employee, agent, attorney, consultant, or representative of
+" it is
+overbroad, unduly burdensome, vague and ambiguous. The Co-Executors will interpret "1
+SPECIFIC OBJECTIONS AND RESPONSES TO REQUESTS
+REQUEST NO. 1
+All Documents relating to Plaintiff, Jane Doe 1000, whether or not they reference her by
+name. This Request includes, but is not limited to, all communications, diaries, journals, calendars
+blog posts (whether published or not), notes (handwritten or otherwise), memoranda
+documentation of car services, airline tickets and/or travel itineraries, wire transfer receipts, or any
+other Documents that concern Jane Doe 1000 in any way, whether or not they reference her by
+name.
+The Co-Executors object to Request No. 1 on the grounds and to the extent that it calls for
+2
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 4 of 51
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 1 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO.2
+All telephone records and other Documents reflecting telephone calls made by Epstein or
+to Epstein, including without limitation cell phone records, telephone logs, and message pads, to
+or from Epstein's employees.
+The Co-Executors object to Request No. 2 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 2 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-
+Executors further object to this Request on the grounds and to the extent that it calls for the
+production of documents and information outside their possession, custody, and control.
+3
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 5 of 51
+REQUEST NO. 3
+All telephone records and other documents reflecting telephone calls made by Epstein or
+to Epstein, including without limitation cell phone records, telephone logs and message pads, to
+or from Maxwell or
+The Co-Executors object to Request No. 3 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 3 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-
+Executors further object to this Request on the grounds and to the extent that it calls for the
+production of documents and information outside their possession, custody, and control.
+REQUEST NO. 4
+All telephone records associated with Epstein, Maxwell, or |
+including cell phone
+records, telephone logs, and message pads, that show any communications with Jane Doe 1000 or
+members of Jane Doe 1000's family.
+The Co-Executors object to Request No. 4 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 4 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-
+Executors additionally object to this Request on the grounds and to the extent that it specifically
+4
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 6 of 51
+calls for the production of documents and information outside their possession, custody, and
+control.
+REQUEST NO. 5
+All Documents relating to calendars, schedules, or appointments for Epstein.
+The Co-Executors object to Request No. 5 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 5 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-
+Executors also object to this Request on the grounds and to the extent that it assumes facts not in
+evidence.
+REQUEST NO. 6
+All Documents relating to contact lists, phone lists, or address books for Epstein.
+The Co-Executors object to Request No. 6 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 6 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 7
+5
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 7 of 51
+All Documents relating to any Amazon.com account associated with Epstein or
+Maxwell, including without limitation the purchase order history for each account.
+The Co-Executors object to Request No. 7 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors further object to Request No. 7 on the grounds that, to the extent it seeks documents that
+are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's claims nor
+proportional to the needs of this case; it is also overly broad and unduly burdensome. The Co-
+Executors additionally object to this Request on the grounds and to the extent that it specifically
+calls for the production of documents and information outside their possession, custody, and
+control. The Co-Executors also object to this Request on the grounds and to the extent that it
+assumes facts not in evidence.
+REQUEST NO. 8
+All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
+CDs, or any other print or electronic media depicting Epstein, Maxwell or
+in the presence
+of Jane Doe 1000.
+The Co-Executors object to Request No. 8 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors additionally object to this Request as duplicative of Request No. 9. The Co-Executors
+additionally object to this Request on the grounds and to the extent that it specifically calls for the
+production of documents and information outside their possession, custody, and control. The Co-
+Executors also object to this Request on the grounds and to the extent that it assumes facts not in
+6
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 8 of 51
+evidence.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO.9
+All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
+CDs, or any other print or electronic media depicting or relating to Jane Doe 1000.
+The Co-Executors object to Request No. 9 on the grounds and to the extent that it calls for
+the production of documents and information protected by the attorney-client privilege, attorney
+work product doctrine, and any other applicable privilege or protection from disclosure. The Co-
+Executors additionally object to this Request as duplicative of Request No. 8. The Co-Executors
+additionally object to this Request on the grounds and to the extent that it specifically calls for the
+production of documents and information outside their possession, custody, and control. The Co-
+Executors also object to this Request on the grounds and to the extent that it assumes facts not in
+evidence.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+7
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 9 of 51
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 10
+All Documents relating to any communications between Epstein, Maxwell, or and
+Jane Doe 1000 or family members of Jane Doe 1000.
+The Co-Executors object to Request No. 10 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 10 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the
+extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
+the grounds that it seeks information already known to Plaintiff or her counsel.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 11
+All Documents relating to any gifts or monetary payments provided to, or for the benefit
+8
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 10 of 51
+of, Jane Doe 1000 by Epstein, Maxwell, or l
+or any related entity.
+The Co-Executors object to Request No. 11 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the
+extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
+the grounds that it seeks information already known to Plaintiff or her counsel.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 12
+All Documents relating to communications between Epstein and Maxwell or
+about
+Jane Doe 1000.
+The Co-Executors object to Request No. 12 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+9
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 11 of 51
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the
+extent that it assumes facts not in evidence.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 13
+All Documents relating to Jane Doe 1000's travel to Florida.
+The Co-Executors object to Request No. 13 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the extent
+that it assumes facts not in evidence. The Co-Executors further object to this Request on the
+grounds that it seeks documents in Plaintiff's possession.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+10
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 12 of 51
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 14
+All Documents relating to Epstein or his employees obtaining or preparing travel
+documents for Jane Doe 1000's travel.
+The Co-Executors object to Request No. 14 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors also object to this Request on the grounds that the term "travel
+documents" is vague and ambiguous. The Co-Executors additionally object to this Request on the
+grounds and to the extent that it specifically calls for the production of documents and information
+outside their possession, custody, and control.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 15
+All Documents relating to any modeling referral, job, audition, casting, or other
+opportunity that Epstein or his employees assisted Jane Doe 1000 in obtaining.
+11
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 13 of 51
+The Co-Executors object to Request No. 15 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors further object to this Request on the grounds that it seeks
+information in Plaintiff's possession.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 16
+All Documents relating to any accommodations made by Epstein or his employees for Jane
+Doe 1000 at an apartment building located at 301 E. 66" Street, New York, NY.
+The Co-Executors object to Request No. 16 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+12
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 14 of 51
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 17
+All Documents relating to McDonald/Richards Model Management.
+The Co-Executors object to Request No. 17 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 17 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 18
+All Documents relating to any service that Epstein, Maxwell, or
+provided or funded
+for Jane Doe 1000, including but not limited to hair appointments and dentist appointments.
+The Co-Executors object to Request No. 18 on the grounds and to the extent that it calls
+13
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 15 of 51
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the
+extent that it assumes facts not in evidence. The Co-Executors further object to this Request on
+the grounds that it seeks documents in Plaintiff's possession.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and ESI protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 19
+All Documents relating to any employee lists or records associated with Epstein or any
+related entity.
+The Co-Executors object to Request No. 19 on the grounds and to the extent that it
+calls for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 19 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 20
+14
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 16 of 51
+All Documents relating to payments made from Epstein, or any related entity, to Maxwell.
+(a/k/a
+(a/k/a
+D, including payments or bonuses for work performed, gifts, real estate purchases, living
+expenses, business ventures, and payments to Maxwell's charitable endeavors, including the
+TerraMar project.
+The Co-Executors object to Request No. 20 on the grounds and to the extent that it
+calls for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 20 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO.21
+All Documents relating to any credit card, business, or store account used by Maxwell,
+Groff,
+or
+that was paid for by Epstein or any related
+entity.
+The Co-Executors object to Request No. 21 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 21 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+15
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 17 of 51
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 22
+All Documents relating to confidentiality or separation agreements between Epstein or any
+associated entity and any employee or associate of Epstein.
+The Co-Executors object to Request No. 22 on the grounds and to the extent that it
+calls for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 22 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+REQUEST NO. 23
+All Documents relating to any house staff, employees, or individuals who were
+compensed by Bipl, in oriny ind nod lord to ye filed with fridials en and Brane,
+Luciano "Jojo" Fontanilla, Rosalyn "
+Fontani a guay Cressi, Maria Alest.
+Michael Liffman, Cathy and Miles Alexander,
+, Floyd |
+Brice
+Michael O'Dell, Kate O'Dell, David
+Larry Visoski, David Rodgers, Andy
+Stewart, Adam
+ang. Rvon Dionne and Igor Zinovier
+The Co-Executors object to Request No. 23 on the grounds and to the extent that it
+16
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 18 of 51
+calls for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 23 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 24
+All Documents relating to Rinaldo Rizzo from 2002 to the present.
+The Co-Executors object to Request No. 24 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 24 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 19 of 51
+REQUEST NO. 25
+All Documents identifying any employees that performed work or services in or on any
+property owned, occupied, or used by Epstein.
+The Co-Executors object to Request No. 25 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 25 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 26
+All Documents reflecting Your or Epstein's direct or indirect interest or control over
+business or personal assets of any employee or associate of Epstein, including but not limited to
+articles of incorporation, power of attorneys, contracts, and meeting minutes.
+The Co-Executors object to Request No. 26 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 26 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to Request No. 26 on the grounds of and to the extent it
+18
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 20 of 51
+seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-
+Executors also object to this Request on the grounds and to the extent that it assumes facts not in
+evidence.
+REQUEST NO. 27
+All video tapes, audio tapes, photographs, portraits, including film negatives or film slides,
+CDs, flash drives, memory cards, or any other print or electronic media depicting Epstein in the
+presence of Maxwell or
+The Co-Executors object to Request No. 27 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 27 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 28
+All Documents relating to Maxwell, including but not limited to all Documents relating to
+communications between Epstein and Maxwell or
+The Co-Executors object to Request No. 28 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 28 on the grounds that, to the extent it seeks
+19
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 21 of 51
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 29
+All Documents relating to any agreements (including but not limited to confidentiality
+agreements, insurance policies or indemnification agreements, employment agreements,
+separation agreements, or agreements to pay legal fees) between Epstein and Maxwell or
+whether such agreements are written, verbal, or merely understood among the parties and no
+otherwise expressed, whether or not such agreements were ever executed or carried out.
+The Co-Executors object to Request No. 29 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 29 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+possession, custody, and control. The Co-Executors also object to this Request on the grounds
+that the phrase "merely understood among the parties and not otherwise expressed" is vague and
+ambiguous.
+20
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 22 of 51
+REQUEST NO.30
+All Documents relating to any Joint Defense Agreement entered into between Epstein and
+Maxwell or
+The Co-Executors object to Request No. 30 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 30 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+REQUEST NO. 31
+All Documents relating to or describing any work Maxwell or
+with Epstein or any affiliated entity.
+performed for or
+The Co-Executors object to Request No. 31 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 31 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+21
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 23 of 51
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 32
+All Documents related to any communications between Epstein or Epstein's attorneys and
+attorneys related to the issue of sexual abuse of females.
+The Co-Executors object to Request No. 32 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 32 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 33
+All Documents related to any communications between Epstein or Epstein's attorneys and
+Maxwell or Maxwell's attorneys related to the issue of sexual abuse of females.
+The Co-Executors object to Request No. 33 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 33 on the grounds that, to the extent it seeks
+22
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 24 of 51
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 34
+All Documents related to any communications between Epstein or Epstein's attorneys and
+or
+attorneys related to the recruitment of any female for any purpose, including
+socializing or performing any type of work or service.
+The Co-Executors object to Request No. 34 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 34 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 35
+All Documents related to any communications between Epstein or Epstein's attorneys
+and Maxwell or Maxwell's attorneys related to the recruitment of any female for any purpose,
+including socializing or performing any type of work or service. RESPONSE:
+23
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 25 of 51
+The Co-Executors object to Request No. 35 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 35 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 36
+All Documents relating to any bank account, household account, or financial account
+identifying Maxwell in any way, including without limitation as an authorized user on the account.
+The Co-Executors object to Request No. 36 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 36 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+possession, custody, and control. The Co-Executors also object to this Request on the grounds
+24
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 26 of 51
+that the terms "household account" and "financial account" are vague and ambiguous.
+REQUEST NO. 37
+All Documents or other media (including photographs) describing or depicting nude or
+partially nude females, including but not limited to all Documents or other media describing or
+depicting how such photographs were displayed in any of Epstein's various residences.
+The Co-Executors object to Request No. 37 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 37 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+possession, custody, and control. The Co-Executors further object to this Request on the grounds
+that it seeks publicly available information and information already known to Plaintiff or her
+counsel.
+REQUEST NO. 38
+All Documents relating to any payments Epstein made to educational institutions or
+programs as sad fore rene a che pers and him engrame tid, to there the
+person.
+The Co-Executors object to Request No. 38 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+25
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 27 of 51
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 38 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 39
+All Documents relating to any request, proposal, or inquiry made by Epstein, Maxwell or
+to any modeling agency for casting, recruitment, potential employment, and/or other
+advancement opportunities and Documents reflecting the identity of any person responding to
+the request, proposal, or inquiry.
+The Co-Executors object to Request No. 39 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 39 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 40
+All Documents relating to calendars, schedules, or appointments for Epstein that relate to
+26
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 28 of 51
+visits with or communications with females, excluding immediate family members.
+The Co-Executors object to Request No. 40 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 40 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 41
+All Documents identifying any individuals who ever provided Epstein with a massage.
+The Co-Executors object to Request No. 41 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 41 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+27
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 29 of 51
+custody, and control.
+REQUEST NO. 42
+All Documents identifying any individuals who Epstein paid for sexual acts, either with
+Epstein or with other individuals.
+The Co-Executors object to Request No. 42 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 42 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 43
+All Documents identifying any females recruited or referred by Maxwell or
+work, sexual acts, or companionship for Epstein.
+for
+The Co-Executors object to Request No. 43 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 43 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+28
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 30 of 51
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 44
+All Documents relating to any females Maxwell or
+sexual acts, or companionship for Epstein.
+introduced to Epstein for work,
+The Co-Executors object to Request No. 44 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 44 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 45
+All Documents relating to any females Epstein paid to perform any kind of service,
+including but not limited to work as an assistant, massage therapist, model, private exercise
+instructor, dance instructor or companion.
+The Co-Executors object to Request No. 45 on the grounds and to the extent that it calls
+29
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 31 of 51
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 45 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 46
+All Documents relating to massages, including but not limited to Documents reflecting
+recruiting or hiring masseuses, advertising for masseuses, flyers created for distribution at high
+schools or colleges, and Documents reflecting e-mails or calls to individuals relating to massages
+The Co-Executors object to Request No. 46 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 46 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+30
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 32 of 51
+REQUEST NO. 47
+All Documents relating to passports applied for, obtained, or paid for by Epstein on behalf
+of any female recruited to work for Epstein to perform any kind of service, including but not
+limited to work as an assistant, massage therapist, model, private exercise instructor, dance
+instructor, or companion.
+The Co-Executors object to Request No. 47 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 47 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it secks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 48
+All Documents relating to Epstein's travel, when that travel was either with Maxwell,
+, or other females or to meet Maxwell,
+1. or other females, including but not limited
+to documentation of commercial flights, private flights, helicopters, boat charters, and car services,
+passport records, records indicating passengers traveling with Epstein, hotel records, and credit
+The Co-Executors object to Request No. 48 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 48 on the grounds that, to the extent it seeks
+31
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 33 of 51
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 49
+All Documents relating to Epstein's travel to and from Florida between 1999 and 2003.
+The Co-Executors object to Request No. 49 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 49 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 50
+All Documents, including flight logs, identifying passengers, manifests, or flight plans for
+any helicopter or plane ever owned, leased, chartered, or controlled by Epstein or any associated
+entity, from 1995 to the present.
+The Co-Executors object to Request No. 50 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 50 on the grounds that, to the extent it seeks
+32
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 34 of 51
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to the time period stated in the Request, which is inconsistent
+with the time frame alleged in the Complaint.
+REQUEST NO. 51
+All Documents relating to travel with Epstein of any female, including but not limited to
+documentation of commercial flights, private flights, helicopters, boat charters, car services,
+passport records, records indicating passengers traveling with Epstein, hotel records, and credit
+card receipts.
+The Co-Executors object to Request No. 51 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 51 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 52
+All video tapes, audio tapes, photographs or any other print or electronic media depicting
+any of Epstein's residences or aircrafts or inside of any of Epstein's residences or aircrafts.
+The Co-Executors object to Request No. 52 on the grounds and to the extent that it calls
+33
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 35 of 51
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 52 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 53
+All Documents relating to Epstein's ownership, lease, occupancy, use, or management of
+property located at 301 East 66' Street, New York, NY.
+The Co-Executors object to Request No. 53 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 53 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 54
+All Documents relating to Alan Dershowitz.
+The Co-Executors object to Request No. 54 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 54 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+34
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 36 of 51
+The Co-Executors additionally object to this Request as duplicative of Request No. 55. The Co-
+Executors additionally object to this Request on the grounds and to the extent that it specifically
+calls for the production of documents and information outside their possession, custody, and
+control.
+REQUEST NO. 55
+All Documents relating to any communications between Epstein or Epstein's attorneys and
+Alan Dershowitz or Alan Dershowitz's attorneys.
+The Co-Executors object to Request No. 55 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 55 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+possession, custody, and control. REQUEST NO. 56
+All Documents relating to any communications between Epstein or Maxwell and Alan
+Dershowitz relating to Jane Doe 1000.
+The Co-Executors object to Request No. 56 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+35
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 37 of 51
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors also object to this Request on the grounds and to the
+extent that it assumes facts not in evidence.
+Subject to and without waiving these objections and the parties' entry into a mutually
+acceptable confidentiality agreement and (proposed) order and EST protocol, the Co-Executors
+will search for and produce non-privileged documents concerning Plaintiff, if any exist and are
+located pursuant to mutually agreeable search parameters. The Co-Executors are working to
+collect and process documents for these purposes and will meet and confer with counsel for
+Plaintiff about the search as soon as practicable.
+REQUEST NO. 57
+All Documents relating to any communications between Epstein's attorneys and Alan
+Dershowitz or Alan Dershowitz's attorneys relating to Jane Doe 1000.
+The Co-Executors object to Request No. 57 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 57 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 58
+All Documents relating to any Joint Defense Agreement entered into between Epstein and
+Alan Dershowitz.
+36
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 38 of 51
+The Co-Executors object to Request No. 58 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 58 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 59
+All Documents relating to Alan Dershowitz traveling with Epstein or to any of Epstein's
+homes.
+The Co-Executors object to Request No. 59 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 59 on the grounds that, to the extent it secks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 60
+All Documents relating to Eva
+or Glen |
+The Co-Executors object to Request No. 60 on the grounds and to the extent that it calls
+37
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 39 of 51
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 60 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 61
+All Documents reflecting or consisting of communications between Jeffrey Epstein and
+MCZ Models or Jean-Luc Brunel, relating or referring to females coming into the United States
+from other countries to pursue a career in modeling, including, but not limited to, letters, notes,
+and emails
+The Co-Executors object to Request No. 61 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 61 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it secks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 62
+All Documents relating to communications with William "Bill" J. Clinton or persons acting
+on his behalf.
+38
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 40 of 51
+The Co-Executors object to Request No. 62 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 62 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 63
+intervenor in
+All Documents relating to communications between You or Epstein and John Doe, the
+v. Maxwell, No. 15-cv-07433-LAP (S.D.N.Y.), or John Doe's attorneys.
+The Co-Executors object to Request No. 63 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 63 on the grounds that, to the extent it secks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to Request No. 63 on the grounds of and to the extent it
+seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-
+Executors additionally object to this Request on the grounds and to the extent that it specifically
+calls for the production of documents and information outside their possession, custody, and
+control. The Co-Executors further object to this Request on the grounds that it seeks information
+already known to Plaintiff or her counsel.
+39
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 41 of 51
+REQUEST NO. 64
+All Documents relating to Leslie Wexner or Abigail Wexner.
+The Co-Executors object to Request No. 64 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 64 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds of and to the extent it seeks
+documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-
+Executors additionally object to this Request on the grounds and to the extent that it specifically
+calls for the production of documents and information outside their possession, custody, and
+control.
+REQUEST NO. 65
+All Documents reflecting Your or Epstein's direct or indirect interest or control over
+business or personal assets of Leslie Wexner or Abigail Wexner, including but not limited to
+articles of incorporation, power of attorneys, contracts, and meeting minutes.
+The Co-Executors object to Request No. 65 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 65 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+40
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 42 of 51
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to Request No. 65 on the grounds of and to the extent it
+seeks documents necessarily held in a capacity other than as Co-Executors of the Estate. The Co-
+Executors also object to this Request on the grounds and to the extent that it assumes facts not in
+evidence.
+REQUEST NO. 66
+All Documents relating to any business transactions, including real estate and other
+financial transactions, between Epstein and Leslie Wexner from 1990 to the present.
+The Co-Executors object to Request No. 66 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 66 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to the time period stated in the Request, which is inconsistent
+with the time frame alleged in the Complaint. The Co-Executors also object to this Request on the
+grounds and to the extent that it assumes facts not in evidence.
+REQUEST NO. 67
+All Documents relating to Victoria's Secret models or actresses who were ever in the
+presence of Epstein between 1999 and the present.
+The Co-Executors object to Request No. 67 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+41
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 43 of 51
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 67 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 68
+All Documents relating to any work that Epstein performed for Victoria's Secret or
+authority that Epstein possessed over Victoria's Secret.
+The Co-Executors object to Request No. 68 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 68 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 69
+All Documents relating to modeling jobs, auditions, casting calls, or other opportunities
+42
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 44 of 51
+with Victoria's Secret or any modeling agency, that Epstein assisted any person in securing.
+The Co-Executors object to Request No. 69 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 69 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 70
+Edward,
+All Documents relating to communications between Epstein and Andrew Albert Christian
+of York (a/k/a Prince Andrew) or persons acting on his behalf.
+The Co-Executors object to Request No. 70 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 70 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+43
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 45 of 51
+not in evidence. The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 71
+From January 2012 to the present, all Documents concerning any source of funding for the
+TerraMar Project or any other not-for-profit entities for which Epstein provided funding, including
+but not limited to funding for the Clinton Global Initiative, the Clinton Foundation (a/k/a William
+J. Clinton Foundation, a/k/a/ the Bill, Hillary & Chelsea Clinton Foundation), and the Clinton
+Foundation Climate Change Initiative.
+The Co-Executors object to Request No. 71 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 71 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors also object to this Request on the grounds and to the extent that it assumes facts
+not in evidence.
+The Co-Executors additionally object to this Request on the grounds and to the
+extent that it specifically calls for the production of documents and information outside their
+REQUEST NO. 72
+All Documents relating to Epstein's estate planning, will, or any financial transactions that
+occurred between the date of his arrest on July 6, 2019, and his death on August 10, 2019.
+The Co-Executors object to Request No. 72 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+44
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 46 of 51
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 72 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 73
+All Documents relating to communications between Epstein or Epstein's attorneys or
+agents and any law enforcement entity, including the FBI, NYPD, Palm Beach Police Department,
+and West Palm Beach Police Department, relating to any criminal investigation, cooperation in
+any criminal investigation, potential criminal charges, immunity, deferred prosecution, or
+suspected or known criminal activity.
+The Co-Executors object to Request No. 73 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 73 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors further object to this Request on the grounds that it seeks publicly available
+information and information already known to Plaintiff or her counsel.
+REQUEST NO. 74
+All Documents relating to communications between Epstein and Epstein's attorneys or
+agents and Alexander Acosta, Maria Villafana, or other attorneys associated with the United States
+Attorney's Office for the Southern District of Florida.
+The Co-Executors object to Request No. 74 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+45
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 47 of 51
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 74 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors further object to this Request on the grounds that it seeks publicly available
+information and information already known to Plaintiff or her counsel.
+REQUEST NO. 75
+All Documents concerning any action or lawsuit brought against Epstein or Maxwell or
+, including but not limited to actions or lawsuits brought in foreign jurisdictions.
+The Co-Executors object to Request No. 75 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 75 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors further object to Request No. 75 on the grounds that it seeks publicly available
+information and information already known to Plaintiff or her counsel.
+REQUEST NO. 76
+All Documents produced by Epstein or Maxwell in discovery in |
+15-cv-07433-L.AP (S.D.N.Y.).
+v. Maxwell, No.
+The Co-Executors object to Request No. 76 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+46
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 48 of 51
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 76 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control. The Co-Executors further object to this Request on the grounds that it seeks
+publicly available information and information already known to Plaintiff or her counsel.
+REQUEST NO. 77
+All Documents seized by any government agency from Epstein's home located at 9 East
+71" Street, New York, New York or at 358 El Brillo Way, Palm Beach, Florida.
+The Co-Executors object to Request No. 77 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 77 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+The Co-Executors additionally object to this Request on the grounds and to the extent that it
+specifically calls for the production of documents and information outside their possession,
+custody, and control.
+REQUEST NO. 78
+All Documents relating to the "two .... payments, one in the amount of $250,000 and
+another in the amount of $100,000 to ... two employees or associates of Mr. Epstein's" referenced
+by Assistant United States Attorney Alexander Rossmiller at Epstein's bail hearing on July 15,
+47
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 49 of 51
+2019, including Documents sufficient to identify the recipients of those payments. See Transcript
+of July 15, 2019 Bail Hearing at 9:15-20, United States v. Epstein, No. 19-cr-490 (RMB)
+(S.D.N.Y.).
+The Co-Executors object to Request No. 78 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 78 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+REQUEST NO. 79
+All Documents relating to Shoppers Travel, including records of payment to Shoppers
+Travel, communications with Shoppers Travel, or records of any airline tickets, hotel reservations,
+or other travel accommodations booked through Shoppers Travel by Epstein or his agents or
+The Co-Executors object to Request No. 79 on the grounds and to the extent that it calls
+for the production of documents and information protected by the attorney-client privilege,
+attorney work product doctrine, and any other applicable privilege or protection from disclosure.
+The Co-Executors further object to Request No. 79 on the grounds that, to the extent it seeks
+documents that are not related to Plaintiff, it seeks information that is neither relevant to Plaintiff's
+claims nor proportional to the needs of this case; it is also overly broad and unduly burdensome.
+48
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 50 of 51
+April 16, 2020
+TROUTMAN SANDERS LLP
+By: /s/Bennet Moskowitz
+Bennet Moskowitz
+875 Third Avenue
+New York, New York 10022
+Tel: (212) 704- 6087
+bennet.moskowitz@troutman.com
+Attorney for Darren K. Indyke and
+Richard D. Kahn, as co-executors of
+the estate of Jeffrey E. Epstein
+49
+
+
+Case 1:19-CV-10577-LJL-DCF Document 46-5 Filed 05/07/20 Page 51 of 51
+The undersigned certifies that on April 16, 2020, I served a copy of the foregoing
+Defendants' Objections and Responses to Plaintiff Jane Doe 1000's First Request for Production
+of Documents to Defendants, by sending them by email to:
+Sigrid McCawley
+Boies, Schiller & Flexner LLP
+401 E. Las Olas Blvd., Suite 1200
+Fort Lauderdale, FL, 33301
+Email: smccawley@bsfllp.com
+TROUTMAN SANDERS LLP
+By: Is/Mary
+W. Metcalfe
+Mary
+W. Metcalfe
+875 Third Avenue
+New York, New York 10022
+Tel: (212) 704-6029
+marygrace.metcalfe@troutman.com
+Attorney for Darren K. Indyke and
+50
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 1 of 4
+
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 2 of 4
+| SCHILLER
+FLEXNER
+Sigrid S. McCawley
+Telephone: (954) 377-4223
+Email: smccawley@bsfllp.com
+April 20, 2020
+VIA EMAIL
+Bennet J. Moskowitz
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+Tel: (212) 704-6087
+bennet.moskowitz/@troutman.com
+Re:
+Jane Doe 1000 v. Indyke et al., Case No. 19-cv-10577
+Dear Bennet:
+I write on behalf of Plaintiff Jane Doe 1000 in response to Defendants Darren K. Indyke
+and Richard D. Kahn, as co-executors of the Estate of Jeffrey E. Epstein (the "Estate"), responses
+and objections to the Plaintiff's discovery requests provided on April 16, 2020. As you likely have
+anticipated, I specifically write in response to your total failure to respond to your discovery
+obligations. I ask that we meet and confer about your lack of responses as soon as practicable.
+First, as you are aware, Plaintiff served eighteen interrogatories on Defendants. You
+answered none of them; rather, each interrogatory is met with an assortment of boilerplate
+objections, ranging from objections to relevancy or "discovery about discovery" or assuming
+"facts not in evidence" (which is especially puzzling, given that the very purpose of discovery is
+to find such facts). At best, these objections are deficient; at worst, they are meritless and
+borderline frivolous.
+Similarly, you have failed to adequately respond to most of Plaintiff's document requests.
+Again, your objections are premised on conclusory objections, ranging from objections to
+relevancy and claims that certain documents are outside Defendants' possession, custody, and
+control. As part of your discovery obligations, "generalized objections that discovery requests are
+vague, overly broad, or unduly burdensome are not acceptable." Shanchun Yu v. Diguojiaoyu,
+Inc., 18-CV-7303, 2019 WL 6174204, *4-5 (S.D.N.Y. Nov. 20, 2019) (granting plaintiffs' motion
+to compel discovery after defendants "raised repeated and rote objections to Plaintiffs' document
+requests, [] refused to provide Plaintiffs any documents whatsoever, and [lanswered the
+interrogatories in [a] substantially similar fashion"); see also Harris v. Bronx Parent Housing
+Network, Inc., 18-CV-11681, 2020 WL 763740, at *2 (S.D.N.Y. Feb. 14, 2020) ("Boilerplate
+objections that include unsubstantiated claims of undue burden, overbreadth and lack of relevancy,
+accompanied by a lack of document production or interrogatory response, are a paradigm of
+discovery abuse.") (internal quotation marks and citation omitted). "A party resisting discovery
+401 East Las Olas Boulevard, Suite 1200, Fort Lauderdale, FL 33301 | (t) 954 356 0011 | (f) 954 356 0022 | www.bsfllp.com
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 3 of 4
+April 20, 2020
+Page 2
+has the burden of showing specifically how, despite the broad and liberal construction afforded
+the federal discovery rules, each interrogatory is not relevant or how each question is overly broad,
+burdensome or oppressive ... by submitting affidavits or offering evidence revealing the nature
+of the burden." Harris, 2020 WL 763740, at *2 (internal quotation marks and citations omitted).
+Second, your relevance objections are meritless. All of Plaintiff's requests are relevant.
+For example, please explain how documents relating to Jane Doe 1000 are not relevant to her
+claims or are not reasonably calculated to lead to the discovery of admissible evidence. See
+Request 1. Epstein abused Plaintiff several times a week for years and housed her in one of his
+apartment buildings. She is entitled to any documents that relate to her. Plaintiff's other requests
+are also directly relevant to her claims or the Estate's affirmative defenses. She is entitled to
+discovery, for example, about Epstein's relationship with Les Wexner, Victoria's Secret, or any
+other modeling connections about which Epstein lied (e.g., RFPs 15, 17, 39, 61, 64-69); any
+Epstein-affiliated attorney she was forced to meet with at Epstein's direction (e.g., RFPs 54-55,
+57-59; Interrogatories 10, 17); Epstein's communications with associates who were present in his
+homes when Plaintiff was abused (e.g., RFP 70); documents relating to the co-conspirators who
+helped Epstein recruit and abuse Plaintiff (e.g., RFPs 3, 4, 12, 25, 28, 29); and Plaintiff's and
+Epstein's travel to the places in which Epstein abused Plaintiff. (e.g., RFPs 13, 14, 48-51;
+Interrogatory 6).
+Moreover, Plaintiff is entitled to know the breadth and nature the sex-trafficking operation
+that she was victimized by. See Fed. R. Evid. 415 ("In a civil case involving a claim for relief
+based on a party's alleged sexual assault or child molestation, the court may admit evidence that
+the party committed any other sexual assault or child molestation."). Plaintiff alleges that Epstein
+utilized his sex-trafficking operation to recruit and abuse countless young girls and women in a
+methodical and similar fashion. Epstein's recruitment, trafficking, and assault of other girls in the
+same way that he recruited, trafficked, and assaulted Plaintiff would make Plaintiff's allegations
+more probable. See Fed. R. Evid. 401. Plaintiff's discovery requests are therefore directly relevant
+to the allegations in her Complaint, or, at a minimum, are reasonably calculated to lead to the
+discovery of admissible evidence.
+Third, your objections to certain of the time periods stated in the Requests are meritless for
+several reasons. As explained above, Epstein's other sexual assaults would be both relevant and
+admissible in this case, regardless of time period. Further, you have raised a statute of limitations
+defense in Plaintiff's case, and Plaintiff has made an equitable estoppel argument in response.
+Plaintiff is entitled to discovery relevant to her equitable estoppel theory, including but not limited
+to any threats or misrepresentations that Epstein made to Plaintiff to prevent her from filing this
+lawsuit, outside of the time period during which Plaintiff was physically abused by Epstein.
+Fourth, your objection to Plaintiff's definition of Jeffrey Epstein as including "any entities
+owned or controlled by Jeffrey Epstein, any employee, agent, attorney, consultant, or
+representative of Jeffrey Epstein" is an improper attempt to narrow your discovery obligations in
+this matter. Your objection directly contradicts the Local Rules of this Court, which define the
+
+
+Case 1:19-cv-10577-LJL-DCF Document 46-6 Filed 05/07/20 Page 4 of 4
+April 20, 2020
+Page 3
+word "parties" as including a defendant's "employees, partners, ... or affiliates." Local Rule
+26.3(c)(5). Plaintiff's definition is proper.
+Fifth, your responses and objections state many times that certain documents and
+information are outside of the Estate's possession, custody, and control. If that is the case, please
+explain what is and is not within the Estate's possession and control. For example, please explain
+in detail what computers, hard drives, email accounts, telephone records, or hard copy documents
+you have reviewed and provide a list of search terms that were used and specifically list what items
+you claim to not have access to. We know that Epstein at a minimum used the following email
+• jeffreye@mindspring.com;
+• Jeeproject(@yahoo.com;
+• jeevacation@gmail.com;
+• jepstein@revonet.com;
+• zorroranch@aol.com;
+• cecilia@ellmax.com:
+•
+• jeffrey.epstein@centurytel.net; and
+• epsteinj@ wanadoo.fr
+Confirm that you have accessed and searched each of these accounts and provide the
+protocol used for the search. In the alternative, if the Estate contends that information that is
+responsive to Plaintiff's discovery requests was destroyed, provide all details relating to the
+destruction.
+Please let us know your availability for a meet and confer on the following dates and times:
+• Wednesday, April 22, 2020 between 2:00 and 3:00 EST;
+• Thursday, April 23, 2020 between 3:00 EST and 6:00 EST; and
+• Friday, April 24, 2020 between 3:00 EST and 5:00 EST.
+Sincerely,
+Is/ Sigrid S. McCawley
+Sigrid S. McCawley
+cc: Counsel of Record
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f5e3a8c5d2ca9c74d0eda5131bfb5778bec5117f24a96f86fa80186eeae1fa68.receipt.json b/vision-fixhub/court-01/f5e3a8c5d2ca9c74d0eda5131bfb5778bec5117f24a96f86fa80186eeae1fa68.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/f5eda4416386a26fc8fb020e43efafe2e7015ca02cf358fc61033d30df0487f6.md b/vision-fixhub/court-01/f5eda4416386a26fc8fb020e43efafe2e7015ca02cf358fc61033d30df0487f6.md
new file mode 100644
index 0000000000000000000000000000000000000000..31d66dc078be82da73fe97aef49e0bac25783401
--- /dev/null
+++ b/vision-fixhub/court-01/f5eda4416386a26fc8fb020e43efafe2e7015ca02cf358fc61033d30df0487f6.md
@@ -0,0 +1,219 @@
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/]
+1
+
+
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 2 of 8
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA1
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA /C
+2
+
+
+Case 9:09-cv-80591-KAM Document 66
+Entered on FLSD Docket 07/29/2009 Page 3 of 8
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFES JANE DOES' 2- 7 MOTION FOR PROTECTIVE
+ORDER AND INCORPORATED MEMORANDUM OF LAW
+Plaintiffs, Jane Does 2-7 ("Plaintiffs" or individually, "Plaintiff"), by and through
+undersigned counsel, hereby file Plaintiffs' Motion for Protective Order, pursuant to
+S.D.Fla.L.R. 7.1, and state as follows:
+1.
+Plaintiffs Jane Does 2-7 are proceeding with a Jane Doe pseudonym as this case
+involves facts of the utmost intimacy and there is a genuine risk of psychological harm if their
+identities are disclosed. See Exhibit "A" (Declaration of Gilbert Kliman, M.D.) (See also DE
+144, Jane Does' 2-7 Response to Defendant's Motion to Compel Identity, et al.).
+3
+
+
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 4 of 8
+2.
+Despite the obvious need for Plaintiffs to have their identities protected,
+Defendant Jeffrey Epstein has employed investigators who have made repeated contacts with exboyfriends, former employers, and others who know nothing of the underlying facts of the case.
+These investigators have contacted such nonparties asking them for extensive personal
+information about a Plaintiff, such as names and contact information of former boyfriends and
+other friends and acquaintances in the Plaintiff's community.
+3.
+The Defendant's repeated contacts with these nonparties is harassing and
+designed to intimidate the Plaintiffs. The purpose and intent of these contacts is to brand the
+Plaintiffs as alleged sexual abuse victims to their families, friends and communities.
+4.
+A Motion is pending in which this Court is being asked to determine whether and
+how Defendant may obtain discovery from nonparties. (DE 91, 144). Defendant's investigative
+efforts improperly circumvent the issues in the pending Motion, and only serve to highlight the
+need for this Court to implement appropriate protective measures to prevent Defendant from
+harassing, intimidating, and intruding unnecessarily into the personal lives of the Plaintiffs.
+5.
+While it is not unusual for a defendant to use appropriate means to obtain records
+from former employers and others referenced in a plaintiff's discovery responses, it is not
+customary for a defendant to retain private investigators to make personal contact with these
+individuals. Indeed, this practice is particularly inappropriate in a sexual abuse case where these
+nonparties are unaware of the underlying abuse. Plaintiffs have a well-grounded fear that the
+investigators will use the opportunity of their contacts with these nonparties to "out" the
+Plaintiffs' as alleged childhood sexual abuse victims of Jeffrey Epstein. (See Kliman Decl., Exh.
+"A" hereto).
+4
+
+
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 5 of 8
+6.
+As an example of the investigators' intimidation tactics, three of Defendant's
+investigators recently called the former employer of Jane Doe 4 on repeated occasions over a
+two-day period, asking personal questions about her, including the name and telephone number
+of her ex-boyfriend. See Exhibit "B", Declaration of Jane Doe 4.
+7.
+Similarly, one of Defendant's investigators contacted the former employer of Jane
+Doe 6. See Exhibit "C", Declaration of Jane Doe 6.
+8.
+There is no basis for Defendant or his multiple investigators to make repeated
+personal contacts with former employers and ex-boyfriends to ask personal questions about a
+Plaintiff. It is apparent that these contacts are not designed to obtain relevant information, but
+rather are intended to intimidate the Plaintiffs and to reveal that they are childhood sexual abuse
+victims.
+9.
+Accordingly, Plaintiffs request the entry of a protective order that would prevent
+Defendant, his attorneys and investigators from making ex parte contacts concerning this
+litigation with nonparties who have no knowledge that a Plaintiff was a childhood sexual abuse
+victim of Jeffrey Epstein.
+10. This Court has discretion to enter a protective order designed to protect a party
+from, among other things, annoyance or embarrassment. Fed.R.Civ.P. 26(c). As set forth above,
+given the investigators' conduct, a protective order is appropriate to prevent unnecessary
+intrusion into the Plaintiffs' personal lives and divulgation of Plaintiffs in their communities as
+childhood sexual abuse victims.
+WHEREFORE, Plaintiffs Jane Does 2-7, respectfully request that this Court grant
+Plaintiffs' Motion for Protective Order, as follows: (i) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties identified in plaintiffs" discovery
+5
+
+
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 6 of 8
+responses, such as, for example, former employers; (ii) order Defendant, his attorneys and
+investigators to cease making ex parte contacts with nonparties found during the course of
+discovery or investigation who know the Plaintiff or live in her community, such as, for example,
+current and former boyfriends and family friends of the Plaintiffs; (il) order Defendant, his
+attorneys and investigators to cease making ex parte contacts with nonparties who otherwise
+know one of the Plaintiffs personally but who are unaware that she is an alleged victim of
+childhood sexual abuse by Jeffrey Epstein; and (iv) grant all such other relief this Court deems
+just and appropriate.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: July 29, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+6
+
+
+Case 9:09-cv-80591-KAM Document 66 Entered on FLSD Docket 07/29/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on July 29, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+7
+
+
+Case 9:09-cv-80591-KAM Document 66
+Entered on FLSD Docket 07/29/2009 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Is/ Adam D. Horowitz
+8
diff --git a/vision-fixhub/court-01/f5eda4416386a26fc8fb020e43efafe2e7015ca02cf358fc61033d30df0487f6.receipt.json b/vision-fixhub/court-01/f5eda4416386a26fc8fb020e43efafe2e7015ca02cf358fc61033d30df0487f6.receipt.json
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diff --git a/vision-fixhub/court-01/f5fa07f5b7e651532a4b5db0459089a551232faf8f6b0f7804246693578daae0.md b/vision-fixhub/court-01/f5fa07f5b7e651532a4b5db0459089a551232faf8f6b0f7804246693578daae0.md
new file mode 100644
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--- /dev/null
+++ b/vision-fixhub/court-01/f5fa07f5b7e651532a4b5db0459089a551232faf8f6b0f7804246693578daae0.md
@@ -0,0 +1,28 @@
+Case 1:19-cv-08673-KPF-DCF Document 26-1 Filed 11/12/19 Page 1 of 2
+
+
+
+Case Gas 94198673900-PAE D000-eRn 236-Filed 19p081192/page Rage12 of 2
+UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK
+CASE NO. 1:19-cv-09610-PAE
+JANE DOE 17,
+Plaintiff,
+V.
+DARREN K. INDYKE AND
+RICHARD D. KAHN, AS JOINT
+PERSONAL REPRESENTATIVES OF
+THE ESTATE OF JEFFREY E. EPSTEIN,
+NINE EAST 71st STREET CORPORATION,
+LAUREL, INC., FINANCIAL TRUST COMPANY,
+INC., NES, LLC, MAPLE, INC., LSJE, LLC,
+HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC.
+Defendants.
+PROPOSED ORDER GRANTING PLAINTIFF'S
+MOTION TO PROCEED ANONYMOUSLY
+Upon the motion of Plaintiff for an order permitting the filing of the Complaint,
+summons, civil cover sheet, and all future papers anonymously, it is hereby
+ORDERED that Plaintiff's Motion for Leave to Proceed Anonymously be GRANTED.
+Dated: November 8
+, 2019
+Page 1 of l
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/f6139c67cdb3891c599db0e4267548862f2edd1de16151177a2b1d9f9e67102f.md b/vision-fixhub/court-01/f6139c67cdb3891c599db0e4267548862f2edd1de16151177a2b1d9f9e67102f.md
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@@ -0,0 +1,235 @@
+Case 9:08-CV-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 1 of fr-
+Case 9:08-cV-80119-KAM
+Document 56 Entered on FLSD Docket 02/27/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+SECOND AMENDED COMPLAINT
+Plaintiff, Jane Doe No. 2 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties, Jurisdiction and Venue
+Jane Doe No. 2 is a citizen and resident of the Commonwealth of Virginia, and is sui
+juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+minor.
+3.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+6.
+This Court has venue of this action pursuant to 28 U.S.C. §1391 (a) as a substantial
+part of the events or omissions giving rise to the claim occurred in this District.
+- 1 -
+
+
+
+Case 9:08-cv-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 2 of 8
+Case 9:08-cv-80119-KAM Document 56 Entered on FLSD Docket 02/27/2009 Page 2 of 8
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male, 52
+years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+8.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004-2005, Jane Doe, then approximately 16 years old, fell into Epstein's
+trap and became one of his victims.
+9.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St.
+10.
+Epstein's scheme involved the use of young girls to recruit underage girls. (Upon
+information and belief, the young girl who brought Jane Doe to Epstein was herself a minor victim
+of Epstein, and will therefore not be named in this Complaint). Under Epstein's plan, underage girls
+were recruited ostensibly to give a wealthy man a massage for monetary compensation in his Palm
+Beach mansion. The recruiter would be contacted when Epstein was planning to be at his Palm
+Beach residence or soon after he had arrived there. Epstein or someone on his behalf would direct
+the recruiter to bring one or more underage girls to the residence. The recruiter, upon information
+and belief, generally sought out economically disadvantaged underage girls from western Palm
+Beach County who would be enticed by the money being offered - generally $200 to $300 per
+"massage" session - and who were perceived as less likely to complain to authorities or have
+-2-
+
+
+Case 9:08-CV-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 3 of 8
+Case 9:08-cv-80119-KAM Document 56 Entered on FLSD Docket 02/27/2009 Page 3 of 8
+credibility if allegations of improper conduct were made. This was an important element of
+Epstein's plan.
+11.
+Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
+Epstein's mansion, the underage victim would be introduced to
+, Epstein's assistant,
+who gathered the girl's personal information, including her name and telephone number.
+would then bring the girl up a flight of stairs to a bedroom that contained a massage table in addition
+to other furnishings. There were photographs of nude women lining the stairway
+and in the
+bedroom. The girl would then find herself alone in the room with Epstein, who would be wearing
+only a towel. He would then remove his towel and lie naked on the massage table, and direct the girl
+to remove her clothes. Epstein would then perform one or more lewd, lascivious and sexual acts,
+including masturbation and touching the girl's vagina.
+Consistent with the foregoing plan and scheme, Jane Doe was recruited to give
+Epstein a massage for monetary compensation. Jane was brought to Epstein's mansion in Palm
+Beach. Once at the mansion, Jane was introduced to
+, who led her up the flight of
+stairs to the room with the massage table. In this room, Epstein told Jane to take off her clothes and
+give him a massage. Jane kept her panties and bra on and complied with Epstein's instructions.
+Epstein wore only a towel around his waste. After a short period of time, Epstein removed the towel
+and rolled over exposing his penis. Epstein began to masturbate and he sexually assaulted Jane.
+13.
+After Epstein had completed the assault, Jane was then able to get dressed, leave the
+room and go back down the stairs. Jane was paid $200 by Epstein. The young girl who recruited
+Jane was paid $100 by Epstein for bringing Jane to him.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+- 3-
+
+
+Case 9:08-CV-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 4 of 8
+Case 9:08-cv-80119-KAM
+Document 56 Entered on FLSD Docket 02/27/2009 Page 4 of 8
+COUNT I
+Sexual Assault and Battery
+15.
+16.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
+apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+17.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril.
+18.
+Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
+with the intent to cause such contact or the apprehension that such contact is imminent.
+19.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+20.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+21.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 4 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+22.
+23.
+24.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+- 4-
+
+
+Case 9:08-cv-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 5 of 8
+• Entered on FLSD Docket 02/27/2009 Page 5 of 8
+of decency.
+25.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
+emotional health to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. $2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+29. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+31.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+- 5-
+
+
+Case 9:08-cv-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 6 of 8
+Case 9:08-cV-80119-KAM
+Document 56 Entered on FLSD Docket 02/27/2009 Page 6 of 8
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §$798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+32.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+33.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+34.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 2 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: February 27, 2008
+Respectfully submitted,
+By: _ s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+Adam D. Horowitz (FL Bar No. 376980)
+horowitz@sexabuseattorney.com
+IERMELSTEIN & HOROWITZ, P.A
+18205 Bissayne invis
+Suite 221.
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 6-
+
+
+Case 9:08-CV-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 7 of 8
+Entered on FLSD Docket 02/27/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on February 27, 2009, 1 electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+- 7-
+
+
+Case 9:08-CV-80119-KAM Document 539-1 Entered on FLSD Docket 05/06/2010 Page 8 of 8
+Entered on FLSD Docket 02/27/2009
+
+SERVICE LIST
+DOE VS. JEFFREY EPSTEIN
+CASE NO.: 08-CV-80380-MARRA/
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz_
+- 8-
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f6139c67cdb3891c599db0e4267548862f2edd1de16151177a2b1d9f9e67102f.receipt.json b/vision-fixhub/court-01/f6139c67cdb3891c599db0e4267548862f2edd1de16151177a2b1d9f9e67102f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cc4c666d7a0cfd3a2be49897a0955ee5a1159ac2
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diff --git a/vision-fixhub/court-01/f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d.md b/vision-fixhub/court-01/f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d.md
new file mode 100644
index 0000000000000000000000000000000000000000..2a7a62248e000d457492b519dc743cf2f8c799f2
--- /dev/null
+++ b/vision-fixhub/court-01/f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d.md
@@ -0,0 +1,56 @@
+Case 9:08-cv-80119-KAM Document 379 Entered on FLSD Docket 10/29/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+JOINT AGREED ORDER ON DEFENDANT'S MOTIONS FOR IMES,
+PLAINTIFFS' RESPONSE TO DEFENDANT'S MOTIONS AND DEFENDANT'S
+REPLY
+This matter came before the Court on Defendant, Epstein, and Plaintiffs Jane Doe
+Nos. 2-8" Joint Agreed Order on Defendant's Motion for IME, Plaintiffs' Response, and
+Defendant's Reply, and the Court having considered Motions, Response and Reply, it is
+HEREBY ORDERED and ADJUDGED as follows:
+Pursuant to Federal Rule 35, Defendant filed various Motions for IMEs of
+Plaintiffs at DEs 303-304, 308-309, 310-311, 317-318, 319-320 and 328-329, with
+attached Affidavits from Dr. Ryon
+Plaintiffs' Memorandum in Response is
+docketed at DE 345. Defendant's Reply is docketed at DE 362. Based upon the
+agreement set forth herein, the above Motions, Response, and Reply are moot.
+2.
+On October 28, 2009, the Court entered an Omnibus Order (DE 377),
+relative to Plaintiffs' sexual history, Questions that involve Plaintiffs' sexual histories at
+
+
+Case 9:08-cv-80119-KAM Document 379 Entered on FLSD Docket 10/29/2009 Page 2 of 2
+the IMEs will be permitted and governed by the Omnibus Order at DE 377. Information
+provided by the Plaintiffs shall remain confidential and used for litigation purposes only.
+3.
+The parties further agree that the Defendant may conduct an Independent
+IME pursuant to rule 35 of Jane Doe Nos. 2-8. The IME may be videotaped. A live
+video-feed of the IME shall be available to counsel in an adjacent room. All videotaping
+expensing shall be shared equally by the Plaintiff and Defendant.
+4.
+Absent further court order, each IME shall last no longer than eight (8)
+hours, including all testing and interviewing.
+5.
+Defendant Jeffrey Epstein will not attend the IMEs or make himself seen
+by Plaintiffs on the date of their IMEs.
+6.
+The IME shall not take place at Epstein's counsel's office but will take
+place at a mutually agreeable location in Palm Beach County, Florida. The fees for an
+additional room for the video feed will be split equally among Plaintiffs and Defendant.
+DONE and ORDERED this
+_day of
+, 2009.
+Linnea R. |
+Magistrate Judge
+Courtesy Copies:
+Counsel of Record
diff --git a/vision-fixhub/court-01/f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d.receipt.json b/vision-fixhub/court-01/f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fa1143f7405e14c3d94f4d3d5cd8aeef8975f00d
--- /dev/null
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@@ -0,0 +1,14 @@
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+  "doc_id": "f613d53b38dded34270a86d057fc2862a1bb726ca284d44b3ee6ed6fe09b376d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/f626a2b627a61a507933a37a7b27574aebe3f8d6b2721a7c54f9d17bf1dfedc2.md b/vision-fixhub/court-01/f626a2b627a61a507933a37a7b27574aebe3f8d6b2721a7c54f9d17bf1dfedc2.md
new file mode 100644
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@@ -0,0 +1,5447 @@
+Case 9:08-cv-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 1 of 52
+PLAINTIFF JANE DOE'S RESPONSE TO DEFENDANT'S MOTION FOR PROTECTIVE
+ORDER [DE 536]
+CASE NO: 08-CV-80119-MARRA/
+
+Part 1 of 3
+
+
+02/26/09
+EPSTEIN. JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+PSTEIN, JEFFREY
+JEFFREY
+JEFFREY
+TEIN, JEFFREY
+Cell Date
+07/03/08
+TM 07/05/08
+TM 07/12108
+TM 07/12/08
+TM 07/17/08
+TM 07/19/08
+TM 07/24/08
+™M
+07/26/08
+TM
+07/31/08
+08/02/08
+TM
+08/07/08
+™M
+08/09/08
+™M
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+08/16/08
+Period
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+2
+2
+4
+2
+4
+08/21108
+2
+0
+0
+P VISOSKI J
+IGOR V ZINOVIEV
+P VISOSKI J
+IGOR V ZINOVIEV
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+IGOR V ZINOVIEV
+ROGER C SCHANK
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+IGOR V ZINOVIEV
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+IGOR ZINOVIEV
+VISOSKI JR
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+301 E 66TH ST 314G/NY/NY
+Case 9:08-CV-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 2 of 52
+
+
+22/26/09.
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFTREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
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+PSTEIN, JEFFREY
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+SMAE AS ABOVE
+TRAIN
+Case 9:08-CV-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 3 of 52
+
+
+02/26/09
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
+EPSTEIN, JEFFREY
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+EPSTEIN, JEFFREY
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+301E. 66TH ST ATTIR***-
+Entered on FLSD Docket 05/07/2010 Page 4 of 52
+
+
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+PASS #
+V-3
+NAME OF STAFF/INMATE VISITING
+Damato,
+(TRinity)
+Ireen ElizAbou
+nina
+Debbie
+Jest. Michael
+HetheR TROu
+Ailin Bron sein
+susan Wilkott
+ohn HaDicht
+atRich Elderman
+(TRinity)
+Cheverle Hutower-SARP.
+Robert Humes- DAF
+Jay Badgett- PBCSB
+Darren Indyke- Attorney
+Tenante Sproull- Clerteal
+Elta Emilcar- Trinity Staff
+Larry Ellis- ESS
+- Juvenile Probation Officer
+Patrecha Newby- Trinity Staff
+Jerry M.Daamna
+AT A ST
+N-L
+V-11
++R90
+P.BSO
+PESO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PRSO
+PBSO
+PB50
+PBSO
+PBSO
+PBSO
+PBSO
+L-3
+PBSO
+PBSO
+PBSO
+V-3
+PBSO
+DRUGTAUR
+DRUG ARM
+DRUGTARM
+srig farm area.
+Drug
+Farm area.
+School Calssroon.
+I/M: Epstein, Jeffrey (T-Special Mgmt).
+Blood Drive.
+9-B1dg.
+I-Control
+I/M:
+Quentyne (M-Dorm).
+Q-B1dg.
+39
+TIME OUT
+2105
+2105
+Mog
+1434
+1535
+1600
+1059
+11416
+iloo
+lo0c
+1400
+1510
+16000
+1710
+1450
+Hi32
+1047
+0959
+1740
+0930
+0954
+Case 9:08-CV-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 5 of 52
+
+
+07-1-08
+07-1-08
+1200
+1306
+07-1-08
+1417
+07-1-08
+1417
+07-1-08
+1445
+7-1-08
+1451
+7-1-08
+1506
+1601571-08
+1415
+7-1-08
+1623
+7-1-08
+1470
+7/1108
+41/08
+7/108
+1845
+1845
+1855
+7/1/08
+2000
+VISITOR NAME / ORGANIZATION
+Angel1k1 Weissinger- SAAP
+Varju- SAAP
+Sarah Korn- DAF
+Jessica Wally- DAF
+Chaplain Bannister-
+G. Scott Penney- Public Defender
+Darren Indyke- Attorney
+Tein Michael CAttoeney)
+Lewis Gul
+Thomas Doherty (Facilitar)
+Licata Evan (elergy)
+talker Deborah
+sar wallace
+Manthey Gabriel
+Hexander stephen
+CENTRAL
+ASTOCKADE
+O WEST COUNTY DETENTION
+O DRUG FARM
+PASS #
+PBSO
+NAME OF STAFF/INMATE VISITING
+Drug Farm area.
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+L-4
+LI
+L-2
+PBSO
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+on the compound.
+IM: Epstein, Jeffrey (T-Special Mgmt).
+entered to see inmate Epstein Jeffrey
+1-special
+compound to J/K
+Church Serukes
+5
+T-specia)
+S
+TIME OUT 53
+STO
+1525
+1710
+1710
+1541
+1600
+1945
+182°
+1820
+40
+855
+855
+2007
+2055
+
+
+pASTOCKADE
+VISITOR NAME / ORGANIZATION
+2-02-08
+13:73
+7.02-08
+13:44
+BRUCE E. REINHART (ANT)
+Mr. BlitzeR (medica
+7-02-08
+1348
+MR.CicCone (DOC)
+7-02-18
+1408
+MS. WAlly (DAF)
+1-02:08
+1408
+Ms. Koen (DAF)
+7-02-08
+1488
+Mr. Humes (SALA)
+7-02-08
+1Y11
+7-01-08
+Mr. Shull (Arly)
+7-01-08
+1432 Actective Wilson (alary P.O).
+1508
+7-02-08
+ms Sancher (AKy.)
+1510
+MR. Lumpkin (T-netin)
+720
+1552
+270
+MRiTe's (ATty)
+1552
+Mr. Lewis (AMTy)
+7208
+1740
+ME FRYE TIMEO
+7203
+1Y00
+2208
+1950
+7z08
+7202
+IS MARSINAL
+rus coMo
+Ms Brisco
+7408
+15/08
+1/5/0
+1/3/08
+Evelyn Wilfaed
+Curtio Pinkney
+O WEST COUNTY DETENTION O DRUG FARM
+PASS #
+V -1
+V-1
+PESO
+PBSO
+PBSO
+L-3
+V-3
+L-1
+PASO
+L-2
+L-3
+VI
+0350
+V3
+V4
+NAME OF STAFF/INMATE VISITING
+T-spie (EpSTEiN, J.)
+Medical
+medical
+Paug Farmy
+Drug Farm
+Drug FaRm
+C-borm
+TSpes:
+SAL SA-Dorris
+T-Sper. Epstein, J
+T'Spci.
+Epstein 3
+20 KABA
+DoG FORM
+Dan
+Karem
+DAM
+PESO
+06Y0
+1/3/08
+0658
+0608
+113,08
+0719
+
+0730
+A74Y
+Tristy - Quebec
+"tip Quebec
+TIME OUT
+1420
+1650
+1432
+1650
+1650
+1650
+1500
+1459
+: 730
+17,855
+' 80%
+1807
+1935
+1905
+200s
+200g
+2os
+7105
+1015
+1057
+1/30
+14/28
+1104/80
+1C/E
+Case 9:08-CV-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 7 of 52
+
+
+
+} STOCKADE
+07-02-280045
+07-02-080400
+VISITOR NAME / ORGANIZATION
+Evelyn WilfoRd (TRinity)
+CuRtis Pinkney
+O WEST COUNTY DETENTION
+O DRUG FARM
+PASS #
+NAME OF STAFF/INMATE VISITING
+PBSO
+PBSO
+07-02-080624
+Q- Blag:
+PBSO
+07-02-080652
+X-Bldg.
+07-02-08/0652
+(SwAnson)
+PBSO
+Canteen
+Indica Criollo (SwAnson
+PBSO
+CAnteen
+07-02-08 0655
+07-03-080659
+Lator Willems
+(SwAnson) PBSO
+Canteen
+_Cedeno
+07-02-08
+(SwAnson) ABSO
+0723
+07-02-80725
+ARthur TRoy
+CAnteen
+(SAAP)
+07-02-081
+0730
+GARy Gibson
+PBSD cRug FaRm
+(DATA)
+PBSO
+DRug FaRm
+caitlin Bronstein
+(DAF)
+07-02-08 0235
+GlORiA
+FaRm
+07-02-080736
+FaRm
+Michael West
+(SAAP)
+07-02-0802316
+TeRRy GRAVeS
+(SAAP) PBSO
+DRug FaRm
+07-02-08 0744
+DRug
+FaRm
+Inevelle HytoweR
+(SAAP)
+PBSO
+07-02-480244
+FaRm
+07-02-08.0744
+Ançeliki. WeissingeR (DAF)
+PBSO
+DRUg
+FaRm
+PatRiciA Edelman
+07-02-08
+0800
+Ms. Crowder
+PeSO
+07- 02-08
+2800
+(ProbAtion)
+DAF)
+PBSO DRue, FaRm
+DANS FARM
+SAAP)
+PBSO
+07-02-08
+Deny FaRm
+0816
+MR. Medina (AMy)
+PASO
+07-02-08
+0855
+Al M-PaRna /VALiDus I/m's
+Ms. Emilesn
+07-02-08
+0859
+(Trinity)
+BBSO
+Q. Balbiry
+17-02-1
+0938
+A Sea Bosene Lary"
+PBSO
+- 02-08
+0557
+07-02-0Y
+MA. TrACy (ATTy)
+Sat DaRm DAnco, J;
+1000
+ms. Newby (Trinita)
+PASO
+P§SO
+F-Dorm
+91-0 0%
+1158
++- DoRm
+TIME OUT
+1110
+133°
+1430
+1212
+1212
+1212
+07|4
+1602
+260:2
+165-
+160z
+1727
+1708
+1Z0S
+1$331
+1730
+92/
+1620
+948
+451
+1018
+1928
+IRAI
+Case 9:08-cv-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010
+
+CENTRAL CONTROL
+ASTOCKADE
+O WEST COUNTY DETENTION O DRUG FARM
+VISITOR NAME / ORGANIZATION
+henelle tertyke
+PASS #
+NAME OF STAFF/INMATE VISITING
+PSSO
+susan Weko
+Public Sefendar
+Drug Far no
+Ear tauthor ta)
+V4
+Drug tarm
+V5
+-Farm
+PD)
+PBSO
+Fan T con
+303 8 goL matt Ses net te i) a3
+, compoun d
+1124
+J3
+1/03/08 1217
+PBSC
+383/68
+1350
+GM, Dsim
+BS0
+1 Dorr
+PASE
+-DorN
+L-1
+sorm
+V4
+PBSO
+TIME OUT
+0938
+9:40
+·440
+//39
+1/39
+1000
+1U31
+1025
+1920
+11.08
+1133
+1045
+1458
+1419
+1419
+Cașe 9:08.cv80119:KAM.Ddçumen₺:540-2.
+
+
+0|3|08
+3,08
+7/4/08
+7/4/08
+7/4/08
+7/4/08
+7/4/08
+7/4/08
+7/4108
+7/4/08
+15/08
+25/08
+7/5/08
+7/5/08
+7/5/08
+7/5/08
+7/5/08
+7/5/08
+75•08
+75•08
+" CENTRAL CONTROL "
+• MAIN DETENTION CENTER
+A STOCKADE
+• WEST COUNTY DETENTION O DRUG FARM
+1920
+1920
+VISITOR NAME / ORGANIZATION
+Melant
+PASS #
+Khouru
+NAME OF STAFF/INMATE VISITING
+3
+Nicole
+Intake
+Dimasi
+0909
+PRED
+Entekke Backing
+Patrecha Newby- Trinity Staff
+PBSO
+Drug Farm
+0930
+9-B1dg.
+Joann Graham- MSW (Social Worker)
+V-9
+I/M's:
+1007
+Mirlanda Osting- Trinity Staff
+(M-Dorm) and Wyche (B-Dorm).
+PBSO
+9-Bldg.
+1246
+Pagano- Paralegal
+V-4
+1940
+I/M: Epstein, Jeffrey (T-Mgmt).
+19451
+Jowany ARocho ( Alumni
+V-11
+Phillip Stephens (Alumni)
+DRUG FORM
+1945
+Vla
+DRUG FaRM
+panoDy Kashad (Alumni)
+120
+V-13
+uRtis vinkneu
+DRugFaRM
+OZHO SARAh KORn
+1B50
+A-blda
+PBSO
+0857
+Sharon
+United Deliverance Min PBSO
+0900
+Mirlande Osting- Trinity Staff
+PBSO
+0955
+Elta Emilcar- Trinity Staff
+1249
+PBSO
+Pagano- Paralegal
+V-17
+1447
+Sgt.
+- Deputy Sheriff
+PBSO
+1503
+1920
+Arnold P. Prosperi- Attorney
+Harris Richard
+L-1
+V1T
+A/B-Dorm.
+9-B1dg.
+9-B1dg.
+I/M: Epstein, Jeffrey (I-Special Mgmt).
+Visitation area.
+I/M: Epstein, Jeffrey (I-Special Mgmt).
+Drug Farm
+TIME OUT
+430
+1930
+1210
+1748
+1108
+1839
+1510
+2104
+2104
+2104
+1020
+1120
+0909
+1750
+1850
+1530
+16015
+11000
+2104
+
+
+0186/085
+1/06/0807:41
+7/6/08
+0903
+7/6/08
+0908
+7/6/08
+1019
+7/6/08
+1216
+7/6/08
+1517
+7/6/08
+1517
+7-4508
+1725
+760-08
+70-08
+1843
+145d
+" CENTRAL CONTROL "
+• MAIN DETENTION CENTER STOCKADE
+VISITOR NAME / ORGANIZATION
+Gue/a
+Ms.
+yn WilFord
+toelman
+Mirlande Osting- Trinity Staff
+Agent
+• Deputy Sheriff
+Elta Emiclar- Trinity Staff
+Pagano- Paralegal
+Guy
+Attorney
+Michael Tein- Attorney
+1. Hlexande
+bertsch, Tut ian
+Smith, James
+• WEST COUNTY DETENTION • DRUG FARM
+PASS #
+NAME OF STAFF/INMATE VISITING
+PBSO
+PBSO
+PBSO
+9-B1dg.
+PBSO
+Adult Cust Office.
+PBSO
+9-B1dg.
+V-7
+I/M: Epstein, Jeffrey (T-Speéial Mgmt).
+L-1
+I/M: Epstein, Jeffrey (T-Special Mgmt).
+L-2
+I/M: Epstein, Jeffrey (T-Special Mgmt).
+V-17 Epstein.
+PB50
+Jeffrey (T-speaal.)
+V-i7
+SE F dorm, Fuller B
+Fdam Atmeeting.
+TIME OUT
+1003
+1021
+1056
+1835
+1445
+1710
+1249)
+1950
+2100
+
+
+CENTRAL CONTROL
+ÇA STOCKADE
+• WEST COUNTY DETENTION
+O DRUG FARM
+VISITOR NAME / ORGANIZATION
+77/08
+01:35
+1/7/08
+Evelyn WilFord
+06:20,
+Elizabeth Green
+77,806i15
+112/080715
+775/08
+07:23
+07:28
+117/03
+07:29
+7/7/08
+67:30
+07:45
+7|7|08
+0748
+7/7/08
+0758
+7/7/08
+0805
+7/7/08
+0814
+7/7/08
+0826
+7/7/08
+0847
+7/7/08
+0859
+7/7/08
+0859
+7/7/08
+0911
+7/7/08
+0944
+7/7/08
+0957
+7/7/08
+7/7/08
+1014
+1023
+717/08
+1213
+7/7/08
+1217
+7/7/08
+1313
+7/7/08
+11377
+ANgelIKa WebsiNger-SAAR
+Susan Wilkoff- SAAP
+Jay Badgett- PBCSB
+Terry Graves- SAAP
+John Habicht- Trinity Staff
+Elta Emilcar- Trinity Staff
+Andre
+- ESS
+Doherty- ESS
+Patrecha Newby- Trinity Staff
+Rony Noreston- Florida Public Utilites
+Mirlande Osting- Trinity Staff
+Jeff
+ESS
+Caitlin Bronstein- DAF
+Caitlin Bronstein -DAF
+Patricia Edelman- SAAP
+Darren Indyke- Attorney
+7_1 1
+PASS #
+PESO
+1BSO
+NAME OF STAFF/INMATE VISITING
+TriniTy Staff - Quebee
+STAFE - Purbec
+bSO
+sure fans
+IBSo
+>AA
+Farm
+SAA Y
+SAtY
+sso
+SATY
+SAAP
+1B80
+PBSO
+Drug Farm area
+Drug Farm area.
+PBSO
+School Classroom.
+PBSO
+Drug Farm area.
+PBSO
+Q-B1dg.
+PBSO
+Q-Bidg.
+PBSO
+J/K-Dorm to gate #68 buzzer not working
+PBSO
+"
+"
+"
+PBSO
+V-2
+PBSO
+PBSO
+PBSO
+PBSO
+PBSOR
+L-1
+Q-Bidg.
+On the compound.
+9-Bldg.
+on the compound.
+Drug Farm area.
+Drug Farm aree.
+Drug Farm area.
+I/M: Epstein, Jeffrey (I-Special Memt).
+TIME OUT
+1113
+1431
+цот 1402
+1018
+1425
+1425
+1746
+1157
+1136
+1516
+1Le0e
+0956
+1440
+1206
+1430
+1602
+
+The fillawing
+cirded didnt leave on C-snift
+
+07/08/08
+07/08/08
+07/08/08
+07/08/08
+07/08/08
+7-8:08
+7-8-08
+7-308
+7-8-08
+1451
+1457
+1500
+1526
+1526
+1615
+1830
+1830
+1830
+8.08
+8-08
+18.:49
+7-8-08
+18:49
+28-08
+surnamas laulor
+Zobert twilliam.
+3-8-08 1849 monzell Laul
+28-08
+18:49
+7-8-08
+lavarus trince
+18:49
+2-8-08
+18:49
+Alfred Monroe
+7-8-08
+Ale thia munroe
+1940
+Hanky, Michael
+78.08
+2000
+Durbaal, Nelson
+" CENTRAL CONTROL "
+O MAIN DETENTION CENTER & STOCKADE
+O WEST COUNTY DETENTION • DRUG FARM
+VISITOR NAME / ORGANIZATION
+Kenneth Huxhold- SAAP
+Darren Indyke- Attorney
+Jack Goldberger- Attorney
+Guy
+- Attorney
+Michael Tein- Attorney
+Indyke, Darren
+antgomer, Thoma
+-len Harete
+PASS #
+PBSO
+L-4
+L-2
+L-5
+NAME OF STAFF/INMATE VISITING
+L-Dorm to see inmates.
+I/M: Epstein, Jeffrey (T-Special Mgmt) .
+"
+"
+"
+"
+L-1
+L-4
+L-4
+==
+"
+"
+€-3
+C-a
+PBSO
+TIME OUT
+154฿
+1538
+1745
+74)
+1745
+1825
+1725
+2010
+2010
+2000
+2040
+2002
+2002
+
+
+• MAIN DETENTION CENTER
+" CENTRAL CONTROL "
+ASTOCKADE
+07-08:08
+VISITOR NAME / ORGANIZATION
+0124
+07-08-08
+0605
+07-08-18
+0130
+Liz
+ARthuR TROY
+07-08-18 0230 michael WesT
+(SAAP)
+07-08-08
+0234
+(SAAP)
+_Justir
+(SAAR)
+07-08-08
+0234
+Ahlman
+07-08-08
+(SAAP)
+0742
+JuliA AdAms
+(SAAP)
+07-08-08
+0244
+07-08-08
+0753
+AngeliKi WeissingeR (DAF)
+07-08-08
+07-08-08
+0154
+ratricia Eldemen.
+(DAF)
+SusaN WilKolf. SAMP
+0821
+Jay Badgett- PBCSB Teacher
+07-08-08
+0835
+John Habicht- Trinity Staff
+07-08-08
+0904
+07-08-08
+Elta Emilcar- Trinity Staff
+1014
+Patrecha Newby- Trinity Staff
+07/08/08
+1043
+Mr. Harper- ESS
+07/08/08
+1137
+Change- Deputy
+07/08/08
+1145
+07/08/08
+1201
+Pablo
+Edwin
+DAF
+07/08/08
+1300
+07/08/08
+1314
+07/08/08
+·316
+07/08/08
+1328
+07/08/08
+1330
+07/08/08
+07/08/08
+07/08/08
+1407
+1413
+1413
+- Attorney
+Varju- SAAP
+Raul Pozos- Fla Dept of Correction
+Darren Indyke- Attorney
+G. Scott Penney- Public Defender
+Evelyn Pennington- Public Defender
+Robert Humes- DAF
+Jessica Wally- DAF
+Sarah Korn-DAF
+O WEST COUNTY DETENTION O DRUG FARM
+PASS #
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+PBSD
+PBSO
+PBSOR
+PBSO
+PBSO
+PBSO
+PBSO
+PBSO
+L-1
+PBSO
+V-18
+L-2
+PBSOR
+L-1
+PBSO
+PBSO
+NAME OF STAFF/INMATE VISITING
+X- Bldgs.
+x-Beda
+DRug FaRm
+DRug FaRm
+Drug FaRm
+DRug Farm
+Rug
+FaRm
+DRug FaRm
+DRug FARm
+Drug Farm axea.
+School Classroom.
+9-31dg.
+9-B1dg.
+9-B1dg.
+Intake Control.
+line-up room.
+Drug Farm area.
+I/M: Pullens, Cleo (D-Dorm).
+Drug Farm area.
+9-B1dg.
+I/M: Epstein, Jeffrey (I-Special Mgmt).
+Various dorms to see inmates.
+Intake Booking area.
+Drug Farm area.
+Drug Farm area.
+TIME OUT
+1115
+1533)
+1400
+1707
+170)
+15a
+113
+1,000
+1735
+1207
+1438
+1758
+1849
+1100
+1242
+1505
+1321
+1505
+1546
+1404
+1600
+1537
+11453
+100
+
+
+7/09/08
+ASTOCKADE
+O WEST COUNTY DETENTION O DRUG FARM
+VISITOR NAME / ORGANIZATION
+PASS #
+NAME OF STAFF/INMATE VISITING
+TIME OUT
+1213
+nIR. INçuke CAT
+L -4
+1308
+TRIK TENUEN (FPL
+T-Spec. /=/m Epstein, J;
+13YL
+10-1
+VAROUS
+1339
+1321
+MICHAEL OPROBINA (P.D.)
+PRIO
+L- DORM
+1409
+1322
+MICHAEL MIVAN (FA VESTIGPTOR
+VARIOW
+1S)3
+1337
+MARC LYONS (AlES)
+I.pecim)
+107
+1337
+JACK GOLDBERGER (ATTY)
+L2
+1411/517
+SPBARON NEELAKANTA (PA
+PAJO
+1540
+1342
+EDWIN FIREWON (ATTY
+L-3
+A-DoRm
+1402
+RORERT HUMES (DAF)
+j430
+1412
+PEJO
+PRUE FARM
+1650
+SARAN KORN (DAF)
+PRJO
+DRUS FARM
+1658
+14/2
+JESSICA WALLY (PAF)
+FBSO
+DRUG FARM
+1G58
+1600
+T-KAGT- LOsTEiN
+iS5O
+1710
+Q330
+_ Dero Farm
+1940
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+- 2000 Harris Richard
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+Q-B1dg.
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+Attorney Duren I. Inclyle
+stay Aurtin (Pera logel)
+Joseph Varju
+?.D. G. scott Penny
+W STOCKADE
+Attormy de J. Mutto
+sergio Conne (Interpets)
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+Jessica Wally- NAF
+Robert Humid- SAAR
+Evelyn Bunnists
+danes k. Indyll (Alfura)
+Attorney Rainer W. Bitchter
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+Honey Minte sino samue
+PASS #
+L-4
+PBSO
+PBSO
+O WEST COUNTY DETENTION O DRUG FARM
+NAME OF STAFF/INMATE VISITING
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+I: special inmate pites Telfrey
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+Kartarmto seeinmate Scarlet Cecilo
+Ta5o
+PRSO
+PBSO
+1645
+3103
+Edom.
+2112.
+ES.P.
+Case 9:08-cv-80119-KAM
+Document 540-2
+Entered on FLSD Docket 05/07/2010 Page 23 of
+
+
+7.15.08
+1.15.08
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+0729
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+Case 9:08-CV-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 25ES.P.
+52
+
+
+71608
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+y50
+JACK GOLOBERGER (ATTY)
+JERRY WADE (STPD.)
+I EDWIN BEZARES (MAXDAVIS
+1607
+/cz;
+180)
+18Bv
+1700
+1920
+2000
+MA
+ATt
+O WEST COUNTY DETENTION O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+6/N- DORm
+DRUG FARM
+DRUG FARM
+C-DORM
+D DORM
+T-SPECIAL (EPSTEIN, 5)
+DRUG FARM
+DRUG FARM
+DRUG FAEM
+I-SPECIAL (EPITEIN)
+T-SPECIAL (EPUTE)N)
+VARIOUS
+INTAKE BOOKING
+PHA LEGAR-DASTIN
+inToMR I/M - SA
+Dan From
+Пать бакт.
+raem
+DONG FINA
+VI
+0155
+ATT
+MR PADLOSON TOMAS
+ma Four I7m0
+ms COnN
+ms sumerz
+MK DELOATCH
+Reyes
+Cutely likend
+V3
+L1
+L3
+PBSO
+PASO
+PeSO
+L-l
+L2
+PASO
+VI
+L2
+155O
+Tanty Smitt - Ober
+Start. ras
+TIME OUT
+131(
+1533
+1325
+1439
+1405
+/(Ss
+1700
+1700
+1655
+1552
+1600
+1547
+1746
+175)
+1535
+1935
+70a6
+2000
+2103T
+A1251
+437
+Entered on ESP. Decket 05/07/2010 Page 26 of
+
+
+07/18/08
+0944
+07/18/08
+1153
+07/18/08
+1155
+07/18/08
+1200
+07/18/08
+1218
+07/18/08
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+07/18/08
+1305
+07/18/08
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+07/18/08
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+7-18:08
+7-1808
+1315
+7-18-08
+181
+2000
+718:00
+FoUr
+7-19.08/2000
+" CENTRAL CONTROL "
+• MAIN DETENTION CENTER
+& STOCKADE
+• WEST COUNTY DETENTION 0 DRUG FARM
+VISITOR NAME / ORGANIZATION
+Michaelanne
+- Stata of Fla.
+Deputy Maharrey- Deputy
+Mirlande Osting- Trinity Staff
+Story Cowles- ParaLegal
+Jeffrey Ivory- Pre-Trial Services
+Julia
+- SAAP
+Susan Wilkoff - SAAP
+Pablo
+- DAF
+Patricia Edelman- SAAP
+Chevelle Hytower- SAAP
+Jospeh Varju- SAAP
+sarah korn
+scott penny
+Timothy Justin- SAAP
+Jessica Wally- DAF
+Rebecca Thomann- DOC
+Tequllia
+- DOC
+Caitlin Bronstein- DAF
+Jack Goldberger- Attorney
+PASS #
+V-11
+PBSOR
+PBSO
+L-1
+PBSO
+PBSO
+PBSO
+PBSOR
+PBSO
+PBSO
+PBSO
+pbso
+pbso
+PBSO
+PBSO
+V-11
+V-5
+PBSO
+L_2
+Caus stocy
+Geltand
+(GED)
+(GED)
+V.
+V-4
+fosperi Arnald Paul (ATt)
+acyn
+(AlumniAA)
+Stephens
+Mn..
+n.l.
+Phillip (alumniAA)
+V-S
+I/m's:
+NAME OF STAFF/INMATE VISITING
+/Baptiste/Fedele/
+ON the compound.
+Q-B1dg.
+I/M: Esptein, Jeffrey (T-Special).
+RA-Dorm to see inmates
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+drug
+farm area .
+f-dorm
+I-dorm
+and s-dorm.
+Drug Farm area.
+Drug Farm area.
+I/M: Trejo,
+I/M: Trejo,
+(SA18)..
+(SA18).
+Drug Farm area.
+I/M: Epstein, Jeffrey (I-Special).
+Ispecial to see inmate Epstein
+Dua Farm
+Prug farm
+I.specia to sel inmate Epstein.
+trug tara
+Devia Far,
+TIME OUT
+/Thelemaque =104!
+1217
+1354
+1257
+n12
+117
+1402
+1603
+1708
+1633
+110Z
+1448
+1448
+1623
+1757
+1836
+183L
+906
+Bint
+
+
+• MAIN DETENTION CENTER
+¡DATE
+01:40
+0325
+935
+• STOCKADE
+O WEST COUNTY DETENTION
+PASS #
+BSU
+1550
+rESO
+P3S0
+O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+TIME OUT
+Lily StAFF- Wrebec 03 35
+1015
+N547
+180
+1247
+PB
+I T-Dorm
+Fdam to sel inmate
+11500
+1500
+1957
+
+
+Central Cuntrol
+908
+J048 91
+
+VE STOCKADE
+VISITOR NAME / ORGANIZATION
+sTory CouleA
+strain texana D
+O WEST COUNTY DETENTION
+PASS #
+PR
+50
+1-Dorm
+O DRUG FARM
+¿NAME OF STAFF/INMATE VISITING
+Tary crown
+USCOn PAGanT
+150/081354
+1-20-08
+11820
+720-08 049
+L4
+L-!
+TIME OUT
+1751
+1000
+100 g
+1844
+152%
+1447
+/57
+Especial to see lanate Estin bas
+Edom to conduct meeting
+Z101
+Case 9:08-CV-E.S.P. a Document 540E.S.P. 7% ted on FLSD Docket 05/07/2010 Page 29 of
+
+
+O STOCKADE
+• WEST COUNTY DETENTION • DRUG FARM
+VISITOR NAME / ORGANIZATION
+jel
+Padle
+wyne
+PASS #
+PESO
+NAME OF STAFF/INMATE VISITING
+rini
+7/21/080130
+7/21/080710
+221/08
+07/2
+1/21/05
+673u
+5731
+0738
+
+1иlя 0131 We тика
+SAAP
+SAAP
+SAAP
+By ER Doms
+TIME OUT
+2055
+1501
+1000
+LUIS
+141O
+12,00
+1600
+1900|
+PESO
+KH DErM
+DIU CLIN
+Dup farm
+IntaKe
+I-special
+T-special to sie Epstein
+T-dorm tr
+702
+18:00
+1909
+141
+144
+1702
+15Tl
+1830
+1850
+Entered on FLSD Docket 107/2010 Page 30 of
+
+
+•CAL VISITOR LOG
+CENTRAL CONTROL"
+I STOCKADE
+O WEST COUNTY DETENTION
+O DRUG FARM
+VISITOR NAME / ORGANIZATION
+721-00
+PASS #
+1900
+7-21-08
+Dunn Michael (ablestucs
+NAME OF STAFF/INMATE VISITING
+TIME OUT
+1820
+Dina Farm
+7-21-08
+1850
+V-1
+1939
+ESpecia
+1650
+"'Church Serv. "
+1938
+711-08
+1855
+clergy chuchser "
+2005
+121•08
+1900
+PBSO
+7-21-08
+V-1l
+Intake Beking to sa inmak Tandoke 9ul
+1930
+721-00
+Colorm
+L-l
+2014
+2007
+T-specia to sie Epstin
+2059
+72108
+2002
+7-22-08
+Demito Brian
+Diya tarn
+V-R
+2106
+0140
+7-22-08
+0618
+Evelyn Wiltoed (Trinity StAff
+dix
+PBSD
+Elizabeth GReen
+12:05
+2-22-08
+ObEB
+PBSO
+2-22-08
+DeDORAn Lina
+1428
+0712
+PBSO
+1419
+7-22-08
+PBSO
+2-22-08
+02311
+2234 Linhy Gustin
+PRSO
+1414
+Donskin
+120c
+2-22-08
+0738
+Angeliki Weissingee
+LESO
+1l417
+2-22-08
+0738
+7-22-08 1738 Gree e HybWeR
+VESD
+1420
+170-
+7/22/08
+150
+0750
+07/22/08
+PBSO
+1550
+0807
+Susan Wilkoff-SAAP
+07/22/08
+0814
+PBSO
+1135
+Drug Farm area.
+Jay Badgett- PBCSB
+PBSO
+School Classroom
+1713
+07/22/08
+0817
+Patricia Edelman- SAAP
+PBSO
+12:10
+07/22/08
+0858
+Drug Farm area.
+Elta Emilcar- Trinity Staff
+PBSO
+1604
+Q-B1dg.
+07/22/08
+0907
+Oglesby- Public Defender
+752
+PBSO
+C-Dorm and G/H-Dorm.
+07/22/08
+0911
+John Habicht- Trinity Staff
+PBSO
+07/22/08
+Q-B1dg.
+1435
+nozn
+11. 1 ...3 .
+|/5dn
+d's
+Ertia Sensory
+Parairpai
+
+
+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08.
+07/22/08
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+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08
+07/22/08
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+1423
+1432
+1449
+1449
+1457
+1501
+1010
+CENTRAL CONTROL"
+*STOCKADE
+• WEST COUNTY DETENTION • DRUG FARM
+VISITOR NAME / ORGANIZATION
+Yvette Farnsworth- Public Defender
+PASS #
+PBSO
+Patrecha Newby- Trinity Staff
+PBSO
+Genevieve
+I- Attorney
+Middlebrooks- Alexxon
+Jeff.
+- ESS
+Michael McLaughan- ESS
+Michael West- SAAP
+Story Cowles- Paralegal
+Jack Goldberger- Attorney
+Robert Critton- Attorney
+Darren Indyke- Attorney
+Varju- SAAP
+Matthew Covil- D.O.C..
+Chaplain Bannister- Chaplain
+Sarah Korn- DAF
+Jessica Wally- DAF
+Robert Humes- DAF
+Jason Siegel- Attorney.
+G. Scott Penney- Public Defender
+Trevor Sutür"- Attorney
+Leonardo Tabordo- Public Defender
+Adam Langino- Public Defender
+Oglesby- Public Defender
+Timothy Justin- SAAP
+Induke Daren (ATT)
+L-4
+V-3
+PBSO
+PBSO
+PBSQ
+L-2
+L-1
+L-4
+L-3
+PBSO
+V-5
+PBSO
+PBSO
+PBSO
+PBSO
+L-1
+PBSO
+L-5
+PBSO
+PBSO
+PBSO
+PBSOR
+1-2
+NAME OF STAFF/INMATE VISITING
+TIME OUT
+Various Dorms to see 1/m.
+Q-Bldg.
+1913
+I/M's: Pierre, W (A-Dorm) Brools, R (SA09) .
+1114
+on the compound reset mouse traps
+1545
+On the compound to repair gate #16.
+1307
+On the compound to repair gate #16.
+1307
+Drug Farm area.
+1550
+I/M: Epstein, Jeffrey (T-Special).
+1320
+I/M: Epstein, Jeffrey (T-Special).
+I/M: Epstein, Jeffrey (T-Special).
+I/M: Epstein, Jeffrey (T-Special).
+Drug Farm area.
+I/M:
+• Quentyne (M-Dorm)
+On the compound.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+I/M:
+, Lemorris (M-Dorm) .
+Various Dorms to see inmates.
+I/M's: Gaines, Brandon (D-Dorm) /Blue, Macio
+I/M's: Quinn,
+L (T-M) and Freeman, Randy
+I/M: l
+1, Miquel (RA05) :
+G/H-Dorm.
+Drug Farm area.
+T-special to see inmate Ensk in
+egaleagfeinc.com
+1358
+1320
+1532
+1528
+1425
+1547
+70
+170
+noT
+1$30
+1420
+(A-Dorm) 1509
+(M-Dorn) 1660
+170s
+1527
+170
+102C
+egal
+case 9:08-CV-80119-KAM Documents, #
+Entered on FLSD Docket 05/07/2010 Page 32 of
+
+
+27/22/08
+7|23|05
+223|08
+7103/07
+1,2308
+173/18
+223/08.
+2/23,081:44
+1250X
+7:45
+13308
+2:47
+Ms.
+Ms.
+Mo
+3308
+Caes
+Willia
+stone
+2:47
+23/08
+180
+723,08
+OB/L
+7|13/08
+0926
+JAY PADGET TEACHER
+GLORIA GREEN (SAMP)
+7 308
+0929
+743/08
+0929
+723,0%.
+O9YO SAINNA SEABORNE (P.D.)
+123/08
+7 23/08
+1004 INKIQUE SOBANO
+11310%
+115.
+CHRSTOPNEK MIDOLEGROOK
+IISY
+123/08
+PATRECHA NEWBY CTRINTI
+7 25 08
+Darren IndykE (Atty.
+"Central Control"
+STOCKADE
+O WEST COUNTY DETENTION
+• DRUG FARM
+PASS #
+PSSE
+Quebe
+NAME OF STAFF/INMATE VISITING
+ABSU
+Cueber
+pESO
+bula
+ABSU
+Till
+Drey fum
+160
+Driftam
+juataym
+Duy
+Fran
+Dus tam
+PBSO
+ASO
+(350
+PEJO
+PISJO
+PASO
+Driffam
+Duffin
+Dangtan
+anytam
+Dastar
+DRUG FARM
+6/HJ
+G-BLAG
+PRiO
+PAjO
+VI
+PAJO
+PRID
+R/S
+AGENT THOMAS
+VARIOUS
+Q- 8L06
+FDorm
+DRUG FARM
+TIME OUT-
+1949
+1014
+1610
+14214
+1l014
++ 1604
+107
+1722
+1017
+* 1650
+1050
+* 1005
+0942
+* 16010
+1001
+1810.
+1024
+1317
++ 1900
+1400
+this Area
+
+723/08
+723/08
+723/08
+7|23/08
+a3/08
+723 / 08
+1/23/08
+7P3/08
+1/23/08
+723/08
+7/23/08
+1/23/08
+1/23/08
+Продов.
+entie!
+Control
+• MAIN DETENTION CENTER
+#STOCKADE
+• WEST COUNTY DETENTION
+O DRUG FARM
+VISITOR NAME / ORGANIZATION
+M103
+SARAH KORN (PAE
+PASS #
+NAME OF STAFF/INMATE VISITING
+412
+PiRSO
+DRUG FARM
+JESSICA WALLY CDAF
+1500
+PBSO
+DRUG FARM
+DAN INDYKE (ATIV
+1535
+UNCK GOLDBERGER (A)TY
+1 PECIAL (F/M: EPSTENJ
+15:50
+IPECIAL (F/M: ENSTEIND
+Jerry Wade I (ATTY
+17:55
+anderson Teacher
+PBSO Diana EsteD.
+C-Dorr
+1800
+P8SO
+napkin bannister
+- 1
+prugtarm
+1840
+). terzanowski
+(-2
+- Dorm Church Service
+184D Deborah Prescott
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+atholic Seruc
+1845
+pulse marshal
+C-Dorm
+ristine Conr
+V-3
+C-4
+Catholic Service
+V-2
+1955
+T-Dorm
+V-3
+C-Dorm
+PBSO
+• Drug tarm
+TIME OUT
+705
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+1725
+1700
+14014.
+1935
+1900
+2000
+2000
+2000
+2000
+2080
+2018
+2100
+2100
+
+
+USTOCKADE
+Central contro
+VISITOR NAME / ORGANIZATION
+724/08/409
+1455
+1455
+Janiel Marsha// (Alty)
+1525
+-IndSay Hanson PD
+1545
+Michael foss lein
+1445
+2/54/08
+7/24108
+2/24|20
+7/29/05
+L4
+IESELER (AVARET) 3350
+1850
+O WEST COUNTY DETENTION O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+Drua tarn.
+PASO
+_-Dorm rE-Dorm
+SaL Dorme
+FDEMIA EOSTEIN T-RE
+Dorm
+FoR LO STON T-MCT
+AF RA I SA Q3
+SA-DoRm
+7/25,08 0130
+12505
+0730
+Custes Petre Kaiten
+7/25/05|0733
+V3
+Peso
+125/0807
+105/08858
+1378 150
+956
+traguelsor
+Ана радис
+PRSO
+PBSO
+Se tem
+Jung tam
+4: Ottice
+Kiterr
+compound
+CINDEUNC
+1500
+TIME OUT
+1700
+1537
+1623
+192)
+192
+1620
+Ricos-
+Zio
+2010
+2012
+2/100
+1141
+007
+1540
+1,00
+1718
+930
+1710
+- YY
+310
+1031
+Case 9:08-cv-80119-KAM Document 549-2
+ES.P.
+Paraleral
+legaleagleinc.
+Entered on FLSD Docket 05/07/2010 Page 35 of
+
+
+1/24/08
+0: 00
+7/21/08 03:59
+1240806:05
+07:20
+STOCKADE
+A VISITOR NAME /ORGANIZATION
+O WEST COUNTY DETENTION • DRUG FARM
+NAME OF STAFF/INMATE VISITING
+renutes
+3tTP1- QBEL
+STAD-QBIda
+SAHA
+SAAP
+TC -DOrM
+DALL HAM
+TIME OUT,
+1030
+/c3s
+1600
+1554
+1640
+1647
+8
+1603>
+175(
+955
+Bry Bau
+PS 2-Building
+k38m
+1735
+105c
+1495-
+1550
+Entered C.S.P. SD. Docket 05/07/2010 Page 36 of
+52
+
+
+* 7.2506
+122508 630
+12506
+18.25
+7-75-08
+725-08
+725-08
+1825
+Dows
+down
+Davo
+200-
+2o00
+STOCKADE
+Central Control
+O WEST COUNTY DETENTION O DRUG FARM
+PASS #
+BR
+NAME OF STAFF/INMATE VISITING
+PBSO
+farm
+нит
+Intake
+Form
+PRSU
+PLO
+CH Gorm
+1 special to see inmate Epacin
+N2
+I special tosee inmate Epstein
+Drua Farm
+sustarm
+Va
+Ma Farm
+TIME OUT
+·330
+14U0
+1455
+135
+1427/
+1105
+157
+173
+2000
+Extra Sen
+Paral
+Jar
+es 8
+Mith
+Fiorin.
+Jonathan tar?
+evm Larki.
+Sandal
+Rogers
+VIl
+Case 9:08-CV-80119-KAM Document 52S P
+Eatered on FLSD Docket 05/07/2010 Page 37 of
+
+
+MY STOCKADE
+VISITOR NAME / ORGANIZATION
+72808
+1150
+1-28-08
+75L
+Perez, Angel (biblestudy),
+7-2808
+1800
+MAnner car
+Kara (bible study) V-NI
+Central Control
+• WEST COUNTY DETENTION • DRUG FARM
+NAME OF STAFF/INMATE VISITING
+Drug arm
+72808
+1855
+7-28-08
+2000
+Quino, Seas CPD
+PASS #
+3
+SherM EriK
+7-2808
+2000
+7-2800
+pumato Brian (AA)
+2000
+V-2
+72828
+ollins, Hilda.
+28002095 Mason: Leronnie (ol
+Drud tarm.
+I-dorm
+C-dorm
+- wrong carpound +7814
+TIME OUT
+1909
+1909
+1927
+1930
+2110
+aldo
+alas
+
+
+7/28/08
+7/29|08
+7/a9|08
+1/29103
+7/29/08
+2/29/08
+07/29/08
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+07/29/08
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+07/29/08
+07/29/08
+ATInAinA
+140
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+1002
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+1046
+1058
+1121
+1140
+12:25
+1258
+1304
+1329
+1347
+1403
+Central Control
+O MAIN DETENTION CENTER STOCKADE
+U WEST COUNTY DETENTION
+O DRUG FARM
+VISITOR NAME / ORGANIZATION
+WILFORD
+TRINITY
+ELIZABETHER RINITY
+MR WEST
+SHAP
+MR 511B50N SNAP
+H19H ton ER SAAP
+tin JUStIN SHAP
+Patricia Edelman- SAAP
+PASS #
+PBSO
+PESO
+PBSO
+PBSO
+PESO
+PBSO
+John Habicht- Trinity Staff
+Nancy Valencia- SAAP
+Elta Emilcar- Trinity Staff
+Dobson- State of Fla. Investigor V-11
+Darren Indyke- Attorney
+Angeliki Weissinger- SAAP
+Patrecha Newby- Trinity Staff
+Robert Swisher- Ellison Services
+Cruz
+Ellison Services
+Julia
+• SAAP
+Arthur Troy- SAAP
+PBSO
+PBSO
+PBSO
+L-1
+PBSO
+PBSO
+v-12
+V-11
+PBSO
+PBSO
+Caitlin Bronstein- SAAP
+Varju- SAAP
+Dena Paquetta- Trinity Staff
+Harry
+- Securis Telephone
+Jay Lefkowitz- Attorney
+Evelyn Bannister- Chaplain
+Susan Hendricks- Attorney
+PBSO
+PBSOR
+PBSO
+PBSOR
+L-2
+PBSOR
+L-5
+NAME OF STAFF/INMATE VISITING
+# ITCHEN
+PRUS FARM
+DRus FARM
+DRUS FARM
+DRUS FARIN
+Drug Farm
+Q-Bldg.
+T-Dorm.
+Q-Bldg.
+I/M's:
+• K; Hader, A and Tipton, J
+I/M: Epstein, Jeffrey (I-Spec.)
+Drug Farm area.
+Q-Bidg.
+on the compound.
+on the compound.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm
+Q-B1dg.
+M-Dorm.
+I/M: Epstein, Jeffrey (T-Spec).
+on the compound to various dorms.
+I/M: Saint Phart, Rodney (F-Dorm).
+TIME OUT
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+
+O MAIN DETENTION CENTER U/STOCKADE
+VISITOR NAME / ORGANIZATION
+7(30/08
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++RIVITY
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+MR, PIVANEY
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+MS. WILLIAMS CANTEEN
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+730|08
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+7/30|08
+7:27
+MR WEST
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+Q-BLDB
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+JEFFREY CLARE (BOCA P.P.)
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+DYANE WILIAMS (DQ.C.)
+bse)n Maruuma(De
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+ESP. 7
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+
+7 30 05
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+OSTOCKADE
+O WEST COUNTY DETENTION
+O DRUG FARM
+PASS #
+NAME OF STAFF/INMATE VISITING
+TPECIAL (F/M: EPSTEIN, J)
+12
+T-SPECIAL (I/M: EPSTEIN, S.)
+
+MR KAYE
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+mira, Ostina?
+1558
+1600
+114
+Case 9:08-CV-01004
+E.S.P.
+Document 540-2
+Entered on FLSD Docket 05/07/2010 Page 41 of
+
+
+Central Control
+VISITOR NAME / ORGANIZATION
+STOCKADE
+OWEST COUNTY DETENTION
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+BSO
+Avebec
+Who is this person?
+Sun Fau
+SAA
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+The following circled didnot leave
+++140 01V4
+
+
+Central Contro
+OI MAIN DETENTION CENTER STOCKADE
+VISITOR NAME / ORGANIZATION
+08/01/08
+0905
+Nicole Bolden- Law of David Jayne
+08/01/08
+0910
+Story Crowles- Para Legal
+08/01/08
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+Nicole Dimasi- State of Fla(Investigator V-6
+08/01/08
+0926
+Patrecha Newby- Trinity Staff
+08/01/08
+1009
+- State of Fla.
+08/01/08
+1157
+Mirlande Osting- Trinity Staff
+08/01/08
+1224
+Det. Ivanovic- Deputy
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+- DAF
+08/01/08
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+Patricia Edelman- SAAP
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+Caitlin Bronstein- DAF
+08/01/08
+13:26
+Goldenberger Jack
+08/01/08
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+G. Scott Penney- Public Defender
+08/01/08
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+Jessica Wally- DAF
+08/01/08
+1412
+Sarah Korn- DAF
+08/01/08
+1436
+Justin. Timothy- SAAP
+08/01/08
+1439
+Kenneth Huxhold-SAAP
+******
+08/01/08
+****** C SHIFT ********** * 7811
+PASS #
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+L-1
+PBSO
+V-15
+PBSO
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+PBSO
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+PBSO
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+A-4
+PBSP
+PBSO
+PBSO
+PBSO
+PBSO
+*******
+8108
+1805
+Caites
+Hubtic Der
+teachers
+1'08
+18B0
+Amete Allen (teachers.
+830
+4-1
+08
+beltana Cork (
+8-1•08
+1830
+lover manuin
+7000
+5-1-08
+2000
+Arche lawan
+teaches)
+Alumni
+Florin
+Thomas (Alumni
+V-S
+81 06
+2,000
+arkin. kevin
+O WEST COUNTY DETENTION O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+I/M: Arthur Saxton (RA-Dorm) .
+I/M: Jeffrey Epstein (T-Special).
+Various dorms to see inmates.
+Q-Bldg.
+Variosu dorms to see inmates.
+Q-Bldg.
+I/M: Levi, Sheri (C-Dorm).
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+Drug Farm area.
+T dorm
+various dorms to see inmates.
+drug Farm AREA.
+Drug Farm area.
+Drug Farm area.
+Drug
+Farm area.
+***************************************
+I-special to see inmate Epstein
+Dria Farm
+Farm
+Dina Farm
+Dra Farm
+TIME OUT
+0928
+1325
+1027
+135
+1835
+1310
+1550
+11602l
+100S
+1621
+1350
+1622
+1454
+1654
+TuZi
+1519
+*******
+1950
+130
+130
+Entered on FLSD Docket 05/0712910 Page 43 of
+ES.P. *
+egal
+legaleagieinc.com
+
+
+0810208 935
+68
+0 08
+0725
+3/2/08
+8/7
+5/21,05
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+57/08
+2/>/118
+8/3/08
+8/3/08
+8/3/0€
+8/3/08
+1004
+8/3/08
+Central Control
+STOCKADE
+VISITOR NAME / ORGANIZATION
+• finbren
+ent Humes
+stephen Atexander (Ar
+sharon coilliam
+O WEST COUNTY DETENTION
+O DRUG FARM
+PASS #
+NAME OF STAFF/INMATE VISITING
+PESO
+PESO
+Trinity Staff
+- Dong
+JosEph
+PARANO
+DOTEiN SETTRi
+32
+TIME OUT
+957
+1105
+730
+YaC
+1316
+1875
+1340
+PBSO
+CBSO
+trinityp
+Sfaft
+Dy farm
+Josephi pagio
+$ 0728
+ittiger
+PBSOT
+Dinit
+H00
+1<10
+1220
+10HE 1845
+=103
+160S
+Case 9:08-CV-80119 ES.P. *Bocument 540-2
+Entered on FLSD Docket 05/07/2010 Page 44 of
+Extra Sens
+
+
+STOCKADE
+Central Control
+O WEST COUNTY DETENTION • DRUG FARM
+PASS #
+NAME OF STAFF/INMATE VISITING
+'RO
+ABSo Due
+taken
+put furn
+PBSO
+-Specia
+ABSC
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+zerry Wade
+Holy Caules (P.O.)
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+sueeney SAlly (AA)
+P3SO V-12
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+PBSO
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+MEDICAL.
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+E.co
+52ES.P. * FLSD Docket 05/07/2010 Page 45 of
+
+
+Central Control
+O MAIN DETENTION CENTER STOCKADE
+8/5/08
+8
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+VISITOR NAME / ORGANIZATION
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+1454
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+Hesi
+MSO
+1950
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+1915
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+1970
+705)
+1959
+200
+Entered on LSD Docket 05/07/2010 Page 46 of
+E.S.P.
+
+
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+EVELYN WILFORO
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+HETNUR TROY
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+GARL GIBSON
+MAICHEAL WEST
+CAITLIN BRONSTIEN
+ANGELIKI WESSMAN
+SUSAN WILKOFE
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+JOHN NABICHT CTANTY
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+1258
+DRUG FARM
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+Drug form
+Dug
+barm
+Doem (Freddy Ew-u Bo?
+Case 9:08-cv-80119-KAM Document 540-2 Entered on FLSD Docket 05/07/2010 Page 47 of
+52
+ESP $
+
+
+8/6/08
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+O WEST COUNTY DETENTION
+VISITOR NAME / ORGANIZATION
+PASS#
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+530
+MR PINKNEY.
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+TRINIITY
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+MS WESt
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+0859
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+MYLIIPTIANA BERTUCN (PD..
+0955
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+elly tnn Crowe
+0955
+V#3
+1005
+itoney Sitory H. Cowes
+sajann Seatrom t
+J0IS
+10.30
+Cantrol
+O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+HETCHE (V
+HITCHEN
+KITCHEN
+-VARIOUS
+VARIOUS
+PRU9 FARM
+LRU49 FARM
+DRUA FARM
+VARIOUS
+PRu9 FARM :
+DRUS FARM
+DRUG FARM
+DR Q-BU06
+Q-BLO6
+T-SPECIAL (IMM : ERSTEIN, 5.)
+Comprund
+C Dorm
+C-Dorn
+E-Dara- Intin, refr
+-builamate
+- bydes ompount
+pr meters omprunl
+TIME OUT
+1730
+(21)
+1)I/
+1430
+·630
+2555
+1G10
+1555
+1454
+11:00
+11:00
+104S
+1045
+130)
+11:00
+Entered on FLSD Docket 05/9E S09 Page 48 of
+Extra Sens
+Paralegal
+
+
+8
+87
+6
+08
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+VISITOR NAME / ORGANIZATION
+SCOTT FENNEY (P.D.)
+PASS #
+PABLO GONZALEZ (PAF)
+PBJO
+NAME OF STAFF/INMATE VISITING
+VARIDUS
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+CHRU FINKLEY (FIRE INSPECT
+PRUO
+DRUG FARM
+JENICA WALLY (DAF
+VI
+1443
+ISTL
+SEADORF
+SARAH KORN (DAF)
+PRIO
+DN46 FARM
+1409
+ROBERT HUMES (DAF)
+PRNO
+DRuG FARM
+MICHAEL TAKIFF (ATY)
+PASO
+K6S8
+PRUG FARM
+1158
+MINAEL TEN(ANTY
+Ll
+SA-DORMI
+Li
+1650
+I-SPECIAL (I/M: ERITE/N, 5)
+ISYB
+1502
+16332
+IRE BIVERA
+Свитси
+1940
+AN CoRTis
+67360
+C/2044
+1553
+2555
+1555
+Ms COHN
+Ins Sumaiz
+Daco Farm
+1551
+1755
+fran 4.
+T-mi
+1553
+ME COSTEIN LISTS
+MR THomPSoN
+Into
+Dore FaRm
+2028
+2/00
+MC MERKINS
+(AA)
+SASTERS -ME»ICAL.
+23/3
+2/057
+
+
+8/7/08
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+2 788
+BA10R
+Central Control
+d STOCKADE
+O WEST COUNTY DETENTION
+O DRUG FARM
+VISITOR NAME / ORGANIZATION
+01#5
+EVELYN WILFORO | TRINIT)
+PASS #
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+NAME OF STAFF/INMATE VISITING
+0y03
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+0637
+CURTIS PINKNEY I TRINITY
+PBSO
+KITCHEN
+ELIZABETU GREEN / TRINTY
+PeSO
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+ARTHUR TROY ISAAS
+KITCHEN
+6727
+GARY GIBSCH /SAAR
+PBSO KITCHEH DRUG FRAM
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+0733
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+CAIFEEAA CAITUN BRONSIEIN /SAA
+KIFeHtEt DRUG FARA
+PASO
+ANGELIKI WEISSMANI / SARP
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+PASO
+KITCKEM
+0752
+MICHAEZ WEST / SAME
+PBSS
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+PBSO
+SUSAN WILKUFEl SAAT
+DiCUrA FAem
+800
+DRUs FARM
+PBSO
+844
+VRSO
+Prugtam
+7 нит
+T-sprcial
+Bay Fum
+1016
+urance Ostin
+farnes, E(SChbOR(PD
+PBSO
+PB5D
+u 'vi ldina
+A BoLlding
+E-Dorm
+Dormi
+USSO
+Diug Fain
+-Dorm
+1414
+744/1 Trinto
+PKSO
+PBSO
+Bug tam
+SB Dorm
+TIME OUT
+1015
+1708
+1b15
+/58
+KGL8
+1778
+1614
+/(2J
+1730
+1700
+120 5
+13.
+118
+185
+049
+1440
+1652
+і 700
+Entered on ESP Bocket 05/07/2010 Page 50 of
+
+
+(shift
+8/8/08
+1SS3
+S/C
+0,810
+1945
+8/08
+8181 08
+1445
+1945
+194S
+STOCKADE
+VISITOR NAME / ORGANIZATION
+Reishast Bruce
+Goellnitz Helmut (Alumni)
+tracho savany
+zonens trilip, Alumi)
+O WEST COUNTY DETENTION
+PASS #
+L:2
+N-l
+VL
+V3
+FiORinI ThanAs.
+(Alumni)
+Central Control
+O DRUG FARM
+NAME OF STAFF/INMATE VISITING
+T'specighto sel inmak. Epstin
+Drug term"
+TIME OUT
+139
+Q107
+20
+210)
+2107
+
+
+8/1/08
+870?
+$ 708
+× 207
+27U8
+8- 8-6 8
+1538
+1203
+iP/S
+1P25
+1845
+1845
+2:20
+8-8:08
+8-8-08
+- 8108
+YOf
+88/08
+1/3/08
+5/8/02
+7f/n
+'entral (ontrol
+O MAIN DETENTION CENTER STOCKADE
+VISITOR NAME / ORGANIZATION
+• WEST COUNTY DETENTION
+PASS #
+O DRUG FARM
+story crowles
+NAME OF STAFF/INMATE VISITING
+CBOWLES
+/special
+ST BESSIN
+/
+VILL
+SCOTT SCHEINRES ROOS
+AA
+SINGH, A
+ПА
+leng
+M. Get pays
+112
+43
+8BSU
+ASSU
+BSU
+PSSU
+PESO
+PASU
+350
+VI
+Bsd
+BST
+In DR
+1S(0
+Stray, corne
+Ra Bagam
+TIME OUT
+1725
+19287
+1935
+19os
+2000
+2000
+1000
+1535
+1535
+11400
+1400
+1503
+-
+50
+Case 9:08-cv-0115 KAM Document 540-2
+Entered on FLSD Docket 05/07/2010 Page 52 of
+E.S.P.
+Paralegal
+14145) unanta pope
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f626a2b627a61a507933a37a7b27574aebe3f8d6b2721a7c54f9d17bf1dfedc2.receipt.json b/vision-fixhub/court-01/f626a2b627a61a507933a37a7b27574aebe3f8d6b2721a7c54f9d17bf1dfedc2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e333c26dc524225bc6abd7c69db69a85e22669dc
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+  "page_markers": false,
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+}
diff --git a/vision-fixhub/court-01/f62c1ad303972d4234d0de7c6ea2e21e596079b4b951c263d203ba1a637c7a6c.md b/vision-fixhub/court-01/f62c1ad303972d4234d0de7c6ea2e21e596079b4b951c263d203ba1a637c7a6c.md
new file mode 100644
index 0000000000000000000000000000000000000000..71975a70e846ef6a20fcd7850a0a978dd08b44cd
--- /dev/null
+++ b/vision-fixhub/court-01/f62c1ad303972d4234d0de7c6ea2e21e596079b4b951c263d203ba1a637c7a6c.md
@@ -0,0 +1,287 @@
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 1 of 10
+Independent
+Epstein Victims' Compensation Program
+PROTOCOL
+DRAFT'
+December 13January 9, 202019
+I.
+Purpose and Overview
+The Epstein Victims' Compensation Program (the "Program") is a voluntary, independent Program that
+has been established to compensate and resolve the claims of victims/survivors of sexual abuse by Jeffrey
+Epstein ("Epstein").
+The Estate of Jeffrey Epstein (the "Estate") has retained the services of nationally recognized claims
+administration experts Kenneth R. Feinberg, Camille S. Biros and Jordana H.
+to design the
+Program.
+will also serve as the Administrator of the Program (the "Administrator").
+Through the Program, the Estate wishes to acknowledge the wrongs endured by victims/survivors and
+offer them an opportunity to voluntarily resolve their individual claims for such sexual abuse.
+The Program is governed by the following non-exclusive guiding principles:
+• The Program is purely voluntary. It does not affect any rights a victim may have
+unless and until the Claimant accepts the offered compensation and executes a
+Release. A Claimant may reject the offer of compensation and may stop participating
+in the Program and withdraw the claim at any time prior to execution of the Release.
+• The Program is independent and will in no way be administered, controlled or
+overseen by the Estate. The Administrator is responsible for all decisions relating to
+the review, processing and evaluation of individual claims submitted to the Program.
+The Administrator will have final, binding and exclusive authority to determine
+Claimant eligibility and the valuation of each eligible individual claim. Decisions of
+the Administrator made pursuant to this Protocol are not subject to review or
+modification in any way by the Estate or any other party or entity.
+• There is no cap or limitation on the aggregate amount of funds available to
+compensate all eligible Claimants or on the amount of compensation to be made to
+each individual Claimant. Each individual claim will be evaluated separately by the
+Administrator. The Administrator will determine, in her sole and exclusive discretion,
+issues of eligibility and the amount of compensation.
+1 This document is a draft of the Protocol governing the Program and is subject to input from victims/survivors, their lawyers,
+other potentially interested parties, and representatives of the Estate.
+1| Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 2 of 10
+• All Claimants will be treated with respect, dignity and fairness without regard to race,
+color, sexual orientation, national origin, religion, gender or disability. To ensure
+claims will be adjudicated fairly, the Administrator will manage the process so that
+all Claimants can equally access the Program's claim process. Individuals with
+disabilities will be given the opportunity to effectively communicate their claims and
+to request special process accommodations.
+The Program will be effective within 90 days of approval by the Superior Court of the U.S. Virgin Islands
+("Effective Date") and is available to all victims/survivors regardless of where they were harmed, when
+they were harmed, whether the claim is time-barred by the applicable statute of limitations, and whether
+they have previously filed a lawsuit against or settled with Epstein and/or the Estate.
+The exclusive claims period for filing a claim pursuant to this Protocol shall commence on the to-bedetermined Effective Date and shall conclude nine (9) months after that date ("Filing Deadline"). All
+individual claims filed with the Program must be postmarked within this period.
+II.
+Eligibility Requirements
+A. Eligibility Criteria
+The persons eligible to participate in this Program are individuals who allege they were sexually abused
+by Epstein. In addition, the following criteria apply:
+• The claim of sexual abuse must be directed against Epstein.
+• An individual whose claim is time-barred by the applicable statute of limitations may participate
+in the Program provided that other eligibility criteria are met.
+• An individual who previously entered into a settlement agreement resolving a claim of sexual
+abuse against Epstein may participate in the Program provided that other eligibility criteria are
+met.
+• An individual who was over 21 at the time and who allegedly assisted Epstein in procuring other
+victims/survivors may participate in the Program where there is a credible basis to determine
+that the individual acted under duress as a result of her own sexual abuse by Epstein, provided
+that other eligibility criteria are met. For avoidance of doubt, the fact that an individual who
+was under 21 is alleged to have assisted Epstein in procuring other victims/survivors is not
+relevant to either eligibility or the amount of recovery under the Program.
+• If the Claimant chooses to accept the offered compensation, the Claimant must dismiss with
+prejudice any existing lawsuits or legal actions or claims filed against the Estate or related entities
+and/or individuals. The Claimant must provide proof of such dismissal along with or prior to the
+signed acceptance letter and executed Release in order to receive payment.
+2| Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 3 of 10
+" The final version of the Protocol will include dates certain identifying the commencement date of the Program and
+registration and filing deadlines, as explained below.
+2| Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 4 of 10
+B. Legal Representatives of Claimants
+An individual may file a claim on a victim's behalf where that individual has been granted legal authority
+to act in a representative capacity pursuant to appropriate law. The "Legal Representative" of an
+individual Claimant shall mean: (1) in the case of a Claimant who is currently a minor, a parent or legal
+guardian authorized by law to serve as the minor's legal representative; (2) in the case of an incompetent
+or legally incapacitated Claimant, a person who has been duly appointed as the Claimant's legal
+representative in accordance with applicable law; or (3) an attorney authorized to represent the Claimant
+for purposes of pursuing a claim through this Program.
+Legal Representatives must provide proper documentation demonstrating representative capacity. Such
+proof may include a power of attorney, documentation showing the individual's appointment as guardian
+or guardian ad litem, or a copy of a retainer agreement showing legal representation signed by both the
+Claimant and the attorney.
+III.
+Claims Administration - Submission, Evaluation and Determination
+A. Claims Submission Process
+Individuals who have filed a lawsuit, legal action or claim against Epstein and/or the Estate on or before
+the Effective Date will be sent a Claim Form and other relevant Program information, including
+Instructions for completion and submission of the Claim Form and a list of Frequently Asked Questions.
+Individuals who have filed a lawsuit need not agree to a stay of litigation or make any other concession
+in a pending litigation to be eligible for participation in the Program.
+Individuals who have not filed a lawsuit, legal action or claim against Epstein and/or the Estate on or
+before the Effective Date may register to participate in this Program on the Program's website at
+www.EpsteinVictimsCompensationProgram.com. To register, such individuals must complete a
+questionnaire setting forth their name, contact information, a summary description of the nature of the
+claim and other requested information. Upon registration, the Administrator will perform a preliminary
+review to consider if the individual is eligible to participate in the Program. If the Administrator deems
+that the individual is eligible to participate in the Program, she will then send that individual a Claim Form
+and other relevant Program information.
+Note: The fact that an individual is sent a Claim Form and other relevant Program information indicates
+that the Administrator has determined that such individual is eligible to participate in the Program. It
+does not indicate that the Administrator has determined that such individual is eligible to receive
+compensation. That determination is made only after a Claim Form and all required documentation has
+been submitted and evaluated by the Administrator.
+Registrations will be accepted by the Administrator from the Effective Date through a date that is 45 days
+prior to the Filing Deadline ("Registration Deadline"). It is important to note that the Registration Deadline
+is separate from, and precedes, the Filing Deadline. As explained above, all claims must be filed by the
+Filing Deadline.
+3 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 5 of 10
+3 This website is in the process of being developed and is yet operational.
+4| Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 6 of 10
+All Claim Forms must be completed and postmarked no later than the Filing Deadline. Claim Forms
+should be mailed via overnight courier (a pre-paid courier voucher will be included with each packet) to
+the Administrator at the following address or uploaded to the Program website at
+www.EpsteinVictimsCompensationProgram.com:
+Epstein Victims' Compensation Program
+c/o Jordana H.
+, Administrator
+[Address - To Be Inserted]
+Claimants are invited to provide documentation identified in the Claim Form, and any other corroborating
+or supporting information sufficient to substantiate the claim, satisfy eligibility requirements, and allow
+the Administrator to review, process and evaluate the claim. If the claim is being presented by a Legal
+Representative, then the Legal Representative will be responsible for submitting the necessary
+documentation relating to the represented Claimant.
+Additional documentation may be requested at the discretion of the Administrator. Both the Claimant
+and the Estate will be afforded the opportunity to submit to the Administrator any information deemed
+relevant to the Administrator's evaluation and determination of the claim before the Administrator's final
+disposition of the claim.
+If a Claimant submits an incomplete or deficient claim, the Administrator will notify the Claimant, explain
+the additional information that is needed, and work with the Claimant or the Claimant's Legal
+Representative (where applicable) to assist in submitting a complete claim.
+B. Claims Evaluation and Determination
+Claims will be evaluated in the order in which they are received, with the Administrator evaluating each
+submitted individual claim in a prompt and fair manner. Claims will only be determined once all required
+documentation has been submitted to the Administrator
+1. Factors Considered in Evaluating Claims
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, whether the allegations of sexual abuse are credible. The Administrator will
+consider appropriate factors and corroborative support, including but not limited to:
+• The level of documentation, corroboration or other circumstantial evidence regarding the nature
+and extent of the abuse, the frequency, location and other details of the abuse, and the age of
+the victim at the time of the abuse. Non-exhaustive examples of such evidence include (i)
+medical or psychiatric counseling/therapy records relevant to the abuse, and
+(ii) contemporaneous written notification or other correspondence (e.g., letters, emails) of the
+abuse by the Claimant to law enforcement authorities, parents, friends or others. The
+Administrator acknowledges that some Claimants may not be able to provide any
+documentation to corroborate their Claim based on the nature and circumstances Epstein's
+conduct.-. If a Claimant testifies credibly about Epstein's abuse, but cannot provide other
+5 | Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 7 of 10
+evidence to corroborate her testimony, the Claimant is still eligible for compensation under the
+Program.
+• Whether there exists any information and/or pertinent findings offered by the appropriate
+Office of the District Attorney, United States Attorney's Office, or other law enforcement
+agency.
+6 | Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 8 of 10
+• Whether the Administrator finds the claims of the individual to be credible after complete review
+of all relevant documentation and other evidence provided by the Claimant and the Estate.
+As to each individual claim, the Administrator will determine, in her sole discretion based upon all of the
+information available, the amount of compensation that should be offered to each eligible Claimant. The
+Administrator will consider appropriate factors and corroborative support, including but not limited to:
+• The nature, duration and extent of the sexual abuse suffered by the Claimant.
+• The age of the Claimant at the time of the sexual abuse.
+• The nature and extent of the Claimant's physical or psychological damage resulting from the
+sexual abuse, and the effect of the sexual abuse on the Claimant.
+• The credibility of the claim based upon all of the facts and circumstances, supporting
+documentation and corroborating evidence.
+• Whether the claim is time-barred under the applicable statute of limitations.
+• Whether the Claimant previously entered into a settlement agreement with Epstein and received
+a payment pursuant to such agreement.
+The Administrator will confidentially send the Claimant a compensation determination letter including the
+following: (1) the Administrator's eligibility decision regarding the claim; (2) the amount of compensation
+offered; (3) a Release to be signed by the Claimant if the Claimant accepts the offered compensation; and
+(4) a Payment Option Form. The Administrator's offer shall be valid for 60 days from the date of the
+compensation determination letter.
+The Administrator's determinations in this Program will not be binding on any potential criminal
+investigation involving the same or similar allegations or Claimant.
+2. Opportunities to be Heard
+The Claimant will be afforded an opportunity to be heard, either before or after the Administrator renders
+her determination. Upon request by the Claimant, the Administrator will be available to meet in person,
+by video conference/Skype, or by teleconference to further discuss the claim. These meetings are
+completely optional and voluntary. Requests to meet with the Administrator should be sent by email
+claimantservices@epsteinvictimscompensationprogram.com* and will be scheduled at a mutually
+convenient time and location. The Administrator may also request a meeting with a Claimant or her Legal
+Representative at a reasonable mutually convenient time and location, though the Claimant is not
+obligated to attend any such meeting.
+4 This email address is not yet active.
+7| Page
+
+
+Case 1:19-CV-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 9 of 10
+3. Release
+By submitting a claim to the Program, a Claimant is seeking to resolve all claims relating to allegations of
+sexual abuse against Epstein and/or the Estate, related and specific entities and/or individuals to be
+identified by the Estate. If a Claimant chooses to accept the offer of compensation pursuant to the
+Program, the Claimant will be required to sign and execute a full Release, in a form satisfactory to the
+Estate, of all past and future claims relating to such allegations of sexual abuse against the Estate,
+related entities and/or individuals. A Claimant may reject the offer of compensation and may stop
+participating in the Program and withdraw the claim at any time prior to the execution of the Release.
+The Release will waive any rights the Claimant and her heirs, descendants, legatees or beneficiaries
+may have to assert any claims relating to allegations of sexual abuse against the Estate, related entities
+and/or individuals, to file an individual legal action relating to such allegations, or to participate in any
+legal action associated with such allegations, except as a witness. However, the Release will not
+operate to preclude or limit the Claimant's ability to report and discuss allegations of sexual abuse with
+law enforcement officials or anyone else.
+Before signing a Release, the Claimant must consult with an attorney. If the Claimant is not represented
+by an attorney, the Program will provide an attorney to provide free legal counseling to the Claimant
+for the sole purpose of advising the Claimant concerning the language and binding nature of the
+Release.
+No one affiliated with the Program will provide tax or legal advice to those receiving payments under
+the Program. Claimants are urged to consult with a tax advisor concerning any questions regarding tax
+liability for payments pursuant to the Program.
+4. Payments
+Upon the Claimant's acceptance of the Administrator's determination, the Administrator's receipt of
+the Claimant's executed Release and, where applicable, dismissal with prejudice of any existing lawsuit
+or legal actions or claims against the Estate or related entities and/or individuals, the Administrator will
+initiate payment by check or electronic funds transfer to each eligible Claimant as directed by the
+Claimant. Checks will be sent to Claimants via overnight courier service. _All payments made under
+the Program shall be for a Claimant's physical injuries, physical sickness and resulting emotional
+distress within the meaning of Section 104(a) of the Internal Revenue Code.
+C. Program Integrity
+For the purpose of protecting both the integrity of the Program and financial resources for eligible
+Claimants, the Administrator will institute all necessary measures to prevent payment of fraudulent
+claims, including taking steps to verify claims and analyze submissions for inconsistencies, irregularities
+or duplication.
+8 | Page
+
+
+Case 1:19-cv-08673-KPF-DCF Document 42-6 Filed 01/10/20 Page 10 of 10
+Each Claimant who signs the Claim Form at the time of submission certifies that the information provided
+in the Claim Form is true and accurate to the best of the Claimant's knowledge, and that the Claimant
+understands that false statements or claims made in connection with such submission may result in fines,
+imprisonment and/or any other remedy available by law. Claims that appear to be potentially fraudulent
+or to contain false information-will be forwarded to federal, state or local law enforcement agencies
+and/or the appropriate Office of the District Attorney for possible investigation and prosecution.
+D. Confidentiality/Privacy
+The Program is confidential. By filing a claim with the Program, the Claimant or her Legal
+Representative (where applicable) agrees that information submitted by the Claimant pursuant to the
+Program will be used and/or disclosed by the Administrator and her designees only for the following
+purposes:
+1) Processing and evaluating the Claimant's claim;
+2) Administering the Program and other Program-related work; and
+3) Reports to law enforcement where appropriate.
+When documents maintained or submitted by the Estate become part of a Claimant's file for purposes
+of the Program, such materials will be reviewed by the Administrator to assist in processing and
+evaluating the claim, but will otherwise remain confidential. These files are not available for inspection,
+review or copying by the Estate or the Claimant or her representatives during or after the Program, and
+all pertinent settlement privileges and other privileges apply.
+To protect the privacy of Claimants participating in the Program, all personal information provided by
+the Claimant during this process will be returned or destroyed within one year after the conclusion of
+the Program.
+Individual Claimants are not bound by any rules of confidentiality. Claimants may, at their sole and
+voluntary option, disclose information in their possession regarding their claim, their compensation and
+their experience with the Program.
+All confidentiality requirements are subject to law, regulation and judicial process.
+The Administrator mayshall, on a periodic-monthly basis, publish reports regarding the Program's claims
+processing or other activities in an effort order to provide transparency including, without limitation,
+the number of claims filed, the number of claims settled, the number of claims rejected, the number of
+claims referred to law enforcement, the aggregate amount of settlement payments made, and the
+amount of fees and costs incurred in administering the Program. Such reports will report on an
+aggregate level only. No individual Claimant information will be published or disclosed in a way that
+compromises Claimant confidentiality.
+9 | Page
diff --git a/vision-fixhub/court-01/f62c1ad303972d4234d0de7c6ea2e21e596079b4b951c263d203ba1a637c7a6c.receipt.json b/vision-fixhub/court-01/f62c1ad303972d4234d0de7c6ea2e21e596079b4b951c263d203ba1a637c7a6c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bae6f0d064ff1acd775e6aebf633a80e19def763
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@@ -0,0 +1,14 @@
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+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
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+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f65e32c3d37a7e922f29d913564e9c256bd0b9526d989135ccd5bb831d1ffbf0.md b/vision-fixhub/court-01/f65e32c3d37a7e922f29d913564e9c256bd0b9526d989135ccd5bb831d1ffbf0.md
new file mode 100644
index 0000000000000000000000000000000000000000..8c5768268672b9bf56af70bd6f314d70f78b01f6
--- /dev/null
+++ b/vision-fixhub/court-01/f65e32c3d37a7e922f29d913564e9c256bd0b9526d989135ccd5bb831d1ffbf0.md
@@ -0,0 +1,87 @@
+Case 9:08-cv-80232-KAM Document 148 Entered on FLSD Docket 06/25/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+/
+STIPULATION OF DISMISSAL WITH PREJUDICE
+Plaintiff, JANE DOE NO. 3 and Defendant, JEFFREY EPSTEIN, (collectively,
+"Parties"), by and through their undersigned counsel and pursuant to Rule 41(A)(ii) of
+the Federal Rules of Civil Procedure, hereby stipulate to the dismissal of this action with
+prejudice. Each party shall bear their own attorneys fees and costs. The Parties further
+stipulate that the Court shall retain jurisdiction to enforce the terms of the Parties'
+settlement.
+Dated this 2514
+. day of June, 2010
+BURMAN, CRITTON, LUTTIER &
+COLEMAN, LLP
+Attorneys for Jeffrey, Epstein
+OR CATION FRE
+., ESC
+Florida Bar No./ 224162
+rcrit@bclclaw.com
+303 Banvan Boulevard
+Respectfully submitted,
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Jane Doe No. 3
+ADAM D. HOROWITZ. ESO.
+Florida Bar No. 376980
+ssm@sexabuseattorney.com
+18205 Biscayne Boulevard
+
+
+Case 9:08-cv-80232-KAM Document 148 Entered on FLSD Docket 06/25/2010 Page 2 of 2
+Page 2
+Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this _
+25111
+day a fune
+, 2010:
+Respectfully submitted,
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe No. 3
+By: _Is/ Robert D. Critton, Jr.
+ROBERT D. CRITTON, JR., ESQ
+Florida Bar No. 224162
+crit@bclclaw.com
+ICHAEL J. PIKE, ESC
+Florida Bar No. 617296
+npike@bclclaw.com
+URMAN,CRITTON,LUTTIER & COLEMAN.LLI
+West Pala Beach, L 33401 400
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/f65e32c3d37a7e922f29d913564e9c256bd0b9526d989135ccd5bb831d1ffbf0.receipt.json b/vision-fixhub/court-01/f65e32c3d37a7e922f29d913564e9c256bd0b9526d989135ccd5bb831d1ffbf0.receipt.json
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diff --git a/vision-fixhub/court-01/f6ad6c14e0eac97f3a7c5cd99bfd0e7837e987c83f21f970bbd37ff430c76be4.md b/vision-fixhub/court-01/f6ad6c14e0eac97f3a7c5cd99bfd0e7837e987c83f21f970bbd37ff430c76be4.md
new file mode 100644
index 0000000000000000000000000000000000000000..2cba4d5057a5dad8f32740120310f5cb0ef1a047
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@@ -0,0 +1,73 @@
+Case 9:09-cv-80656-KAM Document 51 Entered on FLSD Docket 10/15/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-80656-MARRA
+JANE DOE No. 102,
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant,
+DEFENDANT JEFFREY EPSTEIN'S UNOPPOSED MOTION FOR EXTENSION
+OF TIME IN WHICH SERVE RESPONSIVE PLEADING TO COMPLAINT
+Defendant, Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned
+attorneys, respectfully moves this Court for an extension of time in which to respond to
+Complaint dated, May 1, 2009 [DE 1]. Defendant seeks an extension until October 30,
+2009, to file his response. As good cause in support of granting the motion, Defendant
+states:
+1. On May 1, 2009 Plaintiff filed a Complaint [DE 1]. Defendant's response would
+be due on August 20, 2009, as previously agreed upon.
+2. The parties continue to work together to potentially resolve this case.
+3. The requested extension is fair and reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN to fully and adequately respond.
+4. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
+Plaintiff's counsel is in agreement with the requested extension.
+
+
+Case 9:09-cv-80656-KAM Document 51 Entered on FLSD Docket 10/15/2009 Page 2 of 3
+Doe 102 v. Epstein
+Page 2
+WHEREFORE Defendant respectfully requests that this Court enter an Order
+granting an extension until October 30, 2009, to file a response to Plaintiff's Complaint.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by telephone and correspondence with
+counsel for the Plaintiff and Counsel for Plaintiff is in agreement with the requested
+extension until October 30, 2009 for Defendant to respond to Plaintiff's Complaint.
+Attorney for Defendant
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:09-cv-80656-KAM Document 51
+Entered on FLSD Docket 10/15/2009 Page 3 of 3
+Doe 102 v. Epstein
+Page 3
+CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/f6ad6c14e0eac97f3a7c5cd99bfd0e7837e987c83f21f970bbd37ff430c76be4.receipt.json b/vision-fixhub/court-01/f6ad6c14e0eac97f3a7c5cd99bfd0e7837e987c83f21f970bbd37ff430c76be4.receipt.json
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diff --git a/vision-fixhub/court-01/f6b91b6ccc25f563ab598ca88a7ec34674905c6e14edbd416533b747adfba8c4.md b/vision-fixhub/court-01/f6b91b6ccc25f563ab598ca88a7ec34674905c6e14edbd416533b747adfba8c4.md
new file mode 100644
index 0000000000000000000000000000000000000000..f2aef3f84ea01adebdc60552e6257607d5b3d858
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+++ b/vision-fixhub/court-01/f6b91b6ccc25f563ab598ca88a7ec34674905c6e14edbd416533b747adfba8c4.md
@@ -0,0 +1,35 @@
+Case 1:20-cv-02365-LJL-DCF Document 25 Filed 06/01/21 Page 1 of 1
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+Sanders LLP
+troutman.com
+troutman"
+pepper
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+June 1, 2021
+VIA ECE
+Hon. Debra C. Freeman
+Daniel |
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re:
+Jane Doe v. Darren . Indyke and Richard D. Kahn, in their capacities as
+the Executors of the Estate of Jeffrey E. Epstein, 1:20-cv-02365-LJL-DCF
+Dear Judge Freeman:
+Pursuant to the Court's September 4, 2020 Order (ECF No. 15), Plaintiff and
+Defendants Darren |. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey
+E. Epstein, jointly submit this status report.
+Plaintiff has submitted her claim to the Epstein Victims' Compensation Program
+(the "Program"), which is currently being considered. Should Plaintiff resolve her claims
+against Defendants via the Program, the parties will thereafter promptly discontinue this
+action with prejudice.
+To preserve the parties' resources and in the interests of judicial economy, the
+parties respectfully request that this case remain stayed at this time.
+Respectfully submitted,
+/s/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)
diff --git a/vision-fixhub/court-01/f6b91b6ccc25f563ab598ca88a7ec34674905c6e14edbd416533b747adfba8c4.receipt.json b/vision-fixhub/court-01/f6b91b6ccc25f563ab598ca88a7ec34674905c6e14edbd416533b747adfba8c4.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-01/f6cb5f6a2921f96a760abfc8aed180270c5fd105295ec047a2b26ceb2285730b.md b/vision-fixhub/court-01/f6cb5f6a2921f96a760abfc8aed180270c5fd105295ec047a2b26ceb2285730b.md
new file mode 100644
index 0000000000000000000000000000000000000000..b81ef240db1794ea7070860babd8d69976b70cc7
--- /dev/null
+++ b/vision-fixhub/court-01/f6cb5f6a2921f96a760abfc8aed180270c5fd105295ec047a2b26ceb2285730b.md
@@ -0,0 +1,45 @@
+Case 1:19-cV-08673-KPF-DCF Document 14 Filed 10/31/19 Page 1 of 2
+KAPLAN HECKER & FINK LLP
+350 FIFTH AVENUE | SUITE 7110
+NEW YORK, NEW YORK 10118
+TEL (212) 763-0883 | FAX (212) 564-0883
+WWW.KAPLANHECKER.COM
+DIRECT DIAL 212.763.0884
+DIRECT EMAIL rkaplan@kaplanhocker.com
+October 31, 2019
+VIA ECF
+The Honorable Katherine Polk Failla
+United States District Court
+Southern District of New York
+Thurgood Marshall United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re: Doe v. Indyke et al., No. 19-cv-08673 (KPF)
+Dear Judge Failla:
+We represent Jane Doe in the above-captioned action.
+We write in response to the letter dated October 29, 2019, from Bennet Moskowitz, counsel
+for Defendants, representatives of the Estate of Jeffrey Epstein (ECF No. 13), in which Mr.
+Moskowitz argues that the Order that Judge Castel issued granting the plaintiff's motion for leave
+to proceed anonymously in Katlyn Doe v. Darren Indyke and Richard D. Kahn as Joint Personal
+Representatives of the Estate of Jeffrey E. Epstein, et al., 1:19-cv-7771, was issued ex parte, prior
+to Defendants' appearance in that case. It is not clear to us why Defendants would object to
+Plaintiff, a childhood victim of sexual assault, proceeding pseudonymously in this case,
+particularly when so many other courts have granted motions to proceed under pseudonym in
+analogous circumstances. It is also worth noting that although Mr. Moskowitz had 14 days to seek
+reconsideration of Judge Castel's ruling pursuant to Rule 6.3 of the Local Rules, he failed to do
+SO.
+In addition, we would like to request a conference in this matter. Despite multiple rounds
+of email correspondence and an attempt to meet and confer, Defendants have failed to confirm that
+they are properly preserving relevant documents. See Ex. A (parties' correspondence). Although
+Defendants are not obligated to respond to the Complaint until November 15, 2019, given the risks
+
+
+Case 1:19-cv-08673-KPF-DCF Document 14 Filed 10/31/19 Page 2 of 2
+KAPLAN HECKER & FINK LLP
+2
+of spoliation, we respectfully request that the Court calendar a conference in which this issue can
+be discussed with the Court as soon as possible.
+Respectfully submitted,
+Kolk
+Roberta A. Kaplan
+cc: Counsel of Record
diff --git a/vision-fixhub/court-01/f6cb5f6a2921f96a760abfc8aed180270c5fd105295ec047a2b26ceb2285730b.receipt.json b/vision-fixhub/court-01/f6cb5f6a2921f96a760abfc8aed180270c5fd105295ec047a2b26ceb2285730b.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/f71427b298ad467f96cb8e95c97e00912dffd14318381981571c870ea3319621.md b/vision-fixhub/court-01/f71427b298ad467f96cb8e95c97e00912dffd14318381981571c870ea3319621.md
new file mode 100644
index 0000000000000000000000000000000000000000..edeb7bb7604f1cecd66a29694ba7cd18a571e574
--- /dev/null
+++ b/vision-fixhub/court-01/f71427b298ad467f96cb8e95c97e00912dffd14318381981571c870ea3319621.md
@@ -0,0 +1,64 @@
+Case 1:19-CV-10577-LJL-DCF Document 17 Filed 01/02/20 Page 1 of 2
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman"
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+USDC SDNY
+DOCUMENT
+Application GRANTED.
+ELECTRONICALLY FILED
+DOC #:
+A referral order will issue separately. The initial
+DATE FILED:_1/2/2020
+pretrial conference, scheduled for January 9, 2020,
+January 2, 2020
+is canceled.
+ECF
+Dated: January 2, 2020
+New York, New York
+Hon. Lorna G. Schofield
+Thurgood Marshall
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+UNITED STATES DISTRICT JUDGE
+Re:
+Jane Doe 1000 v. Darren K. Indyke and Richard D. Kahn in their capacities as the
+executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cV-10577-LGS
+Dear Judge Schofield:
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E.
+Epstein (together, "Defendants") in the referenced action. Defendants respectfully request that
+the Court refer this action to Magistrate Judge Debra C. Freeman for General Pretrial (including
+scheduling, discovery, non-dispositive pretrial motions, and settlement). Plaintiff consents to
+this request.
+As a matter of context, several other Judges in this District have collectively referred to
+Magistrate Freeman for General Pretrial numerous actions against Defendants in their
+capacities as Co-Executors of the Estate of Jeffrey E. Epstein, including two actions in which
+the parties are represented by the respective counsel of record in this action.' Magistrate
+Freeman held a status conference on November 21, 2019, which counsel of record for the
+parties to this action attended. Magistrate Freeman requested the parties in the matters
+referred to Her Honor to submit status reports on January 10, 2020.
+'See
+v. Darren K. Indyke and Richard D. Kahn, in their capacities as the executors of the
+Estate of Jeffrey Edward Epstein. Case No. 19-cv-10476-PGG-DCF, Order of Reference (ECF Doc. 6)
+(S.D.N.Y. Nov. 21, 2019);
+the executors of the Estate of Jeffrey Edward Epstein, Case No. 19-cv-10479-ALC-DCF, Order of
+Reference (ECF Doc. 8) (S.D.N.Y. Dec. 26, 2019).
+
+
+Case 1:19-cv-10577-LJL-DCF Document 17 Filed 01/02/20 Page 2 of 2
+January 2, 2020
+Page 2
+troutman™
+sanders
+The parties are aware that this Court had planned for the parties to submit Joint Letters and
+Civil Case Management Plans and Scheduling Orders today. However, in light of this request
+for referral to Magistrate Judge Freeman, the parties request the Court's guidance on whether
+these documents should be submitted.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
diff --git a/vision-fixhub/court-01/f71427b298ad467f96cb8e95c97e00912dffd14318381981571c870ea3319621.receipt.json b/vision-fixhub/court-01/f71427b298ad467f96cb8e95c97e00912dffd14318381981571c870ea3319621.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/f714845e6291e47fcd1757fdae6aaf75dec1d67e83995f098013dffc35315304.md b/vision-fixhub/court-01/f714845e6291e47fcd1757fdae6aaf75dec1d67e83995f098013dffc35315304.md
new file mode 100644
index 0000000000000000000000000000000000000000..223994e5e5aaf9c02e281eadcd6d0f53310d47f5
--- /dev/null
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@@ -0,0 +1,1238 @@
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 1 of 33
+CASE NO.: 08-CV-80119-MARRA-J
+JANE DOE NO. 2,
+Plaintiff,
+V.
+FILED by
+D.C.]
+JEFFREY EPSTEIN,
+Defendant.
+SEP 1 1 2009
+TERER US ARST. CT.
+S.D. OF FLA. - W.PE
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+Defendant Epstein's Emergency Motion To Strike Plaintiff's Motion For
+Protective Order (DE 292) And Emergency Motion To Allow The
+Attendance Of Jeffrey Epstein At The Deposition Of Plaintiffs And Response
+In Opposition To Plaintiffs', Jane Doe Nos. 2-8, Motion For Protective Order
+As To Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs, With
+Incorporated Memorandum of Law
+Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to all
+applicable rules, including Local Rule 7.1(e) and Local Rule 12, hereby files and serves his
+Emergency Motion To Strike Plaintiff's Motion For Protective Order (DE 292) And Emergency
+Motion To Allow The Attendance Of Jeffrey Epstein At The Deposition Of Plaintiffs And
+Response In Opposition To Plaintiffs', Jane Doe Nos. 2-8, Motion For Protective Order As To
+Jeffrey Epstein's Attendance At The Deposition Of Plaintiffs. In support, Epstein states:
+Introduction and Background
+On August 19, 2009, Defendant sent a Notice for Taking the Deposition of Jane
+Doe No. 4 for September 16, 2009. See Exhibit "1"
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 2 of 33
+Page 2
+2.
+Additionally, notices were sent out in other cases in connection with deposing
+additional Plaintiffs.
+3.
+No objection(s) was/were received for Jane Doe No. 4, which was the only
+deposition set relative to the Jane Doe 2-8 Plaintiffs.
+4.
+On August 27, 2009, the undersigned counsel sent a letter to counsel for Jane Doe
+No. 4 concerning her deposition and the scheduling of same on the above date. See Exhibit "2".
+5.
+No response was received until counsel for Jane Doe No. 4 called on September
+8, 2009, approximately eight days prior to the scheduled deposition, to indicate that they now
+had an objection and would be filing a motion for protective order seeking to prevent Epstein
+from attending the deposition. Once again, Plaintiffs are attempting to stifle this litigation
+through their own delay tactics during discovery. Plaintiffs wish not only to attempt to force
+Epstein to trial without any meaningful discovery, but now wish to ban Epstein from any
+depositions, thereby preventing him from assisting his attorneys in his very own defense. What's
+next - will Plaintiffs seek to prevent Epstein from attending any of the trials that result from the
+lawsuits Jane Does 2-8 have initiated? Plaintiffs see millions of dollars in damages, both
+compensatory and punitive, against Defendant.
+Defendant is filing this emergency motion and his immediate response to the
+motion for protective order to guarantee his right to be present and assist counsel in deposing not
+only Jane Doe No. 4, but other plaintiffs and witnesses in these cases. To hold otherwise would
+violate Epstein's due process rights to defend the very allegations Plaintiffs have alleged against
+him. Does a Defendant not have a right to be present at depositions or other court proceedings to
+assist counsel with the defense of his case? Does a Defendant, no matter what the charges or the
+allegations, have full and unbridled access to the court system and the proceedings it governs,
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 3 of 33
+Page 3
+including discovery? The short answer is unequivocally, yes. To hold otherwise would be a
+direct violation of Epstein's constitutional due process rights. Plaintiffs' attempts to play fast
+and loose with the law should not be tolerated
+As the court is aware, plaintiffs and defendants routinely attend depositions of
+parties and other witnesses in both State and Federal court proceedings. In fact, parties have a
+right under the law to attend such depositions.
+8.
+As the court will note from Exhibit 2, counsel for the Defendant specifically
+stated that "Please be advised that Mr. Epstein plans to be in attendance at the deposition of your
+client. He does not intend to engage in any conversation with your client. However, it is
+certainly his right as a party-defendant in the lawsuit to be present and to assist counsel in the
+defense of any case." Despite this right, Plaintiffs continue to attempt to control how discovery
+is conducted in this case and how this court has historically governed discovery.
+9. Interestingly, in Jane Doe II, the state court case, attorney Sid
+took the
+deposition of the Defendant and his client, Jane Doe Il, was present throughout the deposition.
+This is despite her claims of "emotional trauma" set forth in her complaint. Jane Doe No. Il is
+also a Plaintiff in the federal court proceeding Jane Doe II v. Jeffrey Epstein (Case No. 09-CIV-
+80469). Is this court going to start a precedent where it allows Plaintiffs to attend the depositions
+of Jeffrey Epstein, but not allow Epstein to attend their depositions (i.e., the very Plaintiffs that
+have asserted claims against him for millions of dollars)? This court should not condone such a
+practice.
+10. The undersigned is well aware of the court's No-Contact Order entered on July
+31, 2009 (DE 238). A copy of the order is attached as Exhibit "3". In fact, the order provides
+that the defendant have no direct or indirect contact with the plaintiffs, nor communications with
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 4 of 33
+Page 4
+the plaintiffs either directly or indirectly. However, there is no prohibition against Mr. Epstein's
+attendance at a deposition where, as is reflected in the order, the communication will be made to
+the plaintiff solely through defense counsel with one or more of plaintiffs' counsel of record
+present in the room in a videotaped deposition. Obviously, any inappropriate contact or
+communication will certainly be flagged by the attorneys in attendance. As such, Plaintiffs
+really have the cart before the horse in this instance (i.e., nothing prevents Epstein from attending
+these depositions and, to the extent Plaintiffs believe that something improper occurs at any
+deposition, only then can that circumstance be addressed by a motion such as the instant one.)
+11. Next, Plaintiffs, Jane Does 2-8, attempt to use the Affidavit of Dr. Kliman for
+every motion for protective order/objection filed to date. This also includes the two most recent
+motions, which attempt to prevent Defendant's investigators from doing their job, such that the
+Defendant and his attorneys can defend the claims asserted in these cases. Plaintiffs lose sight of
+the fact that the court, in discussing the Non-Prosecution Agreement, inquired as to whether
+Epstein and his counsel could fully defend the case, which included discovery and investigation.
+All plaintiffs' counsel and the USAO responded in the affirmative. In fact, Plaintiffs universally
+agreed at the June 12, 2009 hearing on Defendant's Motion to Stay that regular discovery could
+proceed. See Composite Exhibit "4" at pages 26-30 & 33-34. For instance, the court asked
+Plaintiffs' attorneys the following questions:
+The Court: [] So again, I just want to make sure that if the cases go forward and
+if Mr. Epstein defends the case as someone ordinarily would defend a case being
+prosecuted against him or her, that that in and of itself is not going to cause him to
+be subject to criminal prosecution? (Ex. "A," p.26).
+***
+The Court: You agree he should be able to take the ordinary steps that a
+defendant in a civil action can take and not be concerned about having to be
+prosecuted? (Ex. "A," p.27).
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 5 of 33
+Page 5
+***
+The Court: Okay. But again, you're in agreement with everyone else so far
+that's spoken on behalf of a plaintiff that defending the case in the normal course
+of conducting discovery and filing motions would not be a breach? (Ex. "A,"
+p.30).
+Mr. Horowitz - counsel for Jane Does 2-7: Subject to your rulings, of course,
+yes. (Ex. "A," p.30).
+***
+The Court: But you're not taking the position that other than possibly doing
+something in litigation which is any other discovery, motion practice,
+investigations that someone would ordinarily do in the course of defending a civil
+case would constitute a violation of the agreement? (Ex. "A," p.34).
+Ms. Villafana: No, your honor. I mean, civil litigation is civil litigation, and
+being able to take discovery is part of what civil litigation is all about.... But....
+Mr. Epstein is entitled to take the deposition of a Plaintiff and to subpoena
+records, etc. (Ex. "A," p.34)
+12. It is clear from the transcript attached as Exhibit "4" that each of the Plaintiffs'
+attorneys, including Mr. Horowitz for Jane Does 2-8, expected and conceded that
+regular/traditional discovery would take place (i.e., discovery, motion practice, depositions,
+requests for records, and investigations).
+Importantly, Plaintiffs' counsel advised the undersigned that they coordinate their
+efforts in joint conference calls at least two times per month. At recent depositions of two
+witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the
+witnesses for approximately six to eight hours, often repeating the same or similar questions that
+had previously been asked.
+14.
+Clearly, the Plaintiffs' counsel wish to control discovery and how the Defendant
+is allowed to obtain information to defend these cases. However, the court has ruled on a
+number of these issues as follows:
+A.
+Plaintiffs' counsels sought to preclude the Defendant from serving third
+party subpoenas and allowing only Plaintiffs' counsel to obtain
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 6 of 33
+Page 6
+depositions and those materials and "filter them" to defense counsel.
+That motion was denied, and the court tailored a method such that the
+Defendant could obtain the records directly.
+B.
+Plaintiffs' counsels sought to limit the psychological psychiatric
+examination in C.M.A. v. Jeffrey Epstein and |
+(Case No. 08-
+CIV-80811), as to time, subject matter and scope. However, Magistrate
+entered an order denying the requested restrictions.
+Other Plaintiffs' attorneys have said that they object to requested
+no need cal be ed, he a see his o or in eage for
+alleged psychological and emotional trauma.
+D.
+E.
+Many Plaintiffs' object to discovery regarding current and past
+employment (although they are seeking loss of income, both in past and
+future).
+All Plaintiffs object to prior sexual history, consensual and forced as
+being irrelevant, although in many of the medical records that are now
+being obtained, as well as the psychiatric exams done by Dr. Kliman,
+there is reference to rape, molestation, abusive relationships (both
+physical and verbal), prior abortions, illegal drugs and alcohol abuse.
+15.
+Clearly, Plaintiffs wish to make allegations; however, they forget that they must
+meet their burden by proving same. Meeting that burden and disproving those allegations is not
+possible if this court allows Plaintiffs to stifle and/or control the discovery process.
+16.
+Specifically, with regard to Jane Doe No. 4, which is the deposition set for next
+week, September 16, 2009, the plaintiff has in her past (see affidavit of Richard C.W. WI
+M.D., an expert psychiatrist retained by Defendant to conduct exams on various claimants.) See
+
+A.
+B.
+C.
+Sought counseling due to a dysfunctional home situation, specifically with
+regard to her father. She described herself as being angry, bitter,
+depressed and having body image problems;
+Had an ex-boyfriend, Preston Vinyard, who was, on information and
+belief, a drug dealer who she lived with;
+Had drug and alcohol problems herself; and
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 7 of 33
+Page 7
+17.
+D.
+Spoke with two psychiatrists when she was sixteen or seventeen (before
+this lawsuit!) and did not reference Epstein, but did reference her
+boyfriend and family issues.
+There are police reports that reflect that:
+A.
+B.
+C.
+In September 2004, a battery report was filed regarding Jane Doe No. 4
+and Vinyard based on an argument where he grabbed her by the neck and
+began spitting on her and calling her a cheater.
+Also in September 2004, there was a domestic violence file opened where
+Vinyard was physically and verbally abusive to Jane Doe No. 4, his
+girlfriend at the time. There is reference that the two started a serious
+relationship in January 2002, when she was only fourteen (14) years old.
+Vinyard was arrested in December 2003, and charged with reckless
+driving and leaving the scene of the accident with Jane Doe No. 4, when
+their vehicle hit a tree and they fled.
+18.
+Moreover, an ex-boyfriend of Jane Doe No. 4 died in a DUI accident and it took
+her two years to get over his death, and another good friend of hers, "Jen," died in an automobile
+accident involving drinking. Within her Amended Complaint and Answers to Interrogatories,
+she indicates that she went to Epstein's house on several occasions. However, at no time did she
+call the police, at no time did she report any traumatic or severe emotional trauma, nor alleged
+coercion, force or improper behavior by Epstein until she got a "lawyer" and is now pursuing
+claims for millions of dollars. Epstein's assistance to his attorneys at these depositions regarding
+the above issues is not only a constitutional due process right afforded to him but essential given
+the fact that this court has ruled that Plaintiffs' depositions can only occur one time, no "second
+bite" absent a court order.
+19. Given the breadth of the allegations made against Epstein and the substantial
+damages sought, Epstein has an unequivocal and constitutional right to be present at any
+deposition such that he can assist his counsel with the defense of these cases. See infra. Dr.
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 8 of 33
+Page 8
+also prepared affidavits regarding Jane Does 2, 3, 5, 6, and 7, which are attached to DE
+247.
+Memorandum Of Law
+20.
+Plaintiffs' motion is required to be denied as they have failed to meet their burden
+showing the "extraordinary circumstances" necessary to establish good cause to support a
+protective order which would grant the extraordinarily rare relief of preventing a named party
+from attending in person the deposition of another named party. Also requiring denial of
+Plaintiffs' motion is the fact that it seeks to exclude Epstein from all the depositions of all the
+Plaintiffs in actions before this Court. Such relief is unprecedented and attempts to have this
+Court look at the Plaintiffs' collectively as opposed to analyzing each case based on facts versus
+broad speculation whether "extraordinary circumstances" exist on a case by case basis. In other
+words, the standard is such that the Court would be required to determine whether each Plaintiff
+has met her burden, should the Court consider adopting such extraordinary relief. On its face,
+the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7.
+Discussion of Law Requiring the Denial of the Requested Protective Order
+Rule 26(c)(1)(E), Fed.R.Civ.P. (2009), governing protective orders, provides in relevant
+part that:
+(1) In General. A party or any person from whom discovery is sought may move for
+a protective order in the court where the action is pending--or as an alternative on
+matters relating to a deposition, in the court for the district where the deposition will
+be taken. The motion must include a certification that the movant has in good faith
+conferred or attempted to confer with other affected parties in an effort to resolve the
+dispute without court action. The court may, for good cause, issue an order to
+protect a party or person from annoyance, embarrassment, oppression, or
+undue burden or expense, including one or more of the following:
+(E) designating the persons who may be present while the discovery is conducted;
+
+
+Case 9:08-CV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 9 of 33
+Page 9
+In seeking to prevent the Defendant from being present in the room where the Plaintiffs
+are being deposed, Plaintiffs generally rely on treatise material from
+r, 8 Federal
+Practice & Procedure Civ.2d, §2041, and cases cited therein. The case of Gaella v. Onassis, 487
+F.2d 986, at 997 (2d Cir. 1973), cited by Plaintiffs, makes clear that the exclusion of a party from
+a deposition "should be ordered rarely indeed." Unlike the Gaella case, there is no showing by
+each of the Plaintiffs that there has been any conduct by Epstein, in rightfully defending the
+actions filed against him, reflecting "an irrepressible intent to continue ... harassment" of any
+Plaintiff or a complete disregard of the judicial process, i.e. prior alleged conduct versus any
+action/conduct displayed in this or other cases that would justify extraordinary relief. There is
+absolutely no basis in the record to indicate that Epstein will act other than properly and with the
+proper decorum at the depositions of the Plaintiffs and abide in all respects with the No-Contact
+Order.
+Wherefore, Epstein respectfully requests that this Court enter an order denying Plaintiffs'
+Motion for Protective Order, provide that Epstein is permitted to attend the depositions of the
+Plaintiffs that have asserted claims against him in the related matters, and for such other and
+further relief as this court deems just and proper.
+Robert D. Crit
+ton, Jr.
+Michael J. Pike
+Attorney for Defendant Epstein
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 10 of 33
+Page 10
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was hand-delivered to the Clerk
+of the Court as required by the Local Rules of the Southern District of Florida and electronically
+mailed to all counsel of record identified on the following Service List on this 11th day of
+September, 2009.
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Brad
+1. Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+ahorowitz@sexabuseattorney.com
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08-
+80232,
+08-80380,
+: 08-80381, 08-80993, 08- Paul G. Cassell, Esq.
+80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No. 08-
+80811
+reelrhw@hotmail.com
+Isidro M. l, Esq.
+|L Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.W, Esq.
+Searcy Denney Scarola Barnhart & Shipley,
+804sel for Plainif in Related Case No. O8.
+P.A.
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 11 of 33
+Page 11
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant I
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold-Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No. 08-
+08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases Nos.
+09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+BY ROBERT D/CRITTON, JR, ESO.
+Florida Bar No. 224162
+rcrit@bclelaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 12 of 33
+CASE NO.: 08-cv-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+RE-NOTICE OF TAKING VIDEOTAPED DEPOSITION
+PLEASE TAKE NOTICE that the undersigned attorney will take the
+videotaped deposition of:
+DEPONENT
+DATE & TIME
+Jane Doe #4
+September 16, 2009
+c/o Mermelstein & Horowitz PA
+at 1:00 PM
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+LOCATION OF
+DEPOSITION
+Prose Court Reporting
+250 Australian Avenue South
+Suite #115
+West Palm Beach, FL 33401
+RobertD. Critton, Jr.
+Attorney for Defendant Epstein
+1
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 13 of 33
+Certificate of Service
+I HEREBY CERTIFY that the foregoing document is being served this day on all
+counsel of record identified on the following Service List in the manner specified by
+electronic mail (e-mail) on this 19" day of August, 2009
+BODERD. CRITTON, J. ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/]
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+1 Esq.
+Rothstein Rosenfeldt Adle
+01 East Las Olas Boulevar
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-Jaw.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069,
+, 08-80119,
+08-80232, 08-80380,
+, 08-80381, 08-80993, Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 14 of 33
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Avenue North
+Suite 404
+Lake Worth, FL 33461
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Counsel for Plaintiff in Related Case No.
+Law Firm, P.A.
+08-80811
+22A Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+sidrogarcia@bellsouth.ne
+Jack P. Esq.
+Counsel for Plaintiff in Related Case No
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+isx@scarcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 15 of 33
+BURMAN, CRITTON
+CLUTTER & COLEMANTE
+YOUR TRUSTED ADVOCATE
+A LIMITED LIABILITY PARTNERSHIP
+J. MICHAEL BURMAN. P.A 17
+GREGORY W. COLEMAN, PA
+ROBERT D. CRITTON, JR, P.A. '
+BERNARD LEBEDEKER
+MARK T. LUTTIER. PA.
+JEFFREY C. PEPIN
+MICHAEL 1. PIKE
+HEATHER MCNAMARA RUDA
+DAVID YAREMA
+'FLORIDA BOARD CERTIFIED CIVIL TRIAL LAWYER.
+ADMITTED TO PRACTICE IN FLORIDA AND COLORADO
+ADELQUI J. BENAVENTE
+PARALEGAL/INVESTIGATOR
+JESSICA CADWELL
+BOBBIE M. MCKENNA
+ASHLIE STOKEN-BARING
+BETTY STOKES
+PARALEGALS
+RITA H. BUDNYK
+OF COUNSEL
+ED RICCI
+ECIAL CONSUM
+STICE COUNS
+August 27, 2009
+Sent by E.Mail and U.S. Mail
+Stuart S. Mermelstein, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd.
+Suite 2218
+Miami, FL 33160
+Re: Jane Doe No. 4 v. Epstein
+Dear Stuart:
+Please be advised that Mr. Epstein plans to be in attendance at the deposition of
+your client. He does not intend to engage in any conversation with your client. However, it
+is certainly his right as a party-defendant in the lawsuit to be present and to assist counsel
+in the defense of any case.
+Cordially fours,
+RDC/clz
+cc: Jack A. Goldberger, Esq.
+2
+303 BANYAN BOULEVARD • SUITE 400 - WEST PALM BEACH, FL 33401 • PHONE: 561-842-2820 • FAX: 561-844-6929 - MAIL@BCLCLAW.COM
+WWW.BCLCLAW.COM
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 16 of 33
+
+CASE NO.: 08-CV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+vs.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+Vs. JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/.
+CASE NO.: 08-CV-80381-MARRA/.
+VS.
+JEFFREY EPSTEIN,
+1
+3
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 17 of 33
+
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/J
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRA/J
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.: 08-80811-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/.
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 18 of 33
+
+Defendants.
+/
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-80591-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09- 80656-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs Jane Doe. No 101 and 102's Motion for
+No-Contact Order (DE 113) and Plaintiffs Jane Does' 2-7 Notice of Joinder in Plaintiffs' Motion
+(DE 145). The Court has reviewed the motions, responses, and replies (DE's 113, 127, 136, 145,
+3
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 19 of 33
+Document 238 Entered on FLSD Docket 07/31/2009 Page 4 of 5
+233), and is otherwise fully advised in the premises. Plaintiffs seek a Court order prohibiting
+Defendant or his agents from communicating with Plaintiffs directly or indirectly. Defendant.
+Defendant opposes the request as "needless, unwarranted and excessive." (DE 127 at 5).
+Nonetheless, Defendant states in his response that "neither Mr. Epstein nor his attorneys, nor
+their agents intend to have any direct or indirect contact with Plaintiffs counsels' clients." (DE
+127 at 4).
+The Court notes that Defendant is already under court order not to have direct or indirect
+contact with any victims. See Transcript of Plea Conference at 20. During the course of
+Defendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah
+Dale Pucillio explicitly instructed Defendant as follows:
+Court: Okay. D is, you shall not have any contact with the victim, are there more
+than one victim?
+Ms. Belohlavek: There's several.
+Court: Several, all of the victims. So this should be plural. I'm making that
+plural. You are not to have any contact direct or indirect, and in this day and age I
+find it necessary to go over exactly what we mean by indirect. By indirect, we
+mean no text messages, no e-mail, no Face Book, no My Space, no telephone
+calls, no voice mails, no messages through carrier pigeon, no messages through
+third parties, no hey would you tell so and so for me, no having a friend,
+acquaintance or stranger approach any of these victims with a message of any sort
+from you, is that clear?
+Defendant: Yes, I
+Id. at 20-21.
+In light of Defendant's response to Plaintiffs' motion for no contact order, suggesting that
+the state court's order only applies to some victims and that parties are always allowed to contact
+each other directly, the Court finds it necessary to state clearly that Defendant is under this
+4
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 20 of 33
+
+court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended
+scope of the state court's order. Accordingly, it is hereby
+ORDERED AND ADJUDGED as follows: Plaintiffs Jane Doe. No 101 and 102's
+Motion for No-Contact Order (DE 113) is GRANTED. Defendant is hereby prohibited from
+communicating with all plaintiffs directly or indirectly, either personally or through agents,
+except that Defendant may communicate with plaintiffs only through plaintiffs' attorneys of
+record, for the duration of this Order.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 31" day of July, 2009
+KENNETH A. MARRA
+United States District Judge
+-
+Copies furnished to:
+all counsel of record
+'See infra, excerpt of Transcript of Plea Conference at 20-21, for examples of indirect
+contact.
+5
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 21 of 33
+1
+2
+3
+4
+5
+WEST PALM BEACH DIVISION
+CASE NO. 08-80119-CIV-MARRA
+WEST PALM BEACH, FLORIDA
+JANE DOE, et al.,
+Plaintiffs,
+JUNE 12, 2009
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+TRANSCRIPT OF MOTION HEARING
+BEFORE THE HONORABLE KENNETH A. MARRA,
+UNITED STATES DISTRICT JUDGE
+APPEARANCES:
+FOR THE PLAINTIFFS:
+ADAM D. HOROWITZ, ESQ.
+Mermelstein & Horowitz
+18205 Biscayne Boulevard
+Miami, FL 33160
+305.931.2200
+For Jane Doe
+J.
+EsQ.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Fort Lauderdale, FL 33301
+Jane Doe 3, 4, 5, 6, 7
+954.522.3456
+ISIDRO M.
+1. ESQ.
+• Elkins Boehringer
+224 Datura Avenue
+West Palm Beach, FL 33401
+Jane DOE II
+561.832.8033
+RICHARD H. WILLITS, ESQ.
+2290 10th Avenue North
+Lake Worth, FL 33461
+FOI C.M.A.
+561.582.7600
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 22 of 33
+26
+1
+THE COURT: That's not my concern. So, again, I just
+2
+want to make sure that if the cases go forward and if
+Mr. Epstein defends the case as someone ordinarily would defend
+4
+a case that's being prosecuted against him or her, that that in
+and of itself is not going to cause him to be subject to
+criminal prosecution.
+MR. JOSEFSBERG: I agree, Your Honor.
+THE COURT: Any other plaintiff's counsel want to
+6
+7
+8
+9 chime in?
+10
+MR. WILLITS: Richard Willits on behalf of C.M.A.. I
+11 would join, to weigh in on what Mr. Josefsberg said.
+12
+MR. JOSEFSBERG: Your Honor, I could not hear.
+13
+THE COURT: We'll get him to a microphone.
+14| Mr. Willits is speaking.
+15
+MR. WILLITS: On behalf of my client, C.M.A., we join
+16| in what Mr. Josefsberg said, and we also want to point out
+17฿
+something to the Court.
+18
+First, we want to make a representation to the Court,
+19 we have no intention of complaining to the U.S. Attorney's
+20
+Office, never had that intention, don't have that intention in
+21
+the future, but, of course, subject to what occurs in the
+22
+future.
+23
+I want to point out to the Court that Mr. Epstein went
+24
+into this situation with his eyes wide open, represented by
+25
+counsel, knowing that civil suits had to be coming. If he
+4
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 23 of 33
+27
+didn't know it, his lawyers knew it.
+2
+He appears to be having second thoughts now about he
+3
+could have negotiated this way or he could have negotiated that
+4' way with the U.S. Attorney's Office. And they want to impose
+their second thoughts on the innocent plaintiffs. We don't
+6
+think that's fair. We think it's in the nature of invited
+error, if there was any error whatsoever.
+8
+Thank you.
+9
+THE COURT: You agree he should be able to take the
+10 ordinary steps that a defendant in a civil action can take and
+11 not be concerned about having to be prosecuted?
+12
+MR. WILLITS: Of course. And we say the same thing
+13| Mr. Josefsberg said. It's all subject to your rulings and the
+14 direction of this Court as to what is proper and what is not
+15 proper. And we're prepared to abide by the rulings of this
+16|
+Court, and we have no intention of running to the State's
+17 Attorney.
+18
+THE COURT: The U.S. Attorney?
+19
+20
+MR. WILLITS: I'm sorry. The U.S. Attorney.
+THE COURT: Mr.
+1.
+21
+MR. MI: Thank you, Your Honor.
+22
+If I may briefly, I think perhaps defense counsel
+23
+forgot about this, but on pages 17 and 19 of my memorandum of
+24
+law in opposition to the motion to dismiss, I did make
+25) reference to the non-prosecution agreement, and I did say that
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 24 of 33
+30
+it, it doesn't relate to our clients.
+2
+THE COURT: Okay. But, again, you're in agreement
+with everyone else so far that's spoken on behalf of a
+4 plaintiff that defending the case in the normal course of
+conducting discovery and filing motions would not be a breach?
+MR. HOROWITZ: Subject to your rulings, of course,
+6
+7
+yes.
+8
+THE COURT: Thank you.
+9
+Anyone else have anything to say from the plaintiffs?
+10
+Ms. Villafana, if you would be so kind as to maybe
+11 help us out. I appreciate the fact that you're here, and I
+12 know you're not a party to these cases and under no obligation
+13 to respond to my inquiries. But as I indicated, it would be
+14 helpful for me to understand the Government's position.
+15
+MS. VILLAFANA: Thank you, Your Honor. And we, of
+16
+course, are always happy to try to help the Court as much as
+17 possible. But we are not a party to any of these lawsuits, and
+18 in some ways we are at a disadvantage because we don't have
+19 access. My access is limited to what's on Pacer. So I don't
+20 really know what positions Mr. Epstein may have taken either in
+21
+correspondence or in discovery responses that aren't filed in
+22
+the case file.
+23
+But your first order was really just what do you think
+24
+about a stay, and then the second order related to this hearing
+25฿
+and asked a much more specific question, which is whether we
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 25 of 33
+34
+we had filed that response. And what we said in the response
+to the motion to stay is that the reason why he wants to stay
+3
+the litigation is so that the non-prosecution agreement
+4 terminates based on a period of time, as he puts it. And then
+5 afterwards he would be able to come in here and make all of
+6
+these arguments that clearly violate the non-prosecution
+7 agreement but we would be without remedy.
+8
+THE COURT: But you're not taking the position that
+9
+other than possibly doing something in litigation which is a
+10 violation of an express provision of the non-prosecution
+11
+12
+agreement, any other discovery, motion practice, investigations
+that someone would ordinarily do in the course of defending a
+13
+civil case would constitute a violation of the agreement?
+14
+MS. VILLAFANA: No, Your Honor. I mean, civil
+15
+litigation is civil litigation, and being able to take
+16
+discovery is part of what civil litigation is about. And while
+17 there may be, for example, if someone were to try to subpoena
+18 the Government, we would obviously resist under statutory
+19| reasons, all that sort of stuff. But, no, MI. Epstein is
+20-
+entitled to take the deposition of a plaintiff and to subpoena
+21 records, etc.
+22
+THE COURT: And even if he seeks discovery from a
+23
+Government agency, you have the right to resist it under the
+24฿
+rules of procedure but that would not constitute a violation,
+25
+again unless there's a provision in the prosecution agreement
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 26 of 33
+Aus Ease 9.054Bv-8017ShRAN. Halocument 247-5
+407-322-8169
+Entered on FLSD Docket 08/05/2009 Page 1 of 8
+Jane Doe #4
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD CW. M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+c.W.|
+, M.D., who, being by me first duly sworn under oath deposes and says:
+I.
+My name is Richard C.W.
+I|, M.D. I am over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 1996.
+3.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Deptof
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+I received my undergraduate degree from the Johns I
+| University and
+1
+5
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 27 of 33
+Aug Case 912HEV-801RBHN. Haloolment 247-5 Entered on FLSD D8CR67 88985/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+6.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7.
+I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #4 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 28 of 33
+Aug GAS9 9484RV-801RBH6ANt, HabaDnent 247-5 Entered on FLSD BeZRE 08995/2009 Page 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #4 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12.
+She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerring Jane Doe #4.
+14. Plaintiff reports a history of alcohol use and an ex-boyfriend who drank
+alcohol and used pills that were "a form of oxycodine [sic] a form of heroine [sic]." (Page
+18, tape 1)
+15.
+Plaintiff reports obtaining a restraining order against her ex-boyfriend, stating
+that he would spit in her face, push her, and was abusive. (Page 20, tape 1)
+16.
+Plaintiff reports talking with two psychiatrists at age 16 or 17 due to family
+3
+
+
+Case 9:08-cV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 29 of 33
+Aug Case 9405cv-80 HindA/d. Helotment 247-5 Entered on FLSD $&cRe 08705/2009 Page 4 of 8
+issues and boyfriend issues. (Pages 2 and 3, tape 3). In the tapes, she makes no mention of
+telling the psychiatrists of her alleged encounters with Epstein. Moreover, while Plaintiff
+denies recruiting other girls, on page 24 of the Palm Beach Police Report, Plaintiff said she
+left a note for Epstein that indicated "for a good time call [Plaintiff] and [friend]" and left
+the girls' phone numbers.
+17. Plaintiff noted that while in high school a friend, Chris, died in a motor
+vehicle accident, that she was in shock from his death, and that she got over it after about 1
+½ to 2 years, but that it still bothers her. (Page 4, GK Contemp notes)
+18. Plaintiff noted that a close friend, Jen, died in a motor vehicle accident and
+that she was in shock for two months. (Page 4, GK Contemp notes)
+19. Plaintiff reported, "I probably went there over 50 times." (Page 3, tape 4)
+20. Plaintiff was arrested at age 17 for DUI on 3/09/05. (Police Offense Report)
+21.
+On 10/31/04, fight occurred between plaintiff and Preston
+in back of
+cab. Plaintiff (age 17) had been drinking. Police were called for theft of cab fare. Upon
+arriving at residence, police found plaintiff in home with no shirt on. Plaintiff refused to
+cooperate with police and threatened to kill herself.
+was arrested for violation of
+protective order. (Police Offense Report)
+22.
+On 2/28/02, plaintiff was charged with shoplifting bras from Burdines and
+was issued a juvenile referral form. (Police Offense Report)
+
+
+Case 9:08-cV-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 30 of 33
+Aug Case 9087EV-801RBHKAN. HEodment 247-5 Entered on FLSD B&CRet 8305/2009 P&ge 5 of 8
+23.
+On 9/21/04, a protective order was filed against Preston
+after an
+incident on 9/20/04 in which he accused her of cheating on him. He then began choking
+her, threw her against a wall, and yelled at plaintiff. He dumped beer on her, threw
+cigarettes in her face, and slammed her into the ground. On a previous incident in August
+2004, plaintiff reported they agued and Mr.
+•grabbed her by her arms and threw
+her to the ground outside her house. Plaintiff noted she was in fear because he has a
+violent history and has verbally threatened her friends, family and herself. (Petition for
+Injunction for Protection)
+24. All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+the impact of specific events, if any, or her current and future level of function.
+25. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+5
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 31 of 33
+Aug Case 9:08pv-801Rgh4ANF. HBoment 247-5
+Entered on FLSD D7REtB985/2009 Page 6 of 8
+importantly, a list of all medical clinical, school and work records known to the attorney
+in the case.
+26.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us."" "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning,
+which our input is requested." We request the same.
+27. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization; including the
+type and character of the alleged assault, and key victim variables such as demographics;
+psychological reactions at the time of the trauma; previous psychiatric or psychological
+history, history of previous victimization; current or previous psychological difficulties;
+general personality dynamics and coping style; sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+6
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 32 of 33
+Aug Case 9:055ev-801Rg4VANf. HelodiPment 247-5
+Entered on FLSD D7CR3784785/2009 Page 7 of 8
+acquaintances or family members; and whether there was any history of indiscriminate
+behavior that may have placed them at increased risk. It is important to know if there had
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+28.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+29. Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+30. Itis, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatric records/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records.
+31.
+These, in essence, are the same or similar records that plaintiff's expert
+witness (Dr. Kliman) feels are essential for him to do an appropriate evaluation. To obtain
+the necessary information, it will be necessary to identify the plaintiff by name. Such
+7
+
+
+Case 9:08-cv-80119-KAM Document 296 Entered on FLSD Docket 09/11/2009 Page 33 of 33
+Aug ease 9.085Bv-801Ri9hRANG. HBodunent 247-5
+Entered on FLSD 8OCR27 86985/2009 Page 8 of 8
+identification will not humiliate the plaintiff since all we are requesting is pertinent
+information as noted above relative to their past medical and psychiatric histories and
+conduct. We would concur and request of the court that the same and/or similar
+information be made available to us to conduct our examination.
+Respectfully submitted,
+whart. Is Hall Mas
+Richard C. W.
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida College of
+Medicine
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+BEFORE ME, the undersigned authority, personally appeared RICHARD C.W.
+| M.D., who is (~ personally known to me or () who has produced
+as identification, and who did take an oath, deposes and says that
+the attached. Affidavit is true and correct to the best of his knowledge and belief.
+SWORN TO AND SUBSCRIBED before me on this 4th day of Auguet 2009.
+Marcis 1 Clyman
+Notary Public
+Comme DD0561004
+Expines 6/B/2010
+Printed Name: HARGIA J. CHAPnAN
+My Commission Expires:
+8
\ No newline at end of file
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@@ -0,0 +1,73 @@
+Case 1:19-cv-09610-PAE-DCF Document 6 Filed 10/21/19
+
+AO 440 (Rev. 06/12) Summons in a Civil Action
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+JANE DOE 17
+Plaintiffs)
+V.
+Darren K. Indyke and Richard D. Kahn, as Joint
+Personal Representatives of the Estate of Jeffrey E.
+Epstein, Nine East 71st Street Corporation, Laurel,
+Inc., Financial Trust Company, Inc., NES, LLC, et al
+Defendant(s)
+Civil Action No.
+)
+SUMMONS IN A CIVIL ACTION
+To: (Defendant's name and address) DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL
+REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, NINE EAST 71st
+STREET CORPORATION, LAUREL, INC., FINANCIAL TRUST COMPANY, INC.,
+NES, LLC, MAPLE, INC., LSJE, LLC, HBRK ASSOCIATES, INC., NAUTILUS, INC.,
+CYPRESS, INC. and JEGE, INC., c/o Troutman Sanders LLP (NYC), 875 Third
+Avenue, New York, NY 10022
+A lawsuit has been filed against you.
+Within 21 days after service of this summons on you (not counting the day you received it) — or 60 days if you
+are the United States or a United States agency, or an officer or employee of the United States described in Fed. R. Civ.
+P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
+the Federal Rules of Civil Procedure. The answer or motion must be served on the plaintiff or plaintiff's attorney,
+whose name and address are: BUZIN LAW, P.C.,111 Broadway, Suite 1204, New York, NY 10006
+WEISMAN, BRODIE, STARR & MARGOLIES, P.A., 1301 N. Federal Highway, Lake
+Worth, FL 33460
+If you fail to respond, judgment by default will be entered against you for the relief demanded in the complaint.
+You also must file your answer or motion with the court.
+CLERK OF COURT
+Date:
+Signature of Clerk or Deputy Clerk
+
+
+Case 1:19-CV-09610-PAE-DCF Document 6 Filed 10/21/19 Page 2 of 2
+AO 440 (Rev. 06/12) Summons in a Civil Action (Page 2)
+Civil Action No.
+PROOF OF SERVICE
+(This section should not be filed with the court unless required by Fed. R. Civ. P. 4 (D))
+This summons for (name of individual and title, if any)
+was received by me on (date)
+• I personally served the summons on the individual at (place)
+on (date)
+; or
+• Ileft the summons at the individual's residence or usual place of abode with (name)
+, a person of suitable age and discretion who resides there,
+on (date)
+, and mailed a copy to the individual's last known address; or
+• I served the summons on (name of individual)
+designated by law to accept service of process on behalf of (name of organization)
+on (date)
+; or
+, who is
+• I returned the summons unexecuted because
+• Other (specify):
+; or
+My fees are $
+for travel and $
+I declare under penalty of perjury that this information is true.
+for services, for a total of $
+0.00
+Date:
+Server's signature
+Printed name and title
+Server's address
+Additional information regarding attempted service, etc:
+Print
+Save As...
+Reset
diff --git a/vision-fixhub/court-01/f723a3cbcdba6efe79ff458300c4a8cd10fe7ff3290bfb4bc0657b41b031b606.receipt.json b/vision-fixhub/court-01/f723a3cbcdba6efe79ff458300c4a8cd10fe7ff3290bfb4bc0657b41b031b606.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e68b7d37b7ec9c5bf6beb533db4b974686171a67
--- /dev/null
+++ b/vision-fixhub/court-01/f723a3cbcdba6efe79ff458300c4a8cd10fe7ff3290bfb4bc0657b41b031b606.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -35,
+  "dataset": "marble-joined",
+  "doc_id": "f723a3cbcdba6efe79ff458300c4a8cd10fe7ff3290bfb4bc0657b41b031b606",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "4732956cc2d65ae143f6ec2f3482edc4607f7c9f32b619e1ac83577b08e6fab9",
+  "output_sha256": "1dce2900b24d9623fdc8707f880a6dcec498c3aa059a4d4431cb76ed13d37e0f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.md b/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.md
new file mode 100644
index 0000000000000000000000000000000000000000..feb5da8dc71f14f6194eb0b6edf2fb6abfc5042b
--- /dev/null
+++ b/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.md
@@ -0,0 +1,32 @@
+Case 1:19-cv-11869-MKV-DCF Document 11-2 Filed 01/13/20 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ANASTASIA DOE,
+Plaintiff,
+Case No. 1:19-CV-11869-AJN
+VS.
+DARREN K. INDYKE AND RICHARD D.
+KAHAN, AS CO-EXECUTORS OF THE ESTATE
+OF JEFFREY E. EPSTEIN,
+ORDER FOR ADMISSION
+PRO HAC VICE
+Defendant.
+The motion of Brittany N.
+to appear Pro Hac Vice in the above-captioned
+action is granted.
+Applicant has declared that she is a member in good standing of the bar of the State of
+Florida; and that her contact information is as follows:
+Applicant Name: Brittany N
+Firm Name:
+Pottinger LLC
+Address: 425 North Andrews Avenue, Suite 2
+City / State / Zip: Fort Lauderdale, Florida 33301
+Telephone / Fax: (954) 524-2820/ (954) 524-2822
+Applicant having requested admission Pro Hac Vice to appear for all purposes as counsel
+for Plaintiff ANASTASIA DOE in the above entitled action;
+IT IS HEREBY ORDERED that the Applicant is admitted to practice Pro Hac Vice in
+the above captioned case in the United States District Court for the Southern District of New
+York. All attorneys appearing before this Court are subject to the Local Rules of this Court,
+including the Rules Governing discipline of attorneys.
+Dated:
+United States District/Magistrate Judge
diff --git a/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.receipt.json b/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..951e9713ebd268a11b7e16c4478ae831043e787f
--- /dev/null
+++ b/vision-fixhub/court-01/f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f73f4b2b90ddd4de62246bd3e58aa5a8a52b2a7a172c63ce1e3cc593c436bab6",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c8cc31e84fb4f47157a656b7aa35ba9a0993cc44a1c106b950daca585e667d58",
+  "output_sha256": "0cbc02fd429e0dda4fdf4d99a32a8e9f0311242876819c64a87a95aaea2775ff",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.md b/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.md
new file mode 100644
index 0000000000000000000000000000000000000000..f3cf2a88f658efff0fb111e75941a40a2b71aa34
--- /dev/null
+++ b/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.md
@@ -0,0 +1,20 @@
+Case 9:08-cv-80119-KAM Document 267-2 Entered on FLSD Docket 08/14/2009 Page 1 of 1
+DECLARATION OF Y.B.
+I, Y.B., state as follows:
+1. My initials are Y.B. I am the sister of Jane Doc No. 4.
+On August 8, 2009, two investigators, one of them whose business card identified
+him as S. Kevin Black, came to my residence in Port St. Lucie, Florida, I answered the door. He
+said he was there to speak with me about my sister, and had some questions for me.
+The investigator first asked me if I knew my sister had brought a civil lawsuit. I
+was unaware that she was involved in a civil lawsuit before Mr. Black so informed me.
+4. My husband then came to the door, and asked the investigator how he found our
+address. We were both upset that he knew our address because we value privacy and keep our
+phone number and address unlisted.
+5.
+Mr. Black then stated that he wanted to tell us "what was going on." I informed
+him that I wanted to speak with my sister first before he said anything further. Mr. Black then
+left the premises, asking me to call him.
+I declare under penalty of perjury the foregoing to be true and correct.
+Dated this 18 day of August.
+_, 2009
+Y.B. '
diff --git a/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.receipt.json b/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..64f41c1e475d2d4c92c1f1fe78ecf5c8f8a0b6c5
--- /dev/null
+++ b/vision-fixhub/court-01/f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f746e99a449c6cfb7186fbdb1aa96cf954c80630d4de2d2b5c6133b2bc99738b",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e2ec76a98307fd05116c5175ea505d86623b12a6981f5444b79d98dfdc3a2866",
+  "output_sha256": "f6e81172787017b0a146df7958eba4803e52075dabbaab0f77e1a6574737e843",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.md b/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.md
new file mode 100644
index 0000000000000000000000000000000000000000..c2af81a5398bcb8c868ef468210703abe74e2e69
--- /dev/null
+++ b/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.md
@@ -0,0 +1,200 @@
+Case 9:08-cv-80119-KAM Document 411 Entered on FLSD Docket 11/16/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/J
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+REPLY TO ROTHSTEIN ROSENFELDT ADLER'S P.A.'S
+RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER
+FOR THE PRESERVATION OF EVIDENCE [DE 4051
+(AS TO JANE DOE v. EPSTEIN CASE NO.: 08-CIV- 80893)
+Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned attorneys,
+hereby files his Reply to Rothstein Rosenfeldt Adler P.A.'s ("RRA") Response to
+Defendant's Emergency Motion for Order for the Preservation of Evidence [DE 405],
+and states:
+It now appears that the Honorable Herbert Stettin (Mr. Stettin") is the
+sole individual, as the Chief Restructuring Officer, in charge of RRA assets, including
+electronic and paper records. There also appears to be no objection to the entry of the
+preservation order consistent with his fiduciary/trustee duties for RRA, although certain
+documents may no longer exist within his possession.
+2.
+Par. 4 of the response reflects that some 40 plus boxes of documents were
+obtained by the Department of Justice from search warrants served on the offices of
+
+
+Case 9:08-cv-80119-KAM Document 411 Entered on FLSD Docket 11/16/2009 Page 2 of 5
+RRA; "it is believed that the Department of Justice also sequestered about (13) boxes of
+documents related to this [Epstein] case." In fact there are three Epstein cases which
+have been brought by the RRA firm, one being in federal court, two in state court. Mr.
+Stettin confirms Defendant's belief that there are serious ethical and potentially criminal
+issues that may impact Plaintiffs' ability to pursue their cases.
+3.
+Unfortunately, time is critical with regard to this case in that there are
+deadlines to Disclose Experts and Exchange Reports by October 29, 2009 (but Plaintiff
+has not seen her expert, has no report and only made herself available for the Defendant's
+exam on November 13, 2009), deposition discovery deadline is November 28, 2009 and
+a calendar call of February 19, 2010 for the February 22, 2010 trial docket. While the
+undersigned understands that Mr. Stettin may be working expeditiously to deal with
+critical and pressing needs of stabilizing the firm, a delay of 45 days for his deposition
+(which has been set in the state court case in the 15" Judicial Circuit Court, Palm Beach
+County, State of Florida, L.M. v. Epstein, Case No. 502008CA028051XXXXMB AB,
+not the case sub-judice) will place his deposition sometime during the first 15 days of
+January, after every pre-trial deadline has expired.
+4.
+If in fact there has been inappropriate and/or illegal conduct associated
+with the prosecution of this case by RRA or any of its attorneys or by the Plaintff herself,
+which might result in sanctions, dismissal or other remedy, Defendant Epstein will be
+severely prejudiced.
+WHEREFORE, Defendant Epstein request that the court's preservation order be
+made permanent, which does not seem inconsistent with Mr. Stettin's position as
+expressed by his lawyers but deny the relief sought for delaying the deposition unless the
+
+
+Case 9:08-cv-80119-KAM Document 411 Entered on FLSD Docket 11/16/2009 Page 3 of 5
+court is disposed to modify the current scheduling deadlines and trial date that exist in
+this case.
+By: _
+Robert D. Critton, Jr..
+Florida Bar #224162
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+ROBERT D./CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Brad
+1 Esq.
+Rothstein Rosenfeldt Adler
+
+
+Case 9:08-cv-80119-KAM Document 411 Entered on FLSD Docket 11/16/2009 Page 4 of 5
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232, 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 B, Room 101
+ichard Horace Willits, B
+Salt Lake City, UI 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10" Avenue North
+801-585-6833 Fax
+Suite 404
+Lake Worth, FL 33461
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M.
+Counsel for Plaintiff in Related Case No.
+_Esq.
+Law Firm, P.A.
+08-80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+Bruce E. Reinhart, P.A
+Nos. 09-80591 and 09-80656
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+
+
+Case 9:08-cv-80119-KAM Document 411 Entered on FLSD Docket 11/16/2009 Page 5 of 5
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Charles H. Lichtman, Esq.
+Isaac Marcushamer, Esq.
+Berger Singerman, P.A.
+350 East Broward Boulevard, 10" Floor
+954-525-9900
+954-523-2872 Fax
+clichtman@bergersingerman.com
+imarcushamer@bergersingerman.com
+Proposed Attorneys for Alleged Debtor
diff --git a/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.receipt.json b/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8b40b1b1250fa3f0dc2553e6211fbe003a53c68e
--- /dev/null
+++ b/vision-fixhub/court-01/f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -60,
+  "dataset": "marble-joined",
+  "doc_id": "f77a992d4a6eadc3c802a11ba7d1c58182ce8c9a40e9aac56b22957ede440088",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "35549ab7c530d0d6de50bdb5c7a1ef7d7fca4055dcd68f488d7a228d657bc6af",
+  "output_sha256": "4163f7996db7baaeeb059e355d467d8c741dc0b703550a083bf471d63d88c555",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.md b/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.md
new file mode 100644
index 0000000000000000000000000000000000000000..1c4c05661833e2f83e3af09dd63fea3e755a11f3
--- /dev/null
+++ b/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.md
@@ -0,0 +1,64 @@
+Case 9:08-cv-80380-KAM Document 27 Entered on FLSD Docket 07/16/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80380-CIV-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER DENYING MOTION TO SEAL
+THIS CAUSE comes before the Court on Defendant Jeffrey Epstein's Motion to File Ex
+Parte and Under Seal, filed July 10, 2008. Defendant seeks to file a Notice of Continued
+Pendency of Federal Criminal Action under seal.' The Court has carefully considered the motion
+and the record and is otherwise fully advised in the premises.
+As stated in the Local Rules for the Southern District of Florida, 'proceedings in
+the United States District Court are public and Court filings are matters of public record." S.D.
+Fla. L.R. 5.4(A). It is well settled that the media and the public in general possess a common-law
+right to inspect and copy judicial records. See Nixon v. Warner Communications, Inc., 435 U.S.
+589, 597 (1978). "The right to inspect and copy records is not absolute, however. As with other
+forms of access, it may interfere with the administration of justice and hence may have to be
+curtailed."
+v. Graddick, 696 F.2d 796, 803 (11th Cir. 1983). This right of access creates
+'All documents filed conventionally shall henceforth be filed directly with the Office of
+the Clerk in West Palm Beach, Florida. The parties shall not file documents conventionally in
+any other division of the Southern District of Florida.
+1
+
+
+Case 9:08-cv-80380-KAM Document 27 Entered on FLSD Docket 07/16/2008 Page 2 of 3
+a presumption in favor of openness of court records, which "must be balanced against any
+competing interest advanced." United States v. Noriega, 752 F. Supp. 1037, 1040 (S.D.
+Fla. 1990). For example, courts may look to see whether the records sought are for illegitimate
+purposes.
+696 F.2d at 803. Likewise, the Court may consider whether "the press has
+already been permitted substantial access to the contents of the records." Id.
+In his motion to seal, Defendant has made no argument as to why his Notice of Continued
+Pendency of Federal Criminal Action should not be made available to the public. Defendant
+states only that he wishes "[t]o avoid disclosure of confidential material." (Def. Mot. 2.) The
+Court finds this justification insufficient to justify keeping this document (filed ex parte) under
+seal. The Court is supported in this conclusion by its decision in a similar case, In re: Jane Doe,
+No. 08-80736-CIV (S.D. Fla. July 11, 2008), in which the Court unsealed, over the objection of
+the United States Attorney, documents containing similar information regarding Defendant's
+criminal plea agreement. Thus, any argument regarding confidentiality is vitiated by the fact that
+information regarding Defendant's criminal plea arrangement is already a matter of public
+record. See, e.g., Sally Apgar, Victims Object to Palm Beach Billionaire's Plea Deal in
+Underage Sex Case, S. Fla. Sun-Sentinel, July 12, 2008. Similarly, Defendant has not justified
+the necessity of filing his Notice ex parte. As such, Defendant's Motion to Seal shall be denied.
+Accordingly, it is ORDERED AND ADJUDGED that Defendant's Motion to File Ex
+Parte and Under Seal is DENIED. The Clerk shall UNSEAL docket entries 25 and 26 and make
+them available for public inspection through CM/ECF at the earliest possible time. Defendant is
+further ORDERED to serve a copy of his Notice on Plaintiff within five (5) days of the date of
+2
+
+
+Case 9:08-cv-80380-KAM Document 27 Entered on FLSD Docket 07/16/2008 Page 3 of 3
+entry of this Order.
+DONE AND ORDERED in
+Florida, this 16" day of July, 2008.
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+3
diff --git a/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.receipt.json b/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..727d892641ef71c645bf81bced69990fafa82f02
--- /dev/null
+++ b/vision-fixhub/court-01/f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "f7b5025532b44aad0cc070e27647a11ab3f3915b4eed7fb1e2875274899a5acd",
+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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diff --git a/vision-fixhub/court-01/f7c6ffa1d240576a35e118c761eb88ae400a04d30433ed71bd11496ae6aa0f32.md b/vision-fixhub/court-01/f7c6ffa1d240576a35e118c761eb88ae400a04d30433ed71bd11496ae6aa0f32.md
new file mode 100644
index 0000000000000000000000000000000000000000..db53d960e3783cd7e01aceaebd81fa7bb992d905
--- /dev/null
+++ b/vision-fixhub/court-01/f7c6ffa1d240576a35e118c761eb88ae400a04d30433ed71bd11496ae6aa0f32.md
@@ -0,0 +1,91 @@
+Case 9:08-cv-80736-KAM Document 37 Entered on FLSD Docket 04/09/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No.: 08-80736-CIV-MARRA/
+JANE DOES #1 and #2,
+Petitioners,
+V.
+UNITED STATES OF AMERICA,
+Respondent.
+NOTICE OF CHANGE OF ADDRESS AND FIRM AFFILIATION
+Attorney l
+, hereby provides this Notice of Change of Address
+and Firm Affiliation, and advises the Court and all parties that he has changed firms but
+will continue as counsel for Plaintiff in the above-styled cause. Plaintiff respectfully
+requests that the Court and all parties to this cause modify their databases to reflect the
+new firm name and the change of address, and further requests that copies of all
+papers, filings, correspondence, notices and other materials relating to the above-styled
+action be directed to him at his new firm. The new information is as follows:
+J.
+1. Esq.
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 542075
+E-mail: bedwards@rra-law.com
+
+
+Case 9:08-cv-80736-KAM Document 37 Entered on FLSD Docket 04/09/2009 Page 2 of 3
+Case No. 08-80736-CIV-MARRA/
+DATED: April 9, 2009
+Respectfully Submitted,
+Plaintiff, by One of Her Counsel,
+ROTHSTEIN ROSENFELDT ADLER
+Las Olas City Centre
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33301
+Telephone (954) 522-3456
+Facsimile (954) 527-8663
+Florida Bar No.: 542075
+E-mail: bedwards@rra-law.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on April 9, 2009, I electronically filed the foregoing
+by CM/ECF or in some other authorized manner for those counsel or parties who are
+not authorized to receive electronically Notices of Electronic Filing.
+S/
+J.
+J.
+2
+
+
+Case 9:08-cv-80736-KAM Document 37 Entered on FLSD Docket 04/09/2009 Page 3 of 3
+Case No. 08-80736-CIV-MARRAJ
+SERVICE LIST
+Jane Does 1 and 2 v. United States
+Case No. 08-80736-CIV-MARRA/
+Attorney for United States
+A.
+Villafaña
+Assistant U.S. Attorney
+U.S. Attorney's Office
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Telephone: (561) 820-8711
+Facsimile: (561) 820-8777
+Attorneys for Plaintiff
+James
+Rothstein Rosenfeldt Adler
+401 East Las Olas Blvd
+Suite 1650
+Ft. Lauderdale, FL 33301
+954-522-3456
+954-527-8663 (fax)
+bedwards@rra-law.com
+Lead Counsel
+Paul G. Cassell
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 (fax)
+cassellp@law.utah.edu
+Pro Hac Vice
+Jay C. Howell
+Jay Howell & Associates PA
+644 Cesery Boulevard
+Suite 250
+Jacksonville, FL 32211
+jay@jayhowell.com
+3
diff --git a/vision-fixhub/court-01/f7c6ffa1d240576a35e118c761eb88ae400a04d30433ed71bd11496ae6aa0f32.receipt.json b/vision-fixhub/court-01/f7c6ffa1d240576a35e118c761eb88ae400a04d30433ed71bd11496ae6aa0f32.receipt.json
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diff --git a/vision-fixhub/court-01/f7d8d358f23887ee7889edb1521b9ba0dea5cd2567f020c93fd7c49bb2ae6261.md b/vision-fixhub/court-01/f7d8d358f23887ee7889edb1521b9ba0dea5cd2567f020c93fd7c49bb2ae6261.md
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@@ -0,0 +1,223 @@
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 1 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+AMENDED COMPLAINT
+Plaintiff, Jane Doe No. 6 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+Parties. Jurisdiction and Venue
+1.
+2.
+minor.
+Jane Doe No. 6 is a citizen and resident of the State of Florida, and is sui juris.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon a
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+4.
+This is an action for damages in excess of $50 million.
+5.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+Additionally, this Court has jurisdiction pursuant to 28 U.S.C. §1331 because
+Plaintiff alleges a claim under the laws of the United States. This Court has supplemental
+-1-
+
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 2 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 2 of 8
+jurisdiction pursuant to 28 U.S.C. §1367(a) over all other claims set forth herein which form part of
+the same case or controversy.
+7.
+This Court has venue of this action pursuant to 28 U.S.C. §§1391(a) and 1391(b) as a
+substantial part of the events or omissions giving rise to the claim occurred in this District.
+Factual Allegations
+At all relevant times, Defendant Jeffrey Epstein ("Epstein") was an adult male,
+approximately 52 years old. Epstein is a financier and money manager with a secret clientele limited
+exclusively to billionaires. He is himself a man of tremendous wealth, power and influence. He
+maintains his principal home in New York and also owns residences in New Mexico, St.
+and Palm Beach, FL. The allegations herein concern Epstein's conduct while at his lavish estate in
+Palm Beach.
+9.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004, Jane Doe, then approximately 13 years old, fell into Epstein's trap
+and became one of his victims.
+10.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St.
+11.
+Epstein's scheme involved the use of young girls to recruit underage girls. These
+underage girls were recruited ostensibly to give a wealthy man a massage for monetary
+compensation in his Palm Beach mansion. Epstein, upon information and belief, generally sought
+out economically disadvantaged underage girls from western Palm Beach County who would be
+enticed by the money being offered - generally $200 to $300 per "massage" session - and who were
+- 2-
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 3 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 3 of 8
+perceived as less likely to complain to authorities or have credibility if allegations of improper
+conduct were made. This was an important element of Epstein's plan.
+12.
+Epstein's plan and scheme reflected a particular pattern and method. The underage
+victim would be brought or directed to Epstein's mansion, where she would be led up a flight of
+stairs to a bedroom that contained a massage table in addition to other furnishings. The girl would
+then find herself alone in the room with Epstein, who would be wearing only a towel. He would
+then remove his towel and lie naked on the massage table, and direct the girl to remove her clothes.
+Epstein would then perform one or more lewd, lascivious and sexual acts, including masturbation.
+13.
+Consistent with the foregoing plan and scheme, when Jane Doe was only 13 years
+old, she was recruited by another girl to give Epstein a massage for monetary compensation. Jane
+was brought to Epstein's mansion in Palm Beach. Once there, she was led up the flight of stairs to
+the room with the massage table. Epstein came into the room and directed Jane to remove her
+clothes and give him a massage. As directed by Epstein, Jane stripped to her underwear. Epstein
+then sexually assaulted Jane during the massage. In addition, Epstein masturbated during the
+massage. Epstein then paid Jane money.
+14.
+As a result of this encounter with Epstein, Jane experienced confusion, shame,
+humiliation and embarrassment, and has suffered severe psychological and emotional injuries.
+COUNTI
+Sexual Assault and Battery
+15.
+16.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+Doe, creating a reasonable fear of imminent peril and sexual assault.
+17.
+Epstein intentionally inflicted harmful or offensive sexual contact on the person of
+- 3-
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 4 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 4 of 8
+Jane Doe.
+18.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+19.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+20.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+COUNT II
+Intentional Infliction of Emotional Distress
+21.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+22.
+23.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+of decency.
+24.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury that caused or were likely to cause Jane Doe's mental or emotional health
+to be significantly impaired.
+25.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+- 4-
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 5 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 5 of 8
+severe emotional distress to Jane Doe.
+26.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff' Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT III
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+27.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+28.
+Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+29.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+30.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §$796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+31.
+32.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+- 5-
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 6 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 6 of 8
+33.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 6 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: February 27, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 6 -
+
+
+Case 9:08-cv-80994-KAM Document 91-1 Entered on FLSD Docket 05/06/2010 Page 7 of 8
+Case 9:08-cv-80994-KAM Document 18 Entered on FLSD Docket 02/27/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+I hereby certify that on February 27, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+/s/ Adam D. Horowitz
+- 7-
+
+
+'Case 9:08-cv-80994-KAM Document 91-1
+Case 9:08-cv-80994-KAM Document 18
+Entered on FLSD Docket 05/06/2010 Page 8 of 8
+Entered on FLSD Docket 02/27/2009 Page 8 of 8
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz.
+- 8-
diff --git a/vision-fixhub/court-01/f7d8d358f23887ee7889edb1521b9ba0dea5cd2567f020c93fd7c49bb2ae6261.receipt.json b/vision-fixhub/court-01/f7d8d358f23887ee7889edb1521b9ba0dea5cd2567f020c93fd7c49bb2ae6261.receipt.json
new file mode 100644
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diff --git a/vision-fixhub/court-01/f8012fe533b0503c2729929d965f3081232a76f0ce5e0f8f5267559307732272.md b/vision-fixhub/court-01/f8012fe533b0503c2729929d965f3081232a76f0ce5e0f8f5267559307732272.md
new file mode 100644
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@@ -0,0 +1,124 @@
+Case 1:19-cv-10577-LJL-DCF Document 45 Filed 04/30/20 Page 1 of 1
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman"
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+April 30, 2020
+VIA ELECTRONIC COURT FILING
+Hon. Alison J. Liman
+United States Courthouse
+500 Pearl Street
+Courtroom 15C
+New York, NY 10007
+Re: Jane Doe 1000, 1:19-cv-10577 (LJL) (DCF)
+Dear Judge Liman:
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of
+Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced action. We write to
+further supplement the Co-Executors' pending motion to dismiss (ECF Doc. 33) with the
+enclosed copy of the Opinion & Order entered today by The Hon. Paul A. Engelmayer in
+another personal injury action against the Co-Executors (Jane Doe 15 v. Darren K. Indyke and
+Richard D. Kahn, as executors of the Estate of Jeffrey E. Epstein, 19-civ-10653 (PAE) (DCF)).
+In His Honor's Opinion & Order, Judge Engelmayer grants the Co-Executors' motion to dismiss
+the plaintiff's punitive damages claim against them as a matter of law on grounds applicable to
+Plaintiff's claim for punitive damages in this action.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+cc: Counsel of Record (via ECF)
+
+
+Case 119106534EDGE Downeh59 F043920 Pag1074
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 15,
+Plaintiff,
+-V-
+DARREN K. INDYKE and RICHARD D. KAHN,
+as Executors of the Estate of Jeffrey E. Epstein,
+Defendants.
+19 Civ. 10653 (PAE)
+ORDER
+PAUL A. ENGELMAYER, District Judge:
+In this diversity action, plaintiff Jane Doe 15 ("Doe")' brings claims of battery, assault,
+and intentional infliction of emotional distress against Darren K. Indyke and Richard D. Kahn, in
+their capacities as co-executors of the estate of Jeffrey Epstein. These claims arise from Doe's
+allegations of sexual trafficking and abuse perpetrated against her by Epstein in 2004, when she
+was age 15. Doe alleges that Doe visited Epstein's Manhattan townhouse in New York City,
+where Epstein's secretary photographed her and groomed her for future sexual exploitation; on
+Epstein's behalf, the secretary later invited Doe to visit Epstein at his ranch in New Mexico, and
+arranged Doe's visit. See Dkt. 1 ("Cmplt.") 11| 2-4, 25-26, 30-37. Epstein's sexual abuse of
+Doe occurred during the visit to the New Mexico ranch that ensued. Id. 19 5-6, 41-69.
+The defendants have filed a partial motion to dismiss, directed solely at Doe's prayer for
+punitive damages. They argue that New Mexico law governs Doe's claims, and that under New
+Mexico law, punitive damages are unavailable in a personal injury action against the personal
+' Doe has been granted leave to proceed pseudonymously. Dkt. 22.
+
+
+Case 11916534EE Downeh59 F043920 PageZ«4
+representative of an estate. See Dkt. 18 (motion); Dkt. 19 (memorandum of law in support);
+Dkt. 34 (reply). Doe opposes that motion. Dkt. 29 (memorandum of law in opposition).
+The Court grants defendants' motion. The Court's analysis substantially tracks the
+analysis in a memorandum and opinion it issued earlier this week granting a motion seeking the
+same relief in another case in which a plaintiff has brought the same personal injury claims
+against the executors arising from sexual abuse Epstein allegedly perpetrated on her. See Mary
+Doe v. Indyke and Kahn, 19 Civ. 10758 (PAE) ("Mary Doe"); see id. Dkt. 38 ("Mary Doe Op.")
+(issued April 28, 2020). The Court here incorporates that decision by reference.
+In Mary Doe, Epstein's abuse was alleged to have occurred in his Manhattan townhouse.
+The Court noted that the New York statute that authorizes personal injury actions against the
+personal representative of the decedent precludes punitive damages in such actions, see Mary
+Doe Op. at 4 (citing New York Estates, Powers and Trusts Law ("EPTL") § 11-3.2(a)(1)), and
+required dismissal of Mary Doe's prayer for such damages, id. at 4-6. The Court rejected Mary
+Doe's counter-arguments: that defendants' motion was premature, id. at 6-7, and improperly
+styled as a motion to dismiss, id. at 7-9, and that the law of the United States Virgin Islands
+("USVI"), where Epstein's estate is being probated, applies, and permits punitive damages
+against an estate in such an action, id. at 9-16. As to the final argument, the Court noted that
+under New York choice-of-law rules, the substantive law of the location of the tortious conduct
+occurred generally applies as to punitive damages, and that there was no reason to depart from
+that rule here, id. at 9-14. In any event, the Court held, it is likely that, as a matter of common
+law, the USVI-like New York, the majority of states, and Restatement (Second) of Torts
+$ 908
+— would not allow imposition of punitive damages on a tortfeasor's estate, id. at 14-16.
+2
+
+
+The parties in this case are represented by the same counsel as in Mary Doe, and make
+substantially the same arguments for and against dismissal. The one variation is that, because
+Epstein's abuse is alleged to have occurred at the New Mexico ranch, defendants argue that New
+Mexico law applies. See Dkt. 19 at 2-6; Dkt. 34 at 5-8. But that, defendants argue, does not
+change the result, because New Mexico common law as announced by the state supreme court,
+like EPTL § 11-3.2(a)(1), bars punitive damages in a personal injury action against a tortfeasor's
+estate. See Jaramillo v. Providence Wash. Ins. Co., 871 P.2d 1343, 1351-52 (N.M. 1994)
+(canvassing laws; noting that "punishment and deterrence are not accomplished by enabling
+recovery of punitive damages from the estate of deceased tortfeasors"; and adopting majority
+rule that "[w]hen the tortfeasor cannot be punished for his culpable behavior, punitive damages
+no longer have the desired effect and, therefore, the victim loses the legal entitlement to recover
+those damages"); see also Barbara R. as next friend of S.R. v.
+No. 03 Civ. 1225 (MCA)
+(WDS), 2006 WL 8443923, at *28 (D.N.M. Sept. 30, 2006) (citing Jaramillo and noting that
+"It Jhe rationale behind this rule is that "to punish the estate ignores the central purpose of
+punitive damages, which is to punish the tortfeasor and to deter him from repeating the wrongful
+act"). Doe, for her part, does not dispute that New Mexico law mirrors New York law. Instead,
+in opposing dismissal, she makes the same three arguments as in Mary Doe.
+The Court again finds punitive damages unavailable as a matter of law and plaintiffs'
+counter-arguments unavailing. As to the third argument, relating to choice of law, unlike in
+Mary Doe, there is indeed room for debate about which jurisdiction's law applies. But the
+debate is between New York (where the grooming process began) and New Mexico (where the
+sexual abuse occurred). And under either state's law, imposition of punitive damages on the
+3
+
+
+Epstein estate is squarely prohibited. Doe does not have any stronger argument than did Mary
+Doe that USVI law applies in her case, or, if it did, that it would permit such damages.
+The Court, accordingly, grants defendants' motion to dismiss the prayer for punitive
+damages. The Clerk of Court is respectfully directed to terminate the motion pending at Dkt. 18.
+SO ORDERED.
+Panl A. Englangu
+Paul A. Engelmayel
+United States District Judge
+Dated: April 30, 2020
+New York, New York
+4
diff --git a/vision-fixhub/court-01/f8012fe533b0503c2729929d965f3081232a76f0ce5e0f8f5267559307732272.receipt.json b/vision-fixhub/court-01/f8012fe533b0503c2729929d965f3081232a76f0ce5e0f8f5267559307732272.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1153e576163ba5ae9ce347218d0f62681a28bbc3
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/f817ebbe76584cf801378526c335328f37ee00adce5261539424018d7989c488.md b/vision-fixhub/court-01/f817ebbe76584cf801378526c335328f37ee00adce5261539424018d7989c488.md
new file mode 100644
index 0000000000000000000000000000000000000000..1311a91673f5ffabef42127e416e1f4b5de5bf6a
--- /dev/null
+++ b/vision-fixhub/court-01/f817ebbe76584cf801378526c335328f37ee00adce5261539424018d7989c488.md
@@ -0,0 +1,248 @@
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 2 of 10
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+CASE NO.: 08- 80993-CIV-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFFS' MEMORANDUM IN OPPOSITION TO EPSTEIN'S MOTION TO
+COMPEL RESPONSE TO FIRST REQUEST TO PRODUCE, OVERRULE
+OBJECTIONS AND FOR AN AWARD OF REASONABLE EXPENSES
+Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this
+Memorandum in Opposition to Epstein's Motion to Compel Response to First Request to
+Produce, Overrule Objections, and for an Award of Reasonable Expenses, and state as follows:
+I.
+Introduction
+Defendant Epstein served a Request for Production, which includes (Request #s 10, 11,
+17 and 18) requests that seek to unearth all recordings and depictions of every instance of sexual
+conduct and activity which each Jane Doe might have engaged and documents evidencing the
+names and contact information of each sexual partner over the past nine years.
+Plaintiffs
+properly objected to these Requests, in that discovery on the sexual history of a childhood abuse
+victim is substantially limited in federal court; "courts should presumptively issue protective
+2
+
+
+Case 9:08-cV-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 3 of 10
+orders barring discovery unless the party seeking discovery makes a showing that the evidence
+sought to be discovered would be relevant under the facts and theories of the particular case and
+cannot be obtained except through discovery." See Fed. R. Evid. 412, Advisory Committee
+Notes to 1994 Amendments, subdivision (c). Defendant has made no such showing in his
+Motion to Compel to overcome this presumption. Accordingly, Defendant's Motion to Compel
+must be denied in its entirety.
+Defendant also seeks in Request #1 "all tax returns and supporting documentation" dating
+back to 2002. Plaintiffs properly objected to this harassing and burdensome request, which is not
+reasonably calculated to lead to admissible evidence in the present sexual abuse case, particularly
+since Plaintiffs are not making a lost wages or lost income claim. Plaintiffs have already
+disclosed their entire employment history and the request at issue is far broader than necessary to
+determine Plaintiffs' employment or earnings history.
+Il.
+Argument
+Initially, it must be brought to the Court's attention that Epstein's request for depictions
+or recordings of the plaintiff engaged in sexual or simulated sexual activity since the year 2000
+includes materials which are unlawful for anyone to possess, particularly a registered sex
+offender such as Epstein. The notion that a registered sex offender is seeking child pornography
+should disturb this Court as much as it irks the Plaintiffs.
+Epstein incorrectly argues that Fed.R.Evid 412 is strictly an evidentiary rule and that
+Rule 26(b) must be read exclusively to determine whether information about an abuse victim's
+sexual history is discoverable. The Rule 412 Advisory Committee Notes, however, instruct that
+Rule 412 affects not only the admissibility of evidence at trial, but must also "inform the
+discovery process." Barta v. City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996). The
+3
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 4 of 10
+Committee Notes state, in relevant part, as follows:
+Courts should presumptively issue protective orders barring
+discovery unless the party seeking discovery makes a showing that
+the evidence sought to be discovered would be relevant under the
+facts and theories of the particular case and cannot be obtained
+except through discovery.
+Nowhere in Defendant's Motion is it explained how or why this presumption should be
+overcome. It is well established under Fed.R.Evid. 412 that a victim's past sexual behavior is
+wholly irrelevant to the credibility of her testimony, and that her prior and subsequent sexual
+activity with third parties has no bearing on the issue of whether she consented to or complied
+with the sexual acts charged. See United States v.
+, 472 F.2d 909, 919 (5th Cir. 1973);
+Virgin Islands v.
+634 F.Supp. 933, 936-37 (D. V.I. 1986) (policy of rule disallowing
+evidence to show character of assault victim; Dept. of Professional Regulation v. Wise, 575
+So.2d 713 (Fla. Ist DCA 1991) (holding that evidence of sexual relations with a person other
+than an accused is not relevant). One commentator has noted that once the identity of persons
+and similarity of circumstances are removed, "probative value all but disappears." See Ordover,
+Admissibility of Patterns of Similar Sexual Conduct: The Unlamented Death of Character for
+Chastity, 63 Cornell L. Rev. 96, 106 (1977). The discovery at issue is not limited to sexual
+contact involving similar circumstances, and is therefore lacking in probative value. Defendant
+fails in his Motion to demonstrate otherwise.
+Defendant's argument that Rule 412 is merely an evidentiary rule that should be
+disregarded in discovery disputes has been routinely rejected in federal courts. See, e.g., Barta v.
+City and County of Honolulu, 169 F.R.D. 132 (D. Haw. 1996) (granting protective order
+pursuant to Rule 412 to prevent a sexual battery and harassment victim from having to disclose
+off-duty sexual contacts with persons other than defendant in discovery); Herron v. Eastern
+4
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 5 of 10
+Industries, Inc., 2007 WL 2781211 (N.D. Fla. Sept. 19, 2007); Gibbons v. Food Lion, Inc., 1999
+WL 33226474 (M.D. Fla. Feb. 19, 1999); P.J. Herchenroeder v. John |
+| Univ. Applied
+Physical Lab, 171 F.RD. 179 (D. Md. 1997) (looking at both Rule 26 and Rule 412 in resolving
+discovery motion);
+v. Zabihi, 166 F.R.D. 500 (D. N.M. 1996) (explaining that
+"[a]lthough the present motion arises in the context of discovery under Rule 26, the Court must
+remain mindful of Rule 412 and its implications); Stalnaker v. Kmart Corp., 1996 WL 397563
+(D. Kan. 1996) (noting that Rule 412 "is applicable and has significance in deciding certain
+discovery motions*).
+As the above-referenced cases make abundantly clear, childhood sexual abuse cases are
+not garden-variety litigation subject to traditional broad discovery concerning a victim's sexual
+history.
+Rule 412 is designed to protect victims of sexual misconduct from undue
+embarrassment and intrusion into their private affairs. See Fed R.Evid. 412. The committee
+notes explain that the Rule is also intended to prevent "sexual stereotyping that is associated with
+public disclosure of intimate sexual details and the infusion of sexual innuendo into the
+factfinding process." Rule 412, Advisory Committee Notes to 1994 Amendments. Common
+sense dictates that requiring a sexual abuse victim to disclose the intimate details and recordings
+sought by Epstein during the discovery process - which then would presumably lead to
+additional discovery of the victim's other sexual partners - would be at least as embarrassing and
+intrusive during the discovery process as it would be if the victim were questioned about these
+facts at trial, if not more. Thus, in order to carry out its purpose, Rule 412 "must inform the
+discovery process" and the Court "must impose certain restriction on discovery to preclude
+inquiry into areas which will clearly fail to satisfy the balancing test" set forth in Rule 412. See
+Barta v. City and County of Honolulu, 169 F.R.D. at 135.
+5
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 6 of 10
+In Barta, the Court confronted this issue in the context of a discovery motion in a civil
+case. 169 F.R.D. at 133. A former employee brought a sexual harassment and battery claim
+against her former employer and individual employees. Id. The defendants asked questions at
+deposition which delved into the plaintiff's sexual conduct outside the workplace. Id. at 134. The
+Court did not allow these questions and wait until trial to determine admissibility. Id. at 135.
+Instead, the Court sustained the plaintiff's objections. Id. The Court based its decision on
+Fed.R.Evid. 412. Id. Although noting that Rule 412 controls the admissibility of evidence, the
+Court explained that it must also apply Rule 412 to "impose certain restrictions on discovery to
+preclude inquiry into areas which will clearly satisfy the balancing test of 412(b)(2)..." Id.
+Thus, the Court concluded that the defendants should not be permitted to inquire into the
+plaintiff's conduct while she was off-duty, outside the workplace, and which did not involve the
+same defendants. The same rationale should apply here. The Defendant should not be permitted
+to seek intimate details and recordings of Plaintiff's sexual conduct throughout her life.
+Defendant attached three Florida state court orders to its Motion, two of which are trial
+court decisions. These cases do not serve as precedent for this Court, and in any event, they are
+not persuasive. Unlike state courts, federal courts must focus on the interplay between
+Fed.R.Evid. 412 and Fed.R.Civ.P. 26(b), and in this regard must be concerned with
+embarrassment to the victim and protection of her privacy. Indeed, it does not appear that an
+analogous argument was made in any of the state court cases relied upon by Defendant.
+Furthermore, the discovery in Balas v. Russo, 703 So.2d 1076 (Fla. 3d DCA 1997) was far
+narrower than that which is at issue here. It was limited to asking plaintiffs for their employment
+history (which admittedly included prostitution), employment records, electronic recording of the
+conduct which was the subject of the complaint, and a description of her damages. 703 So.2d
+6
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 7 of 10
+1077-78. At no time were the plaintiffs in Balas asked to disclose their entire sexually history
+beginning at age 10. Id. Thus, the three state court cases cited in the Motion are not helpful to
+the Defendant, and should not deflect attention from the burden placed on the party in federal
+court seeking discovery of a victim's other sexual contacts.
+With regard to Request #1 for "all tax returns and supporting documentation", the
+Defendant has not (and cannot) show how these documents are conceivably relevant. Plaintiffs
+are not making a claim for lost income or wages. See Exhibit "A". Moreover, Plaintiffs have
+disclosed their entire employment history and agreed to execute authorizations allowing
+Defendant to obtain their employment personnel records. Given the nature of the claim
+involving sexual assault, it is inconceivable how the tax returns, W-2s, and 1099s, and all other
+"supporting documentation" could be relevant. Cases in which the plaintiff has been ordered to
+produce tax returns is limited to situations involving
+transactions or in which the plaintiff is
+seeking to recover lost wages, lost profits, royalty payments, or similar relief. See Bellose v.
+Universal Tile Restoration, 2008 WL 2620735 (S.D. Fla. June 30, 2008); United States v.
+Certain Real Property ,444 F.Supp.2d 1258 (S.D. Fla. 2006). The instant case involving sexual
+assault is readily distinguishable and the mere filing of a lawsuit does not place all of one's
+income and earnings at issue. Further, if it is Plaintiff's employment history or earnings that
+Defendants are seeking to discover, a request for all "supporting documentation" pertaining to
+their tax returns is overbroad and far more burdensome than necessary to acquire this
+information.
+Finally, Defendant's request for attorney's fees and costs is completely unwarranted. The
+present motion and response involve good-faith, timely and well-founded objections by Plaintiffs
+to over-reaching and harassing discovery efforts. Accordingly, Defendant's request for award of
+7
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 8 of 10
+reasonable expenses should be denied.
+Conclusion
+Based on the foregoing, Plaintiffs respectfully request that Defendant's Motion to
+Compel Response to First Request to Produce, Overrule Objections, and for an Award of
+Reasonable Expenses be denied in their entirety.
+Dated: May 6, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+8
+
+
+Case 9:08-cV-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 9 of 10
+CERTIFICATE OF SERVICE
+I hereby certify that on May 6, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+
+
+Case 9:08-cv-80119-KAM Document 94 Entered on FLSD Docket 05/06/2009 Page 10 of 10
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz
+10
diff --git a/vision-fixhub/court-01/f817ebbe76584cf801378526c335328f37ee00adce5261539424018d7989c488.receipt.json b/vision-fixhub/court-01/f817ebbe76584cf801378526c335328f37ee00adce5261539424018d7989c488.receipt.json
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diff --git a/vision-fixhub/court-01/f830d1d3c44de25b5b91a6f50b084f8827855877c1e732010e0e03569cf28e8f.md b/vision-fixhub/court-01/f830d1d3c44de25b5b91a6f50b084f8827855877c1e732010e0e03569cf28e8f.md
new file mode 100644
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@@ -0,0 +1,139 @@
+Case 9:08-cV-80119-KAM Document 322-2 Entered on FLSD Docket 09/23/2009 Page 1 of 5
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/]
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+"2"
+
+
+Case 9:08-cV-80119-KAM Document 322-2 Entered on FLSD Docket 09/23/2009 Page 2 of 5
+
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:08-CV-80119-KAM Document 322-2 Entered on FLSD Docket 09/23/2009 Page 3 of 5
+
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09- 80656-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs Jane Doe. No 101 and 102's Motion for
+No-Contact Order (DE 113) and Plaintiffs Jane Does' 2-7 Notice of Joinder in Plaintiffs' Motion
+(DE 145). The Court has reviewed the motions, responses, and replies (DE's 113, 127, 136, 145,
+3
+
+
+Case 9:08-cv-80119-KAM Document 322-2 Entered on FLSD Docket 09/23/2009 Page 4 of 5
+Case 9:08-cv-80119-KAM Document 238
+Entered on FLSD Docket 07/31/2009 Page 4 of 5
+233), and is otherwise fully advised in the premises. Plaintiffs seek a Court order prohibiting
+Defendant or his agents from communicating with Plaintiffs directly or indirectly. Defendant.
+Defendant opposes the request as "needless, unwarranted and excessive." (DE 127 at 5).
+Nonetheless, Defendant states in his response that "neither Mr. Epstein nor his attorneys, nor
+their agents intend to have any direct or indirect contact with Plaintiffs counsels' clients." (DE
+127 at 4).
+The Court notes that Defendant is already under court order not to have direct or indirect
+contact with any victims. See Transcript of Plea Conference at 20. During the course of
+Defendant's state plea conference of June 30, 2009, Palm Beach Circuit Court Judge Deborah
+Dale Pucillio explicitly instructed Defendant as follows:
+Court: Okay. D is, you shall not have any contact with the victim, are there more
+than one victim?
+Ms. Belohlavek: There's several.
+Court: Several, all of the victims. So this should be plural. I'm making that
+plural. You are not to have any contact direct or indirect, and in this day and age I
+find it necessary to go over exactly what we mean by indirect. By indirect, we
+mean no text messages, no e-mail, no Face Book, no My Space, no telephone
+calls, no voice mails, no messages through carrier pigeon, no messages through
+third parties, no hey would you tell so and so for me, no having a friend,
+acquaintance or stranger approach any of these victims with a message of any sort
+from you, is that clear?
+Defendant: Yes, MI
+Id. at 20-21.
+In light of Defendant's response to Plaintiffs' motion for no contact order, suggesting that
+the state court's order only applies to some victims and that parties are always allowed to contact
+each other directly, the Court finds it necessary to state clearly that Defendant is under this
+4
+
+
+Case 9:08-cv-80119-KAM Document 322-2 Entered on FLSD Docket 09/23/2009 Page 5 of 5
+Case 9:08-cv-80119-KAM Document 238
+Entered on FLSD Docket 07/31/2009 Page 5 of 5
+court's order not to have direct or indirect contact with any plaintiffs, regardless of the intended
+scope of the state court's order. Accordingly, it is hereby
+ORDERED AND ADJUDGED as follows: Plaintiffs Jane Doe. No 101 and 102's
+Motion for No-Contact Order (DE 113) is GRANTED. Defendant is hereby prohibited from
+communicating with all plaintiffs directly or indirectly'
+, either personally or through agents,
+except that Defendant may communicate with plaintiffs only through plaintiffs' attorneys of
+record, for the duration of this Order.
+DONE AND ORDERED in WI
+at West Palm Beach, Palm Beach County,
+Florida, this 31" day of July, 2009
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+'See infra, excerpt of Transcript of Plea Conference at 20-21, for examples of indirect
+contact.
+5
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/f83eee8d6c3bd84923464a782e553c661f790643387e0b5c57f174555a315832.md b/vision-fixhub/court-01/f83eee8d6c3bd84923464a782e553c661f790643387e0b5c57f174555a315832.md
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@@ -0,0 +1,323 @@
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 1 of 8
+PANISH
+SHEA &
+BOYLE
+LLP
+August 20, 2020
+VIA ECE
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl Street
+New York, NY 10007
+Re: Doe v. Indyke, et al., 1:20-cv-000484-JGK-DCF
+Dear Judge Freeman:
+We are writing on behalf of our client, plaintiff Jane Doe, in the above-referenced
+litigation. Earlier today, counsel for the Jeffrey Epstein Estate submitted a letter to the Court
+seeking to cancel the deposition of Darren Indyke scheduled for next week on Wednesday,
+August 26, 2020. This is a date that Mr. Indyke's own counsel selected last month that was
+agreed upon by the parties. Now, however, the Epstein Estate attorneys are raising a myriad of
+excuses to avoid producing Mr. Indyke for his properly noticed deposition.
+Since Mr. Indyke is being deposed in both his personal capacity and as a co-executor of
+the Epstein Estate, we expect him to offer extremely relevant testimony concerning the
+allegations set forth in Plaintiff's complaint. Indeed, we have reason to believe he has firsthand
+knowledge of Jeffrey Epstein's relationship with Plaintiff while she was a minor and even acted
+on Jeffrey Epstein's behalf to communicate with Plaintiff on several occasions. His testimony is
+vital to Plaintiff's case and the Epstein Estate should not be allowed to prevent his deposition
+from going forward.
+And despite counsel for the Epstein Estate representing to this Court that Plaintiff has not
+agreed to only take one deposition of Mr. Indyke, that is untrue. As stated in our emails to
+counsel for the Epstein Estate',
+, we understand that Mr. Indyke is only being produced one time
+for his deposition. And even though the Epstein Estate has still failed to provide Plaintiff with a
+single document or piece of evidence in this case despite sending requests for them over 4
+' We have attached the full and complete email string concerning this issue for the
+Court's review and consideration.
+11111 Santa Monica Boulevard, Suite 700 - Los Angeles, California 90025 - 310.477.1700 phone - 310.477.1699 fax - www.psblaw.com
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71
+Filed 08/20/20
+PARİSA
+SHEA &
+BOYLE,
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+August 20, 2020
+Page 2
+months ago, Plaintiff still intends on proceeding with the deposition next week with or without
+the documents.
+Respectfully submitted,
+PANISH SHEA & BOYLE
+/s/ Robert Glassman
+Robert Glassman
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 3 of 8
+Robert Glassman
+From:
+Sent:
+To:
+Cc:
+Subject:
+Robert Glassman
+Thursday, August 20, 2020 9:38 AM
+'Moskowitz, Bennet J.'
+Metcalfe, Mary |
+Boyle; Andrew Tomback
+RE: Jane Doe, 1:20-cv-00484-JGK-DCF
+; Nathan Werksman; Laura Menninger; Weiner, Daniel H.; Kevin
+Hi Bennet, as I stated on Tuesday, we would still like to proceed with Mr. Indyke's deposition next week even if you still
+haven't given us documents before then. I am sorry if you did not understand that the first time I said it. In that regard,
+please confirm you received the Zoom link we circulated earlier this week for his deposition.
+I'm not sure you correctly stated the chronology of events concerning your proposed confidentiality order and NDA. I
+provided you with my edits to it on August 10—ten days ago. Up until last night, we did not hear from you whether you
+had issues with or were satisfied with them. As Judge Freeman stated, the PO should protect the identity of other
+alleged Epstein/Maxwell minor victims. Other than that, I can't think of any other subject matter that ought to be
+legitimately protected that already isn't in this case. Regarding carving out Mr. Epstein from paragraph 4(a-b), it is my
+understanding that one does not have a right to privacy after death. If I'm wrong about that, I am happy to take a look
+at your authorities to the contrary. (
+Regarding the documents I told you about earlier this week, as I said then, because of the current stay of document
+production in this case, we will produce such materials to you once we are permitted to do so by the Court. But since
+you asked about them, please also answer for us the same questions you asked me last night about the documents
+you've been withholding from us. Specifically:
+How did you obtain them?
+Who did you obtain them from?
+What comprises the documents you have and when did you receive them?
+Why haven't you produced the materials you have to us upon your receipt of them?
+Regarding Mr. Kahn's deposition, we've been requesting dates for his deposition for several weeks now. To date,
+however, you have not provided any to us. With respect to Mr. Kahn testifying in his personal capacity, we would like to
+know to what extent he knew about Mr. Epstein and Ms. Maxwell's criminal enterprise. We would like to know if Mr.
+Epstein had ever told him that he sexually abused and raped my client and other minor victims. I trust you would agree
+that even if Mr. Kahn started working for Mr. Epstein after Mr. Epstein stopped abusing my client that doesn't mean
+Mr. Kahn wouldn't or doesn't know anything about it. Right?
+Regarding the damages computation, we supplemented our response to your interrogatory which was what you wanted
+us to do in your letter to the Court and which was brought up with Judge Freeman at the conference. We separated out
+non-economic damages from punitive damages which is what Judge Freeman ordered and we specified what plaintiff's
+damages are to the Estate of Epstein and Maxwell. Judge Freeman said that if the past and future numbers are the
+same, we wouldn't need to separate them out. Here, the past and future numbers are the same. If, however, you want
+us to copy and paste the same response in a Rule 26 disclosure for you too, let me know and we would be happy to do
+that as well.
+Lastly, but perhaps most pressing, since Ms. Maxwell moved for a complete stay of this case in its entirety, then per the
+Court's Order, " within two business days of the motion's submission, the parties should jointly propose a schedule
+for opposition and reply submissions, and should also inform this Court of their views as to whether the motion
+should (or should not) affect any other deadlines set by this Order." Accordingly, we need to file a proposed briefing
+schedule by end of day tomorrow addressing the Maxwell request for stay. I propose that we have until Thursday,
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 4 of 8
+August 27 to file oppositions and replies by Friday, Sept. 4. I also think the motion should not affect any other
+deadlines set by the Order. Bennet/Mary |
+Laura, please let me know your respective positions on this so we
+can file the joint proposed briefing schedule. Thanks.
+Robert Glassman, Esq.
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: glassman@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipients). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+From: Moskowitz, Bennet J. [mailto:Bennet.Moskowitz@troutman.com]
+Sent: Wednesday, August 19, 2020 7:03 PM
+To: Robert Glassman <glassman@psblaw.com>
+Cc: Metcalfe, Mary <MaryGrace.Metcalfe@troutman.com>; Nathan Werksman <werksman@psblaw.com>; Laura
+Menninger <Imenninger@hmflaw.com>; Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>; Kevin Boyle
+<Boyle@psblaw.com>; Andrew Tomback <ATomback@mclaughlinstern.com>
+Subject: RE: Jane Doe, 1:20-cv-00484-JGK-DCF
+Robert,
+As an initial matter, please clarify your position: if you are able to take Mr. Indyke's deposition next week, which
+would be over our objections (as explained below), are you committing to forgoing a further deposition of him
+following the parties' document productions? This is a yes or no question; and we need to know the answer
+today so we can advise the Court.
+With regard to the confidentiality agreement, we are not the hold up. Rather, we were waiting for input from
+you and Ms. Maxwell, who has now moved for a stay of the lawsuit.
+As you know, we circulated our draft confidentiality agreement on July 15 but only received your edits on
+August 10, a few hours before our meet-and-confer call. As counsel for Ms. Maxwell noted during the call, this
+short turnaround time had not allowed her to discuss your edits with her client. While we all acknowledged
+during our meet and confer that the confidentiality agreement should not be finalized without Ms. Maxwell's
+input, we did in fact raise several objections to your edits to which you still have not yet responded. In
+particular, we raised concerns that you had completely removed paragraphs 19-24, which provide standard
+claw-back provisions. We noted the importance of such a provision and asked you during the call for an
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 5 of 8
+explanation of your edits. We still have not received an answer. We are similarly concerned by your edits to
+paragraph 4, particularly your carving Mr. Epstein out of 4(a-b) and the deletion of 4(d-f) in their
+entirety. Please explain these changes as well. As noted during the call, you have proposed substantial and
+unusual edits, but once we understand the basis for your edits, we will be able to respond more fully.
+Your account of the "documentary evidence" you received from the witnesses you subpoenaed raises many
+questions. If, as you state, the "documentary evidence" was "not produced by these witnesses pursuant to the
+subpoenas," how did you obtain it? Are these witnesses the only individuals from whom you have obtained
+"evidence"? What comprises this "documentary evidence" and from which of the witnesses was it received
+and when? What is the basis for your expectation that "the last of the evidence" was produced to you this
+week? Why didn't you produce the materials to us upon receipt?
+The fact remains that we do not know the universe of materials that has been produced to your client, when it
+was produced, or by whom. Nor have we had the opportunity to examine or review all of the "documentary
+evidence." As a result, you have unduly prejudiced our clients by depriving us of the opportunity to fully
+prepare them for their depositions. Combined with the lack of a finalized confidentiality agreement and your
+continued refusal to answer our questions regarding the topics to be covered by Mr. Indyke in his deposition as
+a Co-Executor, we are not in a position to proceed with Mr. Indyke's deposition next week. Nor does it make
+any sense for the deposition to proceed pending the resolution of Ms. Maxwell's motion to stay this lawsuit,
+which she filed earlier this evening.
+Please let us know today whether you will agree to reschedule Mr. Indyke's deposition. If not, please indicate
+whether you have any basis for refusing beyond the argument that the "date has already been cleared by the
+parties and has been on calendar for some time now."
+With regard to the deposition of Richard Kahn, please provide us with your basis for seeking his deposition in
+his capacity as an individual. As noted, Mr. Kahn did not work with Mr. Epstein until, per your own Complaint,
+six years after the Plaintiff ceased her interaction with Mr. Epstein. We therefore need some guidance about
+what evidence Mr. Kahn could offer in his personal capacity. Per the Court's Order, if we "cannot agree as to
+whether this would be permissible," we will need to set a briefing schedule to address the scope of his
+deposition. Additionally, as we requested, please let us know when your client is available for her deposition.
+With regard to the damages disclosure and as raised in Mary
+email on Friday, to which you still have
+yet to respond, the document you served on August 13 was styled as a supplemental response to the Co-
+Executors' Interrogatories, not a damages disclosure pursuant to Rule 26(a)(1). That document did not
+separate out the computation of damages as required by the Court during our conference on August 5. There
+is no breakdown of the damages according to the type of harm alleged, whether the harm in question is past or
+future, from which of the Defendants these damages are being sought, or the calculations used to arrive at any
+of these numbers. Nor are there any supporting documents, including medical records or actuarial tables,
+supporting your calculations. Please explain your failure to comply with the Court's instructions and remedy
+the deficiencies in accordance with the Court's recent Order.
+Similarly, as raised by Mary |
+on Friday and previously discussed in our deficiency letters and during our
+meet-and-confer call in June, we have yet to receive verifications from Plaintiff for any of her responses and
+supplemental responses to the Co-Executors' interrogatories. Please provide those immediately.
+We have repeatedly tried to resolve our concerns by emails, which you have either ignored or addressed only
+in part. We have also asked for your availability to meet and confer, without receiving any proposed times. In
+addition to providing us with your position today regarding Mr. Indyke's deposition, please let us know when
+you are available to meet-and-confer tomorrow morning on the outstanding issues identified in this email, Mary
+communications from last week, and our two deficiency letters.
+Thank you,
+Bennet
+3
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 6 of 8
+Bennet J. Moskowitz*
+Partner
+troutman pepper
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+*Licensed to practice law in New York and Connecticut
+From: Robert Glassman <glassman @psblaw.com>
+Sent: Tuesday, August 18, 2020 5:58 PM
+To: Moskowitz, Bennet J. <Bennet.Moskowitz@troutman.com>
+Cc: Metcalfe, Mary L
+<MaryGrace.Metcalfe@troutman.com>; Nathan Werksman <werksman@psblaw.com>; Laura
+Menninger <Imenninger@hmflaw.com>; Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>; Kevin Boyle
+<Boyle@psblaw.com>
+Subject: RE: Jane Doe, 1:20-cv-00484-JGK-DCF
+EXTERNAL SENDER
+Hi Bennet,
+Thanks for your email. I am in agreement with your recitation in paragraph 1 of your email concerning the Court's
+8/14/20 Scheduling Order.
+Regarding Mr. Indyke's deposition which is scheduled for August 26, I understand that you will not be producing him
+multiple times for his deposition. I also realize that we may not receive documents from you before that time. Although
+I will note that nothing is stopping us from finalizing your draft PO before that time. The Court gave us until August 26
+to resolve the issue but we can certainly finalize it before then. Right? In this regard, I would welcome your feedback on
+my proposed edits so we can get the ball rolling. But even if we cannot, for whatever reason, get the documents before
+his deposition, we would still like to proceed with it on 8/26 since that date has already been cleared by the parties and
+has been on calendar for some time now. Let me know your thoughts on that.
+Per the Court's 8/14 Order, please also send me some dates for Mr. Kahn's deposition. Like Mr. Indyke, we would like to
+depose him in both his capacity as Co-Executor and in his personal capacity. So I suppose Mr. Tomback will have to be
+involved in the setting of that.
+Additionally, we served you with our amended damages computation on August 13 separating out the punitive damages
+and non-economic damages as ordered by the Court. Please let me know that you got it. Finally, per the Court's Order,
+please be advised that plaintiff previously served Rule 45 subpoenas for the depositions of Juan Alessi, David Rogers and
+Larry Visoski. Notice of such depositions were email served on you on June 30. Although responsive documents were
+not produced by these witnesses pursuant to the subpoenas, we have recently obtained documentary evidence from
+these witnesses through their counsel. Indeed, we received what we expect to be the last of the evidence yesterday. In
+light of the Court's 8/14 Order regarding the current stay of document production in this case, we will produce such
+materials to you once we are permitted to do so by the Court.
+If you would like to discuss any of this further, do not hesitate to call or email me.
+Robert
+Robert Glassman, Esq.
+Panish Shea & Boyle LLP
+11111 Santa Monica Boulevard, Suite 700
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 7 of 8
+Los Angeles, CA 90025
+Tel: (310) 477-1700
+Fax: (310) 477-1699
+Email: glassman@psblaw.com
+Web: www.psblaw.com
+CONFIDENTIALITY NOTICE:
+This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use,
+distribution or disclosure by others is strictly prohibited. If you are not the intended recipient (or authorized to receive for the
+recipient), please contact the sender by reply e-mail or telephone, and delete all copies of this message.
+If you are a potential client, the information you disclose to us by email will be kept in strict confidence and will be protected to the
+full extent of the law. Please be advised, however, that Panish Shea & Boyle LLP and its lawyers do not represent you until you have
+signed a retainer agreement with the firm. Until that time, you are responsible for any statutes of limitations or other deadlines for
+your case or potential case.
+From: Moskowitz, Bennet J. [mailto:Bennet.Moskowitz@troutman.com]
+Sent: Monday, August 17, 2020 4:51 PM
+To: Robert Glassman <glassman@psblaw.com>
+Cc: Metcalfe, Mary/
+<MaryGrace.Metcalfe@troutman.com>; Nathan Werksman <werksman@psblaw.com>; Laura
+Menninger <Imenninger@hmflaw.com>; Weiner, Daniel H. <daniel.weiner@hugheshubbard.com>
+Subject: Jane Doe, 1:20-cv-00484-JGK-DCF
+Hello Robert,
+Per the Court's August 14, 2020 Scheduling Order that hit the docket earlier today, document production in this
+action is now expressly stayed pending the Court's entry of a protective order (Doc. 68, § 2). Moreover, by
+August 26 (the previously noticed date for Mr. Indyke's deposition), the parties are required to make a joint
+proposal to the Court regarding a protective order (Id.). We trust that, absent complete agreement on such
+order, which regrettably seems unlikely based on prior meet-and-confers and your recent proposed edits, the
+Court will then need time to review the parties' respective submissions and rule on the matter. The parties will
+then have one week from the entry of such an order to make their document productions (id.)-something
+which we are prepared to do, as previously discussed. Separately, until this Wednesday, we will not know Ms.
+Maxwell's position on the discovery schedule or whether she plans to move for a partial or complete stay of
+this action (Id. at § 1).
+You have previously indicated that you would like to receive Defendants' respective document productions
+before you depose them. That is understandable. However, we are not willing to make either of the Co-
+Executors available for multiple depositions. Accordingly, we should reschedule Mr. Indyke's deposition until
+Defendants' documents have been produced. We should discuss that date along with dates for your client's
+deposition and the deposition of Mr. Kahn, as Co-Executor. If you still intend to depose Mr. Kahn in his
+personal capacity, please inform him of that and your basis for doing so -- and then he must be part of the
+discussion regarding the timing and sequence of depositions.
+Please confirm at your earliest convenience whether you agree to reschedule Mr. Indyke's deposition. If you
+decline, we will have no choice but to immediately seek the Court's assistance to: (1) compel Plaintiff to
+provide deposition topics insofar as she seeks to depose Mr. Indyke in his capacity as Co-Executor; and (2)
+preclude Plaintiff from pressing ahead with Mr. Indyke's deposition only to later seek another deposition of him
+following Defendants' completion of their document productions. If you decline, please provide us with the
+basis for your decision so as to expedite our raising the issue with the Court.
+Best,
+Bennet
+5
+
+
+Case 1:20-cv-00484-JGK-DCF Document 71 Filed 08/20/20 Page 8 of 8
+Bennet J. Moskowitz*
+Partner
+Direct: 212.704.6087
+bennet.moskowitz@troutman.com
+troutman pepper
+875 Third Avenue
+New York, NY 10022
+troutman.com
+*Licensed to practice law in New York and Connecticut
+A HIGHER COMMITMENT TO CLIENT CARE
+Troutman Sanders and Pepper
+have combined to become Troutman Pepper (Troutman Pepper
+Sanders LLP). Troutman Pepper offers expanded capabilities and practice strengths while continuing to deliver powerful
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@@ -0,0 +1,349 @@
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+EPSTEIN'S RESPONSE IN OPPOSITION TO
+JANE DOE'S MOTIONS FOR PROTECTIVE ORDER BARRING
+SECOND DEPOSITION AND INCORPORATED MOTION TO STRIKE
+Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Response in Opposition to
+Plaintiff's, Jane Doe, Motion for Protective Order Barring Second Day of Deposition ("Motion)
+(DE # 378) and incorporated Motion to Strike Jane Doe's Motion, and states:
+Response in Opposition to Jane Doe's Motion
+Jane Doe's Motion (DE #378) seeks a protective order barring the completion of
+her deposition, which is set for November 13, 2009.!
+2. On September 20, 2009, Epstein began Jane Doe's deposition. While Jane Doe
+states her deposition lasted approximately eight hours (from 9:37 a.m. to 6:10 p.m.), she fails to
+' While Jane Doe's deposition is set for this Friday, November 13, 2009, it will likely be re-set to the week of
+November 16, 2009 as her compulsory medical exam was rescheduled to November 13, 2009. Jane Doe is
+epresented by the law firm Rothstein, Rosenfeldt & Adler ("RRA"), which as been in the news regarding allege
+llegal and unethical conduct regarding investments in settlements/cases. Brac
+, Esq. of RRA asked to
+reschedule the pending compulsory medical exams of his three clients, Jane Doe and two state court Plaintiffs, LM
+and EW, which were originally set for November 9, 10 and 11, respectively. Epstein's counsel agreed to reset the
+exams. Jane Doe's compulsory medical exam is now scheduled for November 13, 2009. Nevertheless, as Jane
+Doe's deposition will most likely occur during the week of November 16, 2009, Epstein submits this Motion to
+avoid further delay and since the parties are under specific discovery deadlines and the Court previously denied
+Epstein's Motion for Continuance (DE #187).
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 2 of 9
+Epstein's Response in Opposition to Jane Doe's Motion for Profective Order Barring Second Day of Deposition and
+
+take into account lunch and other breaks. When taking into account the various breaks, Jane Doe
+was actually deposed for 6 hours and 52 minutes.?
+Per the Court's May 14, 2009 Order Consolidating Cases for Purposes of
+Discovery (DE # 98), "Local Rule 26.1 K (limiting deposition time to one day of seven hours) is
+waived so as to allow each party an adequate opportunity to develop fully the record as it may
+relate to that party."
+4.
+Jane Doe is seeking in excess of $50,000,000 in damages in this case, primarily to
+"hurt Jeffrey Epstein." See 9/20/09 Deposition Transcript of Jane Doe ("JD Depo") at 421. Yet
+Jane Doe admitted that Epstein never threatened her, never used physical force, never restrained
+her and never provided her with drugs or alcohol. See JD Depo at 322. Moreover, Jane Doe did
+not give or receive oral sex from Mr. Epstein, did not engage in anal or vaginal sex with Mr.
+Epstein. See JD Depo at 312-13.
+5.
+When counsel for Epstein adjourned Jane Doe's deposition, he attempted to
+coordinate the completion of her deposition, which he estimated would take approximately three
+hours. But Jane Doe's counsel opposed additional time and took the position that the Court's
+Order (DE #98) only waived the seven-hour time limit in instances where multiple Plaintiffs'
+attorneys are questioning the witness. See Excerpts of JD Depo at 426-429, attached as Exhibit
+A.
+In adjourning Jane Doe's deposition, counsel for Epstein noted that he intended to
+cover the following topics in the completion of Jane Doe's deposition, which he estimated would
+take approximately two and a half to three hours:
+a. Background information not disclosed in answers to interrogatories and
+family background information. See Exhibit A at 427;
+" Counsel for Epstein confirmed the actual time with the court reporter.
+
+
+Case 9:08-cV-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 3 of 9
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+b. The details of each time Jane Doe went to Mr. Epstein's house, which was
+not addressed at her September 20, 2009 deposition. Counsel for Mr.
+Epstein only had time to question Jane Doe generally about her visits to
+Mr. Epstein's house. Id. at 426-27,
+c. The various counts of the complaint, separate and apart from the
+allegations of the various visits. Id;
+d. Jane Doe's knowledge of other witnesses/Plaintiffs, including LM and
+EW, also clients of Brad
+Esq. Id. at 427; and
+e. School records and medical records, including Milton School, Planned
+Parenthood, St. Mary's Medical Center, Wellington Regional Hospital,
+and Pace Center for Girls. Id;
+7.
+Epstein is also entitled to depose Jane Doe regarding her past sexual history, an
+opportunity he did not have when he began her deposition since the Court had not ruled on
+Epstein's Motion to Compel (DE #s 67 & 68), which sought information related to Plaintiffs'
+past sexual history. Jane Doe's counsel instructed her not to answer any questions "relate[ed] to
+sexual partners' names or sexual positions". See Exhibit A at 162 - 170.
+8.
+However, on October 29, 2009, the Court granted Epstein's Motions to Compel
+(DE #s 67 & 68) related to Plaintiffs' past sexual history. In its Order (DE #377), the Court
+poignantly acknowledged, "[u]nder the circumstances of this case, where Plaintiff has alleged
+that Epstein ... 'sexually assault her' ... Plaintiff has put the nature of her claimed injuries and
+source and extent of her damages at issue, such that Epstein is entitled to discover evidence
+which would show the nature of Plaintiff's relationship with males, whether she has suffered
+other acts of sexual misconduct as alleged in her Complaint, and whether she suffered injury
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 4 of 9
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+and/or damages as a result of the other claimed sexual misconduct with males." See DE #377 at
+9.
+The Court went on, "the requests at issue go to the very heart of Plaintiff's
+damage claims, requesting not only general information relating to Plaintiff's sexual history, but
+inquiring as to specific instances wherein Plaintiff received compensation or consideration for
+sex acts, claim other males sexually assaulted ... her, and/or claim other males committed lewd
+or lascivious acts on her. As a global matter, Plaintiffs clearly and unequivocally place their
+sexual history at issue by their allegations.... To deny Epstein this discovery, would be
+tantamount to barring him from mounting a defense." See DE #377 at 10 (emphasis added).
+10.
+Moreover, there are a myriad of relevant issues that cannot not be adequately
+covered in seven hours, such as Jane Doe's drug use (see JD Depo at 83-85), her employment at
+strip clubs (id. at 272; 304), numerous incidents of violence and drug use in her home (id. at 191-
+94; 232; 361-63), running away from home (id. at 188-90; 232, the murder of Joey Torres by her
+father, her witnessing her father physically abuse Joey prior to his death and the psychological
+effect it had on Jane Doe, including post-traumatic stress disorder, which she is also claiming in
+this case (id. at 150; 193-94; 232; 361-63).
+11.
+Jane Doe is also a witness to other related cases and testified she was friends with
+LM and EW, Plaintiffs in companion state court cases. See JD Depo at 26.
+12. Next, Jane Doe improperly refused to answer questions regarding her address,
+other persons living with her and the identity of her landlord. See JD Depo at 77-79; 265-66;
+302. Her attorney plainly said "[glo to the Court to get [the] information." Id. at 79. She also
+admitted to lying under oath in a deposition as well as a court proceeding (id. at 182-83) and
+testified that the father of her child was a cocaine dealer (id. at 299). Based on Jane Doe's
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 5 of 9
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+eventful past history and the multitude of relevant issues, deposing her for an additional three
+hours is clearly warranted under the circumstances.
+13.
+Indeed, in its Order denying Plaintiff's, C.M.A., Motion for Protective Order (DE
+#289) requesting the Court limit her independent psychological/psychiatric medical examination
+to six hours and to prohibit repeated questions regarding Plaintiff's medical history, psychiatric
+history, sexual history, social history, sexual abuse history and substance abuse history, the Court
+noted that Plaintiff is seeking millions of dollars in personal injury damages and that "full
+knowledge of Plaintiff's past and present medical, psychological, familial and social histories is
+essential." See DE # 289 at 4. The Court therefore allowed eight hours, the full amount of time
+requested by Epstein's expert, to conduct the examination. Moreover, with respect to Plaintiff's
+motion to limited repeated questions, "the Court agree[d] with Defendant that to restrict the
+number of times defense counsel may ask Plaintiff personal and sensitive questions concerning
+some of the pivotal issues in this case would work an injustice by preventing Defendant from
+being able to defend himself." See DE # 289 at 5.
+14. Epstein simply requests an additional three hours to complete Jane Doe's
+deposition. Given that Jane Doe's counsel instructed her not to answer crucial questions related
+to her past sexual history, and considering the Court recently ruled this information is not only
+discoverable, but goes to the heart of Plaintiff's damages, Epstein should be permitted three
+hours to finish Jane Doe's deposition.
+15.
+Although the Court waived the seven hour time limit in S.D. Fla. L.R. 26.1 K
+(also found in Fed. R. Civ. P. 30(d)), Osborne v. Columbia Helicopters, Inc., 2009 WL 2215076
+(S.D. W. Va. 2009) is illustrative and supports Epstein's request for additional time to depose
+Plaintiffs. In Osborne, a personal injury case, the defendant requested additional time to depose
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 6 of 9
+Jane Doe No. 2.v. Epstein
+Case No. 08-CIV-80119-MARRAL
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+the plaintiff because the plaintiff testified to prior injuries, employers, medical providers and
+witnesses which were not included in his written discovery responses. Id. *2. In granting the
+defendant an additional 1 day of 7 hours to depose the plaintiff, the court reasoned that because
+the plaintiff provided incomplete written discovery responses, the defendant "did not have a full
+opportunity to examine Mr. Osborne respecting all of the information which might
+properly be considered in his discovery deposition." Id. *5 (emphasis added).
+16.
+Just like the defendant in Osborne, Epstein has not had a full opportunity to
+examine Jane Doe as to all information which might properly be considered in her deposition
+such as information not disclosed in her interrogatories and since she refused to answers
+questions, both in her deposition and in response to written discovery, regarding her past sexual
+history.
+17. Per the Court's Order (DE #377), Epstein is entitled to discover information
+regarding Jane Doe's past sexual history. If the Court were to grant Jane Doe's Motion, it would
+essentially be punishing Epstein for timely proceeding with discovery while his Motions to
+Compel (DE #s 67 & 68) related to past sexual history were still pending, which Epstein was
+required to do because the Court denied an earlier motion for continuance (DE # 187) and said in
+essence, do your discovery. Granting Jane Doe's Motion would also allow her to circumvent the
+Court's Order (DE #377) by denying Epstein the opportunity to obtain discovery that is central
+to the defense of this and other cases.
+18.
+Accordingly, the Court should deny Jane Doe's Motion (DE #378) and permit
+Epstein an additional three hours to complete Jane Doe's deposition.
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 7 of 9
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+Motion to Strike Jane Doe's Motion
+19.
+As a threshold matter, the Court should strike Jane Doe's Motion for failure to
+comply with the Court's August 11, 2009 Order (DE # 263). Specifically, the Order provides,
+"[hereinafter, all motions and other court filings that relate to discovery ... shall be styled
+consistent with the styling of this Order... Any motions styled incorrectly or filed in multiple
+cases will be stricken from the docket for failure to follow the Court's Order." See DE # 263.
+20.
+Jane Doe's Motion (DE # 378), which is a motion for protective order and
+therefore "relate[d] to discovery," is clearly styled incorrectly and is not consistent with the
+styling of the Court's August 11, 2009 Order (DE #263). Accordingly, the Court should strike
+Jane Doe's Motion.
+WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests the Court strike
+Jane Doe's Motion (DE #378) for failure to comply with the Court's August 11, 2009 Order (DE
+#263) or, alternatively, deny Jane Doe's Motion (DE #378) and permit an additional three hours
+for the completion of Jane Doe's deposition and grant any additional relief the Court deems just
+and proper.
+By: —
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 8 of 9
+Case No. 08-CIV-80119-MARRA/]
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CM/ECF on this 12th day of November, 2009
+Respectfully submitted,
+By: _
+• CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+BURMAN, CRITTON, LUTTIER & COLEMAN
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/253-0164 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No. 08-
+ahorowitz@sexabuseattorney.com
+80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, 08- Paul G. Cassell, Esq.
+80232,
+08-80380, 08-80381, 08-80993, 08- Pro Hac Vice
+80994
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Isidro M. |
+, Esq.
+
+
+Case 9:08-cv-80119-KAM Document 403 Entered on FLSD Docket 11/12/2009 Page 9 of 9
+Case No. 08-CIV-80119-MARRA/
+Epstein's Response in Opposition to Jane Doe's Motion for Protective Order Barring Second Day of Deposition and
+
+Counsel for Plaintiff in Related Case No. 08-
+_ Law Firm, P.A.
+80811
+224 Datura Street, Suite 900
+reelrhw@hotmail.com
+West Palm Beach, FL 33401
+561-832-7732
+Jack Scarola, Esq.
+561-832-7137 F
+Jack P.
+,, Esq.
+isidrogarcia @bellsouth.net
+Searcy Denney Scarola Barnhart & Shipley,
+Counsel for Plaintiff in Related Case No. 08-
+P.A.
+80469
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff. C.M.A.
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+Bruce Reinhart, Esq.
+rjosefsberg@podhurst.com
+Bruce E. Reinhart, P.A.
+kezell@podhurst.com
+250 S. Australian Avenue
+Counsel for Plaintiffs in Related Cases Nos.
+Suite 1400
+09-80591 and 09-80656
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Theodore J. Leopold, Esq.
+561-659-8300
+Spencer T. Kuvin, Esq.
+Fax: 561-835-8691
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-
+08804
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f85c67a1a8a92f53c4e5ff6ca3dfc8177c15cf22bed5e98ace2982b01c014208.receipt.json b/vision-fixhub/court-01/f85c67a1a8a92f53c4e5ff6ca3dfc8177c15cf22bed5e98ace2982b01c014208.receipt.json
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diff --git a/vision-fixhub/court-01/f864d086daa390d6c8b0f6740c926b697ee2895907b02fd13851465682265eed.md b/vision-fixhub/court-01/f864d086daa390d6c8b0f6740c926b697ee2895907b02fd13851465682265eed.md
new file mode 100644
index 0000000000000000000000000000000000000000..a1659d4e72bf365f088dc421a308788a8e4d8361
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+++ b/vision-fixhub/court-01/f864d086daa390d6c8b0f6740c926b697ee2895907b02fd13851465682265eed.md
@@ -0,0 +1,104 @@
+Case 9:08-cv-80736-KAM Document 177 Entered on FLSD Docket 06/06/2012 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+MOTION TO STRIKE NOTICE OF SUPPLEMENTAL AUTHORITY
+This is a motion by limited intervenors Jeffrey Epstein and attorneys Black, Weinberg, and
+Lefkowitz, to strike the plaintiffs' notice of supplemental authority [DE 173] because the "authority"
+cited by the plaintiffs — a comment by attorney Tonja Haddad to attorney Jack Scarola - is neither
+pertinent, significant, nor authoritative to the issues before this Court. Ms. Haddad's comment to
+Mr. Scarola does not pertain to plea negotiations and therefore her comment is irrelevant.
+The facts leading up to Ms. Haddad's comment are these: In a separate civil proceeding, Mr.
+Epstein has sued attorney
+in state court for abuse of process. Jeffrey Epstein is
+represented in that state civil action by Tonja Haddad; Mr. |
+is represented by Jack Scarola.
+The email that the plaintiffs Jane Doe 1 and Jane Doe 2 have asked this Court to consider as
+supplemental "authority" is an exchange between the lawyers Tonja Haddad and Jack Scarola
+concerning a motion to compel discovery that was granted by the state court in the civil case. The
+entire exchange between the two attorneys, the motion to compel, and the order granting the motion
+are attached as EXHIBIT A.
+Among other things, the discovery that was compelled by the state court required that Mr.
+
+
+Case 9:08-cv-80736-KAM Document 177 Entered on FLSD Docket 06/06/2012 Page 2 of 4
+Scarola, on behalf of his client attorney
+, produce all emails and correspondence
+between Mr.
+and the U.S. Attorney's Office or the State Attorney's Office (and other law
+enforcement agencies) regarding or mentioning Jeffrey Epstein. Among other things, the emails
+involve Mr.
+efforts to have Jeffrey Epstein investigated and indicted.
+After the motion to compel was granted, Mr. Scarola complained to Ms. Haddad that emails
+between
+and prosecutors could be privileged. Ms. Haddad responded that such
+communications between
+and the government could not be privileged under any theory.
+The plaintiffs Jane Doe 1 and Jane Doe 2 now claim that this statement by Ms. Haddad is somehow
+supplemental "authority" and relevant to the legal issues pending before this Court concerning plea
+negotiations. This is absurd.
+The issues raised by Mr. Epstein and the intervening attorneys before this Court involve the
+confidential and privileged nature of plea negotiations between attorneys representing Epstein and
+government prosecutors. Mr. Epstein and the intervening attorneys argue in this Court that the
+communications between the lawyers and the government are privileged and confidential because
+they involve plea negotiations engaged in by the lawyers representing Epstein and the prosecutors
+looking to indict him.
+The emails between
+and the U.S. Attorney's Office or the State Attorney's
+Office are not about plea negotiations.
+does not represent Jeffrey Epstein. He did
+not communicate with any prosecutor at the U.S. Attorney's Office or the State Attorney's Office
+for the purposes of resolving or mitigating any potential criminal exposure of Jeffrey Epstein. On
+the contrary,
+communicated with the government for the purposes of harming Mr.
+Epstein. Ms. Haddad's comment about the non-privileged nature of emails between
+2
+
+
+Case 9:08-cv-80736-KAM Document 177 Entered on FLSD Docket 06/06/2012 Page 3 of 4
+and the government is not supplemental "authority" in this case.
+While there is no local rule or rule of civil procedure addressing the filing of supplemental
+authority in the district courts, Federal Rule of Appellate Procedure 28(j) requires that supplemental
+authority be "pertinent and significant," as follows:
+() Citation of Supplemental Authorities. If pertinent and significant authorities
+come to a party's attention after the party's brief has been filed - or after oral
+argument but before decision - a party may promptly advise the circuit clerk by letter,
+with a copy to all other parties, setting forth the citations. The letter must state the
+reasons for the supplemental citations, referring either to the page of the brief or to
+a point argued orally. The body of the letter must not exceed 350 words. Any
+response must be made promptly and must be similarly limited.
+FED. R. APP. P. 28(j).
+Ms. Haddad's comment to Mr. Scarola that
+emails with the government
+about Jeffrey Epstein are not privileged is neither pertinent, significant, nor authoritative to the plea
+negotiation issues before this Court. Indeed, Ms. Haddad's comment is irrelevant to the legal issues
+under consideration here. Accordingly, the Court should strike the plaintiffs' notice of supplemental
+authority or refuse to consider it.
+3
+
+
+Case 9:08-cv-80736-KAM Document 177 Entered on FLSD Docket 06/06/2012 Page 4 of 4
+We certify that on June 6, 2012, the foregoing document was filed electronically with the
+Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office: (305) 371-6421
+Fax: (305) 358-2006
+By
+/S/
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+JACKIE PERCZEK, ESQ.
+Florida Bar No. 0042201
+On Behalf of Limited Intervenors Jeffrey Epstein
+And Attorneys Black, Weinberg, and Lefkowitz
+4
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diff --git a/vision-fixhub/court-01/f88311fee05542ef46557727a9db7f377b0b18d124785e0ccd76adb4ccb1e745.md b/vision-fixhub/court-01/f88311fee05542ef46557727a9db7f377b0b18d124785e0ccd76adb4ccb1e745.md
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@@ -0,0 +1,45 @@
+Case 9:08-cv-80736-KAM Document 175 Entered on FLSD Docket 05/23/2012 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+LIMITED INTERVENORS JEFFREY EPSTEIN AND BLACK, WEINBERG &
+LEFKOWITZ'S UNOPPOSED MOTION FoR EXTENSION OF TIME To
+RESPOND To PLAINTIFFS' NOTICE OF SUPPLEMENTAL AUTHORITY
+This motion is unopposed and seeks until June 8, 2012 for limited intervenors Jeffrey Epstein
+and the attorneys Black, Weinberg, and Lefkowitz, to file an objection to the notice of supplemental
+authority filed by the plaintiffs yesterday [DE 173].
+Plaintiffs' notice of supplemental authority relies on an email written by attorney Tonja
+Haddad. Undersigned counsel Jackie Perczek has communicated with Ms. Haddad, who stated that
+she is out of town until next Tuesday and that she cannot provide us with the context and background
+of her email until she returns from her travels. Without an opportunity to speak with Ms. Haddad
+and obtain information from her concerning that email, we are not able to file a meaningful response
+or objection to the plaintiffs' notice. For this reason, we request until June 8, 2012 to file our papers.
+Undersigned emailed with Paul Cassell, counsel for the plaintiffs, who stated that he does not object
+to the June 8, 2012 date.
+
+
+Case 9:08-cv-80736-KAM Document 175 Entered on FLSD Docket 05/23/2012 Page 2 of 2
+We certify that on May 23, 2012, the foregoing document was filed electronically with
+the Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office: (305) 371-6421
+Fax: (305) 358-2006
+By
+/S/
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+JACKIE PERCZEK, ESQ.
+Florida Bar No. 0042201
+Counsel for Jeffrey Epstein
+Counsel for Black, Weinberg, and Lefkowitz
+2
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+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 1 of 54
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+In re:
+JANE DOE,
+- against -
+INDYKE, et al.,
+:
+Docket #20cv484
+: 1:20-cv-00484-JGK-DCF
+Plaintiff,
+:
+:
+Defendants.
+: New York, New York
+August 5, 2020
+:
+•: TELEPHONE CONFERENCE
+PROCEEDINGS BEFORE
+THE HONORABLE DEBRA C. FREEMAN,
+UNITED STATES MAGISTRATE JUDGE
+APPEARANCES:
+For the Plaintiff:
+For the Defendant
+Ghislaine Maxwell:
+-
+For the Defendant -
+Co-Executors of the
+Estate of Jeffrey E.
+Epstein:
+PARISH SHEA & BOYLE, LLP
+BY: ROBERT GLASSMAN, ESQ.
+NATHAN WERKSMAN, ESQ.
+11111 Santa Monica Blvd., Suite 700
+Los Angeles, California
+90025
+HADDON,
+&
+BY: LAURA MENNINGER, ESQ.
+150 East Tenth Avenue
+Denver, Colorado
+80203
+, PC
+TROUTMAN PEPPER
+SANDERS LLP
+BY: MARY
+METCALFE, ESQ.
+BENNET MOSKOWITZ, ESQ.
+875 Third Avenue
+New York, New York 10022
+Transcription Service: Carole Ludwig, Transcription Services
+155 East Fourth Street #3C
+New York, New York 10009
+Phone:
+(212) 420-0771
+Email: Transcription420@aol.com
+Proceedings recorded by electronic sound recording;
+Transcript produced by transcription service.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20
+
+INDEX
+EXAMINATIONS
+Re-
+Direct
+Cross
+Direct
+Re-
+Cross
+Witness
+None
+Court
+EXHIBITS
+
+Number
+None
+Description
+ID
+In
+Voir
+Dire
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 3 of 54
+1
+2
+3
+THE COURT: So this is Doe versus Indyke,
+20cv484, and this is Judge Freeman, can I have your
+4
+appearances for the record starting with plaintiff.
+5
+MR. ROBERT GLASSMAN: Good morning, Your Honor,
+6 this is Robert Glassman for the plaintiff.
+7
+MR. NATHAN WERKSMAN: Good morning, Your Honor,
+8 Nathan Werksman for plaintiff.
+9
+THE COURT: I'm sorry, same firm?
+10
+MR. WERKSMAN: Yes.
+11
+THE COURT: Okay, I'm not seeing your name on
+12
+the docket, how do you spell your last name?
+13
+MR. WERKSMAN: W-E-R-K-S-M-A-N.
+14
+THE COURT: Okay, who do I have for defendant,
+15
+defendants?
+16
+MS. LAURA MENNINGER: Your Honor, Laura
+17
+Menninger here on behalf of the defendant, Ghislaine
+18 Maxwell.
+19
+THE COURT: Okay. Do I have for the executor?
+20
+METCALFE: Your Honor, this is
+21
+Mary
+Metcalfe of Troutman Pepper on behalf of
+22
+the co-executors. I know that Mr. Moskowitz is
+23
+planning on joining us, he lost power and internet
+24
+during the storm last night and is driving to a place
+25
+where he can get internet and reception. So if it's
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 4 of 54
+1
+4
+2 all right with everyone if we could wait just a couple
+3 of minutes
+for him to join.
+4
+THE COURT: That's fine, I just got off a
+5 conference call where out of four lawyers two had no
+6 power, no internet, no landline service and they were
+7 both out on the street using cell phones trying to
+8 call in and saying we have no access to our files, we
+9 have no access
+to anything. That's usually someone
+10
+dropping off, that beep,
+so let me make sure I still
+11
+have the people I've
+already identified. I have Mr.
+12
+Glassman?
+13
+MR. GLASSMAN: Yes.
+14
+THE COURT: Mr. Werksman?
+15
+16
+MR. WERKSMAN: Here.
+THE COURT: Okay, Ms. Metcalfe?
+17
+MS. METCALFE: I'm here.
+18
+THE COURT: Okay, and I had counsel for Ms.
+19
+Maxwell, Ms. Menninger?
+20
+MS. MENNINGER: Yes, I'm here, Your Honor.
+21
+THE COURT: Okay, I can't actually say who did
+22
+we lose. All right, who just joined?
+23
+MR. BENNET MOSKOWITZ: Hi, this is Bennet
+24 Moskowitz at Iroutman Sanders, can Your Honor hear me?
+25
+THE COURT: I can, I understand you've had a
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 5 of 54
+1
+5
+2 power outage problem?
+MR. MOSKOWITZ: Yes, I actually was already on
+4 the call listening to everyone (indiscernible), I
+5 apologize, my reception is terrible but what was
+6 described is correct, I have, we got hit pretty hard
+7 by this storm and I've been driving along what seems
+8 like the entire Eastern Seaboard to find a place with
+9 consistent cell phone reception.
+10
+THE COURT: Great, okay, we're having fun
+11
+trying to have these conferences today in the
+12
+aftermath of the storm. So I have others who are
+13
+apparently on the call based on the number of
+14
+participants that were identified when I joined. Is
+15
+there anyone else representing a party to the case?
+16 No. Is there anyone on the call who is an attorney in
+17
+one of the other cases involving the Epstein estate?
+18 Okay. Do I have my law clerk,
+?
+19
+THE CLERK: Yes, Judge, I'm here.
+20
+THE COURT: Okay, anyone else from my
+21
+? All right, so who else do I have on this
+22
+call, if you could just let me know who's on, I'd
+23
+appreciate that, do I have any members of the press?
+24
+FEMALE VOICE: Yes, this is Emily
+25
+(indiscernible) --
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 6 of 54
+1
+2
+6
+THE COURT: I'm sorry, you're cutting out.
+FEMALE VOICE: I apologize, Your Honor, I was
+4
+simply identifying myself, this is Emily
+5 (indiscernible) I am a member of the media and I am on
+6 the call.
+7
+THE COURT: Okay, all right, is there anyone
+8 else, I don't actually need all the specific
+9 identifications,
+members of the press, I'll just ask
+10 you to mute your phones. Is there anyone else who does
+11 not fit one of those categories as in a lawyer for the
+12
+parties, a lawyer for or a representative of a party
+13 in another case, someone from my
+or a member
+14
+of the press, or is that everybody? Okay, I'm not
+15 hearing anything so I'm assuming that's who we've got
+16 on this call. That's all fine. You know, if Mr.
+17
+Moskowitz is an important person to have on the call
+18 and if we lose him or if his service is not adequate,
+19 we can adjourn the call in order to be able to have
+20
+everybody to be able
+to participate. We really didn't
+21
+need a pandemic followed by a hurricane to give us two
+22
+separate problems, but the reason that I wanted to
+23
+have the call, aside from the fact that I seem still
+24
+to have the discovery dispute about the damages
+25
+computation, I had gotten this proposed scheduling
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 7 of 54
+1
+7
+2 order
+sent to me late July by Mr. Moskowitz, and it
+3 didn't indicate that it was jointly submitted.
+4 actually, I guess it did, it said it was on behalf of
+5 all parties. But the proposed scheduling order
+6 included discovery from defendant Maxwell and I just
+7 wanted to have counsel for Ms. Maxwell to have a
+8 chance to address the extent to which she's currently
+9 comfortable participating in discovery in the case
+10
+given that there has now been an indictment returned,
+11
+and just to make sure we're all clear on that issue
+12 involving her active participation in the case. So
+13
+those were the two issues, that and then the discovery
+14
+issue involving the computation of damages that I had
+15
+on my agenda. Does anybody have anything else on your
+16 agendas for me?
+17
+MR. GLASSMAN: Your Honor, this is Robert
+18
+Glassman, we still would like to discuss or I should
+19
+say I would still like to discuss with Your Honor the
+20
+fact that we haven't received any documents from the
+21
+estate.
+And after I sent the Court a letter
+22
+addressing some of the discovery issues I was
+23
+forwarded by counsel for the co-executors a draft
+24
+confidentiality agreement and nondisclosure agreement.
+25
+I don't, you know, so I'd like to discuss that. I
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 8 of 54
+1
+8
+2 don't see how the documents that are responsive to our
+3 discovery requests would be covered under that, that
+4 agreement, and so I'm not inclined to sign it, but I'd
+5 like to hear Your Honor's thoughts on it. Because, I
+6 mean the most important thing for us at this juncture is
+7 just to get documents, our discovery is now more than
+8 three months outstanding and we still don't have any
+9 evidence from the co-executors. So I'd like to kind of
+10
+get that moving if we can.
+11
+THE COURT: All right, just to check because
+12 perhaps I am losing my mental capacities here, I did,
+13
+I did indicate I was recording this, right?
+14
+MR. GLASSMAN: Yes.
+15
+MS. METCALFE: Yes, Your Honor.
+16
+THE COURT: Okay, good, okay, I don't want to
+17
+go through this and have forgotten to do that. All
+18
+right, on that last issue about documents from the
+19 estate, is that teed up for me, have you had a full
+20
+good faith conference, have you, and that and
+21
+regarding a protective order, have you gone back and
+22
+forth and is that something where you are stuck in
+23
+your discussions and you need me to pay attention to
+24
+it?
+I don't remember seeing something on that.
+25
+MR. MOSKOWITZ: Your Honor, it's Bennet
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 9 of 54
+1
+9
+2 Moskowitz.
+First, let me just pause and say can you
+3 hear
+me well enough at this moment?
+4
+THE COURT: I can hear you well enough, not
+5 well, but well enough.
+6
+MR. MOSKOWITZ: Okay, this is the first time
+7 I'm hearing that the other side won't sign the
+8 document, in fact, I understood the opposite. So the
+9 answer to your question is a firm no, we have not
+10
+discussed their refusal to sign what has been entered
+11
+in every other case against the executors. And, of
+12
+course, it kind of boggles our minds because this case
+13
+is brought by someone acting through an anonymous
+14
+name. To the extent we produced a single document that
+15
+says the name of this client or other people, that's
+16
+reason alone to have a confidentiality agreement. So,
+17
+yeah, there is still plenty to discuss and, no, the
+18
+meet and confer process has not, if it has started, it
+19
+certainly isn't complete.
+20
+THE COURT: All right, let's take these issues
+21 in turn. Let me start with the question that I had
+22
+about defendant Maxwell's participation in the case in
+23
+light of the changed circumstances on the criminal
+24
+investigation turning into a criminal prosecution. Can
+25
+I hear from the parties as to whether you have been
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 10 of 54
+1
+10
+2 discussing this, whether this jointly proposed
+3 scheduling order
+is, in fact, being jointly proposed
+4 and is acceptable? I just want to make sure before
+I
+5 sign off on that.
+6
+MS. MENNINGER: Your Honor, this is Laura
+7 Menninger on behalf of Ms. Maxwell. We have had some
+8 discussions, at some point counsel for the plaintiff
+9 had indicated the desire to take her deposition in
+10
+this case and I pointed out that she is in custody at
+11|
+the MDC and at this moment in time no one is allowed
+12
+inside of the MDC, myself and her other attorneys
+13 included. And so I was unaware of any ability to take
+14
+a deposition right now. Certainly, obviously, things
+15
+may change over the course of the case and I think we
+16 might need to come back to Your Honor if it's still an
+17
+issue. I believe that our position will be, although I
+18 don't know that it's ripe for today, similar as it was
+19
+in a prior case, that is we would ask in the future,
+20
+Your Honor,
+that her
+responses to interrogatories and
+21
+her deposition be put off so that, you know, if there
+22
+is an ability to answer questions versus asserting her
+23
+Fifth Amendment right in the future in this case, then
+24
+we could address it at that time. But apart from the
+25
+interrogatories and the deposition I think this
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 11 of 54
+1
+11
+2 scheduling order sets forth our joint proposal.
+THE COURT: Well the joint proposal only has
+4 her serving initial disclosures, but it also has a
+5 deadline for the completion of all fact discovery, it
+6 has a
+deadline for serving all document requests and
+7 interrogatories, it doesn't say anything about staying
+8 any responses in
+any way. So there's no stay built
+9 into this for her and the other parties would be
+10
+completely within their rights based on this schedule,
+11
+if I approve it, to be assuming that she would be
+12
+responding to discovery requests and responding to a
+13
+deposition demand, if it's feasible, certainly
+14
+interrogatory responses by the deadline set by the
+15
+rules. And if that's not something that you're
+16
+prepared to do, I think it should be discussed with
+17
+the parties and brought to my attention before I sign
+18
+off on this order.
+19
+I will say for everyone's benefit that it is
+20
+not uncommon for discovery against someone who is
+21
+currently involved as a defendant in a criminal
+22
+prosecution, for discovery to be stayed because of the
+23
+implications
+of the Fifth Amendment invocation in a
+24
+civil case. As I'm sure you know, she could take the
+25
+Fifth in a civil case, and it's very common for
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 12 of 54
+1
+12
+2 criminal defendants to do that, lawyers often urge that
+3 they do, but then there can be an adverse inference from
+4 that in the civil case that can really prejudice her
+5 defense. So I was just surprised that I didn't have any new
+6 application, given that she was actually indicted, and given
+7 that last time around in another case, true, but
+8 nonetheless, I was being told, well, it's only an
+9 investigation, an investigation could go on forever and we
+10
+don't know if she's actually going to be charged with
+11
+anything and so on, and obviously we have a changed
+12
+circumstance.
+13
+So I don't want to argue the case for counsel, but
+14
+I was just surprised that it wasn't coming up and wasn't
+15
+being dealt with and that a prosed schedule was being put in
+16 front of me that did not address it and seemed to gloss over
+17
+the issue. And I would be surprised if the issue doesn't
+18
+come back come time to respond to interrogatories or come
+19
+time for a deposition. Even apart from how easy or difficult
+20
+it is to conduct a deposition while somebody is at the MDC.
+21 Let me hear on plaintiff's side since you're the one I
+22
+assume will want the discovery.
+23
+MR. GLASSMAN: Yeah, thank you, Your Honor, and
+24 again, this is Robert Glassman. We, counsel for Ms.
+25
+Maxwell, for the co-executors, and for us, we've
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 13 of 54
+1
+13
+2 engaged in several emails, we've talked on the phone
+3 about discovery in this case, and, you know, it wasn't
+4 brought up once that, you know, there would be some
+5 kind of stay as to Ms. Maxwell's participation. Ms.
+6 Menninger is correct when she said I did request, you
+7 know, some dates
+for Ms. Maxwell's deposition, and she
+8 advised that it would be very difficult in light of
+9 the circumstances with Ms. Maxwell right now, and it
+10
+really wasn't feasible to take her deposition at this
+11 point. And I, I mean I understand that.
+12
+But this scheduling order that the co-
+13
+executors filed was, you know, as Your Honor pointed
+14
+out, jointly submitted after we discussed and
+15 deliberated over the dates. You know, everyone gave
+16 their input as to what they thought would be realistic
+17
+as far as the dates are concerned. So I, you know, I
+18
+would like, yeah, unless there is now an objection to
+19
+it, I think everyone's, everyone has approved this and
+20
+we're looking forward to it being entered by the
+21
+Court.
+You know, so if there's, however, if there is
+22
+an objection on Ms. Maxwell's side to discovery being
+23
+directed or propounded on her, then I just, I think
+24
+we'd have to --
+25
+THE COURT: All right, I'm not trying to make
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 14 of 54
+1
+14
+2 arguments on behalf of any party, that's the lawyer's
+3 job and not mine,
+it's just that I had Ms. Maxwell as
+4 a defendant previously where an argument was made that there
+5 should be a hold on discovery because of the criminal
+6 investigation. And there were discussions raised at that
+7 time about the fact that it was merely an investigation with
+8 no obvious end in sight. And so I'm just surprised and a
+9 little confused, and if Ms. Maxwell's counsel on her behalf
+10
+is, you know, is jointly making the submission and is
+11
+comfortable with this, then it's all right with me and I'm
+12
+happy to sign off on it. I just didn't want to sign an order
+13
+and then have it all derailed because this issue, which I
+14
+assumed was coming up, you know, would come up after I sign
+15
+the order and throw the whole thing into some uncertainty. I
+16
+would rather find out if this is an issue that is or is not
+17
+being raised. If it's not been raised to date, find out why
+18
+it's not been raised to date. And, you know, I don't really
+19
+need your confidential thinking, I just want to make sure
+20
+that I'm not signing an order only to have you come back in
+21
+30 days and say, you know, we never anticipated that this
+22
+would mean that Ms. Maxwell would be answering
+23
+interrogatories and would be deposed, because that's not
+24
+what this order says.
+25
+So let's, I mean maybe I send you back to talk it
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 15 of 54
+1
+15
+2 over and make sure that you're all in accord, and if you're
+3 not I'll decide the issue. Or I could just sign off on the
+4 order now and wait and see what happens, you know, but I
+5 would just be rather stunned if already having raised the
+6 issue elsewhere, the issue didn't get raised here.
+7
+MS. MENNINGER: Your Honor, this is Laura
+8 Menninger again. I would be in support of sending the
+9 parties back to have discussions about it, it was not
+10 part of our discussions. There were discussions that
+11
+we had that we were trying to come up with dates that
+12
+were reasonable but could change, you know, depending
+13
+on how things change in the future, and obviously
+14
+things are moving quickly and there have been a number
+15
+of developments that have taken place over the last 30
+16
+days, so it's a little difficult right now to
+17
+anticipate all of the issues that may come up with
+18
+these proceedings occurring simultaneously.
+19
+So if Your Honor would like us to take account
+20
+of those issues and have a further discussion about a
+21
+schedule, we are happy to go back and confer with
+22
+counsel for the other parties to reflect that in this
+23
+initial scheduling order rather than asking to amend
+24
+it when the discovery issues arise.
+25
+THE COURT: Why don't I do this, why don't I
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 16 of 54
+1
+16
+2 approve this schedule as to the first three points
+3 which
+would be the initial disclosures deadline, the
+4 initial document request interrogatories deadline and
+5 the motions to
+amend the pleading or join any other
+6 parties.
+Which will take us to August 21, which is at
+7 least keeping you moving for right now.
+8
+On the fact discovery deadline, I think what
+9 I'm going to do is just send you to go back and talk
+10
+about that a little bit more and make sure that you're
+11
+all on the same page. And then the expert discovery
+12
+can certainly be geared to the close of fact discovery
+13
+in the same sort of way as it is now. But, you know,
+14
+I think that you should just make sure that you're of
+15
+a mind if you're going to put something forward as a
+16 joint proposal, make sure it really is a joint
+17
+proposal and it's not something that gets people
+18
+exasperated because you want to re-discuss it, you
+19
+know, 30 days from now.
+20
+So go, and then if you agree, yeah, let's just
+21
+say November 6, and if we end up making an
+22
+application, we do, it's okay with me. And in terms of
+23
+the stipulation to modify interim deadlines, if that
+24
+meant the August 21 deadline that you wanted to agree
+25
+to stipulate to modify that, you can still stipulate
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 17 of 54
+1
+17
+2 to modify that as is reasonable without coming back to
+3 те,
+all right? I just want to avoid problems and I
+4 just see one on the horizon that I'd rather you talk
+5 about before it comes up as a problem, okay?
+6
+By the way, this may be the only case of the
+7 cluster, I'm not sure if there's more than one, maybe
+8 the only one where we don't have a stay in place of
+9 the case generally because of the plaintiffs
+10 participating in the claims program that was set up.
+11 |
+Is that right, let me ask on defendants' side, is this
+12 the only one?
+13
+MR. MOSKOWITZ: Your Honor, Bennet Moskowitz
+14
+for the co-executors, with the exception of one other
+15
+case that was filed the last month, so it's really not
+16 of the same grouping if you are looking at it from
+17
+this perspective, this is the only case that is not
+18 stayed. The other case that I was talking about, by
+19 the way, our answer deadline hasn't even come. And I
+20
+think Your Honor is right to raise that, and this
+21
+coupled with what we just heard from Ms. Menninger
+22
+about the potential, whatever it is, at least partial
+23
+staying of discovery against Ms. Maxwell, makes it
+24
+especially appropriate from my perspective for the
+25
+parties to discuss the case schedule in general. You
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 18 of 54
+1
+18
+2 know, I don't have to belabor the record, when, you
+3 know,
+we've done many calls in other cases. I get this
+4 is a different one, but the estate's position is still
+5 unchanged, you know, we have not moved for a stay, but
+6 there are many reasons that render it a very sensible
+7 thing to do. And the fact that now this is the,
+8 practically, virtually the only case that's moving
+9 forward, necessitates that the parties and potentially
+10
+again with the Court discuss that issue.
+11
+THE COURT: Well I will note that this
+12
+proposed scheduling order was submitted certainly on
+13 behalf of the estate, so I'm assuming you have
+14
+discussed these issues before submitting that proposed
+15
+schedule. But just let me hear on plaintiff's side, is
+16 plaintiff planning to participate at the moment in the
+17
+compensation fund program?
+18
+MR. GLASSMAN: Thank you, Your Honor, this is
+19
+Robert Glassman. Yes, so we have not submitted a
+20
+claim to the fund yet; however, we do plan to at some
+21 point participate in it,
+we just have not submitted
+22
+anything yet. And, you know, my understanding --
+23
+THE COURT: If you decide -- go ahead, I'm
+24
+sorry, go ahead and finish.
+25
+MR. GLASSMAN: I'm sorry, Your Honor. Yeah,
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 19 of 54
+1
+19
+2 so, you know, my understanding based on, obviously,
+3 the terms and conditions of the program, and, you
+4 know, through conversations with Mr. Moskowitz, you
+5 know, participation in the fund in no way means that,
+6 you know, the litigation needs to stop. And so we're
+7 not, we're not interested in stopping the litigation
+8 because we, quite frankly, just it is so unknown what
+9 is going to happen through this program that I think
+10
+it would be very prejudicial to my client to just put
+11
+everything on hold while the program result is
+12
+pending. And then we just have to kind of, if it
+13
+doesn't turn out appropriately or reasonably, then we
+14
+just have to kind of start all over and pick up.
+15
+And, you know, what we're interested in is --
+16
+THE COURT: Why would it be, 1o0k, I
+17
+understand that there is no requirement that you seek
+18 a stay if you participate in the program, no
+19
+requirement that the Court stay the case if you decide
+20
+to participate in the program, but there have been a
+21
+lot of very able plaintiffs' counsel in these cases,
+22
+including very, you know, counsel who are very
+23
+strongly committed to protecting their clients' rights
+24
+and interests, who have, nonetheless, decided that a
+25
+stay would make sense, and have weighed the different
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 20 of 54
+1
+20
+2
+issues and have apparently concluded that a stay would
+3 not be unduly prejudicial to their clients. And the
+4 evidence in these cases is all, already several years
+5 old, the chances at this point if a litigation is
+6 commenced and there's been litigation holds put out
+7 there,
+the chance at this point that there would be,
+8 you know, some serious erosion in the quality of the
+9 evidence seems unlikely. There isn't that much more
+10
+to do in the case, given the deadlines that are being
+11
+proposed, you're proposing November and it's already
+12
+August. So it seems to me that if the case is not
+13
+resolved through the program you can pick up and get
+14
+it done relatively quickly. And I'm not saying you
+15
+should agree to a stay, but I think you should
+16
+consider it and, you know, really be able to explain
+17
+why it's not in the interest of judgment and judicial
+18
+economy and all of the rest to put the case on the
+19
+same sort of track as the other cases, and all of
+20
+which I've asked for a status report pretty soon to
+21
+see how it's all going. I think I had August 14 as the
+22
+date I put on all of the stay orders that I issued
+23
+saying that I wanted to know and keep tabs on it,
+24
+wanted to know how it was going by then.
+25
+So I mean unless you have a particular witness
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 21 of 54
+1
+21
+2 who you think
+is, you know, who might be ill or
+3 something
+like that, or you might lose the testimony
+4 of somebody important, or there is some, really some
+5 concrete reason why you're concerned about the
+6 prejudice that comes from delay, I want to throw it
+7 out there, especially when we have this overlay of
+8 issues regarding Ms. Maxwell and the pending
+9 indictment. Does it make sense to plow forward if
+10 you're going to participate in the program, and
+11
+obviously anybody who participates in the program is
+12
+not satisfied with the results and does not accept the
+13
+settlement, we would put everything back on the
+14
+calendar pretty quickly and the cases would get
+15
+wrapped up and ready to go.
+16
+MR. GLASSMAN: Yes, Your Honor, my concern is
+17
+that it has taken so long to just do anything we want
+18
+to do in this case to date and, you know, if we just,
+19
+if we put everything on ice for three, four months, or
+20
+however long it will take for the administrator to
+21
+consider a package and render a decision, it's just
+22
+going to just delay it that much more. I mean we, you
+23
+know, we haven't been able to take a deposition so
+24
+far. Like I mentioned before, we don't have any
+25
+evidence or documents from the co-executors. Now we do
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 22 of 54
+1
+22
+2 have Mr. Indyke's deposition on calendar for August
+3 26, hopefully this time that date will stick, so I'm
+4 very pleased to see that we're going to start with
+5 depositions in the case. But, you know, I just think
+6 that like in most cases things really aren't going to
+7 pick up until we have a trial date and start working
+8 towards that date. So I just would like to keep
+9 moving forward at this point towards that, but I
+10
+certainly will, I appreciate Your Honor's comments and
+11
+I certainly will discuss them with my client.
+12
+THE COURT: And there is also a motion to
+13
+dismiss pending which the Court is going to have to
+14
+spend time and energy to resolve, and a decision may
+15 be on the way any moment, it's possible.
+16
+MR. GLASSMAN: With respect to the punitive
+17
+damages?
+18
+THE COURT: With respect to counts one through
+19
+four, one through four to the extent they are time
+20 barred, count five in its entirety, and the demand for
+21 punitive damages, as I read the notice of motion, no?
+22
+MR. GLASSMAN: Right, well, yeah.
+23
+THE COURT: That's not just the punitive
+24
+damages count.
+25
+MR. GLASSMAN: No, yeah, I mean I think,
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 23 of 54
+1
+23
+2 obviously it's the co-executor's motion, but I believe
+3 what it is, is, you know, counts one through four with
+4 respect to any allegations after the plaintiffs turned
+5 18.
+6
+THE COURT: Right, I mean there have been
+7 similar motions in other cases and some judges have
+8 decided them, and others where cases were stayed have
+9 held off.
+10
+MR. GLASSMAN: Yeah, and just so Your Honor
+11
+knows, I mean out opposition on that was basically we
+12 kind of submit on it. I mean we agreed to the count
+13 five and, I mean counts one through four for sexual
+14 assault, sexual battery, NIED and IIED, yeah, I mean
+15 anything that happened after she was 18 is not, we
+16 can't recover, you know, for. So that --
+17
+THE COURT: That issue got taken out of the
+18
+case?
+19
+MR. GLASSMAN: I mean that's what we argued in
+20
+our, you know, set forth in our opposition.
+21
+THE COURT: I see. All right, by the way, I
+22
+also see on the docket a motion for an attorney to
+23
+appear pro hoc vice which is still unresolved. I can
+24
+resolve that, I don't think that attorney is on the
+25 phone, but I can grant that motion, I'll take care of
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 24 of 54
+1
+2 that.
+24
+All right, so with respect to, with respect to
+4 your timing, go back and talk further, take not more
+5 than
+one
+week from today's date to write a new letter
+6 that's
+jointly submitted that tells me what the
+7 parties' positions are, and let's sort it out now
+8 instead of later so that I don't hear squawking down
+9 the pike. Okay, with respect to the computation of
+10
+damages issue, I gather there is still discontent
+11
+about the sufficiency of the computation, who wants to
+12 address that?
+13
+MR. MOSKOWITZ: Your Honor, Bennet Moskowitz
+14 here, my colleague, Mary
+Metcalfe will address
+15 that issue.
+16
+MS. METCALFE: Thank you. We don't want to
+17
+belabor this point which I believe Your Honor
+18
+addressed in another case at the end of June involving
+19
+the estate, but plaintiff has today failed to provide
+20
+calculation of damages or any supporting document
+21
+that's required by Rule 26(A) (1)(a). In our letter we
+22
+laid out the various responses we have received, none
+23
+of which are sufficient, and despite raising this with
+24
+plaintiff's counsel repeatedly over the last several
+25
+months, the issue still hasn't been resolved.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 25 of 54
+1
+25
+2
+THE COURT: Do I have the actual response or
+3 do I just have the letter that quotes from it?
+4
+MS. METCALFE: I don't believe we submitted
+5 the actual response, we did quote it in its entirety
+6 throughout the letter though.
+7
+THE COURT: So I read the blocked in quotes
+8 together?
+9
+MS. METCALFE: Yes, please, they consist of
+10
+the first response, or rather the first disclosure
+11
+that we received --
+12
+THE COURT: And the second blocked in quote in
+13
+your letter is the full extent of the second
+14
+disclosure?
+15
+MS. METCALFE: The second blocked in quote is
+16 what was supplemented during the amended disclosures,
+17 the first chunk of the blocked in quote was still
+18 present.
+19
+THE COURT: Okay, and was there anything
+20
+further?
+I guess --
+21
+MS. METCALFE: Your Honor, I'm sorry, in our
+22 interrogatories we requested a calculation of damages
+23
+and the content of the first two blocked in quotes
+24
+combined is the entirety of plaintiff's responses.
+25
+Then during our meet and confer we additionally raised
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 26 of 54
+1
+26
+2 the issue, it was one of the few issues we were able
+3 to discuss, and plaintiff then supplemented her
+4 response to this interrogatory with the third blocked
+5 in quote
+which contains the reference to the New York
+6 (indiscernible) and jury instructions.
+7
+MR. GLASSMAN: Your Honor, I was going to
+8 suggest, I have it up here on my screen, I can just
+9 read it to you if you want --
+10
+THE COURT: I think I have it, unless you
+11
+disagree that what's
+in the letter is accurate.
+12
+MR. GLASSMAN: Well it was kind of a little
+13
+piecemeal, the second supplemental response was not
+14 set forth kind of like in its entirety continuously in
+15 the letter so I don't know if it's going to be clear
+16 to Your Honor --
+17
+THE COURT: Well let me just ask this.
+18
+MR. GLASSMAN: Sure.
+19
+THE COURT: If you have different categories
+20
+of damages that the plaintiff is claiming, then each
+21
+separate category of damages needs to be separately
+22
+set out and computed to the best that you are able to
+23
+do so. There are obviously going to be some types of
+24
+damages that are not going to be readily susceptible
+25
+to a mathematical computation and everybody
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 27 of 54
+1
+27
+2 understands that, you know, pain and suffering is
+3 difficult or emotional distress is difficult. But
+4 there can be categories of damages that are
+5 susceptible of computation and there can be documents
+6 that support those computations, and when there is a
+7 category that is
+capable of being computed to the best
+8 of your ability at this time, it needs to be under the
+9 rule and the documents that support it need to be
+10 produced under the rule.
+11
+So, you know, if you say something like, you
+12
+know, loss of enjoyment of life, okay, we understand
+13
+that, or punitive damages, we understand that it may
+14 be an uncertain computation. You can still put down
+15 the particular amount that as of now you claim to be
+16
+seeking as best as you are able. Everybody understands
+17
+that if there's an expert report later or something
+18 and there's a need to supplement responses, they can
+19 be supplemented. You know, the rule provides that if
+20
+the information is made clear, then, you know, then
+21 that can suffice as supplementation.
+22
+Let me just pull up for a moment the rule
+23 here. Under 26, hold on one moment, 26(E)
+24
+supplementing disclosures and responses, you must
+25
+supplement or correct in a timely manner if you learn
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 28 of 54
+1
+28
+2 that in some material respect the disclosure or
+3 response is incomplete or incorrect, and if the
+4 additional or corrective information has not otherwise
+5 been made known to the other parties during the
+6 discovery process or in writing, or as ordered by the
+7 Court.
+So, you know, if you produce an expert report
+8 that makes clear that you have some additional
+9 information or corrective information that's made
+10
+clear during the discovery process, that may work, but
+11
+that doesn't excuse you from doing the initial
+12 disclosures as best as you are able at the outset of
+13 the case.
+14
+And in addition, you've got some categories
+15 here that are various expense categories that may well
+16 be susceptible to computation, and you may not be able
+17
+to give, you know, the end amount that it's going to
+18
+cost at the end of the day, so reasonable attorney's
+19
+fees incurred in the case by the end of the day, but
+20
+if you have estimates of, you know, court costs,
+21
+quote,
+"other recoverable expenses," you should
+22
+provide as best of a computation as you can provide.
+23
+And if there are particular things that factor into
+24
+plaintiff's damages, I don't know, medical bills, lost
+25
+employment, if there are particular things, they
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 29 of 54
+1
+29
+2 should be itemized and you should provide the
+3 documents
+that support whatever you've got in the
+4 computation. If you really don't have anything,
+5 there's nothing concrete, there are no numbers you can
+6 add, then you have to say, at least in your good faith
+7 conference there are no specifics, there is nothing
+8 that we could add, we do not intend to rely on
+9 anything specific, we just intend to be, you know,
+10
+coming up with general damages numbers that we think
+11
+sound fair. If that's, I mean you can't invent
+12
+documents, you can't invent computations if there is
+13
+nothing to calculate or no formula that you can use,
+14 but if there is, you do it to the best of your ability
+15
+at the outset of the case and then you supplement it
+16
+later if something changes.
+17
+Now what is it on defendants' side that you
+18
+think is, needs to be specifically itemized and
+19
+computed? Ms. Metcalfe?
+20
+MS. METCALFE: Your Honor, I had the phone on
+21 mute for a moment.
+We've seen the categories that
+22 plaintiff's counsel has laid out in the first set of
+23
+initial disclosures which have been sort of all
+24
+grouped together, Your Honor noted the attorney's
+25
+fees, the court costs, medical bills and expenses. In
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 30 of 54
+1
+30
+2 addition, the second supplement set of disclosures
+3 breaks down the calculations, or rather the categories
+4 of emotional damage to include past pain and
+5 suffering, future pain and suffering, emotional
+6 distress, loss of enjoyment of life, and then also
+7 there's the amount of punitive damages at issue. In
+8 particular, that's one we'd like to address because as
+9 noted earlier on the call, the punitive damages are
+10
+the subject of a currently pending motion to dismiss,
+11
+and punitive damages such as those sought by
+12 plaintiffs in this case have bene consistently
+13 dismissed in other actions brought against the estate.
+14
+So if we could please see a breakdown of each
+15
+of the categories of damages plaintiffs identified in
+16
+the various disclosures,
+supplements and answers to
+17
+the interrogatories, and then again, the basic
+18
+documents in support of those categories, for example,
+19
+while I know plaintiffs can't necessarily give us a
+20
+concrete number on how much the litigation will cost,
+21
+I think costs to date is a pretty good indicator and
+22
+then an estimate of how much more time and effort this
+23
+will take, that would go I think a long way towards
+24
+resolving this dispute.
+25
+THE COURT: All right, well attorney's fees
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 31 of 54
+1
+31
+2 are a
+tough one because they continue to be incurred
+3 as
+the
+case goes
+on and sometimes what's low at the
+4 beginning
+ramps up and sometimes what's high at the
+5 beginning goes down, and it's hard to extrapolate. And
+6 you know how much you're spending on your end and it
+7 probably gives you some clue as to how costly
+8 litigation is.
+But I will say that if you have
+9 separate categories of damages, even if the numbers
+10 that you are using for those are numbers that you just
+11
+think are fair, you know, maybe based on other cases
+12
+you've looked at and you don't have a means to compute
+13
+them mathematically, you can still separate out the
+14
+categories.
+So you can separate out punitive damages
+15
+from actual damages. You can separate out past pain
+16
+and suffering from future. You can put different
+17
+numbers that then add up to your total and at least
+18 give defendants the idea of, you know, what they're
+19 dealing with in these different categories of damages
+20
+that you're asserting. Is there any reason on
+21 plaintiff's
+side why you cannot do that?
+22
+MR. GLASSMAN: Well, Your Honor, so to be
+23
+perfectly clear, we are not seeking any economic
+24
+damages in this case, period. And it's very clear in
+25
+our response that we're only seeking pain and
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 32 of 54
+1
+32
+2 suffering, emotional distress and loss of enjoyment of
+3 life. And
+the
+cases that have been cited to
+4 continuously by the co-executors in support of their,
+5 you know, disagreement with this, are cases that
+6 involve patent and copyright infringement claims,
+7 that's the Max Impact v. Sherwood Group case, and also
+8 the Design Strategy v. l
+case which is a breach of
+9 employment agreement and breach of fiduciary duties
+10
+case.
+In those two cases, the ones that they cite,
+11
+too, noneconomic damages are not being sought, period.
+12
+Economic damages are being sought, profits, future
+13
+sales, lost sales, and in some cases injunctive
+14
+relief. But neither, in no case that is cited to does
+15
+a Court ever say that pain and suffering has to be
+16
+computed in some mathematical way. In fact, the law is
+17
+that it's inappropriate and improper to do that.
+18
+So in our response --
+19
+THE COURT: Is there any case law that either
+20
+side has identified that talks about breaking out past
+21 pain and suffering and future?
+22
+MR. GLASSMAN: You know, I 100ked, I 1o0ked
+23
+for that, Judge, and I have not seen it. but I will
+24
+say if, you know, if anyone is going to be satisfied
+25
+with us breaking out the past and future, I'm happy to
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 33 of 54
+1
+33
+2 do that. I mean the past damages would be from 1994 to
+3 2020, or whenever the trial would be in this case,
+4 right, that's how you calculate the past. So since I
+5 don't have a trial date, I don't really know exactly
+6 how, what defines the past, but I mean it would be
+7 from 1994 to the trial date, so 26, 27 years of past
+8 pain and suffering, past emotional distress and past
+9 enjoyment of life. And then the future is from the
+10
+date of the trial until the end of plaintiff's life.
+11
+And obviously there's life expectancy tables that, you
+12
+know, I can look at and see what a normal life
+13
+expectancy is for a 39, 40 year old woman. We have no
+14
+evidence, you know, and I don't think the defense has
+15
+any evidence that she is going to have any kind of
+16
+shortened life expectancy, she's expected to life a
+17
+full life expectancy. So I can put a number on the
+18
+future, too, so 2020 or 2021 through the end of her
+19
+life will be the future.
+20
+So I'm happy to do that, but I mean we're not
+21
+seeking damages for medical bills, we're not seeking
+22
+damages for loss of earnings, so, you know, I think in
+23
+my most recent supplemental response I can't be any
+24
+clearer that we're only seeking noneconomic damages,
+25
+we put a number in there what that amount is, and I
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 34 of 54
+1
+34
+2 mean we specifically say what it's based on. We say,
+3 quote, "it's based upon the damages caused by Jeffrey
+4 E. Epstein to plaintiff as a result of his repeated
+5 and malicious acts of sexual abuse, including rape,
+6 committed against plaintiff over the course of several
+7 years while she was a minor as a result of this
+8 repeated and horrific sexual abuse committed by
+9 decedent Epstein on plaintiff. Plaintiff has suffered
+10
+significant and conscious past and future pain and
+11
+suffering, emotional distress and loss of enjoyment of
+12
+life for which he was aware she lost." And then --
+13
+THE COURT: Okay, let me interrupt you for a
+14
+second. All right, let me rule in this way. First,
+15
+separate actual damages and punitive damages. Okay,
+16 but different numbers on those since you're seeking
+17
+them in different categories, okay? That will be
+18 helpful to defendants understanding, if they win on
+19
+the punitive damages claim, what that does on the
+20
+value of the case and that might be helpful for
+21
+settlement purposes.
+22
+MR. GLASSMAN: Okay.
+23
+THE COURT:
+Second, I don't know and cannot
+24
+know if this is a situation where the plaintiff has,
+25
+based on her allegations, has suffered differently at
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 35 of 54
+1
+35
+2 differently points in her life.
+In other words,
+3 whether she went through a period of extreme turmoil
+4 and, you know, managed to get past it and live her
+5 life, or whether it has never abated, whether it has
+6 worsened, whether it has manifest in different ways in
+7 different levels of severity at different points in
+8 her life. So we're talking about a long period of
+9 time and it may be that the past and the future are
+10
+not calculated the same way, it's not a certain amount
+11 per year from day one forever.
+12
+So have a good faith conversation with
+13
+opposing counsel about the overall picture here,
+14
+because if you're going to take the position that it's
+15
+just really been a constant thing and to the extent
+16
+that it's manifest differently over time, it's of no
+17
+different value from the time when the events were
+18
+occurring to the time immediately thereafter, to the
+19
+time 10 years later or 20 years later or what may be
+20
+30 or 40 years later, then let counsel understand
+21 that. And then I'm not going to require you to break
+22 it out by saying, fine, we'll just divide it by number
+23
+of years of life expectancy and there you can have a
+24
+calculation.
+25
+If, on the other hand, it is a situation where
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 36 of 54
+1
+36
+2 things may be different past and future, then I'm
+3 going
+to ask you, you know, to discuss it so that
+4 defendants' counsel can have an understanding of what
+5 you're claiming and to see if it might make sense to
+6 at least break it out by past and future. It kind of
+7 depends upon what the claim is, I'll let you confer on
+8 your own part first instead of, you know, stating it
+9 now, and have a conversation with defendants' counsel.
+10
+If you are not claiming anything like medical
+11
+expenses or anything, fine, it's not an element and
+12
+doesn't have to be broken out and so on. I'm not
+13
+going to require a breakout now of legal expenses, it
+14
+seems a little bit silly because they are ongoing and
+15
+they're going to just keep changing over time. And I
+16 think that attorney's fees applications can be made at
+17
+the end of the case and everybody understands that.
+18
+Court costs, everybody understands, I don't think it
+19
+has to be broken out and it's going to be a drop in
+20
+the bucket anyway. And expert fees, you haven't even
+21 hired your experts yet, I assume where if you have
+22
+they haven't even incurred the full cost yet, and
+23
+they're going to have to disclose what they're paid
+24
+anyhow in connection with their reports and so that
+25
+will come out that way.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 37 of 54
+1
+37
+2
+If there are no other actual damages other
+3 than the sort of general pain and suffering type
+4 damages, then we're going to leave it at that, and on
+5 defendants' side that's going to be the ruling, we're going
+6
+to leave it at what I just said, all right?
+7
+MR. GLASSMAN: Thank you, Your Honor.
+8
+MS. METCALFE: Thank you very much, Your
+9 Honor.
+10
+THE COURT: Okay, now moving onto the question
+11
+of documents from the estate and the protective order
+12
+issue, talk further, bring it to a head, put it in
+13
+writing to me if you still have an issue that you
+14
+can't work out. I think defendants' point is well
+15
+taken that plaintiff ought to want a protective order
+16
+because plaintiff has confidentiality concerns
+17
+regarding even her identify and I would imagine
+18
+something like her medical records, and she's
+19
+entitled, excuse me, to have some confidentiality on
+20
+her very personal information. It can be used in the
+21
+context of this case and, you know, should not
+22
+otherwise be out there. There's no reason for, you
+23
+know,
+for a minor's personal history of trauma to be
+24
+not afforded some measure of confidentiality
+25
+protection. But talk about it, if you really have an
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 38 of 54
+1
+38
+2
+issue about a protective order and you think in some
+3 way it is overbroad, talk about it, bring it to my
+4 attention, I'll rule on it and we'll get an order in
+5 place that makes
+sense and that can be supported by
+6 the Court with the understanding that documents are
+7 presumptively public unless there is a reason to
+8 protect them.
+And if you show me a good reason, I'll
+9 protect them, and if you don't, I won't.
+10
+In terms of the production of documents, I'm
+11
+assuming once the protective order issue is resolved,
+12
+documents will be produced forthwith and you'll be
+13
+able to work that out. I don't want undue delay but I
+14 /
+also have some concerns about, as I said, the
+15 discovery as to Maxwell. I have some concerns about
+16
+when this case can be tried anyway because we're set
+17
+back on trials because of Covid, and I think you
+18
+should not, on plaintiff's side, not be concerned it's
+19 moving too slowly. If the protective order is in place
+20
+and you're still not getting documents, you'll put it
+21 all in writing to me and I will rule and try to make
+22
+sure things move along appropriately.
+23
+MR. GLASSMAN: Thank you, Your Honor, just two
+24
+quick points. So number one, you know, part of the
+25
+issue with the protective order is we were waiting for
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 39 of 54
+1
+39
+2 Ms. Maxwell's thoughts on whether or not she thought
+3 it would be appropriate to have a protective order in
+4 this case. Ms. Menninger has said she would think
+5 about it and let us know, and we have not kind of
+6 gotten her input on that issue yet so I think that's
+7 part of the holdup. And number two, you know,
+8 presumably the co-executors of the estate do not have
+9 medical records of the plaintiffs in their possession,
+10
+custody and control. In fact, to the contrary, it's my
+11
+understanding, based on prior conversations, that they
+12
+do have some documents with my client's name on them.
+13
+They're not medical records, they are just simply
+14
+documents that were, you know, found through the
+15
+course of their, you know, their investigation and
+16
+discovery of their client. And I don't know why, I
+17
+mean I just, after reading the --
+18
+THE COURT: Well hang on a second, hang on a
+19
+second, is the issue, let me hear from defendant's
+20
+side,
+is the issue about the protective order the fact
+21 that the documents have plaintiff's name on them or is
+22 there some other issue?
+23
+MR. MOSKOWITZ: Your Honor, Bennet Moskowitz,
+24
+that's one issue, but if I take a step back I'm just,
+25
+again,
+scratching my head that something that has been
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 40 of 54
+1
+40
+2 a nonissue in over a dozen other cases against the
+3 estate
+is
+an
+issue here. The broader issue is,
+4 especially given Ms. Maxwell's role as a defendant
+5 here, and if Your Honor has seen any of the coverage
+6 of or otherwise knows anything about what's been going
+7 on in other litigation involving Ms. Maxwell, we want
+8 nothing to do with on the estate side any
+9 confidentiality issues. Whether it's something that
+10
+seems
+innocuous to us that Maxwell, or this plaintiff,
+11
+or someone else will claim shouldn't have been out
+12
+there or should have been protected, there have been
+13
+many very public problems in that regard, not having
+14
+to do with us, but in the greater world of Epstein
+15
+related litigation. And it just stands to reason that
+16
+we would do what we did in every other case, know what
+17
+the rules are for designating things confidential and
+18 if and when we identify any of those things to produce
+19
+we will treat them in accordance with that agreement
+20
+so that there is certainty and so that we are not then
+21
+spending money and time on something that could have
+22
+been avoided had we just simply entered into this,
+23
+again, this pretty standard agreement at this point.
+24
+THE COURT: What on plaintiff's side are the
+25
+problems with the proposed agreement?
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 41 of 54
+1
+41
+2
+MR. GLASSMAN: Well, so number one, there's
+3 been
+no showing by the estate that the documents they
+4 have contain confidential information, number one.
+5
+THE COURT: Well hold on a second, for
+6 starters, you, yourself, said that they have
+7 identified documents that have your client's name.
+8
+MR.
+GLASSMAN: Correct.
+9
+THE COURT: You've asked to proceed in this
+10
+case anonymously. Presumably you want some protection
+11
+for documents that have your client's name.
+12
+MR. GLASSMAN: Well but, Your Honor, so
+13
+production of documents in discovery are not public
+14
+documents, right, I mean --
+15
+THE COURT: No, production of documents in
+16 discovery are not public documents, but if you don't
+17
+have a protective order, anyone with those documents
+18
+is entitled to share them outside the litigation.
+19
+Whereas if you have a protective order in place, it
+20
+limits parties' ability to share those documents in
+21
+other cases, for other purposes and with the public as
+22
+a whole.
+So but your client, to be protected in terms
+23
+of her identity, you would presumably want an order
+24
+that would bind other parties from revealing documents
+25
+with her name on them. Not that the estate is about
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 42 of 54
+1
+42
+2 to do that, but you would presumably want assurance
+3 that a Court would have said, no, don't do that, not
+4 for this moment in time, right, why would you not want
+5 that?
+6
+MR. GLASSMAN: Well I'm operating on the
+7 assumption that neither the estate nor Ms. Maxwell,
+8 well the estate already has the documents, obviously,
+9 and they haven't, to my knowledge, just publicly
+10
+disseminated them so far because that would be
+11
+inappropriate and I don't expect them to do that. I
+12
+wouldn't expect them to do that in the future. Just
+13
+because they have my client's name on them, again, I
+14
+think putting a confidentiality order in a case is
+15
+something that is done when there is extremely
+16
+sensitive confidential proprietary information that if
+17
+it got out would harm a party. And here, just because
+18
+this is a high profile case, doesn't mean that --
+19
+THE COURT: So you want to provide releases
+20
+for your client's medical records and you want
+21
+defendant to be able to get those medical records, and
+22
+you don't care about having a confidentiality order in
+23
+place, even if it's documents being produced by a
+24
+third party or by you?
+25
+MR. GLASSMAN: Well I've already produced,
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 43 of 54
+1
+43
+2 I've produced documents to the executors already,
+3 about 200 pages of them --
+4
+THE COURT: And you don't want a protective
+5 order
+for the documents that you produced, you are
+6 trusting and don't care about any assurance of
+7 protection for your client's personal information?
+8
+MR. GLASSMAN: No, it's not about not
+9 trusting, it's about the standards for a protective
+10
+order and a nondisclosure agreement are pretty high.
+11
+And I don't see any proprietary or commercially
+12
+sensitive information that has any bearing,
+13
+whatsoever, in this case. I mean I think that --
+14
+THE COURT: You don't think your client's, any
+15
+treatment she may have had for emotional distress or
+16 pain and suffering, you don't think, or loss of
+17
+enjoyment of life, you don't think any of that
+18 warrants confidentiality protection? I understand
+19 you're saying that those are not documents currently
+20
+in defendants' hands,
+but you're providing documents
+21 to them of that nature and you might assume that
+22
+they're not to show anyone. But you don't think that
+23
+that would constitute the kind of material that is
+24
+appropriately protected by the Court?
+25
+MR. GLASSMAN: Your Honor, I really don't. so,
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 44 of 54
+1
+44
+2 I mean, unlike perhaps other, you know, like kind of
+3 cases
+that the lawyers for the estate work on, I mean
+4 all my cases involve medical issues and medical
+5 records. And there are not protective orders put in
+6 place just because a defendant gets a HIPAA release
+7 for a medical record, or a plaintiff and then gets
+8 those
+records and can share them with their experts
+9 for litigation purposes.
+10
+THE COURT: So let me ask the estate this,
+are
+11
+there any confidentiality issues that you can think of
+12 that do not relate to plaintiff's information,
+13 plaintiff's identity, plaintiff's personal
+14
+information, is there anything else that you think
+15
+ought to be given confidentiality protection?
+16
+MR. MOSKOWITZ: Yes, Your Honor, Bennet
+17
+Moskowitz here.
+(indiscernible) all the other orders
+18
+that were entered in the others actions, including,
+19
+for example, without conceding that they're relevant
+20
+here but certainly they're things that plaintiff has
+21
+asked for in requests that we object to, financial
+22
+information that is not public, information about
+23
+other nonparties to the extent they come up in
+24
+documents. What about deposition testimony? You can't
+25
+just, plaintiff said they're kind of assuming that
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 45 of 54
+1
+45
+2 there's
+this group of documents and this group, let's
+3 talk about them now, no, this is for planning for the
+4 unknown, of all the fraud issues that will come up in
+5 this case,
+and that have already come up in this case.
+6 You have one defendant who's been indicted. I'm kind
+7 of concerned here that I don't hear what the prejudice
+8 is to plaintiff of something that would --
+9
+THE COURT: Okay, well look, look, hold on a
+10
+second, if there has been a protective order entered
+11
+in another case involving personal information
+12
+regarding other plaintiffs, we're not going to get
+13
+around that by having documents in this case produced
+14 that mention these other plaintiffs who claim to be
+15 victims of Mr. Epstein, and have not protected because
+16 they've bene produced in this case. Similarly, if this
+17 plaintiff were to testify about knowledge about
+18
+someone else she knew, even if not a plaintiff in
+19
+another case, but somebody else who was potentially a
+20
+victim, I think it is entirely appropriate to protect
+21 the identities of victims and information about the
+22
+circumstances, personal information about the
+23
+circumstances of other victims, especially if they
+24
+were minors, so there's that. Even if this plaintiff
+25
+through counsel doesn't think that her own information
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 46 of 54
+1
+46
+2 needs to be protected, I'm not going to gloss over the
+3 fact that
+there may be information that's produced or
+4 that comes out in testimony regarding other claimed
+5 victims. And to me, the quintessential information
+6 that is appropriate to protect is highly sensitive
+7 personal information such as information about sexual
+8 abuse of a minor. That is highly personal and, you
+9 know, unless there is further consideration by the
+10
+Court about why it should be released, in the first
+11
+instance that's appropriate to keep for use
+in the
+12
+case and not to share widely.
+13
+Second, financial information, I don't know,
+14
+whose financial information are we talking about? What
+15
+kind of financial information are we talking about?
+16 You know, that warrants some discussion. But you could
+17
+have a protective order that has a provision in it and
+18
+once documents are produced, if somebody wants to use
+19
+them for purposes other than the case or thinks that
+20
+the designation was really overbroad or improper, you
+21
+can
+come back to the Court and I can take a look at it
+22
+and I can determine whether it really is appropriate
+23
+or not for protection.
+You know, Mr. Epstein had a
+24
+certain amount of wealth, that's not contested, I'm
+25
+sure, information about his finances may not be the
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 47 of 54
+1
+47
+2 sort of thing that is appropriate for protection at
+3 this point. But there may be other kinds of
+4 information that's not public, I don't know what
+5 you're talking about. But you should talk through
+6 these things and I think it makes sense to have a
+7 protective order in this case that covers at least
+8 certain categories of information, and I don't see why
+9 you shouldn't be able to discuss those categories and
+10 come up with something sensible and have a provision
+11
+in there that says that you can return to the Court if
+12 you think a designation was overbroad.
+13
+I do not sign protective orders unless they
+14
+have some specificity. I will not sign an order that
+15
+says we can keep confidential anything we think is
+16
+confidential, that's not acceptable. The public has to
+17
+understand what the rationale is for having something
+18 kept confidential, so it has to be spelled out what
+19
+the category is so that you can see on its face what
+20
+it is that the Court has decided to afford protection
+21
+to. So nothing vague.
+But I don't think that it's
+22
+appropriate to have no protections in a case that
+23
+involves one and potentially more through discovery
+24
+claimed minor victims of sexual abuse. I mean if
+25
+that's not highly personal, I don't know what is.
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 48 of 54
+1
+48
+2
+I'm going to send you back to the well. Again,
+3 I'm going to send you back to talk. As far as Ms.
+4 Maxwell is concerned, counsel, be part of the
+5 conversation.
+Okay, I know there is some stuff going
+6 on about testimony that Ms. Maxwell has given
+7 elsewhere and whether it should be public or not, and
+8 I know that's currently in the courts and being
+9 discussed and, you know, there may be some precedent
+10
+that's relevant, and we'll take it all into account.
+11
+But you should be in discussions, in an initial
+12 discussion phase of what sort of protection order, if
+13
+any, should be issued by the Court, okay. And on
+14
+plaintiff's side, if this is what's slowing down
+15
+production of documents, then let's get the issue
+16 about the protective order teed up quickly and I'11
+17
+try to resolve it as quickly as I can so that the
+18 production can follow.
+19
+MR. GLASSMAN: Okay, Your Honor, thank you,
+20
+thank you, it's still not seen on the issue of
+21
+documents how, you know, the estate is trying to act
+22
+like they're protecting my client's privacy here, I
+23 mean --
+24
+THE COURT: That's not what I'm hearing. What
+25
+I'm hearing is that the estate wants some certainty as
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 49 of 54
+1
+49
+2 to what it can and can't do to avoid issues later and
+3 to
+avoid charges later that they improperly disclosed
+4
+something or didn't keep something confidential.
+5
+MR. GLASSMAN: But we can't litigate in
+6 secret, this is a public case in a public forum and I
+7 just feel like every time we talk about this, I get
+8 the statement that, well, every other case has decided
+9 - -
+10
+THE COURT: Okay, for defendants' benefit, I
+11
+don't care about every other case, I care about this case.
+12
+I do care that information relevant to other cases may
+13
+possibly come out through this witness or through the
+14
+documents that defendants have. If, for example, there's
+15
+a document that list three names, one might be your
+16 client, you may not care if your client's name is
+17
+public, even though you wanted to proceed anonymously,
+18 but the other two may care, and the other two may have
+19
+good reason for caring. And the defendant is right to
+20
+question whether there should be some protection so it
+21
+knows what the ground rules are. Right, let's put the
+22
+ground Iules in place. And if your view is there
+23
+should be no ground rules and everything should be
+24
+fair game, then I'll allow defendant to make its own
+25
+application for a protective order, I'll hear your
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 50 of 54
+1
+50
+2 argument as to which provisions are or are not
+3 appropriate and I'll decide what provisions should or
+4 should not be in place. But I'm inclined to issue an
+5 order that allows at least some protection for
+6 identities and highly personal information regarding
+7 alleged victims.
+8
+MR. GLASSMAN: Okay, so we can go back, as you
+9 said, to the
+well and probably narrowly tailor that
+10
+this --
+11
+THE COURT: You can narrowly tailor it, if you
+12 have a dispute about certain categories of
+13 information, Mr. Moskowitz mentioned financial,
+14 nonpublic financial information, you can talk about
+15
+what that means, what would be covered by that
+16 category, what kind of financial information of whom
+17
+are we talking about. If you cannot reach agreement
+18
+on that, you let me know what the issue is and I'll
+19
+decide it. Okay, Mr. Moskowitz, I am more concerned
+20
+about personal information of minor victims than I am
+21
+about financial information but I don't really know
+22
+what you're talking about. It's not a trade secrets
+23 kind of case, it's not, you know, a case where
+24
+somebody has a customer list that somebody else might
+25
+steal, right,
+so be cautious about what it is, and I'm
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 51 of 54
+1
+51
+2 not going to entertain the argument of, well,
+3 everybody else agreed so you should, too. This case is
+4 its own case, and bringing me back to what I was
+5 saying before, it seems to be the only one that is
+6 going full force which should lead to another
+7 conversation. Not trying to twist anybody's arms
+8 here, I just think you need to talk because I don't
+9 want to see money unnecessarily spent if you're going
+10
+to decide a month from now that maybe the case should
+11
+be stayed. Figure it out now, figure it out, figure
+12
+out whether it should be stayed in its entirety
+13
+because the plaintiff wants to participate in a
+14
+program, figure out whether it should be stayed in
+15
+part as to defendant Maxwell or not, and if in part,
+16
+what part. You know, figure out now, try to figure
+17
+out now the scope of an order so that, a protective
+18
+order so that everybody has clear guidance on
+19 production of documents on both sides and knows what
+20
+they can and can't do.
+And so that the public and the
+21
+press knows what they can and can't get their hands on
+22
+for the asking. And bear in mind that this discovery
+23
+material, yes, it's exchanged between you, but it may
+24
+well be provided to the Court in connection with a
+25
+motion. And if so, and if the Court relies on it and
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 52 of 54
+1
+52
+2 it becomes a
+judicial document, some of those
+3 presumptions
+of confidentiality are going to disappear
+4 anyway because the public is entitled to know what the
+5 basis was
+for the Court's decision. So think about the
+6 whole ball of wax when you're talking and, you know,
+7 think about a protective order that maybe lays it out
+8 a little bit more clearly than some other ones that
+9 you've negotiated if you feel the need.
+10
+All right, go back and talk some more. I'm
+11
+going to grant the motion for pro hoc vice counsel,
+12
+that's easy. I'm going to approve the scheduling
+13
+order that's been proposed as to the August dates and
+14
+then ask you within a week to send me a joint letter,
+15
+all counsel, as to whether you're in agreement as to
+16 what should happen with regard to the close of fact
+17
+discovery and expert discovery or not. If you're not,
+tell me where the disagreement lies, if I need to have
+19
+another conference I will. On the computation of
+20
+damages,
+to summarize, break out punitive and talk
+21
+with your client about the question of whether other
+22
+damages were consistent over time or not. If not, try
+23
+to break it out in a way that makes sense. If so, if
+24
+it's consistent over time, I'm not going to require
+25
+it. I'm not going to require breaking out attorney's
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 53 of 54
+1
+53
+2 fees and the
+like with separate amounts. And on
+3 document production, if you end up slowed down even
+after this protective order, then you come to me with
+5 an informal motion to compel and I'll try to get on it
+6 and try to get you moving, okay?
+7
+MR. GLASSMAN: Thank you, Judge.
+8
+THE COURT: Got all that?
+9
+MR. GLASSMAN: Yes.
+10
+THE COURT: All right, everybody, carry on.
+11
+Be well. Hope you get your power back soon.
+12
+MR. MOSKOWITZ: Thank you,
+Your Honor.
+13
+MR. GLASSMAN: Thank you.
+14
+15
+16
+(Whereupon the matter is adjourned.)
+17
+18
+19
+20
+21
+22
+23
+24
+25
+
+
+Case 1:20-cv-00484-JGK-DCF Document 64 Filed 08/12/20 Page 54 of 54
+1
+2
+54
+CERTIFICATE
+4
+5
+I, Carole Ludwig, certify that the foregoing
+6
+transcript of proceedings in the United States District
+7 Court, Southern District of New York, Jane Doe versus
+8 Indyke, et al., docket #20cv484, was prepared using PC-based
+9 transcription
+software and is a true and accurate record of
+10
+the proceedings.
+11
+12
+13
+14
+15
+Signature
+Carole Ludwig
+16
+Carole Ludwig
+17
+Date: August 12, 2020
+18
+19
+20
+21
+22
+23
+24
+25
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+++ b/vision-fixhub/court-01/f8a2a2fa24fbeee7e8750209d210a630134bccfe7542c6904cd571fe6aebccbe.md
@@ -0,0 +1,39 @@
+Case 9:08-cv-80119-KAM Document 416 Entered on FLSD Docket 11/19/2009 Page 1 of 1
+Case 9:08-cv-80119-KAM
+Document 407-1
+Entered on FLSD Docket 11/13/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+FILED by
+- D.C.
+VS.
+JEFFREY EPSTEIN,
+NOV 1 9 2009
+STEVEN M LARIMOR
+CLERK U.S. DIST. CI
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+ORDER
+Upon Plaintiffs' Unopposed Motion for Enlargement of Time to File Reply
+Memorandum in Support of Motion to Compel Responses to Requests for Net Worth
+(0.E.407)
+Discovery, and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an
+enlargement of until November 23, 2009, to file their Reply Memorandum in Support of
+Motion to Compel Responses to Requests for Net Worth Discovery.
+DONE AND ORDERED in |
+Florida, this A day or Nov.
+19#5
+, at West Palm Beach, Palm Beach County,
+_ 2009.
+amme
+DISPOURT JUBEE
+MAGISTRIe
+LiNNEA R. Iohnson
diff --git a/vision-fixhub/court-01/f8a2a2fa24fbeee7e8750209d210a630134bccfe7542c6904cd571fe6aebccbe.receipt.json b/vision-fixhub/court-01/f8a2a2fa24fbeee7e8750209d210a630134bccfe7542c6904cd571fe6aebccbe.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..634ac9506b8e21e55a8ba57f1ae9487f91557133
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+++ b/vision-fixhub/court-01/f8a2a2fa24fbeee7e8750209d210a630134bccfe7542c6904cd571fe6aebccbe.receipt.json
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diff --git a/vision-fixhub/court-01/f8d81b38244522dd17200af58fe0285092f45dfd7fb9d0f49500bafd5ae0f236.md b/vision-fixhub/court-01/f8d81b38244522dd17200af58fe0285092f45dfd7fb9d0f49500bafd5ae0f236.md
new file mode 100644
index 0000000000000000000000000000000000000000..e621aa1d95cc5af2d3f46ee13100ab79ce919655
--- /dev/null
+++ b/vision-fixhub/court-01/f8d81b38244522dd17200af58fe0285092f45dfd7fb9d0f49500bafd5ae0f236.md
@@ -0,0 +1,25 @@
+Case 9:08-cv-80736-KAM Document 65-1
+Entered on FLSD Docket 04/13/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marral
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+[PROPOSED] ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+MOTION TWO WEEK EXTENSION OF TIME AND FOR PERMISSION TO FILE AN
+OVERLENGTH REPLY TO GOVERNMENT RESPONSES TO THEIR MOTIONS
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Two Week Extension of Time and for Permission to File an Overlength Reply to
+Government Responses to Their Motions, filed April 13, 2011.
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims may file
+replies to responses to the Government's pending motions (DE #58, 59, 60, and 62) on or before
+May 2, 2011. They may also file a reply in support of their Motion for Finding of Violations of
+the Crime Victims' Rights Act not to exceed 27 pages in length.
+DONE AND ORDERED in
+_ at West Palm Beach, Palm Beach County, Florida,
+this
+day of April, 2011.
+KENNETH A. MARRA
+United States District Judge
+1
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index 0000000000000000000000000000000000000000..7cafb66b23e58d7f48e21409b11616ef55109ee4
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f8da5c777aae3d128bfe7c176288131724f6b2d36b25dc909bc802e8849e2ea3.md b/vision-fixhub/court-01/f8da5c777aae3d128bfe7c176288131724f6b2d36b25dc909bc802e8849e2ea3.md
new file mode 100644
index 0000000000000000000000000000000000000000..7360f15abd963a4c29af666a556f613710190f93
--- /dev/null
+++ b/vision-fixhub/court-01/f8da5c777aae3d128bfe7c176288131724f6b2d36b25dc909bc802e8849e2ea3.md
@@ -0,0 +1,120 @@
+Case 9:08-cv-80381-KAM Document 90 Entered on FLSD Docket 05/14/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+
+
+Case 9:08-cv-80381-KAM Document 90 Entered on FLSD Docket 05/14/2009 Page 2 of 5
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRAJ_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/_
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:08-cv-80381-KAM Document 90 Entered on FLSD Docket 05/14/2009 Page 3 of 5
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA
+Plaintift,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09- 80656-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+ORDER CONSOLIDATING CASES FOR PURPOSES OF DISCOVERY AND
+PROCEDURAL MOTIONS THAT RELATE TO MULTIPLE CASES
+THIS CAUSE is before the Court sua sponte.
+In the interests of judicial economy and
+3
+
+
+Case 9:08-cv-80381-KAM Document 90 Entered on FLSD Docket 05/14/2009 Page 4 of 5
+efficiency, it is hereby ORDERED AND ADJUDGED as follows:
+1. The above-styled cases are hereby CONSOLIDATED for purposes of discovery and
+for procedural motions that relate to multiple cases.
+2. Hereinafter, all motions and other court filings that relate to discovery and all
+procedural motions that relate to multiple cases shall be styled with all of the case names and
+numbers, consistent with the styling of this Order, and shall be FILED ONLY IN Jane Doe No.
+2 v. Epstein, case no. 08-80119, which is the lowest-numbered pending case. Any motions styled
+incorrectly or filed in multiple cases will be stricken from the docket for failure to follow the
+Court's Order.
+3. The parties may file separate motions to dismiss, answers to the complaint, summary
+judgment motions, motions in limine and other substantive motions that pertain to their
+individual cases and their individual trials under their individual case styles.
+4. Production of documents by any party or non-party that relate to multiple cases need
+be produced only once.
+5. Defendant is limited to a single deposition of each Plaintiff, during which Defendant
+may depose the Plaintiff as both a party and a witness.
+6. Defendant(s) may be deposed only once.
+7. Any other witnesses common to multiple cases may be deposed only once.
+8. For depositions, Local Rule 26.1 K (limiting deposition time to one day of seven
+hours) is waived so as to allow each party an adequate opportunity to develop fully the record as
+it may relate to that party. However, this waiver shall not be construed as authority for any party
+to take unnecessarily long depositions, or abuse the process. Any abuses of this waiver
+4
+
+
+Case 9:08-cv-80381-KAM Document 90 Entered on FLSD Docket 05/14/2009 Page 5 of 5
+shall result in the imposition of appropriate sanctions against the offending party.
+DONE AND ORDERED in
+Florida, this 14" day of May, 2009
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+Magistrate Judge Linnea R.
+5
diff --git a/vision-fixhub/court-01/f8da5c777aae3d128bfe7c176288131724f6b2d36b25dc909bc802e8849e2ea3.receipt.json b/vision-fixhub/court-01/f8da5c777aae3d128bfe7c176288131724f6b2d36b25dc909bc802e8849e2ea3.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3201b5200e21b709f67ac72e6ab558175af69d49357ac3f1c0a085f9ae83b190",
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diff --git a/vision-fixhub/court-01/f8f0275f31bcaf0def1f8a8ec72aca0c26f5c9f9418f75d5d5a6c95beadad50f.md b/vision-fixhub/court-01/f8f0275f31bcaf0def1f8a8ec72aca0c26f5c9f9418f75d5d5a6c95beadad50f.md
new file mode 100644
index 0000000000000000000000000000000000000000..b3098f085e4311ac1aa0218f37522199bfd136f4
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@@ -0,0 +1,882 @@
+Filing # 197521327 E-Filed 05/02/2024 04:15:44 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+CORRECTED MOTION OF PLAINTIFE CA FLORIDA HOLDINGS, LLC FOR
+LEAVE TO
+DITS COMPLAINT
+Plaintiff CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Motion for
+Leave to Amend its Complaint pursuant to Fla.R.Civ.P. 1.190(a) alleges:
+The Palm Beach Post ("PBP") is a daily community newspaper with offices in West
+Palm Beach, Florida.
+2.
+Since November 2019, PBP has sought to obtain an order allowing the release of
+the 2006 Jeffrey Epstein grand jury transcripts.
+3. 1
+PBP successfully obtained appellate reversal of a final judgment that held the courts
+lack inherent authority to order release of grand jury transcripts. CA Fla. Holdings, LLC v.
+Aronberg, 360 So. 3d 1149 (Fla. 4th DCA 2023).
+4.
+As a result of PBP's litigation, on February 29, 2024, Florida's Governor signed
+bill HB 117 that amended Fla. Stat. section 905.27. A copy of the amended section 905.27, which
+is to take effect on July 1, 2024, is attached hereto as Exhibit A.
+*** FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK. 05/02/2024 04:15:44 PM ***
+
+
+5.
+The amendments to section 905.27 were intended to remove any impediments to
+release of the Jeffrey Epstein grand jury materials. By its terms, and as this Court acknowledged
+in its February 29, 2024 Order, the amended statute provides a remedial process for PBP and the
+public to obtain disclosure of the Epstein grand jury materials.
+6.
+Due to the amendments to section 905.27, and the significant effect they have upon
+PBP's current litigation, PBP requests that it be granted leave to file a Second Amended
+Complaint. A copy of the proposed pleading is attached as Exhibit B.
+If granted leave to amend, the pleadings will conform to the amendments to section
+905.27.
+8.
+Also, due to the dismissal of the State Attorney, the style of the case should be
+amended to delete the State Attorney as a party. References to the current State Attorney in the
+body of the proposed Second Amended Complaint have been removed.
+9.
+As the prior Clerk of the Court has retired, the style should be amended to substitute
+the current Clerk,
+10.
+Abruzzo.
+Because this Court authorized PBP in its February 29, 2024, Order to move for
+reconsideration once the amendments to section 905.27 become effective on July 1, 2024, there is
+no prejudice if leave to amend is granted. The Clerk has publicly stated his support for the section
+905.27
+dments, and he has personally advocated for the release of the Epstein grand jury
+materials, The intervenors have also stated that the Epstein grand jury materials should be
+released.
+WHEREFORE, PBP respectfully requests that this Court grant its motion for leave to
+amend its complaint, permit PBP to file a Second Amended Complaint, and grant such other relief
+the Court deems just and proper.
+2
+
+
+NOT A CER
+3
+Respectfully submitted,
+/s/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+GREENBERG TRAURIG, P.A.
+401 East Las Olas Boulevard, Suite 2000
+Fort Lauderdale, FL 33301
+Tel.: 954.768.8225
+mendelsohns@gtlaw.com
+smithl@gtlaw.com
+MICHAEL J. GRYGIEL
+(Admitted Pro Hac Vice)
+GREENBERG TRAURIG, LLP
+54 State Street, 6th Floor
+Albany, NY 12207
+Tel.: 518,689.1400
+grygielm@gtlaw.com
+NINA D. BOYAJIAN
+(Admitted Pro Hac Vice)
+GREENBERG TRAURIG, LLP
+1840 Century Park East, Suite 1900
+Los Angeles, CA 90067
+Tel.: 310.586.7700
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+Counsel for Plaintiff CA Florida Holdings,
+LLC, Publisher of The Palm Beach Post
+
+
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and accurate copy of the foregoing has been
+electronically filed with the Florida E-File Portal for e-service on all parties of record herein on
+May 2, 2024.
+Is/Stephen A. Mendelsohn
+NOT A CERTIFIED COPY
+4
+ACTIVE 696020069v6
+
+
+NOT A CERTII
+A
+
+
+CHAPTER 2024-7
+Committee Substitute for House Bill No. 117
+In act relating to disclosure of grand jury testimony; amending s. 905.27
+'.S.: revising the list of persons prohibited from disclosing the testimon
+of a witness examined before a grand jury or other evidence it receives
+creating an exception for a request by the media or an interested person to
+the prohibited publishing, broadcasting, disclosing, divulging, or communicating of any testimony of a witness examined before the grand jury, or
+the content, gist, or import thereof; providing criminal penalties; provid
+ing construction; making technical changes; reenacting s. 905.17(1) and
+(2), F.S., relating to who may be present during a session of a grand jury, to
+incorporate the amendment made to s. 905.27, F.S., in references thereto;
+providing an effective date.
+Be It Enacted by the Legislature of the State of Florida:
+Section 1. Section 905.27, Florida Statutes, is amended to read:
+905.27 Testimony not to be disclosed; exceptions.—
+including a grand juror, a state attorney, an assistant state attorney, a
+reporter, a stenographer, or an interpreter, as well as the custodian of a
+grand jury record, may not or any other person appearing before the grand
+jury shall not disclose the testimony of a witness examined before the grand
+jury or other evidence received by it except when required by a court to
+disclose the testimony for the purpose of:
+323E
+(a) Ascertaining whether it is consistent with the testimony given by the
+witness before the court;
+(b) Determining whether the witness is guilty of perjury; or
+) Furthering Justice, which can encompass furthering a public intere
+hen the disclosure is requested pursuant to paragraph (2K
+(2) It is unlawful for any person knowingly to publish, broadcast,
+disclose, divulge, or communicate to any other person, or knowingly to
+cause or permit to be published, broadcast, disclosed, divulged, or communicated to any other person, in any manner whatsoever, any testimony of a
+witness examined before the grand jury, or the content, gist, or import
+thereof, except when such testimony is or has been disclosed in any of the
+following circumstances: a court proeeeding.
+(a) When a court orders the disclosure of such testimony pursuant to
+subsection (1) for use in a criminal case, it may be disclosed to the
+prosecuting attorney of the court in which such criminal case is pending,
+and by the prosecuting attorney to his or her assistants, legal associates, and
+1
+CODING: Words stricken are deletions; words underlined are additions.
+
+
+LAWS OF FLORIDA
+employees, and to the defendant and the defendant's attorney, and by the
+latter to his or her legal associates and employees. However, the grand jury
+testimony afforded such persons by the court can only be used in the defense
+or prosecution of the criminal case and for no other purpose.
+(b) When a court orders the such disclosure of such testimony is ordered
+by a court pursuant to subsection (1) for use in a civil case, it may be
+disclosed to all parties to the case and to their attorneys and by the latter to
+their legal associates and employees. However, the grand jury testimony
+afforded such persons by the court can only be used in the defense or
+prosecution of the civil er criminal case and for no other purpose whatsoever.
+When a court orders the disclosure of such testimony pursuant to
+subsection (1) in response to a request by the media or an interested person,
+regardless of whether that purpose is for use in a criminal or civil case, it
+may be disclosed so long as the subject of the grand jury inquiry is deceased,
+the grand jury inquiry related to criminal or sexual activity between the
+subject of the grand jury investigation and a person who was a minor at the
+time of the alleged criminal or sexual activity, the testimony was previously
+disclosed by a court order, and the state attorney is provided notice of the
+request. This paragraph does not limit the court's ability to limit the
+disclosure of testimony, including, but not limited to, redaction.
+Nothing in This section does not shall affect the attorney-client
+relationship. A client has shall have the right to communicate to his or her
+attorney any testimony given by the client to the grand jury, any matters
+involving the client discussed in the client's presence before the grand jury,
+and any evidence involving the client received by or proffered to the grand
+jury in the client's presence..
+A person who violates Persons convicted of violating this section
+commits shall be guilty of a misdemeanor of the first degree, punishable as
+provided in s. 775.083, or by fine not exceeding $5,000, or both.
+(5) A violation of this section constitutes shall constitute criminal
+contempt of court.
+Section 2.
+For the purpose of incorporating the amendment made by this
+act to section 905.27, Florida Statutes, in references thereto, subsections (1)
+and (2) of section 905.17, Florida Statutes, are reenacted to read:
+905.17 Who may be present during session of grand jury.—
+(1) No person shall be present at the sessions of the grand jury except th
+ritness under examination, one attorney representing the witness for th
+ale her poseis aditin and enturneys, designe tid assiste state attorned
+CODING: Words stricken are deletions; words underlined are additions.
+
+
+LAWS OF FLORIDA
+container not subject to public inspection. The notes, records, and transcriptions are confidential and exempt from the provisions of s. 119.07(1) and s.
+24(a), Art. I of the State Constitution and shall be released by the clerk only
+on request by a grand jury for use by the grand jury or on order of the court
+pursuant to s. 905.27.
+(2)
+The witness may be represented before the grand jury by one
+attorney. This provision is permissive only and does not create a right to
+counsel for the grand jury witness. The attorney for the witness shall not be
+permitted to address the grand jurors, raise objections, make arguments, oi
+otherwise disrupt proceedings before the grand jury. The attorney for the
+witness shall be permitted to advise and counsel the witness and shall be
+subject to the provisions of s. 905.27 in the same manner as all who appear
+before the grand jury. An attorney or law firm may not represent more than
+one person or entity in an investigation before the same grand jury or
+successive grand juries in the same investigation.
+Section 3. This act shall take effect July 1, 202
+Approved by the Governor February 29, 2024.
+Filed in Office Secretary of State February 29, 2024.
+NOT A CERTIF
+CODING:
+Words
+stricken
+are deletions; words underlined are additions.
+
+
+
+$D COPY
+NOT A CERTI
+
+
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-01468-XXXX-MB
+Div.: AG
+V.
+ABRUZZO, as Clerk and
+Comptroller of Palm Beach County, Florida,
+Defendant.
+COPY
+SECOND AMENDED COMPLAINT
+CA Florida Holdings, LLC, publisher of The Palm Beach Post, for its Second Amended
+Complaint against
+Abruzzo, the Clerk of the Court and Comptroller for Palm Beach
+County, Florida, in his official capacity ("Court Clerk"), alleges as follows:
+JURISDICTION
+This is an action within the exclusive jurisdiction of the Circuit Court pursuant to
+Fla. Stat. Sections 26.012(2)(a) and 86.011 et seq.
+PARTIES
+2.
+The Palm Beach Post is a daily community newspaper published by Plaintiff CA
+Florida Holdings, LL.C, with offices located at 2751 S. Dixie Highway, West Palm Beach, Florida.
+Defendant
+Abruzzo is the duly elected Clerk and Comptroller of Palm
+Beach County, Florida. He is sued herein in his official capacity as his office is in possession
+and/or control of documents that are the subject of this action.
+
+
+INTRODUCTION
+In what is now widely if belatedly recognized as a colossal miscarriage of justice -
+which led to the further needless victimization of countless young girls and women - a wealthy,
+politically connected, and powerful financier was not held accountable for, nor even forced to
+confront, allegations of serious sex trafficking crimes. While it is clear that Jeffrey Epstein's 2008
+deal with the State of Florida was not consistent with the evidence gathered against him, what
+remains shrouded in mystery is how that evidence was presented - and the extent to which it was
+presented - to the grand jury that returned an indictment far more limited in scope than expected
+and deserved.
+5.
+Through this action, The Palm Beach Post seeks public access to the testimony,
+minutes, and other evidence presented in 2006 to the Palm Beach County grand jury empaneled
+during the first Epstein sex abuse investigation Typically, access to such materials is limited, for
+example, in order to prevent the flight of those whose indictment may be contemplated and their
+ability to conceal or destroy evidence; to ensure jurors' candor in deliberations; and to protect an
+accused who is later exonerated. However, these factors are inapplicable here. Also, Florida law
+expressly authorizes the disclosure of grand jury proceedings under certain circumstances,
+including, as here, in furthering justice, which can encompass furthering a public interest. Fla. Stat.
+§ 905.27(1)(c).
+It can no longer credibly be maintained that continued blanket secrecy over the
+proceedings that led to the egregiously flawed 2006 Epstein indictment is warranted under the law.
+To the contrary, transparency is required to promote public understanding of the criminal justice
+system and public confidence in the fair administration of justice. As detailed below, Epstein was
+accused of sexually abusing and trafficking dozens of women and girls in south Florida (among
+other locations) over a period of several years while exploiting his wealth and political connections
+2
+
+
+to obstruct the administration of justice at every turn. Public disclosure of the Epstein grand jury
+proceedings will shed light on the extent to which those in our government entrusted with the
+solemn responsibility of enforcing our criminal laws equally as to all citizens fulfilled their duties
+in this instance. Justice will be furthered where it is either (1) demonstrated that Epstein was treated
+like others accused of similar heinous crimes, or (2) as appears more likely to be the case, those
+who chose to give Epstein favorable - "unusual," in the words of the Town of Palm Beach Police
+Chief - treatment, are exposed and held accountable. From what limited information is now in the
+public domain, the State Attorney's referral of Epstein's case to the grand jury - which would be
+out of the ordinary for this type of case - gives rise to a strong inference of favoritism and
+corresponding disregard for the rights of the minor victims of Epstein's sex trafficking. Access to
+the grand jury materials will allow the public to determine whether the grand jury process, and the
+secrecy that comes with it, was used to further justice or, instead, operated to shield Epstein and
+his co-conspirators from the consequences of their criminal activities. Accordingly, Fla. Stat.
+Section 905.27 authorizes the disclosure of Epstein's 2006 grand jury proceedings.
+FACTUAL BACKGROUND
+The following facts were gathered, in large part, from documents obtained by The
+Palm Beach Post through various Florida Public Records Law requests, documents unsealed or
+publicly available in other related judicial proceedings, and information and documents in the
+public record.
+A.
+First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement:
+2005—2008.
+The investigation into Epstein's sex crimes began more than fourteen years ago,
+when a 14-year-old girl's stepmother reported to police in the Town of Palm Beach, Florida, that
+Epstein and others who worked for him arranged for her to give Epstein a "massage." Epstein
+3
+
+
+required the girl to strip, exposed himself, and masturbated while touching her. The girl was paid
+$300. Epstein was 52 years old at the time.
+9.
+Following this initial report in 2005, the Town of Palm Beach Police, and later, in
+2006, the FBI, investigated Epstein. Interviews under oath with five additional alleged victims and
+seventeen witnesses revealed that the events described by the 14-year-old girl occurred, with
+disturbingly similar details, with each of the other victims.
+10.
+Both the victim/witness interviews, as well as evidence retrieved following a search
+of Epstein's home, showed that some of the girls involved were under the age of 18. The police
+search of Epstein's residence also found two hidden cameras and, throughout the house, large
+numbers of nude photos of girls, including victims whom the police had not interviewed in the
+course of their investigation.
+11.
+In March 2006, a State grand jury was scheduled at which all of the victims were
+expected to testify. The proceeding was postponed, however, due to meetings between the State
+Attorney's office and Epstein's prominent criminal defense lawyer and personal friend, Alan
+Dershowitz.
+12.
+to begin receiving evidence.
+Another grand jury was convened in April 2006, but canceled the day before it was
+(1) Police Chief Reiter's Letter to the State Attorney.
+43.
+On May 1, 2006, Town of Palm Beach Police Chief Michael Reiter wrote a
+"personal and confidential" letter to then Palm Beach County State Attorney, Barry Krischer,
+stating:
+I must renew my prior observation to you that I continue to find your office's
+treatment of [the Epstein] cases highly unusual. It is regrettable that I am forced to
+communicate in this manner, but my most recent telephone calls to you and those
+of the lead detective to your assigned attorneys have been unanswered and
+messages remain unreturned. After giving this much thought and consideration, /
+4
+
+
+must urge you to examine the unusual course that your office's handling of this
+matter has taken and consider if good and sufficient reason exists to require your
+disqualification from the prosecution of these cases. (Emphasis supplied)
+14.
+Chief Reiter's letter to State Attorney Krischer enclosed the Town of Palm Beach
+Police Department's probable cause affidavits charging Epstein and two of his assistants with
+multiple counts of unlawful sex acts with a minor and one count of sexual abuse, and requested
+that either an arrest warrant be issued for Epstein or the State Attorney directly initiate the charges
+against him, which would be public.
+15.
+(2) The July 2006 State Grand Jury Presentation
+Instead, State Attorney Krischer elected to refer the case to a grand jury, which is
+mandatory for capital cases but rarely used for all other crimes. According to an official
+spokesperson, this was the first time that a sex crimes case was presented to a grand jury in Palm
+Beach County.
+16.
+In July 2006, after State Attorney Krischer presented testimony and evidence from
+one victim, the grand jury returned an indictment on a sole count of solicitation of prostitution.
+There is no mention in the indictment of the vietim being a minor.
+On information and belief, a second of Epstein's victims was supposed to testify
+before the grand jury, but was unable to attend because of a school exam.
+18.
+No reasonable explanation has been provided as to why the numerous other known
+victims were not presented as witnesses and crime victims to the grand jury convened in July 2006.
+Nor has any reasonable explanation been provided as to why State Attorney Krischer, who was
+initially eager to investigate and prosecute Epstein for his crimes, over time lost the desire to do
+SO.
+19.
+On information and belief, during the grand jury appearance of the single victim
+who testified, the State Attorney presented evidence that vilified the victim and attacked her
+5
+
+
+credibility, including soliciting testimony regarding underage drinking and questionable personal
+behavior that was unrelated to the charges against Epstein. Further upon information and belief,
+this information was initially brought to the attention of the State Attorney's office by Epstein's
+defense counsel.
+20.
+(3) The FBI's Investigation and Epstein's Non-Prosecution
+Agreement With Federal Authorities.
+On information and belief, following the deficient July 2006 indictment, and with
+Chief Reiter's encouragement, the FBI began its own investigation of Epstein.
+21.
+Records unsealed in 2015 revealed that the FBI compiled reports on "34 confirmed
+minors" that were victims of Epstein's sexual predations. Based on evidence gathered by the FBI,
+a 53-page indictment was prepared by the U.S. Attorney's Office in June 2007. However, at the
+request of Epstein's lawyers, the indictment was never presented to a federal grand jury.
+22.
+Instead, then U.S. Attorney for the Southern District of Florida, Alexander Acosta,
+negotiated a plea deal with Epstein's team of lawyers to grant immunity to Epstein (along with
+four named co-conspirators and any unnamed potential co-conspirators) from all federal criminal
+charges.
+23.
+Throughout the remainder of 2007 and through the first half of 2008, Epstein's
+lawyers and the U.S. Attorney continued negotiating the plea arrangement. Upon information and
+belief, Epstein's lawyers insisted that (1) the victims not be notified, (2) the deal be kept
+confidential and under seal, and (3) all grand jury subpoenas (including one that had already been
+issued for Epstein's computers) be withdrawn.
+24.
+On June 30, 2008, Epstein pled guilty to State charges: one count of solicitation of
+prostitution and one count of solicitation of prostitution with a minor under the age of 18. He was
+6
+
+
+sentenced to 18 months in jail, followed by a year of community control or house arrest, and was
+adjudicated as a convicted sex offender required to register twice a year in Florida.
+25.
+The plea deal, called a non-prosecution agreement ("NPA"), allowed Epstein to
+receive immunity from federal sex-trafficking charges that could have sent him to prison for life.
+On information and belief, based on public records, former State Attorney Krischer communicated
+with then U.S. Attorney Acosta concerning the NPA's negotiation with Epstein's lawyers.
+26.
+Indeed, Epstein was not incarcerated in a Florida prison for the State crimes for
+which he was convicted. Instead, he was placed in a private wing of the Palm Beach County
+Stockade, where, after 3 12 months, he was allowed to leave the jail on "work release" for up to
+12 hours a day, 6 days a week. His private driver provided his transportation to and from "work."
+27.
+Epstein was released five months early.
+28.
+Upon information and belief, Epstein violated the terms of his probation, but was
+not prosecuted.
+29.
+(4) The Crime Victims' Rights Act Litigation.
+Epstein's victims only learned after the fact about his plea in State court and filed
+an emergency petition to force federal prosecutors to comply with the Crime Victims' Rights Act
+(18 U.S.C. § 3771, CVRA'), which mandates certain rights for crime victims, including the right
+to be informed about plea agreements and the right to appear at sentencing. U.S. District Judge
+Kenneth A. Marra recently ruled that federal prosecutors violated the CVRA by failing to notify
+Epstein's victims before allowing him to plead guilty to only the two State offenses.
+30.
+The prosecution's failure to keep the victims apprised, among other things, also
+contravenes the Florida Constitution, Article 1, § 16(b) and Fla. Stat. § 960.001.
+31.
+Following publicity exposing the extraordinary leniency of the plea deal, dozens of
+civil suits were brought against Epstein, most of which Epstein's lawyers settled out-of-court.
+7
+
+
+32.
+In 2010, Epstein was registered as a "level three" (i.e., high risk of repeat offense)
+sex offender in New York, a lifelong designation. In 2011, the New York County District
+Attorney's office unsuccessfully sought to lower his registration to low-risk "level one."
+33.
+Upon information and belief, during the course of the Town of Palm Beach and FBI
+investigations, Epstein retained private investigators to follow, harass, and photograph his victims
+and their families, as well as Chief Reiter and the Town of Palm Beach detective who investigated
+the case against Epstein.
+34.
+Upon information and belief, Epstein's victims were threatened against cooperating
+with law enforcement and told that they would be compensated only if they did not cooperate with
+law enforcement.
+B.
+Second Epstein Sex Crimes Investigation, Indictment, Suicide: 2019.
+35. On July 6, 2019, Epstein was arrested on federal sex trafficking charges.
+36.
+Upon information and belief, the United States government's investigation of new
+allegations and charges stemmed, in part, from continued press investigations into and reporting
+on the mishandling of the 2006 charges and the civil suits that followed.
+37.
+In a July 8, 2019, letter to the federal district court by the U.S. Attorney for the
+Southern District of New York, Epstein was described as "a serial sexual predator who preyed on
+dozens of minor girls over a period of years." The letter emphasized that "the Government has real
+concerns — grounded in past experience with this defendant - that if allowed to remain out on bail,
+the defendant could attempt to pressure and intimidate witnesses and potential witnesses in this
+case, including victims and their families, and otherwise attempt to obstruct justice." It also
+described the results of the FBI's search of Epstein's Manhattan townhouse: evidence of sex
+trafficking in the form of "hundreds - and perhaps thousands - of sexually suggestive photographs
+of fully- or partially-nude females," including underage females. In a locked safe, compact discs
+8
+
+
+were found with handwritten labels including the descriptions: "Young [Name] + [Name]," "Misc
+nudes 1," and "Girl pies nude."
+38.
+On July 8, 2019, prosecutors with the Public Corruption Unit of the U.S. Attorney's
+office for the Southern District of New York charged Epstein with sex trafficking and conspiracy
+to traffic minors for sex. The grand jury indictment alleges that "dozens" of underage girls were
+brought into Epstein's mansions for sexual encounters. A few days later, owing to public outery
+over the NPA with Epstein entered into by the U.S. Attorney for the Southern District of Florida,
+Alexander Acosta, who by then was serving as U.S. Secretary of Labor in the Trump
+Kabor in the Trump
+administration, resigned from office.
+39.
+Epstein was denied bail and was placed into pretrial detention at the federal
+Metropolitan Correction Center in lower Manhattan,
+40.
+On or about August 6, 2019, Florida Gov. Ron DeSantis ordered a state criminal
+probe into the actions of the Palm Beach Sheriff and former State Attorney Krischer for their
+handling of the Epstein underage sex trafficking case.
+On August 10, 2019, Epstein was found dead in his cell at the Metropolitan
+Correctional Center. His cause of death was determined to be suicide.
+The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+42.
+On account of his death, prosecutors sought to dismiss the indictment against
+Epstein, while maintaining that they would continue to investigate his co-conspirators.
+43.
+United States Senior District Judge Richard M. Berman ordered a hearing on
+August 27, 2019, on the prosecutors' decision to dismiss the indictment and allowed victims to
+speak at the hearing.
+9
+
+
+44.
+In the course of the hearing, more than two dozen victims delivered their personal
+stories of pain, frustration, and sexual abuse at the hands of Epstein. Several victims spoke of
+violent rape by Epstein. Many more victims were present in the courtroom but did not testify.
+45.
+While some questioned the reasoning behind the court's decision to give the victims
+voice after Epstein's death, District Judge Berman noted that "a public hearing is [the] preferred
+vehicle of resolution," emphasizing that "public hearings are exactly what judges do. Hearings
+promote transparency and they provide the court with insights and information which the court
+may not otherwise be aware of." Indeed, even Epstein's defense lawyer noted at the hearing that
+the court "is the institution that most people have confidence in, in these very troubled times."
+46.
+At the August 27th hearing, the girls, now women, spoke about their "exploitation
+and coercion," and to the fact that many of them "were in very vulnerable situations and in extreme
+poverty, circumstances where [they] didn't have anyone on [their] side, to speak on [their]
+behalf....
+." One victim lamented that "as a victim, [she] never got to see what the agreement was
+or why the special treatment got approved" in the Florida case years earlier. Another noted how
+"completely different" the investigators leading to the 2019 federal indictment were from the
+prosecutors in the Florida case, both in their treatment of her and their investigation of her
+victimization by Epstein.
+47.
+A former federal judge in attendance at the August 27th hearing emphasized that
+"transparency is one of the overriding objectives in our criminal justice system."
+48.
+Nearly all of the victims expressed the conviction that the secrecy that shielded
+Epstein has caused them "irreparable harm" and that an opportunity to address his criminal
+wrongdoings, and those of the individuals who enabled his sexual racketeering, would allow for
+at least some measure of justice to be served after his death. Indeed, one victim stated: "Any efforts
+10
+
+
+made to protect Epstein's name and legacy send a message to the victims that he wins and that he
+is untouchable." Another victim expressed fear that this is a world "where there are predators in
+power, a world where people can avoid justice if their pockets run deep enough." In short, the
+"unusual" treatment Epstein received in Florida in 2006 based on his wealth, social status, and
+connections severely eroded the public's faith in the integrity and impartiality of the criminal
+justice system.
+D.
+The Palm Beach Post's Standing and the Public Interest.
+(1) The Palm Beach Post Has Reported Extensively On
+Epstein's Crimes For Nearly 15 Years.
+49.
+Plaintiff, The Palm Beach Post, is a community newspaper serving readers in Palm
+Beach County and the Treasure Coast vicinity.
+50.
+The Palm Beach Post has been a Pulitzer Prize winner and nominated as a finalist
+three other times.
+51.
+Beginning in 2004, The Palm Beach Post has extensively investigated and reported
+on the allegations against, the law enforcement investigation of, and the crimes committed by,
+Epstein and his co-conspirators. The Newspaper's reportage has included publication of the
+following articles:
+• "Then Who Had Everything: Jeffrey Epstein Craved Big Homes, Elite Friends
+and, Investigators Say, Underage Girls.," published on August 14, 2006, reporting that:
+Haley Robson, a local community college student, admitted in a sworn statement to
+police that "she had taken at least six girls to visit Epstein, all between the ages of 14
+and 16;" Palm Beach Police "interviewed five alleged victims and 17 witnesses;"
+*Dershowitz, the Harvard law professor, traveled to West Palm Beach with information
+about the girls," including social media discussions about "their use of alcohol and
+marijuana;" after meeting with Epstein's legal team, "prosecutors postponed their
+decision to take the case to a grand jury;" Palm Beach Police subsequently "received
+complaints that two of the victims or their families had been harassed or threatened;"
+"relations between police and prosecutors were fraying" as the investigation continued;
+and "one girl who was subpoenaed - the one who said she had sexual intercourse with
+Epstein - never showed up" to testify before the grand jury.
+11
+
+
+• "Trump Snags Gosman Estate for S41 Million" published on November 16, 2004,
+reporting on the bidding war between Donald Trump and Jeffrey Epstein for the
+purchase of a "43,000-square-foot, seven-bedroom estate on 6 oceanfront acres along
+the storied 'Raider's Row' " in Palm Beach.
+• "Indictment: Billionaire Solicited 3 Times" published on July 25, 2006, reporting that
+"Billionaire money manager and Palm Beach part-time resident Jeffrey Epstein
+solicited or procured prostitutes three or more times between Aug. 1 and Oct. 31 of last
+year, according to an indictment charging him with felony solicitation of prostitution."
+The article further reported that "Epstein's case is unusual in that suspected prostitution
+johns are usually charged with a misdemeanor, and even a felony charge is typically
+made in a criminal information - an alternative to an indictment charging a person with
+the commission of a crime."
+• "After Long Probe, Billionaire Faces Solicitation Charge" published on July 26, 2006,
+reporting that "Palm Beach police thought there was probable cause to charge Epstein
+with unlawful sex acts with a minor and lewd and lascivious molestation." The article
+further reported that "Police Chief Michael Reiter was so angry with State Attorney
+Barry Krischer's handling of the case that he wrote a memo suggesting the county's
+top prosecutor disqualify himself," and identified a 20-year-old on-the-record female
+source who said "she gave Epstein a ssage in thé nude, then brought him six girls,
+ages 14 to 16, for massage and sex-tinged sessions at his home."
+• "Police Say Lawyer Tried to Discredit Teenage Girls" published on July 29, 2006,
+reporting that "[f]amed Harvard law professor Alan Dershowitz met with the Palm
+Beach County State Attorney's Office and provided damaging information about
+teenage girls who say they gave his client, Palm Beach billionaire Jeffrey Epstein,
+sexually charged massages" and that "[t]he state attorney's office said it presented the
+Epstein case to a county grand jury this month rather than directly charging Epstein
+because of concerns about the girls' credibility."
+• "Expert: Ignorance of Age Isn't Defense In Sex Cases" published on August 5, 2006,
+reporting that "[lather than file charges, the state attorney's office presented the case
+to a county grand jury" which "indicted Epstein last week on a single, less serious
+charge of felony solicitation of prostitution," and that "It]he case raised eyebrows
+because the state attorney's office rarely, if ever, kicks such charges to a grand jury."
+• "Epstein Camp Calls Female Accusers Liars" published on August 8, 2006, reporting
+that "[a] state attorney's spokesman would say only that the office refers cases to the
+grand jury when there are issues with the viability of the evidence or witnesses'
+credibility."
+• "Palm Beach Chief Focus of Fire In Epstein Case" published on August 14, 2006,
+reporting that Chief Reiter "pressed for Epstein to be charged with the more serious
+crimes of sexual activity with minors" and "slammed State Attorney Barry Krischer in
+blunt language seldom used by one law enforcement official with another because of
+what he perceived as that office's mishandling of the case."
+12
+
+
+• "Delays In Epstein Case Unusual, Lawyers Say" published on March 13, 2007,
+reporting that "[n]early eight months after Palm Beach tycoon Jeffrey Epstein was
+charged with felony solicitation of prostitution, there has been no discernible progress
+in his case."
+• "Woman Sues Billionaire Investor, Says They Had Sex When She Was 16" published
+on October 18, 2007, reporting on a lawsuit brought in New York State court against
+Epstein "by a young woman who says he had sex with her when she was 16 and had
+sought his help becoming a model."
+• "Palm Beacher Pleads In Sex Case" published on July 1, 2008, reporting that "Epstein,
+55, pleaded guilty ... to felony solicitation of prostitution and procuring a person under
+the age of 18 for prostitution," resulting in "a lifelong obligation to register as a sex
+offender," and that "[a]s part of the plea deal, federal investigators agreed to drop their
+investigation of Epstein, which they had taken to a grand jury."
+• "Jeffrey Epstein: Scientist, Stuntman, 'Sex Slave' Visit Jailed Tycoon" published on
+August 13, 2008, reporting that "[dJuring his first month of confinement" Epstein was
+visited by
+, who allegedly escorted victims upon their arrival at his Palm
+Beach waterfront home to an upstairs room, where she prepared the massage table and
+provided the oils for their encounters" with Epstein, and by
+*a
+young woman whom Epstein purportedly described as his Yugoslavian sex slave.
+• "Billionaire Sex Offender Leaves Jail Six Days a Week For Work" published on July
+1, 2008, reporting that Epstein "is allowed to leave the Palm Beach County Stockade
+six days a week on a work-release program."
+• "Women Want Epstein Sex Plea Deal Unsealed" published on June 10, 2009, reporting
+that attorneys for women suing Epstein in various courts "want his [non-prosecution]
+agreement [NPA] with federal prosecutors unsealed" and were moving to unseal the
+agreement in Circuit Court of the Fifteenth Judicial Circuit, and that "Epstein now faces
+at least a dozen civit lawsuits in federal and state courts filed by young women who
+said they had sex with him and now are seeking damages." On that date, The Palm
+Beach Post moved to intervene in the matter for the purpose of obtaining public access
+to the NPA, which was ordered disclosed by this Court on June 25, 2009.
+•
+Epstein's Secret Pact With Feds Reveals 'Highly Unusual' Terms" published on
+September 19, 2009, reporting that, owing to Epstein's non-prosecution agreement,
+Yfederal prosecutors backed down and agreed to recall grand jury subpoenas if Epstein
+pleaded guilty to prostitution-related felonies in state court" and "also agreed not to
+charge any of Epstein's possible co-conspirators:
+1, Lesley
+Groff and
+" The article further reported that, according to an
+attorney representing three of Epstein's victims, "none of the 30 to 40 wom[e]n
+identified as victims in the federal investigation" were informed ahead of time about
+the NPA.
+13
+
+
+• "Judge Rules Epstein Attorneys Can Subpoena Abortion Records" published on
+January 27, 2010, reporting that "a judge ...gave lawyers representing multimillionaire sex offender Jeffrey Epstein the right to subpoena abortion records from
+women who are seeking millions in damages from the part-time Palm Beach resident."
+• "Epstein Journal's Findings Could Resurrect Abuse Case" published on March 20,
+2010, reporting that "[a] purloined journal that is said to contain the names of
+"hundreds' of victims of convicted sex offender Jeffrey Epstein could be used to reopen
+the investigation into the multi-millionaire's appetite for teenage girls."
+• "Epstein Paid Three Women $5.5 Million to End Underage Sex Lawsuits" published
+on October 4, 2017, reporting that, according to court documents, Epstein "shelled out
+$5.5 million to settle lawsuits with three of more than two dozen teens who sued him."
+• "Judge Rules Feds' Agreement With Jeffrey Epstein Pact Violated Teen Victims'
+Rights" published on February 22, 2019, reporting on a ruling by U.S. District Judge
+Kenneth Marra that "Federal prosecutors violated the rights of Jeffrey Epstein's
+teenage victims [under the Crime Victims' Rights Act] by failing to reveal they had
+dropped plans to prosecute the billionaire on dozens of federal charges in connection
+with the girls' claims that he paid them for sex at his Palm Beach mansion."
+• "Epstein Indicted On Sex Charges/Part-Time Palm Beacher Pleads Not Guilty to Sex
+Trafficking, Conspiracy Charges In Federal Court In Manhattan" published on July 9,
+2019, reporting on Epstein's appearance in U.S. District Court for the Southern District
+of New York in which he "pleaded not guilty to charges accusing him of creating a vast
+network of girls as young as 14 that he exploited for his sexual pleasure at his homes
+in Palm Beach and
+Inhattan.
+A true and correct copy of the above news articles, in either the computerized format in which they
+are maintained in The Palm Beach Post's electronic archives or the news print edition in which
+originally published, is annexed hereto as Exhibit 1.
+52.
+Since the filing of the initial Complaint in this matter, The Palm Beach Post-along
+with media worldwide - has continued to report on Epstein's crimes and the ongoing official
+proceedings resulting from those crimes.
+(2) The Palm Beach Post's Standing and the Public Interest.
+53. The press has a constitutional right of access to criminal proceedings, see, e.g.,
+Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573 (1980), including pre-trial criminal
+proceedings.
+v. Graddick, 696 F.2d 796 (11th Cir. 1983). Indeed, "the integrity of the
+14
+
+
+judicial process, which public scrutiny is supposed to safeguard, is just as much at issue in
+proceedings of this kind [pre- and post-trial] as at trial." Id. at 801; see also Miami Herald Publ
+Co. v.
+426 So. 2d 1, 6-7 (Fla. 1982) (identifying the news media as a "public surrogate" in
+matters concerning the closure of judicial proceedings). The press also has a First Amendment
+interest in receiving information from willing speakers. See Va. Pharmacy Bd. v. Va. Consumer
+Council, 425 U.S. 748, 756-57 (1976) ("Where a speaker exists ... the protection afforded [by
+the First Amendment] is to the communication, to its source and to its recipients both."); Pittman
+1, 267 F.3d 1269, 1283 n.12 (11th Cir. 2001) ("The Supreme Court has récognized that the
+First Amendment offers protection to both speakers and those wishing to receive speech."); see
+also Stephens v. Cty. of Albemarle, Va., 524 F.3d 485, 492 (4th Cir, 2008) (providing that a plaintiff
+has "standing to assert a right to receive speech" by "Show[ing) that there exists a speaker willing
+to convey the information to her").
+54. Because of the unique role performed by the press as a "public surrogate" (I
+426 So. 2d at 6-7) in protecting the right offaccess and its interest in reporting information about
+criminal proceedings, news organizations "presumptively have a right to access judicial records,"
+Comm'r, Ala. Dep't of Cortex. Advance Local Media, LLC, 918 F.3d 1161, 1166 (11th Cir. 2019),
+and "standing to question the validity of an order restricting publicity because its ability to gather
+news is directly impaired or curtailed." l
+426 So. 2d at 4; see also Carlson v. United States,
+837 F.3d 753, 757-58 (7th Cir. 2016) ("[a]s a member of the public, [the Reporters Committee]
+has standing to assert [its] claim" to grand jury materials because such materials are "public records
+to which the public may seek access, even if that effort is ultimately unsuccessful").
+55.
+Here, the continued denial of access to information The Palm Beach Post seeks on
+behalf of its journalists and the public it serves "unquestionably constitutes irreparable injury."
+15
+
+
+Gainesville Woman Care, LLC v. State of Florida, 210 So. 3d 1243, 1263 (Fla. 2017); see also
+Zerilli v.
+656 F.2d 705, 711 (D.C. Cir. 1981) (noting that "the press" function as a vital
+source of information is weakened whenever the ability of journalists to gather information is
+impaired," as it is by Attorney General's refusal to disclose unredacted report and underlying grand
+jury materials).
+56.
+The Palm Beach Post has the right to maintain this private right of action because
+the furtherance of justice, an express legislative exception to grand jury seerecy, is intended for
+the public benefit, and The Palm Beach Post seeks access on behalf of the public. Fla. Stat.
+§ 905.27(1)(c). It is further expressed in Fla. Stat. § 905.27 that the legislature in amending Fla.
+Stat. § 905.27(1)(c) and (2)(c) in 2024, intended for this to disclose the Jeffiey Epstein grand jury
+materials. In other words, the legislature cleared all arguments against release of the Jeffrey Epstein
+grand jury materials.
+(3) The Court's Jurisdiction To Declare Rights And
+Construe Statutes.
+57.
+This Court has jurisdiction to declare rights, status, and other equitable or legal
+relations whether or not further relief is or could be claimed. Florida Stat. Section 86.011.
+58.
+Florida law specifically provides that a declaration may be sought from the Court
+concerning a petitioner's rights under a statute. Florida Stat. Section 86.021 (Any person... whose
+rights, status, or other equitable or legal relations are affected by a statute, or any regulation made
+under statutory authority,.... may have determined any question of construction or validity arising
+under such statute,.. or any part thereof, and obtain a declaration of rights, status, or other equitable
+or legal relations thereunder.").
+59.
+The Court's exercise of its power to declare rights "is to be liberally administered
+and construed." Florida Stat. Section 86.101.
+16
+
+
+COUNT!
+(Declaratory Relief - Florida Stat. Sections 86.011 et seq.)
+60.
+The allegations set forth in paragraphs 1 through 59 are incorporated by reference
+as if fully set forth herein.
+61.
+This is an action for Declaratory Relief pursuant to Chapter 86, Florida Statutes,
+and other supplemental relief.
+62.
+The Palm Beach Post respectfully requests that the Court deelare pursuant to Fla.
+Stat. Sections 905.27(1) and (2)(c) that it is entitled access to the testimony, minutes, and other
+evidence presented in 2006 to the Palm Beach County grand jury because such disclosure and
+access would be furthering justice in the public interest. Fla. Stat. § 905.27(1)(c).
+63.
+The Palm Beach Post has sought access to the testimony, minutes, and other
+evidence presented in 2006 to the Palm Beach County grand jury. A good-faith dispute exists.
+64.
+Through this Complaint, The Palm Beach Post presently has a justiciable question
+concerning its rights to obtain the 2006 grand jury materials pursuant to Fla. Stat. Sections
+905.27(1) (c) and (2)(c).
+65.
+In an appeal from the final judgment entered on December 21, 2022 in this case,
+the Fourth Distrior Court of Appeal reversed the trial court's decision that Florida courts lack
+authority to order the release of grand jury materials. Rejecting the trial court's determination, the
+appellate court held that trial courts have inherent authority over grand juries and have the right to
+order release of grand jury materials if such would further justice as defined in Fla. Stat. section
+905.27. CA Fla. Holdings, LLC v. Aronberg, 360 So. 3d 1149 (Fla. 4"* DCA 2023). Therefore, this
+court has inherent authority to release the Epstein grand jury materials in addition to the statutory
+authority granted by the 2024 amendments to Fla. Stat. section 905.27.
+17
+
+
+66.
+A bona fide, actual, present, and practical need for the declaration exists in order to
+further justice in the public interest by the release of the 2006 Epstein grand jury materials.
+WHEREFORE, The Palm Beach Post respectfully requests that the Court determine the
+rights and obligations of the parties by declaring that pursuant to Fla. Stat. Sections 905.27(1)(c)
+and (2)(c). The Palm Beach Post and the public may gain access to the testimony.
+COUNT HI
+67.
+(Florida Stat. Section 905.27)
+The allegations set forth in paragraphs 1 through 66 are incorporated by reference
+as if fully set forth herein.
+68.
+Based on information learned by The Palm Beach Post through its Florida Public
+Records Law requests, law enforcement sources with direet knowledge of the grand jury evidence
+and proceedings, judicial documents obtained from independent but related court proceedings, and
+documents otherwise available in the public record, the 2006 State Attorney for Palm Beach
+County, Barry Krischer, presented truncated evidence of Epstein's criminal wrongdoing to the
+2006 grand jury in a manner that precluded Epstein's indictment for the serious crimes he
+committed, including sex trafficking and sexual assault.
+69. Pursuant to Florida Stat. Section 905.27, as amended in 2024, in order to further
+justice for Epstein's victims and the public, and to provide public disclosure to illuminate whether
+Epstein received unjustifiably lenient treatment based on the available evidence, The Palm Beach
+Post requests that it and the public be granted immediate access to the testimony, minutes, and
+other evidence presented in 2006 to the Palm Beach County grand jury.
+70.
+In 2024, the Florida legislature amended Fla. Stat. Sections 905.27 (1)(c) and (2)(c)
+for the express purpose of removing all legal impediments to the release of the Jeffrey Epstein
+18
+
+
+grand jury materials. Therefore, other than for limited redactions to protect witness and vietim
+identities, Fla. Stat. Sections 905.27 (1)(c) and (2)(c) compel disclosure of the Epstein 2006 grand
+jury materials.
+WHEREFORE, The Palm Beach Post respectfully requests that this Court, pursuant to Fla.
+Stat. Sections 905.27(1)(c) and (2)(c), as amended, order the Clerk of the Court to provide copies
+of the testimony, minutes, and other evidence presented in 2006 to the Palm Beach County grand
+jury during the first Epstein sex abuse investigation so that, following an in camera inspection,
+these materials are immediately disclosed to the newspaper, and grant any other and further
+equitable or legal relief the Court deems just and proper.
+Dated:
+- 2024
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LL.C,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+NOT A
+By: Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+FLService@gtlaw.com
+By: Is/ Michael J Grygiel
+MICHAEL J GRYGIEL
+(Pro Hac Vice application forthcoming)
+54 State Street, 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+19
+
+
+Nina D. Boyajian
+NINA D. BOYAJIAN
+(Pro Hac Vice application forthcoming)
+1840 Century Park East, Suite 1900
+Los Angeles CA 90067
+Telephone: (310) 586 - 7700
+Facsimile: (310) 586 - 7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+NOT A CERTIFIED COPY
+20
\ No newline at end of file
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+Case 1:19-cv-08673-KPF-DCF Document 1
+Filed 09/18/19
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Case No.
+Plaintiff,
+JURY TRIAL DEMANDED
+DARREN K. INDYKE and RICHARD D.
+KAHN, in their capacities as the executors of the
+ESTATE OF JEFFREY E. EPSTEIN,
+Defendants.
+COMPLAINT
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 2 of 16
+Plaintiff Jane Doe ("Doe" or "Plaintiff") alleges, upon personal knowledge and
+information and belief, as follows:
+INTRODUCTION
+Jeffrey Epstein ("Epstein") was one of the world's most powerful, prolific, and
+notorious pedophiles. For years, he exploited and sexually assaulted dozens if not hundreds of
+young vulnerable girls for his personal satisfaction. He molested, fondled, and raped them,
+luring them to his home under the pretext that they would be giving him a "massage," and then
+slowly escalated his abuse. He paid what was for them much needed, life-changing amounts of
+money so that they would return to him and he could continue his cycle of exploitation and
+abuse.
+A successful businessman, Epstein applied all of his finely honed skills to
+acquiring access to more and more young girls. His staff provided a seemingly endless series of
+children who would come to his home-
+—often multiple girls at the same time. The girls would
+sit in a waiting room while Epstein finished assaulting the child who came before them. In just
+one day, Epstein would sexually assault multiple girls in his private, well-guarded homes. And,
+at least from in or around 2002 to in or around 2005, Epstein did so regularly. Each girl was paid
+by Epstein or his staff.
+3.
+Plaintiff Jane Doe is one of Epstein's many victims. She met him when she was
+fourteen years old or younger, in or around 2002. For the following three years, Epstein
+routinely abused and exploited Doe at his home in New York City.
+4.
+In July 2019, Epstein was arrested and charged for his abuse of Doe and others in
+an indictment filed by the United States Attorney's Office for the Southern District of New York
+(the "Indictment"). As alleged in the Indictment, over the course of many years, Epstein
+sexually exploited and abused dozens of minor girls at his homes in New York City, Palm
+2
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 3 of 16
+Beach, Florida, the U.S. Virgin Islands, and other locations. Upon information and belief,
+Plaintiff Jane Doe is the person described as "Minor Victim-I" in the Indictment.
+5.
+Not surprisingly, Epstein's abuse of Doe has forever scarred her and altered her
+life. As a result of his abuse, Doe never received a high school education. She suffers from
+post-traumatic stress disorder, anxiety, and depression. Her severe emotional injuries manifest in
+myriad ways: she often finds herself crying; she is unable to form healthy emotional
+relationships with men; she often cannot sleep through the night or fall asleep at all; she has
+panic attacks; and she is constantly afraid for her young daughter.
+6.
+Epstein, by contrast, was able to operate his brazen sex trafficking scheme with
+relative impunity for most of his life. He used his money and connections to ensure that he and
+his co-conspirators would never face true justice for their heinous crimes. And, now, with his
+reported suicide on August 10, 2019, Epstein cannot be tried for being the criminal that he was.
+But, at the very least, the victims of his crimes, like Jane Doe, can obtain recovery for all the
+harm that he caused them.
+THE PARTIES
+Plaintiff Jane Doe is a citizen of the State of New York. At all times relevant to
+this suit, Doe was a minor child living in New York City.
+Defendant Darren K. Indyke is sued in his capacity as an appointed executor of
+the Estate of Jeffrey E. Epstein.
+Estate of Jeffrey E. Epstein.
+Defendant Richard D. Kahn is sued in his capacity as an appointed executor of the
+10.
+JURISDICTION AND VENUE
+Plaintiff' is domiciled in New York.
+3
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 4 of 16
+11.
+Jeffrey Epstein was a citizen of the United States domiciled in the U.S. Virgin
+Islands at the time of his death. As the legal representatives of the Estate of Jeffrey E. Epstein,
+Darren K. Indyke and Richard D. Kahn are deemed citizens of the U.S. Virgin Islands, and
+jurisdiction in this Court is therefore proper. 28 U.S.C. § 1332(c)(2).
+12. At all times material to the events alleged herein, Plaintiff resided in New York,
+New York, and Defendant maintained a residence in New York, New York.
+13.
+All of the events giving rise to these causes of action occurred in the Southern
+District of New York, thus venue in this district is proper. 28 U.S.C. § 1391(b)(2).
+JURY DEMAND
+14.
+Plaintiff hereby demands a trial by jury on all of her claims in this action.
+FACTUAL ALLEGATIONS
+Defendant Epstein's Scheme of Exploitation and Abuse
+15. Defendant Jeffrey Epstein was born in Brooklyn in 1953.
+16. Epstein graduated from a public high school in Brooklyn, and later took college
+classes at
+Union and New York University. After briefly working as a teacher at a
+prestigious private school in Manhattan and as a partner at Bear Sterns, in 1981 Epstein
+established J. Epstein & Co., a money management business, which he operated until the time of
+his death.
+17.
+Little is known about the actual source or extent of Epstein's wealth, but by 1998
+it is believed that Epstein owned: the largest private home in Manhattan at 9 East 71st Street; a
+7,500 acre ranch in New Mexico; a mansion in Palm Beach, Florida; an apartment in Paris; a
+Boeing 727: and a private island in the U.S. Virgin Islands. By the early 2000s, Epstein became
+4
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 5 of 16
+known as one of the wealthiest individuals in the United States, routinely socializing and
+working with many of the most powerful men in the world.
+18.
+Epstein put his extraordinary resources and wealth to work exploiting and abusing
+teenage girls. Whether at his homes in New York City or Palm Beach, or on his private island,
+Epstein created a vast enterprise designed to lure vulnerable children to his house, where he
+would subject them to varying types of sexual abuse.
+19.
+Epstein believed there was nothing wrong with his conduct. He spoke openly
+about his "interest in young women." He told a New York Times reporter that "criminalizing sex
+with teenage girls was a cultural aberration and that at times in history it was perfectly
+acceptable." In an attempt to justify his sexual interest in children, "he pointed out that
+homosexuality had long been considered a crime and was still punishable by death in some parts
+of the world," thereby equating homosexual relations between consenting adults with the sexual
+abuse of children.
+20.
+In 2008, Epstein entered into a non-prosecution agreement with the United States
+Attorney's Office for the Southern District of Florida (the "Non-Prosecution Agreement) after
+he was investigated for his sexual assault of young girls in Florida. Epstein agreed to plead
+guilty to just two counts of solicitation of prostitution under Florida state law and served just
+over one year in a local jail. While briefly incarcerated, Epstein was afforded extraordinary
+privileges, including being able to leave the jail to work in his office twelve hours per day, six
+days per week.
+Plaintiff Jane Doe Becomes a Victim of Epstein's Scheme of Exploitation and Abuse
+21.
+Jane Doe was born in 1988. For most of her life, Doe was raised by a single
+mother who supported Doe and her younger sister.
+5
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 6 of 16
+22.
+Doe had a difficult childhood that was in many ways marked by financial strain.
+Doe's sister suffered from serious medical conditions that required extensive medical care. Doe
+always worried about whether her family had enough money and thought about how she could
+help her sister then and into the future.
+23. When she was approximately fourteen years old, in or around 2002, Doe was
+approached by a teenage girl from her neighborhood who appeared to be slightly older than Doe.
+The girl told Doe about an opportunity to earn money and offered to introduce her to a wealthy
+man. Doe would subsequently learn that this man was Epstein.
+24.
+By that time, Doe's family was in serious financial straits. Her mother and sister
+were sharing a bedroom. In order to pay their monthly rent, her family rented the other
+bedrooms in their apartment to strangers, leaving no room for Doe. Doe was forced to move out.
+She stayed with a rotating cast of friends and took odd jobs after school to try to help her family
+pay rent. Hoping to help her family and support herself, Doe agreed to meet Epstein.
+25.
+The girl brought Doe to Epstein's mansion at 9 East 71st Street. When they
+entered the mansion, they were greeted by a maid who showed them into a waiting room near the
+entrance to the mansion. Doe can recall thinking that the mansion looked like the castle in the
+fairytale "Beauty and the Beast," one of her favorite Disney movies at the time.
+26.
+After waiting a short period, a maid escorted the two girls to an elevator and led
+them from the elevator to a dimly lit room with a massage table in the middle, where she left the
+girls alone.
+27.
+Minutes later, Epstein entered the room wearing only a robe. He introduced
+himself as "Jeffrey," and asked Doe her name. Epstein also asked Doe her age, and she
+responded truthfully.
+6
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 7 of 16
+28. Epstein then removed his robe and laid face down on the massage table.
+29. The girl who recruited Doe removed her shirt and indicated to Doe that she should
+do the same. As instructed, Doe removed her shirt and began to massage Epstein's back, with
+the other girl coaching her through what Epstein expected.
+30.
+During the massage, Epstein turned over onto his back, exposing his penis to the
+two girls. Epstein then began to touch his penis and directed Doe to pinch his nipples. Doe
+followed orders and touched Epstein's chest while he stared intensely at her and masturbated.
+Finally, Epstein ejaculated and then cleaned himself off with a towel.
+31.
+Afterwards, Epstein put on a robe and retrieved three hundred-dollar bills from
+his robe pocket, which he handed to Doe.
+32.
+Within a day or two, the other girl contacted Doc, and told her that Epstein
+wanted to see her again. She provided Doe with a phone number she could use to schedule
+another visit. Doe called the number and spoke with a woman who arranged for her to return to
+the house and Epstein.
+33.
+Doe returned to Epstein's mansion on 71st Street a few days later. As before, Doe
+was led to the massage room. Epstein entered the room wearing a robe. Having been instructed
+by the girl who brought her the first time to remove her shirt, Doe removed her shirt when
+Epstein came into the room. Topless, she rubbed Epstein's back, until he turned over and
+masturbated. Again, Epstein handed Doe three hundred dollars.
+Epstein's Abuse of Doe Escalates
+34.
+Doe returned to Epstein's home again and again. As described below, as her
+visits became more frequent, Epstein's sexual abuse of Doe became more severe.
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 8 of 16
+35.
+After several visits, Epstein began to touch Doe's bare chest while he masturbated
+at the conclusion of his massage. In earlier encounters, he touched Doe's chest only with his
+hands, but after a few visits he began to touch Doe's breasts with his lips and tongue.
+36.
+In subsequent visits, Epstein directed Doe to remove her pants, shirt, and bra so
+that she was massaging him while wearing only her underwear.
+37.
+Later, Epstein began to touch Doe's genitals over her underwear with a vibrator.
+In visits after that, he would pull Doe's underwear to the side and touch her genitals directly with
+a vibrator.
+38.
+Eventually, Epstein demanded that Doe be completely naked during his massages.
+On multiple occasions, Epstein demanded that Doe lay down on the massage table with him.
+Once she acquiesced, Epstein touched Doe's genitals with his fingers, inserting his fingers inside
+of her vagina and causing her pain. While hurting her, Epstein pushed Doe to moan in supposed
+pleasure and asked her whether she was "enjoying" what he was doing. He demanded that she
+orgasm and would not stop touching her until he believed that she had orgasmed.
+39.
+On other occasions, Epstein also placed Doe's hand on his penis and made her
+move her hand up and down his penis and fondle his testicles until he ejaculated. He moaned
+aggressively while forcing Doe to touch his penis and barked orders at her about how to touch
+him.
+40.
+On one occasion, Epstein brought Doe to a bedroom in his home instead of the
+massage room. In the bedroom, Doe encountered an unfamiliar naked adult woman lying in a
+bed. The woman appeared to be over the age of eighteen. Another young girl close in age to
+Doe was also in the room. Epstein directed Doe and the other girl to remove their clothing and
+8
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 9 of 16
+get into the bed with the naked adult woman. While in the bed, Epstein directed Doe and the two
+others to touch his genitals and to touch one another's genitals.
+41.
+While Epstein physically and emotionally hurt and exploited Doe, a vulnerable
+young girl, she also became financially dependent on him. She stopped attending school and
+spent almost all her time "working" at his home, gratifying him sexually, or bringing other girls
+to do the same.
+42.
+All told, Doe was sexually assaulted by Epstein countless times over the course of
+three years.
+43.
+Doe's experience with Epstein fit within what is now known to have been a
+common pattern for the abuser. He would find vulnerable young girls who needed money and
+slowly test their boundaries
+—first asking them to remove their own clothes and massage him and
+then, over time, he would escalate his conduct, touching them in ways that would become more
+invasive, violent, and painful. As these children grew to rely financially on Epstein, he would
+only cause them more and more harm.
+44.
+As demonstrated by the above, Epstein treated the girls he abused in the same
+way Ghislaine Maxwell, his co-conspirator, viewed them: like "they[] [were] nothing, these
+girls," like "[t]hey [we]re trash."
+Epstein's Abuse of Doe Was Directly and Indirectly Facilitated by His Co-Conspirators
+45.
+Epstein was only able to repeatedly abuse Doe and countless other girls with the
+aid of his many co-conspirators. Some of Epstein's co-conspirators directly enabled his abuse of
+Doe by, for example, arranging for Doe to come to Epstein's home to be assaulted or by
+participating in assaults of Doe alongside Epstein. Other co-conspirators indirectly aided
+Epstein's abuse of young women by giving Epstein access to young women, providing him with
+9
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 10 of 16
+substantial funds, boosting his public profile, and helping to cleanse his public image after his
+2008 prosecution.
+47.
+Two of Epstein's employees specifically facilitated his abuse of Doe. Epstein had
+two adult, female assistants who scheduled most of Doe's visits to Epstein's home and
+maintained regular contact with Doe. Upon information and belief, the assistants were
+and Lesley Groff.
+48.
+During scheduling phone calls,
+and Groff often asked Doe to bring other
+girls with her to Epstein's home. At times,
+and Groff directed Doe to bring with her
+specific girls who Epstein had assaulted before, requesting them by name.
+49.
+paid by L
+Though sometimes Epstein directly paid Doe after abusing her, Doe was often
+or Groff. Doe was also paid by
+or Groff whenever she brought other girls
+to see Epstein.
+50.
+Upon information and belief, as described in Paragraph 40, Doe was sexually
+assaulted by another Epstein employee.
+51.
+Notably,
+and Groff were both listed in Epstein's 2008 Non-Prosecution
+Agreement as potential co-conspirators in Epstein's crimes.
+52.
+Epstein paid hundreds of thousands of dollars to his potential co-conspirators in
+November 2018, shortly after a newspaper reported on the unusually lenient Non-Prosecution
+Agreement Epstein received in 2008, which suggests that Epstein was trying to buy his coconspirators' silence.
+53.
+In addition to assistance provided by Epstein's employees, Epstein built and
+benefitted from a vast network of powerful supporters, including billionaires, prominent
+researchers, and former and current politicians, who provided him with access, opportunity, and
+10
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 11 of 16
+means to abuse young women, and who helped to repair his public image after his 2008
+prosecution.
+Doe's Life Is Materially and Negatively Altered by Epstein's Abuse
+54.
+When Doe turned seventeen, she decided to extricate herself from Epstein. But
+by that time, Epstein's abuse of Doe had already materially and negatively altered her life.
+55.
+Without a high school diploma, and with a very low sense of her own self-worth,
+Doe was forced to take dangerous and often degrading jobs. She still has not been able to
+complete high school, though she hopes to do so in the future.
+56.
+For more than a decade, Doe has suffered from severe mental anguish because of
+Epstein's abuse. She suffers from extreme anxiety and depression, which cause her to
+experience difficulty falling asleep, difficulty staying asleep (because she often wakes up with
+nightmares), difficulty eating, rapid heartbeat, and panic attacks. Her physical and emotional
+injuries impact her daily functioning, making it difficult to go to work and take care of her young
+daughter and her ailing mother.
+57. Doe has been diagnosed with post-traumatic stress disorder (PTSD) in connection
+with Epstein's sexual abuse. She regularly experiences the symptoms of PTSD, including
+flashbacks to Epstein's abuse, which make it difficult for her to take care of herself and her
+family.
+58.
+Doe struggles to be physically and emotionally intimate with her husband because
+of the negative associations she now has with intimacy based on her traumatic experiences with
+Epstein.
+59.
+Doe also struggles to be the mother she wants to be for her daughter. She is
+terrified to let her daughter interact with adult men because all she can think about is what
+11
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 12 of 16
+Epstein did to her. Doe also feels scared and uncomfortable when anyone even a trusted loved
+one-touches her daughter because of her overwhelming fear that what happened to Doe might
+happen to her daughter.
+60.
+All of these harms can be traced directly to Epstein and his co-conspirators.
+Epstein's Recent Criminal Case, Death, and Will
+61.
+In March 2019, Plaintiff was contacted by authorities investigating Epstein's
+decades-long scheme to abuse and exploit children. Plaintiff confidentially cooperated with the
+investigation, recounting Epstein's abuse in painstaking detail over the course of many meetings.
+62. In July 2019, Epstein was indicted by the Unites States Attorney's Office for the
+Southern District of New York, based in large part on information provided by Plaintiff. Indeed,
+upon information and belief, Plaintiff was identified as "Minor Victim-1" in the Indictment and
+was the only victim in the Indictment who Epstein had assaulted in New York.
+63.
+On August 10, 2019, Epstein was found dead in his jail cell at the Metropolitan
+Correctional Center, where he was being held pending trial. Upon information and belief, New
+York City's medical examiner concluded Epstein died by suicide.
+64.
+On August 15, 2019, Epstein's last will and testament (the "Will") was filed in the
+Probate Division of the Superior Court of the Virgin Islands.
+65.
+The Will indicated that it was executed by Epstein on August 8, 2019 at the
+Metropolitan Correctional Center, and that it was witnessed by Mariel Colón Miró and Gulnora
+Tali. The Will was accompanied by affidavits from Darren K. Indyke and Richard D. Kahn
+attesting to their "Oath of Willingness to Serve as Executor and Appointment of Local Counsel."
+Mr. Indyke and Mr. Kahn also filed a Petition for Probate and for Letters Testamentary in the
+Superior Court of the Virgin Islands.
+12
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 13 of 16
+66. The Will's first article directs Epstein's executors "to pay from my estate all
+expenses of my last illness, my funeral and burial expenses, the administration expenses of my
+estate and all of my debts duly proven and allowed against my estate." The Will further directs
+that "after the payments and distributions provided in Article FIRST," Epstein "give[s] all of my
+property, real and personal, wherever situated...to the then acting Trustees of The 1953 Trust."
+67. On August 26, 2019, Defendant Darren K. Indyke filed a Certificate of Trust with
+the Superior Court for the Virgin Islands, confirming that he and Defendant Richard D. Kahn are
+the two Trustees of The 1953 Trust. See Certificate of Trust, In the Matter of the Estate of
+Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Aug. 26, 2019).
+68.
+On September 6, 2019, Magistrate Judge Carolyn P. Hermon-Percell of the
+Superior Court of the Virgin Islands ordered that Epstein's will be admitted to probate and
+authorized Mr. Indyke and Mr. Kahn to administer the estate. See Order for Probate, In the
+Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-19-PB-80 (Super. Ct. V.I. Sep. 6,
+2019); Letters Testamentary, In the Matter of the Estate of Jeffrey E. Epstein, Probate No. ST-
+19-PB-80 (Super. Ct. V.I. Sep. 6, 2019).
+CAUSES OF ACTION
+COUNT ONE
+Sexual Assault
+69.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+if set forth fully herein.
+70.
+On numerous occasions over three years, Epstein made violent sexual demands on
+Plaintiff while placing his hands on her body in a position of dominance and control and while
+touching Plaintiff' in violent and invasive ways.
+13
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 14 of 16
+71.
+These demands, often made when Epstein and Plaintiff were alone, were intended
+to frighten Plaintiff into submitting to Epstein's sexual demands and placed Plaintiff in
+apprehension of harm.
+72.
+This conduct caused Plaintiff serious and persistent harm and contributed to
+injuries that Plaintiff continues to suffer.
+73.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+COUNT TWO
+Sexual Battery
+74. Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+if set forth fully herein.
+75.
+On numerous occasions over three years, Epstein intentionally, violently, and
+invasively used his fingers, lips, tongue, mouth, and foreign objects to make unwanted, unlawful,
+harmful, and offensive physical contact with Plaintiff's body.
+76.
+This conduct caused Plaintiff serious and persistent harm and contributed to
+injuries that Plaintiff continues to suffer.
+77.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+14
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 15 of 16
+COUNT THREE
+Intentional Infliction of Emotional Distress
+78.
+Plaintiff' incorporates by reference all preceding paragraphs and re-alleges them as
+if set forth fully herein.
+79.
+Epstein's three-year campaign of sexual abuse against a teenaged Plaintiff was
+extreme and outrageous conduct that shocks the conscience.
+80.
+Epstein's serial sexual assaults, committed during the course of a methodical plan
+of recruitment, enticement, and attack, inflicted severe pain and anguish upon Plaintiff.
+81.
+Epstein directed this conduct at Plaintiff and knew that it would cause severe and
+lasting emotional distress. Indeed, the conduct caused Plaintiff severe and lasting emotional
+distress and serious injuries to her mental health.
+82.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+COUNT FOUR
+Negligent Infliction of Emotional Distress
+83.
+Plaintiff incorporates by reference all preceding paragraphs and re-alleges them as
+if set forth fully herein.
+84.
+Epstein invited Plaintiff, then a teenaged girl, into his home for a period of three
+years. Once under his supervision, Epstein proceeded methodically to sexually abuse Plaintiff.
+85.
+Epstein's conduct was extreme and outrageous, breached a duty owed directly to
+Plaintiff, endangered her physical safety, and caused severe and lasting emotional distress and
+serious injuries to Plaintiff's mental health.
+15
+
+
+Case 1:19-cv-08673-KPF-DCF Document 1 Filed 09/18/19 Page 16 of 16
+86.
+This cause of action is timely under the Child Victims Act, N.Y. C.P.L.R. § 214-g
+(McKinney 2019), because it arises out of conduct perpetrated against Plaintiff when she was
+under the age of 18 that constitutes a sexual offense as defined in Article One Hundred Thirty of
+the New York Penal Law ("Article 130"). See N.Y. P.L. § 130.52; N.Y. P.L. § 130.55.
+PRAYER FOR RELIEF
+WHEREFORE, Plaintiff Jane Doe prays for this Court to:
+87.
+Issue a judgment declaring that Defendants, as legal representatives of the Estate
+of Jeffrey E. Epstein, are liable for the violations of law alleged in this case;
+88.
+Award actual, compensatory, statutory, consequential and punitive damages;
+89.
+Award pre-judgment and post-judgment interest at the highest rate allowed by
+law; and
+90.
+Grant such further relief as this Court may deem just and proper.
+Dated: September 18, 2019
+Roder
+Roberta A. Kaplan
+Julie E. Fink
+Jenna M. Dabbs
+Justin Horton
+Alexandra K. Conlon (admission pending)
+KAPLAN HECKER & FINK LLP
+350 Fifth Avenue, Suite 7110
+New York, New York 10118
+Telephone: (212) 763-0883
+Facsimile: (212) 564-0883
+rkaplan@kaplanhecker.com
+jfink@kaplanhecker.com
+jdabbs@kaplanhecker.com
+jhorton@kaplanhecker.com
+aconlon@kaplanhecker.com
+Attorneys for Plaintiffs
+16
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+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S MOTION TO COMPEL ANSWERS TO
+INTERROGATORIES AND PRODUCTION OF DOCUMENTS,
+AND INCORPORATED MEMORANDUM OF LAW IN SUPPORT
+Plaintiff, by and through undersigned counsel, files this Motion to Compel Answers to
+Interrogatories and Production of Documents, and Memorandum of Law in Support, pursuant to
+Fed.R.Civ.P. 26 and 37 and S.D.Fla.L.R. 26.1(H)(2), as follows:
+INTRODUCTION
+Plaintiff in this case propounded 17 interrogatories and 24 documents requests. In response,
+Defendant has produced no information and no documents. Defendant's principal objection
+concerns his Fifth Amendment privilege against self-incrimination. Defendant, however, fails to set
+forth a sufficient predicate in his responses to interrogatories or documents requests for his refusal to
+provide any responsive documents or information. Defendant, rather, repeats in each response an
+all-encompassing, blanket assertion of Fifth Amendment privilege.
+Defendant's responses also include a laundry list of objections to Plaintiff's interrogatories
+and documents requests, none of which serve as a basis for a denial of all discovery. For the reasons
+discussed below, Plaintiff requests an order compelling Defendant to answer interrogatories and
+- 1-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 2 of 16
+produce responsive documents.'
+Il.
+EPSTEIN'S BLANKET ASSERTION OF PRIVILEGE
+AGAINST SELF-INCRIMINATION IN RESPONSES
+TO INTERROGATORIES IS INSUFFICIENT
+Defendant's response to each and every one of Plaintiff's Interrogatories contains the
+following privilege objection:
+I intend to respond to all relevant questions regarding this lawsuit,
+however, my attorney has counseled me that I must accept this advice
+or risk losing my Sixth Amendment right to effective representation.
+Accordingly, I assert my federal constitutional rights under the Fifth,
+Sixth, and Fourteenth Amendments as guaranteed by the United
+States Constitution.
+Defendant's canned objection represents a "blanket" refusal to answer questions in this civil
+case. See Anglada v. Sprague, 822 F.2d 1035, 1037 (11th Cir. 1987) (rejecting a "blanket" refusal to
+testify as unacceptable). While Plaintiff does not dispute that Defendant Epstein's Fifth Amendment
+privilege may be asserted in a civil case, the Fifth Amendment's "protection must be confined to
+instances where the witness has reasonable cause to apprehend danger from a direct answer."
+Hoffman v. United States, 341 U.S. 479, 486 (1951) (emphasis supplied).
+"[A] witness has some minimal burden to justify invocation of the privilege." In re J.M.V.,
+Inc., 90 F.R. 737, 739 (Bankr. E.D. Pa. 1988). The privilege must be asserted in response to a
+'This Motion addresses almost entirely general or blanket objections to discovery, which are
+repeated in multiple or all of the Defendant's responses to Plaintiff's discovery requests.
+Accordingly, Plaintiff deviates where necessary from the format set forth in S.D.Fla.L.R. 26.1(H)(2)
+in the interests of clarity and efficiency.
+' Attached as Exhibit "A" is Defendant's Response and Objections to Plaintiff's Interrogatories.
+" This discussion addresses the Defendant's Fifth Amendment claim of privilege. Defendant also
+asserts a privilege under the Sixth and Fourteenth Amendments. The Sixth Amendment does not
+provide a basis to refuse to answer questions in a civil case as a means to preserve the Defendant's
+"right to effective representation", as Defendant asserts in his responses. The Fourteenth
+Amendment likewise is inapposite, as state action is not at issue in this federal case.
+- 2-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 3 of 16
+particular question, and in each instance "[i]t is for the court to decide whether a witness' silence is
+justified and to require him to answer if it clearly appears to the Court that the witness asserting the
+privilege is mistaken as to its validity." In re Morganroth, 718 F.2d 161, 166-167 (6th Cir. 1983)
+(holding that it was not sufficient for witness to answer every question with conclusory assertion of
+Fifth Amendment privilege). Accord Anglada, 822 F.2d at 1037 (noting that Court should not have
+to speculate as to which questions would tend to incriminate); See also Hoffman, 341 U.S. at 486
+(witness' "say-so does not of itself establish the hazard of self-incrimination"'); In re Wincek, 202
+B.R. 161, 168 (Bankr. M.D. Fla. 1996) (rejecting assertion of Fifth Amendment privilege in "broad,
+unsupported fashion").
+The "reasonable cause" for invocation of the Fifth Amendment privilege is not self-evident
+from the interrogatories propounded by Plaintiff. For example, Interrogatory no. 1 asks the
+Defendant to identify employees who performed work or services at his Palm Beach residence. It is
+not apparent that identifying the chef, chauffeur, gardener, etc., would tend to incriminate the
+Defendant. The information sought in the bulk of the Plaintiff' s interrogatories may be categorized
+generally as follows:
+Type of Information
+identification of persons
+Interrogatory No.
+1, 2, 3, 4, 5, 6, 10, 17
+Defendant's travel schedule and
+locations
+identification of health care providers
+8
+telephone numbers used by Epstein
+and his employees
+11,12
+general information based on Florida
+13, 14, 16°
+" Plaintiff does not challenge at this time Defendant's assertion of a Fifth Amendment privilege in
+response to interrogatory no. 9, which seeks information on Defendant's sexual aids.
+- 3-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 4 of 16
+Standard Interrogatories, Fla.R.Civ.P.
+Form 2, nos. 7, 10, 12
+These Interrogatories, on their face, do not infringe upon or otherwise implicate the
+Defendant's rights under the Fifth Amendment. It is, therefore, incumbent upon the Defendant to set
+forth reasonable cause for his invocation of the Fifth Amendment in response to each of these
+Interrogatories. Absent some interrogatory-by-interrogatory showing of reasonable cause, Plaintiff
+asks that Defendant's claims of privilege under the Fifth Amendment be rejected and overruled.
+III. DEFENDANT'S BLANKET ASSERTION OF
+FIFTH AMENDMENT PRIVILEGE IN RESPONSE
+TO REQUESTS FOR PRODUCTION IS INSUFFICIENT
+In response to Plaintiff's Requests for Production, Defendant has asserted an identical,
+"blanket" objection to each and every request, as follows:
+Amendment right to effective representation. Accordingly, I assert
+my federal constitutional rights under the Fifth, Sixth, and Fourteenth
+Initially, it is well established that the Fifth Amendment privilege may not apply to specific
+documents "even though they contain incriminating assertions of fact or belief because the creation
+of those documents was not 'compelled' within the meaning of the privilege." United States v.
+Hubbell, 530 U.S. 27, 35-36 (2000). Accordingly, a party cannot avoid discovery merely because
+demanded documents contain incriminating evidence, "whether written by others or voluntarily
+prepared by himself." Id.
+Nonetheless, the act of procuring documents may be considered testimonial and protected by
+› Defendant's Response to Request for Production, which sets forth each Request and the
+Defendant's Response, is attached hereto as Exhibit "B".
+- 4-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 5 of 16
+the Fifth Amendment privilege in two instances: (1) if the existence and location of the documents
+are unknown; or (2) where production would "implicitly authenticate" the documents. In re Grand
+Jury Subpoena, 1 F.3d 87, 93 (2d Cir. 1993); see also Fisher v. United States, 425 U.S. 391, 410
+(1976) (issue expressed as whether compliance with a document request or subpoena "tacitly
+conceded" the item's authenticity, existence or possession by the defendant). It is the Defendant's
+burden to demonstrate that the act of producing any particular responsive documents would entail
+testimonial self-incrimination. United States v. Wujkowski, 929 F.2d 981, 984 (4th Cir. 1991). It is
+not self-evident or apparent from the Plaintiff's requests that the act of producing responsive items
+would be protected under the Fifth Amendment. In particular, there is no reason to believe that
+production of documents in response to the following requests would compel testimonial selfincrimination:
+Types of Documents Requested
+Agreements with the U.S. Attorney
+and State Attorney, and documents
+exchanged between Defendant and
+the U.S. Attorney or State Attorney
+Request Nos.
+1-4
+Telephone records
+5-6
+Videos, photographs of residence
+Documents relating to Plaintiff Jane Doe
+8
+Air travel records
+Documents relating to modeling agencies
+Correspondence with other witnesses
+Social networking documents
+10
+11
+14, 15, 16, 17,19
+18
+Gifts to minor females
+Personal calendars, diaries
+20
+21,22
+- 5-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 6 of 16
+Prescription medicines
+23°
+As to the above-listed items, it is not possession or control of these items that would prove
+incriminating; rather, if anything, it is their contents, which are not protected by the Fifth
+Amendment privilege so long as they were created voluntarily. Fisher, 425 U.S. at 410; see also In
+re
+156 B.R. 272, 177-78 (Bankr. D. Idaho 1993). Nor would production of items in response
+to these requests "implicitly authenticate" items that are themselves incriminating. See In re Grand
+Jury Subpoena, 1 F.3d at 93-94 (holding that defendant's calendar/diary not protected from
+discovery by "act of production" doctrine under the Fifth Amendment).
+Without more, therefore, Defendant's blanket claim of a Fifth Amendment privilege in
+response to all of Plaintiff's document requests should be rejected, and responsive documents
+ordered to be produced.
+IV.
+DEFENDANT'S OBJECTION AND STATEMENT CONCERNING
+ADVERSE INFERENCE IS INAPPROPRIATE AND INCORRECT
+Defendant makes the following self-serving and unnecessary assertion in response to each
+and every interrogatory and document request propounded by Plaintiff:
+Drawing an adverse inference under these circumstances would
+unconstitutionally burden my exercise of my constitutional rights
+would be unreasonable, and would therefore violate the Constitution.
+Although a defendant's assertion of his Fifth Amendment privilege cannot be used against a
+criminal defendant, it is well established that "an adverse inference based on a refusal to testify in a
+civil case is an appropriate remedy as it provides some relief to the civil litigant whose case is
+unfairly prejudicial by a witness' assertion of the Fifth Amendment privilege..." United States v.
+Custer Battles, L.L.C., 415 F. Supp. 2d 628, 632 (E.D. Va. 2006); accord Baxler v. Palmigiano, 425
+*Plaintiff concedes that the act of producing items in response to request no. 9, concerning witness
+statements, and request nos. 12-13, concerning photographs or images of females, may implicate the
+Fifth Amendment.
+- 6-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 7 of 16
+U.S. 408, 318 (1976) ("the Fifth Amendment does not forbid adverse inferences against parties to
+civil actions when they refuse to testify in response to probative evidence offered against them");
+Securities and Exhange Comm'n v. Graystone Nash, Inc.., 25 F.3d 187, 190 (3d Cir. 1994) (*It]he
+[defendant's] dilemma of choosing between complete silence and presenting a defense [in a civil
+case] does not fatally infect the right against compelled self-incrimination").?
+In any event, the issue of adverse inference, at this juncture, is premature. It is first
+necessary to determine whether the Fifth Amendment privilege is validly asserted in response to
+particular questions. This issue is typically resolved on a motion to compel. Custer Battles, 415 F.
+Supp. 2d at 633. If it is determined that the privilege is properly asserted, then adverse inferences
+are admissible consistent with the Rules of Evidence, i.e., where they are relevant, reliable and not
+unfairly prejudicial, confusing or cumulative. Id. at 634. Such evidentiary issues concerning
+adverse inference are appropriately addressed at the time of summary judgment or trial. It is
+inappropriate and unnecessary to challenge the use of adverse inferences through self-serving
+statements in blanket objections to interrogatories.
+V. PLAINTIFF IS ENTITLED TO DEFENDANT'S
+HEALTH CARE INFORMATION IN DISCOVERY
+A. Interrogatory at Issue
+"Interrogatory No. 8. Identify all of Jeffrey Epstein's health care providers in the past (10)
+ten years, including without limitation, psychologists, psychiatrists, mental health counselors,
+physician, hospital and treatment facilities."
+B.
+Pertinent Portion of Defendant's Objection
+"... [sJuch information is privileged pursuant to Rule 501, Fed.Evid., and §90.503, Fla.Evd.
+"Moreover, a defendant in a civil case may not manipulate his use of the Fifth Amendment privilege
+by shielding himself from inquiries during discovery, and then submitting surprise testimony in a
+summary judgment affidavit or at trial. Id. at 191.
+- 7-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 8 of 16
+Code. In addition, such information is protected by the provision of the Health Insurance Portability
+and Accountability Act (HIPAA)."
+C. Grounds for Objection and Reasons for Motion
+The substantive basis for Defendant's objection is a claim of privilege under state law,
+Florida Statute $90.503 (psychotherapist-patient privilege) and federal law, HIPAA, 42 U.S.C.
+§1320d et seq. Neither of these privilege claims are a basis to withhold relevant health care
+information in this case. Initially, Florida Statute $90.503 does not protect as privileged the identity
+of health care providers, which is all that is sought in Plaintiffs interrogatory. Rather, it protects
+"confidential communications" with a psychotherapist. Florida Statute §90.503(2). Further,
+Plaintiff is ultimately entitled to discovery from the Defendant's psychotherapists because §90.503
+does not apply to relevant documents in a case of child abuse under Florida Statute $39.204. This
+Statute abrogates the psychotherapist-patient privilege in cases involving child abuse:
+Abrogation of privileged communications in cases involving child
+abuse, abandonment, or negleet.- the privileged quality of
+communication ... between any professional person and his or her
+patient or client, and any other privileged communication except that
+between attorney and client or the privilege provided in s. 90.505, as
+such communication relates both to the competency of the witness
+and to the exclusion of confidential communications, shall not apply
+to any communication involving the perpetrator or alleged
+perpetrator in any situation involving known or suspected child
+abuse....
+(Emphasis supplied). "With the exceptions of the attorney-client privilege and the clergy
+communications privilege, section 39.204 abrogates the various evidentiary privileges in cases
+involving child abuse, abandonment or neglect." Nussbaumer v. State, 882 So.2d 1067 (Fla. 2d
+"The term "child abuse" is defined broadly in the Statute to encompass the acts and conduct alleged
+against Epstein in this case. A "child" is a person under the age of 18, and "abuse" means "any
+willful or threatened act that results in any physical, mental, or sexual injury or harm that causes or
+is likely to cause the child's physical, mental or emotional health to be significantly impaired."
+- 8 -
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 9 of 16
+DCA 2004). It represents a determination by the legislature that discovery of facts relating to claims
+of child abuse is more important than the protection of otherwise confidential psychotherapistpatient communications:
+Obviously, the psychotherapist privilege provided by section
+90.503(2) is intended to encourage people who need treatment for
+mental disorders (including child abusers) to obtain it by insuring the
+confidentiality of communication during treatment. We must assume,
+however, that the legislature, in passing [$39.204] weighed the
+desirability of encouraging treatment for child abusers against the
+desirability of discovering them and decided that the latter was more
+important than the former. The intent of [$39.204] is to discourage
+child abuse. That discouragement, in view of the statutory language,
+can occur by way of a civil lawsuit for damages as well as by way of
+a criminal prosecution.
+Carson v.
+466 So.2d 1188, 1190 (Fla. 4th DCA 1985) (analyzing predecessor statute,
+§415.512, Fla. Stat.).
+Defendant also asserts HIPAA, the Health Insurance Portability and Accountability Act, 42
+U.S.C. §1320d et seq.. as a ground for objection to Plaintiff's interrogatory. "HIPAA does not
+create substantive rights that act as a bar on discovery. ... HIPAA regulations is (sic) purely
+procedural in nature and does not create a federal physician-patient or hospital-patient privilege."
+v. Woodford, 2007 WL 309485 *11 (E.D. Cal. 2007). Under HIPAA, health care information
+may be disclosed in discovery under a qualified protective order, which prohibits using or disclosing
+protected health care information for any purpose other than the litigation and requires return or
+destruction of the protected health care information. 45 C.F.R. §164.512(i)(e). Accordingly, there is
+no basis to withhold from discovery Epstein's health care information, particularly as it relates to
+Plaintiff's allegations of child abuse.
+VI.
+OTHER OBJECTIONS TO PLAINTIFF'S
+DISCOVERY REQUESTS ARE MERITLESS
+Florida Statutes §39.201.
+- 9-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 10 of 16
+A. Overbroad; Relevance
+In response to each and every interrogatory propounded by Plaintiff, Defendant asserts in
+blanket and conclusory fashion that it is overbroad and seeks information that is neither relevant to
+the subject matter of the pending action nor dies it appear reasonably calculated to lead to the
+discovery of admissible evidence." Defendant also objects to each and every document request as
+overbroad. These objections are groundless. Plaintiff's discovery requests fall within the scope of
+broad discovery and relevance under Fed.R.Civ.P. 26. All of Plaintiff's interrogatories and
+document requests are sufficiently narrow and tailored for Defendant to reasonably provide
+substantive responses. Defendant fails to indicate unfair prejudice or undue burden from any
+interrogatory or document request. Defendant provides no responsive information whatsoever, nor
+has he made any suggestion to reasonably narrow or limit any of the Plaintiff's discovery requests.
+Defendant complains that the time period covered in the interrogatories is too broad. The
+stated time period, applicable to Plaintiff's interrogatories and documents requests generally, as
+noted in Defendant's responses, is January 1, 2003 to present. This time frame is sufficiently
+narrow, especially since the plan and scheme alleged in the Complaint to lure girls to the
+Defendant's Palm Beach mansion for "massages" has been in place since at least that date.
+Defendant's overbroad/relevance objections should, accordingly, be overruled.
+B.
+Work Product; Attorney-Client Privilege
+In response to various interrogatories and all of the documents requests, Defendant asserts in
+conclusory fashion
+objections based on the attorney work product and attorney-client
+communication privilege.? In making these privilege claims, Defendant failed to provide a privilege
+"These privileges are asserted in response to Interrogatory nos. 13, 14, and 17, and each and every
+document request.
+- 10-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 11 of 16
+log as required by S.D.Fla.L.R. 26.1(G)(3). These interrogatories and requests generally do not on
+their face implicate the work product or attorney client privileges. " These privilege claims should
+therefore be rejected and overruled.
+C.
+Plaintiff's Definitions of "Employee" is Reasonable
+Defendant contests the definition of "Employee" in Plaintiff's document requests and
+interrogatories, which states as follows:
+"Employee" shall mean any person employed to perform
+work for services for Defendant or by Defendant, either directly or
+indirectly, including without limitation:
+i.
+a limited partnership, corporation, limited liability
+company, or other company or entity in which Defendant is a
+member, director, officer or person in control; and
+il.
+control.
+persons employed by a partnership or a subsidiary of a
+partnership in which Defendant is a general partner or person in
+The term "Employee" appears in Interrogatory nos. 1, 2, and Document Request no. 6. The
+breadth of this definition is reasonable under the circumstances of this case. Upon information and
+belief, Defendant Epstein conducted his business and personal affairs through a labyrinth of
+corporate entities and other business forms. This definition of "Employee" is reasonable to
+encompass responsive information and documents.
+D.
+Fed.R. Civ.P. 408 and 410 Do Not
+Create a Privilege in Discovery
+Defendant objects to Document Request nos. 1-5, which seek the Defendant's agreements
+with the U.S. Attorney and State Attorney, and documents exchanged with their offices, on the
+grounds of Fed.R.Evid. 408 and 410. These Rules cover the admissibility in evidence of
+'The only possible exception would be Plaintiff's Document Request no. 9, which seeks witness
+statements; nonetheless, Defendant is required to comply with the Local Rule and provide a
+- 11 -
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 12 of 16
+compromises and plea agreements; they do not set forth a privilege applicable to such agreements in
+discovery. To the extent a protective order with regard to such documents is deemed appropriate,
+Plaintiff's counsel agrees to limit their use to this litigation, and not to disclose documents
+responsive to these requests to third parties.
+E.
+Third Party Privacy Rights
+Defendant broadly and vaguely asserts third party privacy rights in response to various
+document requests. To the extent that any such privacy rights are properly raised in this case,
+Plaintiff consents to the entry of an appropriate protective order under which such documents will
+not be disseminated to third parties and will be used only for purposes of this litigation.
+VII. Conclusion
+Based on the foregoing, Plaintiff respectfully requests that Defendant's assertions of
+privilege and objections be denied and overruled, and that an Order be entered directing Defendant
+to answer the Plaintiff's Interrogatories and produce documents responsive to Plaintiff's Requests
+for Production, subject to such protective order as may be necessary and appropriate. Plaintiff
+further requests such other relief as this Court deems just and proper.
+Dated: March 2, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL. Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiff
+18205 Biscayne Blvd., Suite 2218
+privilege log in response to this request as well as the others.
+- 12-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 13 of 16
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 13 -
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 14 of 16
+CERTIFICATE PURSUANT TO S.D.FLA.L.R. 7.1(A)(3)
+Counsel for Plaintiff has made reasonable efforts to confer with counsel for Defendant, by
+letter dated February 25, 2009, seeking in good faith to resolve or narrow the issues raised in the
+Motion, but Defendant's counsel failed to respond to Plaintiff's letter, and Plaintiff's counsel has
+been unable to resolve this dispute.
+s/ Adam D. Horowitz
+- 14-
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 15 of 16
+CERTIFICATE OF SERVICE
+I hereby certify that on March 2, 2009, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+- 15 -
+
+
+Case 9:08-cv-80380-KAM Document 63 Entered on FLSD Docket 03/02/2009 Page 16 of 16
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+/s/ Adam D. Horowitz
+- 16-
diff --git a/vision-fixhub/court-01/f9113af9a0c244307c4e17cd69738b259e82b1d4ea23025b1bea21828c337202.receipt.json b/vision-fixhub/court-01/f9113af9a0c244307c4e17cd69738b259e82b1d4ea23025b1bea21828c337202.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1eb969f60c03381124f3b06c3f51eba68901c915
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+++ b/vision-fixhub/court-01/f9113af9a0c244307c4e17cd69738b259e82b1d4ea23025b1bea21828c337202.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "f9113af9a0c244307c4e17cd69738b259e82b1d4ea23025b1bea21828c337202",
+  "engine": "marble-apple-vision",
+  "event_count": 18,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "903126ecb73360a0ca3ffc4060166bf7ab34577fa25610fd988adb93e914e0e7",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071.md b/vision-fixhub/court-01/f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071.md
new file mode 100644
index 0000000000000000000000000000000000000000..4d6ac559c48556c4ea74d8676fe2252195ee804f
--- /dev/null
+++ b/vision-fixhub/court-01/f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071.md
@@ -0,0 +1,35 @@
+Case 9:08-cv-80119-KAM Document 280-1 Entered on FLSD Docket 08/28/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER
+This matter came before the Court on Defendant, JEFFREY EPSTEIN'S, Motion
+For Extension of Time in which to Respond to Plaintiff, Jane Doe's Motions to Compel
+Responses to Request to Produce, Answers to Request for Admissions, and Answers to
+Interrogatories. Having considered Defendant's motion and Plaintiff's counsel being in
+agreement with the requested extension, it is HEREBY ORDERED and ADJUDGED
+that:
+Defendant's motion is GRANTED.
+Defendant shall Respond to Plaintiff's
+Motions to Compel Responses to Request to Produce, Answers to Request for
+Admissions, and Answers to Interrogatories.
+on or before September 7, 2009.
+
+
+Case 9:08-cv-80119-KAM Document 280-1 Entered on FLSD Docket 08/28/2009 Page 2 of 2
+DONE and ORDERED this
+day of
+, 2009.
+Kenneth A. Marra
+United States District Judge
+Courtesy Copies:
+Counsel of Record
diff --git a/vision-fixhub/court-01/f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071.receipt.json b/vision-fixhub/court-01/f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071.receipt.json
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@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "f91d8dac6bb77354f160fa318a14074d55d90cb3ea594b36c7d72b900319a071",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5de46939915f2ad469dab7a9bc9a51bd8ef503fce52d5bfda045b4c4538a0dfc",
+  "output_sha256": "a94a3c3d592980f5d2f4202b468b4c0fa2f1902191b7af7a369de88977937f33",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.md b/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.md
new file mode 100644
index 0000000000000000000000000000000000000000..51cee59c63cb027cc478e946d870567491e8b8af
--- /dev/null
+++ b/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.md
@@ -0,0 +1,28 @@
+Case 9:08-cv-80736-KAM Document 101-1
+Entered on FLSD Docket 09/28/2011 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-5073-Cir. Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+[PROPOSED| ORDER GRANTING JANE DOE #1 AND JANE DOE #2'S UNOPPOSED
+MOTION FOR EXENSION OF TIME TO RESPOND TO SUPPLEMENTAL BRIEFING
+IN SUPPORT OF MOTION TO INTERVENE BY ROY BLACK ET AL.
+THIS CAUSE comes before the Court on Jane Doe #1 and Jane Doe #2's Unopposed
+Motion for Extension of Time to File Response to Supplemental Briefing in Support of Motion
+to Intervene of Roy Black,
+Weinberg, and Jay Lefkowitz, filed September 28, 2011.
+Having reviewed the Motion and the Court file, and good cause having been shown,
+It is ORDERED AND ADJUDGED that the Motion is GRANTED. The victims have one
+extra week, to and including Monday October 10, 2011, to respond to the Supplemental Briefing
+in Support of Motion to Intervene of Roy Black,
+Weinberg, and Jay Lefkowitz (DE 94)
+and the government response thereto (DE 100).
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this day of.
+- 2011.
+KENNETH A. MARRA
+United States District Judge
+1
diff --git a/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.receipt.json b/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..97251a9d60f905fbd2a22d2402a880ffb834ab87
--- /dev/null
+++ b/vision-fixhub/court-01/f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f91f10002c118a634b42c2c117fefbda69968c02d35ec8e9dda3068557f81996",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "847e2b6f40c36955fec9361cdab06611b66909d21bb0ff002fccaa637cf0a405",
+  "output_sha256": "1fc46df55ab2ec3c7510ab5c29cc162ea748032f49b27aa3ccc364572f32253c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f92c7488c9fd27fcb50fff574654d3c9f8bae78079ebb44ea0d849e9a0979f52.md b/vision-fixhub/court-01/f92c7488c9fd27fcb50fff574654d3c9f8bae78079ebb44ea0d849e9a0979f52.md
new file mode 100644
index 0000000000000000000000000000000000000000..c76eac385362dcd9c0ee4d78d764a74ad5c6ea67
--- /dev/null
+++ b/vision-fixhub/court-01/f92c7488c9fd27fcb50fff574654d3c9f8bae78079ebb44ea0d849e9a0979f52.md
@@ -0,0 +1,1643 @@
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 1 of 26
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintitt,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+THIRD PARTY WITNESS, IGOR ZINOVIEW'S,
+MOTION FOR PROTECTIVE ORDER AND
+INCORPORATED MEMORANDUM OF LAW
+Third Party Witness, Igor Zinoview's, ("Mr. Zinoview") by and through his
+undersigned attorney, moves this Court pursuant to Fed. R. Civ. P. 26(c) for a protective
+order regarding his deposition and as grounds therefore would state:
+As reflected on the affidavit of Igor Zinoview, attached as Exhibit A, he
+works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did
+not know Mr. Epstein before November of 2005. He first became employed by Mr.
+Epstein in November of 2005.
+2.
+Additionally, Mr. Zinoview would testify as set forth on his affidavit, that
+at no time has he discussed with Mr. Epstein any issues involving Mr. Epstein's criminal
+case nor any of the cases or issues involved with civil plaintiffs.
+1
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 2 of 26
+3.
+In many of the depositions, counsel for L.M. and E.W., has asked them as
+witnesses to assume certain facts about which they have no knowledge, and he then asks
+their opinions about certain facts. See Exhibit B -Epstein's Motion for Protective Order
+to Prohibit Inappropriate Deposition Questions.
+4.
+There is no information which Mr. Zinoview has relating to the facts and
+circumstances surrounding any of the pending civil cases, in that none of their allegations
+directed to Mr. Epstein extend beyond September of 2005. Therefore whatever
+information Mr. Zinoview may have, postdates that time.
+5.
+Regarding the scope of discovery, Judge Linnea
+noted in her
+October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it
+is not without limits. Washington v.
+& Williamson Tobacco, 959 F.2d 1566,
+1570 (11th Cir. 1992)... Courts have long held that '[w]hile the standard of relevancy
+[in discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow
+zones of relevancy and to explore matter (sic) which does not presently appear germane
+on the theory that it might conceivably become so. Food Lion, Inc. y. United Food &
+Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string
+cite omitted)."
+6.
+Rule 26(c), Federal Rules of Civil Procedure, provides that, "[a] party or
+any person from whomn discovery is sought may move for a protective order in the court
+where the action is pending.... The court may, for good cause, issue an order to protect
+a party or person from annoyance, embarrassment, oppression, or undue burden or
+expense, including
+one or more of the following: (A) forbidding the disclosure or
+discovery;"
+2
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 3 of 26
+7.
+As set forth in his affidavit, Mr. Zinoview cannot possibly have any
+knowledge or information that is presently germane to this action. Accordingly, the
+Court should enter a protective order prohibiting his deposition.
+WHEREFORE, third-party witness moves this court for a protective order
+pursuant to Rule 26(c), Federal Rules of Civil Procedure, that his deposition not take
+place or the questioning be limited.
+BACK ALAN GOLDBEROER ESO.
+Florida Bar No. 262013
+jagesq@bellsouth.net
+Rule 7.1 Certification
+I hereby certify that counsel for the movant has conferred or attempted to confer
+with opposing counsel in a good faith effort to resolve the discovery issues prior to the
+filing of this motion for protective order but has been unable to do so.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+vith the Clerk of the Court using CM/ECF. I also certify that the foregoing document i
+he manter spectay by Conf record iden November lowing Service List i
+_ day of November, 2009
+Respectfully submitted,
+By:
+JACK ALAN GOLDBERGER ESQ.
+Florida Bar No. 262013
+agesq@bellsouth.ne
+terbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+(Counsel for Defendant Jeffrey Epstein)
+3
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 4 of 26
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/]
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119, Paul G. Cassell, Esq.
+08-80232, 08-80380, 08-80381, 08-80993,
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A.
+801-585-6833 Fax
+229010 Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+1 Esq.
+Fax: 561-588-8819
+Law Firm, P.A.
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.|
+, Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+riosefsberg@podhurst.com
+Bruce Reinhart, Esq.
+kezell@podhurst.com
+Bruce E. Reinhart, P.A.
+Counsel for Plaintiffs in Related Cases
+250 S. Australian Avenue
+Nos. 09-80591 and 09-80656
+Suite 1400
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+4
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 5 of 26
+561-202-6360
+Fax: 561-828-0983
+ccf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL. 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+5
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 6 of 26
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-d
+JANE DOE NO. 2,
+Plaintiff,
+V.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80581, 09-80656, 09-80802, 09-81092.
+AFFIDAVIT OF IGOR ZINOVIEV
+) SS
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+BEFORE ME, the undersigned authority, personally appeared Igor Zinoviev
+having personal knowledge and being duly sworn, deposes and says:
+1.
+My name is Igor Zinoview.
+2.
+I began working for Mr. Epstein in November of 2005.
+3.
+I did not know him until I began working for him.
+I have never discussed nor has he ever attempted to discuss with me any facts or
+information relating to any legal matters in which he is involved.
+I work for Mr. Epstein as his driver, bodyguard and trainer.
+EXHIBIT_A
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 7 of 26
+Page 2
+FURTHER THE AFFIANT SAYETH NAUGHT.
+gor 'novie
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby Certify that on this day, before me, an officer duly authorized to administer
+named person: Ijor Zinoview
+WITNESS my hand and official seal in the County and State last aforesaid this
+day of Ma. 9
+- 2009.
+ALL MAHONE
+NOTARY
+C: My Comm. Expires
+May 28, 2010
+No. DD519867
+Sit Make
+NAME
+NOTARY PUBLIC/STATE OF FLORIDA
+COMMISSION NO.:
+MY COMMISSION EXPIRES:
+(SEAL)
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 8 of 26
+IN THE COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+CASE NO. 502008CA028051XXXXMB AB
+L.M.,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO
+PROHIBIT INAPPROPRIATE DEPOSITION QUESTIONS
+Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 1.280(c), Florida
+Rules of Civil Procedure, moves for a protective order to prohibit argumentative,
+harassing and inappropriate questions in depositions, and states:
+At numerous depositions, Plaintiff's counsel has repeatedly asked
+argumentative and harassing questions that are irrelevant and not reasonably
+calculated to lead to the discovery of admissible evidence.
+2.
+In particular, Plaintiff's counsel has asked questions that improperly
+sought to illicit lay opinions from fact witnesses, asked questions regarding witnesses'
+feelings towards Mr. Epstein and their beliefs regarding media reports of this case,
+asked whether they would leave their children with Mr. Epstein and asked whether they
+would go back to work for Mr. Epstein assuming the media reports were accurate,
+among other things.
+These questions and the responses thereto will never be
+admissible. They are argumentative, irrelevant and seek speculative answers and
+inadmissible lay opinions.
+EXHIBIT_B
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 9 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+3.
+For example, in the deposition of Larry Visoski, one of Mr. Epstein's pilots,
+Plaintiff's counsel asked the following questions seeking to obtain Mr. Visoski's beliefs
+and opinions on Plaintiff's allegations:
+Q.
+All right.
+When you read in the newspapers
+the
+allegations that Mr. Epstein was involved with
+numerous
+underage girls for sexual reasons, were you surprised?
+A. I didn't believe it.
+Q. Do you believe it today?
+A. I don't believe it.
+Q. You don't believe that Jeffrey Epstein was involved with
+underage girls in a sexual way?
+MR. CRITTON: Form.
+THE WITNESS: You're asking for my opinion, and I don't
+think my opinion is relevant in that matter.
+BY MR.
+Q. I think it's relevant. Can you just tell me whether today
+you believe that Jeffrey Epstein has engaged in sex with
+underage girls?
+MR. CRITTON: Form; speculation, irrelevant, always.
+THE WITNESS: It's irrelevant.
+BY MR.
+Q. I need an answer.
+A. I don't believe he had sex with underage women.
+Q. Or engaged in any sexual acts with underage women?
+MR. CRITTON: Form.
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 10 of 26
+LM V. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+THE WITNESS: No.
+BY MR.
+Q.
+You think that this is just a story that a bunch of
+underage women have made up?
+A.
+Speculation.
+** * *
+Q. Then we'll handle the question this way: If you were to
+believe based on information and evidence that Mr. Epstein
+engaged in sex or some form of sex acts with people of the
+age range of 12, 13, 14, 15 years old, would you continue
+your employment with Mr. Epstein?
+MR. CRITTON: Form; speculation.
+THE WITNESS:
+I would certainly be speculating
+and I have to discuss it with my wife long and hard. I don't
+think I could give you a correct and honest answer at this
+time.
+See Excerpts of Deposition of Larry Visokski at 66-67; 181-82 (attached as
+composite Exhibit A). Other examples of similar improper questions are included in
+
+4.
+Not only do these questions seek improper lay opinions, Plaintiff's counsel
+asked Mr. Visoski his belief as to the truth of hearsay newspaper articles. The
+foregoing questions are obviously irrelevant, argumentative and not reasonably
+calculated to lead to the discovery of admissible evidence.
+5.
+Moreover, whether Mr. Visoski would continue working for Mr. Epstein if
+Plaintiff's allegations are true has absolutely no relevance to any claim or defense in this
+case.
+The questions are simply improper and meant to harass and embarrass the
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 11 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+witness.
+6.
+Mr. Visoski was questioned for over four hours and much of the time was
+wasted on irrelevant and harassing questions.
+7.
+Plaintiff's counsel asked similar questions at the deposition of Larry
+Eugene
+another one of Mr. Epstein's pilots:
+Q. Certainly you've read certain newspaper articles about
+the allegations, police reports, otherwise, the allegations that
+occurred or have been alleged to have occurred at his Palm
+Beach mansion, correct?
+A. Uh-huh.
+Q. Correct?
+A. Correct.
+Q. Given the nature of those allegations, would you leave
+your daughter of 17, 16, 15 years old with Mr. Epstein
+alone?
+MR. PIKE: Form. Move to strike.
+A. Yes.
+****
+Q. And despite pleading guilty to procuring underage girls
+for the purposes of sex, you still feel comfortable leaving a
+13, 14, 15-year-old girl around him?
+MR. PIKE: Form. Move to strike.
+A.
+Yes. I mean, with my daughter, yes. I don't know how
+he behaves around anybody else.
+I just know that the
+respect that he showed me, I feel safe with my daughter.
+And have you read in detail the reports as to what
+happened at his house with the girls?
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 12 of 26
+I-M v. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+A. Only -
+MR. PIKE: Form.
+A.
+- what's been in the newspapers and published.
+Q.
+if you read and hear testimony given - well, I can tell
+you now - testimony has been given in this case that what
+happens is: A 13 or 14 year old is led upstairs by herself,
+told to get naked, he lays down on his back, there is a brief
+• he turns over, exposes himself erect,
+masturbates while he tells this 13 or 14 year old to pinch his
+nipples as hard as she can while he inserts his fingers into
+their vagina and ejaculates all over them before saying,
+"Take your money and leave."
+MR. PIKE: Form. Move to strike.
+BY MR.
+Q. Okay? Then, "You can continue to come back for $200
+every time or every girl you bring me within your age group
+and I get to do this again, I pay you $200 per person." If that
+is the testimony -
+MR. PIKE: Form.
+Q. - that what happens behind closed doors with him, do
+you still teel comfortable leaving a 13 or 14 year old in a
+room with Jeffrey Epstein?
+MR. PIKE: Form.
+A.
+If that, in fact, is what actually happened, no.
+****
+Q. [Would you] go back - considering what you've read and
+hat you may or may not believe - would you go back
+orking for Jeffrey Epstein
+MR. PIKE: Form.
+A. I can't say. I still work for him on a maintenance - to
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 13 of 26
+_M v. Epstein
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+maintain the airplanes and stuff like that, so.
+See Excerpts of Deposition of Larry Eugene L
+(attached as composite Exhibit B).
+at 135-36; 175-76; 184
+8.
+Again, whether Mr.
+I would work for Mr. Epstein "considering what
+[he has] read and what [he] may or may not believe" (i.e. considering hearsay media
+accounts and inadmissible lay opinion) has no bearing on the instant case.
+would leave his
+9. In addition, questions regarding whether Mr.
+children alone with Mr. Epstein could have only been meant to harass and embarrass
+I testified that he would leave his children with
+Mr.
+Nevertheless, Mr.
+Mr. Epstein. As Plaintiff's counsel was obviously not happy with the answer to this
+question, he proceeded to press Mr.
+I with inflammatory statements until he got
+the answer he wanted.
+10.
+Plaintiff's counsel has also asked the same improper line of questions in
+other witnesses' depositions.
+11.
+The above-cited questions exceed the bounds of permissible discovery;
+they have absolutely no relevance to this case. Accordingly, the Court should enter a
+protective order prohibiting such questions and should sanction Plaintiff's counsel if
+such inappropriate questions are asked at future depositions.
+12.
+Regarding the scope of discovery, Judge Linnea
+noted in her
+October 28, 2009 Omnibus Order,' "while the scope of discovery is broad, it is not
+The Omnibus Order (DE #377) was entered in the federal companion case Jane Doe No. 2 V. Epstein
+Case No. 08-CIV-80119 MARRA L
+I in the U.S. District Court, Southern District of Florida
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 14 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+without limits. Washington v.
+& Williamson Tobacco, 959 F.2d 1566, 1570 (11th
+Cir. 1992). ... Courts have long held that "while the standard of relevancy [in
+discovery] is a liberal one, it is not so liberal as to allow a party to roam in the shadow
+zones of relevancy and to explore matter (sic) which does not presently appear
+germane on the theory that it might conceivably become so.' Food Lion, Inc. V. United
+Food & Commercial Workers Intern. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997)
+(string cite omitted)." See also Capco Properties, LLC v. Monterry Gardens of Pinecrest
+Condo., 982 So. 2d 1211, (Fla. 3d DCA 2008) (holding that discovery in civil cases must
+be relevant to the subject matter of the case and must be admissible or reasonably
+calculated to lead to admissible evidence); Morton Plant Hospital Ass'n, Inc. v.
+Shahbas, 960 So. 2d 820, 824 (Fla. 2d DCA 2007) (holding that "discovery should be
+denied when it has been established that the information requested is neither relevant
+to any pending claim or defense nor will it lead to the discovery of admissible evidence,"
+citing Tanchel v. Shoemaker, 928 So. 2d 440, 442 (Fla. 5th DCA 2006)).
+13. As illustrated above, the questions are simply not germane to any pending
+claim or defense nor will they lead to the discovery of admissible evidence. Whether
+Mr. Visoski believes or disbelieves the media accounts of this case, or whether Mr.
+would leave his children with Mr. Epstein is not relevant and cannot
+conceivably lead to the discovery of admissible evidence.
+14.
+The Court should curtail these inappropriate lines of questions and enter a
+protective order prohibiting them.
+15. Rule 1.280(c), Florida Rules of Civil Procedure, provides the Court with
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 15 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+the power to "make any order to protect a party or person from annoyance,
+embarrassment, oppression or undue burden or expense that justice requires including
+... (4) that certain matter not be inquired into, or that the scope of the discovery be
+limited to certain matters."
+16.
+Accordingly, Epstein requests the Court enter a protective order
+prohibiting Plaintiff's counsel from asking witnesses' questions regarding opinions and
+beliefs regarding media articles and the allegations in this case and whether they would
+leave their children with Epstein or questions of a similar nature, and limiting the scope
+to the witnesses personal knowledge regarding matters relevant to the claims and
+defenses in this case. See Shahbas, 960 So. 2d at 824.
+WHEREFORE, Defendant, JEFFREY EPSTEIN, respectfully requests the Court
+enter a protective order prohibiting Plaintiff's counsel from asking witnesses' questions
+regarding opinions and beliefs regarding media articles and the allegations in this case
+and whether they would leave their children with Epstein or questions of a similar
+nature, and limiting the scope to the witnesses personal knowledge regarding matters
+relevant to the claims and defenses in this case and grant any additional relief the Court
+deems just and proper.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
+Mail to the following addressees on this 3rd day of November, 2009:
+Brad
+Esq.
+Jack Alan Goldberger, Esq.
+Rothstein Rosenfeldt Adler
+Atterbury Goldberger & Weiss, P.A.
+401 East Las Olas Boulevard
+250 Australian Avenue South
+Suite 1650
+Suite 1400
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 16 of 26
+Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions
+
+Fort Lauderdale, FL 33301
+954-522-3456 Phone
+954-527-8663 Fax
+Counsel for Plaintiff
+West Palm Beach, FL 33401-5012
+Fax: 561-835-8691
+Co-Counsel for Defendant Jeffrey Epstein
+Jay Howell, Esq.
+Jay Howell & Associates, P.A.
+644 Cesery Boulevard
+Suite 250
+Jacksonville, FL 32211
+904-680-1234 Phone
+904-680-1238 Fax
+Co-counsel for Plaintiff
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+(561) 842-2820
+(561) 844-6929 Fax
+By: —
+12497
+Robert B. Critton, Jr.
+Ar Fforida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 17 of 26
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM DEACH COUNTY, PLORIDA
+CASE NO. 502008CA028051XXXXHAD
+L, H.,
+Plaintite,
+-v's-
+JEVEREY EPSTEIN,
+Defendant.
+DEPOSITION OF TARRY VISORI
+ThursdaTe 1037
+F 18. 200%
+15 N. Plogler Drive
+inste 7200
+lest Pali Beach, Florida 33401
+eported By:
+Notary Public,
+Esquire Deposition Services
+West Palm Beach Office
+Job #127542
+1
+6
+9
+10
+11
+12
+13
+2
+: APPEARANCE
+nbehalf of the Plaintiff
+RONNIEN
+L ESQUIR
+IN, ROSENFELDT, ADL
+401 East Las Olas Boulevard
+Suile 1660
+Fort Lauderdale, Florida 33394
+On behalf of the Defendant:
+ROBERT D. CRITTON, JR., ESQUIRE
+BURMAN, CRITTON & LUTTIER
+303 Banyan Boulevard, Suile 400
+West Pain Beach, Florida 39401
+250 South Australlan Avenue
+Suite 1400
+West Palm Beach, Florida 33401
+ALSO PRESENTiN ESQUIRE
+CARA L.
+1220 N.W. 157th Avenue
+Pembroke Pines, Florida 33028
+ADAM D. HOROWITZ, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard, Sulle 2218
+Miami, Florida 33160
+ICHARD H. WILLITS, ESQUIRE (VIA TELEPHON
+ICHARD H. WILLITS, P.
+2290 10th Avenue North, Suite 404
+Lake Worth, Florida 33461
+3
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+118
+/19
+20
+121
+- 22
+23
+124
+25
+ALL STATE LEGALS
+DEFENDANT'S
+
+3
+INDEX
+• ..
+WITNESS:
+LARRY VISOSKI
+BY MR. L
+BY MR. CRITTON:
+BY MR.
+BY MR, CRITTON:
+DIRECT CROSS REDIRECT RECROSS
+214
+220
+221
+EXHIBITS
+NUMBER
+DESCRIPTION
+PAGE
+PLAINTIFF'S EX. 1 FLIGHT LOG BOOK
+(MARKED IN PREVIOUS DEPO)
+PLAINTIFF'S EX. 2
+MEBBAGE PAD
+PLAINTIFF'S EX. 3
+MESSAGE PAD
+PLAINTIFF'S EX. 4
+COMPLAINT
+119
+119
+139
+PLAINTIFF'S EX. 5 INMATE VISITOR LOG
+161
+4
+PROCEEDINGS
+Deposition taken before. Wendy Beath
+Certified Reallime Reporter and Notary Public in and for
+the State of Florida al Large, in the above cause.
+MR.
+I: We're going to put something on
+the record about - well, we'll do it this way -
+MR. REINHART: Do it at the end, after we get
+him - whatever you want. It's your show.
+MR.
+: Okay. There were - I don't
+even think Mr. Willits is aware of this. There was
+a subpoena duces fecum for this witness, as well as
+the previous witness, which was another pilot, Dave
+Rogers, and that duces fecum was to bring the
+flight logs related from 1998 through 2005. What
+was produced at the previous deposition were flight
+logs from 2002 through 2005, and now Mr. Reinhart
+has agreed to produce the remainder of the flight
+logs requested, those going from 1998 through 2002.
+MR. REINHART: Correct. They're pilot logs,
+not flight logs. There are other records we
+Indicated are corporate records, and with those you
+have to deal with Mr. Critton.
+MR. CRITTON: However, with the proviso, too
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 18 of 26
+1
+2
+3
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+66
+Q. All right. When you read in the newspapers
+the allegations that Mr. Epstein was involved with
+numerous underage giris for sexual reasons, were you
+surprised?
+A. I didn't believe it.
+Q. Do you believe it today?
+A. I don't belleve it.
+Q. You don't believe that Jeffrey Epstein was
+involved with underage girls in a sexual way?
+MR. CRITTON: Form.
+THE WITNESS: You're asking for my opinion,
+and I don't think my opinion is relevant in that
+matter.
+BY MR.
+Q. I think it's relevant. Can you just tell me
+whether today you belleve that Jeffrey Epstein has
+engaged in sex with underage girls?
+MR. CRITTON: Form; speculation, irrelevant,
+always.
+THE WITNESS: It's irrelevant.
+BY MR.
+Q. I need an answer.
+A. I don'i believe he had sex with underage
+woren.
+Q. Or engaged in any sexual acts with underage
+67
+women?
+MR. CRITTON: Form.
+THE WITNESS: No.
+BY MR
+Q. You think that this Is Just a story that a
+bunch of underage women have made up?
+?
+A Speculation.
+,8
+MR. CRITTON: Objection. Now it's
+9
+argumentative. Who gives a darn what he thinks one
+10
+way or angther? If he has personal knowledge -
+11
+MR
+3: You're objecting to the form?
+12
+MR. CRITTON: It's argumentative.
+13
+14
+MR.
+5: You're objecting to the form?
+MR. CRITTON: Yes.
+'15
+MR
+8: Okay.
+'16
+BY MR.
+17
+Q. Is that something that you believe that a
+18
+bunch of women - some of which know each other, some
+19% don't, some of which have been on the airplane and some
+20
+which haven" - made this up, that Jeffrey Epstein
+21
+engaged in some sexual conduct with them?
+22
+MR, CRITTON: Form.
+23
+THE WITNESS: What I believe doesn't matter in
+24
+this case, does it?
+25
+68
+1 BY MR.
+2
+3
+4
+5
+6
+7
+฿
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Q. I need an answer. Do you believe it? Do you
+belleve these girls made this up?
+MR. CRITTON: Form.
+MR. REINHART: I'm going to instruct him not
+to answer. Move on.
+MR.
+: is there a privilege that we're
+asserting?
+MR. REINHART: No, It's irrelevant. It's
+harassment and not likely to lead to discoverable
+evidence
+MR.
+: I'm going to put on the record
+right now that it is - we are allowed discovery
+into a RICO count. We are also allowed discovery
+Into the intent of Mr. Epsten in developing a
+criminal enterprise designed to sexually exploit
+and sexually abuse underage girls. We belleve that
+in doing so, he associated intentionally with
+people of similar belief's that sex with underage
+girls is okay, and that there have been many
+discussions with this witness, as weli as many
+other witnesses with -- to insure his protection
+from law enforcement that they not answer these
+specific questions. And thus, the opinions and
+bellefs of all of these witnesses that we are
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 19 of 26
+2
+5
+6
+7
+B
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+5
+6
+7
+8
+69
+alleging associated with this criminal enterprise
+are certalnly reasonably calculated to lead to the
+discovery of admissible evidence. And if you're
+still instructing the witness, based on that
+proffer, not to answer any of these questions, I'm
+going to continue to ask the questions and you can
+instruct him not to answer and we can go to the
+71
+A. It's an opinion, and 1 believe that he has
+2
+3
+4
+5
+not.
+Q. Okay. Isn't it true that at some point in
+lime you leamed that Jeffrey Epstein has - strike
+that.
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. REINHART: My response is to his opinion
+whether people making allagations in this case are
+colluding or making up a story is irrelevant to
+what you just said. So l am going to instruet him
+not to answer any question that goes to his opinion
+of someone else's motivation or the truth of facts
+to which he has no knowledge.
+So yes, I'm instructing him not to answer,
+MR. CRITTON: Let me add in my pari, is that I
+think - you're certainly not only capable to ask
+questions with regard to what his personal
+knowledge is, and if he knows something or he has
+reasonable basis for it; certainly you are entitled
+to that information. I think you've asked those
+questions and he's given you straightforward
+answers as to what he knew or what he didn't know
+under those circumstances. And as to what his
+70
+thoughts are on something which he has no factual
+basis or even an assumption to know one way or
+another is irrelevant. That's ultimately for a
+fact-finder in this case.
+While it's interesting, it's argumentative and
+I don't think he's -- I mean, do it on a
+question-by-question basis, If he has knowledge,
+thal's great, but to argue your case with this
+witness or any olher witness doesn't serve a
+purpose and | think is, you know - I think it's
+not a good use of our time, I'll put it that way.
+But you know, you can go ahead and ask.
+MR.
+* I can ask the question and if
+the witness is being instructed not lo answer,
+we'll let a judge decide whether he needs lo answer
+the question and whether it's discoverable or not.
+MR. REINHART: Absolutely. Make your record.
+BY MR.
+Q. Do you have any reason to believe that Jeffrey
+Epstein engaged in sexual activity with underage women?
+A. I have no reason lo believe.
+Q.
+Okay. So as you sit here today, based on your
+18 years of knowledge, experience and observation of
+Jeffrey Epstein, is it your belief that he has not had
+sex or engaged in sexual activity with underage women?
+MR. CRITTON: When you ullimately get to a
+7
+good place to break, will you let us know?
+8
+MR.
+Let's break now.
+9
+(A break was had at 11:28 a.m.)
+10
+BY MR.
+11
+Q. All right. Eighteen years of being a pilot
+12
+for Jeffrey Epstein and in terms of being able to name
+13
+somebody that you would say you've observed with Jeffrey
+14
+Epstein and would classify that person as Jeffrey
+15
+Epstein's friend, can you name anybody?
+16
+A Nadia, Sarah; just people that we see
+17
+routinely on the airplane.
+18
+Q. That's people you see routinely in the last
+/19
+five to ten years, right?
+120
+A. Yes.
+21
+Q. Prior to that time, anybody that you've
+22
+noliced as Jeffrey Epstein's friend may be Chislaine
+23
+Maxwell?
+24
+A What time frame?
+25
+Q. Is that a person that at some point in time
+72
+1 you would classify as Jeffrey Epstein's friend?
+A. I would classify it. I don't know If it's
+3
+true.
+Q. But thal's only because they were on the
+5
+6
+airplane together?
+A. Yes.
+Q. Do you know what Jeffrey Epstein does for a
+ving in your 18 years of observing and talking with
+Jeffrey Epstein?
+10
+A No.
+11
+Q. No Idea?
+/12
+A. No.
+/13
+14
+Q. Ever asked him?
+A. No, actually.
+15
+Q. Ever been curious?
+16
+A. Sure.
+17
+Q. Everdone anything to satisfy that curiosity?
+18
+A. If you mean Google it, not really, actually.
+119
+I mean, I really have not.
+20
+Q Okay. So in 18 years of traveling and being
+21
+The pilot and driving -- and taking this person, Jeffrey
+22
+Epsteln, from one property in New York to New Mexico and
+23
+Florida and around the world, you have no idea what he
+24
+does in terms of how he makes money?
+25
+A No, sir.
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 20 of 26
+156
+1
+MIR. CRITTON: Form.
+THE WITNESS: No.
+BY MR.
+Q. If you had been aware that Mr. Epstein was -
+• B
+and by this - this is more in the form of a
+9
+hypothetical, and that I'm not going.to suggest to you
+10
+It's a fact that he was. But if you had been aware that
+11
+every single day Jeffrey Epstein's goal was to locate
+12
+underage girls for the purposes of sex, and either have
+13
+sex with them on the airplane or at some other
+14
+designation that you were destination that you were
+15
+traveling him to, would you have continued to pliot
+16
+those planes?
+MR. CRITTON: Form.
+THE WITNESS: You said it was hypothetical?
+18
+19
+20
+21
+22
+13
+14
+15
+BY MR.
+Q. Right, it is a hypothetical.
+A. Why would I want to answer that? Because
+you're being hypothetical. I mean, it would obviously
+be wrong
+Q. Sure. Well, a hypothetical question is a
+legal question that I'm allowed to ask.
+
+
+Case 9:09-CV-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 21 of 26
+10
+11
+12
+13
+14
+15
+16
+20
+21
+22
+23
+24
+25
+1
+2
+157
+A. Okay.
+Q. And I'm just asking you if you did have
+knowledge that Jefirey Epslein was having sex with
+Ittle girls either on the plane or at a piace that you
+were taking him to or from on a daily basis, that's what
+he did, would you have continued to be his pilol?
+MR. CRITTON: Lel me object. Object to the
+form, It's argumentative. It has no more value
+than assuming he was chopping up bodies or anybody
+was chopping up bodies in the plane you're flying.
+What difference does it make? Form.
+MR.
+What difference does it make in
+a case about him having sex with little girls? I'm
+not going to argue with you about it. You've
+stated your objection.
+MR. CRITTON: Exactly, Il's an argumentative
+question.
+MR.
+I'm not going lo argue with you
+about it.
+MR. CRITTON: You're arguing with him about
+now.
+MR.
+No, I'm asking him the
+hypothetical.
+BY MR.
+158
+7
+9
+10
+11
+12
+13
+girls?
+MR. CRITTON: Form.
+THE WITNESS: It could be any person. It
+doesn't have to be Jeffrey Epstein, then, right?
+BY MR. [
+Q. True.
+A. No, I wouldn't pilot an airplane if there was
+wrongdoing going on.
+Q. That you knew about?
+A. That! knew you about, sure.
+first time you've heard these allegations --
+A. Yes.
+Q.
+- against Mr. Epstein?
+A
+Yes.
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 22 of 26
+2
+4
+5
+6
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+2
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+21
+22
+23
+24
+25
+181
+which he pled guilty to -
+MR. CRITTON: Form.
+MR. REINHART: Can we - for purposes of your
+hypothetical, what facts do you want him to assume
+are true? You said the facts to which he pled
+guilty, but the witness already said he doesn't
+know what he pled guilty to. He knows the charge
+he doesn't know the facts.
+BY MR.
+Q. Solicitation of prostitution of a minor,
+somebody under the age of 18.
+MR.
+That's the charge, right,
+solicitation of prostitution of a minor?
+MR. CRITTON: No. I think you've got it
+wrong. I'l object to the form.
+MR.
+BY MR.
+Q. Then we'll handle the question this way: If
+you were to believe based on information and evidence
+that Mr. Epslein engaged in sex or some form of sex act
+with people of the age range of 12, 13, 14, 15 years
+old, would you continue your employment with
+Mr. Epstein?
+MR. CRITTON: Form; speculation.
+THE WITNESS: 1 would certainly be speculating
+182•
+and 1 have to discuss it with my wife long and •
+hard. I don't think I could give you a correct and
+honest answer at this time.
+BY MR.
+Q. Okay. Given the allegations that have been
+made in this case, is this something that you have
+discussed with anyone other than your attorney?
+A. No, not really. Only from the fact that
+theyre allegations and there's still a lot more work,
+I'm sure, lo be discovered
+MR. CRITTON: Let me put on there, for the -
+If this deposition Is not typed - and we request
+it - I'd like at least this portion where
+Mr.
+last question back about five pages
+worth, so just if you could mark it from this
+page back about five pages.
+If nobody requests the deposition, Id just
+like those five pages.
+MR. M
+: I'm going to request the
+deposition, so...
+MR. CRITTON: Okay. Well mark this then, so
+you could tell me where it is, approximately.
+BY MR. I
+Q. Is there a reason why you have not discusse
+with Jeffrey Epstein the allegations that have been m
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 23 of 26
+Larry Eugene
+- Volume I
+1
+IN THE CIND FOR PALM BERCE GOTH HEAL ATACUTE IN
+VOLNE I
+Pages 1 to 200
+La.M.,
+Paintitt,
+Case No. 50200BCA028051
+і ХХХхНа л
+DEPFREY EPSTEIN,
+Defendant.
+MARRY BUSTED BI
+TAKEN ON DEHALF OF THE PLAINTIFT
+October 5, 2009
+10:55 a.m. - 2:20 p.m.
+Meat Bai: PE 05401-9321
+Jennifer Dilorenzo, court reporter
+4
+5
+10
+111
+12
+13
+114
+15
+16
+17
+23
+25
+October 6, 2009
+3
+APPEARANCE OF COUNSEL
+On behalf of the Defendant:
+ATTERBURY, GOLDBERGER & WEISS
+BY: JACK ALAN GOLDBERGER, ESQ.,
+250 Australan Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-659-8300
+igoldbergen@agwpa.com
+On behalf of the Defendant by telephone:
+BURMAN, CRITTON, LUTTER & COLEMAN
+BY: MICHAEL J. PIKE, ESQ.,
+515 N. Flagler Drivo
+Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+mpike@bolelaw.com
+On behalf of the witness:
+LAW OFFICE OF BRUCE E. REINHART
+BY: BRUCE E. REINHART, ESQ.,
+One Clearlake Center
+250 8, Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6380
+BReinharl@BruceREinhartLaw.com
+4
+/12
+==
+15
+16
+17
+20
+21
+22
+24
+25
+2
+APPEARANCES OF COUNSEL
+On behalf of the Plainlf L.M.:
+ESQ.
+and MICHAEL WF
+401 Easl Las Oles Boulevard
+Sulle 1650
+Fert Louderdalo, FL 33394
+954-522-3458
+bechwards@rra-iaw.com
+mahesler@ra-law.com
+On bahalf of Plainlits Jane Doe 2 through 0;
+ME. JESSICA D, ANDRUR AT DANEY-AT-LAW.
+18205 Biscayne Boulevard
+Sulle 2218
+Maml, FL 33100
+305-931-2200
+jarbour@soxabusesliornay.com
+near lanet an on 101 an 10207
+DHURST ORSECK, P
+KATHERINE W. EZELL, ATTORNEY-AT-L
+25 W. Flaglor Street
+Miami, FL 33130
+305-355-2000
+kozelk@podhurst.com
+On behalf of Uhe Plainilf C.M.A. by lelephone:
+LAW OFFICE OF RICHARD WILLITS, P.A.
+BY: RICHARD WAITS, E5G.,
+2290 100 Avenue N.
+Sule 404
+Lako Worth, FL 33461
+561-562-7500
+luwyarwifts@aol.com
+4
+INDEX OF EXAMINATION
+WITNESS:
+LARRY EUGENE
+Page
+BYRE KANATION
+$5
+CROSS-EXAMINATION
+1. Ezell
+CROSS-EXAMINATION
+By Mr. Willts
+·190
+#195
+10
+CROSS-EXAMINATION
+12
+By Mr. Pike
+EY. LEE REDIRECT EXAMINATION®
+By Mr.
+#199
+25
+INDEX TO EXHIBITS
+Passenger Manifest.*
+22
+125
+I DEFENDANT'S
+*EXHIBIT.
+TTU
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 24 of 26
+October 6, 2009
+135
+1
+A I have no Idea. I don't know.
+Q. When you say tha
+was just
+3
+coming in the picture, what's your understanding as to
+who
+a is relative 1o Mr. Epsteln?
+5
+A I don't know. I don't understand. I
+don't know. I didn' know if maybe she was like an
+exchange - Jeffrey always appeared to be very
+8
+involved in education and philanthropy. I didn't
+know if she was an exchange-type student or something
+10
+or what. I don't know.
+21
+Q. When you say he appeared to be Involved in,"
+12
+what do you mean?
+13
+A. Educational things, foundations, science
+11
+foundations, and things.
+15
+Q. Speaking of - the Flonda Science Foundation
+16
+Is a place where, when he was on work release, he spent a
+17
+lot of time there, you're aware of thal?
+1B
+A That's what /ve heard, yeah.
+18%
+Q. What does that place do?
+20
+A I have no idea.
+21
+Q. Does it do anything?
+22
+A I dont know. I don't know anything about
+23
+24
+25
+Q. Cartainly you've read certain newspaper
+articles about the allegations, police reports,
+136
+1
+:
+2
+otherwise, the allegations that occurred or have been
+alleged to have occurred at his Palm Beach mansion,
+3 correct?
+4
+A. Uh-huh.
+5
+Q. Correct?
+6
+A. Correct.
+7
+Q. Given the nature of those allegations, would
+you leave your daughter of 17,18, 15 years old with Mr.
+9
+Epstein alone?
+,10
+11
+MR. PIKE: Form. Move to strike.
+12
+A. Yes.
+Q. You would?
+13
+14
+A. (Witness nods head.)
+15
+Q. And why?
+16
+A. Because I don" fear that he would try
+17
+anything with my daughter. He showed - When
+worked for him he showed me respect. He never -
+• 18
+never - He never showed me disrespect. He would ask
+19
+how the family is. 1 mean, not on a personal level,
+20
+but an employer/employee.
+21
+Q. Right. Okay.
+22
+A. He never showed me any reason not to trust
+23
+him.
+24
+Q. But you're not a 13-year old girl, so.
+25
+A. No, but, like I say, he never showed me
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 25 of 26
+october 6, 2009
+175
+1°
+3
+4
+Q. And despite pleading guilty to procuring
+underage girls for the purposes of sex, you still feel
+comfortable leaving a 13, 14, 15-year-old girl around
+him?
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+1 14
+19
+20
+21
+22
+23
+24
+25
+MR. PIKE: Form. Move to sirike.
+A. Yes. I mean, with my daughter, yes. I
+don't know how he behaves around anybody else. !
+just know that the respect that he showed me, I feel
+safe with my daughter.
+Q. And have you read in detail the reports as to
+what happened at his house with the glris?
+A. Only -
+MR. PIKE: Form.
+A. - what's been in the newspapers and
+Q. If you read and hear testimony given - well, I
+can tell you now - lestimony has been given in this case
+that what happens is: A 13 or 14 year old is led
+upstairs by herself, told to get naked, he lays down on
+his back, there is a brief massage before he turns over,
+exposes himself erect, masturbates while he tells this 13
+or 14 year old to pinch his nipples as hard as she can
+while he Inserts his fingers into their vagina and
+ejaculates all over them before saying, "Take your money
+176
+MR. PIKE: Form. Move to strike.
+1
+2 BY MR.
+3
+Q. Okay? Then, "You can continue to come back
+4
+for $200 every time or every girl you bring me within
+5
+your age group and 1 get to do this again, I pay you $200
+per person." If that is the testimony -
+MR. PIKE: Form.
+Q. - that what happens behind closed doors with
+him, do you still feel comfortable leaving a 13 or 14
+10
+year old in a room with Jeffrey Epstein?
+11
+MR. PIKE: Form.
+12
+A. If that, in fact, is what actuaily
+13 happened, no.
+
+
+Case 9:09-cv-80656-KAM Document 55 Entered on FLSD Docket 11/09/2009 Page 26 of 26
+1
+2
+3
+4
+5
+7
+9
+10
+11
+12
+13
+15
+16
+17
+10
+19
+20
+21
+22
+23
+24
+25
+184
+you witnessed Jeffrey Epstein committing?
+A. No.
+Q. Would you -
+A. No.
+Q. - go back - considering what you've read and
+what you may or may not believe - would you go back to
+working for Jeffrey Epstein?
+MR. PIKE: Form.
+A. I can't say. I still work for him on a
+maintenance - fo maintain the airplanes and stuff
+iike that, so.
+Q. You're on his payroll?
+A. Salaried, yes.
+Q. Do you know who else Is on hls payroll?
+A. Well, Dave and Larry.
+Q. Cerfainly, ifI want to know more about his
+private life - do you know who's at his house?
+A. No.
+Q. Do you know who his housekeeper Is?
+A. No.
+Q. Do you know who his architect is?
+A. No, no.
+Q. Does Larry visit him at his house?
+A. I would assume so.
+Q. Why do you say you would assume so? That
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/f934b6c40458bf1ea11f24a993423db6ed130bcff37657b650135faaa12bca72.md b/vision-fixhub/court-01/f934b6c40458bf1ea11f24a993423db6ed130bcff37657b650135faaa12bca72.md
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@@ -0,0 +1,710 @@
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 1 of 20
+#281849/clw
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80811-CIV-
+MARRA/
+C.M.A.,
+Plaintiff(s),
+VS.
+JEFFREY EPSTEIN and
+Defendant(s).
+NOTICE OF SERVING
+ANSWERS TO INTERROGATORIES
+COMES NOW the Plaintiff, C.M.A., by and through undersigned counsel, and hereby
+files this Notice with the Court that Answers to Interrogatories propounded by the Defendant,
+JEFFREY EPSTEIN, on January 16, 2009, have been furnished to the attorney for the
+Defendant.
+I HEREBY CERTIFY that a true copy of the foregoing has been furnished by mail this
+18T day of February, 2009, to: See attached list of counsel.
+TACK SCAROLA
+Florida Bar No.: 169440
+JACK P.|
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+PLAINTIFF'S
+
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 2 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+ANSWERS TO INTERROGATORIES
+What is the name and address of all persons answering or assisting in answering
+these interrogatories, and, if applicable, the person's official position oi
+relationship with the party to whom the interrogatories are directed?
+C.M.A.
+c/o her attorneys:
+Jack Scarola, Esq. and Jack P.
+_ Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+2.
+List the names, business addresses, telephone and cell phone numbers, dates of
+employment, immediate supervisor (name and address) and rates of pay
+regarding all employers, including self-employment, for whom you have worked
+in the past 10 years; this includes listing all sources of income you have received.
+Answer this question by year, i.e. 1998-2009.
+Objection. Irrelevant, immaterial and not reasonably calculated to lead to
+discovery of admissible evidence.
+by name, date of birth and the father's name and address. List the names and
+Nickname- Brooke
+2
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 3 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+2210 48 Terrace North
+Dates: July, 2007-Present
+West Palm Beach, FL. 33417
+5168 Pat Place
+Dates: February, 2004- July, 2007
+West Palm Beach, FL.
+Rome, Georgia
+Dates: August, 2003-February, 2004
+1403 Suwanee Drive
+West Palm Beach, FL. 3340 Dates: About 2% years ago
+Tals Palmo Beach, FL. 3340฿
+Dates: Approximately 1 year
+SSN- 052-72-3510 DOB- 1/2/87
+I have never been married.
+Children:
+DOB: 3/12/04
+Father:
+Address: 1603 Plantation Lane
+West Palm Beach, FL. 33407
+Brayden Gilchrest DOB: 3/25/08
+Father: Donald Gilchrest
+Address: West Palm Beach, FL.
+Parents:
+(Father)
+Address Unknown
+Dorothy (Mother)
+2210 48 Terrace North
+West Palm Beach, FL. 33417
+Siblings:
+(Brother)
+3
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 4 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+4.
+Have you ever been convicted of a crime, other than any juvenile adjudication,
+which under the law under which you were convicted was punishable by death or
+imprisonment in excess of 1 year, or that involved dishonesty or a false
+statement regardless of the punishment? If so, state as to each conviction the
+specific crime and the date and place of conviction.
+No
+Please provide the name, address, telephone number, place of employment and
+ob title of any person who has, claims to have or whom you believe may hav
+nowledge or information pertaining to any fact alleged in the pleadings (a
+defined in Federal Rule of Civil Procedure 7(a) filed in this action, or any fact
+underlying the subject matter of this action).
+C.M.A.
+2.
+c/o her attorneys:
+Jack Scarola, Esq. and Jack P., Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Tel: (561) 686-6300
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Tel: (561) 582-7600
+Subject matter:
+Plaintiff.
+Jeffrey Epstein
+clo his attorneys:
+Robert Critton, Esquire
+Burman Critton Luttier & Coleman LLP
+4
+
+
+Entered on FLSD Docket 06/08/2009 Page 5 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Tel: (561) 842-2820
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+West Palm Beach, FL 33401
+Tel:
+(561) 863-9100
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+Tel: (561) 202-6360
+Subject matter: Defendant
+C.M.A.'s mother, Dorothy, and her brother,
+c/o C.M.A.'s attorneys:
+Jack Scarola, Esq. and Jack P. Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Tel: (561) 686-6300
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10th Avenue North, Suite 404
+Lake Worth, FL 33461
+Tel: (561) 582-7600
+Subject matter:
+C.M.A.'s involvement with Epstein.
+4.
+(Address unknown)
+Subject matter:
+Defendant.
+5
+
+
+Entered on FLSD Docket 06/08/2009 Page 6 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+5.
+Jane Doe (Case No.: 1:93-cv-01109-KAM)
+c/o her attorney:
+Theodore Leopold, Esquire
+Leopold, Kuvin, P.A.
+2925 P.G.A. Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Tel: (561) 515-1400
+6.
+8.
+Subject matter:
+Victim of Epstein.
+Jane Doe (Case No.: 502008CA020614)
+c/o her attorney:
+Isidro M.
+_. Esquire
+202 Law Office oreet, Si
+& Associates, LLC
+Street, Suite 202
+Hollywood, FL 33020
+Tel: (954) 414-8033
+Subject matter:
+Victim of Epstein.
+Jane Doe #2 (Case No.: 9:08-cV-80119-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Tel: (305) 931-2200
+Subject matter:
+Victim of Epstein.
+Jane Doe #3 (Case No.: 9:08-cv-80232-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Tel: (305) 931-2200
+6
+
+
+Entered on FLSD Docket 06/08/2009 Page 7 of 20
+Case No.: 08-CV-80811-CIV-MARRA
+Plaintiff's Answers to Defendant's First Interrogatories
+Subject matter:
+Victim of Epstein.
+Jane Doe #5 (Case No.: 9:08-cv-80381-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Tel: (305) 931-2200
+Subject matter:
+Victim of Epstein.
+10.
+Jane Doe #4 (Case No.: 9:08-cv-80380-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Tel: (305) 931-2200
+Subject matter:
+Victim of Epstein.
+11.
+Jane Doe (Case No.: 9:08-cV-80804-KAM)
+c/o her attorney:
+Theodore Leopold, Esquire
+_eopold, Kuvin, P.A
+2925 P.G.A. Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Tel: (561) 515-1400
+Subject matter:
+Victim of Epstein.
+12.
+Jane Doe #7 (Case No.: 9:08-cv-80993-KAM)
+c/o her attorney:
+Jeffrey M. Herman, Esquire
+Herman & Mermelstein, P.A.
+7
+
+
+Entered on FLSD Docket 06/08/2009 Page 8 of 20
+Case No.: 08-CV-80811-CIV-MARRA/I
+Plaintiff's Answers to Defendant's First Interrogatories
+18205 Biscayne Boulevard, Suite 2218
+Miami, FL 33160
+Tel: (305) 931-2200
+Subject matter: Victim of Epstein.
+13.
+A.C. (Case No.: 502008CA025129XXXXMB Al
+c/o her attorneys:
+14.
+16.
+17.
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Tel: (561) 686-6300
+Subject matter:
+Victim of Epstein.
+Jose Alessi
+(Address unknown at this time)
+Subject matter:
+Jeffrey Epstein's !
+Janusa Banasiack
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter:
+Investigator.
+Lanaa Belohavek
+Palm Beach County Prosecutors Office
+401 North Dixie Highway
+West Palm Beach, FL 33401
+Tel: (561) 355-7100
+Subject matter:
+Prosecutor.
+Detective Dawson, lead investigator
+8
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 9 of 20
+Plaintiff's Answers to Defendant's First Interrogatories
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter:
+Investigator.
+18.
+Anthony
+155
+19.
+20.
+21.
+22.
+Street
+Palm Beach, FL 33411-1228
+Subject matter: Former boyfriend of a victim of Epstein.
+Sgt. Frich
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter: Investigator.
+Shawn W. Haught
+1603 Plantation Lane
+West Palm Beach, FL 33417
+Subject matter: Plaintiff's former boyfriend.
+Tony Higgins, supervisor
+Sanitation Bureau of the Town of Palm Beach
+3101 N.W. 16" Terrace
+Pompano Beach, FL 33064
+Tel: (877) 46-WASTE
+Subject matter:
+The incident which is the subject matter
+of this lawsuit. Discovery is ongoing.
+Major Kniesley
+Palm Beach County Sheriff's Office
+3228 Gun Club Road
+West Palm Beach, FL 33406
+(561) 666-3000
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 10 of
+Plaintiff's Answers to Defendant's First Interrogatories
+Subject matter:
+Investigator.
+23.
+Amanda, friend of C.M.A
+(Address will be provided upon receipt)
+Subject matter:
+Victim and friend of C.M.A.
+24.
+Ghislane Maxwell c/o Ghislane Corp.
+3580 Brillo Way
+Palm Beach, FL 33480
+Subject matter:
+Associate of Epstein.
+25.
+Susan Pope
+Parent Child Center
+West Palm Beach, FL
+Subject matter:
+Counselor at Parent Child Center.
+26.
+Detective
+Recarcy
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter:
+Investigator.
+27. Chief Michael Reiter
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter:
+Investigator.
+28.
+(Address unknown at this time)
+Subject matter: Associate of Epstein who facilitated introductions
+with various victims.
+10
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 11 of
+Case No.: 08-CV-80811-CIV.
+Plaintiff's Answers to Defendant's First Interrogatories
+29.
+30.
+31.
+32.
+33.
+34.
+Alfredo Rodriguez
+(Address unknown at this time)
+Subject matter:
+Employee of Epstein.
+Detective
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Tel: (561) 838-5480
+Subject matter: Investigator
+Jeffrey Slomon, Esquire
+First Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+Suite 400
+West Palm Beach, FL 33401
+Tel: (561) 820-8711
+Subject matter: Federal prosecutor.
+Twila
+Federal Bureau of Investigation
+505 South Flagler Drive, Suite 500
+West Palm Beach, FL 33401
+Subject matter: Investigator.
+Dr. Thys
+Address will be provided upon receipt
+West Palm Beach
+Subject matter:
+C.M.A.'s physician.
+Villafana
+Assistant U.S. Attorney
+U.S. Dept. of Justice
+500 South Australian Avenue
+11
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 12 of
+Plaintiff's Answers to Defendant's First Interrogatories
+Suite 400
+West Palm Beach, FL 33401
+Tel: (561) 820-8711
+35.
+Subject matter:
+Federal prosecutor.
+Kelly, friend of C.M.A's mother
+(Address will be provided upon receipt)
+36.
+37.
+Subject matter:
+Friend of C.M.A's mother.
+Dominique, friend of C.M.A.'s mother
+(Address will be provided upon receipt
+Subject matter: Friend of C.M.A.'s mother
+Virginia, friend of C.M.A
+(Address will be provided upon receipt)
+Subject matter:
+Potential victim and friend of C.M.A.
+38.
+(Address unknown at this time)
+Subject matter: Associate of Epstein who may have been involved
+in encounters between Epstein and C.M.A.
+Please state the specific nature and substance of the knowledge that you believe
+the person(s) identified in your response to interrogatory no. 5 may have.
+Please see answer to Interrogatory #5
+Were you suffering from physical infirmity, disability, disease, sickness, or
+sychiatric/psychological condition at the time of the incidents) described in th
+complaint? If so, what was the nature of the infirmity, disability, or sickness'
+12
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 13 of
+Plaintiff's Answers to Defendant's First Interrogatories
+8.
+10.
+11.
+School behavioral problems, received counseling prior to the incident.
+Did you consume any alcoholic beverages or take any drugs or medications
+within 12 hours before the time of each incidents) described in the complaint? If
+so, state the type and amount of alcoholic beverages, drugs, or medication which
+were consumed, and when (dates) and where you consumed them.
+1. On one occasion I had taken "Morning Glory" and "Angel Trumpets". I
+do not recall the date.
+2. On another occasion I used cocaine powder. I do not recall the date.
+Describe each injury (physical, emotional, mental) for which you are claiming
+damages in this case, specifying the part of your body that was injured, the
+nature of the injury and as to any injuries you contend are permanent, the effects
+on you that you claim are permanent.
+I have bi-polar disorder and manic depression. I lost my self-esteem. I
+began cutting myself on my arms and legs and developed drug problems.
+Permanent injuries are psychological.
+Please state each item of damage that you claim, and include in your answer: the
+count to which the item of damages relates; the factual basis for each item of
+damages; and an explanation of how you computed each item of damages,
+including any mathematical formula used.
+I am claiming compensation for mental anguish, mental pain, psychic
+rauma, and loss of enjoyment of life. These damages will be evaluated by
+jury who will provide their own methods of computation in an amount o
+at least the statutory minimum established by 18 U.S.C.A. § 2255.
+Discovery is ongoing.
+List the names and business addresses of each physician (including psychiatrist,
+psychologist, chiropractor or medical provider) who has treated or examined you,
+13
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 14 of
+Plaintiff's Answers to Defendant's First Interrogatories
+and each medical facility where you have received any treatment or examination
+for the injuries for which you seek damages in this case; and state as to each the
+date of treatment or examination and the injury or condition for which you were
+examined or treated.
+Dr. Serge Thys (Psychiatrist)
+2151 45" Street
+Date: I do not recall the date. I would defer
+to the Doctor's records.
+West Palm Beach, FL. 33407
+Susan Pope (Counselor/Therapist) Date: Since high school. Ongoing.
+Parent Child Center
+2001 W. Blue Heron Boulevard
+List the names and business addresses of all other physicians, medical facilities,
+rehab facilities (drug, alcohol or psychiatric) or other health care providers
+including psychiatrist, psychologist, mental health counselor and chiropractors by
+whom or at which you have been examined or treated in the past 10 years; and
+state as to each the dates of examination or treatment and the condition or injury
+Good Samaritan Hospital (3/12/04, 3/25/08)
+Child Birth
+1309 N Flagler Dr
+West Palm Beach, FL 33401
+St. Mary's Hospital (4/07)
+DNC
+901 45t Street
+West Palm Beach, FL 33407
+Gloria C. Hakkarainen, MD
+2825 10* Avenue North, Suite 305
+Palm Springs, FL. 33461
+Theodore Ritota, DDS
+Dentist
+14
+
+
+Case 9:08-cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 15 of
+Plaintiff's Answers to Defendant's First Interrogatories
+3401 South Federal Highway
+Delray Beach, FL. 33483
+Palm Beach County Healthcare Department
+Flu Shots
+45" Street
+West Palm Beach, FL. 33407
+FAU Wellness Center
+1650 Osceola Drive
+West Gate, FL. 33407
+State the name and address of every person known to you, your agents, or your
+attorneys, who has knowledge about, or possession, custody, or control of, any
+model, plat, map, drawing, motion picture, video tape, or photograph pertaining
+to any fact or issue involved in this controversy; and describe as to each, what
+item such person has, the name and address of the person who took or prepared
+it, and the date it was taken or prepared.
+The FBI has photos taken of me at Jeffrey Epstein's home by
+Jeffrey Epstein had a photo taken of me at his home by
+Please state if you (or parents or guardian on your behalf) have ever been a
+party, either plaintiff or defendant, in a lawsuit other than the present matter, and,
+if so, state whether you were plaintiff or defendant, the nature of the action, and
+the date and court in which such suit was filed.
+15.
+No
+List all dates you allege you were at Mr. Epstein's home in Florida, include date,
+time arrived and left, the name(s) of anyone who went with you to the home
+when you were there, the time spent with Mr. Epstein and the name(s) and
+address of any individuals who were present in the home with Mr. Epstein and
+you.
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 16 of
+Case No.: 08-CV-80811-CIV-MARRA/.
+Plaintiff's Answers to Defendant's First Interrogatories
+From May or June of 2002 to August of 2003 | went to Mr. Epstein's home
+on average 2 times a week. There were weeks when I would go 4 times a
+week. All my visit dates were maintained by Jeffrey Epstein and his staff in
+a phone message book kept on a table by the phone in the kitchen.
+16.
+17.
+Discovery is ongoing.
+State in detail how you came to be at Mr. Epstein's home on each occasion, i.e.
+did someone bring you or ask you if you would or wanted to go; if so, state the
+name and address of that individual and what he/she told you and the purpose of
+your visit.
+I was introduced to Jeffrey Epstein by my friend Virginia in 2002. I was to
+give Jeffrey Epstein a massage. I continued to provide massages up until
+August of 2003. I was transported to Jeffrey Epstein's house by Yellow
+Cab, provided by Jeffrey Epstein, Virginia, my ex-boyfriend Shawn Haught,
+ny mother Dorothy Groenert and my brother
+Virginia
+(Address will be provided upon receipt)
+State the amount of monies (or anything else of value, including gifts) you claim
+were given or paid to you by Mr. Epstein (or someone paid/gave you on his
+behalf and that person's name, address and phone number) by year from 2000-
+2006.
+$200-$300 for a massage session at an average of 2 sessions a week from
+May or June of 2002 to August 2003
+$500 for a photo taken by
+at Jeffrey Epstein's house
+Paid for taxi cabs
+Concert tickets-Incubus, delivered by two girls at the concert
+Clothes and lingerie sent by FedEx
+Book-Massage for Dummies
+Flowers
+Express gift card
+
+
+Case 9:08-CV-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 17 of
+Plaintiff's Answers to Defendant's First Interrogatories
+List separately the names, addresses and phone numbers of all males, excluding
+Mr. Epstein, with whom you have had sexual activity since age 10 (by year) up
+through your current age. Describe the nature of sexual activity, the date(s) and
+whether you received money or other consideration from the person.
+Objection. Relevance and overbroad.
+List separately the names, addresses and phone numbers of all males, excluding
+your claims against Mr. Epstein, whom you have claimed (formally or informally)
+committed sexual assault or battery on you since age 10 (by year) up through
+your current age. Describe the nature of sexual assault or battery, the date(s)
+and whether you received money or other consideration from the person.
+None.
+committed lewd or lascivious conduct to you since age 10 (by year) up through
+your current age. Describe the lewd or lascivious conduct, the date and whether
+you received money or other consideration from the person.
+None
+21.
+State the names, addresses and phone numbers of all males, excluding your
+whether you received money or other consideration from the person
+None
+22.
+List in detail all discussions/interviews which you had with any representative
+17
+
+
+Case 9:08-Cv-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 18 of
+Plaintiff's Answers to Defendant's First Interrogatories
+from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County).
+Palm Beach Sheriff's Office and Palm Beach Police Department regarding your
+meetings with Mr. Epstein. Include dates, who was present, the details of what
+was discussed, whether a court reporter was present and whether a taped
+statement was taken or whether you provided a written statement.
+23.
+24.
+25.
+I was interviewed by the FBI and a State Attorney, they have my statement.
+State the names, addresses, ages, phone numbers and dates of all females
+whom you claim were brought by you to Mr. Epstein's home to give him a
+massage or for any other reason. As to each female, state the amount of money
+you claim you were paid to bring each female.
+A.L. Age: 22
+West Palm Beach, FL.
+I was paid $100.00
+Please list each time you were interviewed by any state or federal law
+enforcement agent or prosecutor, who was present, whether notes were taken
+and what vou recall saving to them
+I do not recall who interviewed me. This information would be available in
+the FBI and Prosecutors office. They took notes and I was not provided
+with a copy of those notes.
+Please describe any statements made to you by any federal or state law
+enforcement agent or prosecutor regarding the availability of civil remedies
+against Mr. Epstein and regarding whether there would be any benefit from your
+voluntary cooperation with law enforcement.
+None
+18
+
+
+Case 9:08-CV-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 19 of
+Plaintiff's Answers to Defendant's First Interrogatories
+Carolinaput indian
+Signature of Answering Part
+STATE OF
+Florida
+)
+COUNTY OF Palm Beach )
+The foregoing instrument was acknowledged before me this 17
+_ day of February, 2009
+who is personally known to me or who has produced
+(type of identification) as identification and who did/did
+not take an oath.
+Notary Public
+State of Florida at Large
+My Commission expires:
+Commission No:
+Slee of Penite
+465,8012
+0 753017
+19
+
+
+Case 9:08-CV-80119-KAM Document 147-1 Entered on FLSD Docket 06/08/2009 Page 20 of
+Plaintiff's Answers to Defendant's First Interrogatories
+COUNSEL LIST
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S.
+West Palm Beach, FL 33401
+Phone: (561) 863-9100
+Attorneys for Jeffrey Epstein
+Bruce E. Reinhart, Esquire
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue
+Suite 1400
+Vest Palm Beach, FL 3340
+hone: (561)-202-636
+Fax: (561)-828-0983
+Attorneys for
+- Robert Critton
+Burman Critton Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33414
+Phone: (561)-842-2820
+Fax: (561)-844-6929
+Attorneys for Jeffrey Epstein
+Richard H. Willits, Esquire
+lawyerwillits@aol.com
+Richard H. Willits, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, FL 33461
+Phone: (561)-582-7600
+Fax: (561)-588-8819
+Attorneys for Party
+20
\ No newline at end of file
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new file mode 100644
index 0000000000000000000000000000000000000000..afdf9c98b0eee931cf12df6187340fad8303fe71
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 22,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-01/f93668e4a456853205056759433843752d65d7e63cf4d1aa8753996af30b19ce.md b/vision-fixhub/court-01/f93668e4a456853205056759433843752d65d7e63cf4d1aa8753996af30b19ce.md
new file mode 100644
index 0000000000000000000000000000000000000000..12a9e1f56b8c5e12417d04494cf87a6db4cd6e0c
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@@ -0,0 +1,227 @@
+Case 9:08-cv-80381-KAM Document 29
+Entered on FLSD Docket 07/18/2008 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-80381-CIV-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S MEMORANDUM OF LAW IN
+RESPONSE TO DEFENDANT'S MOTION FOR STAY
+Plaintiff, Jane Doe No. 5, by and through her undersigned counsel, submits this
+Memorandum of Law in Response to Motion for Stay, as follows:
+INTRODUCTION
+Defendant Jeffrey Epstein's Motion to Stay this action is based on the incorrect premise that
+there are criminal actions pending against him in Palm Beach Circuit Court, State of Florida v.
+Jeffrey Epstein, Case No. 2006 CF 09454 AXXMB (Fifteenth Judicial Circuit, Palm Beach County),
+and in the Southern District of Florida, In re Grand Jury, No. FGJ 07-103 (WPB) (S.D. Fla.). The
+Motion to Stay as to the state court criminal action was rendered moot on June 30, 2008 when
+Jeffrey Epstein entered a plea of guilty to violations of Florida Statute $796.07 (felony solicitation of
+prostitution) and §796.03 (procurement of minors to engage in prostitution) in the state criminal
+action. (See Defendant's Notice Concerning Motion to Stay dated July 1, 2008). Jeffrey Epstein,
+now an admitted sex offender, was sentenced to a term of imprisonment followed by community
+control and sex offender registration.
+As to the federal prosecution, Defendant's mistitled "Notice of Continued Pendency of
+- 1-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 2 of 9
+Federal Criminal Action," which has now been unsealed, makes clear that there is in fact no criminal
+federal action pending. This Notice discloses a confidential Agreement between the U.S. Attorney
+and Defendant, the terms of which were triggered when Epstein began serving his state imposed
+criminal sentence. Under the Agreement, according to the Notice, the U.S. Attorney "agreed to
+suspend its grand jury investigation", while "retain[ing] the right to reactivate the grand jury and
+indict Mr. Epstein should he breach any part of the Agreement during its term, which runs for 33
+months, beginning on the date Mr. Epstein began serving his sentence in the Florida Criminal
+Action." (The terms of this Agreement are also described in the notice letter to the victim Plaintiff, a
+redacted copy which is attached hereto as Exhibit "A".) Accordingly, as represented in Defendant's
+own filing, Mr. Epstein is not under indictment and the grand jury is not active in his case. There is
+simply no pending criminal action, a necessary prerequisite for a stay under 28 U.S.C. §3509(k).
+Additionally, the stay provision of 18 U.S.C. 3509(k) is limited to circumstances in which the
+plaintiff is a "a person who is under the age of 18..." The Statute is therefore inapplicable in that
+Plaintiff is not a minor, and was not a minor when she filed this lawsuit. The Motion is also
+procedurally defective because (i) Defendant failed to comply with the Local Rules of the United
+States District Court for the Southern District of Florida in that Defendant's counsel neither
+conferred nor attempted to confer with counsel for the Plaintiff as to the relief request prior to filing
+the Motion to Stay; and (i) in light of changed circumstances after the filing of the Motion to Stay,
+the Motion fails to inform the Plaintiff or the Court of the grounds for the relief sought.
+For the foregoing reasons, Defendant's Motion to Stay must be denied in its entirety.
+THE DEFENDANT HAS NOT DEMONSTRATED THAT
+28 U.S.C. $3509(k) IS APPLICABLE AND A STAY MANDATED
+HErMAN & MermeLsteIn, P. A.
+- 2-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 3 of 9
+As the movant, it is the Defendant's burden to demonstrate that the requirements for a stay
+have been met. He has not met this burden. 18 U.S.C. §3509(k) states as follows:
+Stay of civil action. -- If, at any time that a cause of action for recovery of
+compensation for damage or injury to the person of a child exists, a criminal action
+is pending which arises out of the same occurrence and in which the child is the
+victim, the civil action shall be stayed until the end of all phases of the criminal
+action and any mention of the civil action during the criminal proceeding is
+prohibited. As used in this subsection, a criminal action is pending until its final
+adjudication in the trial court.
+(emphasis added).
+A threshold inquiry in determining whether to invoke the stay provision of 18 U.S.C.
+§3509(k) is whether the plaintiff in a civil action is also the victim of a "criminal action ... pending
+which arises out of the same occurrence and in which the child is the victim...." (Emphasis
+supplied). Given Jeffrey Epstein's plea of guilty to the criminal charges in the state case and the
+Agreement entered into with the U.S. Attorney, his argument that a stay of this lawsuit should be
+granted because of pending criminal charges appears at this point to be specious. Nonetheless,
+Defendant Epstein represents to this Court in his "Notice Concerning Motion to Stay" dated July 1,
+2008 that "the federal criminal proceeding ... remains pending." No further explanation is
+provided. The argument supporting this assertion is unknown to Plaintiff.' There is no indication in
+the statutory language or elsewhere that 18 U.S.C. §3509(k) can be applicable in a situation, such as
+here, where there is an agreement concerning federal crimes but there has been no indictment.
+The notice letter attached hereto as Exhibit "A" further sets forth one of the conditions
+imposed by Mr. Epstein's Agreement with the U.S. Attorney, as follows: "Any person [including
+'The developments relating to the Defendant's plea deal arose after the Defendant filed his Motion
+to Stay. As a result, the Motion does not explain why a stay is justified under the present
+circumstances. Plaintiff is at a disadvantage in filing this Memorandum in Response, and is left to
+guess as the present grounds for the Motion. For this reason alone, the Motion should be denied.
+- 3-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 4 of 9
+this plaintiff], who while a minor, was a victim of a violation of an offense enumerated in Title 18,
+United States Code, Section 2255, will have the same rights to proceed under Section 2255 as she
+would have had, if Mr. Epstein had been tried federally and convicted of an enumerated offense."
+Thus, not only is a necessary prerequisite for a statutory stay missing in that no criminal case is
+pending, but a stay under 28 U.S.C. §3509(k) would be inconsistent with Mr. Epstein's Agreement
+with the U.S. Attorney, which contemplates civil claims by victims pursuant to federal law.
+Defendant Epstein apparently contends that a stay should nonetheless apply for the next 33 months,
+preventing for this extended period the civil litigation of these claims, to see if Mr. Epstein complies
+with his Agreement. Needless to say, this would be absurd. It cannot be seriously argued in the
+circumstances of this case that a stay under 28 U.S.C. §3509(k) is mandated because there is a
+"pending" federal criminal action.
+18 U.S.C. $3509(k) DOES NOT AUTHORIZE A STAY
+OF A CIVIL LAWSUIT FILED BY AN ADULT PLAINTIFF
+Even if there were a criminal case pending, which there is not, 18 U.S.C. §3509(k) would not
+apply to the claim of a child victim who is now an adult. This Statute applies in situations in which a
+child who has been the victim of sexual abuse is the plaintiff in a civil lawsuit at the same time that
+the child is a victim in a criminal proceeding arising out of the same occurrence. That is not the case
+here. The Plaintiff is an adult and was an adult at the time she filed this civil lawsuit. Defendant
+misinterprets 18 U.S.C. §3509(k) to suggest that the Statute also applies in instances where an adult
+plaintiff in the civil lawsuit was a victim of sexual abuse during childhood. A careful reading of the
+definitions section of 18 U.S.C. §3509 reveals that Defendant's interpretation is incorrect. See 18
+U.S.C. §3509(a)(2) (defining "child" as person who is under the age of 18).
+18 U.S.C. §3509(k) states, in relevant part, as follows:
+- 4-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 5 of 9
+(k) Stay of civil action. -- If, at any time that a cause of action for recovery of
+compensation for damage or injury to the person of a child exists, a criminal
+action is pending which arises out of the same occurrence and in which the child is
+the victim, the civil action shall be stayed until the end of all phases of the criminal
+action....
+(emphasis added).
+18 U.S.C. §3509(2) defines as a "child" as "a person who is under the age of 18." Thus, the term
+"child" is limited for purposes of 18 U.S.C. §3509 to a person who is currently under the age of 18.
+While the statute could have been written to say "a person who is under the age of 18 or was under
+the age of 18 at the time of the abuse", it does not. Yet, this is the precise interpretation suggested
+by the Defendant.
+The plaintiff's interpretation of 18 U.S.C. $3509(k) is not only consistent with the plain
+language of the statute, but also with the policies underlying the stay provision. The statute is
+designed to protect children who are involved in legal proceedings arising from physical, sexual, or
+mental abuse. For instance, 18 U.S.C. §3509 provides protections for persons under the age of 18,
+including alternatives to live in-court testimony, competency examinations, psychological
+examinations, privacy issues, filing under seal, closing the courtroom, the handling of videotaped
+testimony, adult attendants, speedy trials, the use of guardians ad litem and testimonial aids. Each of
+these protections is only implicated when the victim "is under the age of 18." See 18 U.S.C.
+§3509(a)(2). In the context of a civil lawsuit, a child similarly needs protection from the possibility
+of concurrent proceedings involving deposition or trial testimony, psychological examinations, and
+competency examinations. Moreover, the use of a stay of a civil lawsuit involving a child-plaintiff
+may be particularly warranted in circumstances where the child may not have had made the decision
+to file the lawsuit in the first instance. Thus, the law protects the children from multiple concurrent
+proceedings. These concerns do not exist to the same degree when a competent adult such as the
+Herman & MermelsteIn, P. A.
+- 5-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 6 of 9
+Plaintiff elects to file suit on her own behalf. Yet, the Defendant seeks to carve out an exception
+where none exists by arguing that the "Stay of Civil Action" provision in subsection (k) must be
+applied to victims who are 18 or older who were under the age of 18 at the time of their abuse. This
+argument is unsupported by the statute or its underlying policies.
+The unpublished, trial court decisions cited by Defendant of Doe v. Francis, 2005 WL
+517487 (N.D. Fla. Apr. 20, 2005) (Francis I) and Doe v. Francis, 2005 WL 950623 (N.D. Fla. Apr.
+20, 2005) (Francis II) are readily distinguishable. The Plaintiffs in Francis / and Francis II
+offered no legal authority or evidence to support their argument that the stay should be lifted."
+Francis II, at *1. By contrast, in this case, the Plaintiff has cited the definition of "child" found in 18
+U.S.C. $3509(a)(2). The Francis cases also involved seven plaintiffs, three of whom were victims in
+the criminal case. That is not the case here were the only plaintiff in this lawsuit is not a victim in a
+pending criminal case. Additionally, the stay in the Francis cases was imposed before the plaintiffs
+reached the age of majority. Here, the civil lawsuit was not even filed until after the plaintiff
+reached the age of majority.
+DEFENDANT'S MOTION SHOULD BE DENIED IN THAT
+DEFENDANT DID NOT CONFER WITH PLAINTIFF'S
+COUNSEL PRIOR TO FILING HIS MOTION, AND THE MOTION
+FAILS TO INFORM PLAINTIFF OR THE COURT OF THE
+GROUNDS FOR RELIEF IN LIGHT OF CHANGED CIRCUMSTANCES
+Defendant's Motion should be denied in that Defendant failed to comply with the Local
+Rules of the United States District Court for the Southern District of Florida in that Defendant's
+counsel neither conferred nor attempted to confer with counsel for the Plaintiff as to the relief
+request prior to filing the Motion to Stay. See S.D. Fla. L. R. 7.1.A.3. Notably, Defendant's Motion
+also contains no certification as to any such attempt as required by the Local Rules. See id. The
+Local Rules provide that the "[flailure to comply with the requirements of this rule may be cause for
+- 6-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 7 of 9
+the court to grant or deny the motion and impose on counsel an appropriate sanction, which may
+include an order to pay the amount of the reasonable expenses incurred because of the violation,
+including a reasonable attorney's fee." Id.
+Finally, when the circumstances materially changed after the filing of the Motion, it was
+incumbent upon the Defendant to either withdraw the Motion or at least amend it to explain the
+grounds for a stay in light of the plea deal. Defendant has not done so, to the prejudice of Plaintiff in
+preparing this Memorandum in response. For this reason alone the Motion to Stay should be denied
+CONCLUSION
+Based on the foregoing, Plaintiff requests that this Court deny Defendant's Motion to Stay
+pursuant to Title 18, United States Code, Section 3509(k) in its entirety, award attorney's fees to
+Plaintiff for Defendant's failure to comply with Southern District of Florida Local Rule 7.1.A.3, and
+all other relief this Court deems just and appropriate.
+Dated: July 18, 2008.
+Respectfully submitted,
+By:
+s/ Jeffrey M. Herman
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman @hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: 305-931-2200
+Fax: 305-931-0877
+- 7-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 8 of 9
+CERTIFICATE OF SERVICE
+I hereby certify that on July 18, 2008, I electronically filed the foregoing document with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this day
+to all parties on the attached Service List in the manner specified, either via transmission of Notices
+of Electronic Filing generated by CM/ECF or in some other authorized manner for those parties who
+are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Jeffrey M. Herman
+- 8-
+
+
+Case 9:08-cv-80381-KAM Document 29 Entered on FLSD Docket 07/18/2008 Page 9 of 9
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+CASE NO.: 08-CV-80381-MARRA/,
+United States District Court, Southern District of Florida
+Jack Alan Goldberger
+jagesq@bellsouth.net
+Michael R. Tein
+tein@lewistein.com
+Is/ Jeffrey M. Herman
+- 9-
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f93668e4a456853205056759433843752d65d7e63cf4d1aa8753996af30b19ce.receipt.json b/vision-fixhub/court-01/f93668e4a456853205056759433843752d65d7e63cf4d1aa8753996af30b19ce.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..27db38c8ae24660c7f446037ea69bb8d33123d66
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@@ -0,0 +1,14 @@
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f93b317aeaf2a140515ac7f01513b2771131d9043f025828004b425c2792dd67.md b/vision-fixhub/court-01/f93b317aeaf2a140515ac7f01513b2771131d9043f025828004b425c2792dd67.md
new file mode 100644
index 0000000000000000000000000000000000000000..da5fb98a1a86d41663e7ece76b95e8ffc6f65eef
--- /dev/null
+++ b/vision-fixhub/court-01/f93b317aeaf2a140515ac7f01513b2771131d9043f025828004b425c2792dd67.md
@@ -0,0 +1,175 @@
+Case 1:19-cv-10577-LJL-DCF Document 52 Filed 05/13/20 Page 1 of 4
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman"
+sanders
+troutman.com
+MatthewJ. Aaronson
+Matthew.aaronson@troutman.com
+Via ECF
+Hon. Debra C. Freeman
+Daniel
+Moynihan
+United States Courthouse
+500 Pearl St.
+New York, NY 10007
+Re: Jane Doe 1000, 1:19-CV-10577-LJL-DCF
+Dear Judge Freeman:
+We represent Defendants Darren K. Indyke and Richard D. Kahn, Co-Executors
+of the Estate of Jeffrey E. Epstein (together, the "Co-Executors"), in the above-referenced
+action (the "Action"). We write to address the substantive issues raised in Plaintiff's letters
+to the Court dated May 7 and May 11, prematurely requesting a pre-motion conference
+on Plaintiff's anticipated motion to compel. For the reasons set forth below and in our
+May 8 letter, we respectfully request that the Court deny Plaintiff's request.
+The picture Plaintiff paints is a false one. On their face, Plaintiff's interrogatories
+are clearly overbroad and unduly burdensome. However, as a compromise and as the
+Co-Executors said they would do before Plaintiff filed her letter, the Co-Executors have
+supplemented their responses to those interrogatories. Notwithstanding that Plaintiff has
+provided no transparency into her own efforts to produce responsive materials (something
+the Co-Executors hope to resolve before filing letters with the Court), the Co-Executors
+have collected and are, in connection with this and the numerous other cases against
+them before Your Honor, reviewing a database of over 730,000 documents. We
+address Plaintiff's specific points below.
+First, Plaintiffs proposed 21-year time frame for discovery is not proportional to
+the needs of this case and would impose an undue burden on the Co-Executors.
+Although Plaintiff asserts that her alleged abuse by Mr. Epstein occurred from 1999 to
+2002, she demands discovery from 1999 through the present. Plaintiff's proposed time
+frame is contrary to the goals of the 2015 amendments to the Federal Rules of Civil
+Procedure, which emphasize the pre-existing but often-unheeded requirement that all civil
+discovery be proportional to the needs of the case. See State Farm Mut. Auto. Ins. Co.
+v. Fayda, No. 14CIV9792WHPJCF, 2015 WL 7871037, at *2 (S.D.N.Y. Dec. 3, 2015),
+
+
+Case 1:19-cv-10577-LJL-DCF Document 52 Filed 05/13/20 Page 2 of 4
+Page 2
+troutman"
+sanders
+aff'd, No. 14CV9792, 2016 WL 4530890 (S.D.N.Y. Mar. 24, 2016) ('[The amended rule
+is intended to encourage judges to be more aggressive in identifying and discouraging
+discovery overuse; by emphasizing the need to analyze proportionality before ordering
+production of relevant information."). Requiring the Co-Executors to conduct a search for
+and produce documents over an 21-year time period is not proportional to the needs of
+this case - which relates to Mr. Epstein's alleged conduct over a four-year period that
+concluded in 2002. The Co-Executors advised Plaintiff's counsel that the appropriate
+time period for discovery is the time period during which Plaintiff alleges she was abused
+and during which time her claims would have accrued. Moreover, the Co-Executors will
+search for and produce all non-privileged communications between Mr. Epstein and
+Plaintiff or otherwise concerning Plaintiff, regardless of the year.
+Plaintiff's position, that all information relating to what Plaintiff describes as a "sex
+trafficking" scheme -- which is based on unproven allegations in the S.D.N.Y.'s 2019
+indictment of Mr. Epstein -- is relevant to Plaintiff's alleged abuse, is untenable. Plaintiff
+does not assert sex trafficking claims. Rather, her claims are limited to battery and
+intentional infliction of emotional distress.
+Moreover, conduct that occurred after Plaintiff's alleged abuse cannot possibly be
+used to support her claims. While Plaintiff posits that discovery relating to Mr. Epstein's
+conduct with other individuals is "relevant" to her claims, that does not mean that such
+discovery is proper. See Mamakos v. United Airlines, Inc., No. CV147294JFBAKT, 2018
+WL 4861392, at *2 (E.D.N.Y. Sept. 28, 2018) ("[A]lthough Rule 26 still permits a wide
+range of discovery based upon relevance and proportionality, the provision authorizing
+the court... to order discovery of any matter relevant to the subject matter involved in the
+action has been eliminated.") (internal citations omitted). Accordingly, the Court should
+reject Plaintiff's attempt to grossly expand the scope of discovery to obtain documents
+that extend "far beyond the scope of Plaintiff's claims and would significantly burden" the
+Co-Executors. See Robertson v. People Magazine, No. 14 CIV. 6759 (PAC), 2015 WL
+9077111, at *2 (S.D.N.Y. Dec. 16, 2015) (denying discovery requests that are
+"burdensome and disproportionate" where Plaintiff sought "nearly unlimited" discovery
+that was not addressed to alleged discriminatory conduct and/or comments).
+Contrary to her counsel's assertion, Plaintiff does not need discovery about Mr.
+Epstein's interactions with other individuals to meet her burden to prove her claims for
+battery or intentional infliction of emotional distress allegedly committed against her. The
+mere fact that certain testimony regarding a defendant's prior conduct could theoretically
+be admissible at trial does not mean that Plaintiff is entitled to wide-ranging discovery.
+Plaintiff cites no authority for that proposition.
+Nor does Plaintiff need discovery about Mr. Epstein's interactions with other
+individuals to invoke her equitable estoppel defense to the Co-Executor's assertion that
+her claims are barred by the statute of limitations. In order to prevail on her equitable
+estoppel defense, Plaintiff is required to show that Mr. Epstein's conduct towards Plaintiff
+
+
+Case 1:19-cv-10577-LJL-DCF Document 52 Filed 05/13/20 Page 3 of 4
+Page 3
+troutman"
+sanders
+prevented her from bringing her suit earlier; his conduct towards others has no bearing
+on such a defense.
+"To invoke equitable estoppel, a plaintiff must show that: "(i) the
+defendant made a definite misrepresentation of fact and had reason to believe that the
+plaintiff would rely on it; and iii) the plaintiff reasonably relied on that misrepresentation
+to h[er] detriment." See Yesh Diamonds, Inc. v. Yashaya, No. 09-CV-2016 (DLI) (RER),
+2010 U.S. Dist. LEXIS 101744, at *5 (E.D.N.Y. Sept. 27, 2010) (quoting Kavowras v. New
+York Times Co., 328 F.3d 50, 56-57 (2d Cir. 2003).
+Second, Plaintiff suggests that the Co-Executors agreed to produce only
+documents that expressly reference Plaintiff. That is an inaccurate representation of the
+parties' conversations during the meet-and-confer sessions. As we explained during the
+parties' April 27 and May 5 meet-and-confers, the Co-Executors have and will continue
+to search for and produce documents that relate to Plaintiff and her claims of battery and
+intentional infliction of emotional distress, regardless of whether they specifically
+reference Plaintiff. For example, if the Complaint alleges that Plaintiff traveled on Mr.
+Epstein's plane, then flight logs for the relevant time period will be produced. Similarly,
+where phone records exist from the relevant time period and Plaintiff provides Co-
+Executors with phone numbers that she used during the Relevant Time Period, Co-
+Executors will search for calls to/from such phone numbers. To the extent Plaintiff bases
+her argument on the Co-Executors' search-term proposal for ESI, her counsel never
+engaged with us. Rather than continue discussions that include bilateral search-term
+proposals - as is customary in this District and something other counsel in the other
+lawsuits against the Estate have done - Plaintiff burdened the Court in an apparent effort
+to obtain a wide-ranging Court order that would unduly burden the Co-Executors. If
+Plaintiff had simply made a single proposal or engaged in any effort to compromise on
+her positions, this could have all been avoided.
+Third, Plaintiff's request that the Co-Executors supplement their interrogatory
+responses is moot. Again, this is exactly the situation the Court warned against. The Co-
+Executors supplemented their interrogatory responses earlier today, as they agreed to do
+before Plaintiff went ahead and burdened the Court with her initial lengthy letter on this
+issue. The Co-Executors provided their initial and supplemental responses to Plaintiff's
+interrogatories in the capacity in which they were sued. Plaintiff provides no support for
+her position that the Co-Executors' responses should be made in their personal or other
+professional capacity. Plaintiff also misrepresents the parties' communications regarding
+information provided by Co-Executors in connection with their interrogatory responses.
+As we advised Plaintiff on several occasions, the Co-Executors reviewed and approved
+the interrogatory responses before they were served.
+Plaintiff incorrectly states that counsel for Co-Executors represented that the Co-
+Executors "do not know where to look for responsive documents." To the contrary, we
+stated that, despite the fact that obtaining documents and information from a large,
+complicated estate is more involved and thus takes longer than the collection of
+documents from an individual party such as Plaintiff, the Co-Executors retrieved hundreds
+
+
+Case 1:19-cv-10577-LJL-DCF Document 52 Filed 05/13/20 Page 4 of 4
+Page 4
+troutman"
+sanders
+of thousands of documents and were reviewing the voluminous database in preparation
+for production, but that the task had been complicated by the need to track down such
+information and the attendant delays caused by the current pandemic. The Co-Executors
+have compiled a database with over 730,000 documents that they have been searching
+for documents responsive to this and discovery requests in numerous other lawsuits.
+Subject to the execution of a mutually acceptable ESI protocol and confidentiality order
+(something made abundantly clear in the Co-Executors' written responses to Plaintiff's
+requests for production), they expect to begin production within the next week. The only
+reason a confidentiality order was not already entered in this action (but was in several
+other lawsuits against the Co-Executors) is that, unlike the plaintiffs' counsel in the other
+actions, Plaintiff's counsel here insisted until shortly before filing their letter that the Co-
+Executors accept unsupportable changes, such as the removal of several categories of
+confidentiality that the Co-Executors require but which Plaintiff does not believe she
+needs—a vexatious tactic.
+Finally, contrary to her representations to the Court, Plaintiff has not complied with
+her discovery obligations. Rather, Plaintiff produced a small set of self-selected, and
+useless materials so she could rush to Court under the guise of having made a meaningful
+production in the face of what she falsely claims was stonewalling from her adversaries.
+Approximately half of the documents Plaintiff produced are irrelevant documents from
+another case that was handled by Plaintiff's counsel that has nothing to do with Plaintiff's
+claims in this action.' There appears to have been no reason for the production of these
+documents other than to inflate the size of Plaintiff's production. Those same documents
+were also produced by the other Plaintiffs that Plaintiff's counsel represents in actions
+against Mr. Epstein's estate. They do not appear to be documents that were in Plaintiff's
+personal possession.
+Accordingly, we request that the Court deny Plaintiff's request for a pre-motion
+conference and instead direct Plaintiff to engage in a good-faith meet-and-confer session
+to resolve the parties' discovery disputes.
+Respectfully submitted,
+s/Matthew J. Aaronson
+Matthew J. Aaronson
+cc: Counsel of Record (via ECF)
+The Court should be aware that the Hon. Lorretta A. Preska disqualified Plaintiff's counsel from
+acting as counsel in a subsequent action related to that other action.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f93b317aeaf2a140515ac7f01513b2771131d9043f025828004b425c2792dd67.receipt.json b/vision-fixhub/court-01/f93b317aeaf2a140515ac7f01513b2771131d9043f025828004b425c2792dd67.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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diff --git a/vision-fixhub/court-01/f93d08f3dea87c4ed1a09ed8e8a4a5ad1fc757b54e8abaff6e3e6c0570dc3811.md b/vision-fixhub/court-01/f93d08f3dea87c4ed1a09ed8e8a4a5ad1fc757b54e8abaff6e3e6c0570dc3811.md
new file mode 100644
index 0000000000000000000000000000000000000000..83c813d686557a5e616f81e18450ce0900e807e6
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@@ -0,0 +1,235 @@
+Case 9:08-CV-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 1 ongtt D
+Entered on FLSD Docket 02/27/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA/.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+SECOND AMENDED COMPLAINT
+Plaintiff, Jane Doe No.3 ("Jane" or "Jane Doe"), brings this Complaint against Jeffrey
+Epstein, as follows:
+1.
+Parties, Jurisdiction and Venue
+Jane Doe is a citizen and resident of the State of Florida, and is sui juris.
+2.
+This Complaint is brought under a fictitious name to protect the identity of the
+Plaintiff because this Complaint makes sensitive allegations of sexual assault and abuse upon her
+when she was a minor.
+3.
+4.
+5.
+Defendant Jeffrey Epstein is a citizen and resident of the State of New York.
+This is an action for damages in excess of $50 million.
+This Court has jurisdiction of this action and the claims set forth herein pursuant to 28
+U.S.C. §1332(a), as the matter in controversy (i) exceeds $75,000, exclusive of interest and costs;
+and (ii) is between citizens of different states.
+6.
+This Court has venue of this action pursuant to 28 U.S.C. §1391(a) as a substantial
+part of the events or omissions giving rise to the claim occurred in this District.
+- 1-
+
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 2 of 8
+Entered on FLSD Docket 02/27/2009 Page 2 of 8
+Factual Allegations
+7.
+At all relevant times, Defendant Jeffrey Epstein ("Epstein"') was an adult male, 52
+years old. Epstein is a financier and money manager with a secret clientele limited exclusively to
+billionaires. He is himself a man of tremendous wealth, power and influence. He maintains his
+principal home in New York and also owns residences in New Mexico, St. " |
+and Palm Beach,
+FL. The allegations herein concern Epstein's conduct while at his lavish estate in Palm Beach.
+8.
+Upon information and belief, Epstein has a sexual preference and obsession for
+underage minor girls. He engaged in a plan and scheme in which he gained access to primarily
+economically disadvantaged minor girls in his home, sexually assaulted these girls, and then gave
+them money. In or about 2004-2005, Jane Doe, then 16 years old, fell into Epstein's trap and
+became one of his victims.
+9.
+Upon information and belief, Jeffrey Epstein carried out his scheme and assaulted
+girls in Florida, New York and on his private island, known as Little St. James, in St.
+10.
+An integral player in Epstein's Florida scheme was
+a Palm Beach
+Community College student from Loxahatchee, Florida. She recruited girls ostensibly to give a
+wealthy man a massage for monetary compensation in his Palm Beach mansion. Under Epstein's
+plan,
+would be contacted when Epstein was planning to be at his Palm Beach residence
+or soon after he had arrived there. Epstein or someone on his behalf directed
+to bring
+one or more underage girls to the residence.
+upon information and belief, generally
+sought out economically disadvantaged underage girls from Loxahatchee and surrounding areas who
+would be enticed by the money being offered - generally $200 to $300 per "massage" session - and
+who were perceived as less likely to complain to authorities or have credibility if allegations of
+improper conduct were made. This was an important element of Epstein's plan.
+- 2-
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 3 of 8
+Document 50 Entered on FLSD Docket 02/27/2009
+
+I1.
+Epstein's plan and scheme reflected a particular pattern and method. Upon arrival at
+Epstein's mansion, the victim would be brought to the kitchen. She would then be led up a flight of
+stairs to a bedroom that contained a massage table in addition to other furnishings. Once the girl was
+alone in this room, Epstein would enter wearing only a towel to cover his private area. He then
+would lay down on the massage table and perform one or more lewd, lascivious and sexual acts,
+including masturbation and touching the girl sexually.
+12.
+Consistent with the foregoing plan and scheme,
+give Epstein a massage for monetary compensation.
+recruited Jane Doe to
+i brought Jane to Epstein's mansion
+in Palm Beach. Jane was led up the flight of stairs to the room with the massage table. She was
+alone in the room when Epstein arrived wearing a towel to cover his private parts. He laid down on
+the massage table, and sexually assaulted Jane Doe during the massage. In addition, Jeffrey Epstein
+masturbated during the massage.
+13.
+After Epstein had completed the assault, he left the room. Jane was then able to leave
+the room and go back down the stairs. She then met
+again who brought Jane home.
+Jane was paid $200 by Epstein.
+was also paid by Epstein for bringing Jane to him.
+14.
+As a result of this encounter with Epstein, the 16-year old Jane experienced trauma,
+shock, confusion, shame, humiliation and embarrassment.
+15.
+COUNTI
+Sexual Assault and Battery
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+16.
+Epstein acted with intent to cause an offensive contact with Jane Doe, or an imminent
+apprehension of such a contact, and Jane Doe was thereby put in such imminent apprehension.
+17.
+Epstein made an intentional, unlawful offer of offensive sexual contact toward Jane
+- 3-
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 4 of 8
+Case 9:08-cv-80232-KAM Document 50|
+Entered on FLSD Docket 02/27/2009 Page 4 of 8
+Doe, creating a reasonable fear of imminent peril.
+18.
+Epstein intentionally inflicted harmful or offensive contact on the person of Jane Doe,
+with the intent to cause such contact or the apprehension that such contact is imminent.
+19.
+Epstein tortiously committed a sexual assault and battery on Jane Doe. Epstein's acts
+were intentional, unlawful, offensive and harmful.
+20.
+Epstein's plan and scheme in which he committed such acts upon Jane Doe were
+done willfully and maliciously.
+21.
+As a direct and proximate result of Epstein's assault on Jane, she has suffered and
+will continue to suffer severe and permanent traumatic injuries, including mental, psychological and
+emotional damages.
+WHEREFORE, Plaintiff Jane Doe No. 3 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, punitive damages, costs, and such other and further relief as this
+Court deems just and proper.
+COUNT II
+Intentional Infliction of Emotional Distress
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+Epstein's conduct was intentional or reckless.
+Epstein's conduct with a minor was extreme and outrageous, going beyond all bounds
+22.
+23.
+24.
+of decency.
+25.
+Epstein committed willful acts of child sexual abuse on Jane Doe. These acts resulted
+in mental or sexual injury to Jane Doe, that caused or were likely to cause Jane Doe's mental or
+emotional health to be significantly impaired.
+26.
+Epstein's conduct caused severe emotional distress to Jane Doe. Epstein knew or had
+- 4-
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 5 of 8
+Case 9:08-cv-80232-KAM Document 50 Entered on FLSD Docket 02/27/2009 Page 5 of 8
+reason to know that his intentional and outrageous conduct would cause emotional distress and
+damage to Jane Doe, or Epstein acted with reckless disregard of the high probability of causing
+severe emotional distress to Jane Doe.
+27.
+As a direct and proximate result of Epstein's intentional or reckless conduct, Jane
+Doe, has suffered and will continue to suffer severe mental anguish and pain.
+WHEREFORE, Plaintiff Jane Doe No. 3 demands judgment against Defendant Jeffrey
+Epstein for compensatory damages, costs, punitive damages, and such other and further relief as this
+Court deems just and proper.
+COUNT HII
+Coercion and Enticement to Sexual Activity in Violation of 18 U.S.C. §2422
+28.
+Plaintiff Jane Doe repeats and realleges paragraphs 1 through 14 above.
+29. Epstein used a facility or means of interstate commerce to knowingly persuade,
+induce or entice Jane Doe, when she was under the age of 18 years, to engage in prostitution or
+sexual activity for which any person can be charged with a criminal offense.
+30.
+On June 30, 2008, Epstein entered a plea of guilty to violations of Florida §§ 796.07
+and 796.03, in the 15th Judicial Circuit in and for Palm Beach County (Case nos. 2008-cf-
+009381AXXXMB and 2006-cf-009454AXXXMB), for conduct involving the same plan and
+scheme as alleged herein.
+31.
+As to Plaintiff Jane Doe, Epstein could have been charged with criminal violations of
+Florida Statute §796.07(2) (including subsections (c), (d), (e), (f), (g), and (h) thereof), and other
+criminal offenses including violations of Florida Statutes §§ 798.02 and 800.04 (including
+subsections (5), (6) and (7) thereof).
+32.
+Epstein's acts and conduct are in violation of 18 U.S.C. §2422.
+- 5-
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 6 of 8
+Document 50 Entered on FLSD Docket 02/27/2009 Page 6 of 8
+33.
+As a result of Epstein's violation of 18 U.S.C. §2422, Plaintiff has suffered personal
+injury, including mental, psychological and emotional damages.
+34.
+Plaintiff hired Herman & Mermelstein, P.A., in this matter and agreed to pay them a
+reasonable attorneys' fee.
+WHEREFORE, Plaintiff Jane Doe No. 3 demands judgment against Defendant Jeffrey
+Epstein for all damages available under 18 U.S.C. §2255(a), including without limitation, actual
+and compensatory damages, costs of suit, and attorneys' fees, and such other and further relief as
+this Court deems just and proper.
+JURY TRIAL DEMAND
+Plaintiff demands a jury trial in this action on all claims so triable.
+Dated: February 27, 2009
+Respectfully submitted,
+By:
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+horowitz@sexabuseattorney.cor
+IERMELSTEIN & HOROWITZ, P.I
+Fax: 305-931-0877
+- 6-
+
+
+Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 7 of 8
+Case 9:08-CV-80232-KAM Document 50 Entered on FLSD Docket 02/27/2009 Page 7 of 8
+CERTIFICATE OF SERVICE
+Thereby certify that on February 27, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day to all parties on the attached Service List in the manner specified, either via transmission of
+Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those
+parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+- 7-
+
+
+• Case 9:08-cv-80232-KAM Document 56-2 Entered on FLSD Docket 03/25/2009 Page 8 of 8
+Entered on FLSD Docket 02/27/2009
+
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Adam D. Horowitz
+- 8-
\ No newline at end of file
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
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diff --git a/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.md b/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.md
new file mode 100644
index 0000000000000000000000000000000000000000..ec179b304e86467d50c90e4489dcc7b13d92f0e6
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+++ b/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.md
@@ -0,0 +1,539 @@
+Page 1 of.5
+
+pate:
+Time: 14:57:04
+ROSAL PALM BEACH POLTOR DEPARTMENT
+pf fense Repott
+Report Date
+Ocour To Date
+Page:
+Pia: 0093021
+10/51/04
+3:2]
+: 10/31/04 3:31
+Day Of Week
+Sunday
+Occir From Date:
+10/31/04 3:21
+Dept Class
+MISDEMEANOR
+Street Number
+; LA MANCHA,
+City
+- *
+ROYAL PALM BEACH,
+EL 3341]
+Zone/division
+Zone One (1) (No of Okee)
+Location Type
+'RES-SNGL FAMILY
+Case Status .: CLEARBD EX ÁRREST
+Repott Officer
+COTABER OI
+INTAHOLAS
+Supeiyieozy Emp:
+11/02/04
+Verif. Emplayee:
+HILD,
+JR... JOHN 11/02/04
+Case Statuş pF.
+**********************ADDIİIONAL
+TIMBS***************
+Case Number
+* 1-04-004495
+Date Dispatched:
+10/31/04 3:24
+Date Arrived
+•: 10/31/04 3:31
+Date Cleared .: 10/31/04 10:43
+************ CA SE
+MANAGEMENT INFORMAIION*************
+Caze Number
+• : 1-04-004495
+Dept Class . . : MISDENEANOR = OTHER
+Case Status
+: CLEARED BY ARREST Case Statua DE : 10/31/04
+*********************OPFENSE
+REPORT # 1*******************
+Staté Class.
+1 : Other orimiral offense Attmpt/Comnitt : Conmitted
+Statute/Ordin
+: 741.31
+Pótced Eritry . : NO
+Structure Occup: Oçcupied
+State Dispo
+-= Commitbed by Adult or Adult/Jav
+Dispo Date : •
+: 10/31/04
+Exception Clear: ARRESTED ON PRIMARY OFFENSE
+Atrest Case No.: 1-04-004495
+Feople Arrested: 1
+********* COMFLAINANT
+INFORMATION - # 1************
+Case
+Numbex
+•: 1-04-004495
+Last Name • : BESPINIS, 09
+Home Phone No. : 561/856-8355
+Biath Date . . : 12/06/1956 47
+Sext
+= Male
+Race
+Ethnic Origin .: UNKNOWN / OTHER
+ocupation ::
+: CAB DRIVER
+Juvehile . . . : ADULT
+**************
+SUSPECT/ARRESTBE INFORMAIION -
+# I **
+Case Number
+• : 1-04-004495
+Prompt valid in: VINYARD, PRESTON S
+Street Number
+103 MEYBRIDGE CR C
+City .. • • •
+PALM BEACH, EL 33411
+County •
+PALM BEACH
+Home Phone No.: 561/798-9410
+Birth Date
+4/05/1980 24
+Maximun Age
+• : 24
+Birth State
+OK
+Birth Country : UNITED STATES
+Oper Lic No.
+1 FL UNITED STATES
+Race •
+Sex
+: Male
+Ethnio Origin
+Non-Hispanic
+Minimum Height
+: 600
+Maximum Height
+601
+Minimum Weight
+: 170
+Juvenile
+ADULT
+Maximin Weight : 175
+Hair ColDI .
+• : Bionda
+Hair Length
+(Up to 2")
+Hait Style . . : Parted in Center
+Eye Color
+Glasses
+* : No
+Complexion • .
+Met
+Teeth
+Facial Hair
+.: None
+_- *
+: Unj
+Build
+: MEDIUM
+speechse :::
+: NO1
+citizenship
+: UNITED STATES
+Hand Use
+: Unk
+
+
+Entered on FLSD Docket 09/16/2009 Page 2 of 5
+
+Date:
+14:57:04
+PALM BEACH POLICE DEPARTMENT
+Offense Report
+Page:
+2
+Program: CMS301L
+Residency Type
+Religion
+Arrest Case No.
+Pants
+Palm Beach
+UNKNOWN
+0-00-049796
+KHAKIS
+1-04-004495
+(Continued)
+Residency Sta
+: Full Year
+Marital Status
+: Single
+Shirt
+Shoes
+::
+NONE
+*****
+Case Number
+**** VICTIM
+1-04-004495
+Street Number
+City •
+Home Phone No.
+Oper Lic No.
+Race
+Ethnio örigin
+Non-Hispanic
+Weight
+... •
+90
+Juvenile . . . :
+JUVENILE
+File Charges . : No
+Victim Sobriety: HAD BEEN DRINKING
+**************VICTIM
+Case Number . : 1-04-004495
+Victim Type
+.: Government
+Can Identify . : Yes
+Injury Extent : Not Applicable
+*********OTHER
+PERSON
+Case Number . : 1-04-004495
+Person Type
+FATHER
+Street Number
+City •
+Home Phone No.
+Oper Lic No. .
+Race
+Ethnic Origin
+INFORMATION *
+Prompt valid in:
+#
+Birth Date
+17
+FL UNITED STATES
+Sex
+Female
+Height :
+505
+Occupation
+..: STUDENT
+Victim Type
+.: Adult
+Can Identify . : Yes
+Injury Extent : Not Applicable
+INFORMATION
+- #2
+*********
+Prompt valid in: STATE OF FLORIDA,
+File Charges . :
+Yes
+Victim Sobriety: SOBER
+INFORMATION - #1
+Last Name
+• :
+Birth Date •
+143
+FL UNITED STATES
+White
+Sex
+Male -
+Non-Hispanic
+Juvenilé:::
+: ADULT
+**** NARRATIVE
+# 1*******
+***
+Original
+Reported By: HOLBERTON, NICHOLAS
+Entered By.: HOLBERTON, NICHOLA
+Reviewed By:
+JR.. JOHN C
+For further. information on casell 04-1495, refer to PC Affidavit.
+No further information.
+****************************NARRATIVE
+#2*********
+P.C. AFFIDAVIT/VINYARD
+Reported By: HOLBERTON, NICHOLAS
+Entered By.:
+_. JANET I.
+ON THE ABOE DATE/TIME I WAS DISPATCHED TO E
+STIN REFERENCE
+TO A BATTERY IN THE BACK OF A TAXI AND THEFT OF SERVICES.
+UPON ARRIVAL I MADE CONTACT WITH THB CAB DRIVER JOHN BESPINIS.
+BESPINIS ADVISED ME THE WAS DRIVING PRESTON S VINYARD AND |
+*****
+11/02/04
+*********
+11/03/04
+
+
+Entered on FLSD Docket 09/16/2009 Page 3 of 5
+Case 9:08-cv-80119-KAM Document 291-7 Entered on FLSD Docket 09/08/2009 Page 3 of 5
+= Date:
+14:57:04
+PALM BEACH
+• POLICE DEPARTMENT
+Offense Report
+Page:
+Program:
+3.
+CMS301L
+1-04-004495
+(Continued)
+TO
+WHEN THEY STARTED TO ARGUE BECAUSE NEITHER OF
+THEM HAD MONEY TO PAY THE CAB. AT SOME POINT DURING THE ARGUMENT
+BESPINIS SAID VINYARD HIT ME
+UPON ARRIVING AT
+BAND VINYARD GOT OUT OF THE VEHICLE AND RAN INTO THE RESIDENCE. I
+WALKED UP TO THB FRONT DOOR AND NOTICED IT WAS PARTIALLY OPEN.
+SHORTLEY AFTER SGT.
+: AND OFC. DOBERR AARRIVED TO ASSIST ME. I
+KNOCKED ON THE DOOR SEVERAL TIMES AND SAID "POLICE", BUT NO ONE
+ANSWERED. MYSBLE SGT.
+1. AND OFC. DOERR ENTERED THE RESIDENCE TO
+MAKE SURE NO ONE WAS INJURED, AS I ENTERED THE RESIDENCE, E
+STEPPED OUT FROM BEHIND A WALL WITH A PAIR OF SHORTS AND NO SHIRT
+EXPOSING HER BREAST.
+ES TOLD US IO GET OUT OF HER HOUSE NUMBROUS
+TIMES. I ADVISED
+TO PUT A SHIRT ON AND SHE DID SO.
+I TRIED TO
+EXPLAIN TO WHY WE WERE THERE, BUT SHE KEPT TELLING US TO GET OUT
+OF HER HOUSE, AND THAT NO ONE WAS IN HER HOUSE.
+THEN CALLED HER
+FATBER, Se
+AND TOLD HIM POLICE WERE IN THERE HOUSE FOR NO
+REASON.
+THEN GOT ON THE PHONE WITH B2
+AND INFORMED HIM OF THE
+SITUATION.
+SINCE S
+WE WAS A JUVENILE,
+I ASKED A
+OFOR CONSENT TO
+SEARCH HIS RESIDENCE FOR THE BATTERY SUSPECT.
+AGREED TO LET US
+SEARCH THE HOUSE,
+BUT S
+I WOULD NOT LET US SEARCH HER FATHERS
+BEDROOM AND LOCKED HERSELF IN THERE. WE STAYED ON THE PHONE WITH
+HER FATHER AND KEPT TELLING HIM SHE WANTED US OUT OF THEIR HOUSE. NE
+TALKED BACK AND FORTH WITH BE
+FOR ABOUT THIRTY MINUTES AND I
+TRIED TO HAVE HER OPEN THE DOOR
+THEN TOLD HER FATHER SHE WAS
+GOING TO KILL HERSELF. SGT.
+ADVISED THE FATHER THAT SINCE SHE
+MADE THAT STATEMENT WE HAD NO CHOICE BUT TO FORCE ENTRY INTO THE ROOM
+IF THE DOOR WAS NOT OPENED.
+HE ADVISED HE WAS ON THE WAY HOME FROM
+FT PIERCE AND THAT HE WILL BE HOME AS SOON AS POSSIBLE. /
+THEN
+OPENED THE DOOR AND WAS PLACED IN HANDCUPES FOR OUR PROTOTION. I THEN
+SAT
+BZA ON THE
+IN THE LIVING ROOM WHILE SGT.
+SEARCHED
+THE BEDROOM AND DISCOVERED VINVARD UNDER THE BED. VINYARD WAS PLACED
+IN CUFFS AND SAT DOWN ON THE
+IN THE LIVING ROOM. AFTER RUNNING
+ORDER FOR HIS BORROR HE CAME BACK ARE D
+ORDER FOR
+SHORTLEY AFTER
+ARRIVED HOME AND
+WAS UPDATED ON THE SITUATION. VINYARD WAS PALCED UNER ARREST FOR
+VIOLATION OF PROTECTION ORDER AND TRANSPORTED TO THE COUNTY JAIL
+WITHOUT INCIDENT.
+ADVISED VINYARD DID NOT HIT HER AT ANY TIME,
+AND REFUSED TO PROSECUTE. BESPINIS HAD LEFT THE SCENE EARLIER AND WHEN
+CONTACTED REFUSED TO RETURN TO MEN
+RANI TO IDENTIFY VINYARD OR TO
+PROSECUTE FOR THEFT OF SBRVICES.
+L WAS TURNED OVER TO HER FATHER.
+NO FURTHER INFORMATION.
+*******************NARRATIVE
+*******
+Supplemental
+Reported By: DOBRR,
+Entered By.:
+Reviewed By:
+DE, JR., JOHN C.
+ON 10/31/04 I RESPONDED TO E
+THEFT OF A CAB FAIR.
+UPON ARRIVAL
+*********
+11/04/04
+
+
+Document 303-7
+
+
+, Date:
+14:57:04
+ROYAL
+PALM BEACH
+POLICE DEPARTMENT
+Offense Report
+Page:
+4
+Program:
+CMS301L
+1-04-004495
+CAB DRIVER WHO ADVISED ME THAT A WHITE FEMALE WALKED ANAY
+SOUTH ON BILBAO AND A WHITE MALE
+AND OFC HOLBERTON MADE CONTACT WITH
+WHO ADVISED
+US THAT THERE WAS NO MALE IN THE HOUSE. I THEN VERIFIED WITH
+HIS CAB AND RAN INSIDE B
+LS INSISTED THAT
+THERE WAS NOBODY INSIDE. SGT MURPHY MADE CONTACT WITH
+(FATHER) WHO AUTHORIZED US TO SBARCH THE HOUSE FOR
+THE SAFETY OF
+NO FURTHER INFORMATION AT THIS TIME.
+**********NARRATIVE.
+#4 ******
+Supplemental
+Reported By: MURPHY, THOMAS B.
+Entered By.: MURPHY, THOMAS E.
+Reviewed By: HILL, JR., JOHN C.
+On 10/31/04 at approximately 0331 hrs. I responded as back-up
+for Ofc. Holberton to a reported theft of services (from
+Si. Upon arrival I learned the following:
+cabdriver John Bespinis had driven a w/m and w/f to the area
+The w/m and w/£ became involved in an argument
+that became physical when the male struck the female. The
+female left the scene by walking or running south on Bilbao
+St.
+The male entered the house at
+continued to wait for the police,
+of the residence. Bespinis advised that both the male and
+female were voung adults. Ofc. Holberton,
+myself approached the front door and found that it was ajar
+by 6-8 inches. Ofc. Holberton knocked on the door and loudly
+called "police" into the open door but received no response.
+I became concerned that the male and female had possibly
+given the cabdriver a fake address with the intention of
+not paying and eluding the cabdriver and that the male might
+have illegally entered the residence at e
+an attempt to skip out on paying the cab fare. Ofc.
+DoerI, and myself entered the residence to ensure that no
+crime
+was ongoing and to check on the welfare of an residents.
+Ne were standing just inside the front door looking around
+the Iivingroom when a
+w/E (later IDed as NE
+years of age) stepped out of her bedroom wearing nothing
+but panties. I asked her to dress, which she did and she
+=
+then asked why we were in her house. I related to her that
+a cabdriver had watched a young white male run into her house.
+Ls stated that this was untrue and that her door had
+been
+Locked and she kept asking how we got in her house and
+why were we there. I explained the circumstances to her several
+times but she insisted that her
+door was locked and noone
+was
+in her house.
+She then stated she was going to call her
+father and I told her that I agreed that was a good idea.
+I then spoke to misse
+eg on his cellphone and related
+the
+information to him and that I believed it possible that
+a w/m
+was possibly still in his house. -
+told me that
+he wanted us to check his house to
+ensure his daughter's
+(Continued)
+********
+11/04/04
+
+
+Document 303-7
+Case 9:08-cV-80119-KAM
+
+Entered on FLSD Docket 09/08/2009 Page 5 of 5
+¡Date:
+14:57:04
+PALM BEACH POLICE DEPARTMENT
+Offense Report
+Page:
+5
+Program:
+CMS301L
+1-04-004495
+(Continued)
+safety. He then informed
+that he had given us permission
+to check the house.
+became enxaged at this and began
+to curse
+vel1 at her father over the phone and she ran
+into the
+refusing to
+allow us to enter. I could hear fi
+redy could earl eling at her fathe
+on the phone cursing at him and then I heard her tell him
+that if he didn't tell us (the police) to leave that she
+would kill herself. She repeated this same threat to him
+about 2 or 3 times. I went into the kitchen and picked up
+the extension and told S
+I was still on the phone
+in the bedroom) that because.
+was now threatening
+to harm herself that we would have to force entry into the
+bedroom to ensure that she didn't barm herself and that she
+would probably be Baker Acted for her protection. When a
+heard this she left the bedroom and came into the livingroom
+where Ofc. Holberton and myself handcuffed her for safety
+reasons until the situation could be sorted out. I stated
+that he would be at his house in about 5 minutes and asked
+for us top wait for
+him before doing anything to
+I checked in the
+bedroom and found Preston Scott Vinyard
+(who is known to me)
+hiding under the bed. Vinyard was handcuffed
+for safety reasons
+and placed in the livingroom. A computer
+check on Vinyard revealed a valid protection order on him
+to stay away from (i
+l While waiting for Bad to arrive,
+admitted that she and Vinyard had gone out and when
+her car broke down they took the cab home, but had no money
+to pay for it, so they began to argue about how to pay. li
+stated that Vinyard never struck her and that she left the
+scene because she was "pissed". I never said how she
+got in the house without the cabdriver seeing her.
+When We got to his residence he stated that Vinyard had
+battered
+9 approximately a month ago and that was why
+there was a protection order against him. l
+Me and I spoke
+with Me
+at length and she stated several times that
+she never intended to harm or kill herself, but that she
+had only told that to her father to try to convince him to
+make the police leave the house so we wouldn't find Vinyard
+hiding there. was convinced that
+i was truthful
+about not hurting herself and I believed that she was no
+danger to herself, only that she had been trying to get us
+to leave and used that threat as leverage against her father.
+I determined that a Baker Act was not warranted because I
+believed at that point that was no threat to herselt.
+During this entire incident Bespinis had left the scene and
+when contacted by phone advised that he didn't want to prosecute
+and refused to come back to the scene to sign a waiver of
+prosecution.
+Vinyard was arrested for the violation of the protection
+order and Bl
+#was released to her father.
+**Nothing
+further"
+* END OF REPORT *
+*
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.receipt.json b/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..160aacc3849948f61b6451fe7da85ccbbef6ce4a
--- /dev/null
+++ b/vision-fixhub/court-01/f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -745,
+  "dataset": "marble-joined",
+  "doc_id": "f97f45f5e0dc16085640cd130cf561a83408b2012e2872056fd178f1aa3d41e7",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "86ca99b0af9afb8df4f2a8edc468d6dea4113bccfbafe65f1410423872df5cab",
+  "output_sha256": "e7b69917254cacbb2667262d6a381fecc3b2f7a1f60112f5dc38a6f86c63fff8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.md b/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.md
new file mode 100644
index 0000000000000000000000000000000000000000..b5f08d52a2c28889930a5cec314e40397ff85517
--- /dev/null
+++ b/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.md
@@ -0,0 +1,79 @@
+Case 9:08-cv-80736-KAM Document 17 Entered on FLSD Docket 07/29/2008 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOES #1 and #2
+Petitioners,
+V.
+UNITED STATES
+Respondent.
+GOVERNMENT'S NOTICE TO COURT REGARDING
+ABSENCE OF NEED FOR EVIDENTIARY HEARING
+Respondent United States, by and through its undersigned counsel, files its Notice to
+Court Regarding Absence of Need for Evidentiary Hearing, and states:
+1. At the conclusion of the hearing held on July 11, 2008, the Court asked the parties
+whether an evidentiary hearing would be necessary.
+The Government suggested that the parties
+confer, and determine whether such a hearing should be held.
+2. After consideration, the Government believes that an evidentiary hearing is not
+necessary. The precise issue before the Court is whether the Government was obligated, under
+18 U.S.C. § 3771(a)(5), to confer with petitioners prior to entering into an agreement with
+Jeffrey Epstein, which permitted the pending State of Florida prosecution to go forward, so long
+as Epstein agreed to certain conditions.
+3. The Government believes there are two relevant facts which will permit the Court to
+resolve the legal issue: (1) there are no criminal charges in the United States District Court,
+Southern District of Florida, filed against Jeffrey Epstein; and (2) Epstein entered pleas of guilty
+
+
+Case 9:08-cv-80736-KAM Document 17 Entered on FLSD Docket 07/29/2008 Page 2 of 3
+in Florida State Court on June 30, 2008, was sentenced, and is now imprisoned in Palm Beach
+County. The Government believes the absence of any charges in the Southern District of
+Florida can be judicially noticed pursuant to Fed.R.Evid. 201(b), because such information is
+either generally known within the territorial jurisdiction of the trial court, or, is capable of
+accurate and ready determination by resort to sources whose accuracy cannot reasonably be
+questioned. Cash Inn of Dade, Inc. v. Metropolitan Dade County, 938 F.2d 1239, 1243 (11"
+Cir. 1991)("A distriet court may take judicial notice of public records within its files relating to
+the particular case before it or related cases.") (citation omitted).
+Under the same rationale, the
+absence of such files can also be judicially noticed.
+Epstein's convictions in State court can be
+established by public record documents, which the Government will file with this Court.
+Respectfully submitted,
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+By:
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4*" Street
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Attorney for Respondent
+2
+
+
+Case 9:08-cv-80736-KAM Document 17 Entered on FLSD Docket 07/29/2008 Page 3 of 3
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on July 29, 2008, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Brad
+Esq.,
+The Law Offices of Brad
+2028|
+Street, Suite 202
+Hollywood, Florida
+33020
+(954) 414-8033
+Fax: (954) 924-1530
+& Associates, LLC
+3
diff --git a/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.receipt.json b/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..eb8dc6d064379e76be56c9f298398424b8dec052
--- /dev/null
+++ b/vision-fixhub/court-01/f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "f98a9ea4d66da74868ba8c5b2f58b84c46f509b569ac36faa98e1638fd059dec",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "5c5f455667ef5a1fe8485c22a11ae877d87f50ec55b9e36cf180345b04441fed",
+  "output_sha256": "84835579867269ebb09fc1f0ac9b06a814c0ecd58d321b7fa34353f2daf4fde0",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.md b/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.md
new file mode 100644
index 0000000000000000000000000000000000000000..afa4a93ab77ae2022867a98066bba1406ed92b0d
--- /dev/null
+++ b/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.md
@@ -0,0 +1,23 @@
+Case 1:19-cv-08673-KPF-DCF Document 3-1
+Filed 09/18/19 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE,
+Plaintiff,
+V.
+Case No. 19 Civ. 8673
+DARREN •. INDYKE and RICHARD D. KAHN, in
+their capacities as executors of the ESTATE OF
+JEFFREY E. EPSTEIN,
+Defendants.
+[PROPOSED] ORDER ON MOTION FOR LEAVE TO
+PROCEED UNDER PSEUDONYM
+WHEREAS Plaintiff Jane Doe ("Plaintiff") filed a Complaint in this action on September
+18, 2019;
+WHEREAS by Notice of Motion dated September 18, 2019, and Memorandum of Law
+dated September 18, 2019, Plaintiff requested that the Court permit her to proceed under a
+pseudonym in this action until such time as the Court may order their names disclosed;
+IT IS HEREBY ORDERED THAT Plaintiff may proceed under a pseudonym in this
+action until such time as the Court may order her name disclosed.
+Dated: September 18, 2019
+U.S.D.J.
diff --git a/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.receipt.json b/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..25f635707237b0081044ff6dbdcf7c0baff4d1de
--- /dev/null
+++ b/vision-fixhub/court-01/f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "f99034d8915159867d2a21c3cf4eaf4451748d2f4615ebd55bb5250775f092d9",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "89b3279d2c784b8f9b74bf7e8099c74e6fde485da7cf7c2c091eb33d7e55d17b",
+  "output_sha256": "243ae668d89effcca2f71d62fbea2f96bd744691a5518a2cb858bb49beb59eca",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.md b/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.md
new file mode 100644
index 0000000000000000000000000000000000000000..af8b3169685c40e6a6e9a8193dd613c54b7952fa
--- /dev/null
+++ b/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.md
@@ -0,0 +1,64 @@
+Case 9:08-cv-80119-KAM Document 132 Entered on FLSD Docket 06/02/2009 Page 1 of 2
+Entered on FLSD Docket 04/29/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA
+JUN - 1 2009
+STEVEN M. LARIMORE
+CLERK U.S. DIST CT
+S.D. OF FLA. - W.P.B.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRALI
+CASE NO.: 08-CV-80380-MARRAL
+CASE NO.: 08-CV-80381-MARRA L
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80994-MARRA/|||
+
+
+Case 9:08-CV-80119-KAM Document 132 Entered on FLSD Docket 06/02/2009 Page 2 of 2
+Entered on FLSD Docket 04/29/2009
+
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- 80993-CIV-MARRA/
+ORDER
+Upon Plaintiffs' Unopposed Motion for Enlargement of Time to File Response to Motions to
+Compel Plainis iReland, Defendant's First Request to Produce and First Set of
+Interrogatories, et al., and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+until May 6, 2009, to respond to the Defendant's Motions to Compel, et al.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this
+day of JuNG
+- 2009.
+Informan
+4-5. MAGiSTRATE
+TuDG
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.receipt.json b/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1e5fb65cd9bf2c0247ae44c575c26c449408c2e0
--- /dev/null
+++ b/vision-fixhub/court-01/f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -121,
+  "dataset": "marble-joined",
+  "doc_id": "f9928cd199dab25e87bc52d0592535dad3a543f0f255898b2b318b7e08143f8a",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "489116add83a9d43fd54cb2343da6dfa8879dfde28d110ddc64a1c1189ef74c0",
+  "output_sha256": "6a8eba90664d77850e00ece505c611ccfe74fe977129e5e1df7a7e2c51a1bb0b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.md b/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.md
new file mode 100644
index 0000000000000000000000000000000000000000..8391ce37936b1de7016197a7966a6cfdbc6a2abe
--- /dev/null
+++ b/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.md
@@ -0,0 +1,139 @@
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+CASE NO.: 08-CV-80119-MARRA/
+Defendant.
+JANE DOE NO. 3,
+/
+CASE NO.: 08-CV-80232-MARRA/
+vS.
+Defendant.
+JANE DOE NO. 4,
+CASE NO.: 08-CV-80380-MARRA/
+Defendant.
+JANE DOE NO. 5,
+CASE NO.: 08-CV-80381-MARRA/JOHNSON
+EXIST A
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 2 of 7
+Defendant.
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80994-MARRA/
+Defendant.
+JANE DOE NO. 7,
+CASE NO.: 08-CV-80993-MARRA/JOHNSON
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA
+Defendant.
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 3 of 7
+JANE DOE,
+CASE NO.: 08-CV-80893-MARRA/
+Defendant.
+JANE DOE NO. II,
+CASE NO.: 08-CV-80469-MARRA/
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 09-CV-80591-MARRAJ
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 09-CV-80656-MARRA/
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 4 of 7
+Defendant.
+ORDER
+THIS CAUSE comes before the Court on Plaintiffs Jane Doe No. 101 and Jane Doe No.
+102's Motion for an Order for the Preservation of Evidence and Incorporated Memorandum of
+Law (DE #114), filed May 26, 2009, and this court's order (DE #192). The parties having
+agreed and the Court having carefully considered the motion and being otherwise fully advised
+in the premises.
+It is ORDERED AND ADJUDGED that Plaintiffs' Motion (DE # 114) is GRANTED as
+follows:
+A.l Defendant, Jeffrey Epstein, and such employees and agents (currently under his control)
+and his attorneys are directed to take every reasonable step to preserve any evidence, resulting
+from the October 25, 2005 search of his home as set forth in this Court's order (DE #151-2; DE
+#20 in Case 9:08 -CV-80804-KAM) previously entered.
+A.2 Defendant, Jeffrey Epstein, and such employees and agents (currently under his control)
+and his attorneys are directed to take every reasonable step to preserve any evidence relevant to
+these cases that have been filed in federal court or that may lead to the discovery of admissible
+evidence relevant to these cases which includes, documents, data, and tangible things, including,
+writings; records; files; correspondence; digital or chemical process photographs (including
+negatives); reports; memoranda; calendars; diaries; minutes; electronic messages; voicemail; e-
+mail; telephone message records or logs; computer and network activity logs; hard drives;
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 5 of 7
+backup data; removable computer storage media, such as tapes, disks, and cards; printouts;
+document image files; web pages; databases; spreadsheets; software; books; ledgers; journals;
+orders; invoices; bills; vouchers; checks; statements; worksheets; summaries; compilations;
+computations; charts; diagrams; graphic presentations; drawings; films; charts; video,
+phonographic, tape, or digital recordings or transcripts thereof; drafts; jottings; and notes.
+Information that serves to identify, locate, or link such material, such as file inventories, file
+folders,
+and indices, is also included. Specifically, Defendant must preserve the following
+evidence as defined herein: records of phone communications; records of domestic and
+international travel, including travel in Defendant's private airplanes; former and current
+employee records; tax returns; any document evidencing payment by Defendant of U.S. currency
+and/or merchandise to each person on the list provided by the United States Attorney's Office
+("USAO list"); any evidence stored in Defendant's storage unit; all photographs of the interior
+and exterior of Defendant's Palm Beach residence as it appeared in 1998 through October 2005;
+any diary, log, memo pad, calendar, or other writing which reflected the date that each person on
+the USAO list visited Defendant's residence; any diary or document wherein each person on the
+USAO list wrote regarding any visits) to Defendant's residence; all documents sent by the Palm
+Beach Police Department ("PBPD"), the FBI, the USAO, or the Palm Beach State Attorney's
+Office ("PBSAO") to the defendant; and all computers used by Defendant and/or such agents
+and employees (currently under his control) to the extent the computers have evidence relating to
+these cases. The time period for the preservation of evidence shall be 1998 - 2002 as it relates to
+Jane Doe 102; and 2002 through October 25, 2005 as it relates to other persons on the USAO
+list.
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 6 of 7
+B.
+"Evidence" is defined as any document or information that is in the possession, custody
+or control of the defendant as of the date of this order and that is relevant to these cases or that
+may lead to the discovery of evidence relevant to these cases. The duty to preserve evidence
+extends to documents, data, and tangible things in the possession, custody, and/or control of
+Defendant, Jeffrey Epstein, and such employees or agents (currently under his control) or
+attorneys who possess materials reasonably anticipated to be subject to discovery in these
+actions. Counsel for the Defendant shall be directly responsible only to the extent they are in
+possession or control of evidence. Counsel shall provide a copy of this Order to the Defendant
+and to those employees or agents whom defense counsel knows or has reason to believe may
+have evidence.
+C.
+"Preservation" is to be interpreted broadly to accomplish the goal of maintaining the
+integrity of all documents, data, and tangible things reasonably anticipated to be subject to
+discovery in these actions under Rules 26, 45, and 56(e) of the Federal Rules of Civil Procedure.
+D.
+If an objection or privilege is raised, the parties may raise the issue with this Court in
+a timely fashion and shall preserve the evidence in question pending resolution by the Court.
+An agreement to preserve evidence and this Order is not a waiver of any existing or future right
+to object to production or any constitutional or evidentiary basis.
+E.
+The parties, without leave of Court, may agree in writing that certain documents or
+categories of evidence need not be preserved as otherwise required by this Order. If such
+agreement is reached, such agreement is effective upon signing and without further order of this
+Court.
+
+
+Case 9:08-cv-80994-KAM Document 77-1 Entered on FLSD Docket 07/28/2009 Page 7 of 7
+F.
+If this Court determines that evidence has been wrongfully destroyed or lost in
+violation of this Order, it may impose appropriate sanctions based upon motion and an
+evidentiary hearing, if necessary.
+G.
+Each party shall bear its own costs for complying with this Order.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this
+-of
+- 2009.
+KENNETH A. MARRA
+United States District Court Judge
+Copies to:
+All counsel of record
\ No newline at end of file
diff --git a/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.receipt.json b/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3ab17762ce1358698fadb2fffd0517c1fe56da8b
--- /dev/null
+++ b/vision-fixhub/court-01/f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -433,
+  "dataset": "marble-joined",
+  "doc_id": "f9ad1ae614f73cdd623d192d212faaa26320248203b31714b3dde82be711abaf",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "4477509b0f5c592de98ed5249ff875a994df0eb743efa02aee43564f725d78d0",
+  "output_sha256": "3a94d329fd43bdf7240cf8761f3985b1e71f2a95b9ec1053a36be7a6033746c3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.md b/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.md
new file mode 100644
index 0000000000000000000000000000000000000000..08b032c535035d8ae393a632402406e914d3fe23
--- /dev/null
+++ b/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.md
@@ -0,0 +1,105 @@
+Case 9:08-cv-80381-KAM Document 145 Entered on FLSD Docket 06/14/2010 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+PLAINTIFE, C.L.'S NOTICE OF WITHDRAWING SUBPOENA SERVED
+ON MARITZA MILAGROS VASQUEZ AND CANCELLING DEPOSITION
+SCHEDULED FOR JUNE 15. 2010
+Plaintiff, C.L., by and through her undersigned counsel, hereby gives notice of
+withdrawing the Subpoena for Deposition directed to Maritza Milagros Vasquez and, further,
+gives notice of canceling the deposition of Maritza Milagros Vasquez scheduled for June 15,
+2010 in the C.L. v. Epstein, Case No. 10-80447-CIV-Marra/Johnson pending in the United States
+District Court, Southern District of Florida.
+CERTIFICATE OF SERVICE
+I hereby certify that on June 14, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day on all counsel of record or pro se parties identified on the attached Service List in the
+manner specified, either via transmission of Notices of Electronic Filing generated by CM/ECF
+or in some other authorized manner for those counsel or parties who are not authorized to receive
+electronically.
+S/SPENCER T. KUVIN
+SPENCER T. KUVIN (Florida Bar No.: 089737)
+Email: skuvin@leopoldküvin.com
+Leopold~Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+(561) 515-1400; (561) 515-1401 (facsimile)
+Attorneys for Plaintiff, C.L.
+
+
+Case 9:08-cv-80381-KAM Document 145 cEnicard 81 self@ Docket 06/14/2010 Page 2 of 2
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA
+Stuart S. Mermeistein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattomney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+Paul G. Cassell, Esq.
+08-80232, 08-80380, 08-80381, 08-80993,
+Pro Hac Vice
+08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Jack Alan Goldberger, Esq.
+801-585-5202
+Atterbury Goldberger & Weiss, P.A.
+801-585-6833 Fax
+250 Australian Avenue South
+cassellp@law.utah.edu
+Suite 1400
+Co-counsel for Plaintiff Jane Doe
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+08-80469
+Robert D. Critton, Jr., Esq.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+Michael J. Pike, Esq.
+Florida Bar No. 617296
+mpike@bclclaw.com
+Burman, Critton, Luttier & Coleman
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL: 33401
+561-842-2820
+561-515-3148 Fax
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.receipt.json b/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c174c3233ac2e3eb462db9ce96a224b58fb816e4
--- /dev/null
+++ b/vision-fixhub/court-01/f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "f9cf0fd004785a4acd1aebc4f745a26343626a52eaff1f8442275440f770363e",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3b804d3d55f92863ff484293ea010924a41ae37b27d56297ef591ceac6066222",
+  "output_sha256": "2d9cbc178755e6715f2b879a0af2df5522c9bd85311d2a3f7cdc6b876cc10ad5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.md b/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.md
new file mode 100644
index 0000000000000000000000000000000000000000..3397402191eba6f76527a5cec730b184b48d27d2
--- /dev/null
+++ b/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.md
@@ -0,0 +1,176 @@
+Case 9:08-cv-80119-KAM Document 304 Entered on FLSD Docket 09/16/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/.
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT'S NOTICE OF INDEPENDENT MEDICAL EXAMINATION OF
+PLAINTIFF. JANE DOE # 4 (80380)
+Defendant, JEFFREY E. EPSTEIN, pursuant to Rule 35, Fed. R. Civ. P., notices
+the Plaintiff for an independent/psychological medical examination and states:
+An appointment for examination of the Plaintiff has been made with Ryan
+M.D. of C.W.
+M.D., P.A. at 9:00 a.m. on October 14, 2009 at the law firm of
+Burman, Critton, Luttier and Coleman, LLP, located at 303 Banyan Boulevard, Ste. 400,
+West Palm Beach, FL, 33401. The Plaintiff' is to wear comfortable clothing and bring a
+sweater. The examination shall consist of an interview and testing and will likely last
+until 5:30 p.m. See infra and Motion attached at DE (303) for scope, time and place of
+IME. See Exhibits attached as well.
+
+
+Case 9:08-cv-80119-KAM Document 304 Entered on FLSD Docket 09/16/2009 Page 2 of 4
+Plaintiff has not provided an available date; however, unless a timely and
+valid objection to this Notice is made, the Plaintiff is required by this Rule to be in
+attendance at the above-scheduled examination.
+Pursuant to Rule 35, if the psychiatrist performing the examination is
+called as a witness, the psychiatrist shall not be identified as one appointed by the Court.
+4.
+The cost of the examination will be originally borne by the Defendant but
+is subject to taxation by the Court upon proper motion.
+The interview will be videotaped.
+6.
+Dr. Halls' specialties and qualifications are attached to the Motion
+to Compel the IME at DE (303). The time, place, manner, conditions and scope
+of the examination are attached to the Motion to Compel the IME at DE (303).
+See Affidavit attached thereto. All of the above documents have been provided
+to the Plaintiff's counsel and, therefore, sufficient notice has been made,
+By C
+MICHABLI. PIKE, ESQ.
+Florida Bar #617296
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+Respectfully submitted,
+By: .
+5. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+
+
+Case 9:08-cV-80119-KAM Document 304 Entered on FLSD Docket 09/16/2009 Page 3 of 4
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/.
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069,
+, 08-80119,
+08-80232, 08-80380, 08-80381,
+08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80817
+reelrhw@hotmail.com
+Jack Scarola, Esq.
+Jack P.
+, Esq.
+Isidro M. L
+, Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff in Related Case No.
+
+
+Case 9:08-cv-80119-KAM Document 304 Entered on FLSD Docket 09/16/2009 Page 4 of 4
+Searcy Denney Scarola Barnhart & Shipley, 08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+isx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A.
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+305 358-2800
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
diff --git a/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.receipt.json b/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..49ccefa709e855a57d81844f357dde4354fee769
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+++ b/vision-fixhub/court-01/f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "f9cf28d595623e87149d93b03ffd121c88993e5529889e5675c6c0d11447094e",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "6e55723e33f131c4ea76f20a010c55a6569e221b194be675a2990388d5f58fe9",
+  "output_sha256": "e8e5d76c558d808b2b99abc9805b91b302ce652fac34f193c31a6a2e4175cfa7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.md b/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.md
new file mode 100644
index 0000000000000000000000000000000000000000..20a0db4fb31bc3a6fc52dc135641e6780c75960b
--- /dev/null
+++ b/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.md
@@ -0,0 +1,107 @@
+Case 9:09-cv-80656-KAM Document 11 Entered on FLSD Docket 05/14/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+vs. JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRA/
+VS.
+JEFFREY EPSTEIN,
+
+
+Case 9:09-cv-80656-KAM Document 11 Entered on FLSD Docket 05/14/2009 Page 2 of 4
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-80994-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-80993-CIV-MARRAJ_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/_
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08- 80893-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN et al,
+2
+
+
+Case 9:09-cv-80656-KAM Document 11 Entered on FLSD Docket 05/14/2009 Page 3 of 4
+Defendants.
+DOE II,
+CASE NO.: 09- 80469-CIV-MARRA
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09- 80591-CIV-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102
+Plaintiff,
+CASE NO.: 09- 80656-CIV-MARRA/_
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+ORDER REQUESTING THE UNITED STATES TO PROVIDE ITS POSITION
+REGARDING DEFENDANT EPSTEIN'S MOTION TO STAY/CONTINUE THE CIVIL
+CASES PENDING AGAINST HIM
+THIS CAUSE is before the Court upon the motions filed in several cases by Defendant
+3
+
+
+Case 9:09-cv-80656-KAM Document 11 Entered on FLSD Docket 05/14/2009 Page 4 of 4
+Jeffrey Epstein to Stay and/or Continue the Action for Time Certain Based on Parallel Civil and
+Criminal Proceedings. See, e.g., docket entry 51 in C.M.A. v. Epstein and
+, case no. 08-
+80811 (attached). Epstein moves for a stay until the expiration of the Non-Prosecution
+Agreement ("NPA") with the United States Attorney's Office (USAO) because, he claims, the
+USAO has taken the position that he is violating the NPA by defending the civil actions filed
+against him. Therefore, he argues that he cannot defend the civil actions without subjecting
+himself to criminal prosecution.
+While the Court recognizes that the United States is not a party to these actions and is not
+obligated to comment on this matter, the position of the United States would greatly assist the
+Court in resolving the merits of these motions to continue/stay the case. Accordingly, the Court
+requests that the United States provide its position on the matter. The Court would appreciate the
+governments position within 15 days if possible. If the United States is unwilling to state its
+position, the Court would also appreciate being so advised.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 14* day of May, 2009
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+Ann
+Villafana
+4
diff --git a/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.receipt.json b/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9b8a6d84e37d34a82b50e3762528c3f17af6342b
--- /dev/null
+++ b/vision-fixhub/court-01/f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "f9cfdefdb061c57a9b2e5b09f8360466dd6d844e38ff31d9ff5f5c5a5fcd9893",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "2b747b8ef887a52031a26ea9ff5b2d46a5929bb7f815d646e963576e189ede4f",
+  "output_sha256": "317803967dc35141e36a78916e753701d03adc75be87346a7124dd0fe2fc8557",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/f9ddd8378aad82b2af5d324698a8fe2be4deee22553ec8d6a7557b038a9a47ff.md b/vision-fixhub/court-01/f9ddd8378aad82b2af5d324698a8fe2be4deee22553ec8d6a7557b038a9a47ff.md
new file mode 100644
index 0000000000000000000000000000000000000000..2c6e2cb791f248946237f5d647f57376a57bd517
--- /dev/null
+++ b/vision-fixhub/court-01/f9ddd8378aad82b2af5d324698a8fe2be4deee22553ec8d6a7557b038a9a47ff.md
@@ -0,0 +1,513 @@
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 1 of 17
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ANASTASIA DOE,
+Plaintiff,
+CASE NO.: 1:19-cv-11869 (MK V) (DCF)
+V.
+DARREN K. INDYKE AND RICHARD D.
+KAHN AS CO-EXECUTORS OF THE
+ESTATE OF JEFFREY E. EPSTEIN,
+Defendants.
+DEFENDANTS' ANSWER AND AFFIRMATIVE DEFENSES TO
+PLAINTIFF'S COMPLAINT
+Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors of the Estate of
+Jeffrey E. Epstein (the "Co-Executors"), through their undersigned counsel, hereby respond to the
+numbered paragraphs of Plaintiff's Complaint (ECF Doc. 1) as follows:
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in the first sentence of paragraph 1 of the Complaint. The second
+sentence of paragraph 1 of the Complaint states a legal conclusion to which no response is required.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 2 of the Complaint, except admit that Plaintiff filed the
+Complaint using a pseudonym.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 3 of the Complaint.
+4.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 4 of the Complaint, except admit that, at the time of his
+death, decedent Jeffrey E. Epstein ("Decedent") was a U.S. citizen.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 2 of 17
+5.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 5 of the Complaint, except admit that Decedent was born
+in 1953 and died on August 10, 2019.
+6.
+Paragraph 6 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors deny the allegations in paragraph
+6 of the Complaint except admit that, on August 15, 2019, a petition for probate and for letters
+testamentary In the Matter of the Estate of Jeffrey E. Epstein was filed in the Superior Court of the
+Virgin Islands Division of St.
+and St. John; and the Co-Executors refer thereto for the full
+text, terms and meaning thereof.
+7.
+Paragraph 7 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 7 of the Complaint.
+8.
+Paragraph 8 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 8 of the Complaint; except
+the Co-Executors admit that, on September 6, 2019, the Superior Court of the Virgin Islands
+Division of St.
+and St. John issued Letters Testamentary appointing the Co-Executors as
+co-executors for Decedent's estate and refer thereto for the full text, terms and meaning thereof.
+FACTUAL ALLEGATIONS
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 9 of the Complaint.
+10.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 10 of the Complaint.
+-2-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 3 of 17
+1l.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 11 of the Complaint.
+12.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 12 of the Complaint.
+13.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 13 of the Complaint.
+14.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 14 of the Complaint.
+15.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 15 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+16. The Co-Executors deny the allegations in paragraph 16, except admit the existence
+of the indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and
+meaning thereof.
+17. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 17 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+18.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 18 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+- 3-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 4 of 17
+19.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 19 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+20.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 20 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+21.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 21 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+22. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 22 of the Complaint, except admit the existence of the
+indictment attached to Plaintiff's Complaint and refer thereto for the full text, terms and meaning
+thereof.
+23.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 23 of the Complaint.
+24.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 24 of the Complaint.
+ANASTASIA DOE
+25.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 25 of the Complaint.
+- 4-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 5 of 17
+26. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 26 of the Complaint.
+27.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 27 of the Complaint.
+28.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 28 of the Complaint.
+29.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 29 of the Complaint.
+30.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 30 of the Complaint.
+31.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 31 of the Complaint.
+32.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 32 of the Complaint.
+33.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 33 of the Complaint.
+34.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 34 of the Complaint.
+35.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 35 of the Complaint.
+36.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 36 of the Complaint.
+- 5-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 6 of 17
+37. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 37 of the Complaint.
+38.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 38 of the Complaint.
+39.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 39 of the Complaint.
+40.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 40 of the Complaint.
+41.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 41 of the Complaint.
+42. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 42 of the Complaint.
+43. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 43 of the Complaint.
+44.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 44 of the Complaint.
+45.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 45 of the Complaint.
+46.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 46 of the Complaint.
+47.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 47 of the Complaint.
+- 6-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 7 of 17
+48. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 48 of the Complaint.
+49.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 49 of the Complaint.
+50.
+Paragraph 50 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 50 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 50 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+51.
+Paragraph 51 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 51 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 51 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+52.
+Paragraph 52 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 52 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 52 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+- 7-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 8 of 17
+53.
+Paragraph 53 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 53 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 53 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+54.
+Paragraph 54 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 54 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 54 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+55.
+Paragraph 55 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 55 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 55 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+56.
+Paragraph 56 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 56 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 56 of the Complaint
+- 8-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 9 of 17
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+57.
+Paragraph 57 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 57 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 57 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+58.
+Paragraph 58 of the Complaint states a legal conclusion to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 58 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 58 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+59.
+COUNT I
+BATTERY/VIOLATION OF SECTION 130
+AGAINST THE ESTATE OF JEFFREY E. EPSTEIN
+The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint
+as if set forth fully herein.
+60.
+Paragraph 60 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 60 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 60 of the Complaint
+characterize the referenced statutes, the statutes speaks for themselves. The Co-Executors refer to
+the referenced statutes for the full text, terms and meaning thereof.
+- 9-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 10 of 17
+61. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 61 of the Complaint.
+62.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in Paragraph 62 of the Complaint.
+63.
+Paragraph 63 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 63 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 63 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+64.
+Paragraph 64 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 64 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 64 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+The "WHEREFORE" paragraph following paragraph 64 of the Complaint purports to state
+Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that
+a response is required, the Co-Executors, based on lack of knowledge or information sufficient to
+form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the
+relief described therein, or to any relief whatsoever.
+- 10 -
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 11 of 17
+COUNT TWO
+SEXUAL ASSAULT
+65.
+The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint
+as if set forth fully herein.
+66.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 66 of the Complaint.
+67.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 67 of the Complaint.
+68.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 68 of the Complaint.
+69.
+Paragraph 69 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 69 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 69 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+70.
+Paragraph 70 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 70 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 70 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+"The "WHEREFORE" paragraph following paragraph 70 of the Complaint purports to
+state Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent
+- 11-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 12 of 17
+that a response is required, the Co-Executors, based on lack of knowledge or information sufficient
+to form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the
+relief described therein, or to any relief whatsoever.
+COUNT THREE
+INTENTIONAL INFLICTION OF EMOTIONAL DISTRESS
+71.
+The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint
+as if set forth fully herein.
+72. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 72 of the Complaint.
+73.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 73 of the Complaint.
+74.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 74 of the Complaint.
+75.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 75 of the Complaint.
+76.
+The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 76 of the Complaint.
+77. Paragraph 77 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 77 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 77 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+- 12-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 13 of 17
+78.
+Paragraph 78 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 78 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 78 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+The "WHEREFORE" paragraph following paragraph 78 of the Complaint purports to state
+Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that
+a response is required, the Co-Executors, based on lack of knowledge or information sufficient to
+form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the
+relief described therein, or to any relief whatsoever.
+79.
+COUNT FOUR
+NEGLIGENT INFLICTION OF EMOTIONAL DISTRESS
+The Co-Executors incorporate their answers to paragraphs 1-58 of the Complaint
+as if set forth fully herein.
+80. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 80 of the Complaint.
+81. The Co-Executors lack knowledge or information sufficient to form a belief about
+the truth of the allegations in paragraph 81 of the Complaint.
+82.
+Paragraph 82 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 82 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 82 of the Complaint
+- 13 -
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 14 of 17
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+83.
+Paragraph 83 of the Complaint states legal conclusions to which no response is
+required. To the extent a response is required, the Co-Executors lack knowledge or information
+sufficient to form a belief about the truth of the allegations in paragraph 83 of the Complaint. The
+Co-Executors further state that, to the extent the allegations in paragraph 83 of the Complaint
+characterize the referenced statute, the statute speaks for itself. The Co-Executors refer to the
+referenced statute for the full text, terms and meaning thereof.
+The "WHEREFORE" paragraph following paragraph 83 of the Complaint purports to state
+Plaintiff's prayer for relief and jury demand, to which no response is required. To the extent that
+a response is required, the Co-Executors, based on lack of knowledge or information sufficient to
+form a belief about the truth of Plaintiff's allegations, deny that Plaintiff is entitled to any of the
+relief described therein, or to any relief whatsoever.
+The Co-Executors deny any and all allegations in the Complaint not expressly admitted
+herein.
+AFFIRMATIVE DEFENSES
+The Co-Executors, to the extent required by Fed. R. Civ. P. 8(c), assert the following
+affirmative defenses. By pleading these defenses, the Co-Executors do not assume the burden of
+proving any fact, issue, or element of a cause of action where such burden belongs to Plaintiff.
+Moreover, nothing stated herein is intended to or shall be construed as a concession that any
+particular issue or subject matter is relevant to Plaintiff's allegations.
+1.
+Plaintiff's Complaint fails, in whole or in part, to state a claim upon which relief
+can be granted.
+- 14-
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 15 of 17
+2.
+Plaintiff's claims are barred to the extent Plaintiff has not suffered any damages;
+alternatively, Plaintiff's claims are barred to the extent Plaintiff has not been damaged to the extent
+alleged, and failed to mitigate any damages she may have suffered.
+3.
+Contributory Negligence. If Plaintiff suffered or sustained any loss, injury, damage
+or detriment, and the same was directly and proximately caused and contributed to by the conduct,
+acts, omissions, activities, carelessness, negligence, and/or intentional misconduct of Plaintiff,
+Plaintiff's recovery herein is partially or completely barred.
+4.
+Assumption of Risk. Plaintiff's claims are barred to the extent that, at the time and
+place of the incidents alleged in Plaintiff's Complaint, Plaintiff knew of and fully understood the
+danger and risks incident to their undertaking; but despite such knowledge, Plaintiff freely and
+voluntarily assumed and exposed herself to all risks of harm and the consequential injuries and
+resultant damages, if any.
+Comparative Fault of Third Parties. If and to the extent that the Co-Executors are
+subjected to any liability to Plaintiff due, in whole or in part, to the acts, omissions, activities,
+carelessness, recklessness, negligence, and intentional misconduct of persons or entities other than
+Decedent, any recovery obtained by Plaintiff against the Co-Executors should be reduced in
+proportion to the respective negligence and fault and legal responsibility of all such other persons
+and entities, and their agents, servants and employees who contributed to or caused any such injury
+or damages, in accordance with the law of comparative negligence; the liability of the Co-
+Executors, if any, is limited in direct proportion to the percentage of fault actually attributed to
+Decedent.
+6.
+Statute of Limitations. The Complaint, and each and every cause of action
+contained therein, is barred by the applicable statute of limitations, including without limitation
+- 15 -
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 16 of 17
+because the New York Child Victims' Act, including without limitation CPLR 214-g, violates the
+New York Constitution and the U.S. Constitution.
+7.
+Intervening/Superseding Causes. To the extent the injuries and damages which
+Plaintiff alleges were proximately caused by, or contributed to by, the acts of other persons or
+other entities, and said acts were intervening or superseding causes of the injuries and damages, if
+any, which Plaintiff alleges, Plaintiff is barred from any recovery against the Co-Executors.
+8.
+Plaintiff's claims are barred by the doctrines of waiver, estoppel and laches,
+9.
+Plaintiff's claims are barred by the doctrines of in pari delicto and unclean hands.
+10. To the extent Plaintiff seeks damages that are punitive in nature, they are barred
+including without limitation pursuant to N.Y. E.P.T.L. § 11-3.2.
+11.
+Plaintiff's claims are barred to the extent she is simultaneously prosecuting her
+claims in the Southern District of New York and the Superior Court of the Virgin Islands Division
+of St.
+and St. John.
+The Co-Executors have not knowingly or intentionally waived any applicable affirmative
+defenses and reserve the right to assert and rely upon such affirmative defenses as may become
+available or apparent during discovery. The Co-Executors further reserve the right to amend their
+Answer accordingly.
+- 16 -
+
+
+Case 1:19-cv-11869-MKV-DCF Document 23 Filed 02/19/20 Page 17 of 17
+Dated: New York, New York
+February 19, 2020
+By: Is/ Bennet J. Moskowitz
+Bennet J. Moskowitz
+TROUTMAN SANDERS LLP
+875 Third Avenue
+New York, New York 10022
+Attorneys for Defendants
+- 17 -
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@@ -0,0 +1,236 @@
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+CASE NO.: 08-CV-80119-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/_
+VS.
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+CASE NO.: 08-CV-80380-MARRA/
+VS.
+Defendant.
+JANE DOE NO. S,
+Plaintiff,
+CASE NO.: 08-CV-80381-MARRAJ
+VS.
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 2 of 9
+Defendant.
+JANE DOE NO. 6,
+Plaintift,
+CASE NO.: 08-CV-80994-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.: 08-CV-80993-MARRAJ
+VS.
+Defendant.
+C.M.A.,
+CASE NO.: 08-CV-80811-MARRA/
+Plaintiff,
+VS.
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.: 08-CV-80893-MARRA/
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 3 of 9
+VS.
+Defendant.
+JANE DOE NO. II,
+Plaintiff,
+CASE NO.: 08-CV-80469-MARRA/
+VS.
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 09-CV-80591-MARRAJ
+VS.
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.: 09-CV-80656-MARRA/
+VS.
+Defendant.
+MOTION TO RESCHEDULE HEARING
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 4 of 9
+COMES NOW Robert C. Josefsberg, as co-counsel for Jane Doe 101 and 102, and
+respectfully requests either a rescheduling of this Court's hearing (just rescheduled for June, 12,
+2009) or in the alternative, permission to appear by telephone at said hearing, on the following
+grounds:
+1) On Wednesday, June 10, 2009, undersigned counsel, his wife and two granddaughters
+will be traveling to Hanover, New Hampshire for counsel's 50"* College Reunion, and an
+opportunity for his two high school granddaughters to visit colleges in the Northeast. Counsel is
+scheduled to return to South Florida on Tuesday, June 16".
+2) Counsel is very appreciative and supportive of the Court's scheduling a hearing on the
+Defendants' Motion to Stay. That hearing was scheduled (within the last 3 hours) for Friday,
+June 12" at 10:00 a.m., right in the middle of Robert Josefsberg's reunion visit.
+3) If Robert Josefsberg cannot attend, Jane Doe 101 and 102 will be well represented by
+co-counsel who can and will appear in person at said hearing on June 12, 2009. However,
+Robert Josefsberg is lead counsel and would prefer to be present during said hearing.
+4) In the event that this hearing cannot be rescheduled for June 4, 5, 8 or 9", or June 17",
+18"' or 19", Robert Josefsberg requests permission to appear at said June 12th hearing by
+telephone.
+WHEREFORE, Robert Josefsberg requests the relief requested above.
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 5 of 9
+Dated May 29, 2009.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/ Robert C. Josefsberg
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 6 of 9
+CERTIFICATE OF SERVICE
+WE HEREBY CERTIFY that on this _
+_ day of May, 2009, we electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. We also certify that the foregoing
+document is being served this day on all counsel of record identified on the attached Service List
+either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other
+authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Respectfully submitted,
+PODHURST ORSECK, P.A.
+Attorneys for Plaintiffs Jane Doe No. 101
+and Jane Doe No. 102
+By:
+s/Katherine W. Ezell
+Robert C. Josefsberg
+Fla. Br No. 040856
+rjosefsberg@podhurst.com
+Katherine W. Ezell
+Fla. Bar No. 114771
+kezell@podhurst.com
+City National Bank Building
+25 W. Flagler Street, Suite 800
+Miami, FL 33130
+Telephone: (305) 358-2800
+Facsimile: (305) 358-2382
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 7 of 9
+SERVICE LIST
+JANE DOE NO. 2 v. JEFFREY EPSTEIN
+Case No. 08-CV-80119-MARRA/
+United States District Court, Southern District of Florida
+Robert Critton, Esq.
+Michael J. Pike, Esq.
+Burman, Critton, Luttier & Coleman LLP
+515 North Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+Phone: (561) 842-2820
+Fax: (561) 515-3148
+rcrit@bclclaw.com
+mpike@bclclaw.com
+Counsel for Defendant, Jeffrey Epstein
+Jack Goldberger, Esq.
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant, Jeffrey Epstein
+Bruce E. Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 South Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 202-6360
+Fax: (561) 828-0983
+ecf@brucereinhartlaw.com
+Counsel for Co-Defendant,
+Jack Scarola, Esq.
+Jack P.
+Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9456
+isx @searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff C.M.A.
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 8 of 9
+Adam Horowitz, Esq.
+Stuart Mermelstein, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Blvd., Suite 2218
+Miami, FL 33160
+Phone: (305) 931-2200
+Fax: (305) 931-0877
+ahorowitz@sexabuseattorney.com
+smermelstein@sexabuseattorney.com
+Counsel for Plaintiffs in Related Cases Nos. 08-80069, 08-80119,08-80232, 08-80380, 08-
+80381, 08-80993, 08-80994
+Spencer Todd Kuvin, Esq.
+Theodore Jon Leopold, Esq.
+Leopold Kuvin, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Phone: (561) 515-1400
+Fax: (561) 515-1401
+skuvin@leopoldkuvin.com
+tleopold@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No. 08-08804
+Richard Willits, Esq.
+Richard H. Willits, P.A.
+2290 10* Ave North, Suite 404
+Lake Worth, FL 33461
+Phone: (561) 582-7600
+Fax: (561) 588-8819
+lawyerwillits@aol.com
+reelrhw@hotmail.com
+Counsel for Plaintiff in Related Case No. 08-80811
+Brad
+1, Esq.
+Law Office of Brad
+& Associates, LLC
+2028
+Street, Suite 202
+Hollywood, FL 33020
+Phone: (954) 414-8033
+Fax: (954) 924-1530
+bedwards@rra-law.com
+be@bradedwardslaw.com
+Counsel for Plaintiff in Related Case No. 08-80893
+Isidro Manuel
+Esq.
+Elkins & Boehringer
+224 Datura Avenue, Suite 900
+
+
+Case 9:09-cv-80591-KAM Document 38 Entered on FLSD Docket 05/29/2009 Page 9 of 9
+West Palm Beach, FL 33401
+Phone: (561) 832-8033
+Fax: (561) 832-7137
+isidrogarcia @ bellsouth.net
+Counsel for Plaintiff in Related Case No. 08-80469
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fa0ca909dbb5422c8f2f28a008a9767b44906f6cd97c746ce5fa12b08be85066.receipt.json b/vision-fixhub/court-01/fa0ca909dbb5422c8f2f28a008a9767b44906f6cd97c746ce5fa12b08be85066.receipt.json
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diff --git a/vision-fixhub/court-01/fa167bc1d08ce96e18d7f6283ede28ff7c5a0f2d109fed96f3017eeb5554b1dd.md b/vision-fixhub/court-01/fa167bc1d08ce96e18d7f6283ede28ff7c5a0f2d109fed96f3017eeb5554b1dd.md
new file mode 100644
index 0000000000000000000000000000000000000000..b465ee58a114d71551e4ddf3ad5d908a7e3ea386
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@@ -0,0 +1,126 @@
+Filing # 132287422 E-Filed 08/09/2021 01:49:55 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+CASE NO.: 50-2019-CA-014681-AG
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+ORDER ON JOINT MOTION TO CONTINUE EVIDENTIARY HEARING ON DAVE
+ARONBERG'S AMENDED MOTION FOR ATTORNEYS' FEES
+THIS CAUSE having come before the Court on the Joint Motion to Continue the
+Evidentiary Hearing on Dave Aronberg's November 9, 2020 Amended Motion for Attorneys' Fees
+(the "Joint Motion"), filed by Plaintiff CA Florida Holdings LLC, and Defendant/Movant Dave
+Aronberg, and the Court being advised in the premises does hereby:
+ORDER AND ADJUDGE as follows:
+1.) The Joint Motion is GRANTED.
+The Evidentiary Hearing on Dave Aronberg's Amended Motion for Attorneys'
+Fees scheduled for August 17, 2021 at 9:30 am, is hereby cancelled.
+1
+FILED: PALM BEACH COUNTY, FL,
+ABRUZZO, CLERK, 08/09/2021 01:49:55 PM
+
+
+3.
+The Evidentiary Hearing on Dave Aronberg's Amended Motion for Attorneys"
+Fees is hereby re-scheduled for the Court's March 14 through May 20, 2022 docket with calendar
+call set for March 4, 2022 at 9:00 am in Courtroom 10D, West Palm Beach, FL.
+DONE AND ORDERED in |
+in West Palm Beach, Palm Beach County, Florida.
+ANMINI
+BARCIRCUIT
+Donald Hafele Circult Judge-
+IF OFFICE OF THE GOINT
+502019CA014681XXXXMB
+Donald Hafele
+Circult Judge
+08/05/2021
+cc:
+Name
+CYNTHIA M
+GUERRA
+DOUGLAS A.
+WYLER
+JAMES CULLEN
+MOONEY
+JESSICA NEER
+MCDONALD
+KENNETH G.
+TURKEL
+Address
+n/a
+n/a
+961687 GATEWAY
+BLVD SUITE 201-1
+FERNANDINA
+BEACH, FL 32034
+n/a
+POST OFFICE BOX
+229 WEST PALM
+BEACH, FL 33401
+777 S FLAGLER DR
+LAUREN R.
+WHETSTONE
+STE 300 E WEST
+PALM BEACH, FL
+33401
+MARK F. BIDEAU
+n/a
+54 STATE STREET
+MICHAEL GRYGIEL 6TH FLOOR
+ALBANY, NY 12207
+MICHAEL J.
+GRYGIEL
+n/a
+Email
+Clerk_e-service@mypalmbeachclerk.com
+doug.wyler@comcast.net
+jmooney@bajocuva.com,
+lheckman@bajocuva.com
+CLERK_E-
+SERVICE@MYPALMBEACHCLERK.COM,
+jnmcdonald@mypalmbeachclerk.com
+kturkel@bajocuva.com,
+lisa.meriwether@bajocuva.com,
+teri.deleo@bajocuva.com
+WHETSTONEL@GTLAW.COM,
+flservice@gtlaw.com,
+sandra.famadas@gtlaw.com
+bideaum@gtlaw.com, thomasd@gtlaw.com,
+FLService@gtlaw.com
+GRYGIELM@GTLAW.COM
+grygielm@gtlaw.com
+2
+
+
+NameR
+Address
+1840 CENTURY
+NINA D. BOYAJIAN
+PARK EAST SUITE
+1900 LOS ANGELES,
+CA 90067
+NINA D. BOYAJIAN n/a
+SHANE B. VOGT
+n/a
+5100 TOWN CENTER
+STEPHEN A.
+CIR SUITE 400
+MENDELSOHN, ESQ BOCA RATON, FL
+33486
+Email
+boyajiann@gtlaw.com, riveraal@gtlaw.com
+shane.vogt@bajocuva.com,
+garnold@bajocuva.com
+mendelsohns@gtlaw.com, smithl@gtlaw.com,
+flservice@gtlaw.com
+NOT A CERTIFIED COI
+3
diff --git a/vision-fixhub/court-01/fa167bc1d08ce96e18d7f6283ede28ff7c5a0f2d109fed96f3017eeb5554b1dd.receipt.json b/vision-fixhub/court-01/fa167bc1d08ce96e18d7f6283ede28ff7c5a0f2d109fed96f3017eeb5554b1dd.receipt.json
new file mode 100644
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "65b85f07b9f783de4be2729bc9562b290c5ef2df3c0671c690745d7b6089a937",
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+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/fa1f7826bc26fb0a8d41447246b3ad2ac8f2f54fa60425004cee3e0b1ea5d422.md b/vision-fixhub/court-01/fa1f7826bc26fb0a8d41447246b3ad2ac8f2f54fa60425004cee3e0b1ea5d422.md
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@@ -0,0 +1,142 @@
+Case 9:08-cv-80232-KAM Document 92 Entered on FLSD Docket 05/18/2009 Page 1 of 5
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/JO
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/J
+VS.
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 08-CV-80380-MARRA/J
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80232-KAM Document 92 Entered on FLSD Docket 05/18/2009 Page 2 of 5
+CASE NO.: 08-CV-80381-MARRA/JQ
+JANE DOE NO. 5,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80994-CIV-MARRA/JO
+JANE DOE NO. 6,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-80993-CIV-MARRA/J
+JANE DOE NO. 7,
+Plaintiff,
+JEFFREY EPSTEIN
+•Defendant.
+C.M.A.,
+CASE NO.: 08-80811-CIV-MARRA/J
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+
+
+Case 9:08-cv-80232-KAM Document 92 Entered on FLSD Docket 05/18/2009 Page 3 of 5
+JANE DOE,
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+CASE NO.: 08-80893-CIV-MARRA/JOHNSON
+/
+DOE II,
+CASE NO.: 09-80469-CIV-MARRA-JL
+Plaintiff,
+JEFFREY EPSTEIN et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+JEFFREY EPSTEIN
+Defendant.
+CASE NO.: 09-80591-CIV-MARRA-JL
+JANE DOE NO. 102,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 09-80656-CIV-MARRA/J
+DEFENDANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME
+TO FILE REPLY TO PLAINTIFFS' JANE DOE 2-7 RESPONSES IN
+OPPOSITION TO MOTION TO COMPEL ANSWERS TO 1 SET OI
+INTERROGATORIES AND REQUEST FOR PRODUCTION
+
+
+Case 9:08-cv-80232-KAM Document 92 Entered on FLSD Docket 05/18/2009 Page 4 of 5
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+reply to Plaintiffs' Responses In Opposition to Defendant's Motion to Compel Answers
+to Interrogatories And Production of Documents, dated March 2, 2009. Local General
+Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P. (2009). Defendant seeks an extension until May
+22, 2009, to file his response. As good cause in support of granting the motion,
+Defendant states:
+1. Defendant's reply to the Plaintiff's Responses in Opposition to Defendant's
+Motion to compel would be due on May 18, 2009. As certified below, Plaintiff's counsel
+is in agreement with the requested extension of May 20, 2009.
+2. Plaintiff's counsel also represents five other Plaintiffs pursuing claims against
+Defendant, EPSTEIN. A total of five of the Plaintiffs have also filed Responses In
+Opposition to Defendant's Motions to Compel bearing the same dates. In order to fully
+and adequately respond to this and the other motions, Defendant is in need of an
+extension until May 20, 2009.
+3. The requested extension is fair in reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately reply to this and
+the other Responses in Opposition to Defendant's Motion to Compel.
+WHEREFORE, Defendant requests that this Court enter an order granting the
+Defendant an extension until May 20, 2009, in which to respond to Plaintiff's Response
+in Opposition to Defendant's Motion to Compel Answers to Interrogatories and
+Production of documents.
+Local Rule 7.1 Certification
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and
+
+
+Case 9:08-cv-80232-KAM Document 92 Entered on FLSD Docket 05/18/2009 Page 5 of 5
+Counsel for Plaintiff is in agreement with the requested extension until May 20, 2009 for
+Defendant to respond to the motion to compel.
+ell
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+being served this day on all counsel of record identified on the following Service List in
+the manner specified by CM/ECF on this 18"* day of May, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesg@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfuly tubmine
+ROBERT D. CRÍTTON, JR., ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+(Co-Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/fa1f7826bc26fb0a8d41447246b3ad2ac8f2f54fa60425004cee3e0b1ea5d422.receipt.json b/vision-fixhub/court-01/fa1f7826bc26fb0a8d41447246b3ad2ac8f2f54fa60425004cee3e0b1ea5d422.receipt.json
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/fa4832ab07b87aaca64427e729851983cbb834d37b6d022b61683f4c706331e7.md b/vision-fixhub/court-01/fa4832ab07b87aaca64427e729851983cbb834d37b6d022b61683f4c706331e7.md
new file mode 100644
index 0000000000000000000000000000000000000000..cbaad24ff7fd836a81ab13b73157f55604574f1b
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@@ -0,0 +1,195 @@
+Case 9:09-cv-80656-KAM Document 29-1 Entered on FLSD Docket 06/08/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 94115
+Phone (415)292-7119 Fax (415) 749-2802
+www.expertchildpsuchiatry.com
+Forensic Child Psychiatric Evaluations, Life Care Plans de Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. I, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents another
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization,
+shame and retraumatization.
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintiffs do not hold their heads high with pride for having been sexually
+controlled by Mr. Epstein. They hold their heads low with shame. The internal life of a
+typical adolescent, into late adolescence and early adult years in the best of
+circumstances, usually involves generous proportions of self-consciousness, shame, selfabsorption and self-doubt and self-blame about sexual acts.
+
+
+
+Case 9:09-cv-80656-KAM Document 29-1 Entered on FLSD Docket 06/08/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted. Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+increases risks among those - as in our plaintiffs as a group - who experience clinical
+depression and self-destructive behaviors: drug use, criminal activity, even prostitution.
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:09-cv-80656-KAM Document 29-1 Entered on FLSD Docket 06/08/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a defensive means to manage overwhelming affects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+(C7) in their social, educational, vocational, relational plans. They are hypervigilant
+(Criterion D4) for further trauma, and this affects lifestyle choices and future planning.
+Hypervigilance is part of the arousal set of criteria. Public disclosure of the victims'
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+plaintiffs. Scientific literature shows that the prognostic consequences of PTSD and
+residual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abuse
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:09-cv-80656-KAM Document 29-1 Entered on FLSD Docket 06/08/2009 Page 4 of 5
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+adjustment difficulties, which include suicidality (Oquendo et al, 2005; Dube et al, CDC,
+2001; Rohde, J. Am. Acad. Child and Adolescent Psychiatry 2005). The plaintiffs will be
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:09-cv-80656-KAM Document 29-1 Entered on FLSD Docket 06/08/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely,
+Babel Kian AP
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN <
+Сомм.# 1791115
+NOTARY PUBLIC- CALIFORNIA
+ÔTY & COUNTY DI SAN FRANCISCO
+Mr CouM. Exp. FEB. 27, 2012
+State of California, City & County of San Francisco
+Subscribed and sworn to (or affirmed) before me on this
+day of neory, by Gilbert Kinceeu
+proved to me on the basis of satisfactory evidence
+5
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diff --git a/vision-fixhub/court-01/fa959825afd5fc0c2dcb46066fdc29f7db65ea7c3d4f2cc1ae2aa0de76459d29.md b/vision-fixhub/court-01/fa959825afd5fc0c2dcb46066fdc29f7db65ea7c3d4f2cc1ae2aa0de76459d29.md
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index 0000000000000000000000000000000000000000..b0b367251240b6306b1e36b3b6edfccb2e41eb57
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@@ -0,0 +1,162 @@
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related Cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092,
+PLAINTIFF JANE DOE NO. 4's RENEWED MOTION FOR PROTECTIVE
+ORDER AS TO THE SCOPE OF INQUIRY AT THE DEPOSITIONS OF
+JANE DOE NO. 4's PARENTS, AND INCORPORATED MEMORANDUM OF LAW
+Plaintiff, Jane Doe No. 4 ("Plaintiff"), by and through undersigned counsel, hereby files
+Plaintiff Jane Doe No. 4's Renewed Motion for Protective Order, pursuant to S.D.Fla.L.R. 7.1,
+and states as follows:
+By Order dated November 19, 2009 (DE 418), in Case No. 08-80380, Plaintiff
+Jane Doe No. 4's Motion for Protective Order was stricken for failure to comply with this
+Court's August 11, 2009 Notice to Counsel, and May 14, 2009, Order Consolidating Cases.
+Plaintiff's counsel inadvertently, in error, filed this Motion under Jane Doe No. 4's case number
+instead of under the consolidated case number, 08-80119. Accordingly, Plaintiff renews her
+Motion by filing under the correct case number.
+2.
+Counsel for Defendant Jeffrey Epstein have advised Plaintiffs' counsel that they
+intend to take the depositions of the mother and father of Jane Doe No. 4 within the next few
+weeks. Plaintiff does not oppose Defendant taking the depositions of her parents, but a
+1
+
+
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 2 of 6
+protective order from this Court is necessary as to the scope of the inquiry into one particular
+discrete matter.
+At Jane Doe No. 4's deposition on October 27, 2009, she testified that she has had
+abortions. She further testified that neither of her parents is aware that she has had abortions.
+At no time has she ever had any intention of disclosing the information about her abortions to her
+parents. Jane Doe No. 4 is presently 22 years old.
+4.
+Counsel for Defendant Epstein asked Jane Doe No. 4 a number of questions at her
+deposition indicating clearly that Jane Doe No. 4's abortions would be a subject of inquiry in her
+parents' depositions. This included the following inappropriate questions:
+a. "Does your mom know you aborted three kids?"
+b. "Does your dad know you aborted three kids?"
+c. "What do you think they'd think?" and
+d. "Do you think they're going to be happy about that?"!
+See Exhibit "A".
+5.
+It is obvious from the questioning at Jane Doe No. 4's deposition that
+Defendant's attorney intends to inform Jane Doe No. 4's parents about the abortions through
+leading questions at their depositions.
+6.
+Fed. R. Civ. P. 26 (c)(1) allows the court to issue an order to protect a party from
+annoyance, embarrassment, oppression, or undue burden or expense by several methods,
+including "(D) forbidding inquiry into certain matters, or limiting the scope of disclosure or
+discovery to certain matters" upon good cause shown by the moving party. "The good cause
+' Furthermore, Jane Doe No. 4's sister, Y.B., was asked about her knowledge of Jane Doe No.
+4's abortions at her deposition. Unlike Jane Doe No. 4's parents, Y.B. was already aware that
+her sister had abortions.
+2
+
+
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 3 of 6
+standard for issuing a protective order requires the Court to balance the moving party's interest
+in preventing the discovery sought against the other person's interest in seeking the discovery."
+v. Burlage, 2009 WL 2230794 at 4 (S.D. Fla. 2009) (citing Chicago Tribune Co. v.
+Bridgestone/Firestone, Inc., 263 F.3d 1304 (11th Cir. 2001).
+Plaintiffs great concern is that through leading questions Defendant's counsel will
+inform Jane Doe No. 4's parents about the abortions. Epstein has no conceivable interest in
+interrogating Jane Doe No. 4's parents about Jane Doe No. 4's abortions. Since they are
+unaware of the abortions, neither will be able to provide any information about when the
+procedures occurred, her mental state at the time of each procedure, whether any complications
+arose, or any other information that could reasonably be calculated to lead to admissible
+evidence. Epstein is not alleged to be the man responsible for impregnating Jane Doe No. 4 on
+any occasion. Counsel intends to inquire into these matters solely for the purpose of harassing,
+embarrassing, and oppressing Jane Doe No. 4. Plaintiff does not object to non-leading questions
+on this subject matter, such as "do you know whether Jane Doe No. 4 has ever had an abortion?"
+8.
+In addition, leading questions revealing Jane Doe No. 4's abortions would have
+the added effect of embarrassing, harassing, upsetting, and shaming Jane Doe No. 4's parents,
+who are non-parties to this lawsuit. The line of inquiry could lead to irreparable damage to Jane
+Doe No. 4's relationship with her Roman Catholic parents. Further, Jane Doe No. 4's parents are
+not expert witnesses and their opinion as to whether these abortions (which they do not even
+know about) affected Jane Doe No. 4 would not seem to have any relevance.
+9.
+Therefore, Jane Doe No. 4 has a great interest in preventing the discovery that
+outweighs any conceivable interest by Epstein in this discovery and a Rule 26(c)(1)(D)
+protective order is appropriate.
+3
+
+
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 4 of 6
+10. Furthermore, Jane Doe No. 4 has not authorized the release of her private medical
+information to third parties. She has not waived her privacy interests in the medical information
+such that disclosure to a nonparty would be authorized. Disclosure to her parents would
+constitute the public disclosure of private facts, a violation of Jane Doe No. 4's right of privacy,
+which she has not waived simply by virtue of being a plaintiff in a lawsuit for sexual abuse
+against a convicted sex offender.
+WHEREFORE, Plaintiff Jane Doe 4, respectfully requests that this Court issue a
+protective order prohibiting leading questions at the depositions of Jane Doe No. 4's parents on
+the subject of Jane Doe No. 4's abortions; limiting Defendant's attorney to asking only openended questions on the subject of abortion, such as whether they know if Jane Doe No. 4 has
+ever had an abortion; and all such other relief this Court deems just and appropriate.
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7.1.A.3
+Undersigned counsel has conferred with Defendant's counsel in a good faith effort to
+resolve the issues raised in this motion, and has been unable to do so, as Defendant's counsel has
+advised that Defendant opposes this motion.
+Dated: November 19, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Altorneys for Plaintiffs Jane Does 2-8
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+4
+
+
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 5 of 6
+CERTIFICATE OF SERVICE
+I hereby certify that on November 19, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Adam D. Horowitz
+5
+
+
+Case 9:08-cv-80119-KAM Document 420 Entered on FLSD Docket 11/19/2009 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+igoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike @bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Adam D. Horowitz
+6
diff --git a/vision-fixhub/court-01/fa959825afd5fc0c2dcb46066fdc29f7db65ea7c3d4f2cc1ae2aa0de76459d29.receipt.json b/vision-fixhub/court-01/fa959825afd5fc0c2dcb46066fdc29f7db65ea7c3d4f2cc1ae2aa0de76459d29.receipt.json
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diff --git a/vision-fixhub/court-01/fa9cd67d168aa13b8a17e23f7457b7d4c5ce23a1c8111552f68b831d73e0faf3.md b/vision-fixhub/court-01/fa9cd67d168aa13b8a17e23f7457b7d4c5ce23a1c8111552f68b831d73e0faf3.md
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@@ -0,0 +1,53 @@
+Case 9:08-cv-80380-KAM Document 82-1 Entered on FLSD Docket 04/13/2009 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+CASE NO.: 08-CV-80119-MARRA
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:08-cv-80380-KAM Document 82-1 Entered on FLSD Docket 04/13/2009 Page 2 of 2
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- 80993-CIV-MARRA/
+ORDER
+Upon Plaintiffs' Unopposed Motion for Enlargement of Time to File Memorandum in
+Opposition to Motion to Stay and/or Continue Action, and good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+ten (10) days, until April 23, 2009, to file a reply memorandum in opposition to the Defendant's
+Motion to Stay and/or Continue Action.
+DONE AND ORDERED in
+in Ft. Lauderdale, Broward County, Florida, this
+day of
+_ 2009.
+DISTRICT COURT JUDGE
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diff --git a/vision-fixhub/court-01/fab2b36ca736e4a490db53396c5b3b8f7137aeb2595007ea721fcbbea123752f.md b/vision-fixhub/court-01/fab2b36ca736e4a490db53396c5b3b8f7137aeb2595007ea721fcbbea123752f.md
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@@ -0,0 +1,69 @@
+Case 1:19-cv-10577-LJL-DCF Document 20 Filed 01/10/20 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff.
+Case No. 1:19-cv-10577-LGS-KNF
+DARREN K. INDYKE and RICHARD D. KAHN,
+in their capacities as the executors of the
+ESTATE OF JEFFREY EDWARD EPSTEIN,
+Defendants.
+ORDER ON PLAINTIFF'S ANONYMITY
+IT IS HEREBY ORDERED that any person subject to this Order, including the parties to
+this action and their respective counsel of record, shall adhere to the following terms:
+1. Within three (3) days of entry of this Order, Counsel of Record for Plaintiff shall disclose
+Plaintiff's identity to Counsel of Record for Defendants, in writing.
+2. Counsel of Record for Defendants may disclose Plaintiff's identity only to Defendants and
+any attorneys, paralegals, and clerical or other assistants working with or for Defendants
+on matters related to this action; and the recipients of such information shall not disclose it
+to any other persons.
+3. If Defendants wish to disclose Plaintiff's identity to any person not otherwise permitted to
+receive such information under this Order, Defendants are limited to doing so in connection
+with defending this action, and must require such person to first execute a non-disclosure
+agreement, in a form agreed to by the parties, that prevents such person from disclosing
+Plaintiff' s identity to any other persons. Defendants must maintain a list of all such persons
+to whom Plaintiff's identity is disclosed and copies of the executed non-disclosure
+agreements, all of which are subject to in camera inspection.
+4. All portions of pleadings, motions or other papers filed with the Court that disclose
+Plaintiff's identity shall be filed under seal with the Clerk of the Court and kept under seal
+until further order of the Court. The parties shall use their best efforts to minimize such
+sealing. Any party filing a motion or any other papers with the Court under seal shall also
+publicly file a redacted copy of the same, via the Court's Electronic Case Filing system,
+that redacts the Plaintiff's identity and text that would reveal Plaintiff's identity.
+5. The parties may seek to modify or amend this Order at any time upon motion to the Court
+or by stipulation.
+40962213vl
+
+
+Case 1:19-cv-10577-LJL-DCF Document 20 Filed 01/10/20 Page 2 of 3
+SO ORDERED.
+Date:
+New York, New York
+Hon. Debra C. Freeman
+United States Magistrate Judge
+Southern District of New York
+40962213vl
+2
+
+
+Case 1:19-CV-10577-LJL-DCF Document 20 Filed 01/10/20 Page 3 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+JANE DOE 1000,
+Plaintiff.
+V.
+Case No. 1:19-cv-10577-LGS-KNF
+DARREN K. INDYKE and RICHARD D. KAHN,
+n their capacities as the executors of th
+'STATE OF JEFFREY EDWARD EPSTEIN
+Defendants.
+NON-DISCLOSURE AGREEMENT
+, acknowledge that I understand that the identity of the
+Plaintiff in this action is confidential. I agree that: (1) I will hold in confidence Plaintiff's identity;
+(2) I will use Plaintiff's identity only in connection with this litigation; and (3) I will take all due
+precautions to prevent the unauthorized or inadvertent disclosure of Plaintiff's identity.
+By acknowledging these obligations under this Non-Disclosure Agreement, I understand
+contempt of court.
+Dated:
+[Signature]
+40962236vl
diff --git a/vision-fixhub/court-01/fab2b36ca736e4a490db53396c5b3b8f7137aeb2595007ea721fcbbea123752f.receipt.json b/vision-fixhub/court-01/fab2b36ca736e4a490db53396c5b3b8f7137aeb2595007ea721fcbbea123752f.receipt.json
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diff --git a/vision-fixhub/court-01/fadbd8dd8407d1036cad2411aa692b54d519a6c540619b95df0b7bd9a9542609.md b/vision-fixhub/court-01/fadbd8dd8407d1036cad2411aa692b54d519a6c540619b95df0b7bd9a9542609.md
new file mode 100644
index 0000000000000000000000000000000000000000..79e1a9aee5c0fa4919ed5720e9362878acb690ae
--- /dev/null
+++ b/vision-fixhub/court-01/fadbd8dd8407d1036cad2411aa692b54d519a6c540619b95df0b7bd9a9542609.md
@@ -0,0 +1,76 @@
+Case 1:19-cv-08673-KPF-DCF Document 20 Filed 11/05/19 Page 1 of 2
+Troutman Sanders LLP
+875 Third Avenue
+New York, New York 10022
+troutman™
+sanders
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+November 5, 2019
+ECF
+Hon. Katherine Polk Failla
+Thurgood Marshall
+United States Courthouse
+40 Foley Square
+New York, NY 10007
+Re:
+Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as the
+Executors of the Estate of Jeffrey E. Epstein, 1:19-cv-08673-KPF
+Dear Judge Failla:
+We represent Darren K. Indyke and Richard D. Kahn, Co-Executors of the Estate of Jeffrey E.
+Epstein (together, "Defendants"), in the referenced action. In accordance with Your Honor's
+Individual Rules of Practice in Civil Cases § 2(c) (providing 3 business days for parties to
+respond to letter motions), we write in response to Plaintiff's counsel's October 31, 2019 letter
+motion (ECF # 14) which they submitted without first meeting and conferring with us as we
+requested. Plaintiff's counsel: (i) requests an unnecessary court conference to discuss "risks of
+spoliation" based on a U.K. tabloid article that we already advised Plaintiff's counsel is, to the
+extent it suggests spoliation has occurred, false; and (ii) misstates Defendants' position on
+Plaintiff's Motion to Proceed Under Pseudonym (ECF# 3) and even though Plaintiff agreed, and
+the Court So Ordered, Defendants have until November 15, 2019 to respond to the Motion (See
+ECF# 10).
+On October 22, 2019, Plaintiff's counsel, Roberta Kaplan, citing a U.K. tabloid article implying
+one of the Co-Executors improperly removed materials in a bag from the decedent's property in
+Manhattan, asked us to confirm the tabloid's accuracy. An attorney for the Co-Executor
+promptly called Ms. Kaplan and explained to her that the tabloid article, to the extent it
+suggested spoliation, was wrong. The Co-Executor's attorney also specifically explained to Ms.
+Kaplan that the subject bag did not contain documents or any other materials relevant to this
+case. In fact, the Co-Executor referenced in the tabloid article was carrying a bag of decedent's
+clothing for purposes of laying decedent to rest.
+We have also advised Ms. Kaplan on multiple occasions, including in writing, that the Co-
+Executors are abiding by their discovery obligations. However, after we addressed the tabloid
+article and further confirmed Defendants' adherence to their discovery obligations, Ms. Kaplan
+
+
+Case 1:19-cv-08673-KPF-DCF Document 20 Filed 11/05/19 Page 2 of 2
+November 5, 2019
+Page 2
+troutman"
+sanders
+then demanded we confirm Defendants are preserving various categories of documents that
+Ms. Kaplan labeled "topics." Many of the so-called topics are argumentative, assume facts that
+have not been proven and implicate information protected by the attorney-client privilege and
+attorney work product doctrine. Ms. Kaplan failed to cite to us or the Court any legal authority
+supporting her demands, and we are not aware of any such authority.
+Despite being at an arbitration hearing in Southfield, Michigan (which Ms. Kaplan was aware of)
+and despite Ms. Kaplan's failure to cite any legal bases for her premature demands, we asked
+Ms. Kaplan to meet and confer with us by phone if she still insisted on seeking Court
+intervention regarding these issues, so we could better understand the basis of her position.
+Instead, Plaintiff's counsel submitted their Letter Motion to the Court last Thursday.
+Given Defendants' confirmation that they are abiding by their preservation obligations, and in
+light of Ms. Kaplan's failure to provide any support (beyond an erroneous tabloid article) for her
+speculative allegations of spoliation, we respectfully submit it is premature to address any
+discovery issues at this very early stage of this case-Defendants have until November 15,
+2019 to respond to Plaintiff's Complaint and the Initial pre-trial conference is scheduled for
+December 13, 2019.
+Finally, Ms. Kaplan incorrectly asserts that Defendants object to Plaintiff's Motion to Proceed
+Under Pseudonym. To the contrary, and as we will further explain in Defendants' response brief
+due per the Court's Order on November 15, 2019, Defendants have no objection to Plaintiff's
+desire to prevent the public from discovering her identity. We never suggested otherwise to Ms.
+Kaplan. Defendants do intend to brief their position on anonymity so they are not, subject to
+measures preventing such public disclosure, deprived of a fair opportunity to defend against
+Plaintiff's claims.
+Respectfully submitted,
+s/Bennet J. Moskowitz
+Bennet J. Moskowitz
+40508371v2
diff --git a/vision-fixhub/court-01/fadbd8dd8407d1036cad2411aa692b54d519a6c540619b95df0b7bd9a9542609.receipt.json b/vision-fixhub/court-01/fadbd8dd8407d1036cad2411aa692b54d519a6c540619b95df0b7bd9a9542609.receipt.json
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diff --git a/vision-fixhub/court-01/fb2f91e9d8702c59f99c8cc966fbaf5df7624911713d87276d1a004c1fa1f01b.md b/vision-fixhub/court-01/fb2f91e9d8702c59f99c8cc966fbaf5df7624911713d87276d1a004c1fa1f01b.md
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@@ -0,0 +1,56 @@
+Case 1:20-cv-00484-JGK-DCF Document 22 Filed 02/11/20
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+USDO SONY
+DOCUMENT
+- X
+ELECTRONICALLY FILED
+JANE DOE,
+DOC#
+DATE FILED: 2.11•20
+Plaintiff,
+20-cv-0484 (JGK)
+- against -
+DARREN INDYKE, ET AL.,
+ORDER OF REFERENCE
+TO A MAGISTRATE JUDGE
+Defendants.
+JOHN G. KOELTL, District Judge:
+The above entitled action is referred to the designated Magistrate Judge for the following
+purposes):
+_x_
+General Pretrial (includes scheduling,
+discovery, non-dispositive pretrial motions,
+and settlement)
+-
+-
+Specific Non-Dispositive
+Motion/Dispute:*
+If referral is for discovery disputes when
+the District Judge is unavailable, the time
+period of the referral is:
+-
+Settlement*
+-
+Inquest After Default/Damages Hearing
+-
+SO ORDERED.
+DATED:
+New York, New York
+February 10, 2020
+Consent under 28 U.S.C. §636(c) for all
+purposes (including trial)
+Consent under 28 U.S.C.§636(c) for
+pirie nay ise ci, dispositive motion,
+Purpose:
+Habeas Corpus
+Social Security
+Dispositive Motion (i.e., motion requiring
+a Report and Recommendation)
+Particular Motion:
+All such motions:
+Sr6/6e9
+John G. Koeltl
+United States District Judge
+* Do not check if already referred for general pretrial.
diff --git a/vision-fixhub/court-01/fb2f91e9d8702c59f99c8cc966fbaf5df7624911713d87276d1a004c1fa1f01b.receipt.json b/vision-fixhub/court-01/fb2f91e9d8702c59f99c8cc966fbaf5df7624911713d87276d1a004c1fa1f01b.receipt.json
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+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "960961f21b5f6a3423dcdc3d2b81bf05b9f6ad7e94a5be8e855d625125efe76e",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fb322d15c9b90239a2cc1006c113e94b32b4708b1e983e92eae51b695a7c5387.md b/vision-fixhub/court-01/fb322d15c9b90239a2cc1006c113e94b32b4708b1e983e92eae51b695a7c5387.md
new file mode 100644
index 0000000000000000000000000000000000000000..2d90819033ed80354f66072c73b2330c0426e563
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@@ -0,0 +1,227 @@
+Case 9:08-cv-80119-KAM Document 319-6 Entered on FLSD Docket 09/22/2009 Page 1 of 8
+Entered on FLSD BUckEt 83705/2009
+
+Jane Doe #7
+v.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W. M.D.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+C.W. Hall, M.D., who, being by me first duly sworn under oath deposes and says:
+1. My name is Richard C.W.|
+M.D. Iam over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+since 1996.
+I have maintained a private practice in psychiatry and forensic psychiatry
+3.
+I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+I received my undergraduate degree from the Johns
+University and
+
+
+Case 9:08-cv-80119-KAM Document 319-6 Entered on FLSD Docket 09/22/2009 Page 2 of 8
+Aug Case 9585cv-801RBHNN. HEbolinent 247-8 Entered on FLSD 58ZRZ7 88985/2009 Page 2 of 8
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+5.
+I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7. I am a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+8.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Froedtert Hospitals.
+• 9.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate | at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #7 against Jeffrey Epstein makes
+2
+
+
+Case 9:08-cv-80119-KAM Document 319-6 Entered on FLSD Docket 09/22/2009 Page 3 of 8
+Aug Ose 0508cv-80 RAM. HaDoMAment 247-8
+Entered on FLSD 672Rt 88885/2009 Påge 3 of 8
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #7 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. Itis further alleged that she suffered, and will
+continue to
+suffer, severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12. She further alleges that she has suffered personal injury including mental,
+psychological and emotional damage.
+13.
+Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventive Psychiatry Associates Medical
+Group, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director.
+14.
+While all pertinent medical history has been withheld, on October 4, 2005,
+Plaintiff did provide a statement to the police, which directly conflicts with the allegations
+in her complaint. Medical records would assist with the veracity (or lack thereof) of her
+statements and the allegations in the complaint. Plaintiff told the police on October 4, 2005
+that she was introduced to Epstein by
+@when she was approximately 17.
+(Police Statement, page 1) &
+y allegedly told her that the first time you go it's
+3
+
+
+Case 9:08-CV-80119-KAM Document 319-6 Entered on FLSD Docket 09/22/2009 Page 4 of 8
+Aug Case BE084CV-8017 SANA. HoBliment 247-8 Entered on FLSD 68ck2t8805/2009 Påge 4 of 8
+just like a massage and she said "well, like, well the more you go supposedly, the more
+like, he expects, and like flirting with girls and that's what kind of scared her." (Police
+Statement, page 2) She also states that the second time she went to Epstein's, she gave him
+a massage and that she had her clothes on. (Police Report, pages 2 & 4) Plaintiff claims she
+thought Epstein might be leaning towards wanting her to take her clothes off, or touching
+her but Epstein never did because she was so shy. (Police Statement, pages 2 & 3) She also
+told police that when she massaged Epstein, he was not naked (Police Statement, page 3),
+he never removed his towel (Police Statement, page 3), she did not take her clothes off
+(Police Statement, page 4), Epstein did not touch her inappropriately (Police Statement,
+page 3), he did not masturbate (Police Statement, page 5), and they did not touch each
+other's private areas (Police Statement, page 3). Further, she claims in the report not to
+have returned to Epstein's home after the second visit. (Police Report, page 3)
+15.
+Her allegations in the complaint are in complete opposite when compared to
+the police report. For instance, the complaint alleges: (a) during the first massage, Epstein
+sexually assaulted her and masturbated (Complaint, Paragraph 13); and (b) Plaintiff
+returned on many occasions to the Palm Beach mansion to provide Epstein with massages
+for money. On those occasions, Epstein engaged in sexual contact and activity with
+Plaintiff, which included, among other things, Epstein touching Jane's breasts, placing a
+vibrator on her vagina and masturbating himself. This sexual abuse continued over a
+
+
+Case 9:08-cv-80119-KAM Document 319-6 Entered on FLSD Docket 09/22/2009 Page 5 of 8
+Aug Case 95387v-801RigbRANg. HedoMment 247-8 Entered on FLSD B82R8t88705/2009 Page 5 of8
+period of approximately 18 to 24 months (Complaint, Paragraph 14). In stark contrast to
+the statement she gave to the police, she now claims in her answers to interrogatories that
+she went to Epstein's home between 8-10 times (Interrogatory, #15) and that she brought
+friends on two separate occasions and was paid $200 per friend (Interrogatory, #17). In
+fact, she denies in her answers to interrogatories that she even provided a recorded
+statement to the police (Interrogatory, #22). In addition, on Tape 2, pages 11, 12 &20, she
+claims that Epstein was aggressive, grabbed her butt, tried to feel parts of her, masturbated
+under the towel and pulled her bra and exposed her nipples and touched her breasts,
+which is totally inconsistent with her statement to the police.
+16.
+For further elaboration of Jane Doe #7's history and background, access to all
+available records is crucial if one is to fully understand the impact of any of these events on
+her subsequent behavior and proportion the impact of specific events, if any, or her current
+and future level of function.
+17. In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical clinical, school, and work records known to the attorney
+5
+
+
+Case 9:08-cv-80119-KAM Document 319-6
+Aug Case 9508 ev-801RighRAN. Helocument 247-8
+Entered on FLSD D0Cke20962/2009 Page,6 of 8
+Entered on FLSD Bocket 08/05/2009 Page 6 of 8
+in the case.
+18.
+Dr. Kliman notes on page 8 of his contract opinion formation that he will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning
+which our input is requested." We request the same.
+19. It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+type and character of the alleged assault, and key victim variables such as demographics,
+psychological reactions at the time of the trauma, previous psychiatric or psychological
+history, previous victimization history, current or previous psychological difficulties, and
+general personality dynamics and coping style, as well as sociocultural factors such as drug
+use/abuse; poverty; social inequity and/or inadequate social support; any previous history
+of abuse within or outside the family; whether individuals were abused by strangers,
+acquaintances or family members; and whether there was any history of indiscriminate
+6
+
+
+Case 9:08-cv-80119-KAM Document 319-6
+Entered on FLSD Docket 09/22/2009 Page of 8
+Aus Cast 9.587ev-801RghRANf. HelbAPnent 247-8
+Entered on FLSD Docket 83985/2009 Page 7 of 8
+behavior that may have placed them at increased risk. It is important to know if there had
+been previous sexual conduct, contact with police or welfare agencies, alcohol or drug
+use/abuse, voluntary sexual activity, contraceptive use, genital infections, or apparent
+indifference to previous abuse.
+20.
+It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+21.
+Knowledge of plaintif's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+22.
+It is, therefore, crucial that the independent medical examiner has available to
+him a full and complete record that includes medical, previous legal, social, criminal,
+academic, psychological and psychiatricrecords/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same and similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+7
+
+
+Aug
+Richard C.
+Pacument 319-6
+Case 9:08-cv-80119-KAM
+Document 247-8
+Entered on FLSD Docket 09/22/2009 Page 8 of 8
+Entered on FLSD Docket 08/05/2009 Page 8 of 8
+and conduct. We would concur and request of the court that the same and such other
+similar information be made available to us to conduct our examination.
+Respectfully submitted,
+Rate i a fall me
+Courtesy Clinical Professor of Psychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+College of Medicine
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+BEFORE ME, the undersigned authority, personally appeared RICHARD CW.
+M.D., who is (V) personally known to me or () who has produced
+_. as identification, and who did take an oath, deposes and says that
+the attached Affidavit is true and correct to the best of his knowledge and belief.
+SWORN TO AND SUBSCRIBED before me on this 4tR day of Augunt
+2009.
+MARCIA. CHAPMAN"
+Comme DD0561004
+5E3:
+Erpites 6/6/2010
+Narcia i Upon
+Notary Public
+Printed Name: MArcis J CHAPMAN
+My Commission Expires:
+8
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new file mode 100644
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@@ -0,0 +1,668 @@
+Filing # 114957423 E-Filed 10/14/2020 01:14:03 PM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of the PALM BEACH POST,
+Plaintiff,
+v.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+/
+DEFENDANT, DAVE ARONBERG'S RESPONSE TO PLAINTIER'S
+MEMORANDUM OF LAW IN OPPOSITION TO THE STATE ATTORNEY'S
+FLA. STAT. SECTION 57.105 MOTION
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned counsel, hereby files this Response to Plaintiff's Memorandum of Law in
+Opposition to the State Attorney's Fla. Stat. Section 57.105 Motion, and in support thereof states:
+REGARDLESS OF PLAINTIFF'S PURPOSE IN BRINGING THE INSTANT
+LAWSUIT, IT IS IMPOSSIBLE FOR THE STATE ATTORNEY TO PRODUCE
+THE RECORDS THAT PLAINTIFF DEMANDS BE PRODUCED.
+From the outset of this litigation the State Attorney has consistently maintained that neither
+he nor his office has possession, custody or control of the Epstein grand jury materials,
+("Requested Materials"), sought by Plaintiff. Nonetheless, the State Attorney has no objection,
+and never has had any objection, to the Clerk releasing the records sought by Plaintiff, as disclosure
+of the Requested Materials sought herein lies solely within the providence of the Clerk pursuant
+to an order of the Court.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 10/14/2020 01:14:03 PM
+
+
+Section 905.17(1), Florida Statutes makes clear that Plaintiff's Requested Materials can
+only be released by the Clerk pursuant to a court order.
+The stenographic records, notes, and transcriptions made by the court reporter or
+stenographer shall be filed with the clerk who shall keep them in a sealed container
+not subject to public inspection. The notes, records, and transcriptions are
+confidential and exempt from the provisions of s. 119.0Z(1) and s. 24(a), Art. I of
+the State Constitution and shall be released by the clerk only on request by a grand
+jury for use by the grand jury or on order of the court pursuant to s. 905.27.
+Section 905.17(1), Florida Statutes (2020).
+Text, context, and purpose are the ordinary tools used for discerning statutory meaning,
+with the overarching principle being that "judges lack the power to construe an unambiguous
+statute in a way which would extend, modify, or limit its express terms or its reasonable and
+obvious implications. To do so would be an abrogation of legislative power." Id. Accordingly,
+here, the plain language of section 905.17 is clear and unambiguous and, therefore, controls. See,
+Horowitz v. Plantation Gen. Hosp. Ltd. P'ship, 959 So. 2d 176, 182 (Fla. 2007).
+Again, the State Attorney has no objection to the Clerk producing and disclosing the
+Requested Materials should the Court grant an order to that effect. To be clear, however, it is
+impossible for State Attorney to comply with the relief sought by Plaintiff in its remaining claim
+for declaratory relief as he does not possess or control the Requested Materials and is statutorily
+barred from any disclosure.
+Il.
+THE STATE ATTORNEY'S FLA. STAT. SECTION 57.105 MOTION WAS
+PROPERLY MADE AND IN NO WAY SEEKS TO DETER THE PALM BEACH
+POST FROM SERVING THE PUBLIC INTEREST.
+To be clear, the State Attorney has no other desire than to litigate on the merits the instant
+lawsuit's remaining issue of declaratory relief prior to a determination of his Fla. Stat. § 57.105
+2
+
+
+Motion for Attorneys' Fees ("57.105 Motion"). ' Furthermore, despite Plaintiff's disingenuous and
+self-aggrandizing contentions, in no way, shape, manner, or form is the State Attorney using the
+threat of sanctions to "suppress The Palm Beach Post's investigative reporting" or to "avoid
+litigating the case on the merits" or to "deter media inquiry into the Epstein grand jury proceeding."
+See, PI. Memorandum pg. 2-3.
+Rather, the State Attorney was properly and entirely within his rights to send his June 8,
+2020, Fla. Stat. § 57.105 Demand Letter and inform Plaintiff of his belief that the Amended
+Complaint and its sole remaining count for declaratory relief has no basis in fact or law. See,
+Exhibit "A". "Under the statute, the legislature has expressed its unequivocal intent that where a
+party files a meritless claim, suit or appeal, the party who is wrongfully required to expend funds
+for attorneys' fees is entitled to recoup those fees? Martin County Conservation Alliance v.
+County, 73 So. 3d 856, 857 (Fla. Ist DEA 2011) (finding that "Courts are not at liberty to
+disregard the legislative mandate that courts shall impose sanctions in cases without foundation in
+material fact or law. The word "shall" in § 57.105, Fla. Stat., evidences the legislative intent to
+impose a mandatory penalty to discourage baseless claims, by placing a price tag on losing parties
+who engage in these activities. Section 57.105 expressly states courts "shall" assess attorney's fees
+for bringing, or failing to dismiss, baseless claims or defenses."). In fact,
+Section 57.105(1) clearly and explicitly confers upon the trial court the authority to
+award attorney's fees to the prevailing party upon the court's initiative, if 'the court
+finds that the losing party .... knew or should have known that a claim or defense
+when initially presented to the court or at any time before trial ... [wlas no
+supported by the material facts necessary to establish the claim or defense
+' This Court's June 8, 2020, Order Granting Defendants' Motions to Dismiss Count II of Plaintiff's First Amended
+Complaint with Prejudice ("Order") did not address Plaintiff's Count I for Declaratory Relief. Notably, the State
+Attorney's § 57.105 Demand Letter and its accompanying proposed Motion for Attorney's Fees was served on
+Plaintiff later in the day of June 8, 2020, after the Court issued its Order.
+3
+
+
+47 So. 3d 320, 324 (Fla. 2d DCA 2010).
+Notably, "IsJection 57.105 does not require a finding of frivolousness to justify sanctions,
+but only a finding that the claim lacked a basis in fact or law."
+County Conservation
+Alliance v.
+County, 73 So. 3d 856, 865 (Fla. Ist DCA 2011). Moreover,
+The primary purpose of section 57.105(4) is not to spring a procedural trap on the
+unwary so that valid claims are lost. Rather, its function is to give a pleader a last
+clear chance to withdraw a frivolous claim or defense within the scope of
+subsection (1) or to reconsider a tactic taken primarily for the purpose of
+unreasonable delay under subsection (3). Having the parties police themselves,
+instead of requiring judicial intervention on section 57.105 issues, promotes
+judicial economy and minimizes litigation costs.
+Vanderpol v. Frengut, 932 So. 2d 1251 (Fla. 4th DCA 2006) (finding that because the plaintiff had
+withdrawn his motion, the defendants were not permitted to file with or present to the trial court
+their motion for attorney's fees).
+Thus, in properly serving his 57.105 demand on Plaintiff, the State Attorney also properly
+put Plaintiff on notice that he would seek sanctions by filing the 57.105 Motion for Attorneys' fees
+if Plaintiff failed to dismiss its Amended Complaint within 21 days of service of the 57.105
+demand letter and motion for attorneys' fees. The course of action taken by the State Attorney
+actually tracks the specific language set forth in the Statute, to wit:
+A motion by a party seeking sanctions under this section must be served but may
+not be filed with or presented to the court unless, within 21 days after service of
+the motion, the challenged paper, claim, defense, contention, allegation, or denial
+is not withdrawn or appropriately corrected.
+Section 57.105(4), Florida Statutes (2020).
+Accordingly, after receiving Plaintiff's June 23, 2020, response refusing to the withdraw
+the remainder of the Amended Complaint and waiting the prerequisite "21 days after service of
+the motion" the State Attorney's Motion for Attorneys' Fees was filed with this Court on July 1,
+2020. See, Exhibit B. Nothing improper was done by the State Attorney in availing himself of the
+4
+
+
+law set forth in § 57.105 given the circumstances of the instant lawsuit and the State Attorney's
+intention to establish that Plaintiff's claim for declaratory relief has no basis in fact or law.
+Here, regardless of Plaintiff's assertions that the State Attorney is "using the threat of
+sanctions to avoid litigating the case on its merits," the simple fact of the matter is that Plaintiff
+failed to withdraw its Amended Complaint against the State Attorney within the 21-day period
+provided for in section 57.105(4), thus the State Attorney was permitted to file his 57.105 Motion
+for Attorneys' Fees as sanctions. Again, the filing of the 57.105 Motion for Attorney's fees was
+filed as a matter of course and a place-marker to further notify Plaintiff of the State Attorney's
+intention to seek sanctions should he prevail on the merits at a future substantive hearing.
+Ill.
+REGARDLESS OF THE "JUSTICE" PROVISION OF FLA. STAT. SECTION
+905.27, FLA. STAT. SECTION 905.17(1) MAKES CLEAR THAT ONLY THE
+CLERK SHALL RELEASE GRAND JURY RECORDS LIKE THOSE SOUGHT
+HEREIN.
+Despite Plaintiff's assertion, the State Attorney has never taken the position that this
+Court's June 8, 2020, Order held that Plaintiff's claims are without any merit. Rather, the State
+Attorney has consistently taken the position that the Order merely dispenses, with prejudice,
+Plaintiff's Count II and that any other discussion pertaining to that claim is immaterial and
+irrelevant to the remaining claim for declaratory relief.?
+Again, Section 905.17(1), Florida Statutes makes clear that Plaintiff's Requested Materials
+can only be released by the Clerk pursuant to a court order. To wit:
+The, stenographic records, notes, and transcriptions made by the court reporter or
+stenographer shall be filed with the clerk who shall keep them in a sealed container
+not subject to public inspection. The notes, records, and transcriptions are
+confidential and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. I of
+the State Constitution and shall be released by the clerk only on request by a grand
+jury for use by the grand jury or on order of the court pursuant to s. 905.27.
+2 Specifically, Plaintiff's remaining Count I for Declaratory Relief seeks a court order declaring that the State Attorney
+provide copies of the Requested Materials to The Palm Beach Post for the purpose of informing the public. See, PI's
+Amended Complaint pg. 20-21.
+5
+
+
+Section 905.17(1), Florida Statutes (2020).
+As stated previously, neither the State Attorney nor his office has possession, custody or
+control of the Requested Materials. Likewise, the State Attorney has no objection, and never has
+had any objection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the
+Requested Materials sought by Plaintiff lies solely within the providence of the Clerk pursuant to
+an order of the Court.
+Thus, based on the impossible nature of Plaintiff's demand of the State Attorney, it was
+proper to demand withdrawal of Plaintiff's remaining claim for declaratory relief and serve the
+57.105 Motion for Attorneys' Fees due to Plaintiff's claim lacking any basis in fact or law.
+Regardless of whether the "justice" provision of § 905.27 has been adjudicated, Plaintiff's Count
+II was dismissed with prejudice and its remaining Count I for declaratory relief has no basis in fact
+or law because the State Attorney does not have the Requested Materials and § 905.17(1), Florida
+Statutes explicitly requires that only the Clerk shall release grand jury materials like the Requested
+Materials and only pursuant to a court order.
+IV.
+THE STATE ATTORNEY'S FLA. STAT. SECTION 57.105 MOTION IS
+RELATED ONLY TO PLAINTIFF'S CLAIM FOR DECLARATORY RELIEF AS
+THIS COURT DISMISSED WITH PREJUDICE COUNT II, REGARDLESS OF
+ANY NOVELTY OR COMPLEXITY.
+Although this Court unambiguously dismissed with prejudice Count II of the Amended
+Complaint, Plaintiff oddly acts as though Count Il is alive and able to be further argued before this
+Court. Additionally, Plaintiff either disingenuously or unawaredly argues that the fees sought
+herein "should not be awarded unless there is *a total or absolute lack of a justiciable issue, which
+is tantamount to a finding that the action is frivolous... and so clearly devoid of merit both on the
+facts and law as to be completely untenable.' Muckenfuss v. Deltona Corp., 508 So. 2d 340, 341
+(Fla. 1987)." Rather than the old standard cited by Plaintiff, the amended version of Fla. Stat. §
+
+
+57.105 "does not require a finding of frivolousness to justify sanctions, but only a finding that the
+claim lacked a basis in material facts or then-existing law."
+County Conservation Alliance
+County, 73 So. 3d 856, 858 (Fla. Ist DCA 2011). See, Long v. AvMed, Inc., 14 So. 3d
+1264, 1265 (Fla. Ist DCA 2009) (noting section 57.105 does not require a party to show complete
+absence of a justiciable issue of fact or law).
+The court in
+v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019), provides further
+insight and guidance regarding 57.105 sanctions as it explained:
+The central purpose of § 57.105, Fla. Stat., is, and always has been, to deter
+meritless filings and thus streamline the administration and procedure of the courts.
+Thus, the post-1999 version of § 57.105 has expanded the circumstances where fees
+should be awarded and the purpose is to deter meritless filings. [The Florida
+Supreme Court] has also stated that § 57.105 creates an opportunity to avoid the
+sanction of attorney's fees by creating a safe period for withdrawal or amendment
+of meritless allegations and claims. Therefore, it appears that [The Florida Supreme
+Court] has viewed even individual allegations as part of what § 57.105(1) seeks to
+deter. By "individual allegations," we are referring to a series of allegations framing
+a theory of liability based on a factual scenario that is not supported by law.
+v. Bailynson, 268 So. 3d 762, 769 (Fla, 4th DCA 2019). Taking this into account further
+detracts from the plausibility of Plaintiff's position, even despite its argument that the issues
+contained in Count II were "novel and complex." Despite Plaintiff's argument that "[w]here an
+issue is novel and complex, sanctions under section 57.105 may not be imposed" and that even
+though Count II was dismissed with prejudice it was brought in good faith, these arguments do not
+rise to such a level as to overcome the reality that Plaintiff's Count I for declaratory relief has no
+basis in fact or law because it is impossible for the State Attorney to comply with its demand.
+Further, the Bailynson court provides guidance here as well by explaining that the State
+Attorney's 57.105 claim does not have to apply to Plaintiff's entire action to succeed:
+Unlike the prior version [of section 57.105], the current version of the statute does
+ot apply only to an entire action, but now applies to any claim or defense
+emphasis added). Because the statute refers to "any claim or defense." it does no
+7
+
+
+require that the entire action be unsupported by material facts or the application of
+then-existing case law.
+|v. Bailynson, 268 So. 3d 762, 769 (Fla. 4th DCA 2019). Thus, "the revised statute expanded
+the number of circumstances in which fees should be awarded" and "if an action asserts a theory
+of liability using more than one, but separate, factual scenarios in support of the theory, and one
+of the factual scenarios meets the criteria for a 57.105(I) fee sanction because it is not supported
+by law, the sanction must be ordered." Id.
+Thus, notwithstanding any of Plaintiff's assertions regarding Count II, Count II not only
+was dismissed with prejudice, but the issues pertaining to it are irrelevant as to the State Attorney's
+57.105 Motion regarding the lack of any basis in fact or law as to Plaintiff's remaining request for
+declaratory relief.
+V.
+REGARDLESS OF PLAINTIFF'S CONSTITUTIONAL ARGUMENTS, ONLY
+THE CLERK, NOT THE STATE ATTORNEY, IS STATUTORILY AUTHORIZED
+TO RELEASE THE GRAND JURY RECORDS SOUGHT HEREIN.
+To be clear, in no way does the State Attorney assume, as Plaintiff suggests, that this
+Court's Order extinguishes and renders frivolous Plaintif's Count I for Declaratory Relief.
+Rather, as the State Attorney's 57.105 demand letter clearly states, Plaintiff's claim for declaratory
+relief has no basis in fact or law.
+Moreover, regardless of Plaintiff's continual attempts to revive and make arguments under
+its Count IT, it was dismissed with prejudice and Plaintiff is consequently foreclosed from litigating
+the issues therein. Thus, despite any constitutional or other argument under Count II, the facts and
+law remain the same: only the Clerk, not the State Attorney, is statutorily authorized to release
+the Requested Materials herein.
+Again, Section 905.17(1), Florida Statutes makes clear that Plaintiff's Requested Materials
+can only be released by the Clerk pursuant to a court order.
+8
+
+
+The stenographic records, notes, and transcriptions made by the court reporter or
+stenographer shall be filed with the clerk who shall keep them in a sealed container
+not subject to public inspection. The notes, records, and transcriptions are
+confidential and exempt from the provisions of s. 119.07(1) and s. 24(a), Art. I of
+the State Constitution and shall be released by the clerk only on request by a grand
+jury for use by the grand jury or on order of the court pursuant to s. 905.27.
+Section 905.17(1), Florida Statutes (2020).
+Likewise, it bears repeating, neither the State Attorney nor his office has possession,
+custody or control of the Requested Materials; and, the State Attorney has no objection, and never
+has had any objection, to the Clerk releasing the records sought by Plaintiff, as disclosure of the
+Requested Materials sought by Plaintiff lies solely within the providence of the Clerk pursuant to
+an order of the Court. Thus, based on the impossible nature of Plaintiff's lawsuit against the State
+Attorney, it was proper to demand withdrawal of Plaintiff's remaining claim for declaratory relief
+and serve the 57.105 Motion for Attorneys' fees due to Plaintiff's claim lacking any basis in fact
+or law.
+VI. THE STATE ATTORNEY HAS NEVER TAKEN A POSITION AGAINST
+DISCLOSING THE RECORDS SOUGHT BY PLAINTIFF, BUT RATHER HAS
+CONSISTENTLY ARGUED THAT NEITHER HE NOR HIS OFFICE HAS
+CUSTODY, CONTROL, OR POSSESSION OF THE RECORDS AND THAT
+UNDER FLA. STAT. SECTION 905.17(1) ONLY THE CLERK SHALL RELEASE
+THE RECORDS AND ONLY PURSUANT TO A COURT ORDER.
+Oddly, Plaintiff argues that the State Attorney has made an unsworn claim that he does not
+possess the Requested Materials, when his Affidavit, filed along with his Motion for Summary
+Judgment on August 18, 2020, clearly provides the following sworn statements:
+1.
+My name is David (Dave) Aronberg, and I am the State Attorney for
+the Fifteenth Judicial Circuit/Palm Beach County, Florida, since 2013, and a
+Defendant in the above-captioned matter.
+2.
+Plaintiff is seeking declaratory relief, pursuant to Fla. Stat.
+90520) and ch, Ad urts i eren e presty, ad in 20 to the fails to ah
+County grand jury, (the "Requested Materials"), and to use those materials for the
+purpose of informing the public.
+9
+
+
+3.
+Despite Plaintiff's above-described action for declaratory relief,
+neither myself nor the Office of the State Attorney for the Fifteenth Judicial Circuit,
+("SAO"), is in control, custody, or possession of the Requested Materials.
+As such, the declaratory relief sought by the Plaintiff seeks materials
+that are impossible for me or my office to produce.
+To be clear, neither myself nor the SAO has the legal authority to
+obtain and deliver the Requested Materials.
+6.
+I have repeatedly made these facts evident to the Plaintiff and the
+public through not only the pleadings and correspondence in this matter, but also
+through an office press release and my public social media accounts.
+Despite the contentions of Plaintiff, neither myself nor the SAO has
+the authority to demand that the Clerk grant the SAO access to grand jury materials
+after a criminal case has concluded.
+8.
+Moreover, during my administration, neither myself nor my office
+has accessed grand jury materials from the Clerk's office in this or any other
+instance.
+9.
+As provided in section 905.17(1), Florida Statutes (2020), the Clerk
+has sole custody and possession of the Requested Materials, which can only be
+released by the Clerk pursuant to an order of the Court.
+See, Exhibit "C". Clearly, the matter presently before the Court is the determination of the State
+Attorney's Motion for Summary Judgment, and then, should he prevail on said Motion a hearing
+should be scheduled on the 57.105 Motion for Attorneys' Fees. Regardless, the State Attorney is
+of the belief that Plaintiff is unable to prove its declaratory relief claim against him as Plaintiff's
+claim has no basis in fact or law as set forth at length above.
+Also, despite the clear, concise, and unambiguous language of Section 905.17(1), Florida
+Statutes, which states that grand jury materials "shall be released by the Clerk only ... on order of
+the Court," Plaintiff attempts to argue that the State Attorney may still have the ability to "access"
+grand jury materials and that therefore he is a necessary party to this action. To be clear, there is
+a great distinction between the ability to "access" and the ability to "disclose" grand jury materials.
+Nonetheless, the State Attorney swore in his Affidavit that "during my administration, neither
+myself nor my office has accessed grand jury materials from the Clerk's office in this or any other
+instance." See, Exhibit "C" 9| 8. Again, even assuming that the State Attorney had the ability to
+10
+
+
+access the Requested Materials, he is foreclosed from making any disclosure pursuant to Section
+905.17(1), Florida Statutes, as only the Clerk shall release grand jury materials pursuant to a court
+order.
+Based on the foregoing, it is clear that Plaintiff indeed has a valid claim against the Clerk
+to seek disclosure of the Requested Materials, and for that reason the Clerk has declined to move
+for 57.105 sanctions. Unlike Plaintiff's case against the Clerk, however, the arguments and
+authority set forth above make clear that it is impossible for the State Attorney or his office to
+produce the Requested Materials demanded by the Plaintiff. This rationale again illustrates the
+lack of any basis in fact or law as to Plaintiff's claim for declaratory relief and provides justification
+for the sanctions sought by the State Attorney should he prevail on the merits of this controversy.
+VII. THE STATE ATTORNEY'S 57.105 MOTION IS NOT PREMATURE, BUT A
+HEARING OR RULING ON SAID MOTION PRIOR TO A SUBSTANTIVE
+HEARING ON THE STATE ATTORNEY'S MOTION FOR SUMMARY
+JUDGMENT WOULD BE PREMATURE.
+Simply put, Plaintiff's argument that "the State Attorney's Motion is admittedly
+premature" is nothing more than a disingenuous stretch of the imagination. To be clear, the State
+Attorney never made such an admission, but rather has consistently argued that "it would be
+premature to have an attorney fee hearing when there is no prevailing party and no substantive
+hearings held since the motion for fees was filed." See, PI's Memorandum, Exhibit "A". Plaintiff
+apparently views this statement as an admission on the part of the State Attorney, which it clearly
+was not. Again the 57.105 Motion was not premature and the State Attorney was entirely within
+his rights to file said Motion based on the statutory instructions set forth in § 57.105(4), Florida.
+Statutes.
+Moreover, despite Plaintiff's false contentions, the State Attorney's 57.105 Motion is not
+based on his Motion to Dismiss Count II of the Amended Complaint. As discussed at length above,
+11
+
+
+the 57.105 Motion is based solely on the reality that Plaintiff's Count I for Declaratory Relief is
+not grounded in fact or law. Because Plaintiff failed to voluntarily dismiss the remainder of its
+Amended Complaint, i.e., Count I for Declaratory Relief, the State Attorney filed its 57.105
+Motion for Attorneys' Fees as authorized, and discussed supra, by § 57.105, Fla. Stat.
+Nonetheless, Plaintiff has purposely misconstrued the filing order of the 57.105 Motion and the
+Motion for Summary Judgment and falsely asserts that the State Attorney "acknowledges that his
+motion is not ripe." See, PI's Memorandum pg. 9.
+Rather, the State Attorney agrees that the Motion for Summary Judgment must first be
+resolved prior to resolving the 57.105 Motion, but the filing of the State Attorneys' 57.105 Motion
+is not unripe merely because it was filed prior to his Motion for Summary Judgment. Not only is
+the State Attorney authorized to file the 57.105 Motion based specifically on statutory instruction,
+the Florida Courts and the Florida Rules of Civil Procedure also support this position. To wit, Fla.
+R. Civ. P. 1.525, Motions for Costs and Attorneys' Fees, states:
+Any party seeking a judgment taxing costs, attorneys' fees, or both shall serve a
+motion no later than 30 days after filing of the judgment, including a judgment of
+dismissal, or the service of a notice of voluntary dismissal, which judgment or
+notice concludes the action as to that party.
+Florida Rules of Civil Procedure, 1.525. As provide above, the Florida Rules of Civil Procedure
+speak only to the filing deadline for Attorneys' Fees Motions and are otherwise silent as to any
+other restriction on filing such motions.
+It is also significant to point out the manner in which Plaintiff has purposely misconstrued
+the very language of § 57.105 by omitting the language that hurts its position. Despite, Plaintiff's
+claims that "57.105 (1)(a)-(b) examines a claim or defense "when initially presented to the court',
+Plaintiff declined to include the remainder of the statutory language, which states "or at any time
+before trial." Clearly, the State Attorney is authorized to pursue sanctions under § 57.105 at any
+12
+
+
+time before trial due, as he has, regarding the lack of any basis in fact or law as to Plaintiff's claim
+for declaratory relief.
+Again, the State Attorney was authorized to file the 57.105 Motion because he did not file
+it with the court until after the prerequisite statutory timeline was satisfied. The 57.105 Motion
+was filed with the Court to further put the Plaintiff on notice that the State Attorney would seek
+sanctions should he prevail on the merits of the lawsuit. Just because the 57.105 Motion for
+Attorneys' fees was filed prior to the State Attorney's Motion for Summary Judgment does not
+necessitate a hearing or ruling on the 57.105 Motion prior to a hearing on the Motion for Summary
+Judgment. See,
+47 So. 3d 320, 325 (Fla. 2d DCA 2010) (finding that "a court is
+typically faced with the decision to impose sanctions for frivolous litigation only after the parties'
+respective positions have been presented to the couft at a substantive hearing."). Likewise, it
+would be far removed from the interests of judicial economy to require a hearing on a place-marker
+57.105 Motion for Attorneys' fees as sanctions prior to a hearing on the Motion for Summary
+Judgment.
+WHEREFORE, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida,
+respectfully requests that a substantive hearing on the merits take place along with the
+determination of a prevailing party before any hearing or ruling on fees or sanctions herein.
+CERTIFICATE OF SERVICE
+THEREBY CERTIFY that on this 14th day of October, 2020, a copy of the foregoing has been
+electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I.
+_ Esq.
+Fla. Bar No.: 10249
+Richard J. Scholz, Esq.
+13
+
+
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esq.
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879 Fax
+Primary: jacobsscholzlaw@comcast.net
+Attorneys for Defendant, Dave Aronberg, and
+General Counsel for the Florida Prosecuting
+Attorney's Association
+NOT A CERTIFIED COP
+14
+
+
+
+
+
+
+THE LAW OFFICES OF
+- ASSOCIATES, P.A.
+ARTHUR L
+ScHoLz & WYLER, LLC.
+A
+LIMITED LIABILITY COMPANY OF PROFESSIONAL ASSOCIATIONS
+ATTORNEYS AT LAW
+GATEWAY TO AMELIA
+961687 GATEWAY BLVD., SUITE 201-1
+FERNANDINA BEACH, FLORIDA 32034
+TELEPHONE (904) 261-3693
+FAX NO. (904) 26l-7879
+RICHARD J. SCHOLZ, P.A.
+RICHARD J. SCHOLZ
+DOUGLAS A. WYLER, P.A.
+DOUGLAS A. WYLER
+June 8, 2020
+VIA ELECTRONIC & U.S. MAIL
+Stephen A. Mendelsohn, Esq.
+Greenburg Traurig, P.A.
+5100 Town Center Circle, Suite 400
+Воса Raton, FL 33486
+COPY
+RE: CA Florida Holdings, LLC v. Dave Aronberg et al.
+Palm Beach County, Case No.: 2019-CA-014681
+Dear Mr. Mendelsohn:
+As you are aware our firm represents the interests of Dave Aronberg, as State Attorney of Palm Beach
+County, Florida, in the above referenced
+tter. The purpose of this letter is to demand the voluntary
+dismissal of your First Amended Complaint, (the "Complaint"), dated January 17, 2020. This demand
+is made pursuant to section 57.105, Florida Statutes.
+As you know, Section 57.105 provides:
+(1) Upon the court's initiative or motion of any party, the court shall award a
+reasonable attorney's fee, including prejudgment interest, to be paid to the
+prevailing party in equal amounts by the losing party and the losing party's attorney
+on any claim or defense at any time during a civil proceeding or action in which
+the court finds that the losing party or the losing party's attorney knew or should
+have known that a claim or defense when initially presented to the court or at any
+time before trial:
+a. Was not supported by the material facts necessary to establish the claim or
+defense; or
+b. Would not be supported by the application of then-existing law to those
+material facts.
+Today, Judge Marx granted, with prejudice, Defendant Aronberg's Motion to Dismiss Count Il of the
+Plaintiff's Complaint. Pursuant to the Court's ruling, the Plaintiff's only remaining cause of action
+consists of Count I, for Declaratory Relief. Accordingly, we believe that the Complaint filed herein
+and its sole remaining Count for Declaratory Relief is not supported by the material facts necessary to
+establish the claims asserted, and that your claims are not supported by the application of current law
+to said material facts.
+
+
+First and foremost, the Complaint is not supported by the material facts necessary to establish the
+claims asserted because neither Defendant Aronberg, nor The Office of the State Attorney for the
+Fifteenth Judicial Circuit is in custody or control of the 2006 grand jury materials sought therein.
+Simply put, the declaratory relief sought by the Plaintiff, seeks records from my client that are
+impossible for him or his office to produce. Accordingly, Defendant Aronberg is not a proper party to
+this action because no matter what, he and his office do not have possession, custody, or control of the
+requested materials.
+In addition to the foregoing material facts that negate the claims asserted in the Complaint, your claims
+are also not supported by the application of current law. Specifically, your action for declaratory relief
+fails based on the clear, unambiguous statutory language found in Section 905.27(2), Florida Statutes,
+which states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a civil
+case, it may be disclosed to all parties to the case and to their attorneys and by the latter
+to their legal associates and employees. However, the grand jury testimony afforded
+such persons by the court can only be used in the defense or prosecution of the civil or
+criminal case and for no other purpose whatsoever.
+Moreover, even if the Plaintiff were to prevail in the declaratory action, Mr. Aronberg would be unable
+to comply with any court order granting disclosure of the requested documents because neither Mr.
+Aronberg nor The Office of the State Attorney for the Fifteenth Judicial Circuit have possession,
+custody, or control of the 2006 Epstein grand jury records.
+Based on the foregoing, if the Complaint is not dismissed within 21 days of the service of this letter,
+the enclosed Motion for Attorney's Fees will be filed and we will seek as sanctions, from your client
+and your firm, recovery of the legal expenses incurred in defending this frivolous action.
+Please govern yourselt accordingl
+Douglas A. Wyler, Esq.
+For the Firm
+Encl.: Defendant's Motion for Attorneys' Fees
+
+
+CA FLORIDA HOLDINGS, LLC,
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+CASE NO.: 19-CA-014681
+COPY
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on this
+_day
+, 2020, the foregoing was electronically filed
+via the Florida E-File Portal for electronic service on the parties of record herein.
+SCHOLZ & WYLER, LLC
+/s/ Douglas A. Wyler
+Arthur I.
+1, Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 0021261
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-I
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879
+jacobsscholzlaw@comcast.net
+Attorneys for Defendant
+NOT A CER
+
+
+
+
+
+
+CA FLORIDA HOLDINGS, LLC,
+Publisher of the PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+alm Beach County, Florida; SHARON F
+OCK. as Clerk and Comptroller of Pali
+Beach County, Florida.
+Defendants.
+/
+COPY
+CASE NO.: 19-CA-014681
+DEFENDANT, DAVE ARONBERG'S MOTION FOR ATTORNEYS' FEES
+Defendant, DAVE ARONBERG, as State Attorney of Palm Beach County, Florida, by and
+through the undersigned attorneys, moves the Court, pursuant to Florida Statutes, Section 57.105,
+to award him reasonable attorneys' fees for the defense of Plaintiff's First Amended Complaint,
+(the "Complaint"), and as grounds therefor, would show that on June 8, 2020, Plaintiff was served
+a copy of this Motion, together with a letter from the undersigned attorney, in accordance with
+subsection (4) of the above Statute, demanding dismissal of the Complaint, at least 21 days prior
+to the filing of this Motion. In said letter, Defendant's attorney advised Plaintiff of the facts which
+establish that the Complaint is without support of the facts or the law.
+WHEREFORE, Defendant, DAVE ARONBERG, as State Attorney of Palm Beach
+County, Florida, respectfully requests the Court enter an Order requiring Plaintiff and Plaintiff's
+attorneys to pay said Defendant's attorneys' fees incurred herein after service of this Motion.
+
+
+CERTIFICATE OF SERVICE
+I hereby certify that on this Ist day July, 2020, the foregoing was electronically filed via
+the Florida E-File Portal for electronic service on the parties of record herein.
+|SCHOLZ & WYLER, LLC
+Is/ Douglas A. Wyler
+Arthur I. L
+1 Esquire
+Fla. Bar No.: 108249
+Richard J. Scholz, Esquire
+Fla. Bar No.: 002126Y
+Douglas A. Wyler, Esquire
+Fla. Bar No.: 119979
+961687 Gateway Blvd., Suite 201-1
+Fernandina Beach, Florida 32034
+(904) 261-3693
+(904) 261-7879
+jacobsscholzlaw@comcast.net
+
+
+
+
+
+
+CA FLORIDA HOLDINGS, LIC,
+Publisher of the PALM BEACH POST,
+Plaintiff,
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R.
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida.
+Defendants.
+AFFIDAVIT OF DAVID ARONBERG
+CASE NO.: 19-CA-014681
+COPY
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Before me, the undersigned authority personally appeared DAVID ARONBERG, being first duly sworn,
+States:
+l.
+My name is David (Dave) Aronberg, and I am the State Attorney for the Fifteenth Judicial
+Circuit/Palm Beach County, Florida, since 2013, and a Defendant in the above-captioned matter.
+2.
+Plaintiff is seeking declaratory relief, pursuant to Fla. Stat. 905.21(1)(c) and the Court's
+inherent authority, allowing Plaintiff access to the testimony, minutes, and other evidence presented in 2006
+to the Palm Beach County grand jury, (the "Requested Materials"), and to use those materials for the
+purpose of informing the public.
+Despite Plaintiff's above-described action for declaratory relief, neither myself nor the
+Office of the State Attorney for the Fifteenth Judicial Circuit, ("SAO"), is in control, custody, or possession
+of the Requested Materials.
+As such, the declaratory relief sought by the Plaintiff secks materials that are impossible
+for me or my office to produce.
+5.
+To be clear, neither myself nor the SAO has the legal authority to obtain and deliver the
+Requested Materials.
+6.
+I have repeatedly made these facts evident to the Plaintiff and the public through not only
+the pleadings and correspondence in this matter, but also through an office press release and my public
+social media accounts.
+
+
+7. -
+Despite the contentions of Plaintiff, neither myself nor the SAO has the authority to
+demand that the Clerk grant the SAO access to grand jury materials after a criminal case has concluded.
+8.
+Moreover, during my administration, neither myself nor my office has accessed grand jury
+materials from the Clerk's office in this or any other instance.
+9.
+As provided in section 905.17(1), Florida Statutes (2020), the Clerk has sole custody and
+possession of the Requested Materials, which can only be released by the Clerk pursuant to an order of the
+Court.
+FURTHER AFFIANT SAYETH NAUGHT.
+By:
+DAVID ARONBERG
+NOT A CERT
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+Sworn to and subscribed before me this 30 day of July; 2020, by DAVID ARONBERG, who is
+personally known'to me or has shown
+as personal identification.
+Siful Pastool
+Notary's Stamp or Seal poe
+LATOSHA LOWE-GOODE
+Consmission # GG 967813
+Expires May 28, 2024
+Banded Thew Sudget Natary Banken
\ No newline at end of file
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@@ -0,0 +1,77 @@
+Case 9:08-cv-80232-KAM Document 30-1 Entered on FLSD Docket 08/06/2008 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+STIPULATION FOR ACCEPTANCE OF SERVICE OF PROCESS
+AND AGREED DATE FOR DEFENDANT'S RESPONSES TO COMPLAINTS
+
+
+Case 9:08-cv-80232-KAM Document 30-1 Entered on FLSD Docket 08/06/2008 Page 2 of 2
+Plaintiffs, Jane Doe 2, Jane Doe 3, Jane Doe 4 and Jane Doe 5, and Defendant Jeffrey
+Epstein, hereby enter into this Stipulation for Acceptance of Service of Process and Agreed Date for
+Responses to Complaints, as follows:
+Defendant Jeffrey Epstein waives formal service of process under Fed.R.Civ.P. 4, and
+hereby accepts service of process in each of these cases through service on his attorney, Michael
+Tein, Esq. It is stipulated, agreed and acknowledged that the Summons and Complaint (DE 1) in
+each of the above-referenced cases was duly served on Michael Tein, Esq. on August 5, 2008.
+2.
+It is stipulated and agreed that Defendant Jeffrey Epstein shall have thirty (30) days
+from the date of service, until September 4, 2008, to serve an answer or otherwise respond to each of
+the Complaints in these cases.
+Dated: August 6, 2008.
+Respectfully submitted:
+By:_
+Is/ Jeffrey M. Herman
+HERMAN & MERMELSTEIN, P.A.
+Attorneys for Plaintiffs Jane Doe 2-5
+Jeffrey M. Herman (FL Bar No. 521647)
+jherman@hermanlaw.com
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@hermanlaw.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@hermanlaw.com
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+By:
+/s/ Michael R. Tein
+TEIN, P.L.
+Attorneys for Defendant Epstein
+Guy A.
+(FL Bar No. 623740)
+Michael Tein, Esq. (FL Bar No. 993522)
+tein@lewistein.com
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Tel: (305) 442-1101
+and
+ATTERBURY, GOLDBERGER, et al.
+Attorneys for Defendant Epstein
+Jack A. Goldberger
+jagesq @bellsouth.net
+250 Australian Ave. S, Suite 1400
+West Palm Beach, FL 33401
+2
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diff --git a/vision-fixhub/court-01/fb4afdbb3a48a4143300aa6c6e3b9fc060f1816779bf35403b21dc36fcaccb18.md b/vision-fixhub/court-01/fb4afdbb3a48a4143300aa6c6e3b9fc060f1816779bf35403b21dc36fcaccb18.md
new file mode 100644
index 0000000000000000000000000000000000000000..08a16b3a4aa899f5d3afc50caa0836b9f2456891
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@@ -0,0 +1,300 @@
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant, Jeffrey E. Epstein's Motion To Compel Plaintiff's Independent Medical
+Examination Pursuant to Rule 35
+Defendant, JEFFREY E. EPSTEIN (hereinafter "Epstein"), by and through his
+attorneys, and pursuant to Fed. R. Civ. P. 35 and other applicable rules, hereby moves
+this Court for an order directing that the Plaintiff, Jane Doe (case #80893), submit to a
+compulsory psychological/psychiatric medical examination (a/k/a independent medical
+,M.D. at the law firm of Burman,
+examination) by Ryan
+,M.D. of Richard
+Critton, Luttier and Coleman, LLP. located at 303 Banyan Boulevard, Ste. 400, WPB, Fl.
+33401. In support, Epstein states:
+Background
+This Court entered an order relating to the IME of CMA, another Plaintiff
+seeking similar damages against Epstein. See Exhibit "A." Given the damages
+claimed in this matter, it is clear that Plaintiff has placed her medical condition at issue
+and that an IME is required. Despite that fact and the fact that discovery has been
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 2 of 8
+Page 2
+consolidated, Plaintiff's counsel has refused to produce Jane Doe for an IME without the
+undersigned having to file a Rule 35 Motion. Thus, the undersigned believes that an
+Omnibus Order is required relative to all the Plaintiffs" IMEs in that each claim similar
+damages and raise similar claims. Such an order would conserve judicial resources
+and require that the attorneys only negotiate dates and times for said IMEs.
+2.
+Nonetheless, this particular Motion, pursuant to Rule 35, only addresses
+the IME of Jane Doe.
+3.
+Plaintiff has alleged in her action that Defendant sexually battered her and
+"caused her emotional distress, past and future suffering, physical injury, pain and
+suffering, psychological trauma, mental anguish, humiliation, embarrassment, loss of
+self-esteem, loss of her child hood, loss of dignity, invasion of privacy, and other
+damages associated with Defendant ... [and]controlling, manipulating, and coercing
+her into a perverse and unconventional way of life for a minor. The then minor Plaintiff
+incurred medical and psychological expenses and... will in the future suffer additional
+medical and psychological expenses. Plaintiff ...has suffered a loss of income, a loss
+of the capacity to earn income in the future, and a loss of capacity to enjoy life. These
+injuries are permanent in nature and Plaintiff... will continue to suffer these losses in
+the future." See Paragraph 28, First Amended Complaint. (DE 38) and Paragraph 34
+thereof. Plaintiff also claims Intentional Infliction of Emotional Distress. See Paragraph
+35-40, First Amended Complaint. (DE 38)
+4.
+Additionally, see Plaintiff's answers to interrogatories, in response to
+interrogatory numbers 2, 4, 5, 6, 7, 10 and 11 wherein Plaintiff claims (a) she worked at
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 3 of 8
+Page 3
+various strip clubs, (b) she was arrested for shop lifting, (c) that she has seen therapists,
+(d) that she was emotionally and psychologically damaged, (e) that she suffered from
+PTSD prior to or at the time of the incident alleged in the complaint, (f) that she incurred
+medical and psychological expenses in the past and will to continue to incur same into
+the future, (g) that she suffered mental anguish, emotional distress, fear, humiliation and
+psychological trauma as a result of her alleged encounter with Epstein, and (h) that she
+was admitted to Milton Girl's Juvenile Residential Facility, a Shelter in West Palm Beach
+and a Drug Center in West Palm Beach. Certainly, all of the above experiences go
+directly to the heart of her allegations (i.e., damages) in that Epstein's medical examiner
+is entitled to know whether any experiences in her life pre-Epstein caused any of the
+emotional, physical and psychological trauma she attempts to pawn-off on Epstein.
+See Responses to Interrogatories, Exhibit "B".
+5.
+It is important for this court to review the detailed Affidavit of Dr.
+attached hereto in that it delineates for the Court several experiences visited upon Jane
+Doe which may have caused the physical, emotional and psychological trauma she
+claims occurred at the hands of Epstein, including, but not limited to, child neglect, drug
+use, being a child runaway, having domestic issues, suffering from PTSD, and her
+father beating her step-brother to death and serving jail time as a result thereof. See
+Affidavit of Dr.
+Attached hereto as Exhibit "C". See also Police Reports at
+Composite Exhibit "D".
+Based upon the foregoing, it is clear that Jane Doe has placed her
+physical, emotional, medical and psychological conditions at issue. Therefore, and IME
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 4 of 8
+Page 4
+is warranted. Without an IME, Epstein would be severely prejudiced. The Affidavit of
+Dr.
+clearly sets out the IME and scope of the examination that must be conducted.
+See also, the curriculum vitae of Dr. Ryan. See Exhibit "E". The examination is set to
+occur at the undersigned office on October 13, 14, 15 or 16, 2009 (whichever is more
+convenient for Plaintiff or whichever date the court so orders). Plaintiff will not provide
+dates for the IME; however, out of abundance of caution and to comply with the
+applicable rule, Defendant has, on a unilateral basis set same pending the outcome of
+this Motion.
+Obviously, if the date noticed is not sufficient or agreeable, the
+undersigned will renotice same for one of the four dates suggested.
+7.
+As this court is well aware, Plaintiff and Defendant are required to
+complete discovery under the deadlines set by this court. It is not the undersigned's
+intention to require the court additional work; however, it is imperative that discovery be
+timely scheduled and completed. The court's assistance is needed in this instance as to
+the IME.
+8.
+Based upon the foregoing, an IME of Plaintiff must occur in order to
+address her claims and the damages she seeks to recover. The IME is expected to last
+between 6-8 hours, and the scope of same is set forth in the Affidavit.
+9.
+Pursuant to Rule 35, Fed.R.Civ. Pro, a party may move for an examination
+by a qualified examiner if the Plaintiff's mental/emotional and/or psychological status is
+at issue in a case.
+10.
+Defendant would be severely prejudiced unless he is able to have an
+examination conducted by a qualified examiner separate and apart from any
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 5 of 8
+Page 5
+psychologist/psychiatrist or similar behavioral health provider who may have or may
+ultimately see the Plaintiff and testify in court.
+11.
+Defendant's counsel has retained the services of Richard | M.D. and
+Ryan 1
+M.D., of C.W.
+M.D., P.A. located at 2500 West Lake Mary Bivd., #219
+M.D., will be performing the examination. Dr. Ryan
+Lake Mary, FL 32746. Ryan |
+Halls' specialties include forensic psychiatry, general psychiatry and medical psychiatry.
+See Exhibit "C" attached to DE 245 outlining Ryan
+• M.D.'s qualifications and the
+scope of the examination which he intends and is required to conduct in order to render
+a report. See also Affidavit of Ryan C.W.
+M.D., outlining the scope of examination
+and other Rule 35 requirements. Accordingly, this motion comports with Rule 35. The
+applicable notice has been filed simultaneously. Defendant will arrange for a videotape
+of the examination.
+12. The undersigned is requesting the court's assistance with regard to
+compelling the IME of Plaintiff along with dates for same to occur.
+Rule 7.1 A. 3. Certification of Pre-Filing Conference
+Counsel for Defendant conferred with Counsel for Plaintiff by telephone and by e-mail;
+however, an agreement has not been reached.
+WHEREFORE, Defendant requests that this Court enter an Order:
+a. providing a date and time for Plaintiff's IME to occur on October 13, 14, 15 or
+16, 2009;
+b. providing that the independent medical examination take place at 9:00 a.m.
+(on a date to be determined by the court) at the law firm of Burman, Critton,
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 6 of 8
+Page 6
+Luttier and Coleman, LLP. located at 303 Banyan Boulevard, Ste. 400, WPB,
+Fl. 33401 under the protocol set forth by Dr.
+in his affidavit, by videotape
+and for such other and further relief as this court deems just and proper.
+Rule 7.1 Certification
+I hereby certify that counsel for the respective parties communicated by
+telephone in a good faith effort to resolve the discovery issues prior to the filing of this
+motion. Counsel was unable to resolve the issues outlined herein.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this A day of Sep
+- 2009
+Respectfully submitted
+By:
+ROBERTD. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bciclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 7 of 8
+Page 7
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Brad
+Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-
+80119, 08-80232,
+08-80380, 08-80381, Paul G. Cassell, Esq.
+08-80993, 08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Salt Lake City, UT 84112
+Richard H. Willits, P.A.
+801-585-5202
+2290 10* Avenue North
+801-585-6833 Fax
+Suite 404
+cassellp@law.utah.edu
+Lake Worth, FL 33461
+Co-counsel for Plaintiff Jane Doe
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Isidro M.
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P. Esq.
+Searcy
+Denney
+Counsel for Plaintiff in Related Case No.
+Scarola Barnhart & 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+561-686-6300
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+jph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff. C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+Bruce Reinhart, Esq.
+Counsel for Plaintiffs in Related Cases
+
+
+Case 9:08-cv-80119-KAM Document 301 Entered on FLSD Docket 09/15/2009 Page 8 of 8
+Page 8
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Ricci-Leopold, P.A.
+2925 PGÁ Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+cc. Dr. Ryan
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+No.
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/fb4fecf88a4782885e522f3a1f63e0779d74b1c9958796f54de94f4fae4c2668.md b/vision-fixhub/court-01/fb4fecf88a4782885e522f3a1f63e0779d74b1c9958796f54de94f4fae4c2668.md
new file mode 100644
index 0000000000000000000000000000000000000000..28f772690f4fef161f86fb84b871ee784ed05a22
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+++ b/vision-fixhub/court-01/fb4fecf88a4782885e522f3a1f63e0779d74b1c9958796f54de94f4fae4c2668.md
@@ -0,0 +1,391 @@
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 1 of 13
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO.2,
+Plaintiff,
+CASE NO.; 08-CV-80119-MARRAI
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.3,
+Plaintiff,
+CASE NO.; 08-CV-80232-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO.4,
+Plaintiff,
+CASE NO.; 08-CV-80380-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+CASE NO.; 08-CV-80381-MARRAL
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 2 of 13
+Page 2
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.; 08-CV-80994-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+Plaintiff,
+CASE NO.; 08-CV-80993-MARRAJ
+vS.
+JEFFREY EPSTEIN,
+Defendant.
+C.M.A.,
+Plaintiff,
+CASE NO.; 08-CV-80811-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE,
+Plaintiff,
+CASE NO.; 08-CV-80893-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendants.
+2
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 3 of 13
+Page 3
+DOE II,
+Plaintiff,
+CASE NO.; 08-CV-80469-MARRA1
+VS.
+JEFFREY EPSTEIN, et al,
+Defendants.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.; 08-CV-80591-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+CASE NO.; 08-CV-80656-MARRA/JOHNSON
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Defendant, Jeffrey Epstein's Motion To Strike Cases From Current Trial Docket
+And Motion to Continue Case And/Or Alternative Motion to Modify Trial and
+Scheduling Order Deadlines
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN") by and through his
+undersigned attorneys, hereby moves this Court for the entry of an order Striking These
+Cases (i.e., C.M.A., Jane Doe (80893) and Jane Does 2-7) From The Current Trial
+Dockets), Continuing The Trials And Setting Them On New Trial Dockets At Least
+3
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 4 of 13
+Page 4
+Three Months After The Current Trial Dates As Set Or, Alternatively, Modifying The
+Current Trial Schedule To Allow For An Additional 3 Months From Current Dates Within
+Which To Complete Discovery, An Additional 2 Months From The Current Dates Within
+Which To Complete All Substantive Pretrial Motions and Expert Discovery, An
+Additional Month From The Current Dates Within Which To Mediate the Matters and An
+Additional Month to Complete the Remaining Scheduling Deadlines under this Court's
+Trial Orders. In support, EPSTEIN states:
+1.
+Procedural Background and Argument,
+With Incorporated Memorandum of Law'
+1. C.M.A. was filed on February 23, 2008. C.M.A. filed her First Amended
+Complaint on February 10, 2009. (C.M.A. DE 39-40). Epstein's Motion to Dismiss same
+was filed on March 12, 2009. (C.M.A. DE 47). The Motion to Dismiss remains
+outstanding.
+2. Jane Doe (80893) was filed on August 13, 2008. On April 17, 2009, Jane Doe
+filed her First Amended Complaint.
+3. The Jane Doe 2-7 cases were filed between February 6, 2008 and September
+10, 2008. Jane Does 2-7 filed their Second Amended Complaints on February 2009.
+4. Pursuant to the court's Orders Setting Trial And Discovery Deadlines, Referring
+Case To Mediator And Referring Discovery Motions To U.S. Magistrate Judge (the
+In an effort not to repeat certain legal arguments set out in various Motions and Replies referenced
+below and identified herein by Docket Number, those motions and replies, with legal arguments, are
+specifically incorporated herein by reference.
+4
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 5 of 13
+Page 5
+"Trial Orders"), these matters are currently set on this court's Trial Dockets commencing
+January 25, 2010, February 8, 2010 and February 22, 2010.
+5. Pursuant to the Trial Orders, discovery cutoff is August 2009 for C.M.A. and Jane
+Does 2-5, and October 2009 for Jane Doe and Jane Does 6-7. Substantive pretrial
+motions must be completed in August 2009 for C.M.A. and Jane Does 2-5, and October
+2009 for Jane Doe and Jane Does 6-7. Mediation must be completed on November
+2009 for Jane Does 2-5, and December 2009 for C.M.A., Jane Doe and Jane Does 6-7.
+Finally, Expert discovery must be completed on June 29, 2009 for C.M.A.
+6. As to C.M.A., Jane Doe and Jane Does 2-7, each has objected to relevant
+discovery. C.M.A. has even refused to produce certain information that she agreed to
+produce in discovery. The foregoing delay tactics has prevented Epstein from
+conducting meaningful discovery in order to defend these matters and prepare for trial.
+At this juncture, Plaintiffs wish for Epstein to try this case without any discovery
+whatsoever. See infra.
+7. For example, in a diligent effort to obtain discovery, Epstein filed substantive
+motions addressing C.M.A.'s objections to discovery, and those motions remain
+outstanding.? See (C.M.A. - DE 54 - Motion to Compel Responses to First Request to
+Produce and First Set of Interrogatories and DE 70 - Epstein's Reply to Plaintiff's
+Opposition Motion thereto). Epstein's Motion to Compel (C.M.A. DE 54) and Reply
+3 king producion of singles tere served up case ore aid and Does Silen a l
+28 and Jane Doe 2-7 (specifically, Jane Doe 2 - DE 67-68, Jane Doe 3 - DE 59-60, Jane Doe 4 - DE 74-75, Jane
+Doe 5 - DE 69-70, Jane Doe 6 - DE 24-25, and Jane Doe 7 - DE 26-27). Those Motions are incorporated herein by
+reference.
+5
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 6 of 13
+Page 6
+(C.M.A. DE 70) are incorporated herein by reference. The Motion and the Reply seek
+basic and elementary discovery. For instance, the Motion and the Reply seek:
+a. individual
+and/or joint income tax returns and supporting
+documentation including W-2 and 1099 forms for 2002-2007 and, as
+well as all records or documentation relative to the Plaintiff's earnings
+for the current year;
+b. All bills/expenses
+from any medical doctor, chiropractor,
+psychologists, psychiatrists, mental health counselors (including any
+members of the healing arts and related
+i.e. drugs,
+prescriptions, etc.) you claim you incurred as a result of the injuries
+which are or may be the subject matter of this lawsuit;
+c. All medical reports and/or records from doctors, physicians,
+(including psychologists, psychiatrists, mental health counselors),
+hospitals, drug or alcohol facilities or any other person or entity who
+has rendered treatment to or examined you for any reason after the
+incidents) which is the subject matter of this lawsuit;
+d. the names, business addresses,
+telephone and cell phone
+numbers, dates ot employment, immediate supervisor (name and
+address) and rates of pay regarding all employers, including selfemployment, for whom you have worked in the past 10 years; this
+includes listing all sources of income you have received. Answer this
+question by year, i.e. 1998 - 2009; and
+e. the names, addresses and phone numbers of all males, excluding
+Mr. Epstein, with whom you have had sexual activity since age 10 (by
+year) up through your current age. Describe the nature of sexual
+activity, the date(s) and whether you received money or other
+consideration from the person.
+(DE 54 & 70)
+8. C.M.A. objected to producing the tax information requested in 4(a) above, which
+will show where C.M.A. worked, and she also speciously objected to the companion
+interrogatory (4(d) above) wherein she refuses to identify where she worked for the
+requested time period. Epstein needs the requested information so his attorneys can
+6
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 7 of 13
+Page 7
+conduct the appropriate discovery on C.M.A.'s supervisors and co-workers (and others
+that may be identified during those depositions) in connection with the allegations
+C.M.A. has made against Epstein in her 89-page Amended Complaint. By virtue of
+C.M.A. and the other Plaintiffs concealing the above information, Epstein has been
+prevented from conducting any meaningful discovery, including the taking of any
+depositions of C.M.A.'s supervisors, co-workers, acquaintances, friends and other third
+parties.
+9. As stated above, Jane Doe and Jane Does 2-7 made similar objections which
+are the subject of various Motions to Compel. Epstein needs this information to defend
+the Plaintiffs' allegations and to prepare for trial.
+10. Next, C.M.A. concedes in her Opposition Motion to Discovery (DE 62) that
+Epstein is entitled to the information set out in 4(b) & (C) above; however, C.M.A.
+refuses to produce the information and/or allow the undersigned to list C.M.A.'s full
+name, date of birth and last four digits of her social security number in any third-party
+subpoenas in order to obtain those records.? While this case was filed by C.M.A. on
+February 23, 2008, Epstein has been prevented from deposing any of the individuals
+that treated Plaintiff at one time or another.* This results directly from C.M.A. 's tactics to
+delay and prevent meaningful discovery in hopes that C.M.A. will be able to prevent
+Epstein from putting on any evidence in defense of his case. The remaining Plaintiffs
+3 Attorney, Brad
+, in case number 08-CIV-080893, agreed to such a procedure. Counsel for
+Jane Does 2-7, Stuart Mermelstein, refuses to agree to such a procedure and, therefore, continues to
+substantially delay discovery. Note, many of the Plaintiffs are witnesses in the related cases. Therefore
+Plaintiffs' discovery delays negatively effect the progress and trial preparation of each case
+7
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 8 of 13
+Page 8
+have the same exact goal. Epstein cannot defend this matter with the element of unfair
+and prejudicial "surprise" is ever so present. Schearbrook Land and Livestock
+Company v. U.S. et. al, 124 F.R.D. 221 (M.D. Fla. 1988).
+11. In an effort to move these cases forward and obtain meaningful discovery,
+Epstein filed his Motion to Compel and Motion to Compel and/or Identify CMA (and
+Jane Does 2-7) in the Style of this Case and Motion to Identify Them in Third-Party
+Subpoenas ("Motions to Identify"). The Motions to Identify are incorporated herein by
+reference and, for the court's edification, same remain outstanding. Should this Court
+grant the Motions to Identify, Epstein will be able to obtain discovery he does not
+currently have in his possession and will be able to take certain depositions of
+individuals that have yet to be identified. Based upon the court's consolidation order,
+the motion to identify equally applies to C.M.A. and the other Plaintiffs.
+12. Plaintiffs must be identified in other third-party subpoenas (unrelated to those
+discussed above concerning medical treatment) in order for Epstein to conduct
+meaningful discovery. Epstein's right to conduct discovery and confront the witnesses
+has, up through today's date, been unreasonably and unduly restricted as a result of
+Plaintiffs' delay tactics.
+13. Finally, the information sought in number 4(e) above has not been produced by
+C.M.A. or the remaining Plaintiffs, despite the case law favoring production. United
+5 In a state court matter filed against Epstein, E.W. v. Epstein, Case No.: 50-2008-CA-028058 XXXXMB
+AD, the undersigned learned through discovery that the Plaintiff in that case worked at Platinum Gold,
+Curves Cabaret, Platinum Showgirls, Cheetah, Diamond Dolls, Vegas Cabaret, Spearmint Rhino, T's
+Lounge, Pure Platinum, Solid Gold, and The Body Shop. Substantial discovery will take place in that
+matter of E.W.:'s co-workers, supervisors and others that may have information regarding the claims she
+asserted against Epstein. Epstein should be afforded that same right in the instant matters.
+8
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 9 of 13
+Page 9
+States v. Bear Stops, 997 F.2d 451 (8'' Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076
+(Fla. 5" DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in
+4(e) is relevant and discoverable even if not admissible at trial. See Motion to Compel
+and Reply (C.M.A. DE 54 & 70). Once Plaintiffs are required to fully answer the
+interrogatories, the answers may yield (at a later deposition or through paper discovery):
+(a) the names of individuals that may have information about Plaintiffs that negate the
+allegations in their Complaints, (b) how certain acts alleged in their Complaints
+materially affected their relationships with others or how those acts did not have such an
+affect on those relationships, and (3) whether Plaintiffs suffered from disorders (e.g.,
+C.M.A.'s claims of bi-polar disorder and manic depression) as a result of other sexual
+acts prior to the acts alleged in the Complaints. Here, evidence of Plaintiffs' sexual
+activity with others may show that those sexual activities (which could include assaults
+once delineated) produced the behaviors that, for instance, C.M.A. attributes to Epstein
+(e.g., bi-polar and manic depression disorders). Accordingly, answers to the above
+discovery requests go the heart of Plaintiffs' damages or lack thereof.
+14. Further, pursuant to this Courts Order (C.M.A. DE 68 and in the related matters),
+Epstein is permitted only to take the Plaintiffs' depositions one time, both as a witness in
+the other related matters and as a plaintiff in their particular matters. As a result, the
+discovery schedule coupled with Plaintiffs' delay tactics and the Order (DE 68) is forcing
+Epstein to take each of the Plaintiffs' depositions without the benefit of other discovery
+and depositions of individuals that may have knowledge of the claims asserted by
+Plaintiffs. As such, in the event Plaintiffs produce information after their depositions,
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 10 of 13
+Page 10
+this Court's order (DE 68) and the Federal Rules effectively prevent Epstein from taking
+Plaintiffs' depositions a second time. This is inherently unfair and prejudicial to Epstein.
+a. Memorandum of Law
+15. Modifying a trial order and the deadlines/schedules thereunder is within the
+sound discretion of this court. Under the circumstances outlined above, failure to strike
+these cases from the current docket, continue the trials, and/or to modify the court's
+scheduling order will prejudice Epstein. Epstein has diligently attempted to comply with
+the Court's scheduling order but has effectively been prevented from doing so in light of
+the Plaintiffs' delay tactics during discovery. See supra; Fed.R.Civ.Pro. 16(b)(4); Altadis
+USA, Inc. v. NPR, Inc., 2004 WL 444533 (M.D. Fla.)(granting motion to extend
+discovery and continue trial).
+16. Epstein has shown good cause to obtain a continuance of the trial of this matter
+and, as well, has shown good cause in order for this court to modity the scheduling
+order. Fed.R.Civ.Pro. 16(b)(4)("A [scheduling order] may be modified only for good
+cause and with the judge's consent."). Epstein's counsel has complied with Local Rule
+7.6 of the U.S. Southern District by executing and providing the attached Affidavit.
+Exhibit "A". Epstein cannot, despite his diligence, timely complete discovery by the
+times outlined in the current scheduling order as a result of the Plaintiffs' delay tactics.
+Thus, as outlined above, failure to strike these cases from the docket, continue this
+case to the next available docket and to extend the discovery schedule and remaining
+deadlines will prejudice Epstein. Epstein has simply not been given the opportunity to
+obtain and/or conduct any meaningful discovery, which violates Epstein's constitutional
+10
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 11 of 13
+Page 11
+due process right to defend himself and to seek the production of information that will
+assist in his defense of the allegations in respective complaints.
+Plaintiffs cannot
+reasonably expect Epstein to try these matters with having only been afforded the
+opportunity to take the deposition of one Plaintiff and not conduct any meaningful
+discovery on others.
+WHEREFORE, Epstein, through his counsel, requests that this court enter and
+Order:
+a. striking these cases from the current trial docket;
+b. continuing the trials of these matters and setting same on new trial
+dockets at least three months after the current trial dates; or, alternatively,
+c. modifying the current trial schedule to allow for an additional 3 months
+from the currently set date within which to complete discovery, an
+additional 2 months from the currently set date within which to complete all
+substantive pretrial motions, an additional month from the currently set
+date within which to mediate this matter; and an additional month to
+complete the remaining deadlines under each of the Court's Trial Orders;
+and
+d. for such other and further relief as this cour deems just and proper.
+ROBERT BYCRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+11
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 12 of 13
+Page 12
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CMECF on this_14 day of May. 2009
+Richard Horace Willits, Esq.
+Jack Alan Goldberger, Esq.
+Richard H. Willits, P.A.
+Atterbury Goldberger & Weiss, P.A.
+2290 10* Avenue North
+250 Australian Avenue South
+Suite 404
+Suite 1400
+Lake Worth, FL 33461
+West Palm Beach, FL 33401-5012
+561-582-7600
+561-659-8300
+Fax: 561-588-8819
+Fax: 561-835-8691
+Counsel for Plaintiff C.M.A.
+jagesq@bellsouth.net
+reelrhw@hotmail.com
+Counsel for Defendant Jeffrey Epstein
+Jack Scarola, Esq.
+Jack P.
+Bruce Reinhart, Esq.
+1, Esq.
+Bruce E. Reinhart, P.A.
+Searcy Denney Scarola Barnhart
+&
+250 S. Australian Avenue
+Shipley, P.A.
+Suite 1400
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33401
+West Palm Beach, FL 33409
+561-202-6360
+561-686-6300
+Fax: 561-828-0983
+Fax: 561-383-9424
+ect@brucereinhartlaw.com
+isx@searcylaw.com
+Counsel for Defendant
+iph@searcylaw.com
+Co-Counsel for Plaintiff
+Respectfully subritted,
+ROBÈRT D/CRItION, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+12
+
+
+Case 9:08-cv-80232-KAM Document 93 Entered on FLSD Docket 05/19/2009 Page 13 of 13
+Page 13
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant, Jeffrey Epstein)
+13
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+Case 9:09-cv-80469-KAM. Document 61
+Entered on FLSD Docket 10/16/2009 Page 1 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 09-CIV- 80469 - MARRA/.
+JANE DOE II,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+_!
+DEFENDANT EPSTEIN'S ANSWER & AFFIRMATIVE DEFENSES
+TO PLAINTIFF'S FIRST AMENDED COMPLAINT [DE 60]
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, files his Answer & Affirmative Defenses to Plaintiff JANE DOE
+Il's First Amended Complaint:
+1. Defendant admits that Plaintiff has sued Defendant in this action. Defendant
+denies the remainder of the allegations.
+2. Deny.
+3. As to the allegations in paragraph 3, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "i]t would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 2 of 9
+Page 2
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+4. As to the allegations is paragraph 4, Defendant is without knowledge as to
+whether "Ms. DOE Il is a natural person residing in Palm Beach County, Florida," and
+denied the same. As to the remainder of the allegations, Defendant realleges and
+adopts his response in paragraph 3 above herein.
+5. As to the allegations in paragraph 5, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "i]t would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 3 of 9
+Page 3
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+6. Admit.
+7. As to the allegations set forth in paragraphs 7 through 14, Defendant asserts his
+Fifth Amendment privilege against self-incrimination. See DeLisi V. Bankers Ins.
+Company, 436 So.2d 1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495
+(1964)(the Fifth Amendment's Self-Incrimination Clause applies to the states through
+the Due Process Clause of the Fourteenth Amendment - "'ilt would be incongruous to
+have different standards determine the validity of a claim of privilege based on the same
+feared prosecution, depending on whether the claim was asserted in state or federal
+court."); 5 Fed. Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against
+Self-Incrimination (... court must treat the defendant's claim of privilege as equivalent to
+a specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions.
+-"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+Count I: 18 U.S.C. §2255(a) vs. Defendant EPSTEIN
+8. As to the allegations of paragraph 15, Defendant realleges and adopts his
+responses to paragraphs 1 through 14 of the First Amended Complaint set forth in
+paragraphs 1 through 7 above herein.
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 4 of 9
+Page 4
+9. As to the allegations of paragraph 16, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "[ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court.); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+Count II: 18 U.S.C. $2255(a) vs. Defendant
+10. Although Count II is not alleged against Defendant EPSTEIN, as to the
+allegations of paragraph 17, Defendant realleges and adopts his responses to
+paragraphs 1 through 14 of the First Amended Complaint set forth in paragraphs 1
+through 7 above herein.
+11. As to the allegations of paragraph 18, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4'" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 5 of 9
+Page 5
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "[ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("... court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+WHEREFORE Defendant requests that this Court deny all relief sought by Plaintiff.
+Affirmative Defenses
+1. As to Plaintiff's claim, Plaintiff actually consented to and was a willing participant
+in the acts alleged, and therefore, her claims are barred, or her damages are required to
+be reduced accordingly.
+2. As to the claim, Plaintiff actually consented to and participated in conduct similar
+and/or identical to the acts alleged with other persons which were the sole or
+contributing cause of Plaintiff's alleged damages.
+3. As to Plaintiff's claim, Plaintiff impliedly consented to the acts alleged by not
+objecting, and therefore, her claims are barred, or her damages are required to be
+reduced accordingly.
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 6 of 9
+Page 6
+4. As to Plaintiff's claim, Defendant reasonably believed or was told that the Plaintiff
+had attained the age of 18 years old at the time of the alleged acts.
+5. As to Plaintiff's claim, Plaintiff's claims are barred as she said she was 18 years
+or older at the time.
+6. As to Plaintiff's claim, Plaintiff's alleged damages were caused in whole or part
+by events and/or circumstances completely unrelated to the incident(s) alleged in the
+complaint.
+7. Plaintiff's claims are barred by the applicable statute of limitations.
+8. Plaintiff has failed to plead a cause of action as she does not and can not show a
+violation of a predicate act under the applicable version of 18 U.S.C. §2255 (2005) - the
+version in effect prior to the 2006 amendment, eff. Jul. 27, 2006.
+9. As to Plaintiff's §2255 claim, the version of 18 U.S.C. §2255 in effect at the time
+of the alleged conduct applies, and, thus, the presumptive minimum damages amount
+should Plaintiff prove the elements of such claim is $50,000, and not subject to any
+multiplier.
+10. As to Plaintiff's §2255 claim, Plaintiff is entitled to only a single recovery of her
+actual damages. Should Plaintiff prove actual damages in an amount less than
+$50,000, the applicable statutory minimum, she is entitled to a single recovery of
+$50,000, regardless of the number of acts. Allowing a multiplication of the damages
+recoverable would be in violation of the prohibition against the recovery of duplicative
+damages.
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 7 of 9
+Page 7
+11. As to Plaintiff's §2255 claim, application of the amended version of 18 U.S.C.
+§2255, effective July 27, 2006, would be in violation of the legal axiom against
+retroactive application of an amended statute, and also in violation of such constitutional
+principles, including but not limited to, the "Ex Post Facto" Clause, U.S. Const. Article I,
+§9, cl. 3, §10, cl. 1, and procedural and substantive due process, U.S. Const. 14"*
+Amend., 5'" Amend. The statute in effect during the time of the alleged conduct applies.
+12. As to Plaintiff's §2255 claim, application of the amended version of 18 U.S.C.
+§2255, effective July 27, 2006, is prohibited pursuant to the vagueness doctrine and the
+Rule of Lenity. A criminal statute is required to give " 'fair warning ... in language that
+the common world will understand, of what the law intends to do if a certain line is
+passed. To make the warning fair, so far as possible the line should be clear.' " United
+States v. Lanier, 520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting
+McBoyle v. United States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931))
+(omission in original). The "three related manifestations of the fair warning requirement"
+are: (1) the vagueness doctrine bars enforcement of a statute which either forbids or
+requires the doing of an act in terms so vague that men of common intelligence must
+necessarily guess at its meaning and differ as to its application; (2) the canon of strict
+construction of criminal statutes, or rule of lenity, ensures fair warning by so resolving
+ambiguity in a criminal statute as to apply it only to conduct clearly covered; (3) due
+process bars courts from applying a novel construction of a criminal statute to conduct
+that neither the statute nor any prior judicial decision has fairly disclosed to be within its
+scope.
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 8 of 9
+Page 8
+13. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+14. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+15. 18 U.S.C. §2255 violates the Equal Protection Clause of the 14* Amendment
+under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred.
+16. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life, liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+ROBERT D. CRITTON, JR, ESO.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+Certificate of Service
+
+
+Case 9:09-cv-80469-KAM Document 61 Entered on FLSD Docket 10/16/2009 Page 9 of 9
+Page 9
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following service list in the
+on this specified via transmission of Notices of Electronic Filing generated by CM/ECF
+_ day of Octahon 2009:
+Isidro M.
+Esq.
+Law Firm, P.A
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+isidrogarcia@bellsouth.net
+Counsel for Plaintiff
+Jack Alan Goldberger, Esq
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+561-835-8691 Fax
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By:
+ROBERT D./CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.com
+VICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561-842-2820
+Fax: 561-515-3148
+(Co-counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/fb76e3a917bf989e0806822fa4cbc51f76d124aa7ac90036d7f8d7b29840b597.md b/vision-fixhub/court-01/fb76e3a917bf989e0806822fa4cbc51f76d124aa7ac90036d7f8d7b29840b597.md
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@@ -0,0 +1,480 @@
+Case 9:08-cv-80119-KAM Document 291
+Entered on FLSD Docket 09/08/2009 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRA/JOHNSON
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+Defendant's Sur-Reply In Connection With Plaintiffs', Jane Does 2-7, Motion For
+Protective Order (DE 226) and Reply (DE 266) With Incorporated Memorandum
+Of Law, And Pursuant To This Court's Order (DE 285)
+Defendant, JEFFREY EPSTEIN ("Epstein" or "Defendant"), by and through his
+undersigned attorneys, hereby files his Sur-Reply In Connection With Plaintiffs', Jane
+Does 2-7, Motion For Protective Order (DE 226) and Plaintiffs' Reply (DE 266), With
+Incorporated Memorandum Of Law, And Pursuant To This Court's Order (DE 285). In
+support, Mr. Epstein states as follows:
+I. Introduction & Argument
+Plaintiffs have attempted to prevent discovery relating to their medical,
+psychological, criminal and employment histories, as well as their general backgrounds.
+Now Plaintiffs wish to prevent Epstein from investigating the very claims they assert
+against him by asking this court to stop Epstein's defense team from learning information
+about the Plaintiffs that would contradict their claims and the damages they seek to
+1
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 2 of 14
+recover. In an attempt to halt any investigation, Plaintiffs claim "they have great fear and
+concern [of] their identities being disclosed as Epstein's victims. ..." however, they do
+not state that investigators are identifying them as said victims, or identifying them with
+Jeffrey Epstein (emphasis added). (DE 266, p.2)
+Notably, Plaintiffs have several preexisting and diagnosed conditions for
+2.
+which they now attempt to pawn off on Epstein in an effort to increase their damages.
+See infra. For instance, prior to any of their alleged encounters with Epstein, certain
+Plaintiffs have been raped, sexually abused, molested and physically and verbally abused.
+See infra. Some of them have been diagnosed with post traumatic stress disorder or
+obsessive compulsive disorder, and some have suicidal thoughts and/or have attempted
+suicide on more than one occasion. Moreover, some of the Plaintiffs have witnessed
+close friends or family members commit suicide. While the above incidents are nothing
+less than tragic, the impact of those incidents on each of the Plaintiffs must be taken into
+consideration with the claims they make and the damages they seek from Epstein.
+Certainly, this court cannot expect or force Epstein to accept what
+Plaintiffs choose to provide at deposition or what they filter through discovery without
+further investigation. Requiring Epstein to do so would be tantamount to giving the
+Plaintiffs the key to the bank in that Epstein will not be afforded the right to investigate
+the claims made against him.
+Plaintiffs' delay tactics are largely out-of-control in that same have
+delayed the timely progress of this case and resulted in several unnecessary discovery
+motions and judicial resources. Plaintiffs continue to attempt to prevent discovery at
+every turn, and their next step will likely be to prevent Epstein from participating in
+2
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 3 of 14
+depositions in connection with the cases that Plaintiffs have filed against him.
+(a) Plaintiffs' Reply Memorandum In Support Of
+Their Motion For Protective Order
+On August 14, 2009, Plaintiffs filed their Reply Memorandum in Support
+of Motion for Protective Order (DE 266). Plaintiffs claim in their Reply that it would be
+of little relevance as to whether Plaintiffs gave "older-rich guys" "massages" for money
+and, as such,
+Defendant's investigators should be precluded from learning that
+information all together. (DE 266, p. 6) Is Plaintiffs' counsel serious? Plaintiffs seek
+damages for allegedly giving massages that purportedly transformed into a sexual assault.
+Is it not relevant whether Plaintiffs have given massages or massages of a sexual nature
+for money in the past? Will that not lead to the discovery of admissible evidence? Is it
+not relevant whether Plaintiffs bragged to others about making money for allegedly
+giving older men massages, whether they worked in the proverbial "jack shack" and
+whether they convinced their friends to do the same. Assuming Plaintiffs provided
+massages of a sexual nature to older men for money and that they did work in "jackshacks" and/or as prostitutes, that information is relevant to this action in that Plaintiffs
+are seeking millions of dollars for psychological injuries, which may have been caused by
+acts other than those allegedly caused by Epstein.
+6.
+This is a civil case, and consent goes to the heart of Plaintiffs' damages
+claims. If Plaintiffs were promiscuous and prostituted themselves out for money, does
+this court believe that Plaintiffs would provide Epstein with that information in an effort
+to prove his affirmative defense of consent or to limit Plaintiffs' damages? Personal
+injury cases and the damages Plaintiffs claim are disproved everyday by virtue of
+investigation and surveillance. Here, Plaintiffs seek millions of dollars in personal injury
+3
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 4 of 14
+damages for, among other things, "confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries." See Amended Complaint. As such,
+Epstein is permitted to conduct the appropriate investigation to determine whether other
+events in the Plaintiffs' lives have caused their psychological problems separate and apart
+from what they alleged in their respective Complaints. As such, this court should not
+allow Plaintiffs to hide behind the cloak of their allegations in an effort to prevent
+discovering their true backgrounds and thus disproving the claims they allege against
+Epstein in these civil cases.
+7.
+Next, Plaintiffs claim they are worried about their identities being revealed
+by Epstein's investigators; however, the declarations cited below do NOT state that
+Epstein's investigators have affiliated Plaintiffs with Jeffrey Epstein, revealed that they
+are alleged sexual battery victims, or that Plaintiffs initiated specious civil lawsuits
+against Jeffrey Epstein.' Moreover, several third-party subpoenas have been served and
+Plaintiffs' counsel has filed Cross-Notices of those Non-Party Depositions on individuals
+without redacting Epstein's name. Plaintiffs' counsel has not complained to their
+colleagues about taking such an approach. Is it Plaintiffs' counsel's contention that when
+they depose third parties, they will never identify Jane Doe 2-7 or associate them with
+Epstein? How else will Plaintiffs prove their damages? Clearly, Plaintiffs seek only to
+limit Epstein's discovery, not their own.
+8.
+After the filing of the Reply, Plaintiffs filed new declarations. In
+particular, Plaintiffs attach to or cite in their Reply the declaration of Jane Doe 4 (dated
+far taken
+a conservative
+Epstein's investigators
+investigative approach
+investigative approach
+Plaintiffs allege
+so long as
+remain, as all have, messon prmessona1 on else lappenis gonnati ator
+the veracity of the allegations Plaintiffs allege against him.
+4
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 5 of 14
+August 14, 2009), the declaration of Jane Doe 7 (dated August 14, 2009) and the
+declaration of Jane Doe 4's sister (Y.B.'s declaration dated August 18, 2009). Once
+again, none of the declarations provide that Epstein's investigators have identified them
+as alleged sexual assault victims or affiliate them in anyway with Jeffrey Epstein.
+The Declaration of Jane Doe Number #4
+9.
+As to Jane Doe #4's declaration, investigators interviewed her former
+boyfriend, Preston Vinyard, by telephone. Mr. Vinyard commented that he knew the
+investigators wanted information about Jane Doe #4 without the investigators even
+mentioning Jane Doe's name. Importantly, Jane Doe #4 provided Mr. Vinyard's name to
+her expert, Gilbert Kliman, M.D. In fact, she stated in the interview with Dr. Kliman that
+Mr. Vinyard was not a good influence on her and that he was an alcoholic. See Exhibit
+"A". In addition, on 9/20/04, a battery report was filed involving Jane Doe #4 and Mr.
+Vinyard in reference to an argument where he grabbed her by the neck and began spitting
+on her and calling her a cheater. Jane Doe #4 also tried to bite Mr. Vinyard. See Exhibit
+"B". Next, a repeat domestic violence case was filed on 9/21/04 and was closed on a
+Final Judgment for Protection Order on 10/6/04. Apparently, Mr. Vinyard was
+physically and verbally abusive to Jane Doe Number 4. See Exhibit "C". On 10/6/04,
+an Order of Protection was issued against Vinyard and was enforce until 10/6/05. See
+Exhibit "D". Mr. Vinyard was also arrested on 12/24/03 and charged with reckless
+driving and leaving the scene of an accident with damages after he and Jane Doe #4 hit a
+tree and fled the scene after leaving a party. See Exhibit "E". On 10/31/04, officers
+entered Jane Doe #4's home in connection with a disturbance between her and Mr.
+Vinyard. Officers found Jane Doe #4 without a top on and advised her to get dressed;
+5
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 6 of 14
+however, she kept yelling at police demanding that they leave her house. See Exhibit
+"F". On 11/31/04, Mr. Vinyard was arrested for violation of domestic violence
+injunction order for repeat violence against Jane Doe #4. Apparently, Jane Doe #4 and
+Vinyard were arguing in a cab over not having money to pay the fair and Mr. Vinyard hit
+Jane Doe #4. See Exhibit "G".
+10. In addition, Jane Doe Number #4 advised Dr. Kliman that her boyfriend
+(Chris) died in a car accident involving a DUI and her best friend (Jen) died in an
+automobile accident involving drinking. See Exhibit "H." In 2003, Jane Doe #4 sought
+counseling because of a dysfunctional home situation, particularly with her father.
+Finally, Jane Doe #4 described herself as angry, bitter, disliking herself, depressed, and
+having problems with her body image - all pre-Epstein. See supra.
+11.
+Clearly, Mr. Vinyard is a person Epstein is entitled to interview by and
+through his investigators. Mr. Vinyard was contacted and he provided information to
+Epstein's investigators. The telephone interview lasted approximately 20 minutes, and
+Mr. Vinyard ended the telephone call and offered to call investigators back. To date, Mr.
+Vinyard has not contacted the investigators.
+(ii)
+The Declaration of Y.B., Jane Doe #4's Sister
+12.
+On August 8, 2009 at approximately 2:40 p.m., investigators visited with
+Y.B. and her husband at their Port St. Lucie address. Epstein's investigators announced
+that they wished to speak to Y.B. about Jane Doe #4, and provided Y.B. a state issued
+private investigator's license and business card. Y.B. stated that she would have to
+speak to Jane Doe #4 before discussing anything with the investigators. Y.B. appeared
+more concerned with how investigators obtained her public address because Y.B. thought
+6
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 7 of 14
+her address was non-public due to her husband's position of employment, which
+appeared to be with a particular fire department. Investigators asked Y.B to discuss her
+sister, Jane Doe #4; however, at approximately 2:49 p.m., Y.B. abruptly ended the
+conversation and led her husband back inside the home. Nothing further was discussed,
+and nothing was revealed during this nine (9) minute conversation.
+(ili) The Declaration of Jane Doe #7
+13.
+Jane Doe #7's declaration is telling. First, she lists several questions that
+investigators allegedly asked three of her friends:
+(a) Was she promiscuous in high school;
+(b) What was her reputation in high school;
+(c) How many guys has she been with;
+(d) Did she date older, rich guys;
+(e) Did she give massages for money; and
+(f) Who were her friends in high school and what is their contact information
+14.
+Clearly, the above questions are basic background questions and cannot be
+limited without violating Epstein's constitutional due process rights to defend himself.
+15.
+Next, Jane Doe #7 claims that investigators mentioned
+but
+fails to state what references were made relative to
+Is it Jane Doe #7's
+contention that investigators cannot ask others whether they ever heard of !
+Such a contention would be silly given the fact that Jane Doe #7 herself makes
+allegations regarding
+in paragraph 13 of her Amended Complaint.
+Therefore, it is imperative know whether Jane Doe #7 ever spoke about |
+and, if so, what did Jane Doe #7 say about
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 8 of 14
+affidavit tells a different story; that is, Jane Doe #7 approached her at a local bar and
+discussed Jeffrey Epstein with her in a public forum, i.e., Jane Doe #7 discussed her
+lawsuit with
+in public, with others. See Exhibit "I",
+Affidavit.
+Even so, an elementary review of the alleged questioning by the investigators as set forth
+in Jane Doe #7's declaration shows that same is relevant and may lead to the discovery of
+admissible evidence. Surely, Jane Doe #7 is not being heard to argue that information
+concerning
+is not relevant to this action when her complaint makes
+allegations to the contrary.
+16. Moreover, on October 4, 2005, Jane Doe #7 gave a taped interview to the
+police under oath, which directly conflicts with the allegations in her Amended
+Complaint Exhibit "J". In that police interview, Jane Doe # 7 stated:
+(a)
+that she was introduced to Epstein by
+(b)
+(c)
+that she went to Epstein's home with
+the first time;
+that she gave Epstein a massage with her clothes on the second time she
+visited the home;
+(d)
+that she only went to Epstein's home 2 times;
+(e)
+that when she massaged Epstein he was not naked and he never removed
+his towel;
+(f)
+that she did not touch his private areas and he did not ask her to do same;
+(g)
+that he did not touch her in her private areas; and
+(h)
+that after the second trip to the home she never went back.
+17.
+Contrast the above with the allegations in the Amended Complaint:
+(a)
+Paragraph 13 - during the first massage, Epstein "sexually assaulted" her
+and "masturbated;"
+(b)
+Paragraph 14 - Jane Doe #7 "...returned on many occasions to the Palm
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 9 of 14
+Beach mansion to provide Epstein with massages for money. On those occasions,
+Epstein engaged in sexual contact and activity with Jane, which included, among
+other things, Epstein touching [her] breasts, placing a vibrator on her vagina and
+masturbating himself.
+This sexual abuse continued over a period of
+approximately 18 to 24 months."
+18.
+In her answers to interrogatories, Jane Doe #7 states that she went to the
+Palm Beach Mansion 8 to 10 times and that she brought friends on 2 separate occasions
+and was paid $200 per friend, each of which directly conflicts with the statement she
+gave to police. See supra.
+19. As to Dr. Kliman, Jane Doe #7 told him that she came back to the home
+for a second massage with Epstein, and Epstein asked if he could see her bra and asked
+questions regarding her sex life. She also told Dr. Kliman that during this second
+massage, she took her shirt off, gave him a massage in her bra and that he masturbated
+under a towel. She also stated that she believes she visited Epstein 8 times and that the
+last time or one of the last times she went there Epstein was aggressive, grabbed her butt,
+tried to feel parts of her body, pulled her bra down, exposed her nipples and touched her
+breasts which, once again, is in direct conflict with what Jane Doe #7 told police under
+oath.
+20.
+Based upon the foregoing, it is clear that the basic questions asked of the
+three non-parties were relevant and reasonably calculated to lead to the discovery of
+admissible evidence.
+Moreover, whether any of the individuals ever heard of
+by and through Jane Doe #7 is also relevant in that any information obtained may
+also lead to the discovery of admissible evidence, which may contradict the allegations
+Jane Doe #7 has made against Epstein much like Jane Doe #7 contradicts herself in the
+statements she made to police and the allegations she subsequently made in the Amended
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 10 of 14
+Complaint.
+(iv)
+The Declaration of Jane Doe #6
+21.
+Jane Doe #6's declaration requests that Epstein not speak to Jane Doe's
+former employers relative to her background. However, Jane Doe # 6's background is
+directly relevant to this action and the damages she seeks to recover from Epstein. For
+instance, according to interrogatory answer number 7, Jane Doe #6 was diagnosed with
+PTSD following a car accident in 2003. On 4/10/05, Jane Doe #6 witnessed a friend
+enter all, transformer box, play with the wires and electrocute himself. See Exhibit
+"K". On 4/13/06, Jane Doe #6's mother made a child abuse report, and advised police
+that Jane Doe #6 and her father had been smoking marijuana together since she was 13.
+See Exhibit "L" Jane Doe #6's mother told police that she tried to help Jane Doe #6 by
+placing her in Growing Together Treatment Program on 3/10/06 and by having her Baker
+Acted on 4/7/06. See Exhibit "L" Then, on 12/22/06, Jane Doe #6 and her then
+, got into an argument and he went out into the street and put a
+boyfriend, James
+gun to his head and killed himself. See Exhibit "M".
+22. On 1/31/07, Jane Doe #6 pled guilty to grand theft and burglary, and she
+pled guilty and was sentenced to a 30 day substance abuse program, 9 months community
+control and 2 years probation. See Exhibit "N". On 3/09/07, Jane Doe #6 was arrested
+and on 3/20/07 was ordered to undergo a mental health evaluation. See Exhibit "O"
+On 4/10/07, she was ordered to 32 days in jail and community control until 11/1/07 with
+probation for 2 years. See Exhibit «p". On August 8, 2007, she was arrested for
+possession of drug paraphernalia and violated her probation. See Exhibit "Q".
+23.
+Based upon the foregoing and the allegations in the Amended Complaint,
+10
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 11 of 14
+investigating Jane Doe #6's background is directly relevant to this action as it relates to
+her medical, psychiatric, social and family histories and the damages she seeks to
+recover.
+(v)
+Brief Conclusion
+24.
+Here, the number and scope of damages claimed are vast. Preventing
+Epstein from investigating this case and the claims made concerning some of the pivotal
+issues in this case would work an injustice by preventing Epstein from being able to
+defend himself. Even the ASAO contemplated that Epstein "...could fight the damages
+portion [of a lawsuit], which means that, of course, he would be entitled to depositions; of
+course, he would be entitled to take discovery..." and investigate claims. See Exhibit
+"R", pp. 33-34, June 12, 2009 Transcript.
+Wherefore, Epstein requests that this court enter an order denying Jane Doe's 2-7
+Motion for Protective Order which seeks to prevent Epstein from investigating the claims
+made against him and the individual Jane Does that make those olaims and for such other
+and further relief as this court deem just and proper.
+By: -
+MICHAEL I. PIKE, ESQ.
+Florida Bar #617296
+11
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 12 of 14
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is
+do are point y Me died dentistep lovine Service Lis in
+Respectfully submitted,
+By: =
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER &
+515 N. Flagler Drive, Suite 40(
+Vest Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+12
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 13 of 14
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+Brad 1
+Esq.
+Rothstein Rosenfeldt Adler
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, FL 33301
+Phone: 954-522-3456
+Fax: 954-527-8663
+bedwards@rra-law.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiffs
+In related Cases Nos. 08-80069, 08-80119,
+08-80232,
+. 08-80380, 08-80381, 08-80993,
+Paul G. Cassell, Esq.
+08-80994
+Pro Hac Vice
+332 South 1400 E, Room 101
+Richard Horace Willits, Esq.
+Richard H. Willits, P.A.
+2290 10# Avenue North
+Suite 404
+Lake Worth, FL 33461
+561-582-7600
+Fax: 561-588-8819
+Counsel for Plaintiff in Related Case No.
+08-80811
+reelrhw@hotmail.com
+Salt Lake City, UT 84112
+801-585-5202
+801-585-6833 Fax
+cassellp@law.utah.edu
+Co-counsel for Plaintiff Jane Doe
+Isidro M. I
+Esq.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+_Esq.
+Counsel for Plaintiff in Related Case No.
+Searcy Denney Scarola Barnhart & Shipley,
+08-80469
+P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+561-686-6300
+Fax: 561-383-9424
+jsx@searcylaw.com
+jph@searcylaw.com
+Counsel for Plaintiff, C.M.A
+Robert C. Josefsberg, Esq.
+Katherine W. Ezell, Esq.
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami. FL 33130
+305 358-2800
+Fax: 305 358-2382
+tjosefsberg@podhurst.com
+kezell@podhurst.com
+13
+
+
+Case 9:08-cv-80119-KAM Document 291 Entered on FLSD Docket 09/08/2009 Page 14 of 14
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant:
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold-Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+Counsel for Plaintiff in Related Case No.
+08-08804
+skuvin@riccilaw.com
+tleopold@riccilaw.com
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+14
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/fba08872e63459282f7011fc6ce758bb702b9cc850ce861cb1ad5a8f4c694166.md b/vision-fixhub/court-01/fba08872e63459282f7011fc6ce758bb702b9cc850ce861cb1ad5a8f4c694166.md
new file mode 100644
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+++ b/vision-fixhub/court-01/fba08872e63459282f7011fc6ce758bb702b9cc850ce861cb1ad5a8f4c694166.md
@@ -0,0 +1,9775 @@
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 1 of 47
+1
+2
+3
++ in
+6
+7
+8
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+11
+12
+13
+14
+15
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 308
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+- VS-
+JEFFREY EPSTEIN,
+Defendant.
+VOLUME III OF III
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF
+JANE DOE NO. 4
+Tuesday, October 27, 2009
+11:11-6:05 p.m.
+250 Australian Avenue South
+Suite 115
+West Palm Beach, Florida 33401
+Reported By:
+Cynthia
+• RPR, FPR
+Notary Public, State of Florida
+Prose Court Reporting
+PROSE COURT REPORTING AGENCY, INC.
+cctec48b-651e-487e-8bb1-b2f478ed0edd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 2 of 47
+2
+3
+5
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+10
+11
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+13
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+20
+21
+22
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+21
+22
+23
+24
+25
+Page 309
+APPEARANCES:
+On behalf of the Plaintiff, L.M. and E.W.:
+MICHAEL J. WHEELER, ESQUIRE
+ROTHSTEIN, ROSENFELDT, ADLER
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, Florida 33301
+Phone: 954.522.3456
+On behalf of Jane Does 1 through 8:
+ADAM D. HOROWITZ, ESQUIRE
+STUART S. MERMELSTEIN, ESQUIRE
+MERMELSTEIN & HOROWITZ, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, Florida 33160
+Phone: 305.931.2200
+E-mail: Ahorowitz@/sexabuseattorney.com
+On behalf of C.M.A.:
+RICHARD HORACE WILLITS, ESQUIRE
+RICHARD H. WILLITS, P.A.
+2290 10th Avenue North
+Suite 404
+Lake Worth, Florida 33461
+Phone: 561.582,7600
+(Via Telephone)
+Page 311
+BORN, TE, SURER & COLEMAN, LP
+Vest Palm Beach, Florida 3340
+hone: 561.842.283
+ALSO PRESENT: Jeffrey Epstein, via video confereno
+Jeff ||||, Videographer
+Visual Evidence, Incorporated
+1
+2
+*
+***
+CONTINUED DIRECT EXAMINATION
+THE VIDEOGRAPHER: It is the beginning of
+4
+Tape Number 3. We're back on the record at
+5
+6
+4:19.
+7
+BY MR. LUTTIER:
+Q. All right. When did you have your first
+8
+abortion?
+9
+A. Sixteen.
+10
+Q. Which would have been -- what year was
+11
+that?
+12
+A. I think it was, I don't remember, but I
+13
+think it was when I was 16.
+14
+Q. Let's see, you were a senior --
+15
+16
+A. A sophomore.
+Q. - you were 17 when you were a senior,
+17 right?
+18
+A. It might have been my sophomore or junior
+19
+year. I don't remember.
+20
+Q. Sophomore or junior year in high school?
+21
+A. Yeah.
+22
+Q. And where did you have that abortion?
+23
+A. I don't remember what the place was
+24
+called, The Pres -- Pres --
+25
+Q. Presidential Women's Clinic?
+Page 310
+Page 312
+INDEX
+WITNESS:
+DIRECT CROSS REDIRECT RECROSS
+JANE DOE NO. 4
+CONTINUED
+BY MR. LUTTIER 311
+EXHIBITS
+- -
+
+DESCRIPTION
+PAGE
+DEFENDANT'S EX. 1 Proposal for Settlement
+72
+DEFENDANT'S EX. 2 Answers to Interrogatories 232
+DEFENDANT'S EX. 3 Petition for Injunction
+348
+DEFENDANT'S EX. 4 Handwritten Note
+384
+DEFENDANT'S EX. 5 Psychological/Social History 394
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+A. Yeah, I think so.
+Q. Over on Congress Avenue?
+A. Yeah.
+Q. And did you register under your real name?
+A. Yeah.
+Q. Did anybody go with you?
+A. Yeah.
+Q. Who?
+A. Preston.
+Q. And who was the daddy of that baby?
+A. Preston.
+Q. And who paid for it?
+A. Preston.
+Q. Do you know what it cost?
+A. $300, I think.
+Q. Was that the first time you were pregnant?
+A. Yeah.
+Q. And would you agree with me, that age 16
+to have to go have an abortion was traumatic to you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. When was your second abortion?
+A. In my senior year in high school.
+Q. That was when you were 17?
+2 (Pages 309 to 312)
+Electronically signed by cynthi
+lectronically signed by cynthi
+cc1ec48b-651e-487e-8bb1-b2f47Bed0edd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 3 of 47
+9
+10
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+20
+21
+22
+23
+24
+25
+Page 313
+A. Yes.
+Q. And where did you get that one?
+A. Same place.
+Q. You registered under your real name?
+A. Yes.
+Q. Did anybody go with you?
+• Yes.
+Q. Who?
+A.
+Preston.
+Q. Who was the daddy?
+A.
+• Preston.
+Q. Who paid for it?
+A. Preston.
+Q. Now, I, I assume at some point in your
+life somebody explained to you what birth control
+was.
+A. Yeah.
+Q. After you aborted one child, didn't you
+use birth control to keep from getting pregnant?
+A. Yeah, I did. I was using birth control.
+Q. And so, obviously, if you had the baby,
+your first baby if you were pregnant at 16 --
+A. I wasn't using birth control then.
+MR. MERMELSTEIN: How about letting him
+finish. Let him finish.
+1
+2
+3
+4
+5
+6
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+Page 314
+BY MR. LUTTIER:
+Q. If you were pregnant at 16, would you,
+would you agree with me that you had begun your
+sexual relations with, at least with Preston, when
+you were 15 --
+MR. MERMELSTEIN: Objection, asked --
+BY MR. LUTTIER:
+Q. - at least?
+A. No.
+MR. MERMELSTEIN: Asked and answered.
+BY MR. LUTTIER:
+Q. Did you get pregnant the first time you
+had sex?
+A. No.
+Q. Had you been having sex with Preston for a
+while before you got pregnant?
+A. I don't remember. I know we were dating
+for a while. I don't remember - I don't - I don't
+know.
+Q. Prior to having sexual intercourse with
+Preston, did you have other types of sex with him?
+Specifically did you have oral sex with Preston?
+MR. MERMELSTEIN: I'm going to object.
+This applies to our Rule 412 objection. Don't
+answer the question.
+1
+2
+3
+5
+6
+7
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+Page 315
+BY MR. LUTTER:
+Q. Did you have -- do you know a guy named
+Mister - a guy by the name of Morales, last name
+Morales?
+A. Yes.
+Q. Did you have oral sex with him?
+MR. MERMELSTEIN: Don't answer the
+question.
+BY MR. LUTTIER:
+Q. When you -- how old were you when you --
+MR. MERMELSTEIN: Same objection.
+BY MR. LUTTIER:
+Q. How old were you when you knew
+Mr. Morales?
+A. I was in middle, or middle school.
+Q. What, middle school?
+A. Yeah, I know him.
+Q. Middle school?
+A. Yeah.
+Q. Do you know a John Vilanto (phonetic)?
+A. Yeah. They were best friends.
+MR. MERMELSTEIN: The question is, do you
+know him.
+THE WITNESS: Yeah.
+Page 316
+BY MR. LUTTIER:
+• And do you know what the relationship
+between John Vilanto and Mr. Morales was?
+A. Friends.
+Q. Okay. They pals or pal around together?
+A. Friends.
+Q. You knew them both?
+A. Yeah.
+Q. Did you have oral sex with both of them?
+MR. MERMELSTEIN: Don't -- again, Rule 412
+objection. Do not answer that question.
+BY MR. LUTTIER:
+Q. And, and did you associate with either of
+these individuals once you got to high school?
+A. Yeah.
+Q. Did you have oral sex with Mr. Morales
+and/or Mr. Vilanto before you went to see
+Mr. Epstein?
+MR. MERMELSTEIN: Objection, Rule 412. Do
+not answer that question.
+BY MR. LUTTIER:
+Q. Do you know a fellow by the name of Joey?
+A. That's Joe Morales.
+Q. Okay. Did you have sexual intercourse
+with either Mr. Morales or Mr. Vilanto at any time?
+3 (Pages 313 to 316)
+cc1ec48b-651e-487e-Bbb1-b21478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 4 of 47
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+MR. MERMELSTEIN: Objection, Rule 412. Do
+not answer that question.
+BY MR. LUTTIER:
+Q. Did you have sexual intercourse with
+Mr. Morales or Mr. Vilanto before you went to see
+Jeffrey Epstein?
+MR. MERMELSTEIN: Objection, Rule 412. Do
+not answer the question.
+BY MR. LUTTIER:
+Q. All right. When did you have your third
+abortion?
+A. Sophomore or junior year in college.
+Q. That would be, let's see, you started in
+'05; so you started in August '05 through June of
+'06 would have been your freshman year, right?
+A. (No verbal response.)
+Q. Right?
+A. Sophomore, Sophomore year.
+Q. So -
+A. Sophomore year in college.
+Q. - it would have been sometime between
+August of '06 -
+A. And '07.
+Q. - and June of '07?
+A. Yeah.
+1
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+Page 318
+Q. Okay. When was it in that period?
+A. I don't remember.
+Q. Well, was it '06 or '07?
+A. I don't -- '06. I don't remember. I
+don't remember.
+Q. Okay. And where did you have that
+abortion?
+A. Same place.
+Q. And anybody go with you?
+A. Lauren.
+Q. Who was the dad of that child?
+A. Preston.
+Q. So, at least through '06 you were still
+having sex with Preston?
+A. Yeah.
+Q. Who paid for it?
+A. Preston.
+Q. Did you tell him that he was the dad?
+A. Yeah.
+Q. What did he say?
+A. He knew.
+Q. And this would have been the third time
+you were pregnant by the same guy?
+1
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+Page 319
+A. Yeah.
+Q. Were you using birth control?
+A. Yeah.
+Q. Okay. When was the -- let's see, that was
+the last abortion?
+A. Yeah.
+Q. Now, in addition to the abortions, were
+you getting prescriptions for what they call the
+Morning After pill?
+A. Yeah.
+Q. Okay. And how many times did you get
+prescriptions for that?
+A. Probably like four times.
+Q. And on each of those occasions, were you
+successful in avoiding pregnancies?
+A. Yeah.
+Q. Do you recall when you got the four
+prescriptions for -
+A. No.
+Q. - the Morning After?
+A.
+• No.
+Q. And who did you get the scripts from?
+A. My doctor.
+A. What doctor?
+Page 320
+Q. The same doctor each time?
+A. Yeah.
+Q. Do you-
+A. Maybe once, I don't even, no -- yeah.
+Q. Well, did you?
+MR. MERMELSTEIN: Be certain of your
+answer.
+BY MR. LUTTIER:
+Q. Yeah, take your time.
+A. Yeah, I think so. Yeah. I think maybe
+Planned - a total of maybe -- Planned Parenthood
+may be one before I went to
+. I don't
+remember.
+Q. Okay.
+A. I am just saying just in case because I
+know they were offering it, but I don't think - I
+don't know.
+MR. MERMELSTEIN: Make sure you're sure of
+your answer before you give it. If you need to
+pause for a minute after the question is asked,
+do so, but make, make sure you're -- you know,
+before you blurt out your answer, make, make
+sure you, you recall correctly. Okay?
+BY MR. LUTTIER:
+Q. So, it's possible that you might have
+4 (Pages 317 to 320)
+•PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
+cc1ec48b-651e-487e-8bb1-b2f478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 5 of 47
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+1
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+gotten some from Planned Parenthood, and you know
+2 you got some from
+A. Yeah.
+Q. Those are the only two that you can
+recall?
+A. Yeah.
+And where did you fill the scripts, or did
+you fill them right there?
+A. There. What you mean, there?
+Q. Well, you've got to get the actual -
+A. No, Walgreen's.
+Q. Okay. Is that where you fill all your
+scripts?
+A. Yeah.
+Q. And which Walgreen's?
+A. The one closest to me.
+Q. Where is that?
+A.
+Once I'm leaving the store, or I don't
+know, anywhere in
+| Palm.
+Q. Well, which, which -- is it one in
+Palm or one near vour
+|| University?
+A. No, I went to one off of
+Palm Beach
+Boulevard.
+Q. Is that the only Walgreen's you've filled
+scripts at?
+1
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+A. No. There's other Walgreen's. I just
+don't remember where. I know that I've gone to
+other Walgreen's though.
+Q. Which scripts have you had in the last
+five - well, what scripts have you had since 2003
+other than for the Morning After pill?
+A. Valtrex.
+Q. Valtrex?
+A. Yeah.
+Q. V-a-I-t-r-a-x [sic]?
+A. Yeah.
+Q. And what's that for?
+A. Genital herpes.
+Q. That's -- do you have herpes?
+A. No.
+Q. Have you ever had herpes?
+A. I was scripted for it. I was given
+medicine for it, but I've never had the outbreaks.
+I've never gotten any, like, medicine. Yeah. What
+do you want -- what are you asking me?
+Q. The question was have you ever had herpes?
+A. No.
+Q. As a matter of fact, you went to the
+doctor because you had lesions on your vagina,
+didn't you?
+1
+2
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+| 18
+19
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+Page 323
+A. Yeah.
+Q. And the doctor told you you had herpes,
+didn't she?
+A. Yeah, but I got -- yeah.
+Q. And she said you were at the end of an
+outbreak, didn't she?
+A. No. Well, yeah, she told me that, but I
+have never had anything after that, and I've gotten
+tested after that.
+Q. Well, she gave you Acyclovir at that time,
+didn't she?
+A. No. She gave me a script of Valtrex.
+Q. And she -- and you, and do you still take
+the Valtrex?
+A. No.
+Q. And she told you, did she not, when she
+diagnosed you, that the disease can become dormant.
+A. Yeah.
+Q. And she told you --
+A. What do you mean dormant? Dormant is like
+with -
+Q. Dormant. You don't have any lesions. You
+don't have any signs of the disease.
+A. No. I mean, I don't remember what she
+told me, but I remember reading about stuff like
+Page 324
+information about it.
+Q. So, when you were asked if you had a
+sexually transmitted disease, the answer is, yes,
+you have, right?
+A. Yeah, but like --
+Q. Right?
+A. Yeah.
+Q. But you haven't been telling the doctors
+that you had a sexually transmitted disease, have
+you?
+A. I haven't had an outbreak and I haven't
+been, like, I know -- okay. Yeah.
+Q. You've been lying to your doctors, right?
+MR. MERMELSTEIN: Objection, form.
+Objection, argumentative.
+BY MR. LUTTIER:
+Q. You've been lying to your doctors?
+A. Yeah.
+MR. MERMELSTEIN: Objection, argumentative
+again.
+BY MR. LUTTIER:
+Q. Is that correct?
+A. Yeah.
+Q. Who did you get the herpes from?
+A. The one person that I was sleeping with.
+5 (Pages 321 to 324)
+cc1ec48b-651e-487e-8bb1-b2f478edDedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 6 of 47
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+Q. Well, who is that?
+1
+A. I don't remember.
+A. Preston.
+Q. Are you sure you got it from him?
+2
+Q. Well, that was before you got pregnant
+3
+A. Yeah.
+4
+right?
+A. Yeah. Could have been like when I was 16.
+Q. When -- did you confront him about that?
+5
+Q. Okay. So 15 or 16?
+A. When? I don't remember. I am sure.
+6
+Q. Do you remember when you got the herpes?
+MR. MERMELSTEIN: Objection to form,
+7
+argumentative.
+A. Yeah.
+8
+BY MR. LUTTIER:
+Q. Still in high school at the time?
+9
+A. Yeah.
+11
+MR. MERMELSTEIN: Objection to form.
+Q. Before you got pregnant the first time?
+10
+Q. One of those two?
+BY MR. LUTTIER:
+A. I don't remember.
+12
+remember if it was before your first pregnancy?
+13
+Q. Did you tell your dad you had been
+Q. Do you remember if it was -- you don't
+14
+sexually active and you got a sore on your vagina?
+A. Yeah.
+A. No. Yeah, it was.
+15
+Q. Or your vulva, actually, would be
+Q. Okay. And tell me about how you, how you
+found out that you had herpes.
+16
+17
+technically correct.
+MR. MERMELSTEIN: Objection to form.
+A. I was on, I was in Pennsylvania with my
+18
+BY MR. LUTTIER:
+parents, and I told my dad about it. And when I
+19
+Q. Correct?
+came home they - my dad made me an appointment with
+my gynecologist.
+20
+A. Yeah.
+21
+MR. MERMELSTEIN: Objection to form.
+Q. Did you tell your dad? Did you tell him
+22
+BY MR. LUTTIER:
+that you had some symptoms; is that what you told
+23
+him?
+Q. And was that embarrassing to you?
+24
+A. Yeah. Well, I didn't know what it was so,
+A. No, I told my dad about what was, what,
+25
+yeah.
+Page 326
+like, what was happening, like about like the sores
+down there. So my dad was concerned, and when we
+came back to the States, he made a gynecologist
+appointment for me, him and my mom.
+Q. Did you, did you tell your dad before your
+mom?
+A. I told them at the same time. I was on a
+vacation with them.
+Q. Okay. And so you told - what did you
+tell them?
+A. Nothing. I told them, like, I didn't know
+what was going on with my body. I've never
+experienced anything like that, so I told them,
+look, I said that there's a sore down there. It
+doesn't look right, and I don't know what it's from.
+And my dad made an appointment for me.
+Q. Did you tell him you had been having sex
+with people?
+A. Yeah, I told my dad about Preston.
+Q. Was that the first time you told him that
+you had been having sex?
+A. No, my dad - no.
+Q. How old were you at that time?
+A. No, I don't remember.
+Q. Fifteen?
+1
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+Q. I mean, it must have been embarrassing for
+a 16-year-old girl to say to her dad, gee, I've got
+sores on my vagina, dad.
+A. Yeah.
+Q. Did it take a lot of courage for you to
+tell him that?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah, me and my dad are
+close.
+BY MR. LUTTIER:
+Q. Did you -- did he -- had you told him
+prior to that or before that occasion that you had
+been sexually active with men?
+A. I told him, yeah.
+Q. When did you first tell your dad you were
+being sexually active with men?
+A. Well, I think my dad kind of -- they - I
+think my dad asked me, and I told him the truth.
+Q. This was when?
+A. I don't remember.
+Q. At 15, at 14, at 12?
+A. I don't remember.
+Q. When did you first become sexually active?
+MR. MERMELSTEIN: Objection to the form.
+It's been asked and answered so many times
+6 (Pages 325 to 328)
+ccfec48b-651e-487e-8bb1-b2f478edDedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 7 of 47
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+Page 329
+already.
+BY MR. LUTTIER:
+Q. Just an age is all I'm looking for.
+A.
+I don't remember. I've already told you.
+Q. How long were you sexually active before
+you told your dad you were sexually active?
+A. I don't remember because I don't remember
+when my dad told me.
+Q. You were telling your dad, remember?
+A. Yeah, when I asked -- when I told my dad,
+sorry.
+Q. Did you - you've had a couple of
+boyfriends since then, right?
+A. Yeah.
+Q. Did you tell these other boyfriends that
+you had herpes?
+A. Yeah. Well, yeah.
+Q. Are you sure?
+A. Yeah.
+Q. Tell your current boyfriend you had
+herpes?
+A. Yes.
+e. Have you had oral sex with your current
+boyfriend?
+4
+5
+MR. MERMELSTEIN: Objection, Rule 412. Do
+7
+8
+9
+10
+11
+12
+13
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+Page 330
+not answer that question.
+1
+BY MR. LUTTIER:
+2
+Q. Did you tell the baseball player you're
+3
+dating down at
+that you had herpes?
+4
+A. Yeah.
+5
+Q. How about Jeffrey Epstein; did you tell
+6
+him you had herpes?
+7
+A. No.
+8
+Q. Didn't bother to let him know, did you?
+9
+A. Never asked.
+Q. Well, did all these other boys that you
+10
+11
+were out with -
+12
+A. I didn't have sex with him.
+13
+Q. Did all these other boys that you were out
+14
+with ask if you had herpes?
+15
+MR. MERMELSTEIN: Objection.
+16
+THE WITNESS: No, I've never, like gone
+17
+out with - no, I mean --
+18
+BY MR. LUTTIER:
+19
+Q So, if I, if I understand your testimony
+20
+correct, during the period of time that you were
+21
+going to Jeffrey Epstein and giving him massages, at
+22
+the same time you were having sex with Preston and
+|23
+you had three abortions?
+24
+A. Yes.
+25
+Page 331
+Q. All simultaneously?
+MR. MERMELSTEIN: Just listen to the --
+THE WITNESS: Wait.
+MR. MERMELSTEIN: Listen to the question
+that he -- make sure you listen -- before you
+answer, make sure you listen to the question
+and answer it.
+Can you read back -
+THE WITNESS: Sorry.
+MR. MERMELSTEIN: -- the prior question?
+(The requested portion of the record was
+read by the reporter.)
+MR. MERMELSTEIN: Well --
+THE WITNESS: What is --
+BY MR. LUTTIER:
+Q. If you need to correct something, go
+ahead. There's no tricks here.
+A. Yeah, can you ask the question one more
+time?
+MR. MERMELSTEIN: We'll go to the first
+question there and answer. I just wanted to
+make sure you think about it before you blurt
+it out.
+BY MR. LUTTIER:
+Q. Is the answer, correct? If you want to
+Page 332
+change it, go ahead and change it if it's wrong.
+I'm not trying to trick you or anything. You had
+three, while you were going to see Jeffrey Epstein
+and giving his - giving him these massages, during
+that same period of time you had three abortions
+with Preston as the father, right?
+A. No, not a third one.
+Q. Two of them were, were while you were --
+A. Yeah.
+Q. Okay. Now --
+MR. MERMELSTEIN: That's why you have to
+be careful when you're answering the question.
+Make sure you understand the question, and,
+and, and think about it before you answer it.
+Okay?
+THE WITNESS: Uh-huh.
+BY MR. LUTTIER:
+Q. Now, your parents know about this lawsuit,
+right?
+A. Yeah.
+Q. Did you tell your parents about the
+lawsuit before you filed it?
+A. Yes.
+Q. Does your sister know about the lawsuit?
+A. Yes.
+7 (Pages 329 to 332)
+cc1ec48b-651e-487e-8bb1-b2147BedOedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 8 of 47
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+Q.
+Did you tell her before you filed it?
+A.
+No.
+Q. And why did you tell your sister?
+A. Why didn't I?
+Q. Why did you?
+A. Because it was something I didn't - well,
+something that I thought she should know.
+Q. Now, you mentioned that in
+Palm
+Beach there's a close group of all you girls that
+were going to see Mr. Epstein; is that right?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. Correct? You said all of you were, that
+you went to school together and you were all
+friends?
+A. I wasn't friends with everyone that went
+there, no.
+Q. Okay. But, but all the girls that went to
+Epstein that you know, they all know you filed this
+lawsuit, right?
+A. I don't know.
+Q. People down at
+University know you
+filed the lawsuit, right?
+A. No.
+Q. Well, didn't they come to the
+Lof
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+Police to interview you?
+Yeah, they went -- well, then, yeah, the
+knows.
+Q.
+Okay. And, then, weren't you babysitting
+or taking care of the
+child or something
+during the summer?
+I did, I worked at Pine Tree Camp. She
+was one of my students.
+So, so he knew because the cops came
+1
+5
+6
+7
+8
+9
+and --
+10
+A. I don't know.
+11
+Q. - had to tell him why they were there to
+12
+see you, right?
+13
+I don't know what the cops told him, so I
+14
+don't know what information he knew.
+15
+Q. Well, you eventually told him what was
+16
+going on, didn't you?
+17
+A.
+• No.
+18
+Q. You never told him?
+19
+A. No.
+20
+Q. You never told him you were in the
+21
+lawsuit?
+22
+A. Never. I don't -- no.
+23
+Q. Who else now have you told that you're in 24
+the lawsuit?
+Page 335
+A. My mom and my dad, my sister, my current
+boyfriend.
+Q. Current boyfriend is who?
+A. Ricky.
+Q. Okay.
+A. My ex-boyfriend Alan, and who else -- and
+friends, Jane Doe No. 7, Lauren. That's it.
+Q. Who is your closet friend?
+A. Jane Doe No. 7.
+Q. Okay. So she knows?
+A. Yeah.
+Q. Who's your second-closest friend?
+A. My boyfriend.
+Q. He knows?
+A. Yeah.
+Q. Who's your third-closest friend?
+A. I don't hang out -- I just have a click.
+That's it. That's all. I already told you the
+people that I --
+Q. Is there any -- doesn't everybody that's
+close to you or you're close to know that you filed
+the lawsuit?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: I don't know.
+Page 336
+BY MR. LUTTIER:
+Q. Well, who is it that you consider to be
+very close to you that doesn't know you filed the
+lawsuit?
+A. My -
+MR. MERMELSTEIN: Objection to form. Go
+ahead.
+THE WITNESS: My boyfriend and my family
+and my best friend, which is Jane Doe No. 7.
+BY MR. LUTTIER:
+Q. I thought you said they all knew?
+A. What do you mean?
+Q. My question was who --
+MR. MERMELSTEIN: Be careful.
+THE WITNESS: Sorry.
+BY MR. LUTTIER:
+Q. Who that you're close to does not know
+that you filed this lawsuit, if anybody?
+A. I don't know.
+Q. I mean, the word spread out in
+_Palm
+Beach among the people that live there that these
+lawsuits were filed and that you were involved,
+correct?
+A. Yeah.
+MR. MERMELSTEIN: Objection to form.
+8 (Pages 333 to 336)
+cetec48b-651e-487e-8bb1-b2f478edOedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 9 of 47
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+BY MR. LUTTIER:
+Q. If you went back to your old neighborhood,
+2
+pretty much everybody knows that you are in this
+lawsuit, correct?
+3
+4
+A. Yeah.
+5
+Q. Pretty much everybody knows that these
+6
+other people, Jane Doe No. 7 and these other girls
+7
+are involved in this lawsuit, correct?
+8
+MR. MERMELSTEIN: Objection to form.
+9
+THE WITNESS: I don't, I don't know if
+10
+they know, but if you are the - I don't know
+if they know. I don't know who knows, but I'm
+11
+12
+sure if you go back in l
+Palm, they know
+who used to hang out. And what was it,
+13
+14
+whenever the cop made statements, it's like
+Palm Beach soccer player, well, hmm, like
+15
+16
+who, who in I
+Palm that hung out that was
+17
+acquaintances with Haley played soccer? Well,
+it's kind of commonsense.
+18
+So I don't know who knows and who doesn't
+19
+20
+know, but if I went back to my hometown, people | 21
+aren't idiots.
+BY MR. LUTTER:
+22
+23
+Q. They would --
+24
+A. They would put two and two, two and two
+25
+Page 339
+A. Last weekend. Or, no, not last weekend.
+I don't know, like two weeks ago, maybe.
+Q. You were arrested two weeks ago?
+A. Uh-huh.
+Q. Who were you arrested by?
+A. Jupiter cops.
+Q. What for?
+A. Domestic violence.
+Q. Well, if you were arrested, you must have
+been the person that committed the act of domestic
+violence.
+MR. MERMELSTEIN: Well, you're assuming
+she was guilty.
+BY MR. LUTTIER:
+Q. Someone thought you were --
+A. I can't --
+MR. MERMELSTEIN: It's a presumption of
+innocence, right?
+THE WITNESS: And I can't talk about it
+either. All right?
+BY MR. LUTTIER:
+" 2. Who told you you can't talk about it?
+It's a matter of public record.
+A. I don't know. I don't know.
+Q. So, who told you couldn't talk about it?
+Page 338
+together.
+Q. They know that you filed a lawsuit and
+you're involved in this?
+A. I don't know if they're --
+MR. MERMELSTEIN: Objection to form.
+2
+3
+4
+5
+Calls for speculation. Go ahead.
+THE WITNESS: I don't know.
+BY MR. LUTTIER:
+Q.
+So, who, who that you care about doesn't
+know, if anybody, that you're in this lawsuit?
+A. People that I care about know that I am.
+Q. Okay. Now, you mentioned this current
+boyfriend, Ricky.
+A. Yes.
+Q. What's his last name?
+A. Bullard.
+Q. Bullard. And you are saying he's -- do
+you know whether or not he's a drug dealer?
+A. No.
+Q. You don't know or you're saying he's not?
+8
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+10
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+14
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+A. He's not.
+Q. Okay. And you're sure of that?
+22
+A. Yeah.
+23
+Q. By the way, when's the last time you were 24
+arrested?
+25
+Page 340
+A. Nobody did. I'm just assuming that
+myself.
+Q. So, you were arrested --
+MR. MERMELSTEIN: He can ask you questions
+about it.
+THE WITNESS:
+BY MR. LUTTIER:
+Q. Tell me, this event happened on what day
+of the week?
+A. On a Friday.
+Q. Friday night?
+A. Yeah.
+Q. And, and can we assume that because the
+Jupiter police were summoned, it happened someplace
+in Jupiter?
+A. Yeah.
+Q. And what time did it happen?
+A. Probably like around 1:00.
+Q. A.m.?
+A. Yeah.
+Q. And where did it happen?
+A. Ricky's house.
+Q. Which is where?
+A. In Jupiter.
+Q. Okay. I mean, do you have an address?
+9 (Pages 337 to 340)
+cc1ec48b-651e-487e-Bbb1-b2t47BedOedd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 10 of
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+Page 341
+A. Off Center Street.
+Q. Do you know anything more than Center
+Street? It's a big street.
+A. 249.
+Q. 249 Center Street. Do you live with him?
+A. No.
+Q. Were you staying there?
+A. Yes.
+Q. Do you stay there with any degree of
+regularity?
+A. What do you mean, regularity?
+Q. On any kind of regular basis, like, I go
+up there for the weekends, or -
+A. Yeah.
+Q. Is that where vou go on the weekends when
+you're not down at
+University?
+A. Why would I be at
+University?
+Q. Well, I don't know if you were still
+there. Are you still a student there?
+A. No, I graduated.
+Q. Okay. When did you graduate?
+A. '09.
+Q. June of '09?
+A. May, yeah.
+Q. May? What did you get a degree in?
+1
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+Page 342
+A. Business.
+Q. BA?
+A. What do you mean, BA?
+Q. Business Administration.
+A. Yeah.
+Q. And --
+MR. MERMELSTEIN: A Bachelor of Arts?
+BY MR. LUTTIER:
+Q. Wait. Okay. Business Admin, all right.
+We'll settle for that. Bachelor's Degree in
+Business Administration, right?
+A. Uh-huh.
+Q. How did you do? Did you do well?
+Yeah.
+Q. Do you know what your GPA was?
+A. Like a 3.3 or 3.2.
+Q. And do you have plans to go further with
+your education?
+A. Yes.
+Q. What are your plans?
+A. To get my
+Q.
+A.
+Yes.
+Q. Have you applied?
+• Yes.
+4
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+Page 343
+Q.
+A.
+Where?
+A.
+Been accepted?
+Yes.
+Q. When will you start?
+A. I am not going to go to
+- or I
+was - maybe spring.
+Q. Spring. By the way, you went to
+University undergrad on a scholarship?
+A. Yeah.
+Q. Who paid for this? Who sponsored you?
+Who gave vou the scholarship?
+A.
+• University.
+Q. Okay. Are you going to be scholarshipped
+for your
+?
+A.
+No. I signed up for my graduate
+assistance program.
+vourt So, you plan to teach while you're taking
+A. No, it's where you work for the system.
+for the School Board and they pay for your
+Q
+Okay. And do you have plans after you get
+your
+A. Yeah, to work.
+Q. Okay. And you've got some plan -
+Page 344
+A. Yeah.
+Q. -- kind of a general plan of what you want
+to do in life?
+A. Yeah, yeah, I want to be a school teacher.
+Q. Okay. What level?
+A.
+Kindergarten or kindergarten or second
+grade.
+Q. Okay. Let's go back to this domestic
+violence thing. Had you and your boyfriend been
+someplace on this Friday night when this happened?
+A. At home.
+Q. And were you anyplace earlier that night?
+A. Yeah.
+Q. Where were you?
+A. Noche. (
+Q. Where?
+A. Noche.
+Q. Noche's, is that the name of a bar or
+something?
+A. Yeah.
+Q. Where?
+A. Gardens, downtown Gardens.
+Q. Had you been anyplace else?
+A. Yeah, we went to Ra Bar for dinner.
+Q. Ra Bar, where is that?
+10 (Pages 341 to 344)
+ectronically signed by cynthi
+ectronically signed by cynt
+
+
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+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 11 of
+Page 345
+A. In Gardens.
+Q. Anyplace else?
+A. No.
+Q. Had you been out looking for anybody that
+night?
+A. No.
+Q. Had you been down south to West Palm Beach
+that night?
+A. No.
+Q. Had you been down south to West Palm Beach
+at any time in the week prior to that?
+A. No.
+Q. Okay. So tell me what happened. What was
+the - what, what occurred at this incident that
+occurs at 1:00 at Ricky's house?
+A.
+It was just, it was over something silly.
+I don't - it was -- just got in an argument about
+being out in the beginning of the night.
+Q. What do you mean?
+A. Nothing. It was just, like, like, real --
+being in a relationship you fight over stupid
+things, and whenever he was - I don't know,
+whenever you have alcohol in your system, you know,
+it brings up, like, silly little fights become big
+dramatic.
+1
+2
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+UN A
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+Page 346
+Q. What was the fight about?
+A. Him - I don't know, over a bunch of small
+little silly things about him not eating enough,
+enough food before we went out to not even wanting
+4
+to go out in the beginning of the night to him
+5
+leaving his ID to -- I mean, there's just a bunch of
+small things that built up into one big argument.
+Q. So, did this argument turn physical?
+7
+8
+A. Yeah.
+9
+Q. What happened?
+A. Nothing. I was leaving, or he asked me to
+10
+11
+leave, so I was leaving to go outside of his house.
+12
+And he took my purse from me and wouldn't let me
+13
+leave, so he never wanted me to leave, so he -- so
+14
+then I was like, well, you need to let me leave, so
+15
+he took my car keys out of my purse. After he took
+my car keys out of my purse, he threw my purse out.
+16
+And I went out and I didn't realize I had
+17
+18
+his car keys in my hand, so I went and got all my
+19
+stuff, and I came back and I was, like, look, I
+think you need to give me my car keys, give me my
+20
+21
+car keys - I was like -- I was like give me my car
+22
+keys. It was just fighting about me and him
+23
+leaving.
+24
+MR. MERMELSTEIN: Before you go on, let me 25
+Page 347
+know. You said, I'm sorry, I just realized I
+should ask you, somebody told you not to talk
+about what happened?
+THE WITNESS: Yeah.
+MR. MERMELSTEIN: Was it a lawyer?
+•THE WITNESS: Yeah.
+MR. MERMELSTEIN: All right. I -- I'm
+going to plead the Fifth then. If she's
+already gotten advice by a lawyer, I'm going to
+plead the Fifth.
+MR. LUTTIER: Well, she has to -- she's
+going to --
+THE WITNESS: I'm going to have to plead
+the Fifth. I have a lawyer and I'm not
+supposed to talk about it.
+BY MR. LUTTIER:
+Q. Are you charged with criminal -- a crime?
+A. Yeah, well, the State's picking up -- he's
+not charging - press, he's not press -- charging
+these things, but I'm sure this automatically in
+domestic violence in the State of Florida, they
+automatically - it doesn't get dropped, the State
+automatically picks it up.
+MR. MERMELSTEIN: Is it civil or is it
+criminal?
+Page 348
+THE WITNESS: Civil, I think. I don't
+Know.
+MR. MERMELSTEIN: Well, I'm going to -
+I'm going to --
+BY MR. LUTTER:
+Q. The State attorney -- has the State
+attorney advised you whether they're going to charge
+you or not?
+A. Not - no, I think -- well, I don't know.
+They said that he's not charging me. I have a
+lawyer. Am I allowed to talk about it? I don't
+know.
+MR. MERMELSTEIN: Well, he's not -- if
+your lawyer -- if you could talk about it, you
+should have your lawyer, yeah.
+THE WITNESS: Yeah, I have a lawyer.
+BY MR. LUTTIER:
+Q. Who is your lawyer?
+A. Ira DeCarlin (phonetic).
+Q. Okay. When you say he's not charging me,
+he didn't go get an injunction against -
+A No.
+Q. - domestic violence against you?
+A. No.
+Q. While we're speaking about injunctions
+11 (Pages 345 to 348)
+
+
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+Entered on FLSD Docket 12/01/2009 Page 12 of
+Page 349
+against domestic violence, let me get you something.
+A. I mean, what is that? I don't know.
+MR. MERMELSTEIN: Let him follow up and
+ask a question.
+MR. LUTTIER: Is this Exhibit 3?
+THE COURT REPORTER: Yes.
+MR. LUTTER: Let me just --
+(Defendant's Exhibit No. 3 was marked for
+identification.)
+BY MR. LUTTIER:
+Q. Let me show you what has been marked as
+Exhibit 3 which purports to be a Petition for
+Injunction for a Protection Against Dating Violence.
+And referring to the first page, it says, 1, full
+name, Jane Doe No. 4, do you see the first page?
+A. Yeah.
+Q. All right. Is this, is this handwriting
+on here yours?
+A. Yeah.
+Q. Let's go to the second page. Is this your
+handwriting?
+A. Yeah.
+Q. Third page your handwriting?
+A. Yeah.
+Q. Fourth page?
+1
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+Page 350
+A. Yeah.
+1
+Q. Fifth page?
+2
+A. Yeah.
+3
+Q. Okay. So did you complete this whole
+form?
+4
+5
+A. Yeah.
+6
+Q. And was it true and correct when you
+7
+completed it?
+8
+A. Yeah.
+Q. Those were the representations you were
+9
+10
+making to The Court, right?
+A. Yeah.
+11
+12
+Q. And then you had a hearing? You went to
+13
+court?
+14
+A. Yeah.
+15
+Q. And Preston was there at court, Vinyard?
+16
+A. I don't remember.
+17
+Q. And you got an order that for a year, that
+was an injunction against domestic violence against
+18
+19
+him, correct?
+20
+A. Yeah.
+21
+Q. So he couldn't come around you for a year;
+|22
+isn't that right?
+23
+A. Yeah.
+24
+Q. Okay. Let's take a look at Page 2,
+25
+Page 351
+Section 1. It says down here in section, section
+Roman Numeral III, No. 1, where it says, describe
+the nature of your relationship. It says, January
+1st, 2002, relationship began. That was you writing
+to the court that your relationship with Preston
+Vinyard began January 1st, 2002, correct?
+A. Yeah.
+Q. And then you wrote, July 15th, 2002,
+relationship became intimate. That is you were
+writing to the court, that on July 15th, 2002, your
+relationship with Preston Vinyard became intimate,
+right?
+A. Yeah.
+Q. That's a specific date, July 15th, 2002.
+A. Uh-huh.
+Q. Well, what did you mean when you say,
+relationship became intimate?
+A. I don't know. Kissing, I'm going to say.
+I mean, kissing, holding hands, like, cuddling. I
+don't know.
+Q. Well, what you meant when you wrote this
+was you were having sexual relations with him -
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+THE WITNESS: I don't remember.
+Page 352
+BY MR. LUTTIER:
+Q. Is that true or false?
+A. Yeah.
+Q. Okay. So as of July 15th, 2002, you had
+sexual relations with Preston Vinyard, correct?
+A. No. I don't remember. No.
+Q. Well, why did you write on here intimate?
+A. Intimate -
+MR. MERMELSTEIN: Objection, asked and
+answered.
+THE WITNESS: Intimate, I mean, intimate
+can mean anything, like holding hands. When
+I'm intimate with somebody that means, I mean,
+anybody. I mean, it's not like, it's not sex.
+I don't see where it says, | I became -- had
+started having sex with him. At that time I
+was 15, so intimate meant making out in the
+movies.
+BY MR. LUTTIER:
+Q. Now, do you recall previously you
+testified that about four or five months after you
+first dated Preston Vinyard you began having sexual
+relations with him?
+A. What? Repeat that.
+Q. Do you remember earlier you testified that
+12 (Pages 349 to 352)
+(601-051-978-2934)
+601-051-976-293
+601-051-976-2934
+
+
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+Entered on FLSD Docket 12/01/2009 Page 13 of
+Page 353
+about four or five months after you began dating
+Preston Vinyard, you had sexual relations with him?
+A. Yeah, about four or five months.
+Q. So that would be about the same as this
+time period here from January to July 2002, wouldn't
+it?
+1
+2
+3
+4
+5
+A. Yeah, but, I mean, intimate, like, to me,
+when I was that young, intimate, like, meant like
+going to the movies and making out with your
+boyfriend in the movie theater. Intimate to me back
+then wasn't sexual intercourse.
+Q. Okay. I just want to make sure we're
+clear. I want you to tell the ladies and gentlemen
+of the jury in that camera that when you filled this
+form out that's been marked as Exhibit 3, and you
+wrote July 15th, 2002, relationship became intimate,
+that you didn't mean sexual intercourse. Is that
+right?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. Tell the ladies and the gentlemen of the
+jury that's not what you meant.
+MR. MERMELSTEIN: Objection to the form
+again. Go ahead.
+THE WITNESS: Yeah, that's not what I
+00
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+Page 354
+meant.
+BY MR. LUTTIER:
+Q. Not what you meant. Now, when we ask your
+mom what you meant, what's she going to say?
+MR. MERMELSTEIN: Objection to form.
+That's speculative.
+THE WITNESS: I don't know.
+BY MR. LUTTIER:
+Q. Just coincidental that you ended up
+getting pregnant shortly after this?
+MR. MERMELSTEIN: Speculative. Objection.
+MR. LUTTIER: Can we agree -
+THE WITNESS: Is that a question?
+BY MR. LUTTIER:
+Q. Can we agree you must have had sexual --
+MR. MERMELSTEIN: I think it was.
+BY MR. LUTTIER:
+Q. - intercourse with Mr. Vinyard before he
+got you pregnant?
+A. That what?
+Q. You must have had sexual intercourse with
+Mr. Vinyard before he got you pregnant.
+MR. MERMELSTEIN: Objection,
+argumentative.
+THE WITNESS: Yeah.
+4
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+Page 355
+BY MR. LUTTIER:
+Q. All right. So tell me, if July 15th,
+2002, wasn't when you started having sexual
+relationships with him, or sexual relations, when
+did you start having a sexual relationship with him?
+THE WITNESS: I don't remember.
+MR. MERMELSTEIN: Objection, asked and
+answered.
+BY MR. LUTTIER:
+Q. When was the first time you gave him oral
+sex?
+A. I don't remember.
+Q. When was the first time he stuck his penis
+in you and ejaculated?
+A. I don't remember.
+Q. Was it a significant event -
+A.
+Was that even a question?
+Q. Yeah.
+A. What did you say?
+Q. When --
+A. Can you repeat that question?
+Q. When did he stick his penis in you and
+ejaculate -
+A. I don't remember.
+Q. - in any orifice?
+Page 356
+A. I don't remember.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. But he did that, right, otherwise you
+couldn't have got pregnant. Can we agree with that?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. Can we agree with that?
+A. Yeah.
+Q. So, you still want to stand on your answer
+to the jury that when you said, became intimate, you
+weren't referring to sexual intercourse?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Okay. Now, let's go to Paragraph 6, the
+next page. Can you read out loud what you told the
+court occurred on September the 20th of 2004 at 147
+Riviera Avenue. First it says, respondent, that
+means Preston Vinyard, right?
+A. Hold on. I'm not following what page
+you're on.
+Q. Paragraph 6, Page 3. This is in your
+handwriting, right?
+A. (No verbal response.)
+13 (Pages 353 to 356)
+cctec48b-651e-487e-8bb1-b2f478ed0edd
+
+
+• Entered on FLSD Docket 12/01/2009 Page 14 of
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+Page 357
+Q. Correct?
+A. Uh-huh.
+Q. All right. It says, respondent; that's
+Preston Vinyard, right?
+4
+A. Uh-huh.
+Q. Now, read to the ladies and gentlemen of
+5
+6
+the jury what you wrote occurred on September 20th,
+7
+2004 with Mr. Vinyard.
+A. Preston and I were laying in bed. When a
+8
+9
+guy friend called my cell phone, Preston said that I
+10
+was a slut, whore, cunt that was cheating on, that I
+11
+was cheating on him. Preston started checking,
+12
+checking, I don't even --
+13
+Q. Choking?
+14
+A. - yeah, choking me into the mattress, and
+15
+then when I went into my purse, he threw me against 16
+the wall and started yelling at me. Then Preston
+17
+pushed me out the door. And whenever I asked for
+18
+the rest of my belongings, he told me to wait.
+19
+Whenever he came back, he spilled a beer
+20
+all over and threw cigarettes it in my face and
+21
+slammed me into the ground. I got up. I went to my 22
+car and he followed me.
+23
+Q. And then did you continue it onto the next
+24
+page?
+25
+Page 358
+A. We were --
+1
+Q. No, onto the next page. Turn onto what's
+2
+called a continuation. What else did you write?
+3
+A. Shut my door and he opened it. He spit in
+4
+my face and he continued to call me a whore, a slut,
+5
+and cunt. I shut the door, and he opened it again,
+6
+and he got in my face, grabbed my arms very hard to
+7
+make him let go. I bit his arm. I bit his arm and
+8
+he bit me back on my finger and cut it open. He
+9
+was, he was biting so hard that he was repeating --
+10
+he repeatedly harassed me since last night -- or
+=
+incodent (sic) or incoherent, or incodent. This
+12
+morning when I woke up my top, or my top lip was
+13
+swollen and my neck and jaw were in pain.
+14
+Q. He humiliated you on September 20th, 2004,
+15
+didn't he?
+MR. MERMELSTEIN: Objection to form.
+16
+17
+THE WITNESS: Humiliated me in front of --
+18
+BY MR. LUTTIER:
+19
+Q. He humiliated you, didn't he?
+20
+MR. MERMELSTEIN: Objection to form again.
+21
+THE WITNESS: For what? Is that your --
+22
+BY MR. LUTTIER:
+23
+Q. Do you know --
+24
+A. Is that your opinion?
+25
+Page 359
+Q. Do you know what humiliation is?
+A. Is that your --
+Q. Yes.
+A. Yeah, I do, but in, in front of who?
+Q What --
+A Like humiliation is humiliating in front
+of a crowd of people.
+MR. MERMELSTEIN: Don't argue with him.
+Just, just answer.
+BY MR. LUTTIER:
+Q. Just humiliate. To yourself, what's
+humiliate mean to you?
+A. Yeah, embarrassing.
+Q. Is that all it means?
+A. Yeah.
+Q. I mean, he treated you worse than an
+animal, didn't he?
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+THE WITNESS: An animal?
+BY MR. LUTTIER:
+Q. Would you treat a dog like this?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No.
+Page 360
+BY MR. LUTTIER:
+Q. No human being ought to be treated like
+this, should they?
+A. No.
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. So, were you humiliated by his --
+A. Yeah.
+Q. - conduct toward you? Did it make you
+feel bad?
+A. Of course.
+Q. Did it make you feel low?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Did it make you feel like you were
+worthless?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Did it make you feel so bad that you went
+and got a court order that said he couldn't come
+near you for a year?
+A. Yeah.
+Q. Jeffrey Epstein never made you feel like
+14 (Pages 357 to 360)
+Electronically signed by cynthia dil!
+1(601-051-976-2934)
+cctec48b-651e-487e-Bbb1-b2t47BedDedd
+
+
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+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 15 of
+Page 361
+Page 363
+that, did he?
+A. No, but just a lot worse.
+Q. He was nice to you, wasn't he?
+A. Yeah, really nice.
+Q. And by the way, did you -- did you ever
+touch Mr. Epstein's penis?
+A. No.
+Q. You had seen a man's penis before you went
+to Jeffrey Epstein the first time, hadn't you?
+A. Yes.
+Q. Matter of fact, had you touched a man's
+penis before you went to Jeffrey Epstein?
+A. I don't remember.
+Q. Had you placed a man's penis in your mouth
+before you had gone to see Jeffrey Epstein?
+A. I don't remember.
+Q. Had you placed a man's penis in your
+vagina before you went to Jeffrey Epstein?
+A. I don't remember.
+Q. When you made the videotape of you and
+Preston having sexual relations, what acts were
+recorded on the videotape?
+A. On the tape?
+Q. Yeah. The tape --
+A. Sex.
+1
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+Page 362
+Q. - you made. And you made that tape,
+1
+right?
+A. Yeah.
+Q. Was it with your video camera?
+A. No.
+5
+Q. Whose video camera?
+6
+A. My, my parents.
+7
+Q. You used your parents' video camera --
+8
+A. Yeah.
+9
+Q. .. to record you and this fellow,
+10
+Preston Vinyard, engaged in sexual relations?
+11
+A. Yeah.
+12
+Q. Where did the actual filming take place?
+13
+A. In my, my house.
+14
+Q. What house?
+15
+A. My room.
+16
+Q. The room, the house your parents owned? |17
+A. Yeah.
+Q. And how old were you at the time?
+18
+19
+A. I don't remember.
+20
+Q. Sixteen?
+21
+A. I don't remember.
+22
+Q. Seventeen?
+23
+A. I don't remember.
+24
+Q. No more than 17, right?
+25
+A. I don't remember.
+Q. But you remember whether you were older
+than 17, don't you?
+A. No, I don't remember.
+Q. Did you make the tape before he got you
+pregnant?
+A. I don't remember.
+Q. Did you make the tape before you --
+A. I don't remember when I took the tape. I
+don't remember when, and when, I am -- like you
+already stated, I have been --
+Q. Okay. Did you --
+MR. MERMELSTEIN: You're okay. You're
+doing fine.
+BY MR. LUTTIER:
+Q. Did you make the tape before you aborted
+the first baby?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: I don't remember.
+BY MR. LUTTIER:
+Q. Did you make it before you aborted the
+second baby?
+A. I don't remember.
+Q. So, you're in your parents' house. You're
+using your parents' video machine. And you're
+Page 364
+recording having sex with Preston Vinyard when
+you're some age that you don't remember, right?
+A. Yes.
+Q. But we know it's while you were in high
+school?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. Tell the ladies and gentlemen, look in the
+camera and tell the ladies and gentlemen of the jury
+you don't know if you were in high school when you
+made this tape.
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+THE WITNESS: I was in high school when I
+made this with Preston.
+BY MR. LUTTIER:
+Q. Okay. All right. Way too young to be
+doing this kind of stuff, right?
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+BY MR. LUTTIER:
+Q. Right? Do you agree with me?
+A. Yeah.
+MR. MERMELSTEIN: Objection.
+15 (Pages 361 to 364)
+oc1ec48b-651e-487e-8bb1-b2147Bed0edd
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+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 16 of
+47
+Page 365
+BY MR. LUTTIER:
+Q. All right. Now, how did you make the tape
+physically? Where did you put the camera?
+A. On my dresser.
+Q. Was it in your bedroom?
+1
+2
+3
+4
+5
+A. Yeah.
+Q. And you turned the camera on?
+A. Yes.
+8
+Q. Whose idea was it to make the tape?
+9
+A. Preston's.
+10
+Q. Think it would be a good idea. You
+11
+thought that was okay, went along with it?
+12
+A. I went on it, yeah. I agreed with him.
+13
+Q. So, tell me what specific acts you engaged
+14
+in with Mr. Vinyard that you then recorded on this
+video, to your parents' videotape machine in your
+15
+16
+parents' home?
+17
+MR. MERMELSTEIN: You know, I'm going to
+18
+object to that, again Rule 412, and ask you not
+19
+to - It's just going too far.
+20
+MR. LUTTER: Well, this is a videotape
+21
+that she admitted she showed Mr. Epstein, so --
+22
+MR. MERMELSTEIN: Yeah, but you're --
+23
+MR. LUTTIER: -- it's clear --
+24
+MR. MERMELSTEIN: -- asking her to
+25
+Page 366
+describe the acts --
+MR. LUTTIER: Yeah.
+1
+2
+MR. MERMELSTEIN: -- on the videotape?
+MR. LUTTIER: It's clear. It's within the
+gambit. Were coming back. And I mean, I am
+4
+5
+not going to argue, but I mean you're going
+to - we're going to come for fees and costs,
+7
+because there isn't any question about whether
+8
+that's a legitimate area of inquiry. So I
+would respectfully suggest you rethink your
+9
+10
+position on that.
+11
+MR. MERMELSTEIN: You're asking her what
+12
+was on the videotape in terms of sex acts.
+13
+MR. LUTTIER: You bet. You bet. The tape
+14
+that she showed Jeffrey Epstein. And there is
+15
+no question about whether that's fair game.
+16
+MR. MERMELSTEIN: I'm going to give you a
+17
+little bit of leeway.
+18
+MR. LUTTIER: Okay, fair enough.
+19
+THE WITNESS: Of us having sex.
+BY MR. LUTTIER:
+20
+21
+Q.
+I want to know the specific acts. Did it
+reflect oral sex?
+22
+23
+A. Sure.
+24
+Q. Were you, did it reflect you having
+25
+Page 367
+Preston Vinyard's penis in your mouth?
+A. Yeah.
+Q. Were you giving him what we would -- a
+typical vernacular, that would be giving him a head
+job, right?
+MR. MERMELSTEIN: Come on. I mean, come
+on. She just --
+BY MR. LUTTIER:
+Q. - in the slang?
+MR. MERMELSTEIN: There is no need to go
+to slang. She just told you what they --
+BY MR. LUTTIER:
+Q. Did it -- did it show him licking your
+vagina?
+A. Yeah.
+Q. Did, did he ejaculate in your mouth?
+A. I don't remember.
+Q. Did it show that on the tape?
+A. I don't remember.
+Q. Do you recall him ever ejaculating in your
+mouth?
+A. Ever? What does that have to do with the
+tape?
+Q. Ever. Ever.
+MR. MERMELSTEIN: Okay. Ever, whether
+Page 368
+it's on the tape or not?
+MR. LUTTIER: Any time.
+MR. MERMELSTEIN: Okay. Don't answer that
+question. Rule 412.
+BY MR. LUTTIER:
+Q. Did it -- did he insert his penis in your
+vagina on this tape?
+A. Yeah.
+Q. And what position were you in at the time?
+A. I don't know. I don't remember.
+Q. Do you remember being on all - what they
+call all fours?
+A. Could have been on all fours. Could have
+been on my back. I don't remember.
+Q. And, and other than him inserting his
+penis in your vagina and in your mouth, did he
+insert his penis in any other orifice of yours?
+A. No.
+Q. And did you perform any other sex acts on
+him other than giving him oral sex on this tape?
+A. No.
+Q. What -- is there anything else depicted on
+this tape?
+A. No, not that I --
+MR. MERMELSTEIN: Objection to form,
+16 (Pages 365 to 368)
+cc1ec48b-651e-487e-8bb1-b2f478edDedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 17 of
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+overbroad.
+THE WITNESS: Not that I remember, no.
+BY MR. LUTTIER:
+Q. And you took this tape after you made it
+on your parents' video in your parents' house, and
+you took it over to show it to Jeffrey Epstein,
+right?
+A. Yeah.
+Q. Was there anybody else that you showed the
+tape to?
+A. No.
+Q. Show it to any of your girlfriends?
+A. No.
+Q. Was there anybody else present when you
+showed it -
+A. No.
+Q. - to Mr. Epstein?
+MR. MERMELSTEIN: You got -- you got to
+wait until he finishes the question.
+BY MR. LUTTIER:
+Q. Did you ever show it to your parents?
+A. No.
+Q. Do they know about?
+A. Yeah.
+Q. When did you tell your parents that you
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+Page 370
+took their video camera and made this videotape in
+their house?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: When I told -- I told them
+1
+2
+3
+about it, they, being respectful parents,
+they're not going to sit there and question me
+about every single act that was on the tape.
+MR. MERMELSTEIN: No. The question was
+when, I think.
+MR. LUTTIER: Yeah.
+MR. MERMELSTEIN: When did you tell your 11
+parents?
+BY MR. LUTTIER:
+Q When did you tell your parents?
+A. L they have known about it. I don't --
+I don't remember when I told them. I don't -- I
+don't remember.
+Q. Was it before you filed this lawsuit?
+A. Yeah, I think so. Yeah.
+Q. Was it before the police came to see you?
+A. It was before, yeah.
+Q. Well, why did you tell them about it?
+A. I don't remember. I told them about it.
+Q. Was the word out in the community that
+you'd made this tape?
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+A. No, the word wasn't out. I think my - I
+think my dad found it in my bedroom, and my dad
+asked me about it and asked me if I had ever made
+any videotapes, and I was honest with him and I told
+him, yes.
+Q. As in, your dad found it and played it and
+saw it?
+A. No, he asked me about a tape that was in
+my bedroom, and he asked me questions about it, and
+I told him.
+Q. Well, what did he ask you about it?
+A. He asked me what was on the tape and why
+it's not in with all the other tapes in the family
+room. And I said, and I was honest with him, I told
+him it was a sexual tape with me and Preston.
+Q. And what was his reaction?
+A. He was upset.
+Q. Now, was it embarrassing to you to have to
+talk to your dad about the fact that you made a
+videotape having sex with Preston Vinyard in their
+house with their videotape machine?
+A. Yeah, it was embarrassing.
+Q. Okay. And was it Preston's idea or your
+idea?
+A. Preston's idea.
+Page 372
+Q. Where is that tape today?
+A. I don't have it. It's ruined.
+Q. Who ruined it?
+A. I did.
+Q. And when did you ruin it?
+A. A while, I don't remember. A while ago.
+Q. You didn't ruin it until after you filed
+this lawsuit, did you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No, I did. It was before.
+BY MR. LUTTIER:
+Q. But how do you know that?
+A. Because I don't -- I just -- it was
+definitely not after. I don't even know, no.
+Q. Well, I don't understand. First you're
+saying you don't know when you did it, now you're
+saying you did it -
+MR. MERMELSTEIN: No, no. no.
+THE WITNESS: No, I, I was -- I remember
+it was before I filed my lawsuit, but I don't
+remember the exact date that I ruined it, but
+it was before I was even in this lawsuit.
+BY MR. LUTTIER:
+Q. Other than the videotape you made of
+having sex and other sexual acts with
+17 (Pages 369 to 372)
+cc1ec48b-651e-487e-Bbb1-b2f478edOedd
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+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 18 of
+Page 373
+Preston Vinyard, and the photograph of you in your
+underwear with this other girl when you were in high
+school, have you been depicted in any other
+videotapes performing sex acts?
+A. No.
+Q. Have you been depicted in any other
+photographs in any state of undress, that is, either
+topless or completely naked?
+A. No.
+Q. You said that at some point in time after
+you went to Mr. Epstein's and you, you voluntarily
+removed your under pants, correct? Remember that
+testimony?
+A. Yes.
+Q. And do you recall at what point whether
+you were a junior in high school when you were
+removing your pants and doing complete nude
+massages to --
+A. No, I was, I was -- yeah. Sorry. Ask the
+question. I completely interrupted you.
+Q. Where in high school were you when you
+were giving complete nude massages to Mr. Epstein?
+A. Like October, like, middle of my junior --
+Junior year.
+1
+2
+3
+4
+7
+Q. Okay. You said there came a point in
+9
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+21
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+Page 374
+time, something about a vibrator.
+A.
+Yeah.
+Q. What happened with the vibrator?
+A. He used it on my clit.
+Q. What do you mean, he used it on your clit?
+A. He turned the vibrator on and would put it
+by my vagina.
+Q. Okay. Did you have your underwear on or
+1
+2
+3
+4
+5
+6
+7
+off?
+8
+A. They were -- they were off.
+9
+Q. Okay. And when did this happen?
+10
+11
+A. In the middle of my junior year.
+Q. Everything happened in the middle of your
+12
+13
+Junior year?
+14
+MR. MERMELSTEIN: Objection,
+15
+argumentative.
+16
+THE WITNESS: Yeah, it, like I said, first
+17
+time I visit, second time I visit. It got
+18
+where, it got to the point where he would use a
+19
+vibrator on me, and then he started fingering
+20
+me, then he started using both on me, and then
+21
+he would ejaculate. I mean, after I had all my
+clothes off, I mean it was -- I mean, it was
+22
+always the same thing. It was --
+23
+24
+25
+Page 375
+BY MR. LUTTIER:
+Q Did he ask you to use the vibrator on you?
+A. Yeah.
+Q. And did you say okay?
+A. Yeah.
+Q. So, you did that voluntarily, too,
+correct?
+A. Yeah.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Was there ever a point in time that you
+said no to the use of a vibrator?
+A. No.
+Q. You, you know what an orgasm is, I assume?
+A. Yeah.
+Q. Did you ever have an orgasm while you were
+at Mr. Epstein's?
+A. Yeah.
+Q. More than once?
+A. Yeah.
+Q. You enjoyed those?
+MR. MERMELSTEIN: Objection,
+argumentative.
+BY MR. LUTTIER:
+Q. Did you not?
+Page 376
+A. Yeah.
+Q. You told him you enjoyed them, didn't you?
+A. I didn't tell him. It was pretty obvious.
+Q. You kept coming back because you enjoyed
+it, didn't you?
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Plus you were getting paid money.
+A. Yeah.
+Q. All right. Did you have an orgasm when
+you were at Mr. Epstein's when he used the vibrator
+on you?
+A. Yeah.
+Q. Yeah. And how many occasions did you go
+back after the first time that he used the vibrator
+on you?
+A. Whenever he would call me up I would go.
+Q. Do you know how many times that was?
+A. After that, every single time he was in
+town, two to three times a week.
+Q. From June of '05 until October of '05, how
+many times did you go to Mr. Epstein and he used the
+vibrator on you?
+MR. MERMELSTEIN: Objection. Objection to
+form.
+18 (Pages 373 to 376)
+| (601-051-976-2934)
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 19 of
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+Page 377
+THE WITNESS: From June to when?
+1
+BY MR. LUTTIER:
+2
+Q. June of '05 to October of '05.
+3
+A. I don't - I don't know.
+4
+Q. More than once?
+5
+A. Yeah.
+MR. MERMELSTEIN: Objection.
+6
+7
+BY MR. LUTTIER:
+8
+Q. Did you have orgasms more than one time
+9
+between June of '05 and October of 05?
+10
+A. Yeah.
+11
+MR. MERMELSTEIN: Objection to form.
+12
+BY MR. LUTTIER:
+13
+Q. Now, did there come a time -- sorry.
+14
+MR. MERMELSTEIN: Focus. You know, he's
+15
+asking about specific dates, so make sure
+you're sure of your answer.
+16
+17
+THE WITNESS: I don't know how many times
+18
+in '05.
+19
+BY MR. LUTTIER:
+20
+Q. Did there come a time that you say - huh?
+21
+A. I don't know how many times I've been
+22
+there.
+23
+MR. MERMELSTEIN: No, well, he's asking
+you a very specific date, so make sure you're
+24
+25
+Page 378
+sure of your answer.
+THE WITNESS: From like, '05, summer --
+MR. MERMELSTEIN: He's now asking you
+June --
+MR. LUTTIER: All right. Let's not have a
+speaking objection.
+MR. MERMELSTEIN: -- of '05 to October of
+05.
+MR. LUTTIER: She knows how to answer and
+that's a speaking objection.
+MR. MERMELSTEIN: No, she doesn't.
+MR. LUTTIER:
+1. she knows, trust me.
+ane, she is very streetwise and knows exactly
+what's being asked of her.
+BY MR. LUTTIER:
+Q. Was there ever a time --
+MR. MERMELSTEIN: Objection to that
+characterization.
+BY MR. LUTTIER:
+Q. Was there ever a time that you told
+Mr. Epstein not to use the vibrator on you?
+A. No.
+Q. Were there times that you asked him to use
+the vibrator on you?
+A. No.
+2
+3
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 379
+Q. Did there come a time that Mr. Epstein
+gave you a vibrator?
+A. Yeah.
+Q. Do you remember what kind of vibrator?
+A. A Rocket Pocket.
+Q. Okay. And what did you do with the Rocket
+Pocket?
+A. I have -- I had the Rocket Pocket in my
+drawer at school. I don't know.
+Q. The drawer at school? What school?
+A. I have it with -- I had it with my --
+where I lived.
+Q. Did you say you had the vibrator at your
+drawer at school?
+A. I had it at home and then I had it where I
+lived. I, it was mine. So, with all my belongings
+to my current address that I was staying at, that's
+where I have it.
+Q. When did he first give it to you?
+A. I don't remember. I know I had it at my
+house though when I was in high school.
+Q. All right. And where did you keep it at
+home?
+A. In the drawer.
+Q. Did your mom and dad know about it?
+Page 380
+A. No.
+Q. Did you tell them about it?
+A. No.
+Q. Did you use it at home?
+A. Yeah.
+Q. Okay. You enjoy it?
+A. Yeah.
+Q. You had orgasms with it?
+A. Yeah.
+Q. Okay. Did you take it to college with
+you?
+A. Yeah.
+Q. Did you use it at college?
+A. Yeah.
+Q. Did you enjoy it?
+A. Yeah.
+Q. Have orgasms with it?
+A. Yeah.
+Q. Still have it today?
+A. No.
+Q. Do you have a different one now?
+A. A different one?
+Q. Yeah, a different vibrator.
+A. Yeah.
+Q. Still use a vibrator today?
+19 (Pages 377 to 380)
+Electronically signed by cynthia !!! !
+cc1ec48b-651e-487e-8bb1-b21478edOedd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 20 of
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+Page 381
+A. Yeah.
+Q. You think there's anything wrong with
+using a vibrator?
+A.
+No.
+Q. Okay. You went out and bought your own,
+A. Yeah.
+Q. Okay. All right. Then you said there was
+a time, came a point in time that he put his finger
+in your vagina?
+A. Yeah.
+Q. And when was that?
+A. The next time, next visit after he used
+the vibrator on me.
+Q. How do you know that that was before you
+were a freshman at
+University?
+A. Before I was a freshman?
+Q. Right.
+A. Because it was before I had even gone to
+prom. It was like, I still -- I hadn't even, wasn't
+even a senior yet.
+Q. And did he ask to put his finger in your
+1
+2
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+A. It wasn't quite like after he - after I
+was orgasming -- orgasming me from the vibrator, he 25
+Page 382
+flipped me around and I was on all fours, and he
+1
+stuck his finger in my vagina, and he didn't ask
+2
+questions. I was already orgasming, so it's not
+3
+like I told him stop.
+Q. Did you say no?
+5
+A. No.
+6
+Q. Did you stop him?
+7
+A.
+No.
+8
+Q. Did you come back any time --
+9
+A. He didn't ask me though.
+10
+Q. Did you come back any time after the first
+11
+time he put his fingers in your vagina?
+12
+A. (No verbal response.)
+13
+Q. Did you ever come back after that?
+14
+A. Yeah.
+15
+Q. Did he put his fingers in your vagina any
+16
+time after that?
+17
+A. Yeah, pretty much every time after that.
+18
+Q. Did you ever tell him not to?
+19
+A. No.
+20
+Q. You enjoyed it, didn't you?
+21
+A.
+• Yeah.
+22
+Q. It was all part of the orgasm, wasn't it?
+23
+MR. MERMELSTEIN: Objection.
+THE WITNESS: Yeah.
+24
+25
+Page 383
+BY MR. LUTTIER:
+Q. The reality here, the truth is that you
+enjoyed going to Mr. Epstein's and having an orgasm
+and getting paid $200 for giving a massage; isn't
+that the truth?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Okay. And you weren't traumatized by any
+of it, were you?
+MR. MERMELSTEIN: Objection to form, calls
+for a conclusion.
+BY MR. LUTTIER:
+Q. What damages have you suffered as a result
+of going to Mr. Epstein?
+A. Honestly? Everything, like, emotionally.
+MR. MERMELSTEIN: Take your time.
+THE WITNESS: I mean, how does it make me,
+emotionally, like, with my parents, disrespect
+from my parents, family, friends. It's
+relationship-wise, like trusting people-wise, I
+don't know. I couldn't -- a lot of things, a
+lot of different things emotionally, like, a
+lot of things.
+Page 384
+BY MR. LUTTIER:
+Q. Well, you, you kept going back to
+Mr. Epstein. You never said no, I don't want to
+come, did you?
+A. I thought he was my friend.
+MR. MERMELSTEIN: Objection,
+argumentative.
+BY MR. LUTTIER:
+Q. You never once said to Mr. Epstein, I
+don't want to come, did you?
+A. No.
+Q. As a matter of fact, you gave Mr. Epstein
+a little feedback, didn't you?
+MR. MERMELSTEIN: Take your time.
+BY MR. LUTTIER:
+Q. You gave him a little feedback, didn't
+you?
+A. What do you mean by that?
+Q. You told him you liked what he was doing,
+didn't you? Didn't you?
+4. I don't know. I don't remember.
+Q. Do you recall?
+MR. LUTTIER: What are we on, No. 4?
+THE COURT REPORTER: Yeah.
+MR. LUTTIER: Let's mark that as 4.
+20 (Pages 381 to 384)
+111
+ce1ec48b-651e-487e-8bb1-b2f47BedDedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 21 of
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+Page 385
+(Defendant's Exhibit No. 4 was marked for
+identification.)
+BY MR. LUTTIER:
+Q. Let me show what's been marked as Exhibit
+No. 4. Is that your handwriting?
+A. No. Love always, Jane Doe No. 4. This
+is, this, for a good time, call -
+Q. Yes.
+A. - that's not my, that's not handwriting;
+that's Lauren's, that's Lauren's handwriting.
+Q. Okay. And then below that the hearts and
+then it's signed Jane Doe No. 4 and Lauren. That's
+your handwriting, the hearts?
+A. Yeah, the heart, the heart --
+Q. Right.
+A. - the heart, and then heart, Jane Doe
+No. 4, Lauren, that's me. But for a good time and
+then I didn't, like, put my number there. That's
+for a good time, call 635-3454, that's Lauren's
+handwriting. And then that's her heart and Lauren.
+Q. Whose number is 635 --
+A. That was my number.
+Q. Okay. So you were present when this note
+was created?
+A. Yeah, we both were there.
+1
+2
+3
+6
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+8
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+23
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+25
+Page 386
+Q. This is
+A.
+Yeah.
+Q. Okay. And so you both created this note
+and left it for Mr. Epstein?
+A. She wrote it there, and then I signed it,
+yeah.
+Q. You knew what you were doing, right?
+MR. MERMELSTEIN: Objection, form,
+argumentative.
+THE WITNESS: No. I wasn't the one that
+wrote it.
+BY MR. LUTTIER:
+Q. You knew what you were doing when you
+signed it with hearts and put your name and left it
+there, didn't you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Nobody made you do that, did they?
+A. No.
+Q. You were telling him you wanted him to
+call, you were having a good time, you wanted to
+come back, weren't you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Well, he was a very, like,
+1
+2
+3
+4
+5
+6
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+8
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+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 387
+sexual, like he was always joking around like
+sex talk, like, I said, for example, he
+would -- had me, like, go up to, like, joking
+around like sexual, like, telling me how to
+give head to a guy, or like always joking
+around sexually.
+So with Lauren -- he was that way with a
+lot of different girls, always joking around
+sexually with girls.
+So whenever -- I didn't write this, I
+didn't tell Lauren to write this. This was
+Lauren's intentions, and I was just joking
+around and signed it. I didn't - my
+intentions weren't to write this, for a good
+time, call Jane Doe No. 4. This is Lauren's
+intentions, not mine.
+BY MR. LUTTIER:
+Q. Wait a minute. Wait a minute. Let's back
+up. You saw the words and you read the words when
+it was handed to you to sign, didn't you?
+A.
+she didn't tell me, sign it, I
+joking
+Q.
+A.
+you did that voluntarily?
+Yeah.
+Q. So, she handed you this piece of paper,
+Page 388
+that is, Lauren?
+A. No, it was -- she wrote it. There was a
+notepad --
+Q. Okay.
+A. - on, on the table. She wrote it, and
+picking up -- I just picked up the pen after she
+wrote something, joking around, because everybody,
+like jokes around with Jeffrey Epstein, like,
+sexually like that, picked it up and signed my name.
+Q. Okay. Let's go through it. When did this
+happen, by the way?
+A. I don't remember.
+Q. You were already at l
+University at
+this time, or before that?
+A. I don't remember.
+Q. So your testimony is that Lauren wrote on
+a pad at Jeffrey Epstein's house, for a good time
+call, and put your number, right?
+A. Yeah.
+Q. And did you put her number too?
+A No.
+Q Is that 324-7996 her number?
+A. It might have been her old number. I
+don't remember.
+Q. Okay. So she wrote all of that, right,
+21 (Pages 385 to 388)
+cc1ec48b-651e-487e-8bb1-b2f478edOedd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 22 of
+Page 389
+1
+2
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+first?
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+13
+14
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+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: Can I have a tissue?
+never mind. I have it right here.
+BY MR. LUTTIER:
+Q.
+• Did she write all of the words that appear
+in this notepad before you put anything on it?
+A. Did she write anything before -- wait.
+Ask me the question again.
+Q. Did she write all the words that appear in
+this notepad before you put anything on it?
+A. No, she wrote, for a good time call.
+Q. So when, when you originally got this
+note, when you were standing there, this is down in
+the kitchen of his house?
+A. Yeah, I think so. I don't remember where
+Q. Both of you were there for some reason?
+A.
+• Yeah.
+e. Had you both been there giving Mr. Epstein
+a massage?
+A. Yeah. She had gone there.
+Q. But you were both there at the same time?
+A. Yeah.
+Q. Were you there -- were you both giving him
+a massage at the same time?
+1
+2
+3
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+A. No.
+Q. By the way, do you know what a three-way
+is?
+A. Yeah.
+Q. Did you ever engage in a three-way?
+A. A three-way phone call?
+Q. No. Three-way sexual experience.
+A. Yeah.
+Q. That is, like, have you ever engaged in
+those?
+A. No.
+Q. Have you ever had a sexual encounter with
+another woman?
+A. No.
+Q. Okay. Now, when you were at
+Mr. Epstein's, you and Lauren are there. She writes
+this pad out. She writes this note on this pad,
+right?
+A. Yeah.
+Q. And then after she writes on it, you take
+a pen and you draw these two hearts and you sign
+your name?
+A. Yeah.
+Q. Nobody made you do that, right?
+A. No.
+3
+4
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+8
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+Q. You did it voluntarily.
+A. Yeah.
+Q. Thought it was funny?
+A. Yeah.
+Q. And you left it there for Mr. Epstein.
+A. Yeah.
+Q. Telling him, call me for a good time.
+MR. MERMELSTEIN: Objection, form.
+BY MR. LUTTIER:
+Q. Right?
+A. Yeah.
+Q. And that's what you wanted him to do, was
+to keep calling and have you come over, wasn't it?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+it?
+Q. Isn't that right? That's the truth, isn't
+A. That I wanted him to keep calling me?
+Q. Yeah, and you wanted to keep going there;
+isn't that the truth?
+A. I knew he was going to keep calling me.
+He told me I was his favorite in Florida, so it
+wasn't something that I, ever crossed my mind.
+Q. And you wanted him to keep calling you and
+you wanted to keep going; isn't that the truth?
+Page 392
+MR. MERMELSTEIN: Objection, objection to
+form, asked and answered.
+BY MR. LUTTIER:
+Q. Isn't that the truth,
+MR. MERMELSTEIN: Objection.
+THE WITNESS: That - yes.
+BY MR. LUTTIER:
+Q. And the only reason you quit going to
+Jeffrey Epstein after you were already a freshman at
+University was because you found out the police
+were investigating him and they showed up at
+University and interviewed you; isn't that true?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No. I got in touch with.
+Wait. Ask the question again.
+BY MR. LUTTIER:
+Q. The only reason you quit going to Jeffrey
+Epstein was because the police showed up at
+University and interviewed you.
+A. No, because I was still, Jeffrey was still
+renting me a car. After I knew the police were
+going to everybody and interviewing questions, like
+he had rented me.
+(Brief telephone interruption.)
+THE WITNESS: I was still talking to him
+22 (Pages 389 to 392)
+lectronically signed by cynthi
+Electronically signed by cynthi
+cctec48b-651e-487e-Bbb1-b2f478eddedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 23 of
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+Page 393
+after he was interviewing cops. I still talked
+to him after I got interviewed by the cops. I
+talked to him about - I talked to his lawyers.
+BY MR. LUTTIER:
+Q. Well, why didn't you go back and give him
+more massages after you got interviewed by the --
+A. Because he, like, he wasn't even -- he
+didn't stay at his Palm Beach house. He like -- I
+don't even know where he was at.
+Q. You would have gone if he had asked you to
+come back and give him a massage, wouldn't you?
+MR. MERMELSTEIN: Objection to form.
+Calls for speculation.
+BY MR. LUTTIER:
+Q. Would you have gone back?
+A. I don't know. Probably more than likely.
+I don't know.
+Q You would have -
+A I thought he was my friend.
+He never did anything to you, right?
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. He didn't do anything compared to what
+Preston Vinyard did to you, got you pregnant three
+times, aborted three kids --
+3
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+MR. MERMELSTEIN: Objection to form --
+MR. LUTTIER: -- treated you like dirt --
+MR. MERMELSTEIN: -- argumentative.
+BY MR. LUTTIER:
+4
+Q. Right? He never did anything like that to
+5
+you, did he?
+6
+MR. MERMELSTEIN: Objection.
+7
+BY MR. LUTTIER:
+8
+Q. And what you want in this lawsuit is
+9
+money, right?
+10
+A.
+NO.
+11
+Q. That's why you sued him was for money.
+12
+A. No.
+13
+Q. And you were offered money to settle the
+14
+suit, but you don't want that. You want more money; 15
+isn't that right?
+A. No.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Well, if you don't want money, what are
+you suing for?
+A. For him to get punished
+Q. That's the only thing you can get in this
+case is money, right? Your lawyers have explained
+that to you, haven't they?
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 395
+MR. MERMELSTEIN: Objection to form.
+Don't talk about what your lawyers have
+explained to you.
+BY MR. LUTTIER:
+Q. That's the only thing you can get. Are
+you under the impression that you can get some kind
+of relief here other than money?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No. It's not for me. It's
+so that he can get punished for things that
+he's done to me and several other girls.
+MR. LUTTIER: Let me show you the next
+exhibit. What number is this?
+THE COURT REPORTER: Five.
+MR. LUTTER: Okay.
+(Defendant's Exhibit No. 5 was marked for
+identification.)
+BY MR. LUTTIER:
+Q. Let me show you what's been marked as
+Exhibit 5. It's entitled Psychological/Social
+History. Do you recognize that document?
+A. Yeah.
+Q. Is that your handwriting on it?
+A. Yeah.
+Q. Is this a document that you completed?
+Page 396
+A. Yeah.
+Q. And did you complete it on December 2nd of
+2008?
+A. Yeah.
+Q. And do you remember why you completed this
+document?
+A. Yeah.
+Q. Why?
+A. Because I was, had an appointment with
+Dr. Kliman.
+Q. Okay. Were all of the answers that you
+gave on this document true and correct?
+MR. MERMELSTEIN: Look at them carefully.
+(Ms. Doe and Mr. Mermelstein were
+conducting a discussion off the record.)
+THE COURT REPORTER: Is this off the
+record?
+MR. MERMELSTEIN: Well, we're kind of on
+the record right now. So, have you read all
+these?
+THE WITNESS: No. I mean there's a few
+that I have questions about, you know. There's
+a tew that I have questions about that I am
+kind of like, I am looking at this now and I am
+like -
+23 (Pages 393 to 396)
+cc1ec48b-651e-487e-8bb1-b21478edOedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 24 of
+5
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+Page 397
+MR. MERMELSTEIN: Anything you need to
+clarify. I think was -- what was the question?
+BY MR. LUTTIER:
+Q. My question was are all of the answers
+that you gave on this document true and correct?
+MR. MERMELSTEIN: So, now that's just Page
+1. The whole thing.
+BY MR. LUTTIER:
+Q. Well, I should -- let me rephrase that.
+Were all the answers that you gave on this document
+true and correct as of December 2nd, 2008, or
+whatever date you completed this document?
+A. On this one?
+Q. Yeah.
+MR. MERMELSTEIN: Okay. Go through each
+page and look at that and refresh your mind.
+BY MR. LUTTIER:
+Q. In all due respect, the answer is yes or
+no. You can't really consult with your lawyer about
+it.
+MR. MERMELSTEIN: If you're confused by
+something then, then you have to qualify your
+answer.
+THE WITNESS: Okay.
+MR. MERMELSTEIN: But, okay.
+1
+2
+3
+4
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+8
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+Page 398
+THE WITNESS: Is everything - well,
+there's one thing -
+MR. MERMELSTEIN: The question is, is
+everything true and correct, that's, that's
+written here, each page.
+THE WITNESS: Well, I am going -- I
+already know the answer to that question. I
+have only gotten to the second page.
+MR. MERMELSTEIN: Do you want to give your
+answer and then you can go or --
+THE WITNESS: Yeah, well, it says, did you
+ever get in trouble while in school? Well,
+yeah, when I was in high school I got a DUI,
+but I had circled no. But yeah, when I was in
+high school I got in trouble.
+BY MR. LUTTIER:
+Q. Well, was this paper given to you by
+Dr. Kliman to complete?
+A. Yeah.
+Q. Did he tell you to give honest --
+A
+Yeah.
+Q - and truthful answers?
+A. Yeah.
+Q. Well, why didn't you give him honest and
+truthful answers?
+1
+2
+3
+4
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+6
+7
+8
+9
+10
+11
+12
+13
+14
+16
+18
+19
+20
+21
+22
+23
+24
+25
+Page 399
+MR. MERMELSTEIN: Objection, form.
+THE WITNESS: Because if you, if you read
+up above, it says how far did you go in school.
+MR. LUTTIER: Right.
+THE WITNESS: I said attended college, but
+did no graduate college. So I am guessing,
+like, whenever I looked at this it said did you
+ever get in trouble while in school, I think
+while I was in college. I think my mind frame
+was set to college, not in high school. And
+that's why I'm looking at this now and I'm
+thinking, well, I know in high school I got
+into trouble. So, I know that's not true.
+MR. LUTTIER: Well, did you --
+THE WITNESS: And, like, whenever I look
+at something, after reading 17, it says, like,
+I am thinking, I was just thinking while I was
+in college. I don't know.
+BY MR. LUTTIER:
+Q Did Dr. Kliman ask you after you completed
+this, didn't he ask you whether you had any
+questions about it?
+A. I don't remember.
+Q. Did you tell him you had questions and
+didn't understand any of these?
+Page 400
+A. No, I don't remember.
+Q. Did you tell him any of the answers
+weren't right?
+A. No, I don't remember.
+Q. So, how is somebody supposed to know
+whether you're telling the truth or lying?
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+BY MR. LUTTIER:
+Q. How do, how does one know on what
+occasions you're telling the truth and when you're
+lying about something?
+MR. MERMELSTEIN: Objection to form,
+argumentative.
+BY MR. LUTTIER:
+Q How does somebody know?
+MR. MERMELSTEIN: Objection.
+THE WITNESS: They should know.
+BY MR. LUTTIER:
+Q. Well, first of all, you talked to the
+police under oath, and you're telling us you lied to
+the Palm Beach Police, right?
+MR. MERMELSTEIN: Objection, asked and
+answered.
+24 (Pages 397 to 400)
+cclec48b-651e-487e-8bb1-b2f47&edOedd
+
+
+Case 9:08-CV-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 25 of
+Page 401
+BY MR. LUTTIER:
+2
+3
+Q. Is that right? That's what you're telling
+us.
+4
+5
+1
+2
+7
+8
+9
+10
+11
+12
+13
+14
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+17
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+19
+20
+21
+22
+23
+24
+25
+MR. MERMELSTEIN: Asked and answered.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. So, we don't really know, even when you're
+under oath, whether you're telling the truth or
+you're lying, do we?
+A. No.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Okay. All right. So what other answers
+are, do you say are incorrect on here,
+notwithstanding the fact, that you gave to
+Dr. Kliman after he told you to answer truthfully?
+MR. MERMELSTEIN: I'm going to object to
+the form of that question.
+THE WITNESS: It says have you had any
+major changes in income during the last two
+years.
+BY MR. LUTTIER:
+Q. What number is that?
+A. Thirty.
+Q. Okay.
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 402
+A. I said no, but during the summers I worked
+at, like, I worked at Pine Tree Camp, so I made a
+little bit of money, but I put no because if you
+read the question, it says no, increasing
+significantly or decrease significantly. I only had
+a summer job.
+Q. Okay. Well, in 39 you reflect that you
+7
+had a summer job, right?
+8
+A. I'm sorry. I didn't read that far.
+9
+THE WITNESS: Can I ask a question? Yes,
+10
+or no?
+11
+MR. MERMELSTEIN: Huh?
+12
+THE WITNESS: Can I ask you a question?
+13
+MR. MERMELSTEIN: You really can't.
+14
+THE WITNESS: Okay.
+15
+MR. MERMELSTEIN: Again remember to keep
+16
+in mind what the question was that he
+17
+originally asked about.
+18
+THE WITNESS: Uh-huh. How would you --
+19
+BY MR. LUTTIER:
+20
+Q. What number?
+21
+A. Fifty-five, how would you describe your
+22
+illegal drug usage. I said I never used drugs.
+23
+Q. That wasn't true, was it?
+24
+A. No.
+25
+Page 403
+Q. You lied to Dr. Kliman, right?
+A. Yes.
+Q. What should the answer have been?
+A. I didn't --
+MR. MERMELSTEIN: Objection, that's been
+asked and answered.
+BY MR. LUTTIER:
+Q. What should the answer have been of those
+choices?
+A Well, out of all those choices, it would
+be two.
+l. Once or twice a year? And you didn't want
+Dr. Kliman to know that, did you?
+A. No.
+Q. You knew when you answered that question
+you were giving him a false answer, didn't you?
+A It was --
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTER:
+Q. You knew that when you answered the
+question you were giving a false answer, didn't you?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+MR. LUTTIER: Okay.
+MR. CRITTON: You know, you could all go
+Page 404
+off the record.
+MR. MERMELSTEIN: I suppose.
+MR. CRITTON: We're just burning up tape
+there. Just go ahead and finish looking.
+MR. MERMELSTEIN: Are you ready?
+THE WITNESS: No.
+MR. LUTTIER: Did you have a question?
+MR. MERMELSTEIN: Well -
+THE WITNESS: If he's going to leave, can
+I use the bathroom?
+MR. LUTTIER: Well, no, I am not going to
+leave. Okay. Go ahead.
+MR. MERMELSTEIN: Yeah, because it's kind
+of a question pending, so let's, let's just
+finish this and then you can go to the
+bathroom.
+THE WITNESS: No. 81, which of the
+following have you experienced in the last two
+years.
+BY MR. LUTTIER:
+Q And, and what did you answer?
+A. Eleven, none.
+Q. And what should the answer have been?
+A. Nine.
+Q. Pregnancy?
+25 (Pages 401 to 404)
+cctec48b-651e-487e-Bbb1-b2147Bed0edd
+
+
+Case 9:08-CV-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 26 of
+2
+3
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+Page 405
+A. Yeah.
+Q. And you knew when this question was asked
+that you had been pregnant in the last two years,
+didn't you?
+A.
+Yeah.
+Q. So you knew you were giving Dr. Kliman a
+false answer.
+A.
+Yeah.
+Q. You didn't want him to know you were
+pregnant, did you?
+A. I didn't want anybody to know.
+Q. You didn't want him to know, because you
+were going to have to tell him you aborted three
+children, weren't you?
+MR. MERMELSTEIN: Objection,
+argumentative.
+BY MR. LUTTIER:
+Q And you didn't want to have to do that;
+isn't that right?
+A Yeah.
+MR. MERMELSTEIN: Objection.
+MR. CRITTON: Just so you know, you're not
+getting it because she's got the paper in front
+of her face.
+MR. LUTTIER: Yeah, you have that.
+5
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 406
+BY MR. LUTTIER:
+Q. You didn't want to tell Dr. Kliman that
+you had been pregnant, because you would have had to
+tell him you aborted three kids, right?
+A. Yeah.
+Q. And you didn't want to have to tell him
+that, right?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. Because it was embarrassing to you?
+A.
+• Yeah.
+Q. Because it upset you?
+A.
+Yeah.
+Q. Because you feel bad about it?
+A. Yeah.
+Q. Because it's contrary to everything you
+were ever taught in your life, isn't it?
+MR. MERMELSTEIN: Think about the question
+before you answer. Objection to form.
+THE WITNESS: Yeah.
+BY MR. LUTTIER:
+Q. It's contrary to everything your parents
+ever taught you, wasn't it?
+A. Yeah.
+1
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+Page 407
+Q. Contrary to your religious beliefs, wasn't
+it?
+A. (No verbal response.)
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTIER:
+Q. Is there any principle that you had in
+your life that having three abortions was consistenti
+with?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No. At the same time, I
+would never want to, doing that instead of
+raising three kids with a boyfriend that is
+abusive, in and out of jail, drug addict. I
+think it's more hurtful to bring a child in
+this life whenever you can't give them
+anything. So, at that time, I thought I was
+making a good decision.
+BY MR. LUTTIER:
+Q. So, if you were that concerned about it,
+then after the first abortion you certainly would
+have insured that you didn't get pregnant twice
+again by the same person.
+THE WITNESS: I was taking birth control.
+MR. MERMELSTEIN: Objection.
+Page 408
+BY MR. LUTTIER:
+Q. By the way, when you went and found out
+you were pregnant, did they show you the sonogram
+that they took?
+A. No. I didn't -- when, the first time I
+got pregnant, I didn't even know. I found out,
+because I thought I had a cyst or I was playing
+soccer and I had, and my egg on MRI that said I had
+a cyst on my ovarian from playing soccer, or a cyst.
+So when I went, I went to go get rid of my cyst, and
+that's when I found out.
+Q. Did they ever show you the sonogram of the
+fetus?
+• No.
+Q. Have you now told me all the questions you
+answered false?
+A. What was --
+Q. Have you now told me each of the questions
+that appear in this exhibit that you answered false,
+falsely?
+A. Yeah.
+Q. Well let's look at Question 52. Question
+52 says which of the following have you used. And
+it refers to 12 different drugs. What did you
+answer?
+26 (Pages 405 to 408)
+
+
+• Entered on FLSD Docket 12/01/2009 Page 27 of
+3
+4
+5
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+22
+23
+24
+25
+Page 409
+A. I stated that one. I already said that.
+Q. And what should the answer - you, you
+wrote none, right?
+A. Right.
+Q. Or you circled it. And what should it
+have been?
+A. Cocaine.
+Q. That would be two. What else?
+A.
+Marijuana.
+Q. Nine. What else?
+MR. MERMELSTEIN: You've got the paper in
+front of your face again. You might want to
+try to hold it down just a bit.
+BY MR. LUTTIER:
+Q. Two and nine and what else?
+A. What is barbit - what is -
+Q.
+• Barbiturates.
+A. Yeah, what are those?
+Q. So if you didn't know, you would ask
+Dr. Kliman what that meant?
+MR. MERMELSTEIN: Objection to form. Go
+ahead and try.
+BY MR. LUTTIER:
+Q. At least two of these drugs you'd used,
+you knew you'd used, and you just, you just gave a
+Page 411
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: Have you ever drank too much
+alcohol? No, I -- yeah, I drank, but never got
+to the point where I was, like, wasted.
+BY MR. LUTTIER:
+Q. You got completely drunk on more than one
+occasion before this?
+A. Yeah. I mean --
+MR. MERMELSTEIN: Objection to form.
+BY MR. LUTTER:
+Q. Just so we're clear, you didn't think that
+meant that, that there was a time when you drank too
+much alcohol, those occasions when you got
+completely drunk?
+A. I drank more -- yeah, I drank before, but
+I guess, I am sorry, yeah.
+Q. Okay. And then over on No. 57, it says --
+or 87, I'm sure, what is the primary problem
+bothering you. You answered other. So none of the
+first 13 items applied, but there was some other
+that you answered, but you didn't say what the other
+was, right?
+A. Yeah.
+Q. Okay. That was a truthful answer, right?
+A. Yeah.
+Page 410
+false answer to Dr. Kliman, right?
+A. Yeah, I already told you that I --
+Q. Okay. Let's take --
+A. -- already told you that.
+Q. Let's take 53. The question was, have you
+ever, have you ever felt there was a time you drank
+too much alcohol. You answered, yes, on one
+occasion.
+A. Yeah.
+Q. That wasn't truthful, was it?
+A. Actually, I drank alcohol on more than one
+occasion. It didn't ask me if I ever thought I did.
+Q. It says, have you ever felt there was a
+time you drank too much alcohol, and you had four
+choices. One of the choices was, yes, on several
+occasions, one was yes on more than several
+occasions. But you answered, yes, on one occasion.
+That's a false answer, wasn't it?
+A. No.
+Q. There was more than one time in your life,
+prior to the time you answered this that you felt
+you drank too much, wasn't there?
+A. Apparently not at that time, no.
+Q. You'd been drunk a bunch of times before
+you answered this, weren't you?
+Page 412
+1
+2
+Q. And then 88 says, how long ago did you
+begin to be troubled by this problem, and you had
+circled, does not apply, and then you crossed that
+4
+5
+out. And you just didn't answer that question,
+right?
+6
+A. I didn't answer it.
+7
+Q. And then 89, rank the degree to which this
+8
+problem has affected your life. You initially had
+9
+circled a little, and then you changed it to does
+10
+not apply, correct, meaning that whatever problem it
+11
+was wasn't a problem that affected your life,
+12
+correct?
+13
+MR. MERMELSTEIN: Objection, form.
+THE WITNESS: No.
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+BY MR. LUTTIER:
+Q. Why do you say it doesn't apply then?
+MR. MERMELSTEIN: Same objection.
+THE WITNESS: I don't know.
+BY MR. LUTTIER:
+Q. What did you mean by that when it said
+rate the degree to which this problem has affected
+your life, and you answered, does not apply. What
+did you mean?
+A. I don't know why I didn't answer it. I
+don't know why I didn't answer that question.
+27 (Pages 409 to 412)
+celec48b-651e-487e-8bb1-b2147BedOedd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 28 of
+47
+2
+3
+4
+5
+6
+7
+8
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+10
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+13
+14
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+Page 413
+Q. Well, you answered it. You answered with
+a specific answer, does not apply. So, what were
+1
+Page 415
+2
+you telling Dr. Kliman?
+3
+A. It means that I don't want to answer that
+4
+question.
+5
+MR. MERMELSTEIN: Objection to form.
+6
+BY MR. LUTTIER:
+7
+Q. Mean what?
+That I don't want to answer that question.
+8
+9
+Q. Well, it doesn't say I don't want to
+10
+answer. It says it doesn't apply.
+11
+MR. MERMELSTEIN: Objection.
+12
+THE WITNESS: That's what I, that's
+13
+what -
+14
+MR. MERMELSTEIN: Objection.
+15
+THE WITNESS: Meaning I don't want to
+16
+answer that question.
+17
+BY MR. LUTTIER:
+18
+Q. Well, let's look at the next one, No. 90.
+How often do you experience this problem? Again you
+19
+20
+A. I don't know.
+Q. None? You don't know of any drugs that
+Jane Doe No. 7 has used?
+A. Maybe -- I don't know.
+Q. Well, let's make sure we're clear here.
+Are you telling me under oath that you don't know of
+any drugs that Jane Doe No. 7 has used?
+A. No, I don't know.
+Q. Never seen her use any drugs? She's never
+told you she used any drugs? You're sure?
+A. Not like, hey, what kind of drugs do you
+do. It's not like we're drug addicts. It's not
+like -
+Q. My question is under oath whether you're
+aware, either from drugs you've seen her use or what
+she's told you drugs she's used?
+A. I have seen her drink.
+Q. Okay.
+A. Maybe smoke pot, maybe. Other than
+that -
+answered, does not apply, correct?
+21
+A. Yeah.
+22
+Q. Again you're saying it has no application
+23
+to your life; isn't that right?
+24
+MR. MERMELSTEIN: Objection to form.
+25
+MR. MERMELSTEIN: Do you remember?
+BY MR. LUTTIER:
+Q. Well, what do you mean, maybe?
+THE WITNESS: No, I don't remember.
+MR. MERMELSTEIN: Okay.
+Page 414
+1
+2
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+13
+14
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+16
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+18
+19
+20
+21
+22
+23
+24
+25
+THE WITNESS: No.
+BY MR. LUTTIER:
+Q. Then the next one says what other kinds of
+1
+2
+3
+problems are bothering you, and there's 14 specific
+items listed. You didn't answer any of those, and
+5
+you answered No. 15 does not apply.
+A. Yeah.
+7
+Q. Indicating that none of those things
+8
+appiled as a problem that was bothering you.
+9
+MR. MERMELSTEIN: Objection.
+10
+THE WITNESS: Because I don't want to
+11
+answer that question.
+12
+BY MR. LUTTIER:
+13
+Q. Okay, now --
+14
+A. It doesn't mean that they don't apply.
+15
+Q. - with respect to Jane Doe No. 7, how
+16
+many abortions has she had?
+17
+A. I don't know.
+Q. How many abortions has Jane Doe No. 3 had?
+18
+19
+A. I don't know.
+20
+Q. You have no knowledge about them?
+21
+A. No.
+22
+Q. Okay. And what drugs do you know from
+23
+your own personal knowledge that Jane Doe No. 7 has
+24
+used?
+25
+Page 416
+BY MR. LUTTIER:
+Q. Your testimony under oath is you've never
+seen Jane Doe No. 7 smoke pot?
+MR. MERMELSTEIN: No, no.
+THE WITNESS: No, I didn't say I've never
+seen her. I just don't remember.
+BY MR. LUTTIER:
+Q. You may have seen her smoke pot?
+A. When I was in high school, I hung out with
+her at high school parties. I don't remember. I
+mean, everybody -- I don't know. I don't remember.
+Q. My question is very simple. You may have
+seen her smoke pot?
+A. Yeah.
+Q. What other drugs do you know that Jane Doe
+No. 7 has used?
+A. I don't know.
+Q. Don't have any idea?
+A. No.
+Q. How about Jane Doe No. 3, what other
+drugs, what drugs have you, do you know that Jane
+Doe No. 3 has used?
+A. Drinking and smoke pot.
+Q. Any others?
+A. No.
+28 (Pages 413 to 416)
+cc1ec48b-651e-487e-8bb1-b2t478edledd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 29 of
+47
+Page 417
+*1
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+Q. Are you sure?
+A.
+Yeah.
+Q. Okay. And with respect to Jane Doe No. 3,
+how many abortions has she had?
+A. I don't know.
+Q. And what sexually transmitted diseases
+does Jane Doe No. 3 have?
+A. I don't know.
+Q. You filled out a health insurance or a
+health questionnaire at
+| University saying that
+a friend of yours had MRSA. Do you know what MRSA
+is?
+1
+2
+3
+Page 419
+5
+A. Yeah, it's where you get like in the
+hospital after having, like, surgery.
+Q. And who are you referring to when you said
+you had a friend that had MRSA?
+A. Alan.
+Q. Alan, the boy you were dating at the time?
+A. At his, yeah, or - yeah.
+Q. How about any of your girlfriends that
+went to Jeffrey Epstein's, were you referring to any
+of them as having MRSA?
+A. No.
+Q. Do you know about any of the girls that
+went to Jeffrey Epstein having MRSA?
+9
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+BY MR. LUTTIER:
+Q. And were you a prostitute at one time?
+A. No.
+MR. MERMELSTEIN: Objection, form.
+BY MR. LUTTIER:
+Q. Did you ever consider yourself to have
+been a prostitute?
+A. No.
+Q. Okay. You mentioned that, you were
+talking about Mr. Epstein, and one other event that
+you said was, you said, I think to use your
+language, he licked your clit.
+A. Yeah.
+Q. When did that occur?
+A. It happened one time.
+Q. Was it after June of '05?
+A. Senior year. I was in my senior year.
+Q. Of high school?
+A. Yeah.
+Q. How do you know it was in your senior year
+in high school?
+A. Because after that moment, I said I never,
+never again.
+Q. Never what again?
+A. Like he is not, like, licking my clit.
+1
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+Page 418
+A. No.
+Q. Do you know whether or not Jane Doe No. 3
+has told -- or has Jane Doe No. 3 ever told you that
+she has any sexually transmitted diseases?
+A. No.
+Q. Have you suffered any economic loss; that
+is, have you lost any money as a result of going to
+see Jeffrey Epstein? And, obviousy, you got paid
+for what you went, but have you lost any money as a
+result of going to see Jeffrey Epstein?
+A. No.
+Q. Okay. Do you know what a pimp is?
+Page 420
+1
+2
+4
+Q. A pimp is someone that gets paid money to
+prostitute somebody or to, to facilitate the service
+of a prostitute. Is that what you understand a pimp
+is?
+A. Yeah.
+Q. Would you agree with me that you were, in
+essence, acting as a pimp; that is, you got paid
+money for taking
+to Jeff Epstein?
+MR. MERMELSTEIN: Objection,
+argumentative.
+THE WITNESS: Yeah.
+9
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+Q. Did he ask you --
+A. He kept begging me.
+Q. Did he ask you to lick your clit?
+A. Yeah, he kept begging me.
+Q And did you --
+A
+Finally, I gave in.
+Q. Did you say, no?
+A. No.
+Q. Had you said --
+A. Yes, I said no. And finally I said, yes.
+Q. Had you said no on prior occasions?
+A. No.
+Q. He never asked you to lick your clit prior
+to the time that, that he did it the first time?
+NO.
+Q. Okay. So the first time he asked to lick
+your clit, you said okay?
+A. No, I said no. And then he kept begging
+me and asking me to lick it that day. And finally
+after saying no, like, three or four times, I said,
+Q. Okay. So every time you said no, he
+didn't do it, right? When you said no, he didn't
+lick your clit?
+A. Yeah.
+29 (Pages 417 to 420)
+cc1ec48b-651e-487e-8bb1-b21478edüedd
+
+
+Document 430-3 Entered on FLSD Docket 12/01/2009 Page 30 of
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+Page 421
+Q. And then when you said yes, then you say
+he licked your clit?
+A. Yeah.
+e. And for how long did this go on?
+A couple of seconds.
+Q. A couple of seconds. Now, you had had
+your clit licked before that event, had you not?
+A. Yeah.
+Q. Preston Vinyard had done it, right?
+A. Yeah.
+Q. Other boys had done it, right?
+A. No.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. And, and then, while he was licking your
+clit, did you tell him you wanted him to stop?
+A. Yeah.
+Q. And did he stop?
+A. Yeah.
+Q. Okay. And when you say he licked your
+clit, did he penetrate your vagina or just lick your
+clitoris?
+A. No, he licked my clit.
+Q. Okay. And, and how were you positioned at
+the time that this happened?
+1
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+Page 422
+A. I was standing. There was a massage table
+to the right of me and there was a
+• to the left
+of me, and I had my right leg lifted up on the
+massage table, and he was on his knees.
+Q. So, you had positioned yourself for this?
+A. Yeah, I was - yeah, I guess.
+I didn't
+position it for me to go like that. He kept begging
+me and begging me.
+• Well, you -
+A Yeah, well, then, yes, I did.
+Q. You had to put your leg up on the massage
+table, right?
+A. Yeah.
+Q. And open up your vagina, right, your
+legs -
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+& - so he could lick your clit, right?
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+¿. That took you some time to do, right?
+A. Yeah.
+Q. So you did all that voluntarily, right?
+A. Yeah.
+Q. You could have said, no, and that would
+1
+2
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+Page 423
+have been the end of it, right?
+A. Yeah.
+Q. You -- at any time while you were going to
+see Jeffrey Epstein, you could have just said, no,
+I'm not going back anymore, couldn't you?
+A. Yeah.
+Q. Nobody coerced you to do it. You were
+going voluntarily, correct?
+A. Yeah.
+Q. Okay. Did you tell, by the way, before
+you let Mr. Epstein lick your clit, did you tell him
+you had herpes?
+A. No.
+Q. Why not?
+A. I didn't think he was going to. After I,
+after he was doing it, I was like, no, off me.
+Q. Did you, you told Dr. Kliman that you were
+uncomfortable with, what you referred to as, your
+body. I think the words used was "down there"; do
+you remember that?
+A. Yeah.
+Q. Are you talking about your vagina or your
+crotch area?
+A. Yeah.
+Q. Okay. And you said you'd been
+Page 424
+uncomfortable with it for some period of time.
+A. Yeah.
+Q. And you said that it didn't - you,
+something about you looked at other girls and you
+thought yours looked different or something like
+that?
+A. Yeah.
+Q. What is it you're referring to?
+A. The way that my vagina is shaped compared
+to other girls.
+Q. And what is it that's different about your
+vagina that's --
+A. My lips are a lot larger than other girls'
+lips are. They come out more, and that's why
+fle apstein said that I was his favorite girt in
+Q. Okay. And, and that's been true your
+whole life?
+A. Uncomfortable? Yeah.
+Q. Didn't prevent you from having sex with
+other men, right?
+A. You mean with Preston?
+Q. With anybody else. Your lawyer hadn't let
+you answered about the other people you've had sex
+with.
+30 (Pages 421 to 424)
+PROSE COURT REPORTING AGENCY, INC.
+cc1ec48b-651e-487e-8bb1-b21478ed0edd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 31 of
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+Page 425
+A. Maybe that's -- maybe that's why I've been
+with him for on and off with him for five or six
+years. So yeah, I was uncomfortable with other
+1
+2
+Q. Your current boyfriend, you had sex with
+4
+5
+him, right?
+A. After being with somebody that's abused me
+for like seven year, five years, do you think I'm
+comfortable - do you think I would go back to being
+with him if I was comfortable with my body?
+MR. MERMELSTEIN: Take it easy. Answer
+the question.
+BY MR. LUTTIER:
+Q. By the way, even after you went and got an
+injunction against domestic violence because of all
+the horrible things that Preston Vinyard did, you
+then wrote a letter to the court telling him you
+wanted him to lift the injunction, didn't you?
+A. Because he kept breaking it, breaking it
+and going back to jail, and I didn't want to see
+somebody have to go through that.
+Q. You had protection against him. Then you
+went and told the judge, release it, right?
+A. Yeah.
+Q. This was a guy that had been in jail
+7
+8
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+22
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+25
+Page 426
+before?
+1
+A. Yeah.
+2
+Q. Guy that had gotten you pregnant three
+3
+times before?
+4
+MR. MERMELSTEIN: Objection.
+5
+THE WITNESS: Before? No. It wasn't
+6
+three times.
+7
+BY MR. LUTTIER:
+8
+Q. So, after you got an injunction against
+9
+domestic violence, you hooked up with Preston
+10
+Vinyard again and got pregnant with him again, and
+11
+had another abortion with him; is that right?
+12
+MR. MERMELSTEIN: Objection, form.
+13
+BY MR. LUTTIER:
+14
+Q. Is that right?
+15
+A. Yeah.
+16
+ę. I mean, wouldn't -- have you discussed
+17
+that with this psychiatrist that you said you had
+18
+gone to in July of '09, Roberto (phonetic) or
+19
+Ruepto?
+20
+A. Rick Ruepto?
+21
+Q. Yeah. Have you talked to him a little bit
+22
+about that?
+23
+A. I haven't got a chance to.
+24
+Q. Well, how many times have you been to him? 25
+Page 427
+A. Well, yeah, I mean, I don't remember. We
+talked about several different things. So I am
+sure, yeah.
+Q. How many times have you been to him?
+A. How many times have I been?
+Q. Yeah, how many times have you been to him?
+• To Rick Ruepto?
+Q. Yeah.
+A. Yeah. I don't know, but I have been going
+there since August, maybe once or twice a week I've
+been going to see him. I don't know, maybe 30
+times.
+Q. Have you, has everything that you told him
+been the truth?
+A. Yes.
+Q. I'm going to tell you, we're going to get
+his records.
+A. Yeah.
+Q. All right. And have you told him the
+whole truth?
+A. Yeah.
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Told him about your abortions, right?
+A. Yeah.
+Page 428
+Q. Told him about Preston?
+MR. MERMELSTEIN: Objection.
+BY MR. LUTTIER:
+Q. Did you tell him Preston was violent
+towards you? Did you tell him that?
+A. Yeah.
+Q. Did you tell him everything that you've
+told me in this deposition?
+MR. MERMELSTEIN: Objection, form,
+overbroad.
+THE WITNESS: Not every single -- he knows
+a broad, broad information about certain
+things.
+BY MR. LUTTIER:
+Q. Okay. Who's paying his bill?
+A. Iam.
+Q. Okay. And where is his office?
+A. In Fort Pierce.
+Q. Fort Pierce. How would you get to Fort
+Pierce to get this fellow Ruepto? How did you get
+to him? Who referred you to him?
+A. I have somebody that I - my boyfriend's
+mother.
+Q. Who is that?
+A. Ricky -- or my ex -- yeah, Ricky.
+31 (Pages 425 to 428)
+11(601-051-976-2934)
+
+
+Case 9:08-cV-80119-KAM Document 430-3
+Entered on FLSD Docket 12/01/2009 Page 32 of
+1
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+Q. By the way, this guy that you had the
+Page 429
+domestic violence with that you got arrested for --
+A. That was my ex-boyfriend.
+Q. - are you still living with him?
+A. No, I live in Port St. Lucie.
+Q. Did you go hunting recently for
+A. Hunting for Haley?
+Q
+Yeah.
+A
+No.
+Q. Did you go try to find her at her place of
+employment?
+A. No.
+Q. Do you know why anybody would say you were
+at her place of employment looking for her?
+A. No.
+Q. Do you -- do you know where she works?
+A. Yeah.
+Q. You know where she works, don't you?
+Where does she work?
+A. Ra Bar.
+Q. Ra Bar located where?
+A. In Gardens.
+Q. Okay. And that's where you went Friday
+night and the domestic violence thing, isn't it?
+4
+5
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+Page 431
+A. I don't know her last name. She has been
+remarried.
+Q. Well, where do you find this lady?
+A. She lives in Port St. Lucie. I don't
+know.
+her?
+Q. How, how is it, how is it you got ahold of
+A. I didn't get ahold of her. She didn't
+tell me. She gave Ricky the, the name, and I got
+the name through Ricky.
+Q. Well, did you call her and ask her about
+the guy?
+A. No. She gave information to her son,
+which her son then gave the information to me.
+Q. Have you ever talked to her on the phone?
+A. Have I talked to her on the phone? Yeah.
+Q. Do you know her phone number?
+A. No.
+Q. Have you got it in your cellphone?
+Q. Now, why is it that -- how did this lady,
+you never talked to her, how did she even know you
+were looking for a psychiatrist?
+A. It was somebody that she knew, knows from
+her church, and her -- she -- her son is seeing him,
+1
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+Page 430
+A. I didn't go there looking for her. We had
+to go there because my boyfriend didn't have his ID,
+so we couldn't get into the Yard House and we needed
+something to eat, and we were in that area so we
+went there --
+Q. Did you tell anybody --
+A. - to eat because you have to have an ID
+to get into Yard House --
+Q
+Did you tell --
+A
+- even if you want to eat food at that
+current time that we went there.
+Q. Did you tell anybody when you were at the
+Ra Bar that you were working for
+A. No, I didn't even bring up Haley's name.
+Q. Do you know why a message would have been
+left if you were looking for her?
+A. No, because I never even brought up her
+1
+2
+3
+Page 432
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+Q. Okay. Now, you say -- what's this Ricky
+or whatever this boyfriend's name is,
+what's his mother's name?
+A. Robby.
+Q. Bobby (sic) what?
+A. Robby.
+Q. Robby. Robby what?
+18
+19
+20
+21
+22
+23
+24
+25
+a psychiatrist, too.
+Q. The guy that you had the domestic
+violence --
+A. She got it for her son. Yeah, she got it
+for her son.
+Q. So, what really happened was Ricky was
+going to this --
+A. Uh-huh.
+Q. - psychiatrist, and that's really where
+you got the name was from Ricky, not from his
+mother --
+A. Yeah.
+Q. - isn't that right?
+A. Yeah. Well, his mother is the one that
+referred him, and so I got the name from his mother,
+not from Ricky.
+Q. The person that you, first told you about
+it was Ricky, wasn't it?
+A. Yeah.
+Q. Not his mother. Ricky told you who he was
+going to?
+A. No, like, yeah.
+Q. Yeah, right?
+A. Yeah, Ricky. Ricky and his mother.
+Q. So, so Ricky then told you that he was
+32 (Pages 429 to 432)
+cc1ec48b-651e-487e-8bb1-b2f47Bed0edd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 33 of
+47
+Page 433
+1
+2
+going to this doctor -
+A.
+3
+Me and him started going at the same time,
+4
+so it wasn't something that he had been going to for
+5
+years. Me and him started going to see him at the
+6
+same time. So, it's somebody that his mother
+7
+referred both of us to because she knows about my
+8
+situations as well with Mr. Epstein.
+9
+10
+BY MR. LUTTIER:
+MR. MERMELSTEIN: Wait for a question.
+11
+Q. So, you told Ricky's mom about this
+12
+situation, too. She's another person that knows
+about this situation.
+13
+14
+A. No, she doesn't know about the situation;
+15
+she knows that I've been in a sex, sexual, like,
+been sexually abused.
+16
+17
+it?
+Q. I thought you told me you told her about
+18
+19
+20
+21
+22
+23
+24
+25
+A. I didn't tell her about it. She knows,
+she knows that I've experienced, I've had a bad past
+and experience. That's what Ricky has told him mom.
+Q. Well, she's know about Jeffrey Epstein,
+didn't you say?
+A. No.
+Q. Didn't you just say she did?
+A. No.
+1
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+ride in the car to the office?
+Page 435
+A. No, just ride in the -- go ride to the
+office with him.
+Q. And did you ever have an appointment with
+this doctor with Ricky?
+A. I have gone in there with him, yeah.
+here.
+Q. Okay. So, now, let's not play semantics
+A. No, appointments for me and him? No.
+I've gone there in with him and listened to his --
+him talk to the psychiatrist, but not about me and
+him.
+Q. You walked in a doctor's office with a
+doctor there and Ricky there and listened to what
+was going on. You were part of that conference,
+right?
+A. Yeah.
+Q. Have you done that more than once?
+A. Yeah.
+Q. How many times have you done that?
+A. Maybe three times.
+Q. When was the last time?
+A. I don't remember.
+Q. And how many times have you gone to this
+doctor alone as just you?
+1
+2
+3
+4
+6
+7
+8
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+10
+11
+12
+13
+15
+16
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+21
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+Q. Okay. So what really happened was you and
+Ricky went to this Dr. Ruepto because of problems
+that you two had; isn't that right?
+A. No.
+Q. And the two of you went to see him
+together?
+1
+2
+3
+4
+5
+6
+A. No.
+Q. You didn't do that?
+A. No.
+8
+Q. You never discussed any problems --
+9
+A. I've gone there with him, but we've never
+10
+gone there to discuss problems, never problems with,
+11
+about me and him.
+12
+Q. Okay. Well, why was he going?
+13
+A. About his parents, like his past with his
+14
+15
+parents.
+Q. What about his past?
+16
+A. Parents are divorced.
+17
+Q. Okay. So, and he just said, you want to
+18
+ride along with me one time; I'm going to this
+19
+doctor?
+20
+yes.
+A. He asked me to go with him, and I said
+21
+22
+Q. When you said, go with him, what do you
+mean, go in and see the doctor with him, or just
+23
+24
+25
+A. Several times.
+Page 436
+Q. How many?
+A. I don't know.
+Q. And how many times have you gone and
+Ricky's been in the meeting with you and the doctor?
+A. Like I have, maybe -- I don't know.
+Q. More than once?
+A. Yeah. I don't know.
+Q. You don't know if it's more than once?
+A. Yeah, probably more -- yeah, more than
+once, but I don't know how many. Like, what do you
+mean, more than once?
+Q. Well, what does more than once mean?
+A. Yeah, like more than once, yeah.
+Q. Okay. And how much --
+A. But how many times, I don't know.
+Q. And how often do you go for these
+sessions?
+A. Like once or twice a week.
+Q. And where in Fort Pierce is this office?
+A. Off of A1A.
+Q. Do you have an address?
+A. No, I just know exactly where it's at from
+driving there.
+Q. Okay. Well, I want to make sure I have
+33 (Pages 433 to 436)
+cc1ec48b-651e-487e-Bbb1-b2f47BedDedd
+
+
+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 34 of
+1
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+Page 437
+this. It's R-u-e-b-t-o (sic).
+A. Yeah, best of my knowledge.
+Q. Is he a psychiatrist or psychologist or
+neither?
+A. No, he's, he's a psychiatrist.
+Q. Is he -- can he prescribe medication?
+A. I think so, yeah.
+Q. Has he prescribed any medication for you?
+A.
+No.
+Has he prescribed any medication for
+Ricky?
+A. No.
+Q. Are you on any medication at the present
+time?
+A. No.
+Q. And how much does he charge you for each
+of these visits?
+A. Like $50 a visit.
+Q. Okay. 45 minute session?
+A. An hour.
+Q. An hour session. Have you ever seen
+Jeffrey Epstein's penis?
+A. Yes.
+Q. Had you seen a man's penis before you saw
+Jeffrey Epstein's penis?
+1
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
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+25
+Page 438
+A. I don't remember.
+Q. You don't remember?
+A. You've already asked me this question, and
+I don't remember whenever I saw Preston's, so I
+don't remember. Yeah, I think so.
+Q. Okay.
+MR. MERMELSTEIN: Make sure of, sure your
+answer. Don't just answer for the sake of
+answering.
+THE WITNESS: For him, yeah, I don't
+remember.
+BY MR. LUTTER:
+Q. Did -- was there ever anything that you
+said that you saw Mr. Epstein at some point
+masturbate. I think your terms were jerking off, to
+be exact. Do you recall that testimony?
+A. Yeah.
+Q. And when did that first occur?
+A. After I started getting naked after, like,
+my fifth or sixth visit. After I had already, like,
+whenever I started taking clothings off.
+Q. Did he ask you if he could do that?
+A. No.
+Q. Did you tell him not to do that?
+A. No.
+8
+9
+10
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+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 439
+Q. Was anyone else ever present for your
+sessions between you and Mr. Epstein?
+A. No.
+Q. Did you ever tell Mr. Epstein you didn't
+want him to masturbate?
+A. No.
+Q. Did Mr. Epstein ever penetrate any orifice
+of your body with a vibrator?
+A. No.
+Q. He just put it on the top of your clit?
+A. Yeah.
+Q. Did Mr. Epstein ever penetrate your anus
+with any object?
+A. No.
+Q. Did he ever penetrate your anus with any
+organ of his body?
+A. No.
+Q. Did you ever tell Mr. Epstein on any of
+these sessions that you had with him that you
+enjoyed it?
+A. Not that I remember.
+Q. Did you ever use any words to that effect
+with him --
+A. Not that I remember.
+Q. - saying that that was great or I enjoyed
+Page 440
+it.
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: I don't remember.
+BY MR. LUTTIER:
+Q. Did you ever tell anyone that you wished
+your boyfriend was more like Mr. Epstein, in
+particularly that you would like it if your
+boyfriend was rougher like Mr. Epstein in having
+sex?
+MR. MERMELSTEIN: Objection to form.
+THE WITNESS: No, I don't remember.
+BY MR. LUTTIER:
+Q. Do you recall telling Dr. Kliman that?
+A. No, I don't remember saying that.
+Q. If, if you told him that, it was true,
+MR. MERMELSTEIN: Objection to form,
+speculation.
+THE WITNESS: I don't remember saying
+that, so like, I don't know.
+BY MR. LUTTIER:
+Q. Do you remember telling Kliman that you --
+A. No, I don't remember saying that to
+Dr. Kliman.
+Q. You and
+were talking about
+34 (Pages 437 to 440)
+PROSE COURT REPORTING AGENCY, INC.
+cetec48b-651e-487e-8bb1-b2147BedOedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 35 of
+1
+Page 441
+it, and you and the other girls and you kid that you
+wished your boyfriends were more like, more like
+3
+4
+A. I don't remember talking to him about it,
+5 no. I'm sorry.
+6
+Q. But you did talk to your girlfriends about
+7 your -- communicatively you-all talked about your
+8
+sexual experiences with Mr. Epstein?
+9
+A. Girlfriends? Yeah, we did.
+10
+Q. Yeah. The other girls that were going to
+11
+see him.
+12
+A. Yeah.
+13
+Q. And you-all knew what each other were
+14
+doing, right?
+15
+A. Yeah.
+16
+17
+Q. You knew who was letting them finger them,
+to use your words?
+18
+A. No, not -- not exactly.
+19
+Q. Who was doing what?
+20
+A. No, we just knew -- I mean, pretty much,
+21
+22
+if you got $200, you weren't doing things. If you
+got $300, you're doing more than just giving him a
+23
+massage and leaving. So if you say, how much money
+24
+did you get, and then that referred to,
+, you must
+25
+have done something --
+1
+2
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+25
+Q. And you knew --
+A. - and just referring, because you knew
+what you've done, so not saying,
+I, this is, this
+is me giving you details, Jane Doe No. 7, of what
+I've done, no. It was, you know,
+how much money
+did you get, , okay. So then it was kind of like
+in the back of your mind you're - you know.
+MR. LUTTIER: Well, I'm going to have to
+stop now because I've got another appointment
+that I have to get to, so this would be a good
+place to stop as any.
+THE VIDEOGRAPHER: Going off the record.
+It is 6:04. It's the end of Tape 3 of 3.
+MR. LUTTIER: We're just adjourning the
+depo.
+MR. MERMELSTEIN: We understand that.
+MR. LUTTIER: Okay.
+MR. MERMELSTEIN: And I understand that
+you had a discussion before regarding the
+seven-hour time limit with Mr. Horowitz here.
+MR. LUTTIER: Well, no, we didn't have any
+discussions at all before about it.
+MR. CRITTON: He raised the seven-hour
+time limit, and I told him if he looked at the
+consolidation order, the consolidation order
+1
+5
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+Page 443
+did not limit, visa vis it was removed.
+MR. MERMELSTEIN: I don't think so. Well,
+the seven-hour time limit is by rule within the
+Federal Rules.
+MR. LUTTIER: Yeah, but there's an order
+that's been entered since then.
+MR. MERMELSTEIN: Yes, it gives you a
+one-day deposition. And a one-day deposition
+in the Federal - in the Federal Rules is seven
+hours, so our position is you have seven hours.
+MR. LUTTIER: I understand.
+MR. CRITTON: I'm telling you that Judge
+Marra, in the consolidation order, is very
+specific with regard to the seven-hour rule
+with regard to this case.
+MR. MERMELSTEIN: You turn into a pumpkin
+at seven hours. If you want, if you want more,
+you're going to have to go back to the judge.
+MR. CRITTON: So the judge has entered an
+order; you're saying you're not going to obey
+that order?
+MR. MERMELSTEIN: I am saying the judge
+had -- show me an order where he says you get
+more than seven hours. The consolidation order
+you refer to, I have it right here in my hand,
+Page 444
+it says you get one day. That to me is seven
+hours. The Federal Rules provide seven hours.
+I think it's clear.
+MR. CRITTON: Let me read it. Let me read
+it.
+MR. LUTTIER: I think the only reference
+to specific hours is when he said that.
+MR. MERMELSTEIN: Yeah, let me read it.
+Let me read it. As to each of the ten above
+styled cases, the Defendant is limited to a
+single deposition of each Plaintiff.
+MR. LUTTIER: Single deposition, it
+doesn't say that. At any rate, everybody knows
+what the other person's interpretation is.
+MR. MERMELSTEIN: Right. Well, yeah. I
+mean, but to say that there's a clear order
+here which gives you the right to take a longer
+deposition, that's not the case.
+MR. CRITTON: This is an order, and just
+so it's clear, this is Docket Entry 86. There
+was a subsequent order that he entered.
+MR. LUTTIER: Okay.
+MR. CRITTON: Or a prior order.
+MR. MERMELSTEIN: If that's the case,
+provide it to me. I mean, you refer to the
+35 (Pages 441 to 444)
+
+
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+Case 9:08-cv-80119-KAM Document 430-3 Entered on FLSD Docket 12/01/2009 Page 36 of
+Page 445
+consolidation of -
+MR. CRITTON: I'm not going to provide you
+that, but I'll refer to you -- I'll send you
+the document.
+MR. MERMELSTEIN: We're supposed to
+cooperate. I mean, if I'm missing something,
+then --
+MR. CRITTON: No, no, listen to me,
+Stuart.
+MR. MERMELSTEIN: -- let me know.
+MR. CRITTON: Listen to me, Stuart.
+MR. MERMELSTEIN: What?
+MR. CRITTON: I said what I will do is
+I'll reference the docket number so you can
+look it up because it will be in your file.
+3
+4
+5
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+8
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+10
+11
+12
+13
+14
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+MR. MERMELSTEIN: That, that's fine.
+MR. LUTTIER: Give me a chance. It's like
+16
+your witness. If you listen to the question,
+17
+you're going to get an answer. Okay?
+18
+19
+MR. CRITTON: You guys are gone. We're
+120
+going to stay here until I know. I am assuming
+21
+I am going to give you three minutes to escape
+|22
+23
+MR. MERMELSTEIN: Five minutes.
+24
+25
+Page 447
+CERTIFICATE OF OATH
+THE STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I, the undersigned authority, certify that
+JANE DOE NO. 4 personally appeared before me and was
+duly sworn on the 27th day of October, 2009.
+Dated this 6th day of November, 2009.
+Cynthia H
+RPR, FPR
+Notary Public - State of Florida
+My Commission Expires: February 25, 2011
+My Commission No.: DD 643788
+Page 446
+MR. CRITTON: Yeah, yeah.
+THE COURT REPORTER: Are you ordering
+this?
+MR. CRITTON: Yes.
+(Witness excused.)
+(Deposition was adjourned.)
+Page 448
+9
+10
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+22
+23
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+25
+CERTIFICATE
+THE STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I, Cynthia l
+Registered Professional
+Reporter, Florida Proressional Reporter and Notary
+Public in and for the State of Florida at large, do
+hereby certify that I was authorized to and did
+report said deposition in stenotype; and that the
+foregoing pages are a true and correct transcription
+of my shorthand notes of sald deposition.
+I further certify that said deposition was
+taken at the time and place hereinabove set forth
+and that the taking of said deposition was commenced
+and completed as herelnabove set out.
+I further certify that I am not attorney or
+Cynthia MI
+TL RPR, FPR
+PROSE COURT REPORTING AGENCY, INC.
+36 (Pages 445 to 448)
+cclec48b-651e-487e-8bb1-b2f478ed0edd
+
+
+10
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+22
+23
+24
+25
+Entered on FLSD Docket 12/01/2009 Page 37 of
+Page 449
+DATE:
+November 5th, 2009
+JANE DOE NO. 4
+A c/o Adam D. Horowitz, Esquire
+-MERMELSTEIN & HOROWITZ, P.A
+18205 Biscayne Boulevard
+11 маті,
+Stipe 2218
+Farida 33160
+IN RE:
+One Doe No. 2 vs. Epstein
+MARRA/!
+Page 451
+sday, the 27th of
+sosition in the
+i you did not
+waive signature. Guis nov
+assary that you sign
+your der
+4997.
+As previdudy agreed
+the petscripe will be
+furnished to yog trough
+r counsel, Please read
+he following instrostipns ca
+At the end of the transcri
+number of said change. DO Norite 6fthy
+transcript itself.
+Once you have read the
+Sure to sign
+and date the errata sheet and retum the pages to
+If you do not read and sign the depositión
+within a reasonable time, the original, which has
+already been forwarded to the ordering attamey, may
+be filed with the Clerk of the Court. If you wish
+to waive your signature, sign your name in the blank
+at the bottom of this letter and retum It to us.
+Very truly yours,
+Cynthia 4
+_RPR, FPR.
+I do hereby waive my signature.
+JANE DOE NO. 4
+5
+ERRATA SHEET
+IN RE: JANE DOE NO. 2 VS. EPSTEIN
+Ri cynthia FL
+DEPOSITION OF: JANE DOE NO.
+TAKEN: October 27, 2009.
+DO NOT WRITE ON TRANSCRIPT - ENTER CHANGES HERE
+PAGE # LINE # CHANGE
+REASON
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+Please forward the original signed errata sheet to
+this office so that copies may be distributed to all
+parties.
+Under penalty of perjury, I declare that I have read
+my deposition and that it is true and correct
+subject to any changes in form or substance entered
+here.
+DATE:
+SIGNATURE OF
+DEPONENT:
+25
+Page 450
+CERTIFICATE
+THE STATE OF FLORIDA
+COUNTY OF PALM BEACH
+I hereby certify that I have read the foregoing
+deposition by me given, and that the statements
+contained herein are true and correct to the best of
+my knowledge and belief, with the exception of any
+corrections or notations made on the errata sheet,
+if one was executed.
+Dated this
+2009.
+day of
+JANE DOE NO. 4
+37 (Pages 449 to 451)
+(561) 832-7500 PROSE COURT REPORTING AGENCY, INC.
+cc1ec48b-651e-487e-8bb1-b2f478eddedd
+
+
+Entered on FLSD Docket 12/01/2009 Page 38 of
+A
+Page 1
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+Entered on FLSD Docket 12/01/2009 Page 42 of
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+Entered on FLSD Docket 12/01/2009 Page 43 of
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+
+Entered on FLSD Docket 12/01/2009 Page 44 of
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diff --git a/vision-fixhub/court-01/fbbfbf6e4c6a680eafc27669fc0f1da67e4eebb9acf7855635013ebe7b939f3e.md b/vision-fixhub/court-01/fbbfbf6e4c6a680eafc27669fc0f1da67e4eebb9acf7855635013ebe7b939f3e.md
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@@ -0,0 +1,448 @@
+Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 1 of 11
+JANE DOE NO. 2,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-,
+Plaintiff,
+DOCKET
+2/25/09
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S RESPONSE & OBJECTION:
+O PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIE
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+serves his responses and objections to Plaintiff's December 9, 2008 Amended First Set
+Of Interrogatories To Defendant Jeffrey Epstein, attached hereto.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing has been sent by fax and
+U.S. Mail to the following addressees this _26th
+_ day of January, 2009:
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+iherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+
+
+
+• Case 9:08-cV-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 2 of 11
+Page 2
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclglaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 3 of 11
+Page 3
+DEFENDANT JEFFREY EPSTEIN'S ANSWERS AND OBJECTIONS TO
+PLAINTIFF'S AMENDED FIRST SET OF INTERROGATORIES
+Interrogatory No. 1.
+Identify all employees who performed work of services inside
+the Palm Beach Residence.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for a time period from
+January 1, 2003 until present. Also, see "Employee" as defined in paragraph g of
+Plaintiff's interrogatories.
+Interrogatory No. 2.
+Identify all Employees not identified in response to
+interrogatory no. 1 who at any time came to Defendant's Palm Beach Residence.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for "all Employees" "who at
+any time" came to the residence. Also, see "Employee" as defined in paragraph g of
+Plaintiff's interrogatories.
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 4 of 11
+Page 4
+Interrogatory No. 3.
+Identify all persons who came to the Palm Beach Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and 1 must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005."
+Interrogatory No. 4.
+Identify all persons who came to the New York Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005."
+Interrogatory No. 5.
+Identify all persons who came to the New Mexico Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 5 of 11
+Page 5
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of in or
+about 2004-2005."
+Interrogatory No. 6.
+Identify all persons who came to the St.
+Residence
+and who gave a massage or were asked to give a massage to Defendant.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005."
+Interrogatory No. 7.
+List all the time periods during which Jeffrey Epstein was
+present in the State of Florida, including for each the date he arrive and the date he
+departed.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 6 of 11
+Page 6
+discovery of admissible evidence. Plaintiff's Complaint alleges a time period of "in or
+about 2004-2005." Plaintiff's interrogatory seeks information for a time period from
+January 1, 2003 until present.
+Interrogatory No. 8.
+Identify all of Jeffrey Epstein health care providers in the
+past (10) ten years, including without limitation, psychologists, psychiatrists, mental
+health counselors, physicians, hospitals and treatment facilities.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. In addition, such information is privileged pursuant to
+Rule 501, Fed. Evid., and §90.503, Fla.Evid. Code. In addition, such information is
+protected by the provisions of the Health Insurance Portability and Accountability Act
+(HIPAA).
+Interrogatory No. 9.
+List all items in Jeffrey Epstein's possession in Palm Beach,
+Florida, at any time during the period of these interrogatories, which were used or
+intended to be used as sexual aids, sex toys, massage aids, and/or vibrators, and for
+each, list the manufacturer, model number (if applicable), and its present location.
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's Amended Complaint alleges a time period
+of "in or about 2004 - 2005," while Plaintiff's interrogatory seeks information from
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 7 of 11
+Page 7
+January 1, 2003, until present. Further, the request is meant to embarrass and harass
+the Defendant.
+Interrogatory No. 10.
+Identify all persons who provide transportation services to
+Jeffrey Epstein, whether as employees or independent contractors, including without
+limitation, chauffeurs and aircraft crew.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff places no time limitation.
+Interrogatory No. 11.
+Identify all telephone numbers used by Epstein, including
+cellular phones and land lines in any of his residences, by stating the complete
+telephone number and the name of the service provider.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant also objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's allegations claim a time period of "in or
+about 2004-2005" and involve Defendant's Palm Beach residence.
+Interrogatory No. 12.
+Identify all telephone numbers of employees of Epstein,
+used in the course or scope of their employment, including cellular phones and land
+lines in any of his residences, by stating the complete telephone number and the name
+of the service provider.
+
+
+• Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 8 of 11
+Page 8
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects as the
+interrogatory is overbroad and seeks information that is neither relevant to the subject
+matter of the pending action nor does it appear reasonably calculated to lead to the
+discovery of admissible evidence. Plaintiff's allegations claim a time period of "in or
+about 2004-2005" and involve Defendant's Palm Beach residence.
+Interrogatory No. 13.
+List the names and addresses of all persons who are
+believed or known by your, your agents, or your attorneys to have any knowledge
+concerning any of the issues in this lawsuit; and specify the subject matter about which
+the witness has knowledge.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, the interrogatory seeks information
+that is attorney-client and work product privileged as it seeks information known by
+Defendant's attorneys. The interrogatory is so overbroad that Defendant cannot
+reasonably form a response, including the raising of additional privileges which may
+apply. Without waiving any objection, see Rule 26 disclosures made by Defendant's
+counsel in this case.
+Interrogatory No. 14.
+State the name and address of every person known to you,
+your agents, or your attorneys who has knowledge about, possession, or custody, or
+control of, any model, plat, map, drawing, motion picture, videotape or photograph
+pertaining to any fact or issue involved in this controversy; and describe as to each,
+what item such person has, the name and address of the person who took or prepared
+it, and the date it was taken or prepared.
+
+
+: Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 9 of 11
+Page 9
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, the interrogatory seeks information
+that is attorney-client and work product privileged as it seeks information known by
+Defendant's attorneys.
+Interrogatory No. 15.
+Identify all persons who have made a claim, complaint,
+demand or threat against you relating to alleged sexual abuse or misconduct on a
+minor, and for each provide the following information:
+a. The person's full name, last known address and telephone number;
+b. The person's attorney, if represented;
+c. The date of the alleged incidents);
+d. If a civil case has been filed by or on behalf of the person, the case number
+and identifying information.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges and without waiving such objection,
+with regard to subparagraph (d), Defendant's counsel states that such information is
+public record and equally attainable by Plaintiff.
+Interrogatory No. 16.
+State the facts upon which you intend to rely for each denial
+of a pleading allegation and for each affirmative defense you intend to make in these
+cases.
+Answer:
+Defendant is asserting specific legal objections to the interrogatories as
+well as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that I cannot provide
+answers to any questions relevant to this lawsuit and I must accept this advice or risk
+
+
+Case 9:08-cv-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 10 of 11
+Page 10
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his
+constitutional privileges, no answer to the Amended
+Complaint has been filed by defense counsel in this case; however, Defendant does not
+intend to waive his constitutional privilege against self-incrimination. Defendant further
+objects in that Plaintiff's interrogatory attempts to obtain discovery in other cases filed
+by her undersigned counsel.
+Interrogatory No. 17.
+Identify all witnesses from whom you have obtained or
+requested a written, transcribed or recorded statement relating to any issue in these
+cases, and for each, in addition to the witness's identifying information, state the date of
+the statement and identify the person taking the statement.
+Answer: Defendant is asserting specific legal objections to the interrogatories as well
+as his U.S. constitutional privileges. I intend to respond to all relevant questions
+regarding this lawsuit, however, my attorneys have counseled me that | cannot provide
+answers to any questions relevant to this lawsuit and | must accept this advice or risk
+losing my Sixth Amendment right to effective representation. Accordingly, I assert my
+federal constitutional rights under the Fifth, Sixth, and Fourteenth Amendments as
+guaranteed by the United States Constitution. Drawing an adverse inference under
+these circumstances would unconstitutionally burden my exercise of my constitutional
+rights, would be unreasonable, and would therefore violate the Constitution. In addition
+to and without waiving his constitutional privileges, Defendant objects to this
+interrogatory in that it seeks information that is attorney-client and work product
+privileged. In addition, the request is overbroad in that it seeks information "relating to
+any issue."
+STATE OF Florida
+COUNTY OF Palm Beach)
+I hereby certify that on this day, before me, an officer duly authorized to administer oaths
+and take acknowledgments, personally appeared Jeffrey
+Epstein
+Known to
+me to be the person described in and who executed the foregoing Interrogatories who
+
+
+•Case 9:08-CV-80119-KAM Document 57-1 Entered on FLSD Docket 03/02/2009 Page 11 of 11
+Page 11
+acknowledged before me that he/she executed the same, that I relied upon the following form of
+identification of the above-named person: personally known/identification, and that an oath
+was/was not taken.
+WITNESS my hand and official seal in the County and State last aforesaid this _ 26 #h
+day of January
+, 2009.
+Sanancia Alanis
+(SEAL)
+NOTARY PUBLIC-STATE OF FLORIDA
+Nayanira Alanis
+Commission #DD841844
+an Expires: DEC. 01, 2012
+BONDED THRU ATLANTIC BONDING CO., INC.
+PRINT NAME: Nayanira Alanis
+Notary Public/State of Florida
+Commission #:
+My Commission Expires:
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fbbfbf6e4c6a680eafc27669fc0f1da67e4eebb9acf7855635013ebe7b939f3e.receipt.json b/vision-fixhub/court-01/fbbfbf6e4c6a680eafc27669fc0f1da67e4eebb9acf7855635013ebe7b939f3e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..08da33004f0103df59f8793de0d3e85d6f88286c
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/fbcc07bb75032a7cdc7faf197d90b1612f6d053ec464d42cf0f3aabeae94432f.md b/vision-fixhub/court-01/fbcc07bb75032a7cdc7faf197d90b1612f6d053ec464d42cf0f3aabeae94432f.md
new file mode 100644
index 0000000000000000000000000000000000000000..a5411a9f64b40b80c8bcac6d8b3c426a962f7db7
--- /dev/null
+++ b/vision-fixhub/court-01/fbcc07bb75032a7cdc7faf197d90b1612f6d053ec464d42cf0f3aabeae94432f.md
@@ -0,0 +1,89 @@
+Case 9:09-cv-80591-KAM Document 31-1 Entered on FLSD Docket 05/27/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 6,
+Plaintiff,
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRAJ
+CASE NO.: 08-CV-80381-MARRA/
+CASE NO.: 08-CV-80994-MARRA/
+
+
+Case 9:09-cv-80591-KAM Document 31-1 Entered on FLSD Docket 05/27/2009 Page 2 of 3
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 7,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/_
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRAJ
+DOE II,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN et al.,
+Defendant.
+CASE NO.: 08-CV- 80469-MARRA/_
+
+
+Case 9:09-cv-80591-KAM Document 31-1 Entered on FLSD Docket 05/27/2009 Page 3 of 3
+JANE DOE NO. 101,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80591-MARRA/
+JANE DOE NO. 102,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA/
+ORDER
+Upon Plaintiffs' Motion for Enlargement of Time to Respond to Defendant's Motion to
+Compel and/or Identify Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third
+Party Subpoenas for Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and
+good cause being shown, it is hereby
+ORDERED that Plaintiffs' Motion is granted. Plaintiffs shall have an enlargement of time of
+twenty (20) days until June 11, 2009, to respond to the Defendant's Motions to Compel and/or
+Identify Jane Doe in the Style, et al..
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida,
+this_
+day of
+., 2009.
+DISTRICT COURT JUDGE
diff --git a/vision-fixhub/court-01/fbcc07bb75032a7cdc7faf197d90b1612f6d053ec464d42cf0f3aabeae94432f.receipt.json b/vision-fixhub/court-01/fbcc07bb75032a7cdc7faf197d90b1612f6d053ec464d42cf0f3aabeae94432f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0269ec76bd72ae80c2e238400b0090fcbc2b6958
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "adc5afc1a17e9e0476750d17464138819254834052146ac5c7dcc956b6fbc5f1",
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+}
diff --git a/vision-fixhub/court-01/fbcc99695d1859c351c0d99ad4efffb1f4b559084204204082478b99727134e2.md b/vision-fixhub/court-01/fbcc99695d1859c351c0d99ad4efffb1f4b559084204204082478b99727134e2.md
new file mode 100644
index 0000000000000000000000000000000000000000..3b224df1a05c146bf073ba420111c30ee7dd7de2
--- /dev/null
+++ b/vision-fixhub/court-01/fbcc99695d1859c351c0d99ad4efffb1f4b559084204204082478b99727134e2.md
@@ -0,0 +1,105 @@
+Case 9:08-cv-80119-KAM Document 148 Entered on FLSD Docket 06/09/2009 Page 1 of 4
+JANE DOE NO. 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-|
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+_!
+DEFENDANT EPSTEIN'S UNOPPOSED FIRST MOTION TO AMEND
+AFFIRMATIVE DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys, moves to amend his affirmative defenses as set forth in the
+attached Defendant EPSTEIN's First Amended Answer & Affirmative Defenses to
+Plaintiff's Second Amended Complaint, attached hereto as Exhibit A. Rule 15(a),
+Fed.R.Civ.P. (2009); Loc. Gen. Rules 7.1, 15.1 (S.D. Fla. 2009):
+1. Pursuant to Rule 15(a)(2), Fed.R.Civ.P., a party may amend his pleading "only
+with the opposing party's written consent or the court's leave. The court should freely
+give leave when justice so requires." Plaintiff's counsel has consented in writing to
+Defendant's proposed amendments set forth in Exhibit A hereto. Plaintiff's written
+consent to the amendment is attached hereto as Exhibit B.
+2. It is well settled that leave to amend is liberally granted where, as here, there is
+no resulting prejudice. The liberal allowance of pleading amendments is a "recognition
+that controversies should be decided on the merits whenever practicable." See
+generally, 27A Fed.Proc., Lawyers Ed. §62.273. Generally; freely allowed (2008). "In
+
+
+Case 9:08-cv-80119-KAM Document 148 Entered on FLSD Docket 06/09/2009 Page 2 of 4
+the absence of any apparent or declared reason-such as undue delay, bad faith or
+dilatory motive on the part of the movant, repeated failure to cure deficiencies by
+amendments previously allowed, undue prejudice to the opposing party by virtue of
+allowance of the amendment, futility of amendment, etc.--the leave sought should, as
+the rules require, be freely given.'" Foman v.
+1. 371 U.S. 178, 182, 83 S.Ct. 227, 9
+L.Ed.2d 222 (1962).
+3. In the instant case, Defendant only amended his affirmative defenses. This is
+the first amendment sought by Defendant. Defendant's original Answer and Affirmative
+Defenses to Plaintiff's Second Amended Complaint was recently filed with this Court on
+April 2, 2009. Recently certain constitutional issues have come to the forefront in other
+litigation filed against EPSTEIN based on similar allegations regarding the 18 U.S.C.
+§2255 claim and the punitive damages claim. Accordingly, Defendant seeks to add
+affirmative defenses directed to those claims. See affirmative defenses in Exhibit A
+hereto.
+4. There will be no resulting prejudice to Plaintiff should leave to amend be granted.
+Defendant has not unduly delayed this matter in seeking the amendments. Defendant
+by written correspondence sought Plaintiff's permission to amend. As noted, Plaintiff
+agreed in writing to the amendments. See Exhibit B hereto.
+5. Accordingly, Defendant is entitled to the amendments sought. Upon this Court
+entering the order granting Defendant's motion to amend, he will file and serve the
+Amended Answer and Affirmative Defenses to Plaintiff's Second Amended Complaint.
+Loc. General Rule 15.1 (S.D. Fla. 2009).
+- 2-
+
+
+Case 9:08-cv-80119-KAM Document 148 Entered on FLSD Docket 06/09/2009 Page 3 of 4
+WHEREFORE, Defendant respectfully requests that this Court enter an order
+granting Defendant's motion to amend.
+Rule 7.1 Certification
+I hereby certify that Defendant's counsel communicated in writing with Plaintiff's
+counsel regarding this motion to amend. Plaintiff's counsel agreed in writing to the
+proposed attached amendment (See Exhibit A and B).
+Attorney for Defendant Epsteir
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this JI day of June, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+- 3-
+
+
+Case 9:08-cv-80119-KAM Document 148 Entered on FLSD Docket 06/09/2009 Page 4 of 4
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
+- 4-
diff --git a/vision-fixhub/court-01/fbcc99695d1859c351c0d99ad4efffb1f4b559084204204082478b99727134e2.receipt.json b/vision-fixhub/court-01/fbcc99695d1859c351c0d99ad4efffb1f4b559084204204082478b99727134e2.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5bb8f16eca89e8bfa2bbcd7365208f26f2ece248
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@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/fbd01f974c8af8995de22a083690f7d2513706b1c42ced5e85bc4af2162e6f22.md b/vision-fixhub/court-01/fbd01f974c8af8995de22a083690f7d2513706b1c42ced5e85bc4af2162e6f22.md
new file mode 100644
index 0000000000000000000000000000000000000000..d9fdefd47a87d49072f8077d36f93b288b562ce9
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@@ -0,0 +1,91 @@
+Case 9:08-cv-80736-KAM Document 101 Entered on FLSD Docket 09/28/2011 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANDE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S UNOPPOSED MOTION FOR EXENSION OF
+TIME TO RESPOND TO SUPPLEMENTAL BRIEFING IN SUPPORT OF MOTION TO
+INTERVENE BY ROY BLACK ET AL.
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move this Court to allow one extra week (7 days) for them to
+respond to the Supplemental Briefing in Support of Motion to Intervene of Roy Black,
+Weinberg, and Jay Lefkowitz (DE 94) and the government response thereto (DE 100). The
+motion is unopposed.
+In support of the motion, the victims note that the briefing schedule set by the Court for
+the victims to respond to the supplemental pleading and government initially contemplated the
+victims brief being filed 10 days earlier. As the result of the Government's (unopposed) motion
+for extension of time, it now appears that the victims' pleading is due on Monday, October 3.
+Co-counsel for the victims, Paul Cassell, is writing the initial draft of the victims" response.
+However, he has a long-scheduled trip to Chicago the three days preceding the filing of the brief.
+His research assistant who is working on the case is also currently ill.
+The victims also hope to be able to file a comprehensive response to numerous new
+issues raised by the Government's pleading and can do so if additional time is granted.
+1
+
+
+Case 9:08-cv-80736-KAM Document 101 Entered on FLSD Docket 09/28/2011 Page 2 of 3
+The victims have conferred with counsel for the Government and the counsel for Roy
+Black, who have stated that they have no objection to the granting of this motion.
+CONCLUSION
+For all the foregoing reasons, the Court should allow Jane Doe #1 and Jane Doe #2 one
+extra week, to and including Monday October 10, 2011, to respond to the Supplemental Briefing
+in Support of Motion to Intervene of Roy Black,
+Weinberg, and Jay Lefkowitz (DE 94)
+and the government response thereto (DE 100).
+DATED: September 28, 2011
+Respectfully Submitted,
+S/
+HE ISING.
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+E-mail: brad@ pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+2
+
+
+Case 9:08-cv-80736-KAM Document 101 Entered on FLSD Docket 09/28/2011 Page 3 of 3
+CERTIFICATE OF SERVICE
+The foregoing document was served on September 28, 2011, on the following using the
+Court's CM/ECF system:
+A.
+Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail:
+Attorney for the Government
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & STumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, FL 33131
+Attorneys for Proposed Intervenors Roy Black et al.
+Respectfully Submitted,
+S/
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+3
diff --git a/vision-fixhub/court-01/fbd01f974c8af8995de22a083690f7d2513706b1c42ced5e85bc4af2162e6f22.receipt.json b/vision-fixhub/court-01/fbd01f974c8af8995de22a083690f7d2513706b1c42ced5e85bc4af2162e6f22.receipt.json
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+}
diff --git a/vision-fixhub/court-01/fc002f098013c56d27a426d3cc2c46f2776b786a99a88710150625cd509c4980.md b/vision-fixhub/court-01/fc002f098013c56d27a426d3cc2c46f2776b786a99a88710150625cd509c4980.md
new file mode 100644
index 0000000000000000000000000000000000000000..91614549f9a216d63e628360e15b63c76f6bf104
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@@ -0,0 +1,409 @@
+Filing # 102188759 E-Filed 01/24/2020 01:38:17 PM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO: 2019CA014681XXXXMB AG
+CATION HOLING ACHPOST
+Plaintiff,
+VS.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R. BOCK
+as Clerk & Comptroller, Palm Beach County,
+Florida,
+Defendants.
+COPY
+DEFENDANT, SHARON R. BOCK, AS CLERK & COMPTROLLER, PALM BEACH
+COUNTY'S ANSWER TO FIRST AMENDED COMPLAINT
+AND MOTION TO DISMISS COUNT II
+Defendant, Sharon R. Bock, as Clerk & Comptroller, Palm Beach County ("Clerk"), by and
+through the undersigned attorney, hereby answers Count I of the First Amended Complaint of
+Plaintiff, CA Florida Holdings, LIC, Publisher of The Palm Beach Post ("Post"), and files a Motion
+to Dismiss Count Il as follows;
+Admits for jurisdictional purposes.
+JURISDICTION
+PARTIES
+2.
+4.
+Admits.
+Admits.
+Admits.
+INTRODUCTION
+FILED: PALM BEACH COUNTY, FL,
+, SHARON R. BOCK, CLERK, 01/24/2020 01:38:17 PM
+
+
+Paragraph 5 contains the Post's statement of the case and legal arguments to which no
+response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 5, and therefore denies the allegations and demands strict proof thereof.
+Paragraph 6 contains the Post's statement of the case and legal arguments to which no
+response is required. To the extent that a response is required, the Clerk admits only that section
+905.27(1)(c), Florida Statute authorizes the disclosure of grand jury proceedings under certain
+circumstances.
+Paragraph 7 contains the Palm Beach Post's statement of the case and legal
+arguments to which no response is required. To the extent that a response is required, the Clerk is
+without knowledge or information sufficient to forma beliefjas to the truth of any factual allegations
+contained in paragraph 7, and therefore denies the allegations and demands strict proof thereof.
+Paragraph 8 sets forth the Post's státement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 8, and therefore denies the allegations and demands strict proof thereof.
+9.
+Paragraph 9 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information, sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 9, and therefore denies the allegations and demands strict proof thereof.
+FACTUAL BACKGROUND
+10.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 10, and therefore denies the allegations and
+2
+
+
+A.
+First Epstein Sex Crimes Investigation, Indictment, and Plea Agreement: 2005-2008.
+11.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 11, and therefore denies the allegations and
+12.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 12, and therefore denies the allegations and
+13.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 13, and therefore denies the allegations and
+14.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 14, and therefore denies the allegations and
+demands strict proof thereof
+15.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 15, and therefore denies the allegations and
+(1)
+Police Chief Reiter's Letter to the State Attorney.
+16., The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 16, and therefore denies the allegations and
+17.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 17, and therefore denies the allegations and
+3
+
+
+(2)
+The July 2006 State Grand Jury Presentation.
+18.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 18, and therefore denies the allegations and
+19.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 19, and therefore denies the allegations and
+20.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 20, and therefore denies the allegations and
+21.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 21, and therefore denies the allegations and
+22. The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 22, and therefore denies the allegations and
+(3)
+The FBI's Investigation and Epstein's Non-Prosecution Agreement with Federal
+Authorities.
+23.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 23, and therefore denies the allegations and
+24.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+4
+
+
+truth of any factual allegations contained in paragraph 24, and therefore denies the allegations and
+demands strict proof thereof
+25.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 25, and therefore denies the allegations and
+26.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 26, and therefore denies the allegations and
+27. The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 27, and therefore denies the allegations and
+28.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 28, and therefore denies the allegations and
+29.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 29, and therefore denies the allegations and
+30-
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 30, and therefore denies the allegations and
+31.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 31, and therefore denies the allegations and
+5
+
+
+(4)
+The Crime Vietims' Rights Act Litigation.
+32.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 32, and therefore denies the allegations and
+33.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 33, and therefore denies the allegations and
+34.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 34, and therefore denies the allegations and
+35.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 35, and therefore denies the allegations and
+36.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 36, and therefore denies the allegations and
+37.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 37, and therefore denies the allegations and
+B.
+Second Epstein Sex Crimes Investigation. Indictment, Suicide: 2019.
+38.
+Admits.
+39.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 39, and therefore denies the allegations and
+6
+
+
+40.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 40, and therefore denies the allegations and
+41.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 41, and therefore denies the allegations and
+42.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 42, and therefore denies the allegations and
+43. The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 43, and therefore denies the allegations and
+C.
+44.
+Admits
+The August 27, 2019, SDNY Hearing: Epstein's Victims Speak.
+45.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 45, and therefore denies the allegations
+and demands strict proof thereof.
+46. y
+Admits that United States Senior Judge Richard M. Berman ordered a hearing on
+August 27, 2019, but the Clerk is without knowledge or information sufficient to form a belief as to
+the truth of any remaining factual allegations contained in paragraph 46, and therefore denies the
+allegations and demands strict proof thereof.
+47.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+7
+
+
+truth of any factual allegations contained in paragraph 47, and therefore denies the allegations and
+48.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 48, and therefore denies the allegations and
+49.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 49, and therefore denies the allegations and
+50. The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations paragraph 50, and therefore denies the allegations and demands strict
+proof thereof.
+51.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 51, and therefore denies the allegations and
+D. The Palm Beach Post's Standing and the Public Interest.
+(1)
+The Palm Beach Post Has Reported Extensively On Epstein's Crimes For Nearly
+15 Years.
+52.
+Admits.
+53.
+Admits.
+54.
+Admits that the Post has extensively investigated and reported on the allegations
+against, the law enforcement investigation of, and the crimes committed by Epstein, but lacks
+sufficient knowledge to admit or deny any factual allegations remaining in paragraph 54, and
+therefore denies the allegations and demands strict proof thereof.
+8
+
+
+55.
+The Clerk is without knowledge or information sufficient to form a belief as to the
+truth of any factual allegations contained in paragraph 55, and therefore denies the allegations and
+(2) The Palm Beach Post's Standing and the Public Interest.
+56. Paragraph 56 of the First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the Clerk admits the press has a constitutional right of access to criminal
+proceedings, but is without knowledge or information sufficient to form a belief as to the truth of
+any remaining factual allegations contained in paragraph 56, and therefore denies the allegations and
+57.
+Paragraph 57 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 57, and therefore denies the allegations and demands strict proof thereof.
+Paragraph 58 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 58, and therefore denies the allegations and demands strict proof thereof.
+59. y
+Paragraph 59 of the First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the Clerk admits that Fla. Stat. 905.27 allows a court to make the determination
+of disclosure but is without knowledge or information sufficient to form a belief as to the truth of
+any remaining factual allegations contained in paragraph 59, and therefore denies the allegations and
+9
+
+
+E.
+The Court's Jurisdiction and Authority.
+(1)
+The Court's Supervision of the Grand Jury Process and Its Authority to Order
+Public Disclosure of the Epstein Evidence.
+60.
+Paragraph 60 of the First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the Clerk admits the press has a constitutional right of access to criminal
+proceedings, but is without knowledge or information sufficient to form a belieflas to the truth of
+any remaining factual allegations contained in paragraph 56, and therefore denies the allegations and
+61.
+Admits.
+62. Admits.
+63.
+Paragraph 63 sets forth the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of any factual allegations contained in
+paragraph 63, and therefore denies the allegations and demands strict proof thereof.
+64.
+Paragraph 64 of the First Amended Complaint contains the Palm Beach Post's
+statement of the case and legal arguments to which no response is required. To the extent that a
+response is required, the Clerk is without knowledge or information sufficient to form a belief as to
+the truth of any remaining factual allegations contained in paragraph 64, and therefore denies the
+allegations and demands strict proof thereof.
+(2)
+The Court's Jurisdiction To Declare Rights And Construe Statutes.
+65.
+Admits.
+10
+
+
+66.
+67.
+Admits.
+Admits
+COUNTI
+(Declaratory Relief - Florida Stat. Sections 86.011 et seq.)
+68.
+The Clerk & Comptroller reincorporates and re-alleges its prior answers to
+paragraphs 1 through 67 above.
+69. Admits.
+70.
+Paragraph 70 contains the Post's statement of the case and legal arguments to which
+no response is required. To the extent that a response is required, the Clerk is without knowledge or
+information sufficient to form a belief as to the truth of ahy factual allegations contained in
+paragraph 70, and therefore denies the allegations and demands strict proof thereof.
+71.
+Admits that The Palm Beach Post is seeking a declaration from this Court but denies
+the remainder of Paragraph 71.
+72.
+Admits.
+73. Denies.
+74. Paragraph 74 contains the Post's legal arguments to which no response is required.
+To the extent that a response is required, the Clerk is without knowledge or information sufficient to
+form a belief as to the truth of any factual allegations contained in paragraph 74, and therefore denies
+the allegations and demands strict proof thereof.
+MOTION TO DISMISS COUNT I|
+(Florida Stat. Section 905.27)
+DEFENDANT, Sharon R. Bock, as Clerk & Comptroller, Palm Beach County, pursuant to
+the Florida Rules of Civil Procedure 1.420, hereby files this Motion to Dismiss Count II of the First
+11
+
+
+Amended Complaint of Plaintiff, CA Florida Holdings, LIC, Publisher of The Palm Beach Post, and
+as grounds states as follows:
+I.
+Argument and Standard of Review
+a.
+Plaintiff Fails to State a Cause of Action
+To state a cause of action, a complaint must allege sufficient ultimate facts to show that the
+pleader is entitled to relief. Florida Rules of Civil Procedure 1.110(b) requires "a short and plain
+statement of the ultimate facts showing that the pleader is entitled to relief." In reviewing an order
+granting a motion to dismiss for failure to state a cause of action, the Court must accept as true all
+well-pled allegations in a complaint, and it must draw all reasonable inferences in favor of the
+pleader.
+Whether a complaint is sufficient to state a cause of action is an issue of law.
+W.R. Townsend Contracting, Inc. V, Jensen Civil Construction, Inc., 728 So.
+2d 297, 299, (Fla. Ist DCA 1999). When a trial court rules on a motion to
+dismiss, the trial court is confined to the allegations within the four corners of
+the Complaint, must accept these allegations as true, and may not speculate as
+to what the true facts may be or what facts may ultimately be proved in the
+trial of the cause. See Al-Hakim v. Holder, 787 So. 2d 939, 941 (Fla. 2d DCA
+2001);
+-Infante y. Union Cent. Life Ins. Co., 809 So. 2d 13 (Fla. 3d
+DCA 2002).
+The purpose of a motion to dismiss is to determine whether the plaintiff has alleged a viable
+cause of action.
+Hammons v. Buckeye Cellulose Corp., 285 So. 2d 7, 10 (Fla. 1973). In fact,
+"[d]espite the elemental proposition that on a motion to dismiss for failure to state a cause of action
+all allegations are taken as true, [a] court will not "by inference on inference or speculations supply
+essential averments that are lacking.?"
+v. E &A Produce Corp., 708 So. 2d 997, 1000 (Fla.
+3d DCA 1998); see also Conley v. Shutts & Bowen, P.A., 616 So. 2d 523, 524-25 (Fla. 3d DCA
+1993).
+Taking the facts alleged therein and exhibits attached to the Complaint, Plaintiff failed to
+12
+
+
+state a cause of action against the Clerk, and therefore, Count II should be dismissed because under
+no set of facts can the Plaintiff state a cause of action for which relief can be granted.
+Admittedly, Fla. Stat. § 905.27, sets forth possible exceptions to the disclosure of grand jury
+testimony, however Plaintiff is barred by the clear language of the statute from access to the records
+it seeks for the purposes it has set forth as Fla. Stat. § 905.27(2) states:
+When such disclosure is ordered by a court pursuant to subsection (1) for use in a
+civil case, it may be disclosed to all parties to the case and to their attorneys and by
+the latter to their legal associates and employees. However, the grand jury testimony
+afforded such persons by the court can only be used in the defense or prosecution of
+the civil or criminal case and for no other purpose whatsoever.
+Here, despite the clear statutory guidelines for disclosure of grand jury materials in a civil
+case, Plaintiff is improperly seeking the requested 2006 grand jury materials for purposes clearly
+outside the statutory limitations pursuant to the court's inherent authority and supervisory powers
+over the grand jury. The statute unambiguously states that grand jury testimony "can only be used in
+the defense or prosecution of the civil or eriminal case and for no other purpose whatsoever", which
+is distinctly different from Plaintiff's intended purpose for public disclosure of the grand jury
+evidence. Fla. Stat. § 905.27(2)
+CONCLUSION
+Here, the Clerk's sole involvement in this action is as the custodian of the record as set forth
+in section 28.13, Florida Statute.
+This duty includes keeping grand jury records confidential
+pursuant to section 905.27, Florida Statute. The Clerk must follow strict statutory guidelines to
+maintain the record's confidentiality. Further emphasizing the statutory intent of confidentiality,
+section 905.27, Florida Statute imposes criminal penalties for improper disclosure of grand jury
+proceedings or identity of persons.
+Ultimately, plaintiff's Complaint is an extensive recitation of the factual background
+13
+
+
+regarding Jeffery Epstein and the testimony and evidence presented to the 2006 grand jury in Palm
+Beach County, Florida.
+However, that recitation fails to state a cause of action for which the
+requested relief can be granted.
+WHEREFORE, based on the foregoing argument and supporting authority, Defendant,
+Sharon R. Bock, as Clerk & Comptroller, Palm Beach County respectfully prays for the Court to grant
+this Motion to Dismiss Count II of Plaintiff's First Amended Complaint with prejudice, provide
+direction to the Clerk as needed, and grant such other and further relief as the court deems proper.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true copy of the foregoing has been emailed in compliance
+with the Florida Rules of Judicial Administration 2.516, on this 24th day of January, 2020, to:
+Stephen A. Mendelsohn, Esq., Greenberg Traurig, P.A.) 5100 Town Center Circle, Suite 400, Boca
+Raton, FL 33486, email: mendelsohns@gtlaw.com and Douglas A. Wyler, Esq., 961687 Gateway
+Blvd., Suite 201-1, Fernandina Beach, FL 32034, email: jacobsscholzlaw@comcast.net.
+NOT
+Hampton C. Peterson, General Counsel
+For Sharon R. Bock, Clerk & Comptroller
+Post Office Box 229
+West Palm Beach, FL 33402
+Telephone: (561) 355-2983
+E-service: Clerk_E-service@mypalmbeachclerk.com
+BY:
+s/Hampton C. Peterson
+Florida Bar No. 331384
+14
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fc002f098013c56d27a426d3cc2c46f2776b786a99a88710150625cd509c4980.receipt.json b/vision-fixhub/court-01/fc002f098013c56d27a426d3cc2c46f2776b786a99a88710150625cd509c4980.receipt.json
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+  "event_count": 15,
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+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/fc0577817006dc2162bb27a369b1ed0ef67d72327d7e6c8963b19135a800e6d5.md b/vision-fixhub/court-01/fc0577817006dc2162bb27a369b1ed0ef67d72327d7e6c8963b19135a800e6d5.md
new file mode 100644
index 0000000000000000000000000000000000000000..0c867b6609a6c3ec45a7ba32f7247ad98f508feb
--- /dev/null
+++ b/vision-fixhub/court-01/fc0577817006dc2162bb27a369b1ed0ef67d72327d7e6c8963b19135a800e6d5.md
@@ -0,0 +1,122 @@
+Case 1:19-cV-11869-MKV-DCF Document 3-1 Filed 12/27/19 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ANASTASIA DOE,
+Plaintiff,
+Case No. 1:19-cv-11869
+VS.
+DARREN K. INDYKE AND RICHARD D.
+KAHAN, AS CO-EXECUTORS OF THE ESTATE
+OF JEFFREY E. EPSTEIN,
+Defendant.
+AFFIRMATION OF 1
+J.
+TIN SUPPORT OF
+APPLICATION FOR ADMISSION
+PRO HAC VICE
+1,
+hereby declare as follows:
+1. I have never been convicted of a felony.
+2. I have never been censured, suspended, disbarred or denied admission or readmission by any
+court.
+3. There are no pending disciplinary proceedings against me in any state or federal court.
+4. Iam a member in good standing of the bar of the State of Florida.
+5. I am a member in good standing of the bar of District of Columbia.
+6. I am a member in good standing of the bar of the State of New York.
+I hereby declare under penalty of perjury that the foregoing statements are true and correct.
+Dated: December 27, 2019
+Fort Lauderdale, Florida
+Respectfully submitted,
+POTTINGER, LLC
+By:
+Bradley J.
+NY Bar No.: 5749684
+Brittany N.
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+(954)-524-2820
+Fax: (954)-524-2822
+Email: ecf@epllc.com
+brad@epllc.com
+brittany@epllc.com
+(Seeking Admission Pro Hac Vice)
+
+
+Case 1:19-cv-11869-MKV-DCF Document 3-1 l
+Filed 12/27/19 Page 2 of 4
+Supreme Court of Florida
+Certificate of Good Standing
+I JOHN A. TOMASINO, Clerk of the Supreme Court of the State of Florida, do
+hereby certify that
+JAMES
+was admitted as an attorney and counselor entitled to practice law in all the
+Courts of the State of Florida on March 8, 2002, is presently in good
+standing, and that the private and professional character of the attorney
+appear to be good.
+EME
+COURT
+WITNESS my hand and the Seal of the
+Supreme Court of Florida at Tallahassee,
+the Capital, this August 15, 2019.
+22
+Clerk of the Supreme Court of Florida.
+
+
+Case 1:19-cv-11869-MKV-DCF Document 3-1
+Filed 12/27/19 Page 3 of 4
+The Florida Bar
+651 East Jefferson Street
+Tallahassee, FL 32399-2300
+Joshua E.
+Executive Director
+State of Florida
+County of
+850/561-5600
+www.FLORIDABAR.org
+)
+)
+In Re: 0542075
+James
+Pottinger LLC
+425 N Andrews Ave Ste 2
+Ft Lauderdale, FL 33301-3268
+I CERTIFY THE FOLLOWING:
+1 am the custodian of membership records of The Florida Bar.
+Membership records of The Florida Bar indicate that The Florida Bar member listed above was admitted to
+practice law in the state of Florida on March 8, 2002.
+The Florida Bar member above is an active member in good standing of The Florida Bar who is eligible to
+practice law in the state of Florida.
+Dated this 27th day of December, 2019.
+Lipithia B. Jackon
+Cynthia B.
+, CFO
+Administration Division
+The Florida Bar
+STORIDA
+PG:R10
+CTM-67839
+1950
+
+
+Case 1:19-cv-11869-MKV-DCF Document 3-1 Filed 12/27/19 Page 4 of 4
+DOBAR
+COURT OF APPENE
+On behalf of JULIO A. CASTILLO, Clerk of the District of Columbia Court of Appeals,
+the District of Columbia Bar does hereby certify that
+Beally Jumes Edwards
+was duly qualified and admitted on June 5, 2017 as an attorney and counselor entitled to
+practice before this Court; and is, on the date indicated below, an Active member in good
+standing of this Bar.
+In Testimony Whereof,
+I have hereunto subscribed my
+name and affixed the seal of this
+Court at the City of
+Washington, D.C., on December
+27, 2019.
+Gulis a Erstello
+JULIO A. CASTILLO
+Clerk of the Court
+Issued By:
+District of Columbia Bar Membership
+For questions or concerns, please contact the D.C. Bar Membership Office at 202-626-3475 or email
+memberservices@dcbar.org.
diff --git a/vision-fixhub/court-01/fc0577817006dc2162bb27a369b1ed0ef67d72327d7e6c8963b19135a800e6d5.receipt.json b/vision-fixhub/court-01/fc0577817006dc2162bb27a369b1ed0ef67d72327d7e6c8963b19135a800e6d5.receipt.json
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+  "event_count": 4,
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+  "input_sha256": "cbf2399ddd6c2e6c30e33d36b1e46e524317344d606274aaf7f2066a267ce2ea",
+  "output_sha256": "cef37bae65cbb29b4eda67a60f988dba848faedee8fdfa52bb2266eef3a585fa",
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+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/fc0713dc00045b1d973e6775482e3359fd9e52125654a4c7ab9d873b424134c4.md b/vision-fixhub/court-01/fc0713dc00045b1d973e6775482e3359fd9e52125654a4c7ab9d873b424134c4.md
new file mode 100644
index 0000000000000000000000000000000000000000..0622221e01947c1eaa662642a86ba6595c8cff3c
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@@ -0,0 +1,163 @@
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S RELEVANCE OBJECTIONS TO PETITIONERS'
+FIRST REQUEST FOR PRODUCTION TO THE GOVERNMENT
+Respondent United States of America, by and through its undersigned counsel, files its
+Relevance Objections to Petitioners' First Request for Production, and state:
+I.
+INTRODUCTION
+On September 26, 2011, this Court found that the Crime Victims Rights Act (CVRA), 18
+U.S.C. § 3771 et. seq., can apply before formal charges are filed. D.E. 99 at 5-10. The Court
+found that "some factual development is necessary to resolve the remaining issues in this case,"
+and it would "permit Plaintiffs the opportunity to conduct limited discovery in the form of
+document requests and requests for admissions from the U.S. Attorney's Office." D.E. 99 at 11.
+The Court also stated that, "[b]ecause the Court will allow this limited factual development, it is
+unnecessary to decide here whether the CVRA or the Federal Rules of Civil Procedure provide
+discovery rights in this context." Id.
+Petitioners' first request for production goes well beyond the "limited factual
+development" permitted by the Court it its September 26, 2011 Order. Respondent has
+submitted a Privilege Log which describes each document withheld, and the privilege invoked
+
+
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 2 of 6
+for that document. Respondent further objects because many of the requests seek documents
+which are irrelevant to the limited matters at issue before this Court.
+Il.
+MANY OF THE DOCUMENTS SOUGHT ARE IRRELEVANT TO THE
+INQUIRY BEFORE THIS COURT
+In Request for Production No. 1, petitioners seek the Federal Bureau of Investigation file
+on the Epstein case, to include documents, correspondence, witness statements, FBI 302s and
+other similar information "collected as part of its case against and/or investigation of Epstein."
+Petitioners also request the government's prosecution memorandum, as well as a draft indictment
+prepared in the case. The information requested is irrelevant to the Court's inquiry as to
+whether the government violated the CVRA, and if so, the appropriate remedy for such violation.
+Petitioners attempt to justify their request by maintaining that the Court's September 26,
+2011 Order (D.E. 99 at 2 n.2) requires "further factual development." This footnote was to the
+"Background" section of the Court's order, and the footnote did not refer specifically to
+petitioners' claim that the government had developed a strong case. More importantly, whether
+the government had a strong or weak case has nothing to do with the extent of the government's
+obligations under the CVRA, whether those obligations were complied with, or what remedy
+should be afforded if a violation did occur. Thus, all the documents sought regarding the
+underlying criminal investigation, the FBI investigative file, prosecution memorandum, draft
+indictment, and other items sought in request for production 1 are irrelevant.
+In Request for Production No. 10, petitioners request documents to support their claim
+that the FBI was led to believe their investigation of Epstein would lead to a federal criminal
+prosecution, and the U.S. Attorney's Office misled the FBI about the status of the case. This has
+no relevance to whether a violation of the CVRA occurred, or the appropriate remedy if the
+Court finds a violation did occur. The United States Attorney is vested with authority to
+2
+
+
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 3 of 6
+"prosecute for all offenses against the United States" within his district. 28 U.S.C. § 547(1).
+The government disputes that the FBI was misled in any way by the U.S. Attorney's Office, but
+that issue is irrelevant to this case. The decision on whether to prosecute belongs to the United
+States Attorney.
+In Request for Production No. 16, petitioners request documents to support their claim
+that a former prosecutor in the U.S. Attorney's Office improperly represented persons close to
+Epstein, after his departure from the U.S. Attorney's Office. They also contend that "it is also
+possible that other improper relationships exist between Government agents and Epstein." The
+documents being requested are irrelevant because the issue before this Court is whether the
+government violated the CVRA, not how it exercised its prosecutorial discretion in the Epstein
+case. The Court has found that "Iw Jhat the government chooses to do after a conferral with the
+victims is a matter outside the reach of the CVRA, which reserves absolute prosecutorial
+discretion to the government." D.E. 189 at 10, citing 18 U.S.C. § 3771(d)(6).
+In Request for Production No. 18, petitioners request documents from December 2010,
+and after the August 2011 hearing, regarding whether the United States Attorney's Office,
+Southern District of Florida, had a conflict of interest precluding it from handling various issues.
+Petitioners request "all documents, correspondence, and other information regarding the potential
+conflicts of interest that the Justice Department discussed or determined existed for the USAO
+SDFL, as well as any referral that was made to Main Justice or to any other District, including
+any documents that were transmitted to any other District regarding the conflict and regarding
+what was to be investigated." The information sought is irrelevant to this lawsuit. The
+relevant events in this case occurred in 2006-2008, when the case was opened by the U.S.
+Attorney's Office, the non-prosecution agreement was signed in September 2007, and Epstein
+3
+
+
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 4 of 6
+entered his guilty plea in June 2008. The lawsuit was filed on July 7, 2008. Whether the U.S.
+Attorney's Office may have had a conflict of interest in December 2010 or August 2011, has no
+relevance to any issue before this Court.
+In Request for Production No. 19, petitioners request documents that support, or
+contradict, an assertion in a three-page letter sent by the former United States Attorney, R.
+Alexander Acosta, to the news media in March 2011. The assertion was that Epstein launched
+"a yearlong assault on the prosecution and the prosecutors." Whether Mr. Acosta's assertions
+are supported or contradicted is irrelevant to whether the CVRA was violated.
+In Request for Production No. 25, petitioners request that the government provide all
+initial disclosures required by the Federal Rules of Civil Procedure, including Rule 26(a)(1).
+Respondents object because no finding has been made that the Federal Rules of Civil Procedure
+even apply to this case. D.E. 99 at 11 ("Because the Court will allow this limited factual
+development, it is unnecessary to decide here whether the CVRA or the Federal Rules of Civil
+Procedure provide discovery rights in this context."). Petitioners cannot obtain initial
+disclosures under Rule 26(a)(1) by simply incorporating it into a request for production.
+DATED: August 2, 2013
+Respectfully submitted,
+WILFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+_s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4 Street, Suite 300
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+4
+
+
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 5 of 6
+ATTORNEY FOR RESPONDENT
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on August 2, 2013, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee.
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States,
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+Esq..
+Jaffe, Weissing,
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Fistos & Lehrman, P.L.
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe # 2
+Roy Black
+Jackie Perczek
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+(305) 371-6421
+Fax: (305) 358-2006
+5
+
+
+Case 9:08-cv-80736-KAM Document 219-1 Entered on FLSD Docket 08/02/2013 Page 6 of 6
+E-mail: rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+espondent's Exhibit
+ase No. 08-80736-CIV-MARP
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/fc1dca3a628ee923346f1ea8de38e9c80159b8d652302602d7a6f3c2d37333fd.md b/vision-fixhub/court-01/fc1dca3a628ee923346f1ea8de38e9c80159b8d652302602d7a6f3c2d37333fd.md
new file mode 100644
index 0000000000000000000000000000000000000000..879228cf1dc98c27f4e6d78b17d939566a097622
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+++ b/vision-fixhub/court-01/fc1dca3a628ee923346f1ea8de38e9c80159b8d652302602d7a6f3c2d37333fd.md
@@ -0,0 +1,226 @@
+Case 9:08-cv-80736-KAM Document 81
+Entered on FLSD Docket 05/16/2011 Page 1 of 8
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/_
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S RESPONSE TO MOTION TO INTERVENE OF
+BRUCE REINHART
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to oppose the motion of attorney Bruce E. Reinhart to permissively
+intervene in this case under Fed. R. Civ. P. 24(b)(1)(b) (DE #79).
+The motion to intervene should be denied. Reinhart appears to be merely the cat's paw
+of a possible real party in interest - Jeffrey Epstein. It is of no concern to Reinhart whether or
+not this Court rules that the Government violated Jane Doe #1 and Jane Doe #2's rights under the
+Crime Victims' Rights Act. Thus Reinhart has not established that he has some kind of
+"common question of law or fact" sufficient to support his permissive intervention into this case.
+Accordingly, as with the similar motion for Epstein's defense attorneys, his motion to intervene
+in this Crime Victims' Rights Act case is without merit and should be denied. Alternatively, if
+the Court elects to permit Reinhart to permissively intervene, legal counsel for Jane Doe #1 and
+Jane Doe #2 should be allowed to, first, depose Reinhart about his involvement in the Epstein
+criminal investigation and, second, respond to his baseless motion for Rule 11 sanctions.
+1
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 2 of 8
+DISCUSSION
+I.
+REINHART DOES NOT HAVE A CLAIM OR DEFENSE THAT SHARES
+SOMETHING IN COMMON WITH THIS CRIME VICTIMS RIGHTS
+ACT ENFORCEMENT ACTION.
+Reinhart claims that the Court should grant him permissive intervention under Fed. R.
+Civ. P. 24(b). The rule grants discretion to the court to allow intervention by a person who has
+"a claim or defense that shares with the main action a common question of law or fact." Fed. R.
+Civ. P. 24(b); accord Mt. Hawley Ins. Co. v. Sandy Lake Properties, Inc., 425 F.3d 1308, 1311
+(11th Cir. 2005) (intervention allowed only where "a claim or defense and the main action have a
+question of law or fact in common and the intervention will not unduly prejudice or delay the
+adjudication of the rights of the original parties."). A district court's ruling on such intervention
+is reviewed only for abuse of discretion. I
+v. First Union Corp., 371 F.3d 1305 (11th Cir.
+2004) see also AT&T Corp. v. Sprint Corp., 407 F.3d 560, 561-62 (2nd Cir. 2005) ("[a] denial of
+permissive intervention has virtually never been reversed" because of the considerable discretion
+afforded to district courts).
+Reinhart claims he has an interest in this Crime Victims Rights Act case sufficient to
+support permissive intervention. Curiously, Reinhart is not the first person to try and intervene
+in the victims' case. As the Court is aware, three defense attorneys have also filed a separate
+motion to intervene (DE #56). All these putative intervenors have one thing in common: they
+have all defended Jeffrey Epstein or his associates in the sexual abuse litigation brought by girls
+Epstein sexually abused. This sudden appearance of so many intervenors aligned with Epstein -
+but not of Jeffrey Epstein himself - strongly suggests that Reinhart and others are being used as
+2
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 3 of 8
+Epstein's cat's paw in an attempt to undercut the victims CVRA lawsuit without Epstein himself
+becoming involved.
+Such litigation-by-surrogate is improper. While Epstein arguably has an interest in the
+CVRA case (because the victims are seeking to invalidate his non-prosecution agreement), a
+civil defense attorney who has represented Epstein employees simply does not. The "claim and
+defense" of this CVRA action is the victims' claim that the government violated their CVRA
+rights and the government's defense that it did not. Reinhart has no interest in how that dispute
+is resolved. Any findings that the Court makes in the course of resolving the victims' CVRA
+action are not binding on Reinhart, and he has not documented that he is suffering any tangible
+harm from them.
+In considering whether to allow intervention, a district court can also consider whether
+adequate representation exists on any issues and whether a putative intervenor will significantly
+contribute to the litigation.
+Department of Fair Employment and Housing v. Lucent
+Technologies, Inc., 2011 WL 1549232, at *6 (9th Cir. 2011) (citing Spangler v. Pasadena City
+Bd. of Educ., 552 F.2d 1326(9th Cir.1977). Here, there is no indication that the Justice
+Department will do anything other than vigorously defend the non-prosecution agreement that it
+negotiated. The Court need not allow another third-party to try undercut the victims as well.
+Reinhart attempts to manufacture an interest by alleging that he is entitled to intervene to
+contest two factual allegations made by the victims that relate to him and seek Rule 11 sanctions
+for the allegations. But as a non-party, he lacks standing to bootstrap his way into this case via a
+Rule 11 motion. As the Second Circuit has explained:
+3
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 4 of 8
+Although the language of Rule 11 does not address the issue of who may move
+for sanctions, the language used in the Advisory Committee Notes indicates that it
+is the parties who should move for sanctions. The Advisory Committee Notes
+accompanying the 1983 amendments require that "[a] party seeking sanctions
+should give notice to the court and the offending party" and make explicit the
+court's authority to impose sanctions on its own motion "in order to overcome the
+traditional reluctance of courts to intervene unless requested by one of the
+parties." Notes of Advisory Committee on Rules-1983 Amendment (emphasis
+added).
+New York News, Inc. v. Kheel, 972 F.2d 482, 488 (2d Cir. 1992). If Reinhart's motion is allowed
+to succeed, then legions of bystanders will have the ability to intervene in lawsuits through the
+simple device of claiming an interest in filing a Rule 11 sanctions motion. Thus, the Second
+Circuit has explained that "we fear that permitting a non-party to move for Rule 11 sanctions
+might fulfill critics' concerns that the rule will create unwieldy " satellite litigation'" that will
+frustrate the rule's goal of 'more effective operation of the pleading regimen."" Id. (citing SA
+&
+Federal Practice and Procedure § 1332, at 29 (1990)).
+Reinhart's motion is also untimely. On March 20, 2011, the victims filed their motion for
+summary judgment - the pleading to which Reinhart objects. The government responded on
+April 7, 2011, and the victims' replied on May 2, 2011. After all the briefing was completed on
+the victims' summary judgment motion, the next day - May 3, 2011 - Reinhart filed his motion
+to intervene. This timing strongly suggests that Reinhart deliberately waited to file his motion
+until briefing on the motion was fully completed. Rule 24(b) requires a "timely" motion for
+intervention. And it further requires the Court to consider whether the parties will be prejudiced
+by intervention. Reinhart's late motion is simply not timely and will prejudice the victims by
+requiring them to brief ancillary issues.
+4
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 5 of 8
+For all these reasons, the Court should exercise its abundant discretion in this area and
+deny Reinhart's motion to permissively intervene.
+II.
+IN THE ALTERNATIVE, IF REINHART'S MOTION TO INTERVENE IS
+GRANTED, THE COURT SHOULD ALLOW THE VICTIMS TO DEPOSE
+REINHARD.
+Alternatively, if the Court grants Reinhart permissive intervention, the victims should be
+allowed to depose him. Reinhart proposes to intervene as a party-in-interest in this civil case,
+Case No. 08-807346-Civ-Marra. Of course, in civil cases "liberal civil discovery rules" provide
+"broad access" to relevant information.
+v. Buckeye Cellulose Corp., 980 F.2d 648, 661
+(11th Cir. 1993). Jane Doe #1 and Jane Doe #2 should be able to avail themselves of those rules
+to determine whether Epstein used Reinhart to improperly obtain information about the criminal
+investigation of the victims" sexual abuse or otherwise to inappropriately influence the process.
+Reinhart has also made factual representations in support of his motion, including
+representations about his lack of involvement in the Epstein case and the supposed inadequate
+basis for the victims'allegations. Reinhart's motion for sanctions (attached to his motion to
+intervene) alleges, "based on information and belief," that victims' counsel "did not speak to any
+current or former personnel from the Office or the FBI who were familiar with the structure of
+the West Palm Beach Office or with Movant's [i.e., Reinhart's] role (or lack thereof) in the
+Epstein investigation." Intervenor's Motion for Sanction at 5. The motion further complained
+that victims' counsel "never contacted Movant." Id.
+Oddly for one complaining about lack of contact, Reinhart never contacted the victims'
+counsel about whether they have spoken to current personnel in the U.S. Attorney's Office about
+5
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 6 of 8
+Reinhart's involvement in the Epstein case. If he had done so, Reinhart would have learned that
+on December 10, 2010, victims' counsel met in Miami with the Wilfredo Ferrer, United States
+Attorney for the Southern District of Florida; Ben Greenburg, First Assistant U.S. Attorney;
+Dexter Lee, Assistant U.S. Attorney; and A.
+Villafaña, Assistant U.S. Attorney and line
+prosecutor on the Epstein matter. Without disclosing any information about the details of that
+settlement meeting, victims' counsel believe it is appropriate to report that Reinhart's
+involvement in the Epstein investigation was discussed.
+Moreover, in an effort to facilitate contact on these issues, the same day that Reinhart
+filed his motion to intervene (May 3), victims" counsel (Cassell) sent an e-mail to Reinhart
+requesting an opportunity to talk with him about his role in the Epstein case. The next day (May
+4), Reinhart sent a letter back refusing to talk about the matter. In view of Reinhart's refusal to
+meet voluntarily with the victims' counsel regarding his factual representations, if the Court
+decides to allow Reinhart to intervene, it should also grant the victims the right of a reasonable
+deposition regarding his involvement in the Epstein case.
+CONCLUSION
+For all the foregoing reasons, the Court should deny Reinhart's motion to intervene in
+this Crime Victims' Rights Act case.
+DATED: May 16, 2011
+Respectfully Submitted,
+ATE WEISSING.
+. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+6
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 7 of 8
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+The foregoing document was served on May 16, 2011, on the following using the Court's
+CM/ECF system:
+Dexter Lee
+A.L
+Villafaña
+Assistant U.S. Attorneys
+500 S. Australian Ave.., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee@usdoj.gov
+Allomeys For the overment
+Roy Black, Esq.
+Jackie Perczek, Esq.
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+7
+
+
+Case 9:08-cv-80736-KAM Document 81 Entered on FLSD Docket 05/16/2011 Page 8 of 8
+(305) 37106421
+(305) 358-2006
+G. Weinberg, P.C.
+20 Park Plaza
+Suite 1000
+Boston, 02116
+(617) 227-3700
+(617) 338-9538
+L. Ackerman, Jr.
+Burnett PA
+777 S. Flagler Drive, West Tower, Suite 901
+West Palm Beach, FL 33401
+Criminal Defense Counsel for Jeffrey Epstei
+(courtesy copy of pleading via U.S. mail)
+Bruce E. Reinhart
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Breinhart@BruceReinhartLaw.com
+(via U.S.
+. mail)
+8
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diff --git a/vision-fixhub/court-01/fc28ce0c8d3a63c6a8e5839de9a7d044376185f6237557d8d5d2682f5e2bd1af.md b/vision-fixhub/court-01/fc28ce0c8d3a63c6a8e5839de9a7d044376185f6237557d8d5d2682f5e2bd1af.md
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@@ -0,0 +1,367 @@
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 1 of 14
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/
+JANE DOES #1 AND #2,
+Plaintiffs,
+VS.
+UNITED STATES,
+Defendant.
+ORDER
+THIS CAUSE is before the Court upon Plaintiffs' Motion for Finding of Violations of the
+Crime Victims' Rights Act (DEs 48, 52), Plaintiffs' Motion to Have Their Facts Accepted
+Because of the Government's Failure to Contest Any of the Facts (DE 49), Plaintiffs' Motion for
+Order Directing the U.S. Attorney's Office Not to Withhold Relevant Evidence (DE 50), and
+Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule 11 Order
+(DE 79).' All motions are fully briefed and ripe for review, and the Court has heard oral
+arguments on all motions. The Court has carefully considered the briefing and the parties'
+arguments and is otherwise fully advised in the premises.
+' The Court is awaiting supplemental briefing on the Motion to Intervene of Roy Black,
+| Weinberg, and Jay Lefkowitz (DE 56) and will rule on that motion after it is fully briefed.
+Also, because the proposed interveners seek intervention to request a protective order against
+disclosure of certain correspondences at issue in Plaintiffs' Motion to Use Correspondence to
+Prove Violations of the Crime Victims' Rights Act and to Have Their Unredacted Pleadings
+Unsealed (DE 51), the Court will defer ruling on the latter motion until the intervention motion is
+ripe for review.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 2 of 14
+Background'
+Plaintiffs Jane Doe #1 and Jane Doe #2 are alleged victims of federal sex crimes
+committed by Jeffrey Epstein in Palm Beach County. Between 2001 and 2007, Epstein sexually
+abused multiple underage girls at his Palm Beach mansion, including Plaintiffs. In 2006, the
+Federal Bureau of Investigation ("FBI") opened an investigation into allegations that Epstein was
+inducing underage girls to engage in sexual acts. The case was eventually presented to the
+United States Attorney's Office for the Southern District of Florida, which accepted it for
+investigation. The Palm Beach County State Attorney's Office was also investigating similar
+allegations against Epstein. Plaintiffs allege that the FBI and U.S. Attorney's Office's
+investigation developed a strong case for a federal prosecution against Epstein based on
+"overwhelming" evidence.
+In June 2007, the FBI delivered to Jane Doe #1 a standard victim-notification letter,
+which explained that the case against Epstein was "under investigation" and notified Jane Doe #1
+of her rights under the Crime Victims' Rights Act ("CVRA"). In August 2007, Jane Doe #2
+received a similar notification letter.
+In September 2007, Epstein and the U.S. Attorney's Office began plea discussions. The
+negotiations led to an agreement under which Epstein would plead guilty to two state felony
+offenses for solicitation of prostitution and procurement of minors for prostitution and the U.S.
+" This background discussion is based on the allegations in Plaintiffs' Petition for
+Enforcement of Crime Victims' Rights Act (DE 1) and the Statement of Material Facts in
+Plaintiffs' Motion for Finding of Violation of the Crime Victims' Rights Act (DEs 48, 52).
+These allegations are not yet supported by evidence and the Court relies on them here solely to
+provide the context for the threshold legal issues addressed in this order. As discussed below,
+further factual development is necessary to resolve the additional issues raised in Plaintiffs'
+motions.
+2
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 3 of 14
+Attorney's Office would agree not to prosecute Epstein for federal offenses. On September 24,
+2007, Epstein and the U.S. Attorney's Office executed a Non-Prosecution Agreement ("NPA")
+under these terms.
+Plaintiffs contend that the U.S. Attorney's Office did not confer with them regarding the
+plea discussions and, in fact, intentionally kept secret the negotiations and the NPA. From
+September 24, 2007, the day on which the NPA was executed, through June 2008, the U.S.
+Attorney's Office did not notify either Plaintiff of the existence of the NPA.
+During this period, Plaintiffs communicated multiple times with the FBI and U.S.
+Attorney's Office, but neither Plaintiff was informed of the NPA. On January 10, 2008, the FBI
+sent letters to Plaintiffs advising them that [t]his case is currently under investigation," but
+failing to disclose the existence of the NPA. On January 32, 2008, Jane Doe #1 met with FBI
+agents and attorneys from the U.S. Attorney's Office to discuss her abuse by Epstein. The
+government did not disclose the existence of the NPA. In mid-June 2008, Plaintiffs' counsel
+contacted the Assistant United States Attorney ("AUSA") handling their case to discuss the
+status of the investigation. The AUSA did not disclose the existence of the NPA. On June 27,
+2008, the U.S. Attorney's Office notified Plaintiffs' counsel that Epstein was scheduled to plead
+guilty in state court on June 30, 2008. The U.S. Attorney's Office did not disclose the existence
+of the NPA nor the relationship between Epstein's state plea and the U.S. Attorney's Office's
+agreement to forgo federal charges. On July 3, 2008, Plaintiffs' counsel sent a letter to the U.S.
+Attorney's Office stating Jane Doe #1's desire that it bring federal charges against Epstein.
+3
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 4 of 14
+On July 7, 2008, Jane Doe #1 filed a petition in this Court to enforce her rights under the
+CVRA.? Jane Doe #1 alleged that she believed plea discussions were under way between Epstein
+and the U.S. Attorney's Office, and that the government, by failing to notify her of this
+development, had violated her rights under the CVRA. The United States responded to the
+petition on July 9, 2008, arguing that (1) a federal indictment had never been returned against
+Epstein and therefore the CVRA did not attach, and (2) nevertheless, the U.S. Attorney's Office
+had used its best efforts to comply with the CVRA. The government's response also disclosed
+that the U.S. Attorney's Office had entered into the NPA with Epstein.
+On July 11, 2008, this Court held a hearing on Jane Doe #1's petition, at which Jane Doe
+#2 was added as a plaintiff. At the hearing, Plaintiffs explained that their petition did not present
+an emergency and that therefore an immediate resolution was not necessary. On August 14,
+2008, the Court held a status conference and ordered the United States to turn over the NPA to
+all identified victims, including Plaintiffs, and further ordered the parties to work out the terms of
+a protective order governing the NPA's disclosure.
+This action was relatively inactive for the next year and one-half while Plaintiffs litigated
+civil actions against Epstein. After those cases settled, Plaintiffs attempted to resolve their
+CVRA dispute with the U.S. Attorney's Office. On March 18, 2011, after the parties' settlement
+efforts failed, Plaintiffs filed a series of motions, which the Court now addresses in turn, along
+with Bruce E. Reinhart's Motion to Intervene.
+3 Jane Doe #2 joined this action after Jane Doe #1 filed the initial Petition for
+Enforcement of Crime Victims' Rights Act.
+4
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 5 of 14
+Motion for Finding of Violations of the Crime Victims' Rights Act
+The CVRA was designed to protect victims' rights and ensure them involvement in the
+criminal-justice process. United States v. Moussaoui, 483 F.3d 220, 234 (4" Cir. 2007); Kenna v.
+U.S. Dist. Court, 435 F.3d 1011, 1016 (9" Cir. 2006) ("The [CVRA] was enacted to make crime
+victims full participants in the criminal justice system."). The statute enumerates the following
+eight rights:
+(1) The right to be reasonably protected from the accused
+(2) The right to reasonable, accurate, and timely notice of any public court
+proceeding, or any parole proceeding, involving the crime or of any release or escape
+of the accused.
+(3) The right not to be excluded from any such public court proceeding, unless the
+court, after receiving clear and convincing evidence, determines that testimony by the
+victim would be materially altered if the victim heard other testimony at that
+proceeding.
+(4) The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, sentencing, or any parole proceeding.
+(5) The reasonable right to confer with the attorney for the Government in the case.
+(6) The right to full and timely restitution as provided in law.
+(7) The right to proceedings free from unreasonable delay.
+(8) The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+18 U.S.C. § 3771(a).
+If a prosecution is underway, the CVRA grants victims standing to vindicate their rights
+in the ongoing criminal action. 18 U.S.C. § 3771(d)(3). If, however, a prosecution is not
+underway, the victims may initiate a new action under the CVRA in the district court of the
+5
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 6 of 14
+district where the crime occurred.* Id. The statute also tasks the district courts and the
+prosecutors with the responsibility of protecting these rights. See 18 U.S.C. § 3771(b)(1) ("[T]he
+court shall ensure that the crime victim is afforded the rights described in subsection (a)."); §
+3771(c)(1) ("Officers and employees of the Department of Justice ... shall make their best
+efforts to see that crime victims are notified of, and accorded, the rights described in subsection
+(a).").
+Here, Plaintiffs first argue that as a matter of law the CVRA's protections attach before a
+formal charge is filed against the criminal defendant. Accordingly, Plaintiffs contend that the
+CVRA applied here and that the U.S. Attorney's Office violated their CVRA rights; namely,
+their rights to confer, to be treated with fairness, and to accurate and timely notice of court
+proceedings. Based on these violations, Plaintiffs request that this Court set a briefing schedule
+and hearing on the appropriate remedy, which according to Plaintiffs is to invalidate the nonprosecution agreement.
+The United States argues that as a matter of law the CVRA does not apply before formal
+charges are filed, i.e., before an indictment or similar charging document, and therefore does not
+apply here because formal charges were never filed against Epstein. The United States further
+argues that even if the CVRA applied here, the U.S. Attorney's Office complied with its
+requirements.
+The Court first addresses the threshold issue whether the CVRA attaches before the
+government brings formal charges against the defendant The Court holds that it does because the
+"Here, because no criminal case was pending, Plaintiffs filed their petition as a new
+matter in this judicial district, which the Clerk of Court docketed as a civil action.
+6
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 7 of 14
+statutory language clearly contemplates pre-charge proceedings. For instance, subsections (a)(2)
+and (a)(3) provide rights that attach to "any public court proceeding ... involving the crime."
+Similarly, subsection (b) requires courts to ensure CVRA rights in "any court proceeding
+involving an offense against a crime victim." Court proceedings involving the crime are not
+limited to post-complaint or post-indictment proceedings, but can also include initial appearances
+and bond hearings, both of which can take place before a formal charge. By way of example,
+under Rule 5(a)(1)(A) of the Federal Rules of Criminal Procedure, upon arrest the defendant
+must be taken before a magistrate judge "without unnecessary delay" for an initial appearance. If
+the arrest takes place on a weekday, "without unnecessary delay" will typically require that the
+initial appearance occur the following morning, which will often be within twenty-four hours of
+arrest. See United States v. Mendoza, 473 F.2d 697, 702 (5" Cir. 1973) (holding that the
+government satisfied Rule 5's "without unnecessary delay" requirement by bringing the
+defendant before the magistrate judge on the first weekday morning following the arrest). By
+contrast, Rule 5(b) requires that where the defendant is arrested without a warrant, the
+government must file the complaint "promptly." The Supreme Court has interpreted "promptly"
+under Rule 5(b) as generally requiring that the complaint be filed within forty-eight hours of
+arrest. Cnty. Of Riverside v. McLaughlin, 500 U.S. 44, 56-57 (1991). It is therefore possible that
+where the defendant is arrested on a weekday without a warrant, the initial appearance—which
+may also involve the detention or bond hearing under Rule 5(d)(3) will take place before the
+government files the criminal complaint.
+Subsection (c)(1) requires that "Officers and employees of the Department of Justice and
+other departments and agencies of the United States engaged in the detection, investigation, or
+7
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 8 of 14
+prosecution of crime shall make their best efforts to see that crime victims are notified of, and
+accorded, the rights in subsection (a)." (Emphasis added). Subsection (c)(1)'s requirement that
+officials engaged in "detection [or] investigation" afford victims the rights enumerated in
+subsection (a) surely contemplates pre-charge application of the CVRA.
+Subsection (d)(3) explains that the CVRA's enumerated rights "shall be asserted in the
+district court in which a defendant is being prosecuted for the crime or, if no prosecution is
+underway, in the district court in the district in which the crime occurred." (Emphasis added). If
+the CVRA's rights may be enforced before a prosecution is underway, then, to avoid a strained
+reading of the statute, those rights must attach before a complaint or indictment formally charges
+the defendant with the crime.
+This interpretation is consistent with other federal decisions that have addressed the scope
+of the CVRA. For instance, in In re
+, 527 F.3d 391 (5" Cir. 2008), the court held that
+subsection (a)(5)'s "right to confer" applied before any prosecution is underway. Id. at 394.
+Specifically, the court explained:
+The district court acknowledged that "there are clearly rights under the CVRA that
+apply before any prosecution is underway." Logically, this includes the CVRA's
+establishment of victims' "reasonable right to confer with the attorney for the
+Government." At least in the posture of this case (and we do not speculate on the
+applicability to other situations), the government should have fashioned a reasonable
+way to inform the victims of the likelihood of criminal charges and to ascertain the
+victims' views on the possible details of a plea bargain.
+Id. at 394 (internal citation and quotation marks omitted). Federal district courts have reached
+similar conclusions. See, e.g., United States v. Rubin, 558 F. Supp. 2d 411, 417 n.5 (E.D.N.Y.
+2008) (discussing victims" "ability to seek pre-prosecution relief" under the CVRA); United
+States v. Okun, No. 08-132, 2009 WL 790042, at *2 (E.D. Va. Mar. 24, 2009) ("IT]he Fifth
+8
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 9 of 14
+Circuit has noted that victims acquire rights under the CVRA even before prosecution. This
+view is supported by the statutory language, which gives the victims rights before the accepting
+of plea agreements and, therefore, before adjudication of guilt."); United States v. BP Prods N.
+Am. Inc., No. 07-434, 2008 WL 501321, at *11 (S.D. Tex. Feb. 21, 2008) ("There are clearly
+rights under the CVRA that apply before any prosecution is underway."), mandamus denied in
+part, In re
+| 527 F.3d 391 (5" Cir. 2008).
+The United States argues that because the CVRA accords rights related to "any court
+proceeding, " 18 U.S.C. §§ 3771(b)(1), (d)(3), and "in the case," § 3771(b)(5), the CVRA applies
+only after formal charges are filed. The Court finds this argument unavailing. First, as discussed
+above, "court proceedings" can occur before formal charges are filed. Similarly, subsection
+(a)(5)'s reference to the right to confer with "the attorney for the Government in the case," is not
+limited to post-charge proceedings, as the United States is represented by attorneys in each
+criminal case at, for example, initial appearances and bond hearings. Last, the government's
+interpretation ignores the additional language throughout the statute that clearly contemplates
+pre-charge protections, such as subsection (c)(1)'s mandate that U.S. agencies involved at the
+"detection" and "investigation" stage use their best efforts to accord victims their enumerated
+rights under the CVRA and subsection (d)(3)'s provision that victims may vindicate their CVRA
+" For this reason, the Court respectfully disagrees with the interpretation adopted in In re
+Petersen, No. 10-298, 2010 WL 5108692 (N.D. Ind. Dec. 8, 2010), upon which the United States
+relies. See id. at *2 (holding that a "victim's "right to be treated with fairness and with respect
+for [his or her] dignity and privacy' may apply before any prosecution is underway and isn't
+necessarily tied to a "court proceeding' or 'case,"" but concluding that "the right "to confer with
+the attorney for the Government in the case' ... arise[s] only after charges have been brought
+against a defendant and a case has been opened"). But see In rel
+,, 527 F.3d at 394 (holding
+that under subsection (a)(5), "the government should have fashioned a reasonable way to inform
+the victims of the likelihood of criminal charges").
+9
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 10 of 14
+rights even if "no prosecution is underway." See United States v. DBB, Inc., 180 F.3d 1277,
+1281 (11" Cir. 1999) ("[W]e read the statute to give full effect to each of its provisions. We do
+not look at one word or term in isolation, but instead we look to the entire statutory context.")
+(citation omitted).
+The Court also rejects the United States' argument that pre-charge CVRA rights could
+impair prosecutorial discretion and decision-making. Any encroachment into the prosecutors'
+discretion is expressly limited by the CVRA itself, which provides: "Nothing in this chapter shall
+be construed to impair the prosecutorial discretion of the Attorney General or any officer under
+his direction." 18 U.S.C. § 3771(d)(6). As the court explained in Rubin, "there is absolutely no
+suggestion in the statutory language that victims have a right independent of the government to
+prosecute a crime, set strategy, or object to or appeal pretrial or in limine orders .... In short, the
+CVRA, for the most part, gives victims a voice, not a veto." 558 F. Supp. at 418; see also BP
+Prods N. Am., 2008 WL 501321, at *15 ("Even under an expansive approach, the reasonable
+right to confer on a proposed plea agreement and the government's obligation to provide notice
+of that right is subject to the limit that the CVRA not impair prosecutorial discretion."). Thus, to
+the extent that the victims' pre-charge CVRA rights impinge upon prosecutorial discretion, under
+the plain language of the statute those rights must yield.
+Having determined that as a matter of law the CVRA can apply before formal charges are
+filed, the Court must address whether the particular rights asserted here attached and, if so,
+whether the U.S. Attorney's Office violated those rights. However, the Court lacks a factual
+record to support such findings and must therefore defer ruling on these two issues pending the
+limited discovery discussed below.
+10
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 11 of 14
+IL
+Motion to Have Their Facts Accepted Because of the Government's Failure to
+Contest Any of the Facts
+For the reasons stated on the record at the August 12, 2011 hearing on this motion, the
+Court will deny Plaintiffs' request to have their facts accepted as true.
+Il.
+Motion for Order Directing the U.S. Attorney's Office Not to Withhold Relevant
+Evidence
+Plaintiffs request an order from the Court "directing the U.S. Attorney's Office not to
+suppress material evidence relevant to this case." (DE 50 at 1). Specifically, Plaintiffs seek all
+information and material known to the government that may be favorable to the victims
+regarding possible violations of their rights under the CVRA. The United States opposes the
+motion, arguing that neither the CVRA nor the Federal Rules of Civil Procedure impose a duty
+upon the U.S. Attorney's Office to provide evidence to Plaintiffs here.
+At the August 12, 2011 hearing on this motion, the United States agreed that this Court,
+under its inherent authority to manage this case, could impose discovery obligations on each
+party. Because the Court finds that some factual development is necessary to resolve the
+remaining issues in this case, it will permit Plaintiffs the opportunity to conduct limited
+discovery in the form of document requests and requests for admissions from the U.S. Attorney's
+Office. Either party may request additional discovery if necessary.
+Because the Court will allow this limited factual development, it is unnecessary to decide
+here whether the CVRA or the Federal Rules of Civil Procedure provide discovery rights in this
+context. The Court therefore reserves ruling on Plaintiffs' motion.
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 12 of 14
+IV.
+Bruce E. Reinhart's Motion to Intervene or in the Alternative for a Sua Sponte Rule
+11 Order
+Bruce E. Reinhart seeks leave to intervene as a party-in-interest under Rule 24(b) of the
+Federal Rules of Civil Procedure. Reinhart seeks to intervene to file a motion for sanctions
+based on allegedly "unfounded factual and legal accusations made about Movant in Plaintiffs"
+Motion for Finding of Violations of the Crime Victims' Rights Act." (DE 79 at 1). In that
+motion, Plaintiffs alleged that Reinhart, a former Assistant U.S. Attorney, "joined Epstein's
+payroll shortly after important decisions were made limiting Epstein's criminal liability" and
+improperly represented Epstein victims in follow-on civil suits. (DE 48 at 22). Plaintiffs
+contend that such conduct "give[s], at least, the improper appearance that Reinhart may have
+attempted to curry [favor] with Epstein and then reap his reward through favorable employment."
+(DE 48 at 23). Reinhart takes great offense to these accusation—
+-which he contends are false,
+irrelevant to the CVRA claims, and gratuitous-and seeks intervention to rebut these allegations
+and move for sanctions.
+Under Rule 24(b) of the Federal Rules of Civil Procedure, "the court may permit anyone
+to intervene who ... has a claim or defense that shares with the main action a common question
+of law or fact." It is "wholly discretionary with the court whether to allow intervention under
+Rule 24(b) and even though there is a common question of law or fact, or the requirements of'
+Rule 24(b) are otherwise satisfied, the court may refuse to allow intervention." In re Bayshore
+Trucks Sales, Inc., 471 F.3d 1233, 1246 (11" 2006). The Court will deny Reinhart's
+request to intervene.
+12
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 13 of 14
+First, the Court finds that Reinhart's claim does not share a common question of law or
+fact with the CVRA action. Reinhart claims that two paragraphs of Plaintiffs' forty-page motion
+make groundless and bad-faith accusations against his integrity and character. However, the
+veracity of Plaintiffs' two paragraphs—i.e., whether Reinhart used his position at the U.S.
+Attorney's Office to ingratiate himself with Epstein and advance his career in private
+practice—involves no common questions with the Plaintiffs' claims that the U.S. Attorney's
+Office violated their CVRA rights through the process in which it entered into the NPA with
+Epstein. Indeed, Reinhart's motion argues that the allegations against him are "irrelevant" and
+that Plaintiffs "dol] not make any effort to connect these allegations to the relief [they] seek[]."
+(DE 79 at 2).
+Second, even if these accusations shared common questions with Plaintiffs' CVRA
+claims, the Court would exercise its discretion and deny intervention. The Court cannot permit
+anyone slighted by allegations in court pleadings to intervene and conduct mini-trials to vindicate
+their reputation. Absent some other concrete interest in these proceedings, the Court does not
+believe that the allegations here are sufficiently harmful to justify permissive intervention.
+Reinhart has publicly aired his opposition to and denial of Plaintiffs' contentions, both on this
+docket and in open court, and the Court finds that further proceedings on this issue are
+unwarranted. For the same reason, the Court declines to conduct a sua sponte Rule 11 inquiry.
+Conclusion
+For the foregoing reasons, it is hereby ORDERED AND ADJUDGED that Plaintiffs'
+Motion for Finding of Violations of the Crime Victims' Rights Act (DEs 48, 52) is GRANTED
+IN PART. The Court concludes that the CVRA can apply before formal charges are filed. The
+13
+
+
+Case 9:08-cv-80736-KAM Document 99 Entered on FLSD Docket 09/26/2011 Page 14 of 14
+Court defers ruling on the merits of Plaintiffs' CVRA claims until the parties complete the
+discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Plaintiffs' Motion to Have Their Facts
+Accepted (DE 49) is DENIED.
+The Court reserves ruling Plaintiffs' Motion for Order Directing the U.S. Attorney's
+Office Not to Withhold Relevant Evidence (DE 50) pending the discovery ordered herein.
+It is further ORDERED AND ADJUDGED that Bruce E. Reinhart's Motion to Intervene
+or in the Alternative for a Sua Sponte Rule 11 Order (DE 79) is DENIED.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County, Florida
+this 26" day of September, 2011.
+KENNETH A. MARRA
+United States District Judge
+14
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+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA-| 11
+JANE DOE NO. 2,
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+DEFENDANT EPSTEIN'S RESPONSE TO PLAINTIFF'S MOTION FOR
+PROTECTIVE ORDER AND TO QUASH SUBPOENA FOR
+DEPOSITION OF JANE DOE NO.3, MOTION TO CONSOLIDATE
+CASES FOR PURPOSES OF DISCOVERY, AND INCORPORATED
+MEMORANDUM OF LAW IN SUPPORT
+Defendant, JEFFREY EPSTEIN, by and through his undersigned counsel, serves his
+Response to Plaintiff's Motion for Protective Order and to Quash Subpoena for Deposition of
+Jane Doe no.3, Motion to Consolidate Cases for Purposes of Discovery, and Incorporated
+Memorandum of Law (hereinafter, the Motion"), with incorporated memorandum of law. In
+support, Defendant states:
+RESPONSE WITH INCORPORATED MEMORANDUM OF LAW AS TO
+DEPOSITION OF JANE DOE. NO. 3 AND MOTION TO CONSOLIDATE
+a. The Depositions
+Plaintiff, Jane Doe No. 2, filed this federal lawsuit against Defendant, Jeffrey Epstein. In
+another separate matter, a Plaintiff, Jane Doe, No. 3., filed her own separate lawsuit against
+Defendant, Jeffrey Epstein. Plaintiff's counsel represents all Jane Does in cases Jane Doe Nos. 2
+through 7 before this court.
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 2 of 7
+Page 2
+Plaintiff, Jane Doe. No. 3, served answers to interrogatories wherein she lists certain
+witness that may have knowledge regarding the facts and allegations alleged in her complaint
+including, but not limited to, Jane Doe No. 2. See Exhibit "A", Answer to Interrogatories, No.
+5, in redacted form. An unredacted copy of the responses will be provided to the court upon the
+court's request and/or in camera. In particular, the response to interrogatory number 5 states that
+Jane Doe numbers 2 and 3 accompanied each other to Defendant's estate. Plaintiff admits this
+much in her Motion. Defendant seeks to take the deposition of Jane Doe. No. 3 as a witness in
+the instant matter and as a party in Plaintiff her own case, which she is an unidentified Plaintiff
+traveling under Jane Doe. No. 3.
+In an attempt to resolve this matter by letter correspondence, Defendant agreed and
+offered only to take the deposition of Jane Doe. No. 3 as a witness in all Jane Doe 2-7 cases only
+one time and separately one time as a Party Plaintiff in the matter Jane Doe No. 3 filed against
+Jeffrey Epstein. While this is a reasonable compromise in that Defendant has agreed not to take
+her deposition three (3) times as Plaintiff suspected, Plaintiff's counsel refused to agree. Plaintiff
+cannot file a lawsuit and then expect this court to protect her from being deposed as a party for
+the time period proscribed under the federal rules while at the same time asking this court to
+limit or prevent her deposition testimony as a witness in the instant matter or other Jane Doe
+matters where she has been identified as a witness.
+It is well settled that a Defendant may take the deposition of a party and/or a witness
+before trial. Rule 26, Fed.R.Civ. P., Rule 30, Fed.R. Civ.,P. and Leve v. General Motors Corp.,
+43 F.R.D. 508 (S.D.N.Y. 2967). Jane Doe. Nos. 2 and 3 commenced separate civil actions upon
+the filing of same against Jeffrey Epstein. Therefore, Defendant is entitled to depose Jane Doe
+Nos. 2 and 3 in their own cases at least one time for the proscribed time periods and then as a
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 3 of 7
+Page 3
+witness in the instant matter or any matter they have knowledge of as reflected in the
+interrogatory responses.
+Therefore, Defendant has a right to depose each party-plaintiff
+separately and then as a witness at least once. Deposing Jane Doe No. 3 as a witness in the
+instant matter is necessary as that deposition will be tailored toward facts known by Jane Doe.
+No. 3 as those facts pertain to Jane Doe. No. 2's claims in her complaint as opposed to the facts
+alleged by Jane Doe. No. 3 in her individual action.
+Plaintiff's attorneys claim that sitting for more than one deposition will be traumatizing
+does not modify the rules and/or the law with regard to the right to take party and witness
+depositions. Plaintiff offers no expert medical or psychological support, by an affidavit of an
+expert or the Plaintiff herself, to support her position. In almost all instances, none of the
+Plaintiff's sought or received any psychological counseling until the concept of a lawsuit and
+money was introduced. A party may, by oral questions take the deposition of any person,
+without leave of court. Rule 30, Fed.R. Civ.,P. Conducting these depositions separately will
+allow for the proper preparation as to each deponent's knowledge as that knowledge pertains to
+the specific case at hand (i.e., whether the deponent is a witness and/or a party plaintiff). Again,
+Defendant is willing to conduct one (1) deposition in connection with each matter before this
+court wherein a party to one matter is listed as a "witness" in another. That is, if Jane Doe No. 3
+has knowledge as a witness to one or more matters, one "witness" deposition will be held.
+However, Defendant is also permitted to separately take a party-plaintiff deposition of any partyplaintiff that happens to be a witness of and/or have knowledge of any other party-plaintiff's
+deposition. As such, only two depositions will occur.
+There is no legal basis supporting Plaintiff's proposition that Defendant not be allowed to
+take the deposition of Jane Doe. No. 3 as a witness in the instant matter and as a party-plaintiff in
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 4 of 7
+Page 4
+Jane Doe. No.3's separately filed action. In fact, Plaintiff's theory flies in the face of the Federal
+Rules.
+Despite Plaintiff's contention, Defendant is not attempting to depose or call a witness
+for a second deposition without leave of court. Quite the opposite, Plaintiff is simply doing what
+the rules allow for - the taking of a deposition of a party and a witness.
+b. Consolidation For Discovery Is Not Practical
+Next, if this case is consolidated for discovery purposes and depositions are limited only
+to one (1) deposition for a party plaintiff and for a witness that happens to be a party plaintiff in
+another matter, then confusion will result and motions in limine will undoubtedly be filed at a
+later date preventing the use of certain testimony at particular hearings and ultimately at trial.
+Further, since there remain separate party-plaintiffs, admissions or answers to discovery by one
+party, arguably, cannot be used by the Defendant in a consolidated discovery matter against
+another party-plaintiff. As such, consolidation in the instant matter is not warranted in that not
+all common issues of fact are present and the parties are not identical. Kelly v. Kelly, 911
+F.Supp. 66 (N.D. NY 1996)(consolidation refused because it would only serve purpose of
+convenience of some witnesses, actions did not share all witnesses and parties were not
+identical); Borough of Olyphant v. PPL Corporation et al., 153 Fed.Appx. 80, 2005 WL 2673489
+(C.A.3 (P.A.)); 1
+Motor Credit Company v. Chiorazzo, 529 F.Supp.2d 535 (D. N.J. 2008).
+Under Florida Rules of Civil Procedure 42, the decision to consolidate cases for discovery
+is not mandatory but that decision remains within the sound discretion of the court. In this
+instance, various Jane Does seek to consolidate the cases for discovery purposes. Very clearly,
+the facts and circumstances, as pled and as is reflected in answers to interrogatories, are different
+for each individual, i.e. the dates, the ages, the events, their experiences, witnesses, medical
+and/or psychological treatment, etc. Each of the Plaintiffs alleged incident history and post
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 5 of 7
+Page 5
+incident history and background is unique to those individuals. While Jane Doe Plaintiffs may
+wish to serve a "standard" set of interrogatories, request for production, or any other type of
+discovery, the Defendant's discovery to the individual Plaintiffs, and certainly their responses, is
+unique to that individual. There will be multiple instances where the discovery is applicable only
+to a specific Jane Doe and not all, such as, physicians, psychologists, parents, siblings, friends,
+employers, teachers, individuals with whom the Plaintiff has had relationships - many of these
+depositions will go to damage related issues wherein the Plaintiffs seek millions of dollars in the
+form of compensation.
+There are some instances where the deposition of a particular individual may be
+applicable to all cases, and defense counsel will suggest, as he did in correspondence directed to
+Plaintiff's counsel that that particular deposition be used in all cases. However, in a vast
+majority of the instances where discovery, deposition and/or paper discovery is being utilized,
+including subpoena which will be sent to many different sources for each of the six Jane Does,
+consolidation serves no purpose.
+Even if this court consolidated the matters requested by Plaintiff, the undersigned would
+still be entitled to additional time to depose any party-plaintiff that is also listed or who has
+knowledge of any aspect of any other party-plaintiff's claim against Jeffrey Epstein. In addition,
+this Court has before it each of the cases filed by certain Plaintiffs against Jeffrey Epstein.
+Therefore, there is no chance of "conflicting results" as to rulings made by the same court and
+the same judge. As such, no true need exists for consolidation. Under Fed.R.Civ.Pro. 42,
+consolidation for discovery is not required, but remains within the sound discretion of the court.
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 6 of 7
+Page 6
+II. Conclusion
+In sum, if Jane Doe No. 3 has knowledge as a witness to one or more matters, one
+"witness" deposition will be held as to her witness knowledge. However, Defendant is also
+permitted to separately take Jane Doe. No. 3's deposition as a party-plaintiff.
+WHEREFORE, Defendant requests that this Court deny the Motion, enter an order
+allowing for the relief requested herein and for such other relief a
+this court deems just and
+proper.
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the
+Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record identified on the following Service List in the manner specified by
+CMECE on this Iday of April, 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #2
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+
+
+Case 9:08-cv-80119-KAM Document 79 Entered on FLSD Docket 04/17/2009 Page 7 of 7
+Page 7
+Respectfully submitted,
+By: _
+ele
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/fc522f8283921224f2128e0360c685d638d595727b28bbf0a455a1e0b2c0e910.receipt.json b/vision-fixhub/court-01/fc522f8283921224f2128e0360c685d638d595727b28bbf0a455a1e0b2c0e910.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..1ac2a0a837fe6eeac170e47cff26fa6bfa4661d9
--- /dev/null
+++ b/vision-fixhub/court-01/fc522f8283921224f2128e0360c685d638d595727b28bbf0a455a1e0b2c0e910.receipt.json
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
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diff --git a/vision-fixhub/court-01/fcc14f33d22f033d4b471841fcac1fb11b29f39466eed0b319d8d4aa6d752d05.md b/vision-fixhub/court-01/fcc14f33d22f033d4b471841fcac1fb11b29f39466eed0b319d8d4aa6d752d05.md
new file mode 100644
index 0000000000000000000000000000000000000000..c4be0e13b3d1a04a684361151e69b64f9f2472f9
--- /dev/null
+++ b/vision-fixhub/court-01/fcc14f33d22f033d4b471841fcac1fb11b29f39466eed0b319d8d4aa6d752d05.md
@@ -0,0 +1,278 @@
+Case 9:08-cv-80232-KAM Document 115-1
+Entered on FLSD Docket 06/09/2009 Page 1 of 10
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA-
+JANE DOE NO. 3
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+DEFENDANT EPSTEIN'S FIRST AMENDED ANSWER & AFFIRMATIVE
+DEFENSES TO PLAINTIFF'S SECOND AMENDED COMPLAINT
+Defendant, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his
+undersigned attorneys,
+files his First Amended Answer to the Second Amended
+Complaint [DE 50] and states:
+1. Without knowledge and deny.
+2. As to the allegations in paragraphs 2, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4* DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "it would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("...court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 2 of 10
+Page 2
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+3. As to the allegations in paragraph 3, deny.
+4. As to the allegations in paragraph 4, deny.
+5. As to the allegations in paragraph 5, without knowledge and deny.
+6. As to the allegations in paragraphs 6, Defendant asserts his Fifth Amendment
+privilege against self-incrimination. See DeLisi v. Bankers Ins. Company, 436 So.2d
+1099 (Fla. 4" DCA 1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth
+Amendment's Self-Incrimination Clause applies to the states through the Due Process
+Clause of the Fourteenth Amendment - "[ilt would be incongruous to have different
+standards determine the validity of a claim of privilege based on the same feared
+prosecution, depending on whether the claim was asserted in state or federal court."); 5
+Fed.Prac. & Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-
+Incrimination ("....court must treat the defendant's claim of privilege as equivalent to a
+specific denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. -
+"... a civil defendant who raises an affirmative defense is not precluded from asserting
+the privilege [against self-incrimination], because affirmative defenses do not constitute
+the kind of voluntary application for affirmative relief" which would prevent a plaintiff
+bringing a claim seeking affirmative relief from asserting the privilege.
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 3 of 10
+Page 3
+7. As to the allegations in paragraphs 7 through 14 of Plaintiff's Second Amended
+Complaint, Defendant exercises his Fifth Amendment Privilege against selfincrimination.
+See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA
+1983); Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-
+Incrimination Clause applies to the states through the Due Process Clause of the
+Fourteenth Amendment - "Tilt would be incongruous to have different standards
+determine the validity of a claim of privilege based on the same feared prosecution,
+depending on whether the claim was asserted in state or federal court."); 5 Fed.Prac. &
+Proc. Civ. 3d §1280 Effect of Failure to Deny - Privilege Against Self-Incrimination
+("...court must treat the defendant's claim of privilege as equivalent to a specific
+denial."). See also 24 Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil
+defendant who raises an affirmative defense is not precluded from asserting the
+privilege [against self-incrimination], because affirmative defenses do not constitute the
+kind of voluntary application for affirmative relief" which would prevent a plaintiff bringing
+a claim seeking affirmative relief from asserting the privilege.
+8. In response to the allegations of paragraph 15, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+9. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 16 through 21 of the Second Amended
+Complaint.
+See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 4 of 10
+Page 4
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "'ilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+10. In response to the allegations of paragraph 22, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+11. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 23 through 27 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4" DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "Tilt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 5 of 10
+Page 5
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against selfincrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+12. In response to the allegations of paragraph 28, Defendant realleges and adopts
+his responses to paragraphs 1 through 14 of the Second Amended Complaint set forth
+in paragraphs 1 through 6 above herein.
+13. Defendant asserts the Fifth Amendment Privilege against self-incrimination to
+the allegations set forth in paragraphs 29 through 34 of the Second Amended
+Complaint. See DeLisi v. Bankers Ins. Company, 436 So.2d 1099 (Fla. 4* DCA 1983);
+Malloy v. Hogan, 84 S.Ct. 1489, 1495 (1964)(the Fifth Amendment's Self-Incrimination
+Clause applies to the states through the Due Process Clause of the Fourteenth
+Amendment - "filt would be incongruous to have different standards determine the
+validity of a claim of privilege based on the same feared prosecution, depending on
+whether the claim was asserted in state or federal court."); 5 Fed.Prac. & Proc. Civ. 3d
+§1280 Effect of Failure to Deny - Privilege Against Self-Incrimination ("...court must
+treat the defendant's claim of privilege as equivalent to a specific denial."). See also 24
+Fla.Jur.2d Evidence §592. Defendants in civil actions. - "... a civil defendant who raises
+an affirmative defense is not precluded from asserting the privilege [against self-
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 6 of 10
+Page 6
+incrimination], because affirmative defenses do not constitute the kind of voluntary
+application for affirmative relief" which would prevent a plaintiff bringing a claim seeking
+affirmative relief from asserting the privilege.
+WHEREFORE, Defendant requests that this Court deny the relief sought by Plaintiff.
+Affirmative Defenses
+1. As to all counts, Plaintiff actually consented to and was a willing participant in the
+acts alleged, and therefore, her claims are barred, or her damages are required to be
+reduced accordingly.
+2. As to all counts alleged, Plaintiff actually consented to and participated in
+conduct similar and/or identical to the acts alleged with other persons which were the
+sole or contributing cause of Plaintiff's alleged damages.
+3. As to all counts, Plaintiff impliedly consented to the acts alleged by not objecting
+and by going to Defendant's home with other females and/or by bringing other females
+to Defendant's home for which Plaintiff received money, and therefore, her claims are
+barred, or her damages are required to be reduced accordingly.
+4. As to all counts, Defendant reasonably believed or was told that the Plaintiff had
+attained the age of 18 years old at the time of the alleged acts.
+5. As to all counts, Plaintiff's claims are barred as she said she was 18 years or
+older at the time.
+6. As to all counts, Plaintiff's alleged damages were caused in whole or part by
+events and/or circumstances completely unrelated to the incidents) alleged in the
+complaint.
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 7 of 10
+Page 7
+7. Plaintiff's claims are barred by the applicable statute of limitations.
+8. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the limitations as set forth in $768.72, et seq., Florida Statutes.
+9. As to Plaintiff's claims for punitive damages in Count | - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," such claims are
+subject to the constitutional limitations and guideposts as set forth in BMW of North
+America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v.
+1, 127 S.Ct. 1057
+(2007); State Farm v.
+123 S.Ct 1513 (2003);
+v. Ligget Group, Inc., 945
+So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the
+United States Constitution and Florida's Constitution, Art. I, §82 and 9, prohibit the
+imposition of grossly excessive or arbitrary punishments
+10. As to Plaintiff's claims for punitive damages in Count 1 - "Sexual Assault &
+Battery," and Count II - "Intentional Infliction of Emotional Distress," the determination of
+whether or not Defendant is liable for punitive damages is required to be bifurcated from
+a determination of the amount to be imposed.
+11. Plaintiff has failed to state a cause of action for sexual assault and/or battery
+under Count I.
+12. As to Count III, Plaintiff has failed to plead a cause of action as she does not and
+can not show a violation of a predicate act under 18 U.S.C. §2255 (2005).
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 8 of 10
+Jane Doe No. 3 V. Epstein
+Page 8
+13. As to Count IlI, the version of 18 U.S.C. §2255 in effect at the time of the alleged
+conduct applies, and, thus, the presumptive minimum damages amount should Plaintiff
+prove the elements of such claim is $50,000, and not subject to any multiplier.
+14. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, would be in violation of the legal axiom against retroactive application of
+an amended statute, and also in violation of such constitutional principles, including but
+not limited to, the "Ex Post Facto" Clause, U.S. Const. Article I, §9, cl. 3, §10, cl. 1, and
+procedural and substantive due process, U.S. Const. 14" Amend., 5" Amend. The
+statute in effect during the time of the alleged conduct applies.
+15. As to Count III, application of the amended version of 18 U.S.C. §2255, effective
+July 27, 2006, is prohibited pursuant to the vagueness doctrine and the Rule of Lenity.
+A criminal statute is required to give " 'fair warning ... in language that the common
+world will understand, of what the law intends to do if a certain line is passed. To make
+the warning fair, so far as possible the line should be clear.' " United States v. Lanier,
+520 U.S. 259, 265, 117 S.Ct. 1219, 137 L.Ed.2d 432 (1997) (quoting McBoyle v. United
+States, 283 U.S. 25, 27, 51 S.Ct. 340, 75 L.Ed. 816 (1931)) (omission in original). The
+"three related manifestations of the fair warning requirement" are: (1) the vagueness
+doctrine bars enforcement of a statute which either forbids or requires the doing of an
+act in terms so vague that men of common intelligence must necessarily guess at its
+meaning and differ as to its application; (2) the canon of strict construction of criminal
+statutes, or rule of lenity, ensures fair warning by so resolving ambiguity in a criminal
+statute as to apply it only to conduct clearly covered; (3) due process bars courts from
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 9 of 10
+Page 9
+applying a novel construction of a criminal statute to conduct that neither the statute nor
+any prior judicial decision has fairly disclosed to be within its scope.
+16. The applicable version of 18 U.S.C. §2255 creates a cause of action on behalf of
+a "minor." Plaintiff had attained the age of majority at the time of filing this action, and
+accordingly, her cause of action is barred.
+17. Because Plaintiff has no claim under 18 U.S.C. §2255, this Court is without
+subject matter jurisdiction as to all claims asserted.
+18. Application of the 18 U.S.C. §2255, as amended, effective July 27, 2006, is in
+violation of the constitutional principles of due process, the "Ex Post Facto" clause, and
+the Rule of Lenity, in that in amending the term "minor" to "person" as to those who may
+bring a cause of action impermissibly and unconstitutionally broadened the scope of
+persons able to bring a §2255 claim.
+19.18 U.S.C. §2255 violates the Equal Protection Clause of the 14* Amendment
+under the U.S. Constitution, and thus Plaintiff's claim thereunder is barred.
+20. 18 U.S.C. §2255 violates the constitutional guarantees of procedural and
+substantive due process. Procedural due process guarantees that a person will not be
+deprived of life, liberty or property without notice and opportunity to be heard.
+Substantive due process protects fundamental rights. Accordingly, Plaintiff's cause of
+action thereunder is barred.
+WHEREFORE Defendant requests that this Court deny the relief sought by Plaintiff.
+Robert D. Critton, Jr.
+Attorney for Defendant Epstein
+
+
+Case 9:08-cv-80232-KAM Document 115-1 Entered on FLSD Docket 06/09/2009 Page 10 of
+Page 10
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this _ day of
+_ 2009:
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #3
+Jack Alan Goldberger
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+ROBERT D. CRITTON, JR, ESC
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+MAN, CAN ON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fcc14f33d22f033d4b471841fcac1fb11b29f39466eed0b319d8d4aa6d752d05.receipt.json b/vision-fixhub/court-01/fcc14f33d22f033d4b471841fcac1fb11b29f39466eed0b319d8d4aa6d752d05.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e875bd7512e584a8862b4c22f37afc3daebd0158
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-01/fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742.md b/vision-fixhub/court-01/fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742.md
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@@ -0,0 +1,100 @@
+Case 9:08-cv-80232-KAM Document 58-1 Entered on FLSD Docket 03/26/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80232-MARRA--
+JANE DOE NO. 3,
+Plaintiff,
+: V.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF JANE DOE 3'S ANSWERS TO DEFENDANT'S FIRST
+INTERROGATORIES
+Plaintiff, JANE DOE 3, by and through their undersigned counsel, and pursuant
+to Federal Rules of Civil Procedure Rule 33, hereby responds to Defendant, JEFFREY
+EPSTEIN'S First Set of Interrogatories to Plaintiff as follows:
+General Objections
+1.
+Plaintiff objects to Defendant's Interrogatories to the extent that the
+Interrogatories call for the disclosure of information protected by the attorney-client
+privilege, attorney work-product doctrine, or other applicable privilege or immunity,
+whether created by statute or common law.
+Plaintiff claims such privileges and
+protections to the extent implicated by each Interrogatory, and excludes privileged and
+protected information from any responses to Defendant's discovery. Any disclosure is
+inadvertent and is not intended to waive those privileges or protections, which are
+specifically reserved.
+2.
+Plaintiff objects to Defendant's Interrogatories to the extent that same are
+vague, ambiguous, incomprehensible and/or overly broad.
+
+
+
+Case 9:08-cv-80232-KAM Document 58-1 Entered on FLSD Docket 03/26/2009 Page 2 of 3
+(
+- Doe No. 3 v. Epstein
+Page 13
+your current age.
+Describe the lewd or lascivious exhibition, the date and
+whether you received money or other consideration from the person
+Answer:
+nora cras vad to dead to decoyery of admissi
+evidence. Moreover, this interrogatory is outrageous, offensive and apparentiy
+posed for the purpose of intimidating the victim. Fed.R.Evid. 412 makes any
+answer to this interrogatory inadmissible, and nothing in the answer. could
+plausibly lead to discovery of admissible evidence.
+22.
+23.
+List in detail all discussions/interviews which you had with any representative
+from FBI, U.S. Attorneys' Office, State Attorneys' Office (Palm Beach County),
+Palm Beach Sheriff's Office and Palm Beach Police Department regarding your
+meetings with Mir. Epstein. Include dates, who was present, the details of what
+was discussed, whether a court reporter was present and whether a taped
+statement was taken or whether you provided a written statement.
+Answer:
+Plaintiff met with the Palm Beach Police Department in 2007. She believes that
+she provided them with a written statement, and that they also tape recorded her
+interview.
+Plaintiff also spoke with FBI agents in 2007 investigating the case on 2-3
+occasions, including one meeting in person. Plaintiff does not believe that the
+statement was recorded.
+State the names, addresses, ages and phone numbers of all females whom you
+claim were brought by you to Mr. Epstein's home to give him a massage. As to
+each female, state the amount of money you claim you were paid to bring each
+female.
+Answer:
+(Jane Doe 4)
+Plaintiff was not paid by the Defendant of bringing C
+• (Jane Doe 4)
+(Jane Doe 2)
+Plaintiff was paid $100 for bringing d
+(Jane Doe 2)
+
+
+Case 9:08-cv-80232-KAM Document 58-1 Entered on FLSD Docket 03/26/2009 Page 3 of 3
+(
+VERIFICATION
+_being duly sworni, deposes and says that the
+foregori ane to rogatories are true any ours, defe best of no knowe te.,
+information and belief.
+Jane Doe 3
+STATE OF FLORIDA
+COUNTY OF PALM BEACH
+SWORN TO AND SUBSCRIBED before me this 19 day of January. 2009 by
+Jane Doe 3
+following identification Lilvers
+- who is personally known to me or has produced the
+hicews: which is current or has been issued
+within the past five years and bears a serial or other identifying number.
+Elzabeth Yuteenez
+rint Nam
+Signature
+Chizabeth fatey
+NOTARY PUBLIC - STATE OF FLORIDA
+Commission Number:
+My commission expires:
+(Notarial Seal)
+Notary Public State of Florida
+Elizabeth Gutienez-
+My Commission CD440926
+Expires 06/14/2009
+:.%.
diff --git a/vision-fixhub/court-01/fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742.receipt.json b/vision-fixhub/court-01/fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..26ebdaf7913086bea6f2c4d4678d5003591c0eb5
--- /dev/null
+++ b/vision-fixhub/court-01/fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -47,
+  "dataset": "marble-joined",
+  "doc_id": "fcc80e919bc9d569e31bcd52f19e64eae8b3303611c23ca4fa0bb9b20abb9742",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "d42dcca8ff98599fdc54f1429b2bb489c64224f965d9b1f023d1736d63bb56e3",
+  "output_sha256": "9b410af04e680e4e8b8fb74e00538c6e591d614658ba20afb0624e020242ba93",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.md b/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.md
new file mode 100644
index 0000000000000000000000000000000000000000..948e26abfab5f041c16fc9433ae363207f4c3ac6
--- /dev/null
+++ b/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.md
@@ -0,0 +1,35 @@
+Case 1:19-cv-09610-PAE-DCF Document 22 Filed 11/06/19
+
+AO 458 (Rev. 06/09) Appearance of Counsel
+UNITED STATES DISTRICT COURT
+for the
+Southern District of New York
+To:
+Jane Doe 17
+Plaintiff
+V.
+Darren |. Indyke and Richard D. Kahn, et al
+Defendant
+Case No. 1:19-cv-09610-PAE
+APPEARANCE OF COUNSEL
+The clerk of court and all parties of record
+I am admitted or otherwise authorized to practice in this court, and I appear in this case as counsel for:
+Plaintiff
+Date:
+10/28/2019
+/s/ Alan Goldfarb
+Attorney's signature
+ALAN GOLDFARB (FBN 146924).
+Printed name and bar number
+100 SE 2ND STREET, SUITE 4500
+MIAMI, FL 33131
+Address
+agoldfarb@goldfarbpa.com
+E-mail address
+(305) 371-3111
+Telephone number
+(305) 577-8375
+FAX number
+Print
+Save As...
+Reset
diff --git a/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.receipt.json b/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..af7d7c6f3bd1a4c7fe1d7fa91439a9d18804ae57
--- /dev/null
+++ b/vision-fixhub/court-01/fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -23,
+  "dataset": "marble-joined",
+  "doc_id": "fcdb0be7c5f341a369fc4a89eb5ffa47d83539804779f003986d470998440e4c",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "9bbf1091c0c002f82dca98c3cd0637d67730f1ba2b901aada7ce11b92e08b044",
+  "output_sha256": "8a36457104fc1659ac3fa134bd4c1dede1c0f74265d5571fac104d495402d806",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.md b/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.md
new file mode 100644
index 0000000000000000000000000000000000000000..82b90348c5cdfc6677f5e8b7c0625fa763b2b5dc
--- /dev/null
+++ b/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.md
@@ -0,0 +1,29 @@
+Case 9:08-cv-80380-KAM Document 72-1 Entered on FLSD Docket 03/25/2009 Page 1 of 1
+INDICTMENT
+ATRUEBILL 06-9454 CF
+Anz
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA J
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
+CIRCUIT OF THE STATE OF FLORIDA
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:
+The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their
+oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State
+aforesaid,
+COUNT ONE
+FELONY SOLICITATION OF PROSTITUTION
+on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31,
+2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to
+Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005,
+contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+against the form of the statute, to the evil example of all others, and against the peace and dignity of the State
+of Florida.
+I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+- Assistant State Attorney of the
+Fifteenth Judicial Circuit of the State
+of Florida, prosecuting for the said
+State
+GRAND JURY FOREPERSON
+DATE
+Jeffrey E. Epstein, Race:
+EXHIT"A"
+Sex: Male, DOB: January 20, 1953, SS#: 090-44-3348; Issue Warrant
diff --git a/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.receipt.json b/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..e2b76a657ea51e7465babe8aac3ae48bddc50896
--- /dev/null
+++ b/vision-fixhub/court-01/fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "fceb338287b796629710c813ad3adb89f4615e257cdc673ed00ddb354b81c558",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "13c801c18895355b887ddd4a3bfa1dff302eb428c78f05bde85d2a0ac91f0252",
+  "output_sha256": "2b74cb3416888060546b97b3ce93434fea95c003d72879edd41d865a1fa92086",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.md b/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.md
new file mode 100644
index 0000000000000000000000000000000000000000..f39ddf507fbc5d718ee1e281311a06d872f2d852
--- /dev/null
+++ b/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.md
@@ -0,0 +1,33 @@
+Case 9:08-cv-80381-KAM Document 127-2 Entered on FLSD Docket 07/29/2009 Page 1 of 2
+DECLARATION OF JANE DOE NO. 4
+1, 1
+, state as follows:
+2.
+I am the Plaintiff identified as Jane Doe No. 4 in this lawsuit.
+During the past week, three investigators working on behalf of Jeffrey Epstein
+contacted the office of my former employer, Florida Realty, on three separate occasions.
+During the contacts, the investigators asked my former employer personal
+questions about me, including whom I am dating and how they can contact my ex-boyfriend.
+The investigators obtained the name of my ex-boyfriend from my former employer and have
+been repeatedly contacting a former co-worker to get the telephone number of my ex-boyfriend.
+Once they obtained the number of my ex-boyfriend, they have repeatedly contact him, asking
+very personal questions about my relationship with him, as well as my current relationship,
+employment, and residence.
+4. None of the individuals whom the investigators have contacted or attempted to
+contact knew that I am a plaintiff in a childhood sexual abuse lawsuit against Jeffrey Epstein, but
+now they are asking me questions about it.
+5.
+I am worried that Jeffrey Epstein will continue to send investigators to speak with
+people I know who do not know that I am a Plaintiff in this lawsuit. I am concerned that the
+investigators will ask these people very personal questions about my life and disclose that I am a
+Plaintiff in a sexual abuse lawsuit against Jeffrey Epstein. It could cause problems in my social
+circle and with my future employment and educational opportunities if people find out that I am
+a plaintiff in a childhood sexual abuse suit against Jeffrey Epstein.
+I declare under penalty of perjury the foregoing to be true and correct.
+
+B
+
+
+Case 9:08-cv-80381-KAM Document 127-2 Entered on FLSD Docket 07/29/2009 Page 2 of 2
+Dated this 1] day of _July, 2009
+) a/kal Jane Doe No. 4
diff --git a/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.receipt.json b/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f9577ad9e54360b8b564121946e05ea8845da5ee
--- /dev/null
+++ b/vision-fixhub/court-01/fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -31,
+  "dataset": "marble-joined",
+  "doc_id": "fd1b137c94173ced9033308d42a2c8f6c45ee14fc0fda6817affdb90280baecd",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "3732bb8637aeee95054e0e41cb5a636918719b8b239dae2d3045a5b8a4b0811b",
+  "output_sha256": "37bd046a8fe76d7c5aca9ba6e01114c81024d3429578081ec4ed7cc3693296be",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.md b/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.md
new file mode 100644
index 0000000000000000000000000000000000000000..193d06ff286c60ba40d09b2c198dfba4e5e50b1e
--- /dev/null
+++ b/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.md
@@ -0,0 +1,78 @@
+Filing # 115383434 E-Filed 10/21/2020.04:13:35 PM
+CA FLORIDA HOLDINGS, LLC,
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50-2019-CA-014681-XXXX-MB
+DIVISION: AG
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida; SHARON R
+BOCK, aș Clerk and Comptroller of Palm
+Beach County, Florida,
+COPY
+Defendants.
+PLAINTIFF CA HOLDINGS, LIC'S
+NOTICE OF DROPPING STATE ATTORNEY, DAVE ARONBERG
+Plaintiff, CA HOLDINGS, LLC, pursuant to Fla. R. Civ, P. 1250(b), hereby notifies the parties that
+it has dropped State Attorney, Dave Aronberg from the above case.
+A
+NOT
+Respectfully submitted,
+GREENBERG TRAURIG, P.A.
+Attorneys for CA Florida Holdings, LLC, Publisher.
+of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+401 East Las Olas Boulevard Suite 2000
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+By:
+Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns/@gtlaw.com
+smithl@gtlaw.com
+FL.Servicel@gtlaw.com
+Party_ JOINT
+ID#. J23. EV# J23
+DATE ADMITTED: 9/6/2022
+Case No. 2019-CA-014681
+ABRUZZO CLERK
+CIRCUIT COURT
+CA/Aronbei@ODQ3OMI BEACH COUNTY, FL, JOSEPH ABRUZZO, CLERK. 3/27/2023 3:44:22 PM
+Joint Exhibit
+J23
+
+
+Bỳ:
+Is/ Michael J Grygiel
+MICHAEL J GRYGIEL
+(Admitted Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By:
+Is/ Nina D. Boyajiari
+NINA D. BOYAJIAN
+(Admitted Pro Hac Vice)
+1840 Century Park East, Suite 1900
+Los Angeles California 90067
+Telephone: (310) 586-7700
+Facsimile: (310) 586-7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 21" day of October, 2020; a true and correct copy of the
+foregoing has been filed with the Clerk of the Court using the State of Florida e-filing system, which
+will send a notice of electronic service for all parties of record herein
+NOT A
+ACTIVE 53317341v1
+Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+2
+CAArontierg0D0302 BEACH COUNTY, FL,
+ABRUZZO, CLERK. 3/27/2023 3:44:22 PM
diff --git a/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.receipt.json b/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..88fe7e063992527c627ebde167ce09e5c66a854e
--- /dev/null
+++ b/vision-fixhub/court-01/fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "fd378bf32712447a5660b24f98f9afe0622f569b61cd0fb6fb502e45961fb42d",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1c4a60ce053ad1f740ce039b0517a11b974a22932b0f689450f21ad7711e9889",
+  "output_sha256": "3411f83801da6811456a469281781d6a5041edd94f3a60cf865ad55abc6d8571",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.md b/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.md
new file mode 100644
index 0000000000000000000000000000000000000000..d597c573bf717da9ffa5da138954398ccaa5fbf0
--- /dev/null
+++ b/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.md
@@ -0,0 +1,29 @@
+Case 9:08-cv-80232-KAM Document 57-1 Entered on FLSD Docket 03/25/2009 Page 1 of 1
+INDICTMENT
+ATRUEBILL 06-9454 CF
+IN THE NAME OF AND BY THE AUTHORITY OF THE STATE OF FLORIDA J
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL
+CIRCUIT OF THE STATE OF FLORIDA
+For Palm Beach County, at the Spring Term thereof, in the year of our Lord Two Thousand and Six, to-wit:
+The Grand Jurors of the State of Florida, inquiring in and for the body of said County of Palm Beach, upon their
+oaths do present that JEFFREY E. EPSTEIN in the County of Palm Beach aforesaid, in the Circuit and State
+aforesaid,
+COUNT ONE
+FELONY SOLICITATION OF PROSTITUTION
+on or about or between the 1st day of August in the year of our Lord Two Thousand and Four and October 31,
+2005, did solicit, induce, entice, or procure another to commit prostitution lewdness, or assignation, contrary to
+Florida Statute 796.07(1) on three or more occasions between August 01, 2004 and October 31, 2005,
+contrary to Florida Statute 796.07(2)(f) and (4)(c). (3 DEG FEL)(LEVEL 1)
+against the form of the statute, to the evil example of all others, and against the peace and dignity of the State
+of Florida.
+I hereby certify that I have advised the Grand Jury returning this indictment as authorized and required by law.
+quelle
+- Assistant State Attorney of the
+Fifteenth Judicial Circuit of the State
+of Florida, prosecuting for the said
+State
+GRAND JURY FOREPERSON
+DATE
+Jeffrey E. Epstein, Race:
+EXHIB ""
+Sex: Male, DOB: January 20, 1953, SS#: 090-44-3348; Issue Warrant
diff --git a/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.receipt.json b/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fb03aad978e63d0ede62aaa4900a3a28cab8dcb9
--- /dev/null
+++ b/vision-fixhub/court-01/fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "fd4a1c158d81601fc49676f2c2929fa96a639cd227d95c027f16d93cf4c8a274",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3bf37c01f371675a847c4e89a65e06394f1303492d159fe4e28ddc493b9537d8",
+  "output_sha256": "7030df422593a5533e73a85cb919fe0fc3003b36505cef2b1f37dc39965c1317",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fd4dc6b64b4d7b88cc2df52cfeeef93d7c76e86506bc2da98fb08f2b24770d7e.md b/vision-fixhub/court-01/fd4dc6b64b4d7b88cc2df52cfeeef93d7c76e86506bc2da98fb08f2b24770d7e.md
new file mode 100644
index 0000000000000000000000000000000000000000..6d8b69c403abf40ec285e89663f96bac1f9525dc
--- /dev/null
+++ b/vision-fixhub/court-01/fd4dc6b64b4d7b88cc2df52cfeeef93d7c76e86506bc2da98fb08f2b24770d7e.md
@@ -0,0 +1,386 @@
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 1 of 15
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+JANE DOE #1 AND JANE DOE #2'S MOTION FOR ORDER DIRECTING THE U.S.
+ATTORNEY'S OFFICE NOT TO WITHHOLD RELEVANT EVIDENCE
+COME NOW Jane Doe #1 and Jane Doe #2 (also referred to as "the victims"), by and
+through undersigned counsel, to move for an order from this Court directing the U.S. Attorney's
+Office not to suppress material evidence relevant to this case. The Court should enter an order,
+as it would in other criminal or civil cases, requiring the Government to make appropriate
+production of such evidence to the victims.
+BACKGROUND
+In discussions with the U.S. Attorney's Office about this case, counsel for Jane Doe #1
+and Jane Doe #2 inquired about whether the Office would voluntarily provide to the victims
+information in its possession that was material and favorable to the victims' case. Victims'
+counsel pointed out that, if they were criminal defense attorneys representing criminals, the
+Office would promptly turn over all information in its possession that was helpful to these
+criminals under Brady v. Maryland, 373 U.S. 83 (1963), and related decisions. Victims' counsel
+asked the Office to extend to the victims the same assistance that it would provide to criminal
+1
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 2 of 15
+defendants - i.e., to voluntarily provide to the victims information in its possession that was
+favorable to the victims' CVRA case.
+In response, victims" counsel were informed by the Office that it could - and would --
+withhold from the victims such information, apparently on the theory that the CVRA does not
+apply to these case or on the theory victims lack due process rights under the CVRA. The
+victims accordingly have been forced to file this motion, seeking an order from the Court
+directing the U.S. Attorney's Office to produce to the victims favorable information.
+The victims are entitled to such information for four separate reasons. First, the U.S.
+Attorney's Office is statutorily-obligated to use it "best efforts to see that crime victims are ...
+accorded|] the rights described in [the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added). The
+Office flouts this best efforts obligation when it deliberately withholds favorable information
+from the victims.
+Second, just as criminal defendants are entitled to receive favorable information in the
+Government's possession under due process rights, see, e.g., Brady v. Maryland, 373 U.S. 83
+(1963), victims are entitled to receive favorable information under their CVRA "right to be
+treated with fairness," 18 U.S.C. § 3771(a)(8) - a right that clearly includes due process
+considerations. The U.S. Attorney's Office is not treating the victims with fairness if it
+withholds the very information that might enable them to prove their case.
+Third, the U.S. Attorney's Office has obligations under the civil discovery rules to
+voluntarily provide information to the victims. See Fed. R. Civ. P. 26(a)(1) (initial disclosures in
+civil cases). The victims" action has been opened as a civil case, and the U.S. Attorney's Office
+has previously argued that it should be treated as a civil case. Proceeding on this basis, the
+2
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 3 of 15
+ordinary civil discovery rules apply and the U.S. Attorney's Office should disclose relevant
+documents "without awaiting a discovery request." Fed. R. Civ. P. 26(a)(1)(A).
+Finally, a decision by the U.S. Attorney's Office to withhold information relevant to this
+case has serious ethical ramifications. The attorneys have a duty of candor to the Court. It is not
+immediately clear how the U.S. Attorney's Office can satisfy those obligations while concealing
+information that might enable the victims to prove their case.
+For all these reasons, the Court should enter an order directing the U.S. Attorney's Office
+to produce to the victims all information in its possession favorable to the victims. A proposed
+order to that effect is attached to this pleading, largely tracking the standard discovery order that
+this Court routinely enters in criminal cases.
+DISCUSSION
+THE GOVERNMENT VIOLATES ITS "BEST EFFORTS" OBLIGATIONS IF IT
+WITHOLDS EVIDENCE FAVORABLE TO THE VICTIMS.
+The U.S. Attorney's Office is obliged to produce favorable information to the victims
+because of the CVRA's requirement that prosecutor use their "best efforts" to protect crime
+victims' rights. The CVRA directs that "loJfficers and employees of the Department of Justice
+and other departments and agencies of the United States engaged in the detection, investigation,
+or prosecution of crime shall make their best efforts to see that crime victims are notified of, and
+accorded, the rights described in [the CVRA]." 18 U.S.C. § 3771(c)(1) (emphasis added). It is
+hard to understand how the Government can argue with a straight face that it is using its "best
+efforts" to protect victims' rights while simultaneously withholding readily-identifiable
+documents from the victims that might allow them to protect those very rights. If a best efforts
+3
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 4 of 15
+obligation means anything, it must mean that the U.S. Attorney's Office cannot suppress
+favorable information.
+This understanding of the best efforts obligation is confirmed by the plain meaning of the
+phrase "best efforts." That phrase is generally understood as requiring "[djiligent attempts to
+carry out an obligation." BLACK'S LAW DICTIONARY 169 (8" ed. 2004). See generally E.
+Farnsworth, On Trying to Keep One's Promises: The Duty of Best Efforts in Contract Law, 46 U.
+PIT. L. Rev. 1, 8 (1984). As a result, "[blest efforts are measured by the measures that a
+reasonable person in the same circumstances and of the same nature as the acting party would
+take." BLACK'S LAW DICTIONARY 169 (8'" ed. 2004). A reasonable prosecutor who is obligated
+to work to "accord" crime victims their rights, 18 U.S.C. § 3771(c)(1), would not simultaneously
+deny victims access to the very evidence that could help them protect their rights. Put another
+way, an obligation to use "best efforts" is usually understood "in the natural sense of the words
+as requiring that the party puts its muscles to work to perform with full energy and fairness the
+relevant express promises and reasonable implications therefrom." Stabile v. Stabile, 774 N.E.2d
+673, 676 (Mass. App. Ct. 2002). Here, far from putting its full energies towards protecting
+victims' their rights, the U.S. Attorney's Office is devoting its energies to blocking those rights.
+The cases construing "best efforts" language have routinely recognized that this language can
+create affirmative obligations to act. See, e.g., Hughes Communications Galaxy, Inc. v. United
+States, 26 CI. Ct. 123, 135 (1992) ("A best efforts clause ... can also affirmatively obligate.").
+Here, the action that is affirmatively required by the U.S. Attorney's Office is to produce readilyidentifiable information that will assist the victims.
+4
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 5 of 15
+It is also important to recognize that the victims here are not seeking to force some kind
+of burdensome
+goose chase on the U.S. Attorney's Office. In their letter to the U.S.
+Attorney requesting relevant evidence, the victims offered to provide a list of specific items they
+were seeking: "To avoid burdening your Office, we would be happy to provide a specific list of
+the information that we believe is material to the victims' CVRA case - a limited amount of
+information that could be swiftly located by your Office." Letter from
+J.
+&
+Paul G. Cassell to Wifredo A. Ferrer, Mar. 1, 2011. The victims have, for example, requested
+that the U.S. Attorney's Office provide to them unredacted copies of correspondence between
+the U.S. Attorney's Office and Jeffrey Epstein. Through civil discovery from Epstein, the
+victims have obtained half of that correspondence - the words written by the U.S. Attorney's
+Office - but are lacking the other half - the words written in reply by Epstein's counsel. This
+correspondence specifically discusses crime victims' rights, so it is obviously quite material to
+the victims' case. The U.S. Attorney's Office could obviously provide this information without
+much difficulty. But instead, the Office has refused to provide to the victims any of the
+correspondence - or, indeed, any other similar information that might assist the victims.
+For all these reasons, the Court should find that the Department's "best efforts"
+obligations require it to produce to the victims information favorable to the victims' case.
+II.
+THE VICTIMS HAVE A DUE PROCESS RIGHT TO ACCESS TO FAVORABLE
+EVIDENCE UNDER THEIR CVRA "RIGHT TO BE TREATED WITH
+FAIRNESS."
+The victims are also entitled to receive favorable evidence in the Government's
+possession for the same reason that criminal defendants receive such information: fundamental
+considerations of fairness require that the Government not deliberately withhold relevant
+5
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 6 of 15
+information contrary to its position in court. For criminal defendants, this principle traces back
+to the landmark decision of Brady v. Maryland, 373 U.S. 83, 87 (1963), in which the Court
+explained the production of exculpatory evidence is a principle designed for
+avoidance of an unfair trial to the accused. Society wins not only when the guilty
+are convicted but when criminal trials are fair; our system of the administration of
+justice suffers when any accused is treated unfairly. An inscription on the walls of
+the Department of Justice states the proposition candidly for the federal domain:
+"The United States wins its point whenever justice is done its citizens in the
+courts." A prosecutor that withholds evidence on demand of an accused which, if
+made available would tend to exculpate him or reduce the penalty helps shape a
+trial that bears heavily on the defendant. That casts the prosecutor in the role of an
+architect of a proceeding that does not comport with standards of justice....
+Id. at 87-88. Of course, precisely the same points can be made here about production of
+evidence to crime victims. The Justice Department will "win its point if justice is done" to crime
+victims in this case - but justice can be done only if these proceedings are fair, in the sense that
+all relevant information is provided to the court. To have this case move forward with the
+prosecutors withholding material information is to truly cast them "in the role of an architect of a
+proceeding that does not comport with standards of justice."
+To be sure, the victims in this case do not rely on a federal constitutional right to due
+process. But they have a parallel statutory right under the CVRA, which promises victims of
+crime that they will be "treated with fairness." 18 U.S.C. § 3771(a)(8). The clear intent of
+Congress in passing this provision was to provide a substantive "due process" right to crime
+victims. As one of the CVRA's co-sponsors (Senator Kyl) explained, "The broad rights
+articulated in this section [$ 3771(a)(8)] are meant to be rights themselves and are not intended to
+just be aspirational. One of these rights is the right to be treated with fairness. Of course,
+fairness includes the notion of due process. Too often victims of crime experience a secondary
+6
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 7 of 15
+victimization at the hands of the criminal justice system. This provision is intended to direct
+Government agencies and employees, whether they are in executive or judiciary branches, to
+treat victims of crime with the respect they deserve." 150 CoNG. REC. S4269 (Apr. 22, 2004)
+(emphasis added).
+Because the CVRA extends a "due process" right to crime victims like Jane Doe #1 and
+Jane Doe #2, victims have a right to fair access to evidence to prove their case. The very
+foundation of the Brady obligation is such a notion of due process: "IT]he suppression by the
+prosecution of evidence favorable to an accused ... violates due process where the evidence is
+material either to guilt or to punishment." Brady v. Maryland, 373 U.S. 83, 87 (1963). It would
+similarly violate due process - and thus not treat victims with "fairness" -- for the prosecution to
+suppress evidence favorable to a crime victim where the evidence is material either to proving a
+CVRA violation or to the remedy for a violation.
+The Brady principles are well understood, and the Government does not have difficulty in
+providing favorable information to criminal defendants. For example, it is our understanding
+that such discovery was provided by the government to Jeffrey Epstein during the course of
+negotiations that led to the non-prosecution agreement in this case. If the Government's
+obligations to see "that justice is done," Brady, 373 U.S. at 87, requires it to produce helpful
+information to a sex offender, surely principles of fairness require the same kind of production to
+the sex offender's victims when they are properly pursuing a contested case against the
+Government before this Court.
+The familiar Brady principles are so commonplace that this Court routinely enters a
+"Standing Discovery Order" in criminal cases directing the Government to provide favorable
+7
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 8 of 15
+evidence to the defendant. The Order typically provides: "The government shall reveal to the
+defendants) and permit inspection and copying of all information and material known to the
+government which may be favorable to the defendant on the issues of guilty or punishment
+within the scope of Brady v. Maryland, 373 U.S. 83 (1963), and United States v. Agurs, 427 U.S.
+97 (1976)." See, e.g., Standing Discovery Order, United States v. Enriquez, No. 1:10-CR-20488-
+MGC (July 9, 2010) (doc. #115). These Standing Discovery Orders follow from identical
+language in the local rule on these issues. See Local Rule 88.10.
+Interesting, the Standing Discovery Order - and associated local rule 88.10(O) - contains
+a broad, commonsense provision which the Government has plainly violated in this case. The
+Order provides: "The parties shall make every possible effort in good faith to stipulate to all facts
+or points of law the truth or existence of which is not contested and the early resolution of which
+will expedite the trial." For more than two-and-a-half years, the victims have been trying to get
+the Government to stipulate to undisputed facts, precisely as the Court's rules envision. The
+Government, however, has refused to do so.
+It is a simple matter to tailor the Standing Discovery Order from a situation involving a
+criminal defendant's need for information to the current situation of a crime victim's need for
+information. A proposed order to that effect is attached to this pleading, largely tracking the
+language of the Standing Discovery Order. The Court should enter that order. The Court has its
+own obligations to ensure that victims' rights are protected. The CVRA directs that "li]n any
+court proceeding involving an offense against a crime victim, the court shall ensure that the
+crime victim is afforded the rights [described in the CVRA]" - rights that include a right to "be
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 9 of 15
+treated with fairness." See 18 U.S.C. § 3771(b)(I), (a)(8). The Court should ensure fair
+treatment for the victims by directing the Government to produce relevant evidence.
+Ill.
+THE VICTIMS ARE ENTITLED TO DISCLOSURE UNDER THE FEDERAL
+RULES OF CIVIL PROCEDURE.
+The victims are further entitled to receive information favorable to them under the rules
+civil procedure. The victims' petition seeking to set aside the non-prosecution agreement has
+been opened as a civil case - as reflected in the case number the matter has borne for the last
+two-and-a-half years: 9:08-CV-80736-Marra/
+Indeed, the Government has seized on
+this point to deny the victims rights that they would otherwise enjoy in a criminal case. For
+example, on October 27, 2010, the U.S. Attorney's Office advised Jane Doe #1 and Jane Doe #2
+that the Office was taking the position that they did not enjoy a right "to confer" with the Office
+under the CVRA, 18 U.S.C. § 3771(a)(5), in this enforcement action because the action was
+"civil" litigation rather than criminal litigation. See Doc. #41 at 1-2.
+If the U.S. Attorney's Office is correct that this matter is "civil" litigation, then the
+Federal Rules of Civil Procedure govern discovery. See Fed. R. Civ. P. 1 ("These rules govern
+the procedure in all civil actions and proceeding in the United States district courts....").'
+Under those Rules, generous discovery is provided. Of particular relevance to this motion is the
+requirement under Fed. R. Civ. P. 26(a)(I)(A) that parties are automatically required produce
+relevant information to a case without waiting for a discovery request.
+In light of the
+Government's position that this case is civil litigation, the victims have been making (and are
+'Rule 1 note that there are certain limitations to application of the Civil Rules, found in
+Fed. R. Civ. P. 81. None of the limitations in Rule 81 (e.g., for bankruptcy and citizenship
+proceedings) apply in this case.
+9
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 10 of 15
+continuing to make) initial disclosures consistent with Rule 26(a)(1)(A). But the U.S. Attorney's
+Office has recently informed the victims that they do not believe that this Rule applies to their
+case and that they will not be making any such disclosures. Accordingly, the victims seek an
+order from the Court requiring the ordinary kinds of document production that are made in civil
+cases.
+To order the Government to make such production, the Court need not engage in
+metaphysical ruminations about whether this CVRA enforcement action is ultimately a "civil"
+case or a "criminal" case.
+For purposes of this motion, it is enough to say that the Government
+has taken the position that it is a civil action and therefore the Government must at least carry
+through on the discovery obligations that attend civil cases.
+Moreover, Congress clearly allowed the filing of this action in this Court. See 18 U.S.C.
+§ 3771(d)(3) (allowing assertion of CVRA rights "in the district court in which a defendant is
+being prosecuted or, if no prosecution is underway, in the district court in the district in which
+the crime occurred."). Congress did not specify whether such actions would be civil or criminal
+in nature. But Congress no doubt envisioned at least a minimum level of cooperation with
+victims by the Government. Congress, in fact, mandated prosecutors to make their "best efforts"
+to afford victims their rights. In a case such as this one where there is a dispute about the factual
+events surrounding, it makes sense to read the CVRA has at least giving victims access to
+information that might prove their case rather than permitting the Government to suppress such
+evidence. The Court should accordingly require the Government to make the disclosures that it
+would ordinarily make in a civil case. The proposed order attached to this pleading includes a
+provision to that effect.
+10
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 11 of 15
+IV.
+ALLOWING THE GOVERNMENT TO WITHHOLD RELEVANT EVIDENCE
+WOULD RAISE SERIOUS ETHICAL ISSUES.
+On a final note, it is worth considering the ethical ramifications of the Government's
+stark position that it can withhold even relevant and material evidence from the victims in this
+case. Prosecutors, no less than other attorneys, have duties of candor to the Court that would not
+permit them to present evidence or testimony to the Court that is known to be false. Fla. Bar
+Rule 4-3.3(a)(4). Allowing the victims access to evidence favorable to their claim will insure
+compliance with this rule. Similarly, in an ex parte proceeding, a lawyer must inform the court
+of all material facts known to the lawyer that will enable the court to make an informed decision
+"whether or not the facts are adverse." Fla. Bar. Rule 4-3.3(d). If the U.S. Attorney's Office is
+correct that the victims are not entitled to access to favorable evidence, then the proceedings
+involving that evidence are essentially ex parte - requiring the Office to make disclosures to the
+Court with notice to the victims.
+An illustration of this problem comes from the sworn declaration filed by one of the
+AUSA's in this case in support of the Government's response to the victims' petition. This
+sworn affidavit recounts a provision in the non-prosecution agreement that would have placed
+victims of Epstein's sexual abuse in "the same position as they would have been had Mr. Epstein
+been convicted at trial." Declaration of
+Villafana, July 9, 2008 (doc. #14) at 3-4. The
+affidavit also goes on to say that "these provisions were discussed," id. at 4, apparently referring
+to this provision. Id. (noting that "as explained above" there was a remedy for crime victims).
+And the declaration notes that on July 9, 2008, the victims in this case (including Jane Doe #1)
+were notified about the existence of this provision.
+11
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 12 of 15
+On October 9, 2008, victims' counsel wrote to government counsel, pointing out that this
+declaration appeared to be (albeit inadvertently) false in two important respects. First, the quoted
+provision was not actually in the non-prosecution agreement. And second, if it was discussed
+with Jane Doe #1, for example, then that would have created false impression. Victims' counsel
+asked for a clarification to be filed with the Court about these two points. See Exhibit "A."
+In response, on December 22, 2008, the government filed a supplemental declaration.
+Doc. #35. The corrective supplemental declaration addressed the first point, agreeing that the
+information was false. The supplemental declaration, however, did not address the second
+question of whether this false information had previously been discussed with the crime victims.
+Moreover, the supplemental declaration raised additional question about Epstein's role in the
+false information. The supplemental declaration states the Epstein's attorney's approved the
+transmission of false information to the victims on and about July 9, 2008. Doc. #35 at 2. But
+none of the underlying information regarding the approval of that false information is included in
+the supplemental declaration.
+Rather than have the government serving as the exclusive conduit for information to the
+Court about these subjects, it seem more consistent with the spirit of the ethical rules - and with
+the general obligations of disclosure discussed previously in this pleading - for the Government
+to make available to the victims all material and favorable information. For example, the
+Government could provide to the victim the underlying correspondence with Epstein's attorneys
+approving the transmission of this false information. This information will be highly relevant to
+the victims' position that the non-prosecution agreement should be set aside in view of violations
+12
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 13 of 15
+of the victims' rights.
+The Court should accordingly order production of this and other similar
+favorable evidence to the victims.
+CERTIFICATE OF CONFERENCE
+As recounted above, counsel for Jane Doe #1 and Jane Doe #2 have repeatedly requested
+that the U.S. Attorney's Office voluntarily stipulate to undisputed facts in this case and provide
+material information favorable to the victims case for more than two and a half years. The U.S.
+Attorney's Office, however, takes the position that the victims are not entitled to any such
+information.
+CONCLUSION
+For all the foregoing reasons, the Court should order the U.S. Attorney's Office to
+produce information favorable to the victims. A proposed order to that effect is attached.
+DATED: March 21, 2011
+Respectfully Submitted,
+S/
+J.
+JAFFE, WEISSING,
+,. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+elephone (954) 524-282
+acsimile (954) 524-282
+Florida Bar No.: 542075
+E-mail: brad@pathtojustice.com
+and
+13
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 14 of 15
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+14
+
+
+Case 9:08-cv-80736-KAM Document 50 Entered on FLSD Docket 03/21/2011 Page 15 of 15
+CERTIFICATE OF SERVICE
+The foregoing document was served on March 21, 2011, on the following using the Court's
+CM/ECF system:
+A.
+Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave.., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail:
+Attorney for the Government
+L. Ackerman, Jr.
+Ackerman, Jr.
+Burnett PA
+777 S. Flagler Drive, West Tower, Suite 901
+West Palm Beach, FL 33401
+Criminal Defense Counsel for Jeffrey Epstein
+(courtesy copy of pleading via U.S. mail)
+15
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diff --git a/vision-fixhub/court-01/fd7415cc6c25880532355fefe1a5ae77482dae185f11e6267ed75c17ba296d2b.md b/vision-fixhub/court-01/fd7415cc6c25880532355fefe1a5ae77482dae185f11e6267ed75c17ba296d2b.md
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@@ -0,0 +1,15 @@
+Case 9:08-cv-80736-KAM Document 183-1
+Entered on FLSD Docket 03/14/2013 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+[PROPOSED] ORDER COMPELLING PRODUCTION OF DISCOVERY
+As directed in the Court's order of September 26, 2011 (DE 99 at 11), the Government shall
+provide answers to the document requests and requests for admissions propounded by the
+victims in this matter. The Government shall provide such answers within two weeks of the date
+of this order.
+Date:
+UNITED STATES DISTRICT JUDGE
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fd7e26781b741ea0b0197b7b78872dfec4bad374a61599d5488f6b26238688e2.md b/vision-fixhub/court-01/fd7e26781b741ea0b0197b7b78872dfec4bad374a61599d5488f6b26238688e2.md
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@@ -0,0 +1,203 @@
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 1 of 7
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRAJ
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+1
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 2 of 7
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRAJ
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRAJ
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA/
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA/
+2
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 3 of 7
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+CASE NO.: 08- CV-80591-MARRA/
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+CASE NO.: 08- CV-80656-MARRA1
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+PLAINTIFFS JANE DOES' 2- 7 NOTICE OF JOINDER IN PLAINTIFFS'
+JANE DOES 101 AND 102'S MOTION FOR NO-CONTACT ORDER
+Plaintiffs Jane Does 2-7 join in Plaintiffs Jane Does 101 and 102's Motion for No-
+Contact Order, filed May 22, 2009, and state as follows:
+Plaintiffs Jane Does 2-7 incorporate and adopt the facts set forth in the pending
+Motion for No-Contact Order. Additionally, Plaintiffs offer additional facts in support of the
+Motion for a No-Contact Order, as set forth below.
+2.
+Upon information and belief, Plaintiffs Jane Does 2-7 were all identified on the
+victims list provided to Defendant Epstein's counsel in connection with the Non-prosecution
+Agreement, and each has been identified as victims to Defendant Epstein in their pending
+3
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 4 of 7
+actions. In June 2008, Palm Beach Circuit Court Judge Pucillo ordered Defendant Epstein "not
+to have any contact, direct or indirect," with any of his victims. Judge Pucillo clarified that
+forbidden "indirect" contact included, but was not limited to, text messages, emails, telephone
+calls, or messages through third parties. As detailed herein, Jane Does 4 and 7 have been
+contacted on multiple occasions by at least one person representing that she is cooperating with
+and communicating on behalf of Defendant Epstein. In these contacts, the Plaintiffs/victims
+were threatened and harassed.
+3.
+As with other Plaintiffs, Jane Does 4 and 7 were first introduced to Defendant
+Epstein by Hayley
+, who was a high school friend.'
+4.
+had had contact with these Plaintiffs on several occasions in which she
+represented to Plaintiffs Jane Doe 4 and 7 that she is cooperating with Defendant Epstein's
+attorneys and that she is being financially supported by Defendant Epstein. Moreover,
+has told these Plaintiffs specifically that she is communicating on behalf of Defendant Epstein.
+5.
+During these contacts,
+made disparaging comments to the Plaintiffs and
+also sent disturbing text messages to Jane Doe No. 4. In one text,
+specifically stated, "I
+just met with my lawyer today and I'm finally done with the Epstein case. LOL. I knew you were
+suing Jeffrey all along and I've learned so much about you in the meantime. LOL." Jane Doe 4
+understood this to mean that
+had exchanged private information about Jane Doe 4 with
+Defendant Epstein and his attorneys. Since February, 2009, Jane Doe 4 has continued to receive
+text messages from
+that are sometimes harassing and other times seek information about
+Jane Doe 4's private life, her lawsuit against Defendant Epstein, and/or her lawyer's strategy.
+was
+named in at least one civil case against Mr. Epstein as a co-defendant. See
+Jane Doe v. Epstein, case no. 50-2008-CA-0065996, Palm Beach County Circuit Court.
+brought multiple underage girls to Epstein in addition to Jane Does 4 and 7.
+4
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 5 of 7
+6.
+On one occasion,
+approached Jane Doe 7 and disclosed that she was
+cooperating with Defendant Epstein's defense, and that she (
+agreed that she would
+testify against Jane Doe 7 and the other plaintiffs to make sure that none of the Plaintiffs ever
+received any money from Defendant Epstein, making clear that her testimony would not be
+truthful to achieve this end. She also made disparaging comments to Jane Doe 7, accusing her of
+ruining Defendant Epstein's reputation.
+7.
+The very possibility of any contact with Epstein or his agents, including |
+causes anxiety and distress particularly to Jane Doe 4 and 7, as well as the other Plaintiffs. A nocontact order should prevent further harassment of the Plaintiffs by Epstein and his agents,
+including, but not limited to, Hayley
+WHEREFORE, Plaintiffs Jane Does 2-7, respectfully join Plaintiffs Jane Does 101 and
+102 in moving this Court to enter an order granting Plaintiffs' Motion for a No Contact Order
+prohibiting the Defendant, Jeffrey Epstein, from any contact or communication with Plaintiffs,
+either directly or indirectly, except through Plaintiffs' attorneys of record for the duration of the
+Order.
+Dated: June 8, 2009
+Respectfully submitted,
+By:_
+_s/ Adam D. Horowitz.
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+5
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 6 of 7
+CERTIFICATE OF SERVICE
+THEREBY CERTIFY that on June 8, 2009, I electronically filed the foregoing document
+with the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day to all parties on the attached Service List in the manner specified, either via
+transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized
+manner for those parties who are not authorized to receive electronically Notices of Electronic
+Filing.
+Is/ Adam D. Horowitz
+6
+
+
+Case 9:08-cv-80381-KAM Document 115 Entered on FLSD Docket 06/08/2009 Page 7 of 7
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+/s/ Adam D. Horowitz
+7
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new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "de744b6ebac4f13f3e9ad5899b947ff9f757be707e6fab472b648551676b3e3f",
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diff --git a/vision-fixhub/court-01/fd8c7616bc08d640adf0aafbd92368212295dde318d879647f8187a88161eb25.md b/vision-fixhub/court-01/fd8c7616bc08d640adf0aafbd92368212295dde318d879647f8187a88161eb25.md
new file mode 100644
index 0000000000000000000000000000000000000000..5e9a886a6dd2df8a0db7b896b0655b5636328881
--- /dev/null
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@@ -0,0 +1,1105 @@
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 1 of 23
+professional publications include books and peer-reviewed medical journal articles on mass
+disasters, most recently concerning the Attack on America.
+He was extensively interviewed in 1997 by CBS Dallas TV regarding psychiatric testimony
+concerning eleven altar boys, testimony which had resulted in a record-making jury verdict
+against the Archdiocese of Dallas. In April, 1998, Dr. Kliman was interviewed by Channel Four
+anchorwoman, Linda
+i, concerning his Salvation Army project providing the Cornerstone
+form of psychoanalytic psychotherapy for homeless preschoolers and toddlers,. The Cornerstone
+project itself was viewed on the Channel II Five O'Clock News. KGO TV interviewed Dr.
+Kliman concerning a forensic testimony, with a focus on a Stanford football player who had
+allegedly become a child molester. During the Lewinsky-Clinton matter, Kliman was
+interviewed by Channel 12/20 concerning psychoanalytic views of leaders having exceptional
+sexual access to partners and the risk of a position of power overcoming the judgments of such
+leaders. During 2001 following the World Trade Building terrorism, Dr. Kliman was
+interviewed by Channel II News and appeared on five occasions thereafter through 2003
+concerning the Afghanistan and Iraq wars. In May 2003, he was discussant with U.N. Secretary
+General Olaru Otonu, featured on Dhubai Business TV concerning the plight of children in war.
+In 2004, together with the International Psychoanalytic Association, Dr. Kliman helped organize,
+establish
+and supervise a therapeutic preschool project in Buenos Aires.
+"Cornerstone
+Argentina" is now in its second year of treating severely disturbed and impoverished
+preschoolers, with his continuing collaboration.
+Following the hurricane disasters of 2005 he collaborated with Mercy Corps and the Children's
+Psychological Health Center to produce a mental health resource. The result, "My Katrina and
+Rita Story", a guided activity resource of families who had to deal with the hurricanes. Mercy
+Corps is distributing copies to 20,000 families.
+In 2005, RE DISTURBED PRESCHOOLERS Dr. Kliman helped organize. establish and
+supervise a therapeutic project in Piedmont California, at the nonprofit Ann
+Center.
+In 2007, RE HOMELESS CHILDREN: Dr. Kliman helped establish a Reflective Network
+Therapy service for homeless preschoolers in Seattle. He provided four days of training in that
+method for the Family Service Center of
+• County (located in Seattle), and created an
+organizational link between The Family Services Center and The Children's Psychological
+Health Center, Inc. of San Francisco in order to continue serving homeless children in Seattle.
+In 2008, Dr. Kliman activated the Reflective Network Therapy services for preschoolers in
+Seattle. He supervises there in person and by phone and video.
+In 2008, RE DISASTER SERVICES: Following the Sichuan Earthquake Disaster of May 12,
+2008, Dr. Kliman established a link between Children's Psychological Health Center, Inc.
+Mercy Corps, and The China America Psychoanalytic Alliance. He created mental health
+resources (see Publications) which were licensed for mass distribution in China by Mercy Corps.
+In 2008, Dr. Kliman helped found a new non-profit organization called Teach with Africa and is
+a member of its Board of Directors.
+2
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 2 of 23
+PROFESSIONAL POSITIONS:
+Medical Director: The Children's Psychological Health Center, Inc. (a non-profit agency), San
+Francisco, 1993- Responsible for standards of research. clinical treatment, clinical supervision,
+staff training and forensic evaluations - reporting directly to the Board of Directors. Psychiatrie
+Consultant: Ann
+Center, Piedmont, CA. Psychiatric Consultant:
+• County Family
+Services, Seattle, WA. Private Practice: Medical Director, The Psychological Trauma Center,
+(a division of Preventive Psychiatry Associates, Medical Group, Inc.), San Francisco, 1989-.
+Chief Psychiatric Consultant, Children's Garden, San Rafael, CA, 1990-1991. (Children's
+Garden is a residential
+i care facility, consisting of group care cottages and a school.)
+Director, Preventive Psychiatry Services and Unit for Study of Mass Violence and Genocide, St.
+Mary's Hospital, San Francisco, CA 1987-1989. Private practice of Psychiatry and
+Psychoanalysis (Adult, Child, and Adolescent), San Francisco, CA, 1985-. Director and
+Principal Investigator,
+Care Study Unit, Columbia University, College of Physicians and
+Surgeons, New York, N.Y., 1984-87. Associate Clinical Professor, Columbia University,
+Department of Child Psychiatry, New York, N.Y., 1985-87. Founder, Editor-in-Chief, the
+Journal of Preventive Psychiatry, New York, N.Y., 1980-. Principal Investigator, NIMH
+project ("Preventive Mental Health Services for Children Entering
+¡ Care"), The Center for
+Preventive Psychiatry,
+| Plains, N.Y., 1979-1985. Consultant, Children's Television
+Workshop, New York 1976. Assistant Clinical Professor, Mount Sinai Medical School,
+Department of Psychiatry, New York, N.Y., 1969-70. Director, Preventive Psychiatry Service,
+Elmhurst General Hospital, Queens, N. Y.,1969-70
+GRANTS AWARDED:
+Grants have been received as Principal Investigator for research and service in preventive
+psychiatry from: The Aaron Norman Foundation, American Chai Trust,
+Barrie
+Foundation, Bydale Foundation, Cheesborough Pond's Inc., Ciba-Giegy Corporation, Julius H. &
+Bessie R. Cohn Foundation, David and Ruth Kosh Foundation, James
+Foundation,
+Estate of Florence Mascias, Birny Mason Foundation, The Charles and Emma Goldmann
+Foundation, The Haas Foundation, The Savin Corporation, The Harris Foundation, The Abelard
+Foundation, AMF Corporation, CNA Financial Corporation, D. & R. Gottesman Foundation,
+Stella & Charles Guttman Foundation, Longhill Charities, Virginia & Leonard Marx Foundation,
+The Klingenstein Foundation, The Lavanburg-Corner House Foundation, Herman Muehlstein
+Foundation, Nestle Corporation, Louise Ottinger Charitable Trust, Pettus Crowe Foundation,
+Edward & Ellen Roche Relief Foundation, Samuel Rubin Foundation, Savin Business Machines
+Corp., S. & H. Scheuer Foundation,
+Tannenbaum Foundation.
+Grants have been received as Principal Investigator for a project to develop nonmedical training
+in Early Childhood Psychotherapy from: The Cleveland Foundation, The Van Ameringen
+Foundation. A grant was received for equipment for preschool therapeutic services, from: The
+Hecksher Foundation. Grants have been received as Principal Investigator for Research in the
+Etiology of Early Childhood Psychosis from: The Bochm Foundation. Grants have been received
+as Principal Investigator for Research in Assessment of Preventive Clinical Interventions with
+Children Entering |
+Family Care, from: The National Institute of Mental Health (Grant #
+RO1 MH 27944), and The Harris Foundation. Grants received as Principal Investigator, The
+Columbia University
+I Care Study Unit, for development of preventive interventions with
+children, from the following foundations: The Daniel and Florence Guggenheim
+3
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 3 of 23
+Foundation, The Dreyfus Foundation, The Seth Sprague Foundation, The Gralnick Foundation,
+The Harris Foundation, U.S. Trust, and The Scheuer Family Foundation.
+Most recent grants.
+1996-2002: Support from The Office of Education, Division of Special Education, San Mateo
+County, California.
+1996 The Windholz Foundation, San Francisco, for video documentation of an experimental
+project concerning treatment of disturbed and traumatized preschool patients in a public
+education special education division.
+1999 Morris Stulsaft Foundation for video-recording facility to document treatment in The
+Cornerstone Therapeutic School.
+1999-2001 The Cadence Corporation - for early childhood treatment services
+2000-2001 The Harris Foundation for Cornerstone Therapeutic School.
+2000 Funding and Recognition by the State of California: In 2001, The Department of
+Education, Division of Special Education, certified the Cornerstone Therapeutic School as a
+nonpublic special education school, allowing public entities to fund the school by contracts with
+Unified School Districts.
+2001 The San Francisco Day Care Corporation - for Cornerstone Therapeutic School.
+2001 The Sophie Murvis Foundation for Training of Teachers and Therapists in the Cornerstone
+Method.
+2002, 2003. The Five
+Preschool 2003.
+Foundation for development of The Cornerstone Therapeutic
+2005 The Sophie Murvis Foundation grant for Training of Teachers and Therapists in the
+Cornerstone Method.
+2005 Mercy Corps for creation of "My Personal Story about Hurricanes Katrina and Rita"
+2008 Mercy Corps for creation of "My Sichuan Earthquake Story"
+JANUSZ KORCZAK INTERNATIONAL LITERARY PRIZE:
+Albert Rosenfeld, co-authors of Responsible Parenthood, published by Holt, Rinchart and
+Winston, New York, 1980
+PUBLISHED PAPERS AND BOOKS:
+4
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 4 of 23
+01. "Adrenal Medullary Function," in G.
+Yearbook of Endocrinology, Yearbook
+Publishers, 1955.
+02. Improved Visual Recognition in Hypnotic Versus Control State," Archives of General
+Psychiatry, Vol. 7:155-162, October 1962.
+03. Children and the Death of a President, Editor and Contributor (with Martha
+Wolfenstein, Ph.D.), Doubleday & Company, New York, 1965.
+04. Oedipal Themes in Children's Reactions to the Assassination of President Kennedy,"
+in Wolfenstein and Kliman, Children and the Death of a President, Doubleday, New
+York, 1965.
+05. "The Role of Stimulus Ambiguity in Hypnotic Recognition," (with Eugene Goldberg,
+M.D.), Arch. Gen. Psychiat. 14: 100, Jan. 1966.
+06. "Sharing Truths for Mental Health," in Mental Health in Our Daily Life. Mental
+Health Association,
+Plains. New York, 1966.
+07. "A Psychoanalyst Looks at
+Violence as a Factor in Black Violence," The
+Center for Preventive Psychiatry, 1968.
+08. Teacher Recognition of Psychiatric Needs Among Preschoolers," The Center for
+Preventive Psychiatry, 1968.
+09. Psychological Emergencies of Childhood. Grune and
+New York, 1968.
+10.
+"A Psychiatrist Speaks Out: 3,000 Blighted Children of Westchester," The Center for
+Preventive Psychiatry, 1969.
+11. "On a Vacuum in Mental Health Practices," The Center for Preventive Psychiatry,
+1969.
+"Psychological Management of the Dying Child," in W. Kutscher (Ed.) Death and
+Bereavement, Charles C.
+Company, Springfield, III. 1969.
+13. "The Unique Function of the Teacher in an Experimental Therapeutic Nursery School"
+(with Doris Ronald), The Center for Preventive Psychiatry,
+Plains, New York,
+1970.
+14. The Open Family Series (Consultant Editor, with Sarah Bonnett
+author). A
+series of five books entitled About Dying, Making Babies, That New Baby, A Hospital
+Story, and About Handicaps,
+Publishing Co., New York, 1974.
+15. "Death in the Family-Its Impact on Children," Terry
+Klein Memorial
+16.
+Lecture. Behavioral Sciences Tape Library, Leonia, New Jersey, 1974.
+"Death of a Parent Occurring During a Child's Analysis," in Trauma: Monograph V of
+17.
+the Monograph Series of the Ernst Kris Study Group, New York, 1974.
+"A Case of a Dying Child," in Trauma: Monograph V of the Monograph Series of the
+Ernst Kris Study Group, New York Psychoanalytic Institute, International Universities
+Press, New York, 1974.
+18. "Analyst in the Nursery: Application of Child Analytic Techniques in a Therapeutic
+Nursery," The Psychoanalytic Study of the Child, Volume 30, New York Times
+Publishing Company, 1975.
+19. "A Study of Maternal Depression in the First Two Years of Life: A Possible
+Contributing Factor in the Etiology of Infantile Psychosis and Neurosis" (with Judyth
+Katz), The Center for Preventive Psychiatry,
+Plains, New York, 1975.
+20. Introduction to Love and Mankind's Future, by Alexander Arzoumanian, Persepolis
+Press, New York, 1976.
+21. "Preventive Measures in Childhood Bereavement," in Linzer, N. Understanding
+Bereavement and Grief. Yeshiva University Press, New York, 1977.
+22. "Childhood Mourning: A Taboo Within a Taboo," in Gerber, I., Wiener, A., Kutscher,
+A., et al., Perspectives on Bereavement, MSS Information Corporation, New York,
+5
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 5 of 23
+23. "Mourning, Memory, and Reconstruction: The Analysis of a Four-Year-Old
+Maternally Bereaved Girl at Age Sixteen Months" (With
+1, Ph.D.), in
+The Psychoanalytic Study of the Child, Volume 34, The New York Times Press, New
+York, 1979.
+"Facilitation of Mourning During Childhood," in Gerber, I., Wiener, A., Kutscher, A.,
+et al., Perspectives on Bereavement, MSS Information Corporation, New York, 1979.
+25. "The Cornerstone Treatment of a Preschool Boy from an Extremely Impoverished
+Environment" (with
+, Ph.D.), The Psychoanalytic Study of the Child,
+Vol. 35, The New York Times Press, New York, 1980.
+26. Responsible Parenthood: The Child's Psyche Through the Six-Year Pregnancy, Holt,
+Rinehart, and Winston, New York, 1980.
+27. "Death: Some Implications in Child Development and Child Analysis," in Advances in
+Thanatology, Vol. 4, No. 2, Arno Press, New York, 1980.
+28.
+"Children in
+Care: A Preventive Service and Rescarch Program for a High Risk
+Population" (with M. Harris Schaeffer,
+, and Bernard G.
+Pasquariella). The Journal of Preventive Psychiatry, Volume I: 1, 1981.
+Editorial(s). The Journal of Preventive Psychiatry. Volume I, 1981-1982, Volume II,
+1983-4, Volume III, 1985-7, Volume IV, in press.
+30. Preventive Mental Health Services for Children Entering
+Assessment (with M. Harris Schaeffer, and M.
+Family Care: An
+The Center for Preventive
+31.
+Psychiatry,
+Plains, New York, 1982.
+"Summary
+of Two Psychoanalytically Based Service and Research Projects:
+Preventive Treatments for
+Children" with M. Harris Schaeffer, Ph.D. J. of
+Preventive Psychiatry, Vol. II, No. 1, 1983.
+"Three New Areas in Litigation on behalf of Children," in Child Psychiatry and the
+33.
+Law, Diane Schekty, Editor, Volume 2, Bruner/Mazel, New York, 1985.
+Preventive Psychiatry: Early Intervention and Situational Crisis Management, coeditor, with S.C. Klagsbrun, M.D., E.J. Clark, Ph.D., others. The Charles Press,
+Philadelphia, 1989.
+34. My Earthquake Story: A Guided Workbook for Children, Parents and Teachers, with
+Harriet Wolfe, M.D. and Edward Oklan, M.D. Psychological Trauma Center Press,
+Kentfield, CA. October, 1989.
+"Facilitation of Mourning During Childhood," chapter in Preventive Psychiatry: Early
+Intervention and Situational Crisis Management. (Eds) S. Klagsbrun, G. Kliman, E.
+Clark, A. Kutscher, R. DeBellis, C. Lambert. The Charles Press, Philadelphia, 1989.
+"Toward Preventive Intervention in Early Childhood Object Loss," chapter in
+Noshpitz, H. and Coddington, D. (Eds) Stressors and Clinical Techniques in Child
+Psychiatry. Charles
+, NY, 1990.
+37. "Brief Report: Loss of Parental Services—-A Guide to Categorization." J. Preventive
+Psychiatry and Allied Disciplines 4:1, 1990. Human Sciences Press, NYC.
+"A Methodologic Breakthrough: The Saga of Delivering Effective Primary Preventive
+Psychotherapy to Groups of |
+| Children." J. Preventive Psychiatry and Allied
+Disciplines 4:1, 1990. Human Sciences Press, NYC.
+"The Rise of Adolf Hitler and Other Genocidal Leaders—Psychoanalytic and
+Historical Symposium (Summary)," J. Preventive Psychiatry and Allied Disciplines
+4:1,1990. Human Sciences Press, NYC.
+6
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 6 of 23
+40. Kliman, G. et al (2007). "Facilitating Effective Coping in Children Following
+Disasters: A Psychoanalytic Informed Guided Narrative Intervention." J. Am Psan.
+Assoc. In Press
+41. Kliman, G. and M.H. Schaeffer, Ph.D. "A Breakthrough in Prediction and Prevention:
+Diagnoses as Social Predictors for
+_ Children." J. Preventive Psychiatry and
+Allied Disciplines 4:1, 1990 Human Sciences Press, NYC.
+42. "My Flood Story-a Guided Activity Workbook for Children, Families and
+Teachers," co-authored with Edward Oklan, M.D., Family Development Press, 1010
+Sir Francis Drake Blvd, Kentfield, CA 94960.
+43. "My Earthquake Story, A Guided Activity Workbook for Children, Families and
+Teachers," co-authored with Harriet Wolfe, M.D., Preventive Psychiatry Associates
+Medical Group, Inc., 2105 Divisadero Street, San Francisco, CA 94115 and Edward
+Oklan, M.D., Family Development Press, 1010 Sir Francis Drake Blvd, Kentfield, CA
+94960.
+44. "Field Notes:
+| Care: The Personal Life History Book: A Psychoanalytically
+Based Intervention for
+Children," Journal for the Psychoanalysis of Culture &
+Society, Fall 1996 1:2. 159-162.
+45. Kliman G and Zelman A. (1996). "Use of a Personal Life History Book in the
+Treatment of
+_ Children-An Attempt to Enhance Stability of
+Care
+Placements." Chapter in Zelman A (ed). Early Intervention with High-Risk Children:
+Freeing Prisoners of Circumstance. Jason Aronson, Northvale, NJ. 105-124.
+46. "Cornerstone Project: Analysis in Special Ed Classes," The American Psychoanalyst,
+1997. 31:2.27-28
+"My Book about Kosovo - a Guided Activity Workbook for Kosovo Children,
+Families, and their Teachers." English and Albanian Editions, CPHC, 1999, San
+Francisco.
+48. "My Book about the Attack on America", A Guided Activity Workbook for Children,
+Families and Teachers, coauthored with Ed Oklan, M.D. and Ann Oklan, M.D. 2001,
+CPHC, San Francisco.
+49. "Helping Patients and their Families Cope in a National Disaster", The S.F. Medical
+Society, January 2002. Reprinted in J. L.A. Medical Society, March 2002.
+50. Discussion of Reactive Attachment Disorder. Developmental Pediatrics. 2003.
+51. "My Personal Story About Hurricanes Katrina and Rita - a guided activity workbook
+Portland, OR.
+"My Personal Story About Tropical Storm Stan" English Ed. Feb. 24, 2006, The
+Children's Psychological Health Center. Spanish Translation " Mi Historia De La
+Tormenta Stan" Feb. 2006
+53.
+Israeli Terror Book
+54. "'Methods for Maximizing the Good Effects of
+Care: Evidence Based Strategies
+to Prevent Discontinuities of
+Care and Raise I.Q." International Journal of
+Applied Psychoanalytic Studies, April, 2006
+"My Personal Story about being Homeless" A Guided Activity Workbook to help
+Children Cope. The Children's Psychological Health Center Jan 15, 2008
+56. "My Sichuan Earthquake Story - A Guided Activity Workbook to help Children
+Cope" 85 pages. First English Edition May 22, 2008 available for download online at
+www.childrenspsychological.org. Mandarin edition by CPHC and China America
+Analytic Association, in press with Mercy Corps June 2, 2008.
+7
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 7 of 23
+57. "My Hurricane Story" A Guided Activity Workbook to help Children Cope. The
+Children's Psychological Health Center. Sept 21, 2008
+WORKS IN PROGRESS: available in Draft:
+IQ Rise among Preschoolers with Pervasive Developmental Disorders.
+Child Psychoanalytic Contributions to Civil Justice System, submitted by invitation, to
+Psychoanalytic Inquiry
+Books in Draft:
+1. Reflective Network Therapy: Early Childhood Psychotherapy in the Classroom
+2. A Unifying New Theory of Posttraumatic Stress Disorder
+PRESENTATIONS:
+01. "Specific Traumas: Selective Review of Literature," presented at the Ernst Kris Study
+Group, New York Psychoanalytic Institute, New York, 1965.
+02. "Psychoanalysis of a Four-Year-Old in a Preschool Group," presented at the American
+Psychoanalytic Association, Atlantic City, New Jersey, May, 1966
+03. "Covert Suicidal Impulses in Maternally Deprived Children" (with Harriet Lubin, M.S.W.),
+presented at the American Association of Psychiatric Services for Children, Boston,
+Massachusetts, November, 1969.
+04. Children's Reactions to National Events: The 1968 Federal Elections," presented at the
+American Orthopsychiatric Association, Washington, D.C., 1969.
+05. "Facilitation of Mourning During Childhood," presented at the Chicago Psychoanalytic
+Institute, May 1973.
+06. "Preventive Approaches to Preschool Psychiatric Disorders: Some Assessments," presented
+at the Academy of Child Psychiatry, Washington, D.C., October, 1973.
+"Biological Drive Derivative Cycles in Preschool Patients," presented at the New York
+Psychoanalytic Institute Research Seminar, 1974.
+08. "Children in National Disasters," presented at the International Association for Child
+Psychiatry, Philadelphia, Pennsylvania, 1974.
+09. "Childhood Mourning: Some Social Aspects," presented at Yeshiva University, New York,
+October, 1974.
+10. The Secter far Pral entive Rey diate Impact ors with men and chident presented
+Yeshiva University, October 15, 1975.
+11. "Death: Implication for Psychoanalytic Theory and Practice," presented at The Association
+for Psychoanalytic Medicine, New York, 1977.
+12. "A Psychoanalytic View of an Ancient Mass Disaster: The Mayan Exodus," The Center for
+Preventive Psychiatry, 1977.
+8
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 8 of 23
+13. "A Psychoanalytic View of Preventive Psychiatry," presented at Stockbridge, Mass.,
+December, 1977.
+14. "The Self-Concept and Healthy Narcissism: Relevance to Preventive Psychiatry," presented
+at the Westchester Psychoanalytic Socicty, L
+Plains, New York, 1978.
+15. "Special Problems of the Single Parent Child," presented at Department of Child
+Psychiatry, Rutgers Medical School and published by Jason Aronson Psychotherapy Tape
+Library, New York, 1978.
+16. "The Self-Concept: Its Significance in Prevention of Mental Illness," presented at The
+Alumni Association of the Chicago Psychoanalytic Institute, Child Psychotherapy Program,
+Chicago, 1978.
+17. "Treatment of an Impoverished Intellectually Retarded Ghetto Child by the Cornerstone
+Method" (with
+. Ph.D.), presented at the American Psychoanalytic
+Association, New York, 1979.
+18. "Preventive Approaches Among
+| Children Using Modern Theory of Narcissism,"
+presented at The Department of Psychiatry, Mountainside Hospital, Symposium on Primary
+Prevention of the Mental and Behavioral Disorders, Mountainside, NJ, 1979.
+19. "The Center for Preventive Psychiatry: Its Relationship to Infant Psychiatry," at the
+Symposium on Infant Psychiatry, The Center for Preventive Psychiatry,
+Plains, New
+York, 1979.
+20. "Mourning,
+Memory and Reconstruction," presented at The Westchester Psychoanalytic
+Association,
+Plains, New York, 1980.
+21. "Preliminary Report on Preventive Psychiatric Services for
+Children," presented at
+American Association of Psychiatric Services for Children, 1980.
+22. "Assessment of Primary Preventive Services: Children Entering
+Family Care,"
+presented at American Orthopsychiatric Association, May, 1981.
+23. "Psychoanalytically-Based Approaches to the Problems of
+Care: A Pilot Project,"
+presented at the American Psychoanalytic Association Interdisciplinary Seminar on
+Psychoanalytic Observations of
+| Care, New York, December, 1978. See also report of
+this Seminar by
+T.: "Psychoanalytic Observations of
+Interdisciplinary Seminar of the American Psychoanalytic Association)." The Journal of
+Preventive Psychiatry, Volume I:1, 1981.
+24. "A Project to Deliver and Evaluate Preventive Psychiatric Services," Columbia College of
+Physicians & Surgeons, Division of Child Psychiatry Grand Rounds, May, 1982.
+25. "New Concepts in Litigation on Behalf of Children," presented at New York Medical
+College, October, 1982.
+26. "Cruel Experiments of Nature: General Remarks on Childhood Bereavement and
+Developmental Pathology:" Vulnerable Child Workshop, American Psychoanalytic
+27. Facilitation of Mourning During Childhood: Role of The Clinician," presented at New York
+28. "A Questionnaire for Surveying the Practice of Preventive Psychiatry," presented at the
+American Academy of Child Psychiatry, Prevention Committee, October, 1983.
+29. "Experiences and Problems in Research Concerning Childhood Bereavement," presented at
+Department of Psychiatry, University of Ottawa, November, 1983.
+30. "Prediction and Prevention with
+Children" (co-authored with M. Harris Schaetter,
+Ph.D.), presented at American Psychiatric Association, May, 1984.
+31. "Preventive Psychiatry as Applied to
+Children," Grand Rounds,
+Porter
+Psychiatric Institute, 1985.
+32.
+"The Childhood of Adolf Hitler," with Robert Pois, Ph.D., The American Psychoanalytic
+Association, Denver, May 1985.
+9
+
+
+Case 9:08-cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 9 of 23
+33. Seminar on "New Areas in Forensic Psychiatry," at the Robert
+law firm, San
+Francisco, 1986. VIDEOTAPE AVAILABLE
+34. "Children's Reactions to the Challenger Shuttle Disaster," on 20/20 (Television Broadcast),
+1986. VIDEOTAPE AVAILABLE
+35.
+The Fathering of Adolf Hitler," Grand Rounds, McAuley Neuropsychiatric Institute, St.
+Mary's Hospital, San Francisco, 1986.
+36. "Child Sexual Abuse: Psychoanalytic and Forensic Approaches," Children's Hospital, San
+Francisco, 1986. VIDEOTAPE AVAILABLE
+37.
+"Preventive Psychiatry for Children," Training Seminar at McAuley Neuropsychiatric
+Institute, St. Mary's Hospital, San Francisco, 1987. VIDEOTAPE AVAILABLE
+38. "Multi-Victim Child Sexual Abuse," San Francisco Psychoanalytic Institute Extension
+Division, October 1987. VIDEOTAPE AVAILABLE
+39. "Children in
+¡ Families: Advances in Preventive Psychiatry," Continuing Education
+Program for Psychiatrists, U.C.
+8, 1988.
+40. "The Mothering of Adolf Hitler," Grand Rounds. McAuley Neuropsychiatric Institute, St.
+Mary's Hospital, San Francisco, Dec. 1988.
+41. "Adolf Hitler's Mothering: A Child Psychoanalytic View," Westchester Psychoanalytic
+Society, New York Hospital, January, 1989.
+42. "The Personal Life History Book: Preventive Psychotherapy for Children in Chaos."
+Department of Child Psychiatry, Harlem Hospital, New York, NY, January, 1989.
+43. Chairman: Symposium April 20-21, 1989. The Rise of Adolf Hitler and Other Genocidal
+Leaders. Interdisciplinary Unit for Study of Mass Violence and Genocide. St. Mary's
+Hospital Department of Psychiatry, San Francisco.
+44. "The Mothering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+45.
+46.
+"The Fathering of Adolf Hitler," Symposium above. VIDEOTAPE AVAILABLE
+Public Media: Following the October 17th earthquake, Dr. Kliman and his Psychological
+Trauma Center associates appeared on KRON-TV, KFAS, KQED and public service radio
+network to offer advice and respond to call-in questions regarding earthquake stress and
+trauma. His Earthquake Story guided workbook (see above) was distributed as a public
+service by San Francisco Community Mental Health Services and the Oakland Bureau of
+Education to 11,000 teachers in Oakland and San Francisco.
+Psychoanalytic Society: (April 1990) "Simultaneous child and couple therapy:
+emergence and interpretation of congruent unconscious themes."
+48. University of California College of Medicine, Department of Psychiatry, Irvine. Chune
+1990) "Prevention of Psychopathology among Children: Systematic Projects with
+Children."
+49. Preventive Interventions with Traumatized Children," Grand Rounds California Pacific
+Hospital Department of Psychiatry, October 20, 1992. VIDEOTAPE AVAILABLE.
+50. Altered Interpersonal Schemas After Life Threatening Childhood Trauma," Center for
+Study of Consciousness, UCSF, October 1992.
+51. Alterations of Pre-Traumatic Memory and Post Traumatic Schemas," Child Analysis
+Colloquium, San Francisco Psychoanalytic Institute, November 1992.
+52. Toward A New Theory of Post Traumatic Stress Disorder," Control Mastery Group, San
+Francisco Psychoanalytic Institute, December 1992.
+53. Severe Psychological Trauma in Very Young Children," Grand Rounds at the Menninger-
+San Mateo County Hospital Psychiatric Residency Program, March 23, 1993.
+54. Psychological Crises Among Preschoolers," Department of Health, City of San Francisco,
+April 1993.
+55. Child Analysis Colloquium," San Francisco Psychoanalytic Institute, May 1993.
+10
+
+
+Case 9:08-Cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 10 of
+56. "Loss of Parental Services—a Guide for Clinicians and Attorneys," Children's
+Psychological Trauma Center, September 16, 1993. (120 min. VIDEOTAPE
+AVAILABLE.)
+57. Catastrophic Levels of Psychological Trauma—a Guide for Clinicians and Attorneys,"
+Children's Psychological Trauma Center, September 27, 1993 (120 min. VIDEOTAPE
+AVAILABLE.)
+58. Systematic Preventive Interventions with
+• Children," Keynote Address, Western
+Pennsylvania Psychiatric Institute Conference on Adoption and
+• Care, Sept. 22, 1993.
+59. Cost Benefits of Preventive Interventions with
+• Children," American Behavioral
+Health Institute, San Francisco, Sept. 28, 1993. (60 min. VIDEOTAPE AVAILABLE.)
+60. True and False Allegations of Child Molestation," Children's Psychological Trauma Center,
+October 1, 1993. (120 min. VIDEOTAPE AVAILABLE).
+61. Severe Psychological Trauma in Childhood-Some New Observations," Grand Rounds,
+Dept. of Child Psychiatry, Oakland Children's Hospital, Oct. 7, 1993. (60 min.
+VIDEOTAPE AVAILABLE.)
+Preventive Approaches in Severe Psychological Trauma," Bar Association of San
+Francisco, October 28, 1993. (90 min. VIDEOTAPE AVAILABLE.)
+63. New Theory of Post Traumatic Stress Disorder," Pediatric Grand Rounds California Pacific
+Hospital, Nov. 5, 1993.
+64. Preventing Depression in Yourself, Your Clients and Your Co-Workers," San Francisco
+Bar Association, San Francisco, CA, December 2, 1993.
+A New Theory of Post Traumatic Disorders," Center for Preventive Psychiatry,
+Plains, NY, January 11, 1994.
+66. KRON-TV, "Helping Children Deal with Earthquake Stress," San Francisco, CA, January
+20, 1994.
+67. Samuel Kahn Memorial Lecture, The Center for Preventive Psychiatry,
+, Plains, N.Y.
+Topic,
+"Catastrophic Traumas of Childhood-New Findings,
+New Theory, New
+Therapeutic Tasks," February 28, 1994.
+68. "Preventing Job Stress: The Disease of the 20th Century," San Francisco Bar Association,
+San Francisco, CA, March 25, 1994.
+69. "Controlled Assessment of Psychoanalytically Derived Psychotherapy with
+Children," American Psychoanalytic Association, Philadelphia, PA, May 1994.
+70. "A senior researcher's subjective experience of a new hypothesis," California School of
+Professional Social Work Studies. Commencement Address, May 1994.
+71. "Oppositionalism Among Traumatized Children," International Association Child and
+Adolescent Psychiatry, San Francisco, CA, July 23, 1994.
+72. "New Theory of Posttraumatic Stress Disorder," International Association Child and
+Adolescent Psychiatry, San Francisco, CA, July 25, 1994.
+73. "Violence Against Young Children-Children in War," Co-sponsored by San Francisco
+Psychoanalytic Institute, San Francisco, CA, July 26, 1994.
+74. "Method for Treatment of Preschool Psychiatric Patients in Groups," American
+Psychoanalytic Association, Philadelphia, PA, December 15, 1994.
+Francisco Psychoanalytic Institute, March 31, 1995.
+76. "New Theory of Child Abuse Effects," T.A.S.K., Monterey, CA, April 1, 1995.
+77. "Psychological Trauma, Day Care and Mental Health," San Francisco Psychoanalytic
+Institute Extension Division. April 26, 1995.
+78. "Special Problems of Medical Ethics in Psychiatric Treatment: Child Abuse Concerns," San
+Francisco Psychoanalytic Institute Research Group, June 30, 1995.
+11
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 11 of
+79. "Operational Confirmation of a Psychoanalytic Hypothesis: Detecting and Interfering with
+The Repetition Compulsion," Cleveland Psychoanalytic Institute and Anni Katan Center for
+Child Development, October 28, 1995.
+80. The Personal Life History Book Method: Reducing Transfers Among
+Family
+Homes," The Center for Preventive Psychiatry, 1
+Plains, NY, October 30, 1995.
+81. "A New Theory of Posttraumatic Stress Disorder," Grand Rounds, Baylor University
+School of Medicine, Houston, November 8, 1995.
+82. "Raising IQ's in a Therapeutic Nursery: The Cornerstone Method. How it works as
+illustrated by video clips of the therapist and patients in the classroom," The Houston
+Psychoanalytic Institute and Stedman West Child Development Center, Houston, TX,
+November 8, 1995.
+83. "The Difficult Client: Accredited Continuing Legal Education seminar for California
+Attorneys." The Psychological Trauma Center, The Psychological Trauma Center, 1996.
+84. "Catastrophic injuries and psychological trauma: Accredited Continuing Legal Education
+seminar for California Attorneys." The Psychological Trauma Center, 1996.
+85. "Why Small Clients Get Large Awards: Proving and Disproving Psychological Injuries in
+Childhood. Accredited Continuing Legal Education seminar for California Attorneys."
+86. "A New Public Health Approach in Public Special Education: Presentation to The San
+Mateo Board of Education," San Mateo, CA. April 17, 1996.
+87. A new model for special education of preschoolers: The Cornerstone Method -- for synergy
+between early childhood education and psychotherapy. California State Dept. Education,
+Division of Special Education September 1996, Red Lion Hotel, Orange County Airport,
+88. "Synergy Between Special Education and Psychotherapy in the Classroom: Special
+Education Learning Program Administrators," San Mateo, CA. October 10, 1996.
+89. "The Role of Psychoanalyst as Forensic Expert in Catastrophic Psychological Trauma
+Cases." American Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY.
+December 1996
+"Controlled Assessment of a Psychoanalytically Derived Psychotherapy." American
+Psychoanalytic Association, Winter Meeting, Waldorf Astoria, NY December 1996.
+91. "Child Psychotherapy Course: Several preschool patients with different diagnosis, treated in
+a preschool therapeutic nursery, showing response to interpretations, with discussions of the
+role of teacher, parents and medications." San Francisco Psychoanalytic Institute, March 4,
+11, 18, 1997
+92.
+"Synergy between Psychotherapy and early childhood special education" SELPA
+Administrators, April 17, 1997
+93.
+"Analyst in the Nursery: The Cornerstone Method," San Francisco Psychoanalytic Institute,
+May 21, 1997
+94.
+"Psychological Trauma Among Preschoolers," San Francisco Psychoanalytic Institute, May
+15, 1997
+95. ACT for Mental Health, April 17, 1997
+96.
+"New Theory of Posttraumatic Stress Disorder," Fifth European Conference on Traumatic
+Stress, European Society for Traumatic Stress Studies, July 1, 1997.
+97. The Cornerstone Method: Intensive Preschool Psychotherapy in Public School Special
+Education Classes. California State Federation/Council for Exceptional Children 48'h
+Annual Conference & Special Education Fall Conference, San Francisco, CA, October 21-
+24, 1998.
+98.
+Research and treatment with highly traumatized preschoolers.
+Institute, Berkeley,
+Feb. 4, 2002.
+12
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 12 of
+99. Five year and thirty-three year follow ups of early childhood psychotherapy: Some startling
+findings among children treated by The Cornerstone Method. Grand Rounds, Dept. of
+Psychiatry, California Pacific Medical Center, San Francisco, February
+1, 2000.
+(VIDEOTAPE AVAILABLE).
+100. Post-Traumatic Stress Disorder and new methods of treatment. Department of Mental
+Health, State of Oklahoma, and Dept. of Psychiatry, Oklahoma State College of Medicine.
+Two Days of Workshops and Seminars to fellows, residents in psychiatry and child
+psychiatry, medical students, and mental health clinicians. October 22,23 2000.
+101. A Psychoanalytic Treatment of Young Children: Surprisingly Measurable Positive
+Outcomes", San Francisco Psychoanalytic Institute - Extension Division Discussion for
+Clinicians, 03.05.2001
+102. Regarding the 9/11/2002 Attack on America.
+2001-2002 Attack on America Events: 2001-2002 Public Health/ Public Education
+Activities:
+Seminar for Parents on Crisis Management following 9/11: Convent of Sacred Heart
+Elementary School Seminar for Teachers on Crisis Management following 9/11: Stuart
+and Convent of Sacred Heart Elementary Schools Federal Emergency Management
+Agency: Web-Site Linkage for CPH's advice to parents and teachers American Academy
+of Child and Adolescent Psychiatry: Web-Site Linkage for free copies of guided activity
+workbook for children, parents and teachers.
+American Psychoanalytic Association: Web-site linkage for free copies of guided activity
+workbook for children, parents and teachers.
+Channel II: Three interviews on primary prevention of the effects of psychological trauma
+and terror
+Channel II: Three interviews on secondary prevention via early life psychiatric treatment of
+children
+103. Day Long Workshop on The Cornerstone Method. The Children's Psychological Health
+104. Child psychoanalysis. San Francisco Psychoanalytic Institute. Six seminars to child
+analysts and advanced students, using illustrations from parent-permitted videos of the
+author's recent treatment work with young children.
+105. Theory and Intervention regarding Early Childhood Trauma: Extension Division, San
+Francisco Psychoanalytic Institute.
+106. Educating and treating disturbed young children: Office of Education, County of San
+Mateo, ten conferences a year. (1995- 2002)
+107. The Cornerstone Method of educating and treating disturbed young children: 45
+conferences a year, Children's Psychological Health Centcr, San Francisco. (1999-
+continuing)
+108. New methods for treatment of traumatized and/or developmentally disordered young
+children. Northern California Mental Health Association, February 9, 2002. A day long
+workshop. Eureka, Ca.
+109. Research and treatment with disturbed and traumatized young children.
+Berkeley, Feb 4, 2002.
+Institute,
+13
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 13 of
+110. Presentations of video-taped child treatment sessions: The Child Analysis Study Group of
+the San Francisco Psychoanalytic Institute, six occasions 2001-2002.
+I11. New Theory and New Treatments of Children. Northern California Society of Mental
+Health Professionals. Feb 8, 2002.
+112. Treatment of Children in their Real Life Spaces. Ann ||| Center, Berkeley, CA
+February 2, 2002.
+113. Treatment of children in community school settings. Workshop on Community Child
+Psychiatry. American Academy of Child and Adolescent Psychiatry. October 2002.
+114. Treatment of preschoolers in real life space - The Cornerstone Method. A two day training
+workshop for the L.A. County Dept. of Mental Health. October 2002.
+115. The Cornerstone Method. The American Psychoanalytic Association, Workshop on Early
+Childhood. January 2003, New York.
+116. Treatment of Three Autistic Preschoolers: The American Psychoanalytic Association. June,
+2003. Boston.
+117. The Personal Life History Book: A Preventive Therapy for
+| Children. A day-long
+workshop at Counseling4Kids, Los Angeles, September 2003.
+118. A new method of treatment of autistic preschoolers. The Chinatown Child Development
+Center, San Francisco, December 4, 2003
+119. Results of the Cornerstone Method: Pervasive Developmental Disorder with eight month to
+37 year followup. The M.I.N.D. Institute, U.C.
+. December 19, 2003.
+120. Procedures for preventing and reducing psychopathology among
+| children. Joint
+Committee of AACAP and Child Welfare League, November 2003, with Marilyn Benoit,
+M.D.
+121. The Role of Child Psychiatrists in Prevention of Child Abuse: Forensic Child Psychiatry as
+a Societal Influence. Mensa Society, January 2004.
+122. Psychoanalysis Confronts Autism. The L.A. and SoCal Psychoanalytic Institutes, February
+22,2004.
+123. Child Psychiatric Testimony and the Leading Edge of Social Change. American College of
+Forensic Psychiatry, March 28, 2004
+124. The Cornerstone Method of Treating Autism. American Psychoanalytic Association,
+Boston, Mass., January 2005.
+125. An evidence based method for in-classroom treatment of disturbed preschoolers. Child
+Welfare League of America. New Orleans, May 2005.
+126. Two evidence-based methods for treating
+| children. International Psychoanalytic
+Association, Rio de Janeiro, Brazil, July 2005.
+127. A novel evidence-based method for treatment of Asperger's Disorder. Lorman Educational
+Seminars, Redding, CA. November 18, 2005
+128. "Applications of The Cornerstone Method to Children with Autism Spectrum Disorders"
+American Psychoanalytic Association, New York, New York. January 18, 2006
+129. "Applying The Cornerstone Method in Public Schools" Philadelphia Board of Education
+April 28,06 DVD FORMAT AVAILABLE
+130. "Crises Intervention Techniques Within Schools: What you Need to Know When Large or
+Small Scale Disasters Strike" Lorman Educational Seminar, Sacramento, CA Oct. 6, 2006
+131. "Saying Goodbye: Termination in Psychotherapy" 53d Annual Meeting of The American
+Academy of Child and Adolescent Psychiatry, San Diego, Ca October 28, 2006
+132.
+|| LE, Viron M, I!
+_JE,
+A, Samples G, Kliman G: A school-based mental
+health recovery effort. Poster session presentation at the 58th Institute on Psychiatric Services
+Annual Meeting, New York, NY, October 5-8, 2006.
+14
+
+
+Case 9:08-cv-80381-KAM
+Document 114-2 Entered on FLSD Docket 06/08/2009 Page 14 of
+133.
+¿, L, Viron M,
+a JE
+§ A, Samples G, Kliman G, O'Neill P. A School-based
+Mental Health Recovery Effort. Poster session presentation at ADMSEP Annual meeting. Park
+City, Utah, June, 2007.
+134. Mishkin, AD, Viron M,
+* LE,
+n JE, Samples G, Kliman G. Reducing Post-
+Traumatic Stress after Hurricane Katrina: A School-Based Intervention. Poster presented at the
+59th Institute on Psychiatric Services Annual Meeting, New Orleans, LA, October 11-14, 2007.
+135. Videotape evidence for a new theory of PTSD etiology and treatment. Combined meeting of
+American Academy of Psychoanalysts with Academy of Psychoanalysis and Psychodynamic
+Psychiatry, The Marriot, Washington, D.C. May 3, 2008
+CURRENT TEACHING:
+Faculty Member: S.F. Psychoanalytic Institute. Eight 90 minute seminars on Pathogenesis in
+Early Childhood, with Focus on Psychological Trauma (a course for Candidates in the Child
+Analysis Program). See also Grand Rounds presentations below.
+THESIS CHAIR ACTIVITIES:
+Chairperson, Thesis Committee, California School of Professional Psychology, for Thesis of E.
+Wayrynen, M.A. concerning "Oppositional Behavior Following Childhood Sexual Abuse." 1998
+Chairperson, Thesis Committee,
+* Institute, for Thesis of Miquela
+* Hope, Ph.D. on IQ
+and CGAS changes following in-classroom psychotherapy and control group. 1999.
+Chairperson, Thesis Committee, Pacific Graduate School of Psychology, for Tina Scovis-
+Weston, Ph.D., on Early Memory Changes among Twelve Boys Raped by Men. 2001.
+RECENT AND CURRENT PROFESSIONAL ASSOCIATION COMMITTEE WORK:
+Chairperson, Forensic Subcommittee of S.F. Psychoanalytic Institute, 1993-1996. Established
+liaison with San Francisco Bar Association for a series of Continuing Legal Education Credit
+seminars presented by a panel of psychoanalysts. Topics presented by G. Kliman, 1993-1994:
+"Post Traumatic Stress Disorder," "Prevention of Stress in the Workplace," and "Prevention of
+Depressive Reactions during Legal Practice." Place: S.F. Bar Association.
+CURRENT:
+Member, Child Development Program Committec, San Francisco Psychoanalytic Institute.
+Member, Child Analysis Study Group, San Francisco Psychoanalytic Institute.
+Member, Committee on Psychoanalysis and the Community, American Psychoanalytic Institute.
+15
+
+
+Case 9:08-Cv-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 15 of
+Member, Joint Committee on
+Child Welfare Association.
+Care: Academy of Child and Adolescent Psychiatry and the
+PROFESSIONAL COMMENDATIONS:
+A letter of commendation regarding clinical work in the classroom within a public school
+system:
+December 3, 2001
+To Whom It May Concern:
+This is to report that the San Mateo County Office of Education, Special Education programs,
+has benefited from the services of The Children's Psychological Health Center, specifically its
+Cornerstone Therapeutic School Project.
+We have worked together for the past six years. Under the leadership of Gilbert Kliman, M.D.,
+the Center has trained members of our teaching and school psychology staff to carry out a
+mental health service on our premises. We now have a collaborative project in its sixth year for
+our special education preschool children with Pervasive Developmental Disorders (PDD) and
+for those with Serious Emotional Disorders (SED) which interfere with their education. As an
+alternative to sending children to a private nonpublic special education school for extremely
+intensive mental health services at significant cost, this project has created and provides just
+such intensive service within a public preschool special class program at 65 Tower Road, San
+Mateo.
+To my knowledge, among the 30 children served so far under the collaborative project, we are
+seeing cognitive, social and human gains which have decreased the gap between these children
+and their typically developing peers. Several families and children are thriving with less
+intensive special education service or returned to regular education class. Not only has the
+family and child suffering been reduced, the burden to taxpayers is also reduced. The children
+have been able to remain in the community, and some who were functioning as severely autistic
+and retarded now appear to be developing within a somewhat normal range. We are pleased
+with the quality of special education services our County provides for preschoolers with PDD or
+SED. We are also gratified with the research results provided by The Children's Psychological
+Health Center.
+We recommend the Cornerstone project to other school systems, so that they consider it an
+important opportunity should they be able to collaborate similarly with The Children's
+Psychological Health Center. At California's common cost of $15,000 to $40,000 or more a
+year, for a special education child who needs full time special education services and auxiliary
+intensive help, the savings for even one child's 12-year career of intensive services in special
+education can be substantial. The savings from one of the successes we have seen may equal the
+costs of the entire Cornerstone project with the 30 children helped so far.
+16
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 16 of
+We have not yet seen any failures. The agency is showing measurable cognitive gains for our
+collaborative work which, according to their research, averages 20 to 28 points in independent
+WPPSI testing of the children in the Cornerstone program. The techniques are far more
+economical to use than we have found with the Lovaas method, which we also implement for
+some students. We have also seen the techniques transmitted to special education teachers as
+well as inexperienced therapists.
+I invite you to visit our project in action.
+Sincerely,
+JAYS. PARNES, Ed.D.
+Senior Administrator
+Special Education
+MAJOR FEDERAL COURT FORENSIC ACTIVITIES:
+EVALUATIONS AND RECOMMENDATIONS HEARD IN FEDERAL COURT, HANNIBAL
+MISSOURI, November 15, 2001
+Under Dr. Kliman's leadership, a Children's Psychological Health Center team of five clinicians
+na two administrative staff has been at work since May 2, 2001 conducting a behavioral aud
+garding the psychiatric conditions and the residential treatment of over 100 children (most
+ages 13 to 17) at Heartland Christian Academy, as requested by the Academy's general counsel.
+2001: Doe vs. Three Springs Treatment Center, Nashville, TN.
+2004: Does vs. L.K. Baliredy et al (An international child trafficking matter). Five days of
+deposition.
+2004 Doe vs. State of New Mexico and Arthur Brokup.
+MAJOR STATE COURT CASES:
+Some cases of public health significance, concerning allegedly traumatized minors in care of
+governmental or institutional agencies:
+Does vs. OK Boys Ranch and State of Washington: 44 children in care at a state-licensed
+rehabilitation and
+| care-related center were allegedly allowed to abuse each other while
+staff and therapists did not report harmful activities of which they knew, Dr. Kliman opined. The
+plaintiff children have to date all received settlements in four phases of this litigation over a nine
+year period, with Dr. Kliman as the principal expert.
+York vs. Chaparral/Victor Treatment Facility. Orange County Superior Court. An eleven year
+old child severely and chronically molested by a residential treatment staff member was
+evaluated and an opinion given by Dr. Kliman concerning harm and how to rehabilitate the child
+as much as possible. Implications for standards of residential care are contained within the case.
+Carlson vs. Ray-Lara||
+Home. Orange County Superior Court. Dr. Kliman evaluated and
+testified concerning a twelve year old boy who was allegedly molested by a l
+father and had
+17
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 17 of
+to rescue himself. The | | father's partner was negligent, Dr. Kliman opined. The judge
+agreed and awarded the child compensation for psychological damages.
+Does vs. Archdiocese of Los Angeles. Dr. Kliman was the lead psychiatric witness. The case
+settled after six days of his deposition testimony.
+Does vs. Salesian Order Western Region. Dr. Kliman was the lead psychiatric witness. The case
+settled after nine days of his deposition testimony and two days of trial.
+Does v South Dakota School for the Deaf. Multiple boys were molested by an older student. The
+state school administration was allegedly negligent and major psychological damages were
+claimed. Dr. Kliman served as the principal plaintiffs' expert on administrative liability issues
+and psychological damages. The case settled with major compensation for the plaintiffs during
+the time of jury deliberations.
+CHILD PSYCHIATRIC EXPERT TESTIMONY:
+Dr. Kliman helped set legal precedents for the inclusion of psychiatric testimony in matters
+concerning wrongful death of a parent and loss of parental services, in both New York State and
+California. He has testified in over 275 cases including over 100 trials. A Federal Rule 26 list is
+available on request and on www.expertchildpsychiatry.com. His courtroom and deposition
+testimony experience includes
+cases of institutional negligence of children leading to
+psychological trauma, negligent
+I care, loss of parental services due to wrongful deaths,
+psychological trauma as part of personal injury of adults and children, childhood molestation,
+sexual harassment, termination of parental rights, and disputed custody. Since 2000 about 30%
+of his forensic work has been requested by defense, about 70% by plaintiffs, with the defense
+tasks increasing markedly in recent years.
+Dr. Kliman's evaluations and testimony regarding 16 children negligently cared for and abused
+at The Kiwanis' OK Boys' Ranch, Olympia, WA, helped lead to settlements and awards,
+totalling $25,000,000. Responding to disclosures in that case, many improvements have occurred
+in the publicly funded and licensed institutional care of children throughout the State of
+Washington, according to newspaper accounts.
+Dr. Kliman's evaluations and opinions, together with that of The Children's Psychological
+Trauma Center team led by Robert Wynne MFCC, led to record-making $8,000,000 loss of
+parental and other services compensation for 17 bereaved subsistence-economy Alaskan Inupiat
+Native Americans (|
+•vS. Ryan Airlines, Anchorage, 1997).
+Principal expert regarding institutional negligence and psychological damages in Does vs.
+Rudolph Kos and the Diocese of Dallas, Dallas 1997. The Catholic Church of Dallas was held
+liable for institutional negligence, testimony concerning the need for major psychiatric treatment
+planning was accepted by the jury, and $119,000,000-including punitive damages against the
+18
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 18 of
+OTHER PUBLIC HEALTH ACTIVITIES AND RECOGNITION:
+In response to the mental health needs of families following recent massive firestorms, United
+Way printed and distributed 10,000 copies of "My Fire Story -- a Guided Activity Workbook for
+Children, Families and Teachers," co-authored with Edward Oklan, M.D. Copies can be obtained
+from Family Development Press, 1010 Sir Francis Drake Boulevard, Kentfield, CA 94960. The
+State of lowa purchased rights to reproduce 10,000 copies of "My Book about The Attack on
+America - a Guided Activity Workbook for Children, Families and Teachers", published in 2001.
+During 1996 - 2002 Sophie Murvis Foundation, The Windholz Foundation, The Atkinson,
+Cadence Corporation, Irving Harris Foundation and The Stullsaft Foundations have recently
+awarded grants to Dr. Kliman as principal investigator for his Cornerstone Therapeutic Nursery
+project, serving seriously disturbed preschoolers in the San Mateo Office of Education.
+Presentations on The Cornerstone Therapeutic Nursery Project have been made by Dr. Kliman
+during 1997 through 2002 at the San Francisco Psychoanalytic Institute and the Seattle Institute
+for Psychoanalysis.
+Three documentary videotapes concerning Dr. Kliman's psychotherapies of disturbed children
+treated by him using this method in a therapeutic special education class are now available for
+scientific and educational purposes, parental permission having been gained. Such use requires a
+confidentiality agreement.
+Tape I: The Cornerstone Method.
+Tape II: Treatment of an Autistic Boy
+Tape III: Unique Features of The Cornerstone Method
+As a pilot application of his techniques for preschoolers, Dr. Kliman opened a Cornerstone
+Therapeutic Nursery at the Salvation Army Shelter for homeless families in January 1998,
+serving seven homeless families with preschool children. He is supervising the project weekly as
+Medical Director of The Children's Psychological Trauma Center. Unedited videotapes of that
+project are available to scientists and educators with a confidentiality agreement. The
+Institute has provided a psychology intern to conduct the treatment under Dr. Kliman's training
+and supervision. The California School of Professional Psychology has assigned a doctoral thesis
+candidate to Dr. Kliman's supervision to study the I.Q. rise phenomenon previously documented
+in Cornerstone therapies.
+Peer-reviewed publications of Dr. Kliman's work with
+children appear in Zelman, A:
+Interventions with High Risk Children, Jason Aronson 1997 (Chapter by Kliman on Controlled
+Assessment of The Personal Life History Book Method for
+Children). Results of Dr.
+Kliman's Cornerstone Method are also reported extensively in that book, focusing on the I.Q. rise
+phenomenon.
+19
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 19 of
+Archive of Videotaped
+Seminars and Events:
+- Gilbert Kliman, M.D., Medical Director
+THE CHILDREN's PSYCHOLOGICAL TRAUMA CENTER
+(A division of the Children's Psychological Health Center, Inc.)
+Archive of Videotaped Seminars and Events:
+CONTINUING LEGAL EDUCATION TAPES:
+California MCLE credit is available to attorneys for study of these tapes. Unless otherwise
+indicated, Gilbert Kliman, M.D. was the sole or principal speaker. Contact Edith Lee at 415 474
+0955 for MCLE credit fulfillment associated with study of these tapcs.
+O1. True and False Allegations of Sexual Molestations, 1987. 1.5 hrs.
+02. Loss of Parental Services, May 6** 1992 Elina Wayrynen and Gilbert Kliman, M.D.
+2.0 hrs.
+03. Abuse in Institutions, August 1" 1995, 2.0 hrs.
+Catastrophic Accidents with Lifetime Psychological Damage, December 5 1995 2.5
+05. Evaluating Psychological Trauma in Catastrophic Accidents (Grosvenor Hotel, San
+Francisco) 1996, 2.5 hrs.
+06.
+Loss of Parental Services (Holiday Inn), January 9* 1996, 2.5 hrs.
+07.
+Loss of Parental Services, May 12" 1993 1.5 hrs.
+08.
+True and False Allegations of Sexual Abuse, June 7" 1993, 1.5 hrs.
+09.
+Catastrophic Psychological Traumas in Childhood, February 1994, 2.5 hrs.
+10.
+The Difficult Client, February 27* 1996, 2.5 hrs.
+11. The Difficult Client (at Wells Fargo), February 6" 1996, 2.5 hrs.
+Evaluating the Validity of Recovered Memories: Perspective of a Forensic Expert,
+February 29# 1996, 1.0 hr.
+13. How Small Clients Get Large Awards, Psychological Trauma in carly childhood
+produces life time consequences in some cases. Defense and plaintiff considerations.
+Giving Powerful Voices to Children in Court: I, March 20*' 1998. Windle Turley, Esq.
+With Gilbert Kliman, M.D., 2.5 hrs.
+Giving Powerful Voices to Children in Court II, May 8* 1998, John Connelly, Jr. with
+Gilbert Kliman, M.D., 2.5 hrs.
+20
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 20 of
+16. Giving Powerful Voices to Children in Court III, June 12" 1998, Mare June, Esq. With
+Gilbert Kliman, M.D., 2.5 hrs.
+17. Psychoanalysis and the Law: How Child Psychoanalysis Contributes to Justice for
+Children. Conference at the San Francisco Psychoanalytic Institute, March 1" 1999,
+Introduction by Maureen Katz, M.D., Discussion by Katherine MacVicar, M.D.,
+Gilbert Kliman, M.D., presenter. San Francisco Psychoanalytic Institute Extension
+Division. 1.5 hrs.
+21
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 21 of
+The Children's Psychological Health Center
+Archive of Videotaped Seminars and Events:
+- Gilbert Kliman, M.D., Medical Director
+CLINICAL AND SCIENTIFIC TAPES:
+STARRED (*) TAPES BELOW ARE A PRECIOUS ARCHIVE OF INFORMATION ABOUT
+PROBLEMS AND TREATMENT OF SEVERELY STRESSED CHILDREN. THEY ARE
+NOT FOR SALE OR COMMERCIAL DISTRIBUTION. THEY MAY BE STUDIED AT
+CPHC ON-SITE WITH ASSISTANCE OF OUR STAFF BY QUALIFIED RESEARCHERS,
+CLINICIANS, SPECIAL EDUCATION TEACHERS, ADMINISTRATORS OF NONPROFIT
+CLINICAL ORGANIZATIONS AND SCHOOLS FOR CHILDREN, SCIENTISTS AND
+STUDENTS OF RELEVANT DISCIPLINES BY APPOINTMENT AT CPTC
+HEADQUARTERS. CREDENTIALS, REFERENCES AND CONFIDENTIALITY
+AGREEMENT ARE REQUIRED COLLABORATIVE RESEARCH ARRANGEMENTS CAN
+BE CONTRACTED FOR WITH CONFIDENTIALITY AGREEMENTS AND LONG TERM
+USE OF THE TAPES.
+*1.
+Childhood Post Traumatic Stress Disorder (California Pacific Hospital Grand Rounds).
+1992
+New Theory of Post Traumatic Stress Disorder, Gilbert Kliman, M.D. December 4"
+1992, International Association of Child and Adolescent Psychiatry and Allied
+Disciplines, Fairmont Hotel, San Francisco.
+*3. Severe Psychological Trauma in very Young Children, March 23d 1993
+*4. Post Traumatic Stress Disorder: Child & Adult, September 27" 1993
+5.
+Cost Effectiveness: Mental Health Services for
+Children, September 28" 1993
+6.
+Preventive Child Psychiatry, Mc Auley St Mary's, October 16* 1993,
+*7.
+New Theory of Post-Traumatic Stress Disorder, for Int, Association of Child and
+Adolescent Psychiatry, July 25* 1994
+*8.
+Cornerstone Method Conference, Wells Fargo, January 30"* 1996
+*9.
+Cornerstone Conference: Control - Mastery Group, San Francisco Psychoanalytic
+Institute. February 9" 1996
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 22 of
+10.
+Conference on Childhood of Adolf Hitler: Control-Mastery Group, San Francisco
+Psychoanalytic Institute, May 17" 1996
+11.
+Orientation to the Personal Life History Book Method. CPTC & ACT For Mental Health,
+April 4'' 1997 (two tapes)
+*12.
+The Cornerstone Method: A Public Health Approach. National Association for Social
+Work and Psychoanalysis, Seattle. September 26* 1997
+*13.
+New Theory of Psychological Trauma: Colloquium, San Francisco Psychoanalytic
+Institute, October 12" 1996
+*14.
+Treatment of Severely Disturbed Preschoolers in their Public School Special Education
+Classrooms: A New Application of Intensive Psychotherapy. American Academy of
+Child and Adolescent Psychiatry.
+*15. Treatment of an Autistic Boy, the Cornerstone Method
+*16. The Cornerstone Therapeutic Nursery Method
+*17. The Cornerstone Method: Unique Features
+18.
+Investing in our Futures: Rotary Club: About the Cornerstone Method, December 9'h
+1997 Robert Denebeim, Esq. With Gilbert Kliman, M.D.
+19.
+Salavation Army Cornerstone Program: Channel 4 News. Linda
+Reporter.
+20. Gilbert Kliman M.D. on Channel 4 News, April 22d 1998. Linda
+Reporter.
+21. Orientation to The Personal Life History Book, October 13* 1998 (three tapes)
+*22. The Psychoanalytic Psychotherapy of a Four Year Old Boy, 1999. An ongoing archive
+made with generous permission of the child's family, now totaling over 25 hours. This
+child has had severe stressors in his life, and suffers behavioral and overanxious
+symptoms. He has impulse dyscontrol, attentional deficits, and expressive language
+difficulties from which he can be seen to be recovering. Two excerpted tapes have been
+created to illustrate features of the child's pathology, and of the response to interpretive
+aspects of treatment. Gilbert Kliman, M.D. is the psychoanalyst, and the treatment is
+conducted three times a week, with parent guidance every two weeks. The videographer
+is in the room. This may be the only existing video archive of a child analysis conducted
+by a certified child psychoanalyst.
+Cornerstone Treatment Archives: 1995-2008. Ongoing archive of intensive in-classroom
+treatment of seriously disturbed preschoolers, within their public special education
+classrooms in San Francisco and San Mateo, Shelters for homeless families in San
+23
+
+
+Case 9:08-CV-80381-KAM Document 114-2 Entered on FLSD Docket 06/08/2009 Page 23 of
+Francisco and Seattle, private therapeutic preschool in San Francisco, and Cornerstone
+Argentina
+24.
+Thirty four year follow-up of a Cornerstone Treated autistic child, now recovered.
+Presented at The San Francisco Psychoanalytic Institute, Child Analysis Study Group,
+2001. Permission for public viewing granted by the patient. Excerpts may be viewed on
+www.childrenspsychological.org or the entire video obtained from
+gilbertkliman2008@gmail.com
+*25
+Orientation of the Family Services Center of 1
+2007, in Seattle. Six DVD's.
+County. Four days in December,
+Scientific and Educational Video Archives under Dr. Kliman's supervision:
+With parental permission, The Children's Psychological Health Center, under Dr. Kliman's
+leadership, is collecting unedited treatment documents of a special method of treatment in a real
+life space, called "The Cornerstone therapeutic preschool method." Now totaling over 200 video
+archive hours, eight different California therapists working with various educator teams have
+recorded their Cornerstone therapeutic preschool method work. Beginning in 1995, this archive
+started with Gilbert Kliman, M.D. working for a year as daily in-classroom therapist in a public
+special education school. He was assisted by Leanne Runyan and Gail
+as the teachers
+at the San Mateo Early Childhood Education Center, a preschool special education facility of
+The County of San Mateo. A second team under his supervision included work at The San
+Francisco Unified School District (Vanessa Vigilante and Esther Kronenberg). Third and fourth
+teams were at The Salvation Army Gateway Shelter (Vanessa Vigilante as therapist and Lynda
+Byrd as teacher, Deanna Reardon as therapist and Lynda Byrd as teacher). A fourth was at The
+Cadence Cornerstone Site at Mt. Pleasant School, San Jose (Karita Hummer, therapist and Kathy
+Krall, teacher). Fifth team therapy was provided by Jane Christmas. The sixth team therapists
+was Dr. Miquela
+Hope, the seventh Molly Franklin, MFT. All have been extensively
+videotaped carrying out the method. An eighth team was assembled in late 2002, when Linda
+Hirshfeld Ph.D. joined as Fellow in Cornerstone Therapy. In 2001 Mike McDonald, Ed.D.
+became Special Education Director of Cornerstone School. All the treatments are have been
+under principal supervision of Dr. Kliman with additional supervision by Mali
+M.D.,
+Myrna Frankel, Ed.D., and Jan Baeuerlen, M.D. Linda Hirshfeld, Ph.D. of the Ann
+Center is conducting the archival work for her Cornerstone Services.
+A professional researcher/ training confidentiality agreement is required to study this archive.
+S:IGK. Private Forensic 7-13-04ICV1PPA CVs|Gilbert Kliman CV ppa 06 02 08.doc
+24
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+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 1 of 13
+Aug Cases 90@86pv-801
+Habolinent 247-4 Entered on FLSD 148ZK7788f85/2009 Page 1 of 13
+Jane Doe #3
+V.
+Jeffrey Epstein
+AFFIDAVIT OF RICHARD C.W.)
+1M.U.
+STATE OF FLORIDA
+COUNTY OF SEMINOLE
+On this day personally appeared before me, the undersigned authority, Richard
+c.w.L
+| M.D., who, being by me first duly sworn under oath deposes and says:
+1. My name is Richard C.W.
+M.D. Iam over the age of majority, and make
+this affidavit and declaration upon the basis of personal knowledge of the factual matters
+contained herein.
+2.
+I have maintained a private practice in psychiatry and forensic psychiatry
+since 1996.
+3. I, also, currently serve as a Courtesy Clinical Professor of Psychiatry at the
+University of Florida, College of Medicine, Gainesville, Florida; Affiliate Professor, Dept of
+Psychiatry and Behavioral Medicine, University of South Florida; and Professor of
+Psychiatry, Department of Medical Education, University of Central Florida College
+Medicine.
+4.
+| University and
+I received my undergraduate degree from the Johns
+1
+''6"
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 2 of 13
+Aug CaseD 908.86pV-801 RAND. HabdPhent 247-4 Entered on FLSD D19Zt8₽88/85/2009 Pagé2 of 13
+medical degree from the University of Florida College of Medicine, Gainesville, Florida.
+5. I served as a Lieutenant Commander in the United States Navy, where I
+researched and evaluated biological and neurochemical factors associated with the onset of
+psychiatric disorders and served as a representative to the Joint Services Task Force
+planning Operation Homecoming, the return of POW's from Vietnam.
+Thave previously served as an assistant clinical professor at the University of
+South Florida College of Medicine, directed one of the ten model mental health centers in
+the United States, and served as a medical consultant to the Kennedy Space Center.
+7.
+Iam a former member of the academic faculty at the University of Texas, in
+Houston, Texas where I served as Assistant Professor and then Associate Professor of
+Psychiatry and Internal Medicine, Director of Clinical Research, Director of Residency
+Training, Chief of the Consultation/Liaison Service, and Chief Psychiatrist at the M.D.
+Cancer Hospital in Houston.
+I, also, have served as a Professor of Internal Medicine and Psychiatry at the
+Medical College of Wisconsin where I was appointed Chief of Psychiatry at the Milwaukee
+County and Proedtert Hospitals.
+9.
+In addition, I have served as a Professor of Psychiatry and Internal Medicine
+and Associate
+at the University of Tennessee College of Medicine, Memphis.
+10.
+The amended complaint filed by Jane Doe #3 against Jeffrey Epstein make
+2
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 3 of 13
+Aug 648894.Bepv-801 RataANt. HElpdamnent 247-4 Entered on FLSD B8ZR2788995/2009 Page' 3 of 13
+sensitive allegations of sexual assault and abuse upon a minor and seek damages in excess
+of $50 million. Jane Doe #3 alleges confusion, shame, humiliation, embarrassment, and
+severe psychological and emotional injuries. It is further alleged that she suffered, and will
+continue to suffer, severe and permanent traumatic injuries, including mental,
+psychological, and emotional damages.
+11.
+She alleges the intentional infliction of emotional distress and that Mr.
+Epstein's conduct caused severe emotional distress, severe mental anguish and pain.
+12. She further alleges that she suffered personal injury including mental,
+. psychological and emotional damage.
+13. Plaintiff's counsel has retained an expert witness, Dr. Kliman of the
+Psychological Trauma Center, a division of Preventative Psychiatry Associates Medical
+Głoup, Inc., of San Francisco, California, of which Gilbert W. Kliman, MD, is the medical
+director. Dr. Kliman's initial records indicate the following concerning Jane Doe #3.
+14. Plaintiff's Answers to Defendant's First Interrogatories note that she had seen
+a therapist in Palm Beach County at age 11. She believes that she had previously been
+diagnosed with depression following her parents' divorce. (Page 7) She reports that she has
+suffered from anxiety, depression, suicidal ideation, guilt, self-blame, feelings of being
+degraded, feeling unattractive, a diminished sense of femininity, fluctuations in weight and
+appetite, sexual intimacy problems, flashbacks, disturbing memories, stress, irritability,
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 4 of 13
+Aug ease tQ.8epv-801 kiAN. Hangument 247-4 Entered on FLSD DOZR8R08995/2009 Page4 of 13
+feelings of being isolated and trapped, diminished trust, social problems, problems in
+personal relationships, indecisiveness, low energy, lower ambition and initiative,
+headaches, back pain, feels stress (particularly around men), obsessive thoughts, problems
+concentrating, alcohol abuse, corruption of morals and values, loss of innocence, and cries a
+lot. (Page 8)
+15.
+She reported that she had seen Mr. Epstein four times from the fall of her
+sophomore year in high school through her senior year, but had only had physical contact
+with him once, had voluntarily returned on three other occasions with other girls, and
+spent 30-45 minutes alone with the defendant, but remained on the premises of the estate
+for four or five hours. (Page 11, interrogatories)
+16.
+Plaintiff notes that she has recently married and is " very happy about that."
+She met her husband on Myspace.com. She reported that they dated for 2½ years, that it
+was a good relationship, that they click, and feel that they can spend the rest of their life
+with each other. (Page 1, Dr. Kliman's contemporaneous notes).
+17. Plaintiff reports that she had a deep depression that lasted for a year and that
+she shut people out since the time of her parents' divorce at age 11. (Page 1, Dr. Kliman's
+contemp notes)
+18.
+She reports that she attempted suicide five times, beginning at age 11, after
+her parents got a divorce, and attempted suicide at age 15 by running a car in a closed
+4
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 5 of 13
+AugCats@990@#apv-801 FOsKard/C. bcMPent 247-4 Entered on FLSD D9ZR2P0885/2009 Page 5 of 13
+garage. She reports she would have died if her sister and nephew hadn't walked in. On
+subsequent attempts, she swallowed "a whole bunch of pills" and a friend made her throw
+up. This was at age 18 or 19. She reports she took " a huge handful." (Page 1, Dr. Kliman's
+contemp notes)
+19. Plaintiff reports that she had seen many psychologists and finally found one
+that she liked, Rhonda Perdue. (Page 1, contemp notes)
+20. Shenotes that she has been taking 25 mg of Lexapro prescribed by Dr. Nabel
+Karrum, MD, for the last year. (Page 2, contemp notes)
+21. She notes that her father was verbally abusive to her and physically abusive
+with her sister and her mother. On one occasion, she reports, her father took all of her
+mother's clothes and threw them in the front yard of her house while she (the mother) was
+taking a shower and that she and her sister had to leave the house with her mother. She
+reports that between ages 9 and 11 her father was "heavy in drinking and had a gun in the
+house." She reports that her mother "didn't want us there." (Page 2, contemp notes)
+22.
+Plaintiff reports that she was the individual who found out that the father was
+cheating on her mother with a woman who lived around the corner. The divorce was final
+when she was 13 years of age. They lived in the parental home for two years, until she was
+15, and then moved. The father was in the picture "here and there." He remarried,
+divorced, had a girlfriend, went to AA to get help, and was sober for four years. She
+5
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 6 of 13
+Aug CaseD900B/pv-801 18okaRV. HalboPent 247-4 Entered on FLSD D8ZK2708985/2009 Page 6 of 13
+wondered if he was doing pills or marijuana. Her parents are back together and she
+reports they have been living together for the past eight months. She reports her father
+suffers from depression and that while depressed he is distant, has angry spells, and she
+"worries what he will do... he snaps so much." (Suggesting very unstable home, feax and
+apprehension, concern for mother's safety.) She reports that she deals with this by "I try to
+keep all this out of my mind, try not to think about it..." The most distressing event was
+when she was awakened and had to leave the house with her mother and sister because of
+the father's threatening behavior. (Page 2, contemp note) She reports that in school "I was
+mean" and that she would "not put up with crap or teasing." She notes that "I got teased
+about wearing the same jeans or shoes" and she was teased about her weight. "I was a
+little chunky:" (Pages 2 and 3, contemp notes)
+23.
+Plaintiff notes that two of her friends had seen Mr. Epstein previously.
+anded
+had done it and said it went smoothly and I didn't have to worry about anything.
+Don't ask, don't tell. So I felt comfortable with $200 for a half hour." (Page 1, interview
+part 2)
+-24.
+She reports that she lied about her age. "I was told to tell him I was 19, which
+said we had to lie about our age." Plaintiff reports that after her initial contact with
+Mr. Epstein she went back to bring other people there. "Not to do anything. I went back
+three times with two different girls and C
+(Page 3, interview part 2)
+6
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 7 of 13
+Aug @99@94.87sv-801 kRaaANC. Hancument 247-4 Entered on FLSD D8ZREP08995/2009 Pagé7 of 13
+25.
+Plaintiff reports that she had told another woman.
+"he might try to
+touch you but just move away and wear whatever." (Page 5, interview part 2) Although
+plaintiff reports she had no further physical contact with Mr. Epstein, she did voluntarily
+return to his estate on three separate occasions with other girls.
+26.
+Plaintiff reports that she is taking phentermine 5 mg, an agent that can cause
+anxiety. (Page 1, part 3)
+27.
+She began drinking at age 13. (Page 2, part 3) She reports that she has driven
+while intoxicated. (Page 2, part 3) She reports that she has had blackouts "I quite a few
+times have been unable to remember things others say I did... that I peed on the floor in
+the middle of the night, that I passed out in the club, my friend's cousin drove us home,
+which I don'tremember, and I got into an argument with somebody and I don't remember
+that Thad an argument at the club or that we stopped and ate on the way home and I don't
+remember, or falling down stairs, ripping my pants." (Page 2, part 3)
+28.
+The plaintiff reports that she was raped at age 15 and never told anyone
+about it. It occurred at a graduation party. She was drinking. "I couldn't remember
+anything until the next day." "I saw marks on myself." "I thought I had locked the doot
+where I was sleeping. Later I remembered I was unable to move, paralyzed, and he ripped
+my clothes off and raped me." "When I saw the marks and my mom took me to a doctor,
+who gave me a rape kit, found no semen, told me the scratch marks would go away, and
+7
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 8 of 13
+Aug 689882876V-801RRAM. Hancent 247-4 Entered on FLSD DEZREP 08995/2009 Pale8 of 13
+tried to get me to write a report, but I wouldn't." (Page 3, part 3)
+29. Plaintiff reports she was also molested at age 12 by her best friend's brother,
+who had just gotten out of jail. (Page 3, part 3) "He molested four children that night by
+playing with our bottoms, tops, face, and hair. We all woke up and never said anything
+until he raped his sister a month later. He touched me just that one night on a sleepover.
+One of the girls was up and pretended she was sleeping. I remember being touched, but
+thought I was dreaming until my friend told me the same thing and we found out he raped
+his own sister so then it was obvious." "That house was a house where there was drinking
+and pot smoking." "He gave us pot and made smart comments. He was in his mid 20's,
+about to turn 25." Plaintiff thus reports marijuana use at age 12. She notes that in fourth
+grade she took her first pot when she was 10 years of age. She reports that they pressed
+charges concerning the molestation. (Page 3, part 3)
+30.
+She notes that Kevin g
+the boy who molested her, subsequently raped
+his sister. "I consider what Kevin did to me was a rape." (Page 3, part 3)
+31.
+In an interview with Dr. Kliman, plaintiff reported that she has been married
+for three months and that she is very happy about it and going to school part time. (Page 2,
+tape 1)
+32.
+Plaintiff reports that she was depressed over her parents' divorce, that she
+had attempted suicide on five occasions, the first at approximately 11 when she tried to cut
+8
+
+
+Case 9:08-cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 9 of 13
+Aug Daste 90670V-801 R$HAM. HBboPhent 247-4 Entered on FLSD 18722788985/2009 Pale 9 of 13
+her wrists. Atage 15, she tried to asphyxiate herself with a running automobile in a garage.
+The next attempt was with an overdose of pills at 18 or 19. (Page 5, tape 1)
+33.
+She reported that her father was very abusive to her (Page 6, tape 1) more
+verbal with her, but physical with her sister and her mother. (Page 6, tape 1) "They would
+argue about anything he wanted, anything that was on his mind. I remember one time she
+was in the shower and he took all her clothes and threw them in the front yard; and they
+were just having a screaming match and we were already in bed and I remember my mom
+had to wake us up and tell us to get dressed and put our shoes on; and we would have to
+walk all the way to a little 7-11 in front of our development to get picked up because my
+dad would just be out of control, and we would have to stay at my aunt's house and sleep
+there and stay there until things got better. This must of happened like too many times and
+..." Plaintiff was ages 9 to 11 when this would happen. (Page 7, tape 1)
+34.
+She noted, that her father cheated on her mother and that she was the one
+who found out about it and that after reporting it, the parents divorced when she was 13.
+She had a turbulent family life. The thing that stands out as most distressing of the things
+that they had considered was being awakened and having to go to store. (Page 8, tape 1)
+35.
+She reports that she had a few core friends, but "I didn't have too many
+friends" (Page 10) and that as a child she was teased about her clothes (Page 10) and her
+weight.
+
+
+Case 9:08-Cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 10 of
+AuSC9$69:08527-8011814Ka4MC. HUclARent 247-4 Entered on FLSD D82k8778163/2009 Page'90 of 13
+36.
+Plain tiff reports, "Right now I'm okay. I'm content with what I have to look
+forward to right now, and that is trying to have a good life for me and my husband; trying
+to have a sense of normalcy." (Page 2, tape 3)
+37. In her interview with Dr. Kliman (as well as her sworn statement to the police
+on 11/07/2005), Plaintiff claims that she was told all she would have to do was to give a
+massage and that Epstein would ask her to get "comfortable", that's it. This conflicts with
+the Probable Cause Affidavit (page 9) and the Palm Beach Police Incident Report (page 37)
+where she indicates she was told that a massage would be expected, possibly naked and
+possibly some touching. In addition, Tape 2, page 6-14, she claims Epstein touched her
+breasts and fondled her nipples, and that he touched her vagina. However, this statement
+conflicts with what she told police in her sworn statement where she indicated Epstein
+never touched her breasts or her vagina. See sworn statement at PP. 4, 7 and 8. The
+Plaintiff's medical records may show that the Plaintiff has a propensity to lie when it comes
+to explaining events allegedly involving Epstein and/or her past.
+38.
+All of the above show that this plaintiff came from an unstable and disturbed
+home, had been subject to previous physical and sexual abuse, was fearful, isolated, and
+had had suicidal ideation prior to meeting Mr. Epstein. For further elaboration of her
+history and background, access to all available records is crucial if one is to fully
+understand the impact of any of these events on her subsequent behavior and proportion
+10
+
+
+Case 9:08-Cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 11 of
+Aucas 09:08587-8011BigharMC. HelcURent 247-4 Entered on FLSD D88k8738189/2009 Page 91 of 13
+the impact of specific events, if any, or her current and future level of function.
+39.
+In Dr. Kliman's initial replenishment retainer agreement and fee schedule
+(date 7/18/08), in a heading entitled "Regarding Full Disclosure," Dr. Kliman notes that
+prior to deposition, counsel will make every effort necessary to provide experts with
+information requested by the experts including: 1) a list of all depositions, statements,
+declarations, and motions in the case, 2) a copy of any requested items, and 3) most
+importantly, a list of all medical clinical, school, and work records known to the attorney
+in the case.
+40. Dr. Kliman notes on page 8 of his contract opinion formation thathe will not
+form opinions, give reports, or testify in certain circumstances.
+These include
+circumstances where he has reason to believe a retaining attorney has "available important
+and relevant documents which are being deliberately withheld from us." "We define such
+as documents in possession of retaining attorney, which we have requested or that we have
+stated would ordinarily be part of medical opinion formation on the topics concerning,
+which our input is requested." We request the same.
+41.
+It is critical for an IME examiner to be able to make a cogent assessment of
+any plaintiff and to understand their medical, social, academic, psychological and
+psychiatric condition/state prior to any act of alleged victimization. There are a number of
+variables that combine to determine the effects of such alleged victimization, including the
+11
+
+
+Case 9:08-Cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 12 of
+Au6B90Rs8y-8011RıdKAdc. Damminent 247-4 Entered on FLSD D60k87208195/2009 Page92 of 13
+type and character of the alleged assault, plaintifl's knowledge or risk, and key alleged
+victim's variables such as demographics; psychological reactions at the time of the trauma;
+reactions post event; previous psychiatric or psychological history; previous history of
+victimization; current or previous psychological difficulties; general personality dynamics
+and coping style; sociocultural factors such as drug use/abuse; poverty; social inequity
+and/or inadequate social support; any previous history of abuse within or outside the
+family; whether individuals were abused by strangers, acquaintances or family members;
+and whether there was any history of indiscriminate behavior that may have placed them
+at increased risk. It is important to know if there had been previous sexual conduct, contact
+with police or welfare agencies, alcohol or drug use/abuse, voluntary sexual activity,
+contraceptive use, genital infections, or apparent indifference to previous abuse.
+42. It is also essential to understand the plaintiff's level of emotional support,
+whether any significant psychiatric illnesses were present, whether they were taking any
+medications (prescribed or non-prescribed), whether there had been previous suicide
+attempts, thoughts, plans, etc.
+43.
+Knowledge of plaintiff's relationships to her family and familial factors,
+including social disadvantage, family instability, impaired parent/child relationship, and
+parental adjustment difficulties is also critical.
+44.
+It is, therefore, crucial that the independent medical examiner has available to
+12
+
+
+Case 9:08-Cv-80119-KAM Document 317-7 Entered on FLSD Docket 09/21/2009 Page 13 of
+AufasФ8sSy-8011RithAlc. Rapundent 247-4 Entered on FLSD Den*e228165/2009 Pagel13 of 13
+him a full and complete record that includes plaintiff's medical, legal, social, criminal,
+academic, psychological and psychiatricrecords/data; psychological tests; laboratory tests;
+and clinical, hospital, physician records. These, in essence, are the same or similar records
+that plaintiff's expert witness (Dr. Kliman) feels are essential for him to do an appropriate
+evaluation. To obtain the necessary information, it will be necessary to identify the plaintiff
+by name. Such identification will not humiliate the plaintiff since all we are requesting is
+pertinent information as noted above relative to their past medical and psychiatric histories
+and conduct. We would concur and request of the court that the same and such other
+similar information be made available to us so that we are able to conduct a proper and
+meaningful examination of the plaintiff and what, if any contribution the above alleged
+event may have on her current and/or future health and adjustment.
+Respectfully submitted,
+Richard C. W.
+Courtesy Clinical Professor of I'sychiatry, University of Florida, College of Medicine
+Affiliate Professor, Department of Psychiatry and Behavioral Medicine, University of South
+Florida
+Professor of Psychiatry, Department of Medical Education, University of Central Florida
+13
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@@ -0,0 +1,289 @@
+Case 1:19-CV-09610-PAE-DCF Document 2 Filed 10/17/19 Page 1 of 2
+JS 44C/SDNY
+REV. 06/01/17
+CIVIL COVER SHEET
+The JS-44 civil cover sheet and the information contained herein neither replace nor supplement the filing and service of pleadings or
+other papers as required by law, except as provided by local rules of court. This form, approved by the Judicial Conference of the
+United States in September 1974, is required for use of the Clerk of Court for the purpose of initiating the civi docket sheet
+PLAINTIFFS
+JANE DOE 17
+DEFENDANTS
+DARREN K. INDYKE AND RICHARD D. KAHN, AS JOINT PERSONAL
+REPRESENTATIVES OF THE ESTATE OF JEFFREY E. EPSTEIN, ET AL.
+ATTORNEYS (FIRM NAME, ADDRESS, AND TELEPHONE NUMBER
+BUZIN LAW, P.C.
+111 BROADWAY, SUITE 1204
+NEW YORK, NY 10006
+875 Third Avenue
+New York, NY 10022
+CAUSE OF ACTION (CITE THE U.S. CIVIL STATUTE UNDER WHICH YOU ARE FILING AND WRITE A BRIEF STATEMENT OF CAUSE)
+(DO NOT CITE JURISDICTIONAL STATUTES UNLESS DIVERSITY)
+BATTERY, 18 USC ss. 1591, 1592, 1593, 1594, 1595
+Has this action, case, or proceding, or one essentally the same been previously fled in SONY at any time? No ves ditherine Polk Failla
+If yes, was this case Vol. • Invol. • Dismissed. No [X Yes • If yes, give date
+_ & Case No.
+Is THIS AN INTERNATIONAL ARBITRATION CASE?
+No X
+Yes L
+NATURE OF SUIT
+(PLACE AN (x] IN ONE BOX ONLY)
+TORTS
+ACTIONS UNDER STATUTES
+CONTRACT
+PERSONAL INJURY
+| 110
+INSURANCE
+1310 AIRPLAN
+] 120
+] 130
+MARINE
+1 315 AIRPLANE PRODUC
+ACT
+[ ] 140
+REGOTIABLE
+LIABILITY
+I 1320 ASSAULT, LIBEL S
+INSTRUMENT
+1 1 150
+RECOVERY OF
+SLANDER
+I 1330 FEDERAL
+OVERPAYMENT &
+ENFORCEMENT
+EMPLOYERS
+LIABILITY
+OF JUDGMENT
+11152
+MEDICARE ACT
+11340 MARINE
+| 345 MARINE PRODUCT
+RECOVERY OF
+LIABILITY
+DEFAULTED
+] 350 MOTOR VEHICLE
+STUDENT LOANS
+I 355 MOTOR VEHICLI
+(EXCL VETERANS)
+PRODUCT LIABILITY
+1] 153
+RECOVERY OF
+[M 360 OTHER PERSONAL
+OVERPAYMENT
+INJURY
+OF VETERANS
+I 1382 PERSONAL INJURY -
+BENEFITS
+MED MALPRACTICE
+1] 150
+STOCKHOLDERS
+SUITS
+[1190
+OTHER
+PRISONER PETITIONS
+1]195
+CONTRACT
+] 483 ALIEN DETAINE
+CONTRACT
+1510 MOTIONS T
+PRODUCT
+ACTIONS UNDER STATUTES
+VACATE SENTENCE
+LIABILITY
+28 USC 2255
+[ ] 196 FRANCHISE
+CIVIL RIGHTS
+| 1530 HABEAS CORPUS
+i 535 DEATH PENALTY
+[1440 OTHER CIVIL RIGHTS
+[ 1540 MANDAMUS & OTHER
+REAL PROPERTY
+(Non-Prisoner)
+| 1441 VOTING
+11210
+CONDEMNATION
+11250
+FORECLOSURE
+DISABILITIES -
+11200
+TORT PRODUCT
+EMPLOYMENT
+11446 AMERICANS WITH
+11280
+LIABUTY
+DISABILITIES -OTHER
+ALL OTHER
+11443 EDUCATION
+REAL PROPERT
+PSST HER THERED
+FORFEITURE/PENALTY
+PHARMACEUTICAL PERSONAL [ 1825 DRUG RELATED
+INJURY/PRODUCT LIABILITY
+SEIZURE OF PROPERTY
+[ ] 365 PERSONAL INJURY
+PRODUCT LIABILITY
+21 USC 881
+BANKRUPTCY
+1 1422 APPEAL
+28 USC 158
+| ] 423 VTHDRAWAL
+28 USC 157
+1 1368 ASBESTOS PERSONAL 11680 OTHER
+INJURY PRODUCT
+LIABILITY
+PROPERTY RIGHTS
+PERSONAL PROPERTY
+| 1820 COPYRIGHTS
+| 830 PATENT
+STO OTHER FRA
+371 TRUTH IN LEND:
+| 1835 PATENT-ABBREVIATED NEW DRUG APPLICATION
+[ 1840 TRADEMARK
+| 1380 OTHER PERSONAL
+PROPERTY DAMAGE
+I 1385 PROPERTY DAMAGE
+PRODUCT LIABILITY
+LABOR
+I 1710 FAIR LABOR
+STANDARDS ACT
+1 1720 LABOR/MGMT
+RELATIONS
+1 1740 RAILWAY LABOR ACT
+[ 1 751 FAMILY MEDICAL
+LEAVE ACT (FMLA)
+I 1 790 OTHER LABOR
+LITIGATION
+I 1791 EMPL RET INC
+SECURITY ACT (ERISA)
+IMMIGRATION
+PRISONER CIVL RIGHTS
+I1482 NATURALIZATION
+APPLICATION
+SOCIAL SECURITY
+11861 HIA(13850
+| 1 862 BLACK LUNG (922
+663 DIWC/DIV (405(g)
+[ ] 864 SSID TITLE XVI
+1865 R$I (405(g))
+OTHER STATUTES
+I 1375 FALSE CLAIMS
+[ 1378 QUI TAM
+[ 1400 STATE
+REAPPORTIONMENT
+1410 ANTITRUS
+| 430 BANKS & BANKINI
+1450 COMMERCE
+I 1 480 DEPORTATION
+i 1 470 RACKETEER INFLU-
+ENCED & CORRUPT
+ORGANIZATION ACT
+(RICO)
+1140 CORSET TOTE
+CABLE/SATELLITE TV
+I 1850 SECURITIES/
+COMMODITIES/
+EXCHANGE
+FEDERAL TAX SUITS
+I 1890 OTHER STATUTORY
+ACTIONS
+| 1891 AGRICULTURAL ACTS
+[ 1870 TAXES (U.S. Ptaintiff or
+Detendant)
+1 1 871 IRS-THIRD PARTY
+26 USC 7609
+I 1893 ENVIRONMENTAL
+MATTERS
+I 1895 FREEDOM OF
+INFORMATION AC
+1109 ASTRATIE
+PROCEDURE ACT/REVIEW OR
+APPEAL OF AGENCY DECISION
+Check it demanded in complaint:
+CHECK IF THIS IS ACLASS ACTION
+JNDER F.R.C.P. 23
+DEMAND $_
+OTHER
+Check YES only if demanded in complain
+JURY DEMAND: @ YES ONC
+DO YOU CLAIM THIS CASE IS RELATED TO A CIVIL CASE NOW PENDING IN S.D.N.Y.
+AS DEFINED BY LOCAL RULE FOR DIVISION OF BUSINESS 13?
+IF SO, STATE:
+JUDGE _
+DOCKET NUMBER
+NOTE: You must also submit at the time of filling the Statement of Relatedness form (Form IH-32).
+
+
+Case 1:19-cv-09610-PAE-DCF Document 2 Filed 10/17/19 Page 2 of 2
+(PLACE AN x IN ONE BOX ONLY)
+* 1 Original
+Proceeding
+• 2 Removed from
+State Court
+• a. all parties represented
+ORIGIN
+3 Remanded
+• 4 Reinstated or
+from
+Reopened
+Appellate
+Court
+] 5 Transferred from • 6 Mutteistrict
+(Specify District)
+Litigatior
+•7 Appeal to District
+Judge from
+(Transferred)
+Magistrate Judge
+•8 Mutidistrict Litigation (Direct File)
+• b. At least one party
+is pro se.
+(PLACE AN x IN ONE BOX ONLY)
+BASIS OF JURISDICTION
+• 1 U.S. PLAINTIFF •2 U.S. DEFENDANT [X] 3 FEDERAL QUESTION
+•4 DIVERSITY
+IF DIVERSITY, INDICATE
+CITIZENSHIP BELOW.
+(U.S. NOT A PARTY)
+CITIZENSHIP OF PRINCIPAL PARTIES (FOR DIVERSITY CASES ONLY)
+(Place an (X] in one box for Plaintiff and one box for Defendant)
+CITIZEN OF THIS STATE
+CITIZEN OF ANOTHER STATE 12 | 12
+CITIZEN OR SUBJECT OF A
+TF DE
+131*
+FOREIGN COUNTRY
+CORPORATED or PRINCIPAL PLACE [ 14[ ]
+F BUSINESS IN THIS STAT
+CORPORATED and PRINCIPAL PLACE i]5 [
+• BUSINESS IN ANOTHER STA
+FOREIGN NATION
+116 116
+PLAINTIFF(S) ADDRESS(ES) AND COUNTY(IES)
+JANE DOE 17
+FLORIDA
+DEFENDANT(S) ADDRESS(ES) AND COUNTY(IES)
+Darren K. Indyke, 575 Lexington Ave., 4th Floor, New York, NY 10022
+Richard D. Kahn, 919 Third Ave, New York, NY 10022
+Nine East 71st Street Corporation, c/o Darren K. Indyke, Esq. (see above)
+HBRK Associates, Inc., 1365 York Avenue, Apartment 28, New York, NY 10021
+DEFENDANT(S) ADDRESS UNKNOWN
+REPRESENTATION IS HEREBY MADE THAT, AT THIS TIME, I HAVE BEEN UNABLE, WITH REASONABLE DILIGENCE, TO ASCERTAIN
+THE RESIDENCE ADDRESSES OF THE FOLLOWING DEFENDANTS:
+Laurel, Inc., Financial Trust Company, Inc., NES, LLC, Maple, Inc, LSJE, LLC, Nautilus, Inc., Cypress,
+Inc., JEGE, Inc.
+COURTHOUSE ASSIGNMENT
+I hereby certify that this case should be assigned to the courthouse indicated below pursuant to Local Rule for Division of Business 18, 20 or 21.
+Check one: THIS ACTION SHOULD BE ASSIGNED TO:
+DATE 10/17/2019 SIGNATURE OF ATTORNEY OF RECORD
+RECEIPT #
+Magistrate Judge is to be designated by the Clerk of the Court.
+Magistrate Judge.
+Ruby J. Krajick, Clerk of Court by
+Deputy Clerk, DATED
+UNITED STATES DISTRICT COURT (NEW YORK SOUTHERN)
+PLAINS
+X MANHATTAN
+I NOTED TO PRACTICE IN THIS DISTRICT
+IN YES (DATE ADMITTED Mo.11
+_ Yr. 2007
+Altorney Bar Code # 4453890
+is so Designated.
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diff --git a/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.md b/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.md
new file mode 100644
index 0000000000000000000000000000000000000000..f4ef319741a249744b5d8f8512263d67995eea00
--- /dev/null
+++ b/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.md
@@ -0,0 +1,97 @@
+Case 9:08-cv-80232-KAM Document 140-2 Entered on FLSD Docket 03/12/2010 Page 1 of 3
+Dep
+IN THE CIRCUIT COURT OF THE 15™H
+JUDICIAL CIRCUIT IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+Case No: 502008CA37319XXXX MB AB
+B.B.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PLAINTIFF'S NOTICE OF TAKING VIDEOTAPED DEPOSITION
+PLEASE TAKE NOTICE THAT THE UNDERSIGNED ATTORNEY WILL TAKE THE DEPOSITION OF:
+NAME:
+DATE AND TIME:
+Jean Lue Bruhel
+LOCATION:
+November 3, 2009
+Esquire Court Reporters
+10:00 AM
+515 N. Flagler Drive
+West Palm Beach, FL 33401
+upon an oral examination before a Notary Public or officer authorized by law to take depositions in
+the State of New York. The oral examination will continue from day to day until completed. The
+depositions are being taken for purposes of discovery, for use at trial or are being taken for such
+other purposes as are permitted under the Rules of the Court
+WE HEREBY CERTIFY that a true and correct copy of this Notice was mailed this
+day of October, 2009 to: Jack A. Goldberger, Esq., 250 Australian Avenue, Suite 1400, West Palm
+Beach, FL 334101; Bruce E. Reinhart, Esq., 250 Australian Avenue South, Suite 1400, West Palm
+Beach, FL. 33401; Robert D. Critton, Jr., Michael J. Pike, 515 North Flagler Drive, Suite 400, West
+Palm Beach, FL 33401.
+LEOPOLD-KUVIN, P.A.
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+(561) 515-190
+(561) 515-140
+By:_
+Spencér//
+Kuvin, Esq.
+Florida Bar No: 089737
+CO,SE, DI
+
+
+Case 9:08-CV-80232-KAM Document 140-2 Entered on FLSD Docket 03/12/2010 Page 2 of 3
+Depo
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION
+L.M.,
+)
+Plaintiff,
+CASE NO.: 502008CA028051XXXXMB AD
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+)
+NOTICE OF TAKING DEPOSITION
+PLEASE TAKE NOTICE that the attorney for Defendant in the above-styled
+cause will take the deposition of Jean Luc Bruhnel on November 3, 2009 at 10:00
+a.m. for the purposes of discovery at the following location:
+Esquire Court Reporters
+515 N Flagler Dr
+West Palm Beach, FL 33401-4321
+Said deposition will be taken before Esquire Court Reporters, a Notary Public or
+any officer authorized to administer oaths by the laws of the State of Florida, and a
+person who is neither a relative, nor employee, nor attorney, nor counsel of any of the
+parties and who is neither a relative nor employee of such attorney or counsel, and who
+is not financially interested in the action.
+Said deposition will be taken pursuant to Florida Rules of Civil Procedure in such
+cases provided. Said oral examination will continue from hour to hour and from day to
+day until completed.
+D
+
+
+Case 9:08-cv-80232-KAM Document 140-2 Entered on FLSD Docket 03/12/2010 Page 3 of 3
+Case No. 502008CA028051XXXXMB AD
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been served
+via U.S. Mail and Facsimile this ZUk day of October, 2009 to: Michael Burman, Esq., &
+Robert D. Critton, Jr., Esq., Burman, Critton, et al., 515 North Flagler Drive, Suite 400,
+West Palm Beach, FL 33401; Jay Howell, Esq., Jay Howell & Assoc., 644 Cesery
+Boulevard, Suite 250, Jacksonville, FL 32211; and Jack Alan Goldberger, Esq., Atterbury
+Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401
+and a courtesy copy to Tama Kudman, Esq., 444 PGA Boulevard, Suite 600, West Palm
+Beach, Florida 33410.
+ROTHSTEIN ROSENFELDT ADLER
+Attorneys for Plaintiff
+401 East Las Olas Blvd., Suite 1650
+Fort Lauderdale, Florida 33394
+Telephone (954) 522-3456
+Telecopier (954) 527-8663
+ERR
+Florida Bar No. 542075
+bedwards@rra-law.com
+William J. Berger
+Florida Bar No. 197701
+wberger@rra-law.com
diff --git a/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.receipt.json b/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..795d164de07dd03dd1b5960df7b500a345dc2337
--- /dev/null
+++ b/vision-fixhub/court-01/fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "fda92558e2b84a36389d9f27c6195a11260819015fbc9f9e378b174b0690e151",
+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "b0a385c9061a9ae83d7ccc602f90920a9dad239a5939ced8cc30ee48d3f81c05",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.md b/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.md
new file mode 100644
index 0000000000000000000000000000000000000000..0b88d0f345a121ed90bc449a51376bf356e6f8c8
--- /dev/null
+++ b/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.md
@@ -0,0 +1,99 @@
+Case 9:08-cv-80119-KAM Document 526-2 Entered on FLSD Docket 04/12/2010 Page 1 of 3
+11:09
+P.02
+In Reply, Please Refer lo
+Pile No.
+U.S. Department of Justice
+Federal Bureau of Investigation
+16320 N.W. 2nd Avenue
+North Miami Beach, Florida 33169
+March 16, 2010
+Sent Via Facsimile & U.S, Mail
+Jessica D. Arbour, Esc
+fermelstein & Horowitz, PI
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Re: Jane Doe 2-7 v. Jeffrey Epstein
+Dear Ms. Arbour:
+We are in receipt of your subpoena and letter dated March 12, 2010. Please be
+dvised that the PBI response to this request is governed by the provisions of Title 28, Code o
+'ederal Regulations (CFR), Section 16.21 et seg, and the Privacy Act (Title 5, United State
+code, section 552a). These regulations specify that no employee of the Department of Justice
+›ast or present, shall in response to a demand, produce or disclose information unless there is
+complance with the applicable provisions. The procedure is mandatory and governs state and
+federal proceedings and has been upheld in the United States Supreme Court, See U.S. ex rel
+Touhy v. Ragen, 340 U.S. 462 (1951).
+i agency records pertaining to an individual, or information from those records, for a non-lav
+entorcement purpose. The FBI may not disclose this information without the notarized writter
+As you noted in your letter you will seek a court order allowing for the release of
+regulations, we must receive the notarized consent or Privacy Act Order before any documents
+
+2
+
+
+Case 9:08-cv-80119-KAM Document 526-2 Entered on FLSD Docket 04/12/2010 Page 2 of 3
+P.03
+Aponte at (305) 787-6727.
+Should you require further assistance, please contact Paralegal Specialist Deyanira
+Very Truly Yours,
+JOHN V. GILLIES
+Special Agent in Charge
+Maces
+NAVAS
+Chiet Division Counsel
+2
+TOTAL P.03
+
+
+Case 9:08-cV-80119-KAM Document 526-2 Entered on FLSD Docket 04/12/2010 Page 3 of 3
+11:09
+FD-448
+Revised
+10-27-2004
+• Immediate
+r Top Secret
+r Secret
+Name of Office:
+Mermelstein & Horowitz PA
+Atto:
+Jessica D. Arbour, Esq.
+Name of Office:
+FBI Miami, Chief Division Counsel
+Originator's Name:
+PLS Deyanira Aponte
+Approved:
+FN
+Subject:
+Jane Does 2-7 v. Jeffrey Epstein
+P.01
+FEDERAL BUREAU OF INVESTIGATION
+FACSIMILE COVER SHEET
+PRECEDENCE
+Priority
+CLASSIFICATION
+r. Confidential
+TO
+C. Routine
+( Sensitive
+Unclassified
+FROM
+Originator's Telephone Number:
+(305) 787-6727
+Facsimile Number
+1(305) 931-0877
+Room:
+Date:
+|03/16/2010
+Telephone Number:
+(305) 931-2200
+Number of Pages: (including cover)
+Originator's Facsimile Number:
+| (305) 787-6124
+DETAILS
+Special Mandling Instructions:
+Please review and provide FR compliance letter & Privacy Act Order to Chief Division Counsel l
+Navas.
+Brief Description of Communication Faxed:
+reportion, taste to or use is a s or i rented 1a. . , es ended re renter or are on decisir, l
+immediately to arrange for proper disposition.
+FD-448 (Revised 10-27-2004)
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.receipt.json b/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..21e1a0f4944c64600b92320e0f81cb1eca442522
--- /dev/null
+++ b/vision-fixhub/court-01/fdd35bb980c8b2d0716c9e88147d6553c7ef43a59d75307707f83adf7c0bb624.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "127a13ba42978abda6c395dbca27f84ffe807a710c57fd58aecf7d6bbd5d13ba",
+  "output_sha256": "10cb85f9f90bfd92f2fa90e9ebc5ce5af473390001a00004c1312287a986940b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.md b/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.md
new file mode 100644
index 0000000000000000000000000000000000000000..c7d7c2a2dd3d77cd70196a04a938444582e35372
--- /dev/null
+++ b/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.md
@@ -0,0 +1,86 @@
+Case 1:20-cv-00484-JGK-DCF Document 108
+Filed 05/26/21 Page 1 of 3
+USDS SDNY
+DOCUMENT
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF NEW YORK
+ELECTRONICALLY FILED
+DOC#:
+JANE DOE,
+DATE FILED:
+5-26-21
+Plaintiff,
+20-cv-484 (JGK)
+- against -
+ORDER
+DARREN K. INDYKE, ET AL.,
+Defendants.
+JOHN G. KOELIL, District Judge:
+Defendant Ghislaine Maxwell may refile her bill of costs by
+June 2, 2021.
+On March 22, 2021, judgment was entered dismissing the case
+on the plaintiff's motion. ECF No. 103. On April 21, 2021, Ms.
+Maxwell filed a bill of costs that was rejected by the Clerk for
+failure to comply with technical filing requirements under the
+Court's Local Rules. ECF No. 104. Ms. Maxwell refiled a bill
+of costs on May 11, 2021, but this filing was untimely. ECE No.
+105.
+Federal Rule of Civil Procedure 54 (d) (1) provides that
+"[ulnless a federal statute, these rules, or a court order
+provides otherwise, costs-other than attorney's fees-should be
+allowed to the prevailing party. . . . The clerk may tax costs
+on 14 days' notice."
+Fed. R. Civ. P. 54(d) (1). Local Civil
+Rule 54.1 (a) provides, in part, that "[w]ithin thirty (30) days
+after the entry of final judgment, . . . unless this period is
+1
+
+
+Case 1:20-cv-00484-JGK-DCF Document 108 Filed 05/26/21 Page 2 of 3
+extended by the Court for good cause shown, any party seeking to
+recover costs shall file with the Clerk a notice of taxation of
+costs by Electronic Case Filing . . . indicating the date and
+time of taxation which shall comply with the notice period
+prescribed by Fed. R. Civ. P. 54, and annexing a bill of
+costs. . . . Any party failing to file a notice of taxation of
+costs within the applicable thirty (30) day period will be
+deemed to have waived costs."
+"The decision to award costs to a prevailing party under
+Fed. R. Civ. P. 54(d) rests within the sound discretion of the
+district court. The directive in Local Rule 54.1 does not
+purport to interfere with that discretion. " Caravalho v. City of
+New York, No. 13-cv-4174, 2018 WL 5312886, at *2 (S.D.N.Y. Oct.
+26, 2018) (internal citations and quotation marks omitted)
+(allowing bill of costs to be filed one day late); see also V-
+Formation, Inc. V. Benetton Grp. SpA, No. 01-cv-610, 2003 WL
+21403326, at *1 (S.D.N.Y. June 17, 2003) ("[E]inal judgment was
+entered on March 18, 2003 and Salomon defendants moved for costs
+on January 16, 2003 under the assumption that the stipulation of
+discontinuance
+entered December 16, 2003 constituted a final
+judgment. Although the bill of costs was filed prematurely, I
+find good cause shown, given the confusion over whether the
+stipulation constituted a final judgment, and no prejudice to
+plaintiff to enlarge the time to submit a bill of costs.").
+2
+
+
+Case 1:20-cv-00484-JGK-DCF Document 108 Filed 05/26/21 Page 3 of 3
+In this case, good cause is shown because the plaintiff
+originally timely filed the bill of costs, but the bill of costs
+was rejected by the Clerk's office for failure to comply with
+the Local Rules.
+There is no significant prejudice to the
+plaintiff to allow for a brief extension to refile the bill of
+costs in compliance with the local Rules. Therefore,
+refile the bill of costs by June 2, 2021. She should
+consult with the Clerk's Office to assure that the form is
+correct
+SO ORDERED.
+Dated:
+New York, New York
+May 26, 2021
+Or Globa
+John G. Koeltl
+United States District Judge
+3
diff --git a/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.receipt.json b/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a7c90b9b0bb1b259774235202b8886e98f02a25e
--- /dev/null
+++ b/vision-fixhub/court-01/fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "fdedc65153a4c75b9daf762b49970d392c06b1d483824f3f5705bf264d6f323e",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "78f3c6d7dabfe9933cf46f557bd62536a9ce5505bdff2a9d9e80c3a5e41e5732",
+  "output_sha256": "7b0e2688f8ba8f13416a3ffe7299b732bd33cdd1d107dd8367d5fb831e8bba40",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.md b/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.md
new file mode 100644
index 0000000000000000000000000000000000000000..2e4a077f84dab833161a7aa495b1250657a4d6aa
--- /dev/null
+++ b/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.md
@@ -0,0 +1,141 @@
+Casse: 202000/BAGGIDDEF Damment7 FletO2820 Pagege of 3
+Troutman Pepper
+875 Third Avenue
+New York, New York 10022
+Sanders LLP
+troutman™
+pepper
+troutman.com
+Bennet J. Moskowitz
+bennet.moskowitz@troutman.com
+Depositions in this action shall be
+stayed pending the Court's resolution
+of defendant Maxwell's motion for a
+stay of all proceedings. Counsel are
+directed to select an alternative
+deposition date for Mr. Indyke in
+September, should Ms. Maxwell's
+motion be denied, in whole or in part.
+Dated: 8/23/2020
+SO ORDERED
+August 20, 2020
+VIA ECF
+The Honorable Debra C. Freeman
+United States District Court
+Southern District of New York
+Daniel
+Moynihan Courthouse
+500 Pearl Street
+DEBRA FREEMAN
+United States Magistrate Judge
+New York, NY 10007
+Re:
+Jane Doe v. Darren K. Indyke and Richard D. Kahn, in their capacities as
+executors of the Estate of Jefferey E. Epstein, and Ghislaine Maxwell,
+No. 1:20-cv-00484-JGK-DCF
+Dear Judge Freeman:
+We represent Defendants Darren K. Indyke and Richard D. Kahn, as Co-Executors
+of the Estate of Jefferey E. Epstein (the "Co-Executors"), in the above-referenced action.
+We write to obtain relief from Plaintiff Jane Doe's ("Plaintiff") refusal to reschedule the
+deposition of Darren K. Indyke, scheduled for August 26, 2020. Given recent case
+developments, holding the deposition next week defies the parties' obligations to promote
+judicial economy and avoid wasting party resources, as well as common sense.
+There are five reasons the deposition should not proceed next Wednesday. First,
+if the deposition occurs next week then Plaintiff will undoubtedly seek to hold another
+deposition at a later date, following the parties' substantial completion of document
+discovery. Per this Court's Order dated August 14, document production has been stayed
+pending the entry of a protective order. The parties are required to make a joint proposal
+to Your Honor regarding the protective order by August 26, the day upon which the
+deposition is currently scheduled. Even if the parties are able to jointly propose, and the
+Court approve, a mutually agreed upon protective order in the next several days (which
+seems unlikely given that we are still waiting on feedback from counsel for the other
+parties), there would not be nearly enough time for the parties to complete their document
+productions, let alone to review each other's productions in preparation for the deposition.
+Regrettably, Plaintiff's counsel has repeatedly refused to confirm that she will not seek to
+further depose Mr. Indyke following the parties' document productions.
+
+
+Casase: 2020001B4GBDDEF Dumument7 flet02820 Pagg₴ af 3
+Robert Glassman, Esq.
+August 20, 2020
+Page 2
+troutman?
+pepper
+The parties' document productions should be completed before the deposition
+proceeds. This will necessarily happen in short order: the Court's Order requires the
+parties to complete their document productions within one week of entry of the protective
+order. Doc. 68 at (P 2.
+Second, for the same reasons that this Court stayed document production pending
+entry of a protective order, it makes no sense to have any depositions proceed until the
+ground rules regarding confidentiality, including with respect to deposition testimony and
+exhibits, are set.
+Third, having the deposition next week would be unduly prejudicial to the Co-
+Executors as the result of Plaintiff's prior failures to provide proper notice of non-party
+discovery. Yesterday, counsel for Plaintiff confirmed for the first time that she has in fact
+received various documents from subpoenaed witnesses, stating in an email:
+Although responsive documents were not produced by these witnesses
+pursuant to the subpoenas, we have recently obtained documentary
+evidence from these witnesses through their counsel. Indeed, we received
+what we expect to be the last of the evidence yesterday. In light of the
+Court's 8/14 Order regarding the current stay of document production in this
+case, we will produce such materials to you once we are permitted to do so
+by the Court.
+However, the fact remains that we do not know the universe of so-called documentary
+evidence that Plaintiff received, when she received it, or from whom. The deposition of
+Mr. Indyke should not proceed while Plaintiff is improperly in sole possession of discovery.
+The Co-Executors have a fundamental right to review discovery materials that may form
+the basis for Plaintiff's deposition questions.
+Fourth, Plaintiff has failed to provide topics about which she will depose Mr. Indyke
+in his capacity as Co-Executor of Mr. Epstein's Estate. (See Fed. R. Civ. P. 30(b)(6) ("In
+its notice or subpoena, a party may name as the deponent a public or private corporation,
+a partnership, an association, a governmental agency, or other entity and must describe
+with reasonable particularity the matters for examination." (emphasis added)).' We
+raised this straightforward, uncontroversial issue multiple times, including by email on
+August 4, 6, 14, 17, and 19; Plaintiff's counsel never responded. During the parties' meetand-confer telephone call on August 10, counsel for Plaintiff said he would confer with his
+' The Committee Notes to the 2007 amendment of Fed. R. Civ. P. 30(b)(6) provide: '[Other entity" is added
+to the list of organizations that may be named as deponent. The purpose is to ensure that the deposition
+process can be used to reach information known or reasonably available to an organization no matter what
+abstract fictive concept is used to describe the organization. Nothing is gained by wrangling over the place
+to fit into current rule language such entities as limited liability companies, limited partnerships, business
+trusts, more exotic common-law creations, or forms developed in other countries." (emphasis added). Mr.
+Indyke is being deposed as the fiduciary of an estate, not solely in his individual capacity.
+
+
+Casese: 2020001B4GGIDDEF Damment Flet02820 Pageg8 8f8 3
+Robert Glassman, Esq.
+August 20, 2020
+Page 3
+troutman™
+pepper
+colleagues and then provide us with a response. Despite this representation and our
+follow-up inquiries, Plaintiff counsel has still not confirmed whether he will be providing a
+list of topics for Mr. Indyke in his capacity as Co-Executor, much less actually provided
+one. If Plaintiff's counsel does not provide such a list, we will be forced to seek relief from
+this Court and the deposition should not proceed until that issue is resolved. Even if
+Plaintiff provides such a list today, we will not have sufficient time between now and next
+Wednesday to consider it, meet and confer with Plaintiff regarding any issues, and, if
+necessary, raise such issues with the Court.
+Fifth, yesterday evening Defendant Ghislaine Maxwell moved to stay this lawsuit
+in light of her ongoing criminal matter, which is currently scheduled for trial next summer.
+There is no reason that discovery should proceed in a piecemeal fashion, either while the
+motion for a stay is pending or during the stay itself.
+When we raised these issues with Plaintiffs counsel, we did not receive a
+substantive response to our concerns. Rather, Plaintiff's counsel stated they "would still
+like to proceed with [the deposition] on 8/26 since that date has already been cleared by
+the parties and has been on calendar for some time now" and "would still like to proceed
+with Mr. Indyke's deposition next week even if [the Co-Executors] still haven't given
+[Plaintiff] documents before then". Despite our requests, no further explanation for
+Plaintiff's position has been provided.
+We have not received an answer to our repeated requests for a time to meet-andconfer today by phone about these and other pressing issues related to Plaintiff's
+discovery deficiencies, which are not as time-sensitive and thus we do not raise at this
+time. However, given the rapidly approaching deposition date and the issues listed
+above, we are left with no choice but to seek the intervention of the Court. We therefore
+respectfully request that the Court order Plaintiff to reschedule Mr. Indyke's deposition for
+a mutually agreeable date after resolution of Ms. Maxwell's motion to stay, Plaintiff's
+disclosure of deposition topics, entry of a protective order, and the parties'
+substantial
+completion of their document productions.
+Very truly yours,
+Bennet J. Moskowitz
+CC:
+Laura Menninger, Esq.
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.receipt.json b/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3e57ef7e4b5633702ecfc544e7700a981feb0b9b
--- /dev/null
+++ b/vision-fixhub/court-01/fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -77,
+  "dataset": "marble-joined",
+  "doc_id": "fe0ce7e9c131f57b9342ff07f278ef011e7077b8a615a1172770caed60ebe05b",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "f986b43c36a4ad4ff83370e18a77281edbcad271a2b9f10a9997cedb4199785f",
+  "output_sha256": "4a5107531db611a745b7be276220ee25b3a976dd7dc42d49e1d77a5faaf9865e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.md b/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.md
new file mode 100644
index 0000000000000000000000000000000000000000..effc09dcf26d562d78631688cf23efcdb918791a
--- /dev/null
+++ b/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.md
@@ -0,0 +1,35 @@
+IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
+FOURTH DISTRICT, 110 SOUTH TAMARIND AVENUE, WEST PALM BEACH, FL 33401
+March 20, 2023
+CASE NO.: 4D23-0536
+L.T. No.:
+502019CA014681
+DAVE ARONBERG, as State Attorney of v. CA FLORIDA HOLDINGS, LLC, Publisher of
+Palm Beach County, Florida
+THE PALM BEACH POST
+Appellant / Petitioner(s)
+Appellee / Respondent(s)
+BY ORDER OF THE COURT:
+ORDERED sua sponte that appellant's March 10, 2023 amended notice of appeal is
+treated as the status report requested by the court's March 6, 2023 order. The above-styled
+appeal shall proceed from both the February 1, 2023 order denying the motion for attorneys'
+fees and March 6, 2023 order denying the motion to alter or amend.
+Served:
+cc: Arthur
+Michael J. Grygiel
+Stephen A. Mendelsohn
+Douglas Wyler
+Lauren R. Whetstone
+Nina D. Boyajian
+Richard J. Scholz
+Clerk Palm Beach Hon. Luis Delgado
+KK
+Lon.
+- Keischlun
+LONN WEISSBLUM, Clerk
+Fourth District Court of Appeal
+s1
+ATE
+OF
+FILED: PALM BEACH COUNTY, FL
+ABRUZZO, CLERK 03/20/2023 04:37:34 PM
diff --git a/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.receipt.json b/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..322b754da4d9dea24148dd973580eb4d362a2d54
--- /dev/null
+++ b/vision-fixhub/court-01/fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "fe15ff081880e7753a64612f95175c1a63db6a4938c8a8fea2ca03a2608e9fe7",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "734be2393483f8d6e5a5490a262014fbb20479ea93c218e8c59d7c0da1982e0e",
+  "output_sha256": "6650d0cab18c16bb0d7899db7ecb6ed59f5822428482357b2f7215f4aaeafe25",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.md b/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.md
new file mode 100644
index 0000000000000000000000000000000000000000..b2f49fd8c1763716428369fe5042eb6c70ec7e22
--- /dev/null
+++ b/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.md
@@ -0,0 +1,174 @@
+Case 9:09-cv-80656-KAM Document 59 Entered on FLSD Docket 11/20/2009 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CIV-80119-MARRAI,
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-08380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+DEFENDANT EPSTEIN'S MOTION TO ATTEND MEDIATION
+AND MEMORANDUM IN SUPPORT THEREOF
+(AS TO CMA v. EPSTEIN AND
+08-CIV-80811)
+Defendant, JEFFREY EPSTEIN, by and through his undersigned attorneys,
+moves this Court for an order allowing him to attend mediation in the above-styled
+matter and as grounds set forth would state:
+The Court entered a no contact order which may apply to
+| [DE 238].
+Plaintiff's counsel and plaintiff,
+have no objection to Mr.
+Epstein attending deposition, mediation and obviously trial.
+3.
+Therefore, Defendant, Jeffrey Epstein, in an abundance of caution,
+requests that the court enter the attached proposed Agreed Order which shall not
+
+
+Case 9:09-cv-80656-KAM Document 59
+Entered on FLSD Docket 11/20/2009 Page 2 of 4
+Page 2
+preclude him from attending Plaintiff
+trial of this case.
+deposition, mediation, or the
+Rule 7.1 Certification
+Defense counsel has spoken with Plaintiff's counsel and he has no objection to
+the entry of the proposed agreed order.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the following Service List in the
+manner specified by CM/ECF on this 20 day of _November_ 2009
+Respectfully submitted,
+By:
+ROBERT D. CRITTON, JR., ESQ.
+Florida Bar No. 224162
+crit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Counsel for Defendant Jeffrey Epstein)
+
+
+Case 9:09-cv-80656-KAM Document 59 Entered on FLSD Docket 11/20/2009 Page 3 of 4
+Page 3
+Certificate of Service
+Jane Doe No. 2 v. Jeffrey Epstein
+Case No. 08-CV-80119-MARRA/JOHNSON
+Stuart S. Mermelstein, Esq.
+Brad
+Esq.
+Adam D. Horowitz, Esq.
+Rothstein Rosenfeldt Adler
+Mermelstein & Horowitz, P.A.
+401 East Las Olas Boulevard
+18205 Biscayne Boulevard
+Suite 1650
+Suite 2218
+Fort Lauderdale, FL 33301
+Miami, FL 33160
+Phone: 954-522-3456
+305-931-2200
+Fax: 954-527-8663
+Fax: 305-931-0877
+bedwards@rra-law.com
+ssm@sexabuseattorney.com
+Counsel for Plaintiff in Related Case No.
+ahorowitz@sexabuseattorney.com
+08-80893
+Counsel for Plaintiffs
+In related Cases Nos.
+08-80069, 08- Paul G. Cassell, Esq.
+80119, 08-80232,
+08-80380, 08-80381, Pro Hac Vice
+08-80993, 08-80994
+332 South 1400 E, Room 101
+Salt Lake City, UT 84112
+Richard Horace Willits, Esq.
+801-585-5202
+Richard H. Willits, P.A
+801-585-6833 Fax
+2290 10* Avenue North
+cassellp@law.utah.edu
+Suite 404
+Co-counsel for Plaintiff Jane Doe
+Lake Worth, FL 33461
+561-582-7600
+Isidro M.
+, Esq.
+Fax: 561-588-8819
+Law Firm, P.A.
+Counsel for Plaintiff in Related Case No.
+224 Datura Street, Suite 900
+08-80811
+West Palm Beach, FL 33401
+reelrhw@hotmail.com
+561-832-7732
+561-832-7137 F
+Jack Scarola, Esq.
+isidrogarcia@bellsouth.net
+Jack P.
+, Esg.
+Counsel for Plaintiff in Related Case No.
+Searcy
+Denney
+Scarola Barnhart & 08-80469
+Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+Robert C. Josefsberg, Esq.
+West Palm Beach, FL 33409
+Katherine W. Ezell, Esq.
+561-686-6300
+Podhurst Orseck, P.A.
+Fax: 561-383-9424
+25 West Flagler Street, Suite 800
+jsx@searcylaw.com
+Miami, FL 33130
+iph@searcylaw.com
+305 358-2800
+Counsel for Plaintiff, C.M.A.
+Fax: 305 358-2382
+rjosefsberg@podhurst.com
+kezell@podhurst.com
+
+
+Case 9:09-cv-80656-KAM Document 59 Entered on FLSD Docket 11/20/2009 Page 4 of 4
+Page 4
+Bruce Reinhart, Esq.
+Bruce E. Reinhart, P.A.
+250 S. Australian Avenue
+Suite 1400
+West Palm Beach, FL 33401
+561-202-6360
+Fax: 561-828-0983
+ecf@brucereinhartlaw.com
+Counsel for Defendant
+Theodore J. Leopold, Esq.
+Spencer T. Kuvin, Esq.
+Leopold, Kuvin, P.A.
+2925 PGA Blvd., Suite 200
+Palm Beach Gardens, FL 33410
+561-684-6500
+Fax: 561-515-2610
+skuvin@leopoldkuvin.com
+Counsel for Plaintiff in Related Case No.
+08-08804
+Counsel for Plaintiffs in Related Cases
+Nos. 09-80591 and 09-80656
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.receipt.json b/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9bc742e2cb3df1b05d86e888e3e35ca130371c05
--- /dev/null
+++ b/vision-fixhub/court-01/fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -127,
+  "dataset": "marble-joined",
+  "doc_id": "fe2292c637a1afc2215da6a6261616ca5017aaf7cad15db95254415e59ad9763",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "5198147b607a4e90eca434e16a3e5e421a5dca4f8bcda624c0c1cbfecae52d86",
+  "output_sha256": "6bb6da1e42a9ebd5d5c367124ee180776cf6f913601ff19a3f20a2059db83c8e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.md b/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.md
new file mode 100644
index 0000000000000000000000000000000000000000..a88f69fcafcb91e46347e047c6a3880c92592e9f
--- /dev/null
+++ b/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.md
@@ -0,0 +1,626 @@
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 1 of 14
+CURRICULUM VITAE
+Ryan C. W.L
+I. M.D.
+Updated 06/17/09
+"G"
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 2 of 14
+TABLE OF CONTENTS
+PRESENT POSITION
+EDUCATION
+MEDICAL LICENSE
+CERTIFICATION
+ADDITIONAL TRAINING
+SOCIETY MEMBERSHIPS, PAST AND PRESENT
+COMMITTEES
+HONORS
+PROFESSIONAL ACTIVITIES
+REVIEWER
+BOOK REVIEWS
+PUBLICATIONS
+ABSTRACTS
+PRESENTATIONS AT NATIONAL AND INTERNATIONAL MEETINGS
+AND INVITATIONAL ACADEMIC LECTURES
+MEDIA
+2
+2
+2
+3
+3
+3
+3
+4
+4
+5
+5
+5
+7
+9
+12
+1
+
+
+Case 9:08-cv-80119-KAM Document 319-7
+Entered on FLSD Docket 09/22/2009 Page 3 of 14
+NAME:
+DATE OF BIRTH:
+PLACE OF BIRTH:
+MARITAL STATUS:
+PRESENT POSITION:
+07/2008 -
+Present
+Ryan Chaloner Winton ||| M.D.
+May 10, 1976
+Titusville, Florida
+Single
+03/01/2008 -
+07/31/2011
+03/03/09 -
+06/30/12
+EDUCATION:
+1995 - 1999
+Psychiatrist
+Richard C. W. || MD, PA
+2500 West Lake Mary Blvd; Ste 219
+Lake Mary, FL 32746
+Ph: 407-322-8199
+Affiliate Instructor
+University of South Florida
+Department of Psychiatry
+Assistant Professor of Psychiatry
+University of Central Florida College of Medicine
+Department of Medical Education
+1999 - 2003
+2003-2004
+2004-2007
+2007 - 2008
+Johns
+University
+Baltimore, Marylanc
+Double Major - Biology and Psychology
+B.A. Degree, graduated Phi Beta Kappa with honors
+Georgetown University School of Medicine
+Washington, DO
+VI.D. Degree
+Internal Medicine Internship
+Sinai Hospital of Baltimore/Johns
+Baltimore, Maryland
+| Hospital
+Desperate and aly and once sonas
+Baltimore, Maryland
+case eternie pee intersity
+Cleveland, Ohio
+2
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 4 of 14
+MEDICAL LICENSE:
+2004
+2007
+2007
+CERTIFICATION:
+2008
+ADDITIONAL TRAINING:
+2006
+2007
+2008
+Maryland - D62746 - Inactive
+Ohio - 89483 - Inactive
+Florida - ME99792
+Diplomate, American Board of Psychiatry and Neurology, #58286
+Forensic Psychiatry Review Course
+American Academy of Psychiatry and the Law, Chicago, IL
+Forensic Psychiatry Review Course
+American Academy of Psychiatry and the Law, Miami Beach, FL
+Florida Forensic Examiner Training
+University of South Florida College of Behavioral and Community
+Sciences, Ft. Lauderdale, FL
+SOCIETY MEMBERSHIPS, PAST AND PRESENT:
+Member, Academy of Psychosomatic Medicine
+Member, American Psychiatric Association
+Member, Maryland Psychiatric Society
+Member, American Academy of Psychiatry and the Law
+Member, American Medical Association
+Member, Ohio Psychiatric Association
+Member, Florida Psychiatric Society
+Member, Southern Psychiatric Association
+Member, The American College of Psychiatrists
+COMMITTEES:
+Public Relations Committee, Maryland Psychiatric Society
+3
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 5 of 14
+2007 - present
+2007 - present
+2007 - 2009
+2008 - 2009
+Legislative Committee, Maryland Psychiatric Society
+Disaster Committee, Maryland Psychiatric Society
+Resident and Fellows Committee, Maryland Psychiatry Society
+Psychopharmacology Committee, American Academy of
+Psychiatry and the Law
+Research Committee, American Academy of Psychiatry and the
+Law
+Corresponding Committee on Graduate Education, American
+Psychiatric Association
+Member, New Member Task Force, Southern Psychiatric
+Association
+HONORS:
+1999
+2004
+2005
+2005
+Phi Beta Kappa, Johns |||||| University
+"Superior" performance rating, 1st-year residency, by Sinai
+Hospital Department of Medicine's Clinical Competency and
+Evaluation Committee
+Dorfman Award, presented by The Academy of Psychosomatic
+Medicine for best review article of the year for Definition,
+Diagnosis, and Forensic Implications of Postconcussional
+Syndrome. Psychosomatics, 46(3):195-202, May-June 2005.
+Rappeport Fellowship, American Academy of Psychiatry and the
+PROFESSIONAL ACTIVITIES:
+2008
+2009
+Written testimony on Elder Abuse in support of bills HB873/SB501
+Criminal Law - Crimes Against the Elderly or Persons with a
+isability - Penalties, presented to Maryland House Judician
+Committee for Delegate
+Kramer, District 19
+county, Maryland. Hearing March
+Central Florida Psychiatric Society representative to Florida
+Psychiatric Society's Council Meeting, January 10.
+4
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 6 of 14
+2009
+Testified before the Florida Senate Banking and Insurance
+Committee (SB 354) on Mental Health Parity. March 17.
+REVIEWER:
+-Archives of Internal Medicine
+-Clinical Geriatrics
+-Disaster Medicine and Public Health Preparedness
+-European Psychiatry
+-Journal of Neuropsychiatry and Clinical Neuroscience
+-Nature Clinical Practice Neurology
+-Neurology India
+-Psychosomatics
+-Social Science & Medicine
+-World Journal of Surgical Oncology
+BOOK REVIEWS:
+1. Clark MR and Treisman GJ: Pain and Depression: An Interdisciplinary, Patient-
+Centered Approach. Psychosomatics, July-August 2006, 47(4)365-366.
+PUBLICATIONS:
+1.
+RCW, Dunlap PK,
+I CA, Blakey RE, L
+J: Thyroid
+disease and abnormal thyroid function tests in patients with eating disorders and
+depression. The Journal of the Florida Medical Association, Inc. 82(3)187-192, 1995.
+2.
+| RCW: Anxiety and Endocrine Disease. In Popkin, MK, Seminars in
+Clinical Neuropsychiatry 4(2)72-83, 1998.
+3.
+RCW,| || DE, || RCW: Suicide Risk Assessment: A Review of Risk
+Factors for Suicide in 100 Patients Who Made Severe Suicide Attempts.
+Psychosomatics 40:(1)18-27, 1999.
+4. M RCW.
+RCW: Fee-Splitting: Ethical Implications and Principles for
+Practice Management. Transference 20(2)14, 1999.
+5. MRcW.
+RCW: Long-term Psychological and Neurological Complications of
+Lindane Poisoning. Psychosomatics 40(6)513-517, 1999.
+6.
+ROW.
+RCW: False Allegations: The Role of the Forensic Psychiatrist.
+Journal of Psychiatric Practice 7(5)343-346, September 2001.
+RCW: Principles of Physician Recruiting. In Handbook of Mental
+5
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 7 of 14
+8.
+9.
+Health Administration and Management; Reid WH and Silver S (ed.): Brunner-
+Routledge, New York, NY; Chapter 34:440-448, 2003.
+RCW, F
+IRCW, Chapman M: Identifying Geriatric Patients at Risk for Suicide
+and Depression. Clinical Geriatrics 11(10)36-44, October 2003.
+ROW,
+RCW: Establishing Liaison Before Disaster Strikes.
+http://www.psych.org/disasterpsych/pdfs/apadisasterhandbk.pdf; Chapter 2:12-19.
+2004.
+10. ROW,
+RCW, Chapman MJ: Emotional and Psychiatric Effects of Weapons
+of Mass Destruction in First Responders. In: Bioterrorism: Psychological and Public
+Health Interventions; Ursano RJ, Norwood AE & Fullerton CS (eds). Cambridge
+University Press:Cambridge; Chapter 14:250-273; 2004.
+11.
+RCW, Appleby B,
+RCW: Atypical Neuroleptic Malignant Syndrome
+Presenting as Fever of Unknown Origin in the Elderly. Southern Medical Journal
+1(98) 114-117, January 2005.
+12.
+IRCW,
+|RCW, Chapman MJ: Exploitation of the Elderly: Undue Influence as
+a Form of Elder Abuse. Clinical Geriatrics 13(2)28-36, February 2005.
+13.
+|IRCW, RCW, Chapman MJ: Definition, Diagnosis, and Forensic
+implications of Postconcussional Syndrome. Psychosomatics, 46(3) 195-202, May-
+June 2005.
+14.
+IRCW,
+RCW: Abuse of Supraphysiologic Doses of Anabolic Steroids.
+Southern Medical Journal, 98(5)550-555, May 2005.
+15.
+RCW
+RCW, Chapman MJ: Psychiatric Complications of Anabolic Steroid
+Abuse. Psychosomatics, 46(4)285-290, July-August 2005.
+16.
+RCW, Chapman MJ: Medical and Psychiatric Casualties caused by
+Conventional and Radiological (Dirty) Bombs. General Hospital Psychiatry,
+28(3):242-248, May-June 2006.
+17. RCW.
+RCW, Chapman MJ: Postconcussional Syndrome: A Work in
+Progress (Response to Dr.
+. Letter to the Editor. Psychosomatics, 47(3):272,
+May-June 2006.
+18.
+RcW,
+RCW, Chapman MJ: Neuroleptic Malignant Syndrome in the
+Elderly: Diagnostic Criteria, Incidence, Risk Factors, Pathophysiology, and
+Treatment. (CME article) Clinical Geriatrics, 14(5):39-46, 2006.
+19.
+RCW, Chapman MJ: Effects of Terrorist Attacks on the Elderly, Part
+I: Medical and Psychiatric Complications of Bombings and Biological, Chemical,
+and Nuclear Attacks. Clinical Geriatrics, 14(8):26-35, 2006.
+20.
+ReW,
+RCW, Chapman MJ: Effects of Terrorist Attacks on the Elderly, Part
+6
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 8 of 14
+2: Posttraumatic Stress, Acute Stress, and Affective Disorders. Clinical Geriatrics,
+14(9):17-24, 2006.
+21. 1| RCW, I
+|| RCW: Malingering of PTSD: forensic and diagnostic
+considerations, characteristics of malingerers and clinical presentations.
+General Hospital Psychiatry, 28(6):525-535, 2006.
+22. || RCW, L
+IRCW: A Profile of Pedophilia: Definition, Characteristics of
+Offenders, Recidivism, Treatment Outcomes, and Forensic Issues. Mayo Clinic
+Proceedings, 82(4):457-471, 2007.
+23.
+RCW, | RCW: Detection of Malingered PTSD: An Overview of Clinical,
+Psychometric, and Physiological Assessment: Where Do We Stand? Journal of
+Forensic Sciences, 52(3): 717-725, 2007.
+24.
+RCW, Macvaugh GS IlI, Merideth P.
+J: Commentary: Delving
+Further Into Liability for Psychotherapy Supervision. The Journal of the American
+Academy of Psychiatry and the Law, 35(2):196-9, 2007.
+25.
+RCW, I
+[RCW, Chapman MJ: Psychiatric Effects of Terrorism: Medical and
+Societal Implications of Recent Attacks. In: Focus on Terrorism, Vol. 9; Linden EV
+(ed), Nova Science:New York; Chapter 11, Publication date: 3'0 Quarter, 2007.
+26.
+| RCW, RCW: The 1995 Kikwit Ebola outbreak - Model of virus properties
+on system capacity and function: A lesson for future viral epidemics. American
+Journal of Disaster Medicine, 2(5):270-276, 2007
+27. L
+RCW, Chapman MJ: Central Serotonin Syndrome: Part I-
+Causative Agents, Presentation, and Differential Diagnosis. Clinical Geriatrics,
+15(12):18-25, 2007.
+28.
+RCW, Chapman MJ: Central Serotonin Syndrome: Part I| -
+Pathophysiology, Drug Interactions, and Treatment. Clinical Geriatrics, 16(1):24-28,
+2008
+29.
+| RCW, Resnick PJ: Psychotherapy Malpractice: New Pitfalls. Journal of
+Psychiatric Practice, 14(2):119-121, 2008
+30.
+| RCW,
+RCW, Chapman MJ: Violence in Older Persons: Part I - Occurrence
+in Forensic/Criminal Situations, Partner Relationships, and Sexual Offenses.
+Clinical Geriatrics, 16(5):27-32, 2008
+31.
+RCW, |||| RCW, Chapman MJ: Violence in Older Persons: Part II -
+Occurrence in Hospitals and Pharmacological/Behavioral Treatment of Agitation,
+Aggression and Violence. Clinical Geriatrics, 16(6): 28-32, 2008.
+32.
+RCW.|| RCW, Chapman MJ. The 1995 Kikwit Ebola outbreak: lessons
+hospitals and physicians can apply to future viral epidemics. Gen Hosp Psychiatry.
+2008 Sep-Oct;30(5):446-52. Epub 2008 Jul 23
+7
+
+
+Case 9:08-cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 9 of 14
+33.
+| RCW,
+SH: Drug Diversion Program Rights. Legal Digest. The Journal
+of the American Academy of Psychiatry and the Law, 36(4):579-580, 2008
+34.
+RCW, Chapman MJ: Nursing Home Violence: Occurrence, Risks,
+and Interventions. Annals of Long-Term Care, 17(1):25-31, 2009
+35. Paul RK, Lockey C,
+| RCW, Bursztajn H: Practice Management: Managing Risks
+When Practicing in Three-Party Care Settings. Psychiatrictimes.com, 26(2), Feb. 3,
+2009.
+36. |
+RCW, Chapman MJ: Letter to the Editor response re: Nursing Home
+Violence: Occurrence, Risks, and Interventions) Annals of Long-Term Care,
+17(1):25-31, 2009), Annals of Long-Term Care, 17(4):17-21, 2009.
+37. | RCW.||| RCW, Myers W, Chapman M: Testamentary Capacity: History,
+Physicians' Role, Requirements, and Why Wills are Challenged. Clinical Geriatrics,
+in press.
+* Boldface indicates Ryan C. W. I, MD
+ABSTRACTS:
+1. || RCW, Hazard SC, I RcW.
+I CA, Blakey RE, L
+J: Thyroid
+Disease in Eating Disordered and Depressed Patients.
+- 146th Annual Meeting, American Psychiatric Association, May 25, 1993, San
+Francisco, CA, P.1.57 (Poster Session).
+2. MRcW, MI DE, || RCW: Suicide Risk Assessment: A Review of Risk
+Factors for Suicide in 100 Patients Who Made Severe Suicide Attempts:
+Evaluation of Suicide Risk in a Time of Managed Care.
+- Psychiatric Practice and Managed Care, American Psychiatric Association, Vol. 5,
+No. 5, P 12, Sept-Oct 1999.
+3.
+|I RCW, Gould N, McCann U, McKibben J: The Role of Morphine in the
+Development of Acute Stress Disorder and Posttraumatic Stress Disorder in
+Patients with Severe Burn Injury
+- 418 Annual Meeting, American Burn Association. San Antonio, TX, Mar 25, 2009.
+4. Gould N, McCann U, McKibben J,
+RCW: Peri-traumatic Heart Rate as a
+Predictor of Acute Stress Disorder and Post-traumatic Stress Disorder ir
+Patients with Burn Injury.
+8
+
+
+Case 9:08-Cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 10 of
+- 418 Annual Meeting, American Burn Association. San Antonio, TX, Mar 25, 2009.
+* Boldface indicates Ryan C. W._
+LI, MD
+PRESENTATIONS AT NATIONAL AND INTERNATIONAL MEETINGS AND INVITATIONAL
+ACADEMIC LECTURES:
+1.
+| RCW, Hazard SC, Dunlap PK,
+| RcW,
+, CA, Blakey RE,
+•J:
+Thyroid disease and abnormal function tests in patients with eating disorders
+and depression. Poster Session - American Psychiatric Association Annual
+Meeting, San Francisco, CA, May 25, 1993
+- RCW,
+RCW: Management of Hostage Situations. Psychiatric Responses
+to Trauma, U.S. State Department Conference on International Terrorism, hosted by
+Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999
+3.
+Row,
+RCW: Terrorism: Its Aftermath and Long-term Effects on
+Survivors - A Consultation-Liaison Perspective -- Part I. Psychiatric Responses
+to Trauma, U.S. State Department Conference on International Terrorism, hosted by
+Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999
+4.
+RCW: Terrorism: Its Aftermath and Long-term Effects on
+Survivors - A Consultation-Liaison Perspective - Part II. Psychiatric Responses
+to Trauma, U.S. State Department Conference on International Terrorism, hosted by
+Uniformed Services University of Health Sciences, Washington, D.C., April 28, 1999
+5.
+• RCW.L
+|| RCW,
+| DE: Impact of Managed Care on Suicide Risk
+Assessment. American Academy of Psychiatry and the Law, 1999 Annual Meeting.
+Baltimore, MD, October 15, 1999
+6.
+|| RCW: Ethical Issues in Managed Care. American Psychiatric
+Association, 1999 Ethics Workshop, Washington, DC, November 3, 1999
+7.
+RCW: Terrorism, Bioterrorism and Disaster - Aftermath and
+Long-term Effects on Survivors. Cycle of Violence: Assessment and Management
+of Aggression - A Mardi Gras Symposium, Tulane University, New Orleans, LA,
+February 26, 2000
+8.
+•Rcw, I
+| RCW: Bioterrorism - Dealing with Medical and Psychiatric
+Consequences of Victims and Responders. Cycle of Violence: Assessment and
+Management of Aggression - A Mardi Gras Symposium, Tulane University, New
+Orleans, LA, February 26, 2000
+9.
+RCW: Psychiatric Consequences of Terrorism, Bioterrorism and
+Disaster. Rocky Mountain Emotional Trauma Symposium, Pathways Treatment
+Center, Kalispell, MT, June 29, 2000
+10. I RCW. | RCW: Suicide in an Era of HMO's and Managed Care. Rocky
+9
+
+
+Case 9:08-Cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 11 of
+Mountain Emotional Trauma Symposium, Pathways Treatment Center, Kalispell, MT,
+June 30, 2000
+11. | RCW, L
+|||RCW: Psychological Response to Disasters and Terrorism.
+International Society of Political Psychology, 23rd Annual Scientific Meeting, Seattle,
+WA, July 4, 2000
+12. || RCW,
+|RCW: Biological Warfare - Attack Scenarios, Response to
+Terrorist Attacks, and Sources of Conflict. American Academy of Psychiatry and
+the Law, Pre-AAPL meeting, Ireland, September 16-26, 2000
+13. RCW,
+RCW, Chapman M: Workplace Violence. American Academy of
+Psychiatry and the Law, Pre-AAPL meeting, Ireland, September 16-26, 2000
+14. | RCW,|
+RCW: Biological Warfare: Attack Scenarios and Public Health
+Issues. Grand Rounds, Hennepin County Medical Center, Minneapolis, MN,
+December 8, 2000
+15. || RCW,
+|RCW: Bioterrorism: A Short History of Biowarfare & Analysis of
+the Threat. Grand Rounds, Mayo Clinic, Jacksonville, FL, August 15, 2001
+16. | RCW,||RCW: Situational Suicide. Halifax Medical Center, Daytona Beach,
+FL, September 13, 2001
+17.
+RoW,
+RCW: Domestic Violence: The Physician's Role. Halifax Medical
+Center, Daytona Beach, FL, September 14, 2001
+18. RCW,
+RCW: Terrorism, Bioterrorism and Assault with Anthrax as a
+Biological Weapon.
+-Florida Psychiatric Society, Fall Meeting, Coconut Grove, FL, November 4, 2001
+-Grand Rounds, Louisiana State University Health Sciences Center, Shreveport, LA,
+January 30, 2002
+19.
+RCW: Smallpox. Grand Rounds, Louisiana State University Health
+Sciences Center, Shreveport, LA, January 30, 2002
+20.
+RCW: Psychopharmacology - Forensic Risk and Clinical
+Practice: Things the clinician must know. Apopka Community Health Center
+Apopka, FL, March 13, 2002
+21.
+RCW: Overview of Terrorism and Bioterrorism. Orlando Police
+Academy, Orlando Police Department, Orlando, FL, August 2, 2002
+22.
+IRCW,
+RCW: Workplace Violence, School Shootings and Occupations
+at Risk: Analysis of current data and psychological profiles. Orlando Police
+Academy, Orlando Police Department, Orlando, FL, August 2, 2002
+23.
+RCW: Smallpox as a Biological Weapon. Orlando Police
+10
+
+
+Case 9:08-Cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 12 of
+Academy, Orlando Police Department, Orlando, FL, August 2, 2002
+24. 1
+|IRCW,
+RCW: Smallpox as an Agent for Biological Warfare. Southern
+Psychiatric Association Annual Meeting, Loews Ventana Canyon Resort, Tucson, AZ,
+October 3, 2002
+25. 1
+_IRCW,
+|IRCW: Domestic Violence: The Physician's Role. Mandatory
+Madness, Halifax Medical Center, Daytona USA, Daytona Beach, FL, December 14,
+2002
+26. | /RCW, |||| RCW, Chapman MJ: Workplace Violence, School Shootings and
+Occupations at Risk: Analysis of current data and psychological profiles.
+Orlando Police Department, Orlando, FL, February 11, 2003
+27.
+IRCW, I
+]RCW: Medical and Psychological Sequelae of Bombings:
+Implications for First Responders and Critical Government Staff. Orlando Police
+Department, Orlando, FL, February 11, 2003
+28.
+ROW,
+RCW: Domestic Violence: The Physician's Role. Florida
+Psychiatric Society Spring Meeting, Orlando, FL, April 5, 2003
+29. | RCW, |||RCW: Terrorist Bombings: Medical and Psychiatric Impact.
+Southern Psychiatric Association's Annual Meeting, Nashville, TN, October 11, 2003
+30.
+RCW: Terrorism, Bombings, and Psychiatric Casualties.
+University of Florida, Department of Psychiatry, Visiting Professor Program,
+November 7, 2003
+31.
+RCW: Domestic Violence: The Physician's Role. Tampa Bay
+Psychiatric Society, Tampa, FL, sponsored by Pfizer, January 29, 2004
+32.
+RCW: Smallpox as an Agent for Biological Warfare. Orlando
+Police Academy, Orlando Police Department, Orlando, FL, August 13, 2004
+33.
+RCW: Medical and Psychiatric Casualties of Terrorist Bombings.
+Orlando Police Academy, Orlando Police Department, Orlando, FL, August 13, 2004
+34. RCW,
+RCW: Medical and Psychological Consequences of Bombings
+Grand Rounds, Tulane University, Department of Psychiatry, New Orleans, LA
+January 28, 2005
+35.
+ROW,
+RCW: Psychological Sequelae of Weapons of Mass Destruction
+on First Responders. South Central Center for Public Health
+Preparedness/Alabama Department of Public Health,
+AL, Satellite
+Conference, May 6, 2005
+36. | RCW
+RCW: Medical and Psychological Aspects of Terrorist Bombings.
+Grand Rounds, Sinai Hospital, Department of Medicine, Baltimore, MD, June 2, 2005
+
+
+Case 9:08-Cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 13 of
+37.
+RCW: Managed Care Disrupting the Physician-Patient
+Relationship: The New Realities. (Abbreviated version) Forensic Psychiatry
+Fellows and Residents, University of Florida, Gainesville, FL, January 24, 2006
+38.
+IRCW.
+RCW, Chapman MJ: Managed Care Disrupting the Physician-
+Patient Relationship: The New Realities. Presidential Address. Southern
+Psychiatric Association, Baltimore, MD, September 30, 2006.
+39.
+RCW: When the System is Overwhelmed: Protecting the
+Provider during Biodisaster. Satellite Conference, University of Alabama
+Birmingham South Central Center for Public Health Preparedness/Alabama
+Department of Public Health/Tulane University School of Public Health,
+AL, February 27, 2007.
+40.
+RCW: Testamentary Capacity from Isaac Ray to Anna Nicole
+- Grand
+Rounds, Case Western Reserve School of Medicine, Cleveland,
+March 28, 2008
+41.
+]IRCW,
+RCW, Rundell JR, Winstead DK: Psychiatrists' Role in Disaster
+Management: Lessons Learned. Course 14, American Psychiatric Association,
+Annual Meeting, Washington, DC, May 3, 2008.
+42.
+RCW: Violence in the Elderly: Forensic and Treatment Concerns. Forensic
+Forum, Florida Psychiatric Society, ChampionsGate, FL, September 20, 2008.
+43.
+RCW: Testamentary Capacity: From Isaac Ray to Anna Nicole
+Southern Psychiatric Association, September 25, 2008.
+44.
+RCW: Testamentary Capacity: From Isaac Ray to Anna Nicole
+Forensic Psychiatry Program, University of South Florida, Tampa, FL, January 29,
+2009.
+45.
+RCW: Domestic Violence as Portrayed in Film - A Realistic
+Appraisal? Florida Psychiatric Society, St. Petersburg Beach, FL, March 20, 2009.
+46.
+RCW, Silberman E, Preven D, Weissman S (chairperson): Indications for the
+Use of Combined Talking Therapy and Pharmacotherapy and How to Teach in
+Residency. Corresponding Committee on Graduate Education, CW16, American
+Psychiatric Association, San Francisco, CA, May 19, 2009.
+* Boldface indicates Ryan C. W.
+I MD
+MEDIA:
+1. Time Magazine, Definition, Diagnosis, and Forensic Implications of
+Postconcussional Syndrome, May 16, 2005
+2. Reach MD Radio, Pedophilia. April 25, 2007
+12
+
+
+Case 9:08-Cv-80119-KAM Document 319-7 Entered on FLSD Docket 09/22/2009 Page 14 of
+3. MD Consult. Doug
+1. Joint telephone interview with Richard C. W. I
+, MD,
+Pedophilia. May 2, 2007
+4. The Korean Broadcasting System, KBS Special, Pedophilia. March 11, 2008.
+5. Tony Pipitone, WKMG-TV Channel 6, Mothers Who Kill Their Children. October 28,
+2008.
+6. J.L.
+Orlando Medical News. Cyberchondriacs. November 13, 2008.
+7. Fox 35 News, Orlando. Forensic Implications of Anthony case. December
+11,2008.
+8. 50x35 News, Orlando. The Anthony Case: DNA Evidence. December 12,
+9. Jessica
+1: WKMG-TV Channel 6. The
+Anthony Case: Baker Act and
+Stressors. January 23, 2009.
+10. Nam Nae Won and Jihyun Song. Korea Educational Broadcasting System.
+Pedophilia. March 30, 2009.
+1. Kuth 15,20,5 x 35 News, Orlando. Effects of Stress and Financial Strain
+12. Heidi Hatch, Fox 35 News, Orlando. Effects of Stress on Families. June 16, 2009.
+13
\ No newline at end of file
diff --git a/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.receipt.json b/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3c15b583913e522f443f0dbd73543f2799617d2c
--- /dev/null
+++ b/vision-fixhub/court-01/fe2365a80e920c3a6206c8e1fd39199e533f31ceeb2dcd924053d866cd29861c.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "b940b9f3407afe1fc8360e24ac4cc9a1d93bb8de5d0faa23a9d9adedf215a757",
+  "output_sha256": "613d8a282d27246e68f660911ff1df8b61c24f27cde82b21a56c0a863d8f05fc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.md b/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.md
new file mode 100644
index 0000000000000000000000000000000000000000..73f28c553ad736e1dc4aadebb80a39bda8330c06
--- /dev/null
+++ b/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.md
@@ -0,0 +1,139 @@
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA/_
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/]
+1
+
+
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 2 of 6
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRAJ
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRAJ
+JANE DOE,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRA J
+DOE II,
+CASE NO.: 08-CV- 80469-MARRA/
+2
+
+
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 3 of 6
+VS.
+Plaintiff,
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80591-MARRA/
+JANE DOE NO. 102,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA1
+NOTICE OF FILING PROPOSED ORDER
+Plaintiffs, Jane Does 2-7, by and through their undersigned counsel, hereby file the
+attached Proposed Order in reference to document no. 111 filed in case no. 08-80119 on May 21,
+2009.
+Dated: May 27, 2009
+Respectfully submitted,
+By:_
+s/ Adam D. Horowitz
+Stuart S. Mermelstein (FL Bar No. 947245)
+ssm@sexabuscattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+3
+
+
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 4 of 6
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+4
+
+
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 5 of 6
+CERTIFICATE OF SERVICE
+I hereby certify that on May 27, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Adam D. Horowitz
+5
+
+
+Case 9:09-cv-80656-KAM Document 18 Entered on FLSD Docket 05/27/2009 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+James
+bedwards@rra-law.com
+Isidro Manuel
+isidrogarcia@bellsouth.net
+Jack
+jph@searcylaw.com
+Katherine Warthen Ezell
+KEzell@podhurst.com
+Michael James Pike
+MPike@bclclaw.com
+Paul G. Cassell
+cassellp@law.utah.edu
+Richard Horace Willits
+lawyerwillits@aol.com
+Robert C. Josefsberg
+rjosefsberg@podhurst.com
+Is/ Adam D. Horowitz
+6
diff --git a/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.receipt.json b/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..47d70f39a2801c40870c9b9ebf6dd7c3629344e7
--- /dev/null
+++ b/vision-fixhub/court-01/fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "doc_id": "fe452a95fa6156888d2fa8c3defed7f4a712e379eb2303f4d0da007b9ad7aa5c",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "bac56d40d7481ee2b082ba4744ef7c1442a7924161991707ae4b41b401242a81",
+  "output_sha256": "9248593413f6dacde76573284824c84f407927f39f17c5367faf034a2c9bc313",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe5653f9483d6c68b90d09089de2c11e260094eaf914461e536f9fad1142aa00.md b/vision-fixhub/court-01/fe5653f9483d6c68b90d09089de2c11e260094eaf914461e536f9fad1142aa00.md
new file mode 100644
index 0000000000000000000000000000000000000000..3720087a85fd84eb703ebe946aeef9824f82ffef
--- /dev/null
+++ b/vision-fixhub/court-01/fe5653f9483d6c68b90d09089de2c11e260094eaf914461e536f9fad1142aa00.md
@@ -0,0 +1,73 @@
+Case 9:08-cv-80381-KAM Document 27 Entered on FLSD Docket 07/17/2008
+
+sealed
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRA-,
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+PM12: 24
+D.C
+FILED EX PARTE
+UNDER SEAL
+DEFENDANT'S MOTION TO FILE EX PARTE AND UNDER SEAL
+
+
+Case 9:08-cv-80381-KAM Document 27 Entered on FLSD Docket 07/17/2008 Page 2 of 4
+Pursuant to S.D. Fla. L.R. 5.4, defendant Jeffrey Epstein hereby moves to
+file his Notice of Continued Pendency of Federal Criminal Action, as well as this
+motion, ex parte and under seal, stating as follows:
+1.
+In support of his motion to stay [DE 11], defendant has herewith filed
+a Notice of Continued Pendency of Federal Criminal Action.
+2.
+The Notice relates to a confidential agreement between the United
+States Attorney's Office for the Southern District of Florida and the defendant.
+3.
+The information contained in the Notice is material to this Court's
+consideration of Epstein's motion to stay.
+To avoid disclosure of confidential material, Epstein requests leave to
+file the Notice, and this motion, ex parte and under seal.
+Pending a ruling from this Court, Epstein has not served this motion
+or the Notice on counsel for plaintiff.
+2
+
+
+Case 9:08-cv-80381-KAM Document 27 Entered on FLSD Docket 07/17/2008 Page 3 of 4
+WHEREFORE, defendant Jeffrey Epstein respectfully requests leave to file this
+motion and his Notice of Continued Pendency of Federal Criminal Action, ex parte
+and under seal.
+Respectfully submitted,
+TEIN, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, Florida 33133
+Tel: 305 442 1101 Fax: 305 442 6744
+By: -
+UluTei
+GUY A.
+Fla. Bar No. 623740
+MICHAEL R. TEIN
+Fla. Bar No. 993522
+tein@lewistein.com
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel. 561 659 8300 Fax. 561 835 8691
+By: JACK A. GOLDBERGER
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+3
+
+
+• 'Case 9:08-CV-80381-KAM Document 27 Entered on FLSD Docket 07/17/2008 Page 4 of 4
+CERTIFICATE OF SERVICE
+1 HEREBY CERTIFY that this motion, in accordance with S.D. Fla. L.R.
+5.4, has not been served on opposing counsel and was filed under seal on July 10,
+2008.
+Millitei
+Michael R. Tein
+4
diff --git a/vision-fixhub/court-01/fe5653f9483d6c68b90d09089de2c11e260094eaf914461e536f9fad1142aa00.receipt.json b/vision-fixhub/court-01/fe5653f9483d6c68b90d09089de2c11e260094eaf914461e536f9fad1142aa00.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a74902524dcd33dfc8eaefbffed2639c7215613a
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-01/fe5c516ff341bb8bc9832be346fa392f9e0dcf958f582026453142a4a052a774.md b/vision-fixhub/court-01/fe5c516ff341bb8bc9832be346fa392f9e0dcf958f582026453142a4a052a774.md
new file mode 100644
index 0000000000000000000000000000000000000000..cf998b2f1cda185813f36aa41b03b68073d92f12
--- /dev/null
+++ b/vision-fixhub/court-01/fe5c516ff341bb8bc9832be346fa392f9e0dcf958f582026453142a4a052a774.md
@@ -0,0 +1,154 @@
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 1 of 6
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 3,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 4,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80119-MARRA/
+/
+CASE NO.: 08-CV-80232-MARRA/
+CASE NO.: 08-CV-80380-MARRA/
+CASE NO.: 08-CV-80381-MARRA/
+
+
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 2 of 6
+JANE DOE NO. 6,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08-CV-80994-MARRA/
+JANE DOE NO. 7,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80993-MARRA/
+C.M.A.,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80811 -MARRA/
+JANE DOE,
+VS.
+Plaintiff,
+JEFFREY EPSTEIN, et al.,
+Defendant.
+CASE NO.: 08- CV-80893-MARRAJ
+DOE II,
+VS.
+CASE NO.: 08-CV- 80469-MARRA/
+Plaintiff,
+2
+
+
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 3 of 6
+JEFFREY EPSTEIN et al.,
+Defendant.
+JANE DOE NO. 101,
+Plaintiff,
+CASE NO.: 08- CV-80591-MARRA/
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+JANE DOE NO. 102,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+CASE NO.: 08- CV-80656-MARRA/
+PLAINTIFFS' JANE DOES 2-7 MOTION FOR ENLARGEMENT
+OF TIME TO RESPOND TO DEFENDANT'S MOTION TO COMPEL
+AND/OR IDENTIFY JANE DOE IN THE STYLE ET AL.
+Plaintiffs, JANE DOES 2-7, by and through their undersigned counsel, hereby file this
+Motion for Enlargement of Time to Respond to Defendant's Motion to Compel and/or Identify
+Jane Doe in the Style of this Case and Motion to Identify Jane Doe in Third Party Subpoenas for
+Purposes of Discovery, or Alternatively Motion to Dismiss Sua Sponte, and state as follows:
+Defendant Epstein filed his Motion to Compel and/or Identify Jane Doe in the
+Style, et al., in the cases brought by Jane Does No. 2-7 ("Does 2-7") on May 5 and 6, 2009.
+Under S.D.Fla.L.R. 7.1(C), Does No. 2-7' response is due on May 22, 2009.
+2.
+Plaintiffs request an additional twenty (20) days to respond to the Motion to
+3
+
+
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 4 of 6
+Compel and/or Identify Jane Doe in the Style, et al. This request for enlargement of time of
+twenty (20) days is necessitated primarily by Plaintiffs desire to have the psychiatric expert who
+examined the Plaintiffs consider the issue of their public identification and, if appropriate, submit
+an expert declaration in response to the relief sought in the Defendant's Motion. The
+enlargement of time requested is sought to provide the expert with adequate time to perform this
+work.
+3.
+Additionally, Plaintiffs' counsel has conflicts with other cases and matters which
+necessitate additional time for a response, including, without limitation, a special set hearing and
+upcoming trial in John Doe 6 v. Diocese of Orlando, case no. 48-2005-010138-0, Ninth Judicial
+Circuit for Orange County, Florida; and an upcoming deadline to file Appellant's initial Brief in
+Jane Doe v. Florida International University Board of Trustees, case no. 3D09-414, Florida Third
+District Court of Appeals.
+4.
+Plaintiffs' counsel has conferred with Defendant's counsel, Robert Critton and
+Michael Pike, regarding this request for extension of time. While Defendant's counsel
+represented that Defendant would consent to an extension of time of one (1) week, until May 29,
+2009, Defendant opposes any further extension of time. The grounds stated by Defendant's
+counsel for opposing the extension of time requested concern the relief sought in Defendant's
+Motion to Strike Cases from the Current Trial Docket, filed on May 19, 2009.
+WHEREFORE, Plaintiffs Jane Doe Nos. 2-7 respectfully request an enlargement of time
+until June 11, 2009 to file their response to Defendant's Motion to Compel and/or Identify Jane
+Doe in the Style, et al., and for such other and further relief this Court deems just and proper.
+Dated: May 21, 2009
+Respectfully submitted,
+By:
+s/ Stuart S. Mermelstein
+Stuart S. Mermelstein (FL Bar No. 947245)
+4
+
+
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 5 of 6
+ssm@sexabuseattorney.com
+Adam D. Horowitz (FL Bar No. 376980)
+ahorowitz@sexabuseattorney.com
+MERMELSTEIN & HOROWITZ, P.A.
+Attorneys for Plaintiffs
+18205 Biscayne Blvd., Suite 2218
+Miami, Florida 33160
+Tel: (305) 931-2200
+Fax: (305) 931-0877
+CERTIFICATE OF SERVICE
+I hereby certify that on May 21, 2009, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served
+this day to all parties on the attached Service List in the manner specified, either via transmission
+of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for
+those parties who are not authorized to receive electronically Notices of Electronic Filing.
+Is/ Stuart S. Mermelstein
+5
+
+
+Case 9:08-cv-80232-KAM Document 100 Entered on FLSD Docket 05/21/2009 Page 6 of 6
+SERVICE LIST
+DOE vs. JEFFREY EPSTEIN
+United States District Court, Southern District of Florida
+Jack Alan Goldberger, Esq.
+jgoldberger@agwpa.com
+Robert D. Critton, Esq.
+rcritton@bclclaw.com
+Is/ Stuart S. Mermelstein
+6
diff --git a/vision-fixhub/court-01/fe5c516ff341bb8bc9832be346fa392f9e0dcf958f582026453142a4a052a774.receipt.json b/vision-fixhub/court-01/fe5c516ff341bb8bc9832be346fa392f9e0dcf958f582026453142a4a052a774.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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diff --git a/vision-fixhub/court-01/fe6e11a0ff57295e04024ae3c83f42b7296407765e398f08a2cf5e32021adda0.md b/vision-fixhub/court-01/fe6e11a0ff57295e04024ae3c83f42b7296407765e398f08a2cf5e32021adda0.md
new file mode 100644
index 0000000000000000000000000000000000000000..5ad71a73bdb18f48d7343e6739da7502127ead14
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@@ -0,0 +1,42 @@
+Case 9:08-cv-80736-KAM Document 261-1 Entered on FLSD Docket 10/08/2014 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs
+V.
+UNITED STATES OF AMERICA,
+Defendant
+PROPOSED
+ORDER OF CONFIDENTIALITY (*PROTECTIVE ORDER")
+THIS CAUSE came before the Court upon the Intervenor's Unopposed Motion for
+a Supplemental Protective Order. The Motion is hereby GRANTED, and it is
+ORDERED that:
+1. The Supplemental Protective Order applies to all correspondence between the
+United States Attorney's Office and the Intervenor and his counsel, including
+any attachments thereto, that was the subject of the Court's Order of June 18,
+2013 [D.E.
+188], hereinafter referred to as the "Confidential Discovery
+Material."
+2. The Supplemental Protective Order incorporates the limited Protective Order of
+the Court's September 22, 2014 Order. [D.E. 255 at 4-5].
+3. The Parties and Intervenor are further ordered that the filing of any
+"Confidential Discovery Material" as defined in paragraph one of this Order
+1
+
+
+Case 9:08-cv-80736-KAM Document 261-1 Entered on FLSD Docket 10/08/2014 Page 2 of 2
+shall be under seal, and further that any quotations from the "Confidential
+Discovery Material" in any pleading or motion shall be redacted from any
+public filing, with each party and the intervenor reserving the right to seek a
+further order unsealing the exhibit or the redacted portion of any filing. The
+Court also reserves the right to unseal any sealed exhibit or redacted portion of
+any filing with notice to the parties and intervenor.
+DONE and ORDERED in
+in West Palm Beach Florida this 8t day of
+October, 2014.
+Kenneth Marra
+United States District Judge
+Cc:
+All Counsel
+2
diff --git a/vision-fixhub/court-01/fe6e11a0ff57295e04024ae3c83f42b7296407765e398f08a2cf5e32021adda0.receipt.json b/vision-fixhub/court-01/fe6e11a0ff57295e04024ae3c83f42b7296407765e398f08a2cf5e32021adda0.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fe827f64ad3531b36f6ff9ae9f935f39ec8d3b95470c1ec66b0b9f77fa934618.md b/vision-fixhub/court-01/fe827f64ad3531b36f6ff9ae9f935f39ec8d3b95470c1ec66b0b9f77fa934618.md
new file mode 100644
index 0000000000000000000000000000000000000000..e28d8925e93addcc60b23900be381054ed539ef6
--- /dev/null
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@@ -0,0 +1,97 @@
+Case 9:08-cv-80380-KAM Document 80 Entered on FLSD Docket 04/10/2009 Page 1 of 3
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80380-MARRA-y
+JANE DOE NO. 4,
+V.
+JEFFREY EPSTEIN,
+Plaintiff,
+Defendant.
+Defendant's Amended Motion For Extension Of Time In Which To Respond To
+Plaintiff's Motion For Protective Against Piecemeal Depositions Of Jane Doe.
+No.4, Motion To Consolidate Cases For Purposes Of Discovery And Incorporated
+Memorandum Of Law
+Defendant, Jeffrey Epstein, (hereinafter "Epstein") by and through his
+undersigned attorneys, respectfully moves this Court for an extension of time in which to
+respond to Plaintiff's Motion For Protective Against Piecemeal Depositions Of Jane
+Doe. No.4, Motion To Consolidate Cases For Purposes Of Discovery And Incorporated
+Memorandum Of Law("Motion"). Local General Rule 7.1 A.1 and Rule 6, Fed. R. Civ. P.
+(2009). Defendant seeks an extension until April 16, 2009 to file his response. As good
+cause in support of granting the motion, Defendant states:
+1. Defendant's response to the Motion is due on or about April 6, 2009, and an
+extension was given to April 13, 2009.
+2. Plaintiff's counsel also represents five (5) other Plaintiffs pursuing claims against
+Defendant, EPSTEIN, most of which have filed similar Motions. In order to fully and
+adequately respond to this and the other motions, Defendant is in need of an extension
+until April 16, 2009.
+
+
+Case 9:08-cv-80380-KAM Document 80 Entered on FLSD Docket 04/10/2009 Page 2 of 3
+Jane Doe No. 4 v. Epstein
+Page 2
+3. In addition to the multiple motions, good cause for the extension also includes
+that counsel has been attempting to resolve discovery issues in this and other cases
+against Defendant, EPSTEIN; an associate of Defendant's undersigned counsel who
+works extensively on this case is currently out of the office and the undersigned was
+working on and has filed between 12-15 motions and responses in the various cases
+during the time these motions were filed.
+4. The requested extension is fair and reasonable under the circumstances as it will
+provide time to allow the Defendant, EPSTEIN, to fully and adequately respond to this
+and the other motions. In addition, this action is still at its early stages.
+5. As certified below, counsel for Defendant conferred with counsel for Plaintiff, and
+Plaintiff's counsel is in agreement with the requested extension.
+WHEREFORE, Defendant requests that this Court enter an order granting an
+Defendant an extension until April 16, 2009, in which to respond to the Above Motion.
+Local Rule 7.1 Statement
+Counsel for the movant conferred by telephone with counsel for the Plaintiff and
+Counsel for Plaintiff is in agreement with the requested extension until April 16, 2009 for
+Defendant to respond to the Motion.
+By:
+Ma
+ROBERT D. CRITTON, JR., ESQ.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record identified on the follawing Service List in the
+manner specified by CM/ECF on this lu
+_ 2009:
+
+
+Case 9:08-cv-80380-KAM Document 80 Entered on FLSD Docket 04/10/2009 Page 3 of 3
+Jane Doe No. 4 v. Epstein
+Page 3
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Mermelstein & Horowitz, P.A.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ssm@sexabuseattorney.com
+ahorowitz@sexabuseattorney.com
+Counsel for Plaintiff Jane Doe #4
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Co-Counsel for Defendant Jeffrey Epstein
+Respectfully submitted,
+By:.
+ROBERT D
+CRITTON, JR., ESQ.
+Florida Bar No. 224162
+rcrit@bclclaw.com
+MICHAEL J. PIKE, ESQ.
+Florida Bar #617296
+mpike@bclclaw.com
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+561/842-2820 Phone
+561/515-3148 Fax
+(Co-Counsel for Defendant Jeffrey Epstein)
diff --git a/vision-fixhub/court-01/fe827f64ad3531b36f6ff9ae9f935f39ec8d3b95470c1ec66b0b9f77fa934618.receipt.json b/vision-fixhub/court-01/fe827f64ad3531b36f6ff9ae9f935f39ec8d3b95470c1ec66b0b9f77fa934618.receipt.json
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+}
diff --git a/vision-fixhub/court-01/feb42a7b6f7957a3b237b0d0735e99b54d4626b854d453e7e510e3e295a1f7fc.md b/vision-fixhub/court-01/feb42a7b6f7957a3b237b0d0735e99b54d4626b854d453e7e510e3e295a1f7fc.md
new file mode 100644
index 0000000000000000000000000000000000000000..4f0a43fabe83db23ab9de51d45ccb4f0060e054c
--- /dev/null
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@@ -0,0 +1,21 @@
+Case 9:08-cv-80119-KAM Document 18-1
+Entered on FLSD Docket 07/10/2008 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80119-MARRA
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+[PROPOSED| ORDER
+Upon Plaintiff's Motion for Enlargement of Time to Respond to Defendant's Motion for
+Stay, and good cause being shown it is hereby
+ORDERED that Plaintiff's Motion is granted. Plaintiff shall have an enlargement of time of
+twenty (20) days, until July 30, 2008, to respond to Defendant's Motion for Stay.
+DONE AND ORDERED in
+in Ft. Lauderdale, Broward County, Florida, this
+day of
+-, 2008.
+DISTRICT COURT JUDGE
+- 1 -
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@@ -0,0 +1,14 @@
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+  "event_count": 1,
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+  "idempotent": true,
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+}
diff --git a/vision-fixhub/court-01/fec3894948921f47d34b5b5ad48a08fdc5aaea6b2de23e001e83aa7d388ecead.md b/vision-fixhub/court-01/fec3894948921f47d34b5b5ad48a08fdc5aaea6b2de23e001e83aa7d388ecead.md
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index 0000000000000000000000000000000000000000..fb874c61d5bb89ec2ba9ff33c581283ed3944c50
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@@ -0,0 +1,173 @@
+Case 9:08-cv-80119-KAM Document 328-1
+Entered on FLSD Docket 09/25/2009 Page 1 of 6
+Case 9:08-cv-80119-KAM
+Case 9:08-cv-80119-KAM
+Document 303-2
+Document 289
+Entered on FLSD Docket 09/16/2009 Page 1 of 6
+Entered on FLSD Docket 09/04/2009
+
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-CIV-80119-MARRAI|
+JANE DOE NO. 2,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+Related cases:
+08-80232, 08-80380, 08-80381, 08-80994,
+08-80993, 08-80811, 08-80893, 09-80469,
+09-80591, 09-80656, 09-80802, 09-81092
+ORDER
+THIS CAUSE is before the Court on Defendant Epstein's Emergency Motion
+For Independent Medical Examination of Plaintiff (D.E. # 228). For the following
+reasons said Motion is granted.
+In this case, which has been consolidated for purposes of discovery, Plaintiffs are
+former under-age girls who allege they were sexually assaulted by Defendant, Jeffrey
+Epstein ("Epstein"), at his Palm Beach mansion home. The scheme is alleged to have
+taken place over the course of several years in or around 2004-2005, when the girls in
+question were approximately 16 years of age. As part of this scheme, Epstein, with the
+help of his assistant
+|, allegedly lured economically disadvantaged minor girls
+to his homes in Palm beach, New York and St.
+with the promise of money in
+1
+TOENDANTS
+
+-STATE
+
+
+Case 9:08-cv-80119-KAM Document 328-1 Entered on FLSD Docket 09/25/2009 Page 2 of 6
+Case 9:08-Cv-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 2 of 6
+Entered on FLSD Docket 09/04/2009 Page 2 of 6
+exchange for a massage. Epstein purportedly transformed the massage into a sexual
+assault. The three-count Complaint alleges sexual assault and battery (Count 1),
+intentional infliction of emotional distress (Count I), and, coercion and enticement to sexual
+activity in violation of 18 U.S.C. §2422 (Count i).
+By the instant Motion Epstein seeks an order compelling
+, one of the Plaintiffs, in the case, to submit to an independent
+psychological/psychiatric medical examination by Ryan
+I. M.D., presently
+scheduled for September 8, 2009. |
+has agreed to submit to said exam, but
+requests the Court impose certain restrictions. Since the filing of the Motion the
+parties have managed to resolve some of the issues involved, such as the proposed
+examination's time and date and
+request to have a representative from
+her team present at said examination. As for the latter issue, Defendant has agreed
+to provide, at his expense, a video feed and monitor in an adjacent room for
+Plaintiff's representative's use. The remaining issues involve Plaintiff's request for
+a court order limiting the scope of the proposed examination by disallowing repeated
+questioning regarding "highly sensitive areas of inquiry including Plaintiff's medical
+history, psychiatric history, sexual history, social history, sexual abuse history.
+substance abuse history, etc.,'and imposing certain time restraints on the
+examination itself.
+Plaintiff's request to limit the scope of the examination is denied. It is Dr.
+'See Pitff's Resp. to Rep.(D.E. #279), p.3.
+2
+
+
+Case 9:08-cv-80119-KAM Document 328-1 Entered on FLSD Docket 09/25/2009 Page 3 of 6
+Case 9:08-CV-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 3 of 6
+Entered on FLSD Docket 09/04/2009 Page 3 of 6
+routine procedure when conducting psychological/psychiatric medical
+examinations of patients to require the patient to fill out a 10-page "Life History
+Questionnaire" and a 14-page "Patient Questionnaire." Both questionnaires request
+detailed background information regarding past medical history, psychiatric history,
+social history, work history, and the like. Presumably Plaintiff will be asked these
+same questions two more times, first by defense counsel at
+deposition
+scheduled to take place shortly, and again by Dr. at the upcoming examination.
+Plaintiff's objection is that by having to answer these same questions about the
+same subject matter three separate times "would only serve to embarrass, humiliate,
+intimidate and further victimize Plaintiff." Pltff's Resp. (D.E. #254), p.6. Plaintiff's
+position is that she should only "be required to regarding past medical history,
+psychiatric history, social history, work history, and the like, if at all, only one time,"
+either during the "deposition of Plaintiff or through Dr.
+examination, but
+certainly not both." Id.
+Plaintiff cites no case law and independent research has uncovered none, to
+support her novel position that a Plaintiff who puts her mental, emotional and
+psychiatric state at issue can place a limitation on the number of times defense
+counsel or agents retained by him can inquire into areas relevant to these issues
+where the subject matter involved is "highly personal," "embarrassing," "sensitive,"
+or otherwise "humiliating." Plaintiff is seeking millions of dollars in personal injury
+damages for, among other things, "physical injury, pain and suffering, emotional
+
+
+Case 9:08-cv-80119-KAM Document 328-1 Entered on FLSD Docket 09/25/2009 Page 4 of 6
+Case 9:08-cv-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 4 of 6
+Entered on FLSD Docket 09/04/2009 Page 4 of 6
+distress, psychological trauma, mental anguish, humiliation, embarrassment, loss
+of self-esteem, loss of dignity, [and] invasion of her privacy." = Based on the
+allegations made in Defendant's Reply,' Plaintiff's childhood was, to put it mildly, a
+difficult one, with numerous episodes of child abuse and sexual abuse, which in turn
+may of been the cause of Plaintiff's later engaging in numerous instances of
+substance abuse, self-mutilation, prostitution, aggravated assault, truancy, and the
+like. According to Defendant, in 2005 Plaintiff's mother filed a case committing
+for a Petition for Involuntary Assessment for substance abuse, stating in
+the accompanying file that
+Schizophrenic." *
+has been diagnosed as "Bipoloar and
+Under these circumstances, where Plaintiff is seeking to recover medical
+expenses associated with these complex medical issues, full knowledge of Plaintiff's
+past and present medical, psychological, familial and social histories is essential.
+And while neither duplication nor embarrassment is desired, under the
+circumstances presented, where the number and scope of damages claimed are
+vast and Plaintiff's past history eventful, it may nonetheless be unavoidable. This is
+not to say that restrictions on the scope of questioning may never be put into effect.
+If, as the case progresses, Plaintiff can show that Defendant's invasive questioning
+First Am. Compl., Counts I-XXX.
+2 Plaintiff,
+» (D.E. #273), pp.7-8,
+* As quoted in Def's Rep. (D.E. #273), p.8, from Palm Beach County Case #05MH1667.
+4
+
+
+Case 9:08-cv-80119-KAM Document 328-1 Entered on FLSD Docket 09/25/2009 Page 5 of 6
+Case 9:08-CV-80119-KAM Document 303-2 Entered on FLSD Docket 09/16/2009 Page 5 of 6
+Entered on FLSD Docket 09/04/2009 Page 5 of 6
+is being done in bad faith or for purposes of harassment, the Court may reconsider
+imposing limitations of the sort requested herein. At this point, however, the Court
+agrees with Defendant that to restrict the number of times defense counsel may ask
+Plaintiff personal and sensitive questions concerning some of the pivotal issues in
+this case, would work an injustice by preventing Defendant from being able to defend
+himself.
+The Court likewise rejects Plaintiff's request to limit the time for conducting the
+examination and any related testing to 6 hours. Dr.
+has filed an affidavit stating
+that he needs 6-8 hours to conduct the examination and related testing, and that
+anything less than that might result in compromising the test results? Considering
+the 31 counts alleged against Defendant, as well as Plaintiff's event-filled past, the
+amount of time sought does not appear unreasonable. Should the length of time
+prove draining, Plaintiff may take breaks as needed, of reasonable duration.
+Furthermore, Defense Counsel and Dr.
+are hereby put on notice that while the
+Court has allowed the full 8 hours requested for the examination and related testing,
+should less time be needed, the Court expects less time will be taken, and in no
+event may the examination and related testing exceed a total of 8 hours. In
+accordance with the above and foregoing, it is hereby
+ORDERED AND ADJUDGED that Defendant Epstein's Emergency Motion
+For Independent Medical Examination of Plaintiff (D.E. # 228) is GRANTED IN
+" Affidavit of Dr.
+attached as Ex. "B" to Defendant's Rep. (D.E. #273).
+5
+
+
+Case 9:08-cv-80119-KAM Document 328-1 Entered on FLSD Docket 09/25/2009 Page 6 of 6
+Case 9:08-cv-80119-KAM|
+Case 9:08-cv-80119-KAM
+Document 303-2
+Document 289
+Entered on FLSD Docket 09/16/2009 Page 6 of 6
+Entered on FLSD Docket 09/04/2009 Page 6 of 6
+ACCORDANCE WITH THE TERMS HEREOF.
+DONE AND ORDERED this September 4, 2009, in
+, atWest Palm Beach,
+Florida.
+LINNEA R. JOHNSO
+UNITED STATES MAGISTRATE JUDGE
+CC:
+The Honorable Kenneth A. Marra
+All Counsel of Record
\ No newline at end of file
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diff --git a/vision-fixhub/court-01/fed62bc10808dee213611797ad169cb98b3533cd0044162df6a0b8249089146f.md b/vision-fixhub/court-01/fed62bc10808dee213611797ad169cb98b3533cd0044162df6a0b8249089146f.md
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@@ -0,0 +1,26 @@
+Case 9:08-cv-80736-KAM Document 87 Entered on FLSD Docket 06/23/2011 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+ORDER SETTING HEARING
+THIS CAUSE is before the Court sua sponte.
+It is hereby ORDERED that the above-styled cause is set for oral argument on Friday,
+August 12, 2011, at 2:00 p.m. before United States District Judge Kenneth A. Marra, 701
+Clematis Street, Courtroom 4, West Palm Beach, Florida, on all motions currently pending in this
+matter. The parties should also be prepared to discuss whether an evidentiary hearing will be
+necessary to resolve the issues pending in this case.
+DONE AND ORDERED in
+this 23" day of June, 2011.
+at West Palm Beach, Palm Beach County, Florida,
+KENNETH A. MARRA
+United States District Court
+Copies to:
+Counsel of record
+
+
+Case 9:08-cv-80736-KAM Document 87 Entered on FLSD Docket 06/23/2011 Page 2 of 2
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@@ -0,0 +1,1136 @@
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 1 of 21
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+SENTENCE
+(As to Count(s)
+Defendan Jeffrey E. Epstein
+Case NumBol 060F9454 - CE ANTA
+OBTS Number -
+The Dared eps re this and acon been alicated endan here, any or cord,
+_ and having been adjudicated guilty herein, and the Court having given
+the Defendant an opportunity to be heard and to offer matters in mitigation of sentence, and to show cause why
+defendant should not be sentenced as provided by law, and no cause being shown,
+IT IS THE SENTENCE OF THE COURT that:
+The Defendant pay a fine of $
+pursuant to §
+_ Florida Statutes, plus all costs and additional
+charges as outlined in the Order assessing additional charges, costs and fines as set forth in a separate order entered
+herein
+The Defendant is hereby committed to the custody of the
+I 1 Department of Corrections
+*Sheriff of Palm Beach County, Florida
+for a term of
+122 ament forrections as a youthful offender
+.. It is further ordered that the Defendant shall be allowed a
+total of
+days as credit for time incarcerated prior to imposition of this sentence, is further ordered that
+the composite term of all sentences imposed for the counts specified in the order shall run
+[ ] consecutive to [ ] concurrent with (check one) the following:
+Any active sentence being served.
+JUN 30 2008
+Specific sentences:_
+In the event the above sentence is to the Department of Corrections, the Sheriff of Palm Beach County, Florida is
+hereby ordered and directed to deliver the Defendant to the Department of Corrections together with a copy of the
+Judgment and Sentence, and any other documents specified by Florida Statute. Additionally, pursuant to §947.16(4),
+Florida Statutes, the Court retains jurisdiction over the Defendant.
+Pursuant to §$322.055, 322.056, 322.26, 322.274, Fla. Stat., the Department of Highway Safety and Motor
+Vehicles is directed to revoke the Defendant's privilege to drive. The Clerk of the Court is Ordered to report
+the conviction and revocation to the Department of Highway Safety and Motor Vehicles:
+The defendant in Open Court was advised of the right to appeal from this Sentence by filing notice of appeal within
+thirty days from this date with the Clerk of the Court. The Defendant was also advised of the right to the assistance of
+counsel in taking said appeal at the expense of the State upon showing of indigency.
+DONE AND ORDERED in Open Court at West Palm Beach, Palm Beach County, Florida this
+une 200€
+NihWaleke
+Form Circuit 5 (rev 8/2000)
+CIRCUIT COURT INCE
+3O day of
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 2 of 21
+STATE OF FLORIDA
+IN THE
+CAL DIVISION OF THE CIRCUIT
+COURT& THE FIFTEENTH JUDICIAL CIRCUIT,
+VS.
+IN AND FOR PALM BEACH COUNTY, FLORIDI
+10 06: CF 009454AM
+Jeffrey Epsten
+CASENUMBER 0 05-87 009381AMB
+PLEA IN THE CIRCUIT COURT
+1. DEFENDANT:
+I am the defendant in the above-mentioned matter(s), and I am represented by the attorney indicated below. I
+understand I have the right to be represented by an attorney at all stages of the proceeding until the case is terminated,
+and if I cannot afford an attorney, one will be appointed free of charge.
+2. DEFENDANT:
+3. DEFENDANT:
+4. DEFENDANT:
+5. DEFENDANT:
+6. DEFENDANT:
+7. DEFENDANT:
+8. DEFENDANT:
+9. DEFENDANT:
+10.DEFENDANT:
+11. DEFENDANT:
+I understand I have the right to a speedy and public trial either by jury or by court. I hereby waive and give ug this
+right.
+I understand I have the right to be confronted by the witnesses against me and to cross examine them by myself or
+through my attorney. I hereby give up these rights.
+I understand I have the right to testify on my own behalf, but I cannot be compelled to be a witness against myself
+and may remain silent if I so choose. I hereby give up these rights.
+I understand I have the right to call witnesses to testify in my behalf and to invoke the compulsory process of the
+Court to subpoena those witnesses. I hereby give up these rights.
+specifically reserving my right to appeal, I will give up such right of appeal.
+specialty reserving my it to peal, at give up set in horsepand, mies plea Guily or No 9 a
+I understand that if I am not a United States Citizen, my plea may subject me to deportation pursuant to the laws and
+regulations governing the United States Immigration and Naturalization Service; and, this Court has no jurisdiction
+(authority) in such matters.
+I have not received any promises from anyone, including my attorney, concerning eligibility for any form of early
+release authorized by law and further no promises have been made to me as to the actual amount of time that I will
+secrete in the ear to eased. fucia on its wited plea may be used to enhance future crit
+penalties in any court system, even if adjudication of guilt is withheld.
+I offer my plea freely and voluntarily and of my own accord, with full understanding of all matters set forth if the
+pleadings and this waiver.
+I have personally placed my initials in each bracket above, and I understand each and every one of the rights outlined
+above. I hereby waive and give up cach of them in order to enter my plea to the within charge(s). I understand that
+even though the Court may approve the agreement of sentence, the Court is not bound by the agreement, the Court
+may withdraw its approval at any time before pronouncing judgment, in which case I shall be able to withdraw my
+plea should I desire to do so.
+ent
+Choose one:
+If applicable, I choose a program which is or may be spirituaily based.
+JUN ?0
+If applicable, I choose a program which is NOT spiritually based.
+If applicable, I have no preference if the program is or may be spiritually based.
+6/30/08
+DATE
+DEFENDANT'S ATTORNEY ONLY:
+I am attorney of record. I have explained each of the above rights to the defendant and have explored the facts with him/her and studied his/her
+possible defenses to the charge(s). I concur with his/her decision to waive the rights and to enter this plea. I further stipulate that this document
+may be received by the Court as evidence of defendant's intelligent waiver of these rights and that it shall be filed by the Clerk as permanent record
+of that waiv
+- Jock Goldberge
+& THE DEFENDANT
+6/30/08
+DATE
+Original - Clerk
+Page 1 of
+- State Attorney Yellow - Defense Attorney
+Pink Defendane Goldenrod- Probation 07 91
+Form 002
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 3 of 21
+25400
+IN THE CRIMINAL DIVISION OF THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA.
+IN AND FOR PALM BEACH COUNTY
+CASE NO.,
+06-C5 9154-
+2006 CF 94.54AXX
+OBTS NUMBER
+STATE OF FLORIDA
+COMMUNITY
+CONTROL
+VIOLATOR
+V.
+CFN 20080267522
+OR BK 22760 PG 1081
+RECORDED 07/17/2008 08:52:50
+Palm Beach County, Florida
+Sharon R. Bock, CLERK & COMPTROLLER
+Pg 1081; (1pg)
+etrey E. Epsteir
+JEFENDAN
+1/2053
+DATE OF BIRTH
+RACE
+PROBATION
+VIOLATOR
+M
+GENDER
+090 44 3348
+SOCIAL SECURITY NUMBER
+JUDGMENT
+The above Defendant, being personally before this Court represented by
+J. Goldberger
+Having been tried and found guilty of
+the following crime(s):
+Having entered a plea of guilty to
+the following crime(s):
+COUNT
+Felony Solicitativi
+of Prostitutim
+290.
+(attorney)
+Having entered a plea of nolo
+contendere to the following
+crime(s):
+DEGREE
+3°F
+and no cause having been shown why the Defendant should not be adjudicated guilty. IT IS ORDERED THAT the Defendant is hereby
+ADJUDICATED GUILTY of the above crime(s).
+and having been convicted or found guilty of, or having entered a plea of nolo contendere or guilty,regardless of adjudication, to attempts or
+offenses relating to sexual battery (ch. 794). lewd and lascivious conduct (ch. 800), or murder (s. 782.04), aggravated batfery (S4784.045).
+burglary (s. 810.02), carjacking (s. 812.133), or home invasion robbery (s. 812.135), or any other offense specified in section 943.325, the
+defendant shall be required to submit blood specimens.
+and good cause being shown: IT IS ORDERED THAT ADJUDICATION OF GUILT BE WITHHELD
+JUN 33/.3
+SENTENCE
+STAYED
+I The Court hereby stays and withholds imposition of sentence as to count's) and places the Defendant on
+1] Probation and/or | ] Community Control under the supervision of the Dept. of Corrections (conditions of probation
+set forth in separate order).
+SENTENCE
+DEFERRED
+| ] The Court hereby defers imposition of sentence until
+The Defendant in Open Court was advised of his right to appeal from the Judgment by filing notice of appeal with the Clerk of Court within thirty days
+following the date sentence is imposed or probation is ordered pursuant to this adjudication. The defendant was also advised of his right to the assistance
+of counsel in taking said appeal at the expense of the State upon showing of indigenc
+ID ORDERED in Open Court at Palm Beach County, Florida, this
+30
+day or June
+_ 200
+1L07
+1805
+Swit
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 4 of 21
+PLEA IN THE CIRCUIT COURT
+THE FOLLOWING IS TO REFLECT ALI. TERMS OF THE NEGOTIATED SI: TTLEMEN?
+Name: Jeffrey E. Epstein
+Plea: Guilty X
+Gase No
+20 0GCF009454AME
+Charge
+Count Lesser
+1
+_Degree
+08CE009381AMB
+Feiony Solicitation of Prostitution
+Procuring Person Under 18 for Prostitution 1
+No
+No
+3 FEL
+2 FEI.
+PSI: Waived/Not Required
+ADJUDICATION:
+Required/Requested ...
+Adjudicate [x 1
+SENTENCE:
+On 06CF009454AMB, the Defendant Is sentenced to 12 months in the Palm Beach County
+Detention Facility, with credit for 1 (one) day time served.
+imprison jail gentence
+On 08CF009381 AMB, the Defendant is sentenced to 6 months in the Palm Beach County
+Detention Facility, with credit for 1 (one) day time served. This 6 month sentence is to be
+served consecutive lo the 12 month sentence in 06CF009454AMB. Following this 6
+month sentence, the Defendant will be placed on 12 months Community Control 1 (one).
+The conditions of community control are attached hereto and incorporated herein.
+OTHER COMMENTS OR CONDITIONS:
+As a special condition of his community control, the Defendant is to have no unsupervised
+contact with minors, and the supervising adult must be approved by the Department of
+Coffections.
+The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943.0435 and
+must abide by all the corresponding requirements of the statute, a copy of which is attached
+hereto and incorporated herein.
+The Defendant must provide a DNA sample in court at the time of th:
+Defendant
+4/30/08
+Date of Plea
+JUN 30
+polenda
+51€
+
+
+FURTEASe OBSCURA KOUBPOU OMPy wntered on FLSD Docker 08/18/2008 Page 5 ot 2.
+A THE FOLLOWING
+TIONS OF SUPERVISION:
+- I. =
+IMMUNITY CONTROL STANDARD CONDITIONS:
+You will remain confined to your residence except one half hour before and after your approved employment,
+community service work, or any other activities approved by your probation officer.
+You will maintain an hourly accounting of all your activities on a daily log which you will submit to your supervising
+officer upon request.
+(c)
+The Department of Corrections, may at its discretion, places you on Electronic Monitoring during the term of your
+Community Control. If placed, on Electronic Monitoring, you will wear a monitor at all times. You will maintain a.
+private phone line, be financially responsible for any lost or damaged equipment and follow all rules and regulations as
+instructed. The telephone will be available within five working days of being placed ion Blectronic Monitoring Program.
+While on electronic monitoring you will remain confined to your residence and are prohibited from being outside the
+residential walls.
+(d)
+If while being monitored and the monitor is found to have been tampered with you shall be taken into custody
+immediately, if the officer determines that your were not at your schedules place of work or school while allowed to be
+outside the residence then in that event you shall be taken into custody immediately. If taken into custody, you shall be
+held without bond and shall, on the next working day, brought before a Judge presiding over his or her case for further
+disposition at the discretion of the presiding Judge
+If placed on Electronic Monitoring you will pay to the State of Florida, for the cost of Electronic Monitoring $1.00 per
+@Detendant Will be isiainita, 33El Brillo Way,
+II.
+DRUGO
+PALM ROBARNSARD CONDITIONS
+(a) You will submit to and, unless otherwise waived, be financially responsible for drug testing, urinalysis at least on a
+monthly basis, and counseling if deered appropriate by your supervising officer.
+(b) You will enter and successfully complete a non-secure or inpatient drug treatment program if deemed appropriate by
+your officer.
+(c) You will comply with any curfew restrictions, confinement approved residence or travel restrictions as instructed by
+your officer and approved by the Officer's Supervisor.
+SEX OF
+ONS:
+you shall submit to a mandatory curfew from 10:00 PM to 6:00 AM
+(if the victim was under the age of 18 years) you shall not live within 1000 feet of a school, day care center, park,
+playground, or other place where children regularly congregate.
+(c) you shall enter, actively participate in, and successfully complete a sex offender treatment program with a therapist
+particularly trained to treat sex offender, at probationer's or community controlees expense
+you shall not have any contact with the victiin directly or indirectly, including through a third person, unless approved
+by the victim, the therapist and sentencing court.
+(if the victim was under the age of 18 years) you shall not, until you successfully attend and complete the sex offender
+D) program, have any unsupervised contact with a child under the age of 18 years, unless authorized by the sentencing
+court, without an adult present who is responsible for the child's welfare and which adult has been advised of the crime
+'and is approved by the sentencing court.
+(if the victim was under the age of 18 years) you shall not work for pay or as a volunteer in any school, day care center,
+Park, playground, or other place where children regularly congregate.
+Intess otherwise indicated in the treatment plan provided by the sexual offonder treatment
+prograin, you shall not view,
+own, or posses any obscene, pornographic or sexually stimulating visual or auditory material, including telephone,
+electronic media, computer programs or computer services that are relevant to your deviant behavior pattern.
+You shall submit two specimens of blood to the Florida Department of Law Enforcement to be registered with the DNA
+Data Bank.
+(i). You shall make restitution to the victim as ordered by this court pursuant to F.S. 775,089 for all necessary medical and
+related professional services relating to the physical, psychiatric and psychological care of the victim.
+residence, or vehicle.
+You shall submit to a warrantless searc by your probation officer or community control mom ur Contra
+9) Detendant to have contact with his betar
+oficer at a minimum one tine a weck. so
+6 Detendant to work @ Flovida Science Foundation,
+250 Australian Are MIdA FI
+
+
+Case A108-CV-80804-KAM
+Document 11-1: Entered on FLSD Docket 08/18/2008 Page 6 of 21
+DEK PROBATH
+IMUNITY CONTROL STANDARD CO
+ONS:
+you shall submit to a mandatory curfew from 10:00 PM to 6:00 AM
+(if the victim was under the age of 18 years) you shall not live within 1000 feet of a school, day care center, park,
+playground, or other place where children regularly congregate.
+(c)
+you shall enter, actively participate in, and successfully complete a sex offender treatment program with a therapist
+particularly trained to treat sex offender, at probationer's or community controlees expense.
+(d)
+you shall not have any contact with the victim; directly or indirectly, including through a third person, unless approved
+by the victim, the therapist and sentencing court.
+(e)
+(if the victim was under the age of 18 years) you shall not, until you successfully attend and complete the sex offender
+program, have any unsupervised contact with a child under the age of 18 years, unless authorized by the sentencing
+court, without an adult present who is responsible for the child's welfare and which adult has been advised of the crime
+and is approved by the sentencing court.
+(if the victim was under the age of 18 years) you shall not work for pay or as a volunteer in any school, day care center,
+park, playground, or otber place where children regularly congregate.
+(g)
+Unless otherwise indicated in the treatment plan provided by the sexual offender treatment program, you shall not view,
+own, or posses any obscene, pornographic or sexually stimulating visual or auditory material, including telephone,
+• electronic media, computer programs or computer services that are relevant to your deviant behavior pattern.
+(h)
+You shall submit two specimens of blood to the Florida Department of Law Enforcement to he registered with the DNA
+Data Bank.
+You shall make restitution to the victim as ordered by this court pursuant to F.S. 775.089 for all necessary medical and
+related professional services relating to the physical, psychiatric and psychological care of the victim.
+You shall submit to a warrantless search by your probation officer of community control officer of your person,
+residence, or vehicle.
+you shall, as part of a treatment program, participate once/twice annually in polygraph examination to obtain information
+necessary for risk management and treatment and to reduce your denial mechanisms: Your polygraph examinations must
+be conducted by a polygrapher trained specifically in the use of polygraph for monitoring sex offenders and it shall be
+paid by you. The results of the polygraph examinations shall not be used as evidenced in court to prove that a violation
+of community supervision occurred.
+You shall maintain a driving log, you shall not drive a motor vehiçle while alone without prior approval of your
+supervising officer.
+(if there was sexual contact) you shall submit to, at probationer's or community controlee's expense, an HIV test with
+the results to be released to the victim, - or the victim's parents or guardian.
+You will not obtain or use a Post Office Box without the prior approval of the supervising officer.
+You will submit to electronic monitoring when deemed necessary by the community control or probation officer and his
+or her supervisor, and ordered by the court at the recommendation of the Department of Corrections.
+Other:
+THE COURT RESERVES THE RIGHT TO RESCIND, MODIFY, OR REVOKE SAL
+DONE AND ORDERED AT West Palm Beach, Palm Beach County, Florida, this.
+Nunc Pro Tunic: 10/5/2005,
+KTANT PROVIDED BY LAW
+Honorable Sandra K. MeSorley
+Judge, Circuit Court
+I have received a copy of the terms and conditions of my supervision. I have read and understand these condit, ms " - agree to report to the Department of
+Corrections Probation Office for further instructions. Also, I hereby consent to the disclosure of my alcohol and drug abuse patient records, the confidentiality
+of which is federally regulated under 42CFR, Part II, for the duration of my supervision.
+DEFENDA
+AP 10/11
+DATE
+6
+
+
+Case 9:08-cV-80804-KAM Docyment 11-1 Entered on FLSD Docket 08/18/2008 Page 7 of 21
+948.101 Terms and conditions of community control and criminal quarantine community
+control.--
+(1) The court shall determine the terms and conditions of community control. Conditions
+specified in this subsection do not require oral pronouncement at the time of sentencing and
+may be considered standard conditions of community control.
+(a) The court shall require intensive supervision and surveillance for an offonder placed into
+community control, which may include but is not limited to:
+1. Specified contact with the parole and probation officor.
+2. Confinement to an agreed-upon residence during hours away from employmont and public
+service activities.
+3. Mandatory public service.
+4. Supervision by the Department of Corrections by means of an electronic monitoring device
+or system.
+5. The standard conditions of probation set forth in s. 948.03.
+(b) For an offandor placed on criminal quarantine community control, the court shall require:
+1. Eloctronic monitoring 24 hours per day.
+2. Confinement to a designated residence during designated hours.
+a probation and restitution center under the jurisdiction of the Department of Corrections, a
+probation program drug punishment phase i secure residential treatment institution, or a
+community residential facility owned or operated by any entity providing such services.
+(3) The court may place a dofondant who is being sentenced for criminal transmission of HIV in
+violation of s. 775.0877 on criminal quarantine community control. The Department of
+Corroctions shall dovelop and administer a criminal quarantine community control program
+emphasizing intensive supervision with 24-hour-por day electronic monitoring. Criminal
+quarantine community control status must include surveillance and may include othor moesures
+normally associatod with community control, except that spocific conditions nocassary to
+monitor this population may be ordered.
+7
+
+
+Case 9:08-cV-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 8 of 21
+"943.0435 Sexual offenders required to register with the department; penalty.-
+(1) As used in this section, the term:
+(a)1. "Sexual offender" means a person who meets the criteria in sub-subparagraph a., subsubparagraph b., sub-subparagraph c., or sub-subparagraph d., as follows:
+a. (1) Has been convicted of committing, or attempting, soliciting, or conspiring to commit, any
+of the criminal offenses proscribed in the following statutes in this state or similar offonses in
+another jurisdiction: s. 787.01, s. 787.02, or s. 787.025(2)(c), where the victim is a minor and
+the defendant is not the victim's parent or guardian; s. 794.011, excluding s. 794.011(10); s.
+794.05; s. 796.03; s. 796.035; s. 800.04; s. 825.1025; s. 827.071; s. 847.0133; s. 847.0135,
+excluding s. 847.0135(4); s. 847.0137; s. 847.0138; s. 847.0145; or s. 985.701(1); or any similar
+offense committed in this state which has been redesignated from a former statute number to
+one of those listed in this sub-sub-subparagraph; and
+not limited to, a fine, probation, community control, parola, conditional relcasa, control
+release, or incarceration in a state prison, foderal prison, private correctional facility, or local
+detention facility;
+b. Establishes or maintains a residence in this state and who has not been designatod as a
+sexual predator by a court of this state but who has been designated as a sexual predator, is a
+sexually violent prodator, or by another sexual offender designation in another state or
+jurisdiction and was, as a result of such designation, subjected to registration or community or
+public notification, or both, or would be if the person were a resident of that state or
+jurisdiction, without regard to whether the person otherwise moets the critoria for registration
+as a sexual offendor;
+c. Establishes or maintains a residence in this state who is in the custody or control of, or
+under the supervision of, any other state or jurisdiction as a result of a conviction for
+committing, or attempting, soliciting, or conspiring to commit, any of the criminal offenses
+proscribed in the following statutes or similar offonse in another jurisdiction: s. 787.01, s.
+787.02, or s. 787.025(2)(c), where the victim is a minor and the defendant is not the victim's
+state which has boon redesignated from a former statute number to one of those listed in this
+sub-subparagraph; or
+d. On or after July 1, 2007, has been adjudicated delinquent for committing, or attompting,
+soliciting, or conspiring to commit, any of the criminal offenses proscribed in the following
+statutes in this state or similar offenses in another jurisdiction when the juvenile was 14 years
+of ago or older at the time of the offonse:
+(I) Soction 794.011, excluding s. 794.011(10);
+(II) Section 800.04(4)(b) where the victim is under 12 years of age or where the court find:
+sexual activity by the use of force or coercion;
+(li) Saction 800.04(5)(c)1. where the court finds molestation involving unclothed genit
+8
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 9 of21
+(IV) Section 800.04(5)(d) where the court finds the use of force or coercion and unclothed
+genitals.
+2. For all qualifying offonses listed in sub-subparagraph (1)(a)1.d., the court shall make a
+writton finding of the age of the offender at the time of the offense.
+For each violation of a qualifying offonse listed in this subsection, the court shall make a
+written finding of the age of the victim at the time of the offense. For a violation of s.
+800.04(4), the court shall additionally make a written finding indicating that the offense did or
+did not involve sexual activity and indicating that the offense did or did not involve force or
+coercion. For a violation of s. 800.04(5), the court shall additionally make a written finding
+that the offense did or did not involve unclothed genitals or genital area and that the offenso
+did or did not involve the use of force or coercion.
+(b) "Convicted" moans that there has been a determination of guilt as a result of a trial or the
+entry of a plea of guilty or nolo contendere, regardless of whether adjudication is withheld,
+and includes an adjudication of delinquency of a juvenile as specified in this saction.
+Conviction of a similar offense includes, but is not limited to, a conviction by a federal or
+military tribunal, including courts-martial conducted by the Armed Force's of the United States,
+and includes a conviction or entry of a ploa of guilty or nolo contendere resulting in a sanction
+in any state of the United States or other jurisdiction. A sanction includes, but is not limited
+to, a fine, probation, community control, parole, conditional release, control release, or
+incarceration in a state prison, federal prison, private correctional facility, or local detention
+(c) "Permanent residence" and "temporary residence" have the same meaning ascribed in s.
+775.21.
+(d) "Institution of higher education" means a career conter, community college, college, state
+university, or indopendent postsecondary institution.
+(e) "Change in enrollment or employment status" means the commencemont or tormination of
+enrollment or employment or a change in location of enrollment or employment.
+(f) "Electronic mail address" has the same meaning as provided in s. 668.602.
+(g) "Instant message name" ineans an identifier that allows a person to communicate in real
+time with another person using the Internet.
+(2) A sexual offender shall:
+(a) Roport in person at the shoriff's office:
+1. In the county in which the offender establishes or maintains a permanent or temporary
+residence within 48 hours after:
+a. Establishing permanent or temporary residence in this state; or
+b. Being released from the custody, control, or supervision of the Departmont of Corrections
+or from the custody of a private correctional facility; or
+2. In the county where he or she was convicted within 18 hours after being convicted for a
+qualifying offense for registration under this section if the offender is not in the custody or
+9
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 10 of 21
+control of, or undor the supervision of, the Department of Corrections, or is not in the custory
+of a private correctional facility.
+Any change in the sexual offender's permanent or temporary residence, name, any electronir
+mail address and any instant message name required to be provided pursuant to paragraph
+(4)(d), after the sexual offender reports in person at the sheriffs office, shall be accomplished
+in the manner provided in subsections (4), (7), and (8).
+(b) Provide his or her name, date of birth, social security number, race, sex, height, weight,
+hair and eye color, tattoos or other identifying marks, occupation and place of employment,
+address of permanent or legal residence or address of any current temporary residence, within
+the state and out of state, including a rural route address and a post office box, any electronic
+mail address and any instant message name required to be provided pursuant to paragraph
+(4)(d), date and place of each conviction, and a brief description of the crime or crimes
+committed by the offender. A post office box shall not be provided in lieu of a physical
+residontial address.
+1. If the sexual offender's place of residonco is a motor vehicle, trailer, mobile home, or
+manufactured home, as defined in chapter 320, the sexual offender shall also provide to the
+department through the shoriffs office written notice of the vehicle identification number; the
+license tag number; the registration number; and a description, including color scheme, of the
+motor vehicle, trailer, mobile home, or manufactured home. If the sexual offendor's place of
+residence is a vessol, livo-aboard vessel, or houseboat, as defined in chapter 377, the sexual
+offender shall also provide to the department written notice of the hull identification number;
+the manufacturer's serial number; the name of the vessel, live-aboard vessol, or houseboat; the
+registration numbor; and a description, including color scheme, of the vessol, live-aboard
+vessel, or houseboat.
+2. If the sexual offender is onrolled, employed, or carrying on a vocation at an institution of
+higher education in this stato, the sexual offender shall also provide to the department through
+the sheriffs office the name, address, and county of each institution, including each campus
+attonded, and the sexual offonder's enrollmont or omployment status. Each change in
+onrollment or employment status shall be reported in person at the sheriff's office, within 45
+hours aftor any change in status. The shoriff shall promptly notify each institution of the sexual
+offender's presence and any change in the soxual offender's enrollment or employment status.
+When a sexual offender roports at the sheriff's office, the sheriff shall take a photograph and a
+set of fingerprints of the offonder and forward the photographs and fingerprints to the
+departmont, along with the information providad by the sexual offender. The sheriff shall
+promptly provide to the department the information roceived from the sexual offender.
+(3) Within 48 hours after the report required under subsection (2), a sexual offender shall
+report in porson at a driver's license office of the Department of Highway Safety and Motor
+Vehicles, unless a driver's liconse or identification card that complies with the requironent: uf
+s. 322. 111(3) was previously secured or updated under s. 914.607. At the driver': license off e
+the sexual offendor shall:
+(a) If otherwise qualified, secure a Florida driver's license, renow a Florida driver's license, ur
+securo an identification card. The sexual offonder shall identify himself or herself as a saxual
+offender who is required to comply with this section and shall provide proof that the sexuai
+offender reported as required in subsection (2). The sexual offander shall provide any of thr
+information specified in subsoction (2), if requested. The sexual offender shalt subinit to thir
+taking of a photograph for use in issuing a driver's license, renewad license, or idontification
+card, and for use by the departient in maintaiming current records of sexual offendors.
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 11 of 21
+(b) Pay the costs assessed by the Department of Highway Safety and Motor Vehicles for issuing
+or renewing a driver's license or identification card as required by this section. The driver's
+license or identification card issued must be in compliance with s. 322. 141(3).
+(c) Provide, upon request, any additional information necessary to confirm the identity of the
+sexual offender, including a set of fingerprints.
+(4)(a) Each time a sexual offender's driver's license or identification card is subject to renewal,
+and, without regard to the status of the offender's driver's license or identification card, within
+48 hours after any change in the offender's permanent or temporary residence or change in the
+offender's name by reason of marriage or other legal process, the offender shall report in
+person to a driver's license office, and shall be subject to the requiroments spocified in
+subsection (3). The Departmont of Highway Safety and Motor Vehicles shall forward to the
+department all photographs and information provided by sexual offenders. Notwithstanding the
+restrictions set forth in s. 322.142, the Dopartment of Highway Safaty and Motor Vehicles is
+authorized to release a reproduction of a color-photograph or digital-image license to the
+Department of Law Enforcement for purposes of public notification of sexual offenders as
+provided in this section and ss. 943.043 and 944.606.
+(b) A sexual offender who vacates a permanent residence and fails to establish or maintain
+another permanent or temporary residence shall, within 48 hours after vacating the permanont
+residence, report in person to the sheriff's office of the county in which he or she is located.
+The sexual offender shall specify the date upon which he or she intends to or did vacate such
+residence. The sexual offender must provide or update all of the registration information
+required under paragraph (2)(b). The sexual offonder must provide an address for the residence
+or other location that he or she is or will be occupying during the time in which he or she fails
+to ostablish or maintain a permanent or temporary residence.
+(c) A sexual offender who remains at a permanent residence after reporting his or her intent
+to vacate such residence shall, within 48 hours aftor the date upon which the offender
+indicated he or she would or did vacate such residence, report in person to the agency to which
+he or she reported pursuant to paragraph (b) for the purpose of reporting his or her address at
+such residence. When the sheriff receives the report, the sheriff shall promptly convey the
+information to the departmont. An offender who makes a report as required under paragraph
+(b) but fails to make a roport as required under this paragraph commits a felony of the second
+degree, punishablo as proviced in s. 775.082, s. 775.083, or s. 775.084.
+(d) A sexual offender must register any electronic mail address or instant message name with
+the department prior to using such electronic mail address or instant message name on or after
+October 1, 2007. The department shall establish an online system through which sexual
+offenders may securely accoss and update all electronic mail address and instant message
+name information.
+(5) This section does not apply to a sexual offonder who is also a sexual predator, as defined in
+s. 775.21. A sexual prodator must rogistor as required under s. 775.21.
+(6) County and local law enforcement agencies, in conjunction with the department, shall
+verify the addresses of sexual offenders who are not under the care, custody, control, or
+supervision of the Departmont of Corrections in a manner that is consistent with the provisions
+of the faderal Adam Walsh Child Protection and Safety Act of 2006 and any othor federal
+standards applicable to such verification or required to be met as a condition for the raceipt of
+federal funds by the state. local law enforcemont agencies shall roport to the departmont any
+failure by a sexual offender to comply with registration requiremonts.
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 12 of 21
+(7) A sexual offender who intends to establish residence in another state or jurisdiction other
+than the State of Florida shall roport in person to the sheriff of the county of current residence
+within 48 hours before the dato ho or she intends to leave this state to establish residence in
+another state or jurisdiction. The notification must include the address, municipality, county.
+and state of intended residence. The sheriff shall promptly provide to the department the
+information receivod from the sexual offonder. The department shall notify the statewide law
+enforcement agency, or a comparable agency, in the intended state or jurisdiction of residence
+of the sexual offender's intonded residence. The failure of a sexual offender to provide his or
+her intended place of residonce is punishable as provided in subsection (9).
+(8) A sexual offender who indicates his or her intent to reside in another state or jurisdiction
+other than the State of Florida and later decides to remain in this state shall, within 48 hours
+after the date upon which the sexual offender indicated he or she would loave this state,
+report in person to the sheriff to which the sexual offender reported the intended change of
+residence, and report his or her intent to remain in this state. The shoriff shall promptly roport
+this information to the department. A sexual offender who reports his or her intent to reside in
+another state or jurisdiction but who remains in this state without reporting to the sheriff in
+the manner required by this subsection commits a folony of the second degree, punishable is
+provided in s. 775.082, s. 775.083, or s. 775.084.
+(9)(a) A sexual offonder who does not comply with the requirements of this section commit: a
+felony of the third degree, punishable as provided in s. 775.082, s. 775.083, or s. 775.084.
+(b) A sexual offender who commits any act or omission in violation of this soction may be
+prosecuted for the act or omission in the county in which the act or omission was committed,
+the county of the last registered address of the sexual offender, or the county in which the
+conviction occurrod for the offense or offenses that meet the criteria for designating a person
+as a sexual offondor.
+(c) An arrest on charges of failure to registor when the offender has been provided and advised
+of his or her statutory obligations to register under subsection (2), the service of an
+information or a complaint for a violation of this section, or an arraignment on charges for a
+violation of this section constitutes actual notice of the duty to rogister. A sexual offonder's
+failure to immediatoly register as required by this section following such arrest, service, or
+arraignment constitutes grounds for a subsequent charge of failure to registor. A sexual
+offender charged with the crime of failure to register who assorts, or intends to assert, a lack
+of notice of the duty to register as a defense to a charge of failure to register shall
+immodiately register as required by this section. A sexual offonder who is charged with a
+subsoquent failure to registor may not assert the defense of a lack of notice of the duty to
+registor.
+(d) Registration following such arrest, service, or arraignment is not a defense and does not
+relievo the soxual offonder of criminal liability for the failure to register.
+(10) The departmont, the Dopartment of Highway Safety and Motor Vehicles, the Departinent
+of Corrections, the Dopartment of Juvenile Justice, any law enforcement agoncy in this stair:,
+and the personnel of those departments; an elected or appointed official, public employoe. ur
+school administrator; or an omployee, agency, or any individual or entity actim, at the roquet
+or upon the direction of ar, law enforcoment agoncy is immune from civil liability for dair-ges
+for good faith compliance with the requirements of this section or for the release of
+inforration under this section, and shall be prosumed to have acted in food faith in compring.
+recording, reporting, or relessing the information the presumption of good faith is not
+overcome if a technical or clerical error is made isy the department, the Department of
+lighway Safoty and Motor Vohicles, the Department of Corrections, the Department of turpie
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 13 of 21
+Justice, the personnel of those departments, or any individual or entity acting at the request
+or upon the direction of any of those departinents in compiling or providing information, or if
+information is incomplete or incorract because a sexual offender fails to report or falsely
+reports his or her current place of permanent or temporary residence.
+(11) Except as provided in s. 943.04354, a sexual offender must maintain registration with the
+departmont for the duration of his or her life, unless the sexual offender has roceived a fuli
+pardon or has had a conviction set aside in a postconviction proceeding for any offense that
+meets the criteria for classifying the person as a sexual offender for purposes of registration.
+However, a sexual offender:
+(a)1, Who has been lawfully released from confinement, supervision, or sanction, whichever is
+later, for at least 25 years and has not been arrested for any folony or misdemeanor offenso
+since release, provided that the sexual offender's requirement to registar was not based upon
+an adult conviction:
+a. For a violation of s. 787.01 or s. 787.02;
+b. For a violation of s. 794.011, excluding s. 794.011(10);
+c. For a violation of s. 800.04(4) (b) where the court finds the offense involved a victim undor
+12 years of age or sexual activity by the use of force or coercion;
+d. For a violation of s. 800.04(5) (b);
+e. For a violation of s. 800.04(5)c. 2. where the court finds the offense involved unclothed
+genitals or gonital area;
+f. For any attempt or conspiracy to commit any such offonse; or
+8. For a violation of similar law of another jurisdiction,
+may petition the criminal division of the circuit court of the circuit in which the sexual
+offender resides for the purpose of removing the requirement for registration as a sexual
+offender.
+2. The court may grant or deny relief if the offender demonstrates to the court that he or sho
+has hot been arrested for any crime since release; the requested relief complies with the
+provisions of the foderal Adam Walsh Child Protection and Safety Act of 2006 and any other
+foderal standards applicable to the removal of registration requiremonts for a sexual offender
+or required to be met as a condition for the receipt of federal funds by the state; and the court
+is otherwise satisfied that the offander is not a current or potential threat to public safoty. The
+state attorney in the circuit in which the petition is filed must be given notice of the petition
+at least 3 weeks before the hearing on the matter. The state attorney may present evidenco in
+opposition to the requested relief or may otherwise demonstrate the reasons why the petition
+should be denied. If the court denies the petition, the court may set a future date at which the
+sexual offender may again petition the court for relief, subjoct to the standards for relief
+provided in this subsection.
+3. Tho department shall remove an offondor from classification as a sexual offender for
+purposes of registration if the offender provides to the department a certifiod copy of the
+court's written findings or order that indicatos that the offender is no longer required to
+comply with the requirements for registration as a sexual offender.
+13
+
+
+Case 9:08-cv-80804-KAM
+Docktnent 11-1 Entered on FLSD Docket 08/18/2008 Page 14 of 21
+(b) As defined in sub-subparagraph (1)(a)1.b, must maintain registration with the department
+for the duration of his or her life until the person provides the department with an order issued
+by the court that designated the person as a sexual predator, as a sexually violont predator, or
+by another sexual offonder designation in the state or jurisdiction in which the order was
+issued which statos that such designation has been removed or demonstrates to the
+department that such designation, if not imposed by a court, has beon removed by operation of
+law or court order in the state or jurisdiction in which the designation was made, and providod
+such person no longer meets the criteria for registration as a sexual offender under the laws of
+this state.
+(12) The Legislature finds that sexual offenders, especially those who have committed offenses
+against minors, often pose a high risk of engaging in sexual offenses oven after being releasod
+from incarceration or commitment and that protection of the public from sexual offenders is a
+paramount government interest. Saxual offenders have a reduced expectation of privacy
+because of the public's interest in public safety and in the offective operation of government.
+Roleasing information concerning sexual offenders to law enforcement agencies and to persons
+who request such information, and the release of such information to the public by a law
+enforcement agency or public agency, will further the governmental interests of public safoty.
+The designation of a person as a sexual offender is not a sentence or a punishment but is simply
+the status of the offender which is the result of a conviction for having committed certain
+crimes.
+(13) Any person who has reason to belove that a sexual offender is not complying, or has not
+complied, with the requirements of this section and who, with the intent to assist the sexual
+offonder in eluding a law enforcement agency that is seeking to find the sexual offender to
+quastion the sexual offender about, or to arrest the sexual offender for, his or her
+noncompliance with the requiremonts of this section:
+(a) Withholds information from, or does not notify, the law enforcement agency about the
+sexual offender's noncompliance with the roquirements of this section, and, if known, the
+wheroabouts of the sexual offender;
+(D) Harbors, or attempts to harbor, or assists another person in harboring or attempting to
+harbor, the sexual offender; or
+(c) Conceals or attempts to conceal, or assists another person in concealing or attempting to
+concoal, the sexual offender; or
+(d) Provides information to the law enforcement agency regarding the sexual offender thet the
+person knows to be false information,
+commits a felony of the third degree, punishable as provided in s. 775.062, s. 775.063, or s.
+775.084.
+(14)(a) A sexual offender must report in person each year during the month of the sexual
+offender's birthday and during the sixth month following the sexual offender's birth month to
+the sheriffs office in the county in which he or she resides or is otherwise located to rerogistor.
+(b) However, a sexual offender who is required to register as a result of a conviction for:
+1. Section 787.01 or s. 787.02 whore the victim is a minor and the offender is not the victim's
+parent or guardian;
+14
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 15 of 21
+2. Section 794.011, excluding s. 794.011(10);
+3. Section 800.04(4)(b) where the court finds the offense involved a victim under 12 years of
+age or sexual activity by the use of force of coercion;
+4. Section 800.04(5)(b);
+5. Section 800.04(5)(c)1. where the court finds molestation involving unclothed genitals or
+genital area;
+6. Section 800.04(5)c.2. where the court finds molestation involving unclothed genitals or
+genital area;
+7. Section 800.04(5)(d) where the court finds the use of force or coercion and unclothed
+genitals or genital area;
+8. Any attempt or conspiracy to commit such offonse; or
+9. A violation of a similar law of another jurisdiction,
+must reregister each year during the month of the sexual offender's birthday and overy third
+month thereafter.
+(c) The sheriffs office may determine the appropriate times and days for reporting by the
+sexual offender, which shall be consistent with the reporting requirements of this subsection.
+koregistration shall include any changos to the following information:
+1. Name; social security number; age; race; sex; date of birth; height; weight; hair and eye
+color; address of any permanent residence and address of any current tomporary residence,
+within the state or out of state, including a rural route address and a post office box; any
+electronic mail address and any instant message name required to be provided pursuant to
+paragraph (4)(d); date and place of any employment; vehicle make, model, color, and licenso
+tag number; fingerprints; and photograph. A post office box shall not be provided in lieu of a
+physical residential address.
+2. If the sexual offender is enrolled, employed, or carrying on a vocation at an institution of
+ignor education in this state, the sexual offender shall also provide to the departmont the
+name, address, and county of each institution, including each campus attended, and the sexua
+offender's onrollment or omployment status.
+3. If the sexual offender's place of residence is a motor vehicle, trailer, mobile home, or
+manufactured home, as defined in chapter 320, the sexual offonder shall also provide the
+vahicle identification numbor; the license tag number; the registration number; and a
+description, including color scheme, of the motor vehicle, trailer, mobile homo, or
+manufactured home. If the sexual offondor's place of residence is a vessel, live-aboard vessel,
+or houseboat, as dofined in chapter 327, the sexual offender shall also provide the hull
+identification number; the manufacturer's serial number; the name of the vessol, live-aboard
+vessel, or housaboat; the registration number; and a description, including color scheme, of
+the vessol, live-aboard vessol or houseboat.
+4. Any sexual offonder who fails to ruport in person as required at the shoriff's office, or whe
+fails to respond to any address verification correspundence from the departmont within 3
+weeks of the date of the correspondance or who falls to report electronic mail addrosses or
+15
+
+
+Case 9:08-cv-80804-KAM Dogement 11-1 Entered on FLSD Døcker 08/18/2008 Page 16 of 21
+instant message names, commits a felony of the third degree, punishable as provided in s.
+775.082, s. 775.083, or s. 775.084.
+(d) The sheriff's office shall, within 2 working days, electronically submit and update all
+information provided by the sexual offender to the department in a manner prescribed by the
+department.
+16
+
+
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 17 of 21
+RULE 3.992(l, CRIMINAL PUNISHMENT CODE SCORESHEET
+1. DATE OF SENTENCE
+2. PREPARER'S NAME L DO A SAO
+COUNTY
+4. SENTENCING JUDGE
+€ 30/08
+belohlauck
+almseach
+Fucillo
+5. NAME (LAST, FIRST, MI.I.)
+10. PRIMARY OFF. DATE
+Epstein, Jefrey
+,E.
+1/20/33
+DeW OTHER
+PLEA T
+11. PRIMARY DOCKET #
+08 4387
+TRIAL L
+PRIMARY OFFENSE: If Qualifier, please check_.. A...S.
+20060+9y54XXX
+_R (A-Attempt, S=Solicitation, C=Conspiracy, R=Reclassification
+FELONY
+F.S.#
+DESCRIPTION
+OFFENSE
+POINTS
+DEGREE
+2ºE
+79403 trzuring Person Under 18 to
+LEVEL
+07
+Level - Points: 1=4, 2=10, 3=16, 4=22, 5=28, 6=36, 7=56, 8=74,/0=92, 10=116
+Prior capital felony triples Primary Offense points
+Prostitation
+156
+II. ADDITIONAL OFFENSES): Supplemental page attached J
+DOCKET#
+FEL/MM
+06-9454
+DEGREE
+F8N7.94607(24
+Description
+Felon,
+elom
+Solicitabas
+QUALIFY COUNTS
+AS CR
+x'
+POINTS
+. 7.
+TOTAL
+0000
+Description
+0000
+Description
+(Level - Points: M=0.2, 1=0.7, 2=1.2, 3=2.4, 4=3.6, 5=5.4, 8=18, 7=28, 9=37, 9=46, 10=58)
+Prior capital felony triples Additional Offense points L
+Supplemental page points
+Il.
+56.7
+III. VICTIM INJURY:
+Number
+Total
+Number Total
+2 Degree Murder
+Death
+Severe
+Moderate
+240 X
+120 X
+40 X
+18X
+Slight
+Sex Penetration
+Sex Contact
+4X
+80 X
+40 X
+Cr
+IlI.
+IV. PRIOR RECORD: Supplemental page attached O
+JUN 30 2203
+FEL/MM
+DEGREE
+F.S #
+OFFENSE
+LEVEL
+QUALIFY
+A S C R
+DESCRIPTION
+0000
+0000
+0000
+0000
+0000
+0000
+(Level - Points: M=0.2, 1=0.5, 2=0.8, 3=1.6, 4=2.4, 5=3.6, 6=9, 7=14, 8=19, 9=23, 10=29)
+NUMBER
+POINTS
+TOTAL
+Supplemental page points
+Page 1 Subtotal:
+"567
+17 577
+1 mud:
+
+
+Case 9:08CV-80804-KAM Documes 120er 99000032008 Page 1801212
+V. Legal Status violation = 4 Points
+VI.
+Community Sanction violation before the court for sentencing
+Jeffrey epstein ann. 56.7
+VI.-
+6 points x each successive violation OR
+New felony conviction = 12 points x each successive violation
+VII. Firearm/Semi-Automatic or Machine Gun = 18 or 25 Points
+VIII. Prior Serious Felony = 30 Points
+Subtotal Sentence Points
+VII.
+VIlI._
+567
+IX.
+Enhancements (only if the primary offense qualifies for enhancement)
+Law Enlorcement Protection
+Drug Trafficking
+Grand Theit Motor Vehicle
+-x 1.5
+_x 1.5
+Street Gang
+(offenses committed on or añter 10-1-90)
+-x 1.5
+Domestic Violence
+fallenges committed on or after 10-1-97)
+_x 1.5
+Enhanced Subtotal Sentence Points
+TOTAL SENTENCE POINTS
+156.7
+SENTENCE COMPUTATION
+If total sentence points are less than or equal to 44, the lowest permissible sentence is any non-state prison sanction.
+If total sentence points are greater than 44:
+56.
+total sentence polis
+minus 28 = 28.2
+x.75=
+21.5
+lowest permissible prison
+sentence in months
+he maximum sentence is up to the statutory maximum for the primary and any additional offenses as provided in s. 775.08
+.S., unless the lowest permissible sentence under the code, exceeds the statutory maximum. Such sentences may be impose
+concurrently or consecutively. If total sentence points are greater than or equal to 363, a life sentence may be imposed.
+maximum sentence
+in years
+TOTAL SENTENCE IMPOSED
+Years
+Months
+Days
+• State Prison
+* County Jail
+• Life
+• Time Served
+12
+18 month
+I te menths
+Violent career criminal, a prison ropes C
+entender or entered or minimum rendere
+Megated Depanure Plea Bargain
+Other Reason
+Дила менів
+JUDGE'S SIGNATURE
+L 86958:
+18
+
+
+NAME:
+Case 9:08-cv-80804-KAM Document 11-1 Entered on FLSD Docket 08/18/2008 Page 19 of 21
+EPSTEIN, JEFFREY
+ЛАСКЕТ#: 0338617
+BOOK#: 2008039317
+ALIAS NAMES:
+OVER B NAMES:
+EPSTEp. JEFFREY - EPSTEIN, JEFFREY EDWARD-
+Monday, June 30, 2008
+11:33:12 AM
+INCARCERATION DATE/TIME 06/30/2008 11:13
+PRISONER TYPE: LOCAL CHARGES
+DOB: 01/20/1953
+AGE: 55
+SSN: 090-44-3348
+R/S:
+W/M
+HEIGHT: 6ft ft0 in
+WEIGHT: 200
+PALM BEACH SHERIFFS OFFICE
+BOOKING CARD
+BKG.LOC: MOBILE BOOKING
+BKG. ID #: 8548
+HAIR COLOR: GRY
+EYE COLOR: BLU
+ADDRESS: 358 EL BRILLO WY
+CITY: PALM BEACH
+ID #:
+
+SID #: 06587245
+ALIEN #:
+POUCH: 3050
+AFIS: 2006036744
+U.S. MARSHAL#:
+OBTS #:
+STATE: FL ZIP: 33480
+NCIC:
+DOC#:
+INCIDENT #:
+CITIZEN
+COUNTRY: USA
+FBI #:
+787075K6
+ARREST ADDRESS:205 N DIXIE HWY (MAIN CT HOUSE) CITY: WPB
+ARREST DATE: 06/30/2008
+ARREST TIME: 10:15
+BKG. DATE:
+06/30/2008
+BKG. TIME:
+11:13
+WARRANT/CASE#:
+COURT DIVISION:
+ARREST OFFICER: DIS DELPLATO
+ARREST AGENCY: 01 - PBSO
+TRANS. OFFICER: DIS MCINTOSH
+TRANS. AGENCY: 01 - PBSO
+CASE TYPE: RECOMMIT-FELONY
+NOTE:
+STATUTE:
+CASE FLAG: NO BOND
+9999.0004 (NN)
+0
+CT: DESCRIPTION:
+-RE-COMMIT
+FELONY OFFER TO COMMIT PROSTITUTION // CASE: 2006CF009454AXXX // BK#2006036744
+STATE: FL ZIP:
+CURRENT BOND:
+$0.00
+VOFC; B TYPE: CUR. BOND:
+$0.00
+$0.00
+2203
+1-
+HOLDS:
+HOLD DATE/TIME:
+HOLD BY:
+HOLD DEPT.:
+HOLD REM.DATE/TIME: HOLD REM. BY:
+289
+HOLD.REM. DEPT:
+1
+2
+3
+ALERT DESCRIPTION:
+31
+ALERT NARRATIVE:
+DNA NOT ON FILE/FELONY CONVICTION
+80
+2
+3
+OVER 3 ALERTS:
+KEEP SEPARATE FROM:
+NONE
+OVER 6 NAMES:
+:77
+ASSIGNED HOUSING:
+NCIC INTAKE:
+PALMS REL.:
+MED. CLEAR REL:
+RELEASE DATE/TIME:
+COURT DATE/TIME:
+CLERK
+NTA DATE/TIME:
+NOIC RELEASE:
+PHOTO ID:
+RELEASE MOVE:
+RELEASE INFORMATION:
+COURT LOCATION:
+WARRANTS I]
+F.P. ENTERED:
+CLASSIFICATION:
+NTA LOC:
+F.P. CLEAR:
+MED.CLEAR IN:
+STATE ATTY LI
+CENTRAL RCDS O]
+CLASS O
+JUL - 1 2008
+01952
+
+
+Case 9:08-CV-80804-KAM Dockfient 11-1 Entered on FLSD Docker 88/18/2008 Page 20 of 21
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT,
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 2006CF009454AXX
+DIVISON:
+"W"
+STATE OF FLORIDA
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+C'ARON R. BOCK. CLE:
+2008 JUL - 2 PM 3:40
+AGREED ORDER SEALING DOCUMENT IN COURT FILE
+THIS MATTER came before the Honorable Judge Deborah Dale Pucillo on June 30,
+FILED
+apprised in the circumstances, it is hereby:
+attached
+ORDERED AND ADJUDGED that theflocument filed by the Defendant on July 2, 2008
+be sealed by the Clerk in the court file.
+DONE AND ORDERED in
+West Palm Beach, Palm Beach County, Florida
+this 2
+day of July, 2008.
+Debolical fallo
+DEBORAH DALE PUCILLO
+Circuit Court Judge
+Copies forwarded to:
+Jack A. Goldberger, Esq.
+Counsel for the Defendant
+250 Australian Avenue South, Ste. 1400
+West Palm Beach, Florida 33401
+Lanna Belohlavek, Esq.
+Assistant State Attorney
+(interoffice)
+AB JUL 0 3 2008
+2054
+
+
+Case 9:08-cv-80804-KAM Docment 11-1 Entered on FLSD Docket 98/18/2008 Page 21 of 21
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT OF FLORIDA, IN AND FOR
+PALM BEACH COUNTY
+CASE NO. 2006 CF 0U9454AXX
+DIVISION_
+W
+STATE OF FLORIDA
+VS.
+Jeffrey Epstein
+oN July 2,2008
+SHARON R. BOCK. CLERK
+TAL
+ACH COUNTY. FL
+2008 JUL - 2 PM 3:40
+FILED
+Psychiatric (Medical, etc.) Report dated
+from
+Presentence Investigation Report dated
+from
+Other.
+Non- Prosecutio Apeement
+SEALED IN COURT FILE, NOT TO BE
+OPENED WITHOUT ORDER OF COURT
+- 22 0 3200
diff --git a/vision-fixhub/court-01/fed7a3f9087a371405f067521e092b7ddd93d31e152b0b979871402f38013429.receipt.json b/vision-fixhub/court-01/fed7a3f9087a371405f067521e092b7ddd93d31e152b0b979871402f38013429.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4a53b53cbb56702bb9182994c3105a1a66344084
--- /dev/null
+++ b/vision-fixhub/court-01/fed7a3f9087a371405f067521e092b7ddd93d31e152b0b979871402f38013429.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -265,
+  "dataset": "marble-joined",
+  "doc_id": "fed7a3f9087a371405f067521e092b7ddd93d31e152b0b979871402f38013429",
+  "engine": "marble-apple-vision",
+  "event_count": 23,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "a3cef6c359df3693b98e840da336e3ff2a5f67cb54cdfb08a2fc3b43e7c2904e",
+  "output_sha256": "30d6d3929465724552f8d0fbbd39d826d3c64abfd0e39e3a6623292c55943024",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.md b/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.md
new file mode 100644
index 0000000000000000000000000000000000000000..267c21f9c5cd4890a63ed9a351221fb6d256cda5
--- /dev/null
+++ b/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.md
@@ -0,0 +1,40 @@
+Case 9:08-cv-80736-KAM Document 116 Entered on FLSD Docket 10/31/2011 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE No. 08-80736-CIV-MARRA/
+JANE DOE 1 and JANE DOE 2,
+Plaintiffs,
+V.
+UNITED STATES OF AMERICA,
+Defendant.
+UNOPPOSED MOTION FOR LEAVE To FILE OVERLONG PLEADING
+Proposed intervenors Roy Black,
+Weinberg & Jay Lefkowitz seek leave to file their
+"Reply In Support Of Supplemental Briefing By Proposed Intervenors Roy Black,
+Weinberg,
+and Jay Lefkowitz," which is 19 pages. Undersigned counsel communicated with Paul Cassell,
+counsel for the plaintiffs, who indicated that he did not object. The reply addresses significant
+issues, including arguments on the merits that were addressed by the plaintiffs.
+We made every effort to address each issue in an efficient manner, and believe that this 19-
+page reply is necessary to fully address all the arguments raised by the parties. We respectfully
+request that the Court grant leave to file his overlong reply.
+
+
+Case 9:08-cv-80736-KAM Document 116 Entered on FLSD Docket 10/31/2011 Page 2 of 2
+We certify that on October 31, 2011, the foregoing document was filed electronically with
+the Clerk of the Court using the CM/ECF system.
+Respectfully submitted,
+BLACK, SREBNICK, KORNSPAN
+& STUMPF, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+Office: (305) 371-6421
+Fax: (305) 358-2006
+By
+/S/
+ROY BLACK, ESQ.
+Florida Bar No. 126088
+JACKIE PERCZEK, ESQ.
+Florida Bar No. 0042201
+2
diff --git a/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.receipt.json b/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7d67b18f864200e9858c6cc5767db22dd9230649
--- /dev/null
+++ b/vision-fixhub/court-01/fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "fede81939a976a2309c6abf0b853ec8314b7076dd0a401aaa4a7109ffe624815",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3fb3306295e93ee8617a7edb3a2a9d3b0a290a239fca767b1036b97488607456",
+  "output_sha256": "88ab8c94b4151980b0665c13b5254110afc289a85921a5b0ac69db622b55ca40",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/fee73d166d93b24fb4d3b9578729709706b89e1f24423b4b9ccad68df05fec88.md b/vision-fixhub/court-01/fee73d166d93b24fb4d3b9578729709706b89e1f24423b4b9ccad68df05fec88.md
new file mode 100644
index 0000000000000000000000000000000000000000..eec2b5f6be2eae1c88a32e1d06cfe2ff9781faf2
--- /dev/null
+++ b/vision-fixhub/court-01/fee73d166d93b24fb4d3b9578729709706b89e1f24423b4b9ccad68df05fec88.md
@@ -0,0 +1,266 @@
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 1 of 11
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80381-MARRA-
+JANE DOE NO. 5,
+Plaintiff,
+VS.
+JEFFREY EPSTEIN,
+Defendant.
+/
+MOTION TO SET ASIDE CLERK'S DEFAULT
+Defendant Jeffrey Epstein, pursuant to Fed. R. Civ. P. 55(c), hereby moves
+to set aside the clerk's default entered on June 2, 2008, upon the following
+showing of "good cause."
+Introduction
+The clerk's default was entered prematurely. Service was effected as of
+June 2. Accordingly the response is due 20 days later, on or before June 23. See
+Fed. R. Civ. P. 12(a)(1)(A)(i).
+The plaintiff, in moving for a clerk's default, implied that service was made
+in accordance with either federal or Florida procedure. As discussed below,
+however, service was clearly ineffective under the federal and Florida rules of
+1
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 2 of 11
+procedure. Accordingly, the only possibility for valid service was service under
+New York rules of procedure. Cf. RCP's Lear, LLC v. Taughannock Aviation
+Corp., No. 5:07-CV-96, 2008 WL 305103, at *4 (N.D.N.Y. Jan. 31, 2008)
+(observing that "[a]s a threshold matter, the court must [first] address the rules
+pursuant to which process was served"').
+Service of process was valid under New York's rule for so-called
+"substitute-service" (i.e., service in a manner other than delivery in-hand to the
+defendant herself or himself), but that statute gives the defendant more time to
+respond than do the federal or Florida rules. See id. (acknowledging that Fed. R.
+Civ. P. 4(e)(2) has a "'resided therein' requirement," unlike "New York's
+substituted service statute," NY CPLR 308); NY CPLR 308 (providing that
+service is not deemed effected until 10 days after the process-server's affidavit is
+filed with the Court).
+This is not a motion to quash, or a motion arguing that service was
+completely ineffective. To the contrary, we acknowledge that service was effective
+under New York procedure, but point out that it was ineffective under Florida and
+federal procedure. Federal Rule of Civil Procedure 4(e)(1) permits service to be
+made according to "state law for serving a summons in ... the state ... where
+service is made" as an alternative to following the federal service method (i.e.,
+Rule 4(e)(2)).
+2
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 3 of 11
+As shown below, under New York's so-called "substituted-service" rule,
+service was effected on June 2, not May 7 (as the plaintiff and the deputy clerk of
+court evidently believed). Accordingly, the defendant's response to the complaint
+is not due until June 23. See Fed. R. Civ. P. 12(a)(1)(A)(i) (allowing 20 days from
+the date of service of process to serve answer).'
+Facts and Procedural History
+On May 7, 2008, service was delivered at defendant Epstein's house
+located at 9 East 71st Street, New York, New York, to Richard Barnett, an
+employee.
+Mr. Barnett does not reside at that address. See Affidavit of Richard
+Barnett (attached as Ex. A).
+Upon the plaintiff's motion, the Clerk of Court entered a clerk's
+default on June 2, 2008. [D.E.5, 6].
+4.
+On June 6, the plaintiff filed a motion for judgment upon default. 3
+ID.E. 7].
+1
+In this case, the 20th day falls on a Saturday (June 21). The answer is therefore due on
+Monday, June 23. See Fed. R. Civ. P. 6(a)(3) (establishing that when a deadline falls on
+Saturday, the "period runs until the end of the next day that is not a Saturday").
+2
+Notably, the plaintiff's attorney never mailed Mr. Epstein a copy of his motion for a
+Clerk's entry of default.
+The plaintiff's attorney here previously filed an identical action, captioned Jane Doe No.
+1 v. Epstein, Case No. 08-80069-KAM, on behalf of a different plaintiff. That action was
+voluntarily dismissed by the plaintiff's attorney after a motion to intervene was filed by Jane Doe
+3
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 4 of 11
+Overview of Rules for Service of Process
+The Federal Rules of Civil Procedure authorize three distinct methods of
+service in a diversity action. First, service can be effected in accordance with the
+procedures "in the state where the district court is located" (here, Florida). See
+Fed. R. Civ. P. 4(e)(1). Second, service can be effected in accordance with the
+procedures "in the state ... where service is made" (here, New York). See Fed. R.
+Civ. P. 4(e)(1). Third, service can be effected in accordance with federal
+procedure. See Fed. R. Civ. P. 4 (e)(2). Cf. David D. Siegel, Practice Commentary
+on Rule 4 of the Federal Rules of Civil Procedure, Commentary C4-22 (observing
+that "there is no priority between the [authorized methods of service]") (emphasis
+added).
+No. 1 (through her mother) indicating that neither Jane Doe No. 1 nor her mother had consented
+to the attorney's filing the lawsuit on her behalf. See Case No. 08-80069-KAM [D.E. 9].
+In addition to that action, the same plaintiff's attorney here has filed four other, identical
+lawsuits against Jeffrey Epstein on behalf of four plaintiffs that are still pending before this
+Court: Jane Doe No. 2 v. Epstein, Case No. 9:08-cv-80119-KAM; Jane Doe No. 3 v. Epstein,
+Case No. 9:08-cv-80232-KAM; Jane Doe No. 4 v. Epstein, Case No. 9:08-cv-80380-KAM; and
+Jane Doe No. 5 v. Epstein, Case No. 9:08-cv-80381-KAM. Plaintiff's counsel has sought an
+entry of default in each case. In the Jane Doe No. 2 litigation, the deputy clerk, identified on the
+docket as "tp," declined to enter a default on the grounds that there had been "Improper Service."
+See 9:08-cv-80119-KAM [D.E. 7, 8]. In the Jane Doe No. 3 litigation, the deputy clerk has not
+yet ruled upon the plaintiff's motion. See Case No. 9:08-cv-80232-KAM [D.E. 5]. In the Jane
+Doe No. 4 and Jane Doe No. 5 litigation, the deputy clerk, identified on both docket sheets as
+"ail," entered the default. See Case No. 9:08-cv-80380-KAM [D.E. 7, 8] and Case No. 9:08-cv-
+80381-KAM [D.E. 5, 6]. Since then, the plaintiff's attorney has moved for a judgment of default
+in those two cases (Jane Doe Nos. 4 and 5). See Case No. 9:08-ev-80380-KAM [D.E. 9] and
+Case No. 9:08-cv-80381-KAM [D.E. 7].
+4
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 5 of 11
+Thus, when a diversity action is brought in the Southern District of Florida,
+and service is made in New York, service is effective when it complies with either
+Florida law or New York law, or alternatively, with federal procedure.
+As discussed below, because New York does not have a residency
+requirement for the person to whom substitute-service is delivered (and Florida
+and the federal rules do), service was effective only in accordance with New York
+procedure. Cf. RCP's Lear, LLC, 2008 WL 305103, at *4 (resolving parties'
+dispute concerning the intended method of service, and applicable procedure).
+Stated differently, service did not comply with either federal procedure or Florida
+procedure.
+New York Procedure-CPLR 308 (no residency requirement)
+Under New York law, service of process can be effected by delivering the
+summons "to a person of suitable age and discretion at the ... dwelling place or
+usual place of abode of the [defendant]," and when the summons is "mailed to the
+[defendant] at his or her last known residence or ... mailed] ... by first class
+mail to the [defendant] at his or her actual place of business" in accordance with
+specific technical instructions. N.Y. C.P.L.R. § 308(2) (McKinney 2008). As an
+additional requirement, "proof of such service shall be filed with the clerk of the
+court designated in the summons within twenty days of either such delivery or
+mailing, whichever is effected later." Id.
+5
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 6 of 11
+In accordance with New York procedure, such substituted service "shall be
+complete ten days after such filing." Id. (emphasis added). Accordingly, New
+York does not use the date of delivery to the person at the defendant's "abode" as
+the date service is effected. This was the point of error for the deputy clerk and the
+plaintiff's attorney.
+Florida Procedure-Fla. Stat. § 48.031 (residency requirement)
+Under Florida law, service of process can be effected "by leaving the copies
+[of the summons and complaint] at [the defendant's] usual place of abode with any
+person residing therein who is 15 years of age or older and informing the person
+of their contents." Fla. Stat. § 48.031(1)(a) (2007) (emphasis added). Service is
+deemed effected as of the date of delivery.
+Federal Procedure-Fed. R. Civ. P. 4 (e)(2)(B) (residency requirement)
+Service is effective, under federally authorized procedures, when copies of
+both the summons and the complaint are "le[ft] ... at the individual's dwelling or
+usual place of abode with someone of suitable age and discretion who resides
+there." Fed. R. Civ. P. 4 (e)(2)(B). Again, service is deemed effected as of the
+date of delivery.
+6
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 7 of 11
+Discussion
+Defendant Jeffrey Epstein's response to the complaint is not due until June
+23. Accordingly, the clerk's entry of default was premature. For the following
+"good cause," it should be set aside. Fed. R. Civ. P. 55(c) ("The court may set
+aside an entry of default for good cause.").
+A. Service was not made on someone who "resided" at the subject address.
+Substituted service was attempted on Richard Barnett at a house owned by
+Mr. Epstein located at 9 East 71st Street, New York, New York. See Affidavit of
+Service [D.E. 4]. Mr. Barnett has never lived there.* (Barnett Aff. I| 3.)
+B. Because service was not made on someone who "resided" at the subject
+address, service was effective only in accordance with New York
+procedure.
+Of the three possible methods of service in this case-New York service,
+Florida service, and federal-rules service-only New York rules allow substituted
+service on someone who does not "reside" at the service address. Compare Fla.
+Stat. § 48.031(1)(a) (authorizing substituted service of process only on a person
+meeting certain criteria who "reside[s]" at the service address), and Fed. R. Civ. P.
+4 (e) (2)(B) (same), with NY CPLR 308(2) (authorizing so-called "leave-and-mail"
+* Indeed, in a motion for an order compelling the Clerk to enter default against Mr. Epstein,
+filed in connection with the Jane Doe No. 2 litigation, the plaintiff's attorney characterized Mr.
+Barnett simply as an "Assistant and House Staff Employee," not a resident of the property.
+Case No. 9:08-cv-80119-KAM [D.E. 9 at 2].
+7
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 8 of 11
+substituted service, which does not require delivery to a person who actually
+resides the service address).
+Because Mr. Barnett was not a resident of 9 East 7lst Street, logically,
+service could have been effected only in accordance with New York procedure.
+C. Service was effective as of June 2, not earlier.
+As noted above, Fed. R. Civ. P. 4 permits service according to the law 'in
+the state ... where service is made," here, New York. See Fed. R. Civ. P. 4(e)(1).
+While New York permits substitute service on a non-resident at the defendant's
+"abode," such substituted service is not complete until 10 days after the affidavit
+reciting the method of service is actually filed with the Court. See NY CPLR
+308(2).
+Although the summons was left with Mr. Barnett at Epstein's New York
+home on May 7, the affidavit of service was not filed with the Court until May 22.
+Accordingly, under NY CPLR 308(2), service is not deemed complete until 10
+days later, which was June 2. Counting 20 days more, according to Fed. R. Civ. P.
+12(a)(1)(A)(i) and 5, Mr. Epstein's response is still not due until June 23.
+Accordingly, the plaintiff's motion for default was almost three weeks early and
+the default was entered improperly.
+8
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 9 of 11
+D. "Actual" notice is irrelevant.
+In the related Jane Doe No. 2 case, the plaintiff advances the untenable
+position that the service rules are trumped simply because Epstein had "actual
+notice" of the complaints. See D.E. 9 at 4, I 9 (Jane Doe No. 2 v. Epstein, Case
+No. 9:08-cv-80119-KAM) ("Defendant Epstein had actual notice of the filing of
+the Complaint, and the Plaintiff has exercised diligence and good faith in
+attempting to serve Defendant Epstein with process. Accordingly, entry of default
+is appropriate."). The Eleventh Circuit is clear, however, that "actual notice of a
+suit does not dispose of the requirements of service of process."
+V.
+Warden, FCC Coleman-USP, 259 Fed. Appx. 181, 182 n.2 (11th Cir. 2007) (citing
+Mfrs. Hanover Trust Co. v. Ponsoldt, 51 F.3d 938, 940 (11th Cir. 1995)).
+Conclusion
+We do not dispute that service was effective. We only dispute the date that
+it became effective. Since service was ineffective under both Florida law and the
+federal-rules alternative (because the recipient of the service did not "reside" at the
+address), the only service law that could apply is New York's. New York's rule
+for substituted-service does not start the 20-day clock for responding to the
+complaint until 10 days after the process-server's affidavit is filed with the Court.
+9
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 10 of 11
+Accordingly, the 20-day clock did not start to tick (i.e., service was not
+deemed to have been effected) until June 2. Counting time as provided by Fed. R.
+Civ. P. 6(a)(3), Epstein has until June 23 to serve a response to the complaint.
+WHEREFORE, "good cause" having been showing under Fed. R. Civ. P.
+55(c), the clerk's default should be set aside.
+Respectfully submitted,
+ATTERBURY, GOLDBERGER &
+WEISS, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, Florida 33401
+Tel: 561 659 8300
+Fax: 561 835 8691
+By: Is/ Jack A. Goldberger
+Jack A. Goldberger
+Fla. Bar No. 262013
+jgoldberger@agwpa.com
+Attorneys for Defendant Jeffrey Epstein
+10
+
+
+Case 9:08-cv-80381-KAM Document 9 Entered on FLSD Docket 06/13/2008 Page 11 of 11
+CERTIFICATE OF COMPLIANCE WITH LOCAL RULE 7
+Counsel for defendant has conferred in good faith with counsel for the
+plaintiff, who opposes the relief requested in this motion.
+Is/ Jack A. Goldberger
+Jack A. Goldberger
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 13, 2008, I electronically filed the
+foregoing document with the Clerk of the Court using CM/ECF. I also certify that
+the foregoing document is being served this day on counsel of record identified
+below by facsimile and U.S. Mail.
+Jeffrey M. Herman, Esq.
+Stuart S. Mermelstein, Esq.
+Adam D. Horowitz, Esq.
+Herman & Mermelstein, P.A.
+18205 Biscayne Blvd, Suite 2218
+Miami, Florida 33160
+Fax: 305 931 0877
+Is/ Jack A. Goldberger
+Jack A. Goldberger
diff --git a/vision-fixhub/court-01/fee73d166d93b24fb4d3b9578729709706b89e1f24423b4b9ccad68df05fec88.receipt.json b/vision-fixhub/court-01/fee73d166d93b24fb4d3b9578729709706b89e1f24423b4b9ccad68df05fec88.receipt.json
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diff --git a/vision-fixhub/court-01/ff1310e2b3bde79948de16f3af52e2a688639124e1c1002ee98b1f3423f6b569.md b/vision-fixhub/court-01/ff1310e2b3bde79948de16f3af52e2a688639124e1c1002ee98b1f3423f6b569.md
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@@ -0,0 +1,66 @@
+Case 9:08-cv-80994-KAM Document 3
+Entered on FLSD Docket 09/15/2008 Page 1 of 2
+JANE DOE NO. 6
+V.
+JEFFREY EPSTEIN,
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.: 08-CV-80994-HURLEY|
+Plaintiff,
+Defendant.
+NOTICE OF APPEARANCE
+Burman, Critton, Luttier & Coleman, LLP file their appearance as co-counsel for
+Defendant, JEFFREY EPSTEIN, in the above-styled matter.
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being
+served this day on all counsel of record, identified on the following Service List in the
+manner specified by CM/ECF on this JuL day of
+September
+_, 2008:
+Adam D. Horowitz, Esq.
+Jeffrey Marc Herman, Esq.
+Stuart S. Mermelstein, Esq.
+18205 Biscayne Boulevard
+Suite 2218
+Miami, FL 33160
+305-931-2200
+Fax: 305-931-0877
+ahorowitz@hermanlaw.com
+jherman@hermanlaw.com
+Irivera@hermanlaw.com
+Counsel for Plaintiff Jane Doe #6
+Jack Alan Goldberger
+250 Austrian Avenue Wals, P.A.
+Suite 1400
+West Palm Beach, FL 33401-5012
+561-659-8300
+Fax: 561-835-8691
+jagesq@bellsouth.net
+Counsel for Defendant Jeffrey Epstein
+Michael R. Tein, Esq.
+Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+305-442-1101
+
+
+Case 9:08-cv-80994-KAM Document 3 Entered on FLSD Docket 09/15/2008 Page 2 of 2
+Jane Doe No. 6 v. Epstein
+Page 2
+Fax: 305 442 6744
+Counsel for Defendant Jeffrey Epstein
+tein@lewistein.com
+Respectfully submitted,
+BURMAN, CRITTON, LUTTIER
+& COLEMAN, LLP
+515 N. Flagler Drive, Suite 400
+west Palm Beach, FL
+03401
+(561) 842-2820
+By:
+Robert D. Critton, Jr.
+Florida Bar #617296
+Co-counsel for Defendant Jeffrey Epstein
+rcrit@bclclaw.com7
+mpike@bclclaw.com
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diff --git a/vision-fixhub/court-01/ff3a7accf01bf98d5d16060bd56b24a95a945acb06d66ad9079b617f1a9cc53c.md b/vision-fixhub/court-01/ff3a7accf01bf98d5d16060bd56b24a95a945acb06d66ad9079b617f1a9cc53c.md
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@@ -0,0 +1,21 @@
+Case 9:08-cv-80736-KAM Document 23 Entered on FLSD Docket 08/13/2008 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+NO. 08-80736-CIV-MARRA/
+IN RE: JANE DOES 1 & 2,
+Petitioner
+ORDER
+PLEASE TAKE NOTICE that this cause has been set for a status conference on
+Thursday, August 14, 2008, at 3:30 p.m. before United States District Judge Kenneth A. Marra.
+The hearing shall be held in Courtroom 4 at the United States Courthouse, 701 Clematis Street,
+West Palm Beach, Florida. The parties may appear by telephone.'
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 13" day of August, 2008.
+KENNETH A. MARRA
+United States District Judge
+Copies furnished to:
+all counsel of record
+'Any party wishing to appear by telephone must contact I
+12:00 noon on August 14, 2008, to make the appropriate arrangements.
+at 561-514-3765 by
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diff --git a/vision-fixhub/court-01/ff475b80a21b5a8b92fe554f31961984e92ec746d8387da872d16bd164cd6995.md b/vision-fixhub/court-01/ff475b80a21b5a8b92fe554f31961984e92ec746d8387da872d16bd164cd6995.md
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@@ -0,0 +1,190 @@
+Case 9:08-cv-80381-KAM Document 127-1 Entered on FLSD Docket 07/29/2009 Page 1 of 5
+The Psychological Trauma Center
+a division of Preventive Psychiatry Associates Medical Group, Inc.
+Medical Director: Gilbert W. Kliman, M. D.
+2105 Divisadero St., San Francisco, CA 9411:
+Phone (415)292-7119 Fax (415) 749-2802
+www.experichildpochiatrx.com
+Forensic Child Psychiatric Evaluations, Life Care Plans & Testimony
+DECLARATION OF GILBERT KLIMAN, M. D.
+June 4, 2009
+RE: EXPECTATION OF HARM FROM DISCLOSING THE PLAINTIFFS' IDENTITIES
+IN DOES V JEFFREY EPSTEIN
+1. 1, Gilbert W. Kliman, M.D., of 2105 Divisadero Street, San Francisco, California,
+CA. Physicians License G55912, declare the following under penalty of perjury:
+2. I have been retained by plaintiffs' law firm, Mermelstein & Horowitz, to give expert
+testimony. If called as a witness, I would testify truthfully and competently concerning
+my psychiatric findings about each of the plaintiffs' alleged experiences of sexual abuse,
+and the enduring effects that I find each of the young women have suffered as a direct
+result of the sexual acts perpetrated by the defendant.
+3. I have been asked to respond to the Defense motion, which requests that some of the
+plaintiffs, who are now adults, should be publicly named. It is my opinion that
+involuntary public disclosure will result in the plaintiffs experiencing revictimization,
+albeit by a justice system that is designed to protect them. If their identities are released,
+the victims will be at-risk of having their personal lives scrutinized by friends, extended
+family, spouses, children, fellow students, employers and fellow employees, the media
+and general public. This type of exposure humiliates many victims and represents anothe
+betrayal of trust. Public exposure places the plaintiffs at further risk of stigmatization
+4. Due to traumatization the plaintiffs are arrested in their development, and even those
+who are now legally adults are arrested in part to adolescent aspects of psychology.
+5. The plaintifts do not hold their heads high with pride for having been sexually
+absorption and self-doubt and self-blame about sexual acts.
+
+A
+1
+
+
+Case 9:08-cv-80381-KAM Document 127-1 Entered on FLSD Docket 07/29/2009 Page 2 of 5
+6. Clinically harmful levels of shame, self-consciousness, self-doubt and self-blame are
+even more prominent among victims of molestations than among the general population.
+7. Molested teenagers are particularly vulnerable to wrongful manipulations and special
+clinical harms from the experiences of shame and humiliation. In fact, shame and efforts
+to cope with it played an underlying role in the harm to each plaintiff. Each was lured
+into Mr. Epstein's sexual lair with the promise of overcoming bodily and sexual shame
+by earning money and bettering their lot in life. The defendant capitalized on their sexual
+naiveté, insecurities and effort to better themselves, and he worked hard to overcome
+their shame at his enlistment of them in his selfish gratifications.
+8. The defendant who wishes to make their identities public is one whom the criminal
+justice system has already determined is a person who has already committed a crime of
+child molestation. That surely means he has already exploited and manipulated the girls'
+state of adolescent sexuality, including their embarrassment, awkwardness and bodily
+self-consciousness. He perverted their nascent and developing moral structures by posing
+as a generous, avuncular mentor who could coach them about their bodies, sex and love.
+The exploitation of adolescent bodies, sex and love is - from a psychoanalytic point of
+view - an influence on the developing moral conscience of the children, as well as on
+their sexual urges. Now the ravaging of their internal and private moral conscience is
+intended by the perpetrator to be made a public ravaging.
+9. Among sexual trauma victims, the insidious and destructive persistence of shame,
+humiliation and associated self-blame is well-documented (Finkelhor and
+_, 1985).
+Stigmatization, as experienced by a sexual trauma victim, has especially painful and
+pathologic consequences. Shame lingers and becomes integrated within the adolescent
+victim's malleable emerging identity, character structure and self image. Moral clarity is
+distorted, Perceptions of self-blame and guilt are magnified. The impact of shame lends
+to cultivating a self image of being "spoiled goods."
+10. Stigmatization following sexual trauma results in long-term risks that can negatively
+shape multiple facets of adult development: sexual, emotional, interpersonal and
+vocational. Stigmatization, which is generally to be avoided among psychiatric patients,
+ncreases risks among those - as in our plaintitts as a group - who experience clinical
+epression and self-destructive behaviors: drug use, criminal activity, even prostitution
+Stigmatization following abuse is associated with delinquency due to increased anger
+and affiliation with deviant peers (Feiring et al., 2007).
+11. Shame and guilt are important dimensions of both complex and single event,
+posttraumatic stress disorder (PTSD). Symptoms of shame are associated with feelings of
+helplessness and powerlessness, which each of the plaintiffs endorsed experiencing in
+relation to Mr. Epstein.
+
+
+Case 9:08-cv-80381-KAM Document 127-1 Entered on FLSD Docket 07/29/2009 Page 3 of 5
+12. The DSM-IV-TR recognizes both powerlessness and helplessness as requisite parts of
+the traumatic experience in Criterion A for the diagnosis of posttraumatic stress disorder
+Seligman, recent Past President of the American Psychological
+Association, coined relevant terms of "learned helplessness and "Loss of Personal Locus
+of Control." See Seligman, M.P. 1975: Helplessness, Depression, Development and
+Death. W. H. Freeman, San Francisco). The teenaged girls suffered the loss of personal
+locus of control to a much more experienced, sexually aggressive, powerful and
+dominant, manipulative perpetrator.
+13. Releasing names of the plaintiffs to the public will reenact experiences of
+powerlessness and helplessness in the face of a boundary violation. Repetition and
+reenactment represent central features of Criterion B in the DSM-IV-TR diagnosis of'
+posttraumatic stress disorder trauma. In effect, release of their identity and public
+intrusion into their personal life represents a reenactment of the shame of sexual
+traumatization. Repetition and reenactment are central pathologies that afflict sexual
+trauma survivors.
+14. Victims of sexual abuse often rely upon some form of dissociation, splitting or denial,
+as a detensive means to manage overwhelming attects associated with the sexual trauma.
+Each of the plaintiff girls has employed some variation of this defense, both during the
+massages and then subsequently following disclosure of the abuse. Primitive,
+maladaptive responses of this nature will become additionally reinforced as a result of
+public disclosure.
+15. Another aspect of the plaintiffs' experience, which is recognized by DSM-IV-TR, is
+that the trauma was associated with human design factors (such as cruel intention to do
+harm, rape, torture). Trauma of this origin has a tendency to produce more "severe or
+long lasting" posttraumatic stress disorder than natural events (DSM IV TR p. 464). A
+policy of deliberate revelation of the names of the victims would reinforce the sense of
+design, pattern and policy of human intentions.
+16. Negative expectations about significant activities are noted in DSM-IV-TR, as part of
+Criterion C. Symptoms of foreshortened future are characteristic of a traumatized
+individual's clinical course (C4). They expect revictimization. They expect bad outcomes
+identity will aggravate existing symptoms of hypervigilance.
+17. The DSM-IV-TR diagnostic category of "chronic" is justified for each of the
+auntills. Scientifie literature shows that the prognostic consequences of PTSD an
+esidual effects may last for decades (U.S. Dept. of Health, 2005; Issues in Child Abus
+Prevention Number 9 Autumn1998: Long-term Effects of Child Sexual Abuse, Paul E
+Mullen and Jillian Fleming). The lasting impact upon character, identity and moral
+development will probably affect long-term influences upon adult development. It is
+more probable than not that stigmatization associated with public disclosure of the
+3
+
+
+Case 9:08-cv-80381-KAM Document 127-1 Entered on FLSD Docket 07/29/2009 Page 4 of 5
+plaintiffs' identities will intensify the scope, nature and severity of the chronic symptom
+course.
+18. In addition to PTSD, shame and humiliation themselves have also been associated
+with causing clinical depression. Coexisting PTSD and clinical depression places the
+plaintiff's at increased risk for re-victimization and high risk sexual behaviors (e.g.,
+sexually transmitted disease, premature pregnancy, rape) (Nelson, 2002), and at greater
+risk to victimize others (Filipas and Ullman, 2006; Desai, Centers for Disease Control,
+2002) who are in their control. Studies have also shown that chronic symptoms of PTSD,
+in association with a single episode of Major Depressive Disorder, can produce lifetime
+additionally vulnerable to these clinical outcomes, if they suffer the stigmatization and
+humiliation associated with public disclosure of their identities.
+19. Alternative hypothesis: I have applied the evidence shown from examination and
+testing of the plaintiffs and relevant observations and information from other
+professionals while testing an alternative hypothesis: that no harm would result from
+public disclosure of the plaintiffs' identities. During the evaluations with the six
+plaintiffs, I used generally acceptable criteria for establishing whether a DSM-IV-TR
+disorder occurred. I established that there were provable and diagnosable injuries,
+primarily posttraumatic stress disorder and comorbid depression. Based upon these
+diagnostic signs, it is more probable than not, that exposing the plaintiff's identity to the
+public is not a trivial concern or one without substantial clinical repercussions. I believe
+that most child, adolescent and adult psychiatrists would share the opinion that additional
+psychiatric injury will result from such exposure.
+20. However, consider for the sake of argument, that my diagnostic conclusions are
+incorrect, notwithstanding having fulfilled standard psychiatric evaluation procedures of
+taking a history from multiple sources, videotaping and transcribing my initial interview,
+and reviewing available medical and legal documents. Even if this was the case, and my
+diagnostic conclusions were faulty, I believe that multiple experts, even those who may
+now propose publication of the victims' names, would still come to a conclusion that the
+plaintiff's suffered sexual abuse, and in some cases, multiple acts of ongoing abuse, at the
+hands of Jeffery Epstein. Even without developing a subsequent disorder, there is much
+clinical evidence and scientific literature showing likelihood of substantial psychiatric
+harm to these sexually abused plaintiffs.
+21. To form these conclusions, I have used my extensive experience in forming these
+opinions. That experience is both as a treating child psychiatrist and separately as a
+forensic psychiatrist. I have treated hundreds of minor patients, as well as additionally
+evaluated hundreds of children and adolescents who have suffered sexual abuse. I have
+made long term followups of many of the children and have treated many adults who
+have been molested as adolescents. It is my opinion, with a reasonably high degree of
+medical certainty that the defense motion to allow public disclosure of the plaintiffs'
+identities is clinically and ethically a wrongful plan. The act of revealing their identities
+against their wishes places the plaintiffs at risk, in the best of circumstances, of suffering
+4
+
+
+Case 9:08-cv-80381-KAM Document 127-1 Entered on FLSD Docket 07/29/2009 Page 5 of 5
+an aggravation of existing diagnostic concerns. It is more probable than not that releasing
+personal identities will f
+an exacerbation and magnification of symptoms lending to
+increased risk of revictimization and retraumatization.
+I declare under penalty of perjury under the laws of the State of California that the
+foregoing statements are true and correct, and that this declaration was executed at San
+Francisco, California on June 4, 2009.
+Sincerely
+Babe man up
+Gilbert Kliman, M.D.
+Distinguished Life Fellow, American Psychiatric Association
+Senior Fellow, American Academy of Child and Adolescent Psychiatry
+Brockman Award Holder, for Distinguished Lifetime Contributions to
+Psychoanalysis and Psychiatry, bestowed by the American College of Psychoanalysis and
+Psychiatry
+LEONID NAKHODKIN
+Соми. # 1791115
+NOTARY PUBLIC- CALIFORMA
+CITY & COUNTY OF SAN FRANCISO
+ty Cow. Exp. FEe: 27, 2012 H
+State of California, City & County of San Francisco
+subscibed and sworn to (or attimed) before me on thi
+yay of undory by Gilbert Klinkeen
+pond to me petrole to opened store me
+5
diff --git a/vision-fixhub/court-01/ff475b80a21b5a8b92fe554f31961984e92ec746d8387da872d16bd164cd6995.receipt.json b/vision-fixhub/court-01/ff475b80a21b5a8b92fe554f31961984e92ec746d8387da872d16bd164cd6995.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..efd18d6067a7f9c7d5a2b1e78287226138d71b1d
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+{
+  "byte_delta": -67,
+  "dataset": "marble-joined",
+  "doc_id": "ff475b80a21b5a8b92fe554f31961984e92ec746d8387da872d16bd164cd6995",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "735f29ef4a336a3e759246107d0ffe5439882928d6d557d2fe729be118695896",
+  "output_sha256": "249d055203b49667196c71dd88c1c7688150b653c10ea87d319def162a799331",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.md b/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.md
new file mode 100644
index 0000000000000000000000000000000000000000..17624d1b19e47f3e97ef054618f24713e6e9c23f
--- /dev/null
+++ b/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.md
@@ -0,0 +1,95 @@
+Filing # 105074917 E-Filed 03/18/2020 11:59:08 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 50-2019-CA-014681-XXXX-MB
+Division: AG
+CA FLORIDA HOLDINGS, LLC
+Publisher of THE PALM BEACH POST,
+Plaintiff,
+V.
+DAVE ARONBERG, as State Attorney of
+Palm Beach County, Florida, SHARON R. !
+BOCK, as Clerk and Comptroller of Palm
+Beach County, Florida,
+Defendants.
+COPY
+PLAINTIFF'S UNOPPOSED
+MOTION TO CONTINUE HEARING
+SCHEDULED FOR MARCH 24, 2020
+Plaintiff, CA FLORIDA HOLDINGS, LLC., Publisher of the Palm Beach Post (the
+"Plaintiff" or "Post") files this Unopposed Motion to Continue Hearing Scheduled for March 24,
+2020 and states:
+Plaintiff publishes a newspaper known as the Palm Beach Post. It has filed this
+Declaratory Judgment action tó seek access, on behalf of the public, to the grand jury evidence in
+former Palm Beach County State Attorney Barry Krischer's prosecution of the late Jeffrey Epstein.
+2. 1
+Both defendants have moved to dismiss Count II of the Amended Complaint, and
+this Court set a hearing in court for March 24, 2020 at 10:00 a.m.
+Due to the current national health emergency, the Post requests that the hearing be
+continued.
+4.
+The Post understands that the Court may not be in session on March 24, 2020 as it
+has been reported that the Court is in a voluntary 14 day quarantine due to a recent foreign trip.
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 03/18/2020 11:59:08 AM ***
+
+
+CASE NO. 50-2019-CA-014681-XXXX-MB AG
+Further, the Post's lead counsel, Nina Boyajian, resides in California, and travel to
+Florida to orally argue against the motions to dismiss poses a health risk to her.
+6.
+The Post believes that conducting
+, the hearing via tele-conference will be
+problematic, and that the hearing should be continued sine die until such time as the Court deems
+it appropriate.
+8.
+None of the parties will be prejudiced by a continuance.
+The Post has reached out to defendants' counsel and they agree to a continuance.
+WHEREFORE, Plaintiff respectfully requests that the hearing on Defendants' motions to
+dismiss Count II of the Amended Complaint, currently scheduled for March 24, 2020 at 10:00
+a.m., be continued sine die, and that when appropriate the matter should be rescheduled for oral
+argument, and the Court should grant such other relief it deems just and proper.
+Dated: March 18, 2020
+Respeetfully submitted,
+GREENBERG TRAURIG, P.A.
+Allorneys for CA Florida Holdings, LLC,
+Publisher of The Palm Beach Post
+Stephen A. Mendelsohn, Esq.
+5100 Town Center Circle, Suite 400
+Boca Raton, Florida 33486
+Telephone: (561) 955-7629
+Facsimile: (561) 338-7099
+NOT A
+By: Is/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+Florida Bar No. 849324
+mendelsohns@gtlaw.com
+hasenh@gtlaw.com
+FLService@gtlaw.com
+-and-
+
+
+CASE NO. 50-2019-CA-014681-XXXX-MB AG
+By: Is/ Michael.J Grygiel
+MICHAEL J GRYGIEL
+(Pro Hac Vice)
+54 State St., 6th Floor
+Albany, New York 12207
+Telephone: (518) 689-1400
+Facsimile: (518) 689-1499
+grygielm@gtlaw.com
+By: Is/ Nina D. Boyajian
+NINA D. BOYAJIAN
+(Pro Hac Vice)
+1840 Century Park East, Suite
+1900 Los Angeles CA 90067
+Telephone: (310) 586 -7700
+Facsimile: (310) 586 -7800
+boyajiann@gtlaw.com
+riveraal@gtlaw.com
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on this 18th day of March 2020, a copy of the foregoing has
+been electronically filed with the Florida E-File Portal for e-service on all parties of record herein.
+/s/ Stephen A. Mendelsohn
+STEPHEN A. MENDELSOHN
+NOT
diff --git a/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.receipt.json b/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2b271a48a80fa834cdb842eb30967808d8b66563
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+++ b/vision-fixhub/court-01/ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "ffcce2bb3cc20f3859c884064dc0424fb9909a9abfb7d15f95bc5c3dc9e813e1",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "3247bfe01b23fa64c2f218290a9a61079e936b727751359181434c6b1854d9b0",
+  "output_sha256": "effb61caf5697108fa8257400eda4b8442743aa9b11b636fbe736f6ec1d73fa6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-01/ffd96c98ce6ef5210e1cbaf156d535e7d3b0887b063acab6f1b9dfbec8e7cc5d.md b/vision-fixhub/court-01/ffd96c98ce6ef5210e1cbaf156d535e7d3b0887b063acab6f1b9dfbec8e7cc5d.md
new file mode 100644
index 0000000000000000000000000000000000000000..cbf74159caf67d52b44311acbc3d42768911f221
--- /dev/null
+++ b/vision-fixhub/court-01/ffd96c98ce6ef5210e1cbaf156d535e7d3b0887b063acab6f1b9dfbec8e7cc5d.md
@@ -0,0 +1,1329 @@
+Entered on FLSD Docket 08/07/2009 Page 1 of 27
+83059
+BURMAN, CRITTON, LUTTIER
+& COLEMAN LLP
+A LIMITED LIABILITY PARTNERSHIP
+July 31, 2009
+J. MICHAEL BURMAN, PA.
+GREGORY W. COLEMAN, PA.
+ROBERT D. CRITTON, JR., P.A.)
+BERNARD LEBEDEKER
+MARK T. LUTTIER, PA.
+JEFFREY C. PEPIN
+MICHAEL J. PIKE
+HEATHER MCNAMARA RUDA
+1 FLORIDA BOARD CERTIFIED
+CIVIL TRIAL LAWYER
+DELQUI J. BENAVENI
+IRALEGAL / INVESTIGATO
+ARBARA M. McKENN
+SHLIE STOKEN-BARIN
+BETTY STOKES
+PARALEGALS
+RITA H. BUDNYK
+OF COUNSEL.
+Jack
+1, Esq.
+Searcy Denney Scarola Barnhart &
+Shipley, P.A
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+Re:
+CMA v. Epstein
+Dear Jack:
+Please find enclosed questionnaires for your client to fill out in advance of the
+IME appointment set for August 20, 2009 at 9:00 a.m. at my firm. My expert, Ryan C.
+M.D.., respectfully requests that your client fill these out and send them back to
+me within one week.
+1 look forward to your cooperation in this matter.
+Very truly yours
+1L
+Michael J. Pike
+CC:
+Jack A. Goldberger, Esq.
+Robert D. Critton, Jr.
+
+1
+L•A •W• Y •E • R•S
+515 N. FLAGLER DRIVE / SUITE 400 / WEST PALM BEACH, FLORIDA 33401
+TELEPHONE (561) 842-2820 FAX (561) 844-6929
+mail@belclaw.com
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 2 of 27
+RELEASE OF INFORMATION
+I hereby give permission to Dr. Richard C. W.
+/Dr. Ryan C. W.
+to use the information I gave in
+the Life History Questionnaire. I understand that this consent is revocable upon written notice to Dr.
+except to the extent that action by him has been taken in reliance on this authorization.
+NAME
+WITNESS_
+Date
+Date_
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 3 of 27
+CASE NO.
+Name
+The purpose of this questionnaire is to help us to better understand you and the problems which brought you to
+our office. Since some of the information you will be giving us in this questionnaire is of a personal nature, we
+want to assure you that all case records are held in strict confidence. Unless required by law, your case record will
+not be released without your permission. Findings from this questionnaire may be used in compiling group data
+and will never be released in any way that could identify you.
+Please read the questions carefully and answer as accurately as you can. The questionnaire will probably take about fifteen
+minutes to complete, but feel comfortable working at your own pace.
+EARLY DEVELOPMENT
+Date of birth
+1. As a child did you have any of the following?
+Serious Accidents • No DYes, please specify
+Serious Ilinesses
+•No dYes, please specify-
+Surgeries
+•No DYes, please specify-
+2. Did either parent die during your childhood or adolescence?
+• NO
+• Yes, my mother, when I was
+• Yes, my father, when I was.
+• years old.
+- years old.
+• Unknown
+3. Check the persons. with whom you lived most of the time while growing up.
+• Both my natural parents
+• One parent and [ stepmother or • stepfather
+• One parent, • mother or [father
+• Other relative (explain) -
+parents)
+• Adoptive parents)
+• An Institution
+• Other (explain) _
+4. Were you able to confide in your parents?
+• Yes, usually
+•No, not usually
+•Not applicable
+5. How well did your parents get along with each other?
+• Very well
+• Not very well
+• Don't know
+• Fairly well
+• Very poorly
+• Not applicable
+Age.
+PAGE 1
+B43-0010 (10-92y0Ih(MPC#351)
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 4 of 27
+wily lal you know nave applied to your parents or brothers or sisters.
+Specify family member below
+• Hospitalization for mental illness
+• Drinking problem.
+• Drug abuse
+• Attempted or committed suicide
+• Dont know
+7. How many schools did you attend from grades 1 through 12?
+• 1-3
+04-7
+• More than 7
+• Don't know
+8. What kind of grades did you make in school? • Excellent • Good Fair
+9. Did you participate in school activities? • No
+• Poor
+• Yes, some • Yes, many
+10. When you were growing up, did you belong to churches), clubs) or other organized groups)?
+• Yes, many
+• Yes, a few
+• None
+11. Did you have close friends around your own age?
+© Many
+O Few
+12. Check any of the following that applied to you as a child.
+• One
+• None
+• nightmares
+• stealing
+• fire setting
+[nail biting
+• running away
+• accident prone
+• speech problems
+• bullying
+O lying
+• daydreaming
+• sleepwalking
+•temper tantrums
+• crueity to animals
+• bed wetting
+• loneliness
+• scapegoat (picked on)
+• thumb sucking
+• head banging
+• insomnia
+13. How would you describe your physical health at present?
+• Excellent
+• Good • Fair
+• Poor
+14. Have you ever had any of the following?
+Jo you still have a
+problem with this?
+Yes
+Yes
+Do you still have a
+problem with this?"
+Yes
+•
+• Failing
+Yes
+• heart trouble
+• nervous breakdown
+• epilepsy
+• tuberculosis
+| diabetes
+• teeth trouble
+• eye trouble
+• nose trouble
+• bladder trouble
+• kidney trouble
+• bowel trouble
+• stomach trouble
+• chest trouble
+•
+•
+3000
+backache
+hernia
+dizziness
+blackout
+_rheumatism
+chronic
+_shortness of breath
+fits or convulsions
+cancer
+_asthma
+_arthritis
+high blood pressure
+low blood pressure
+•000
+Yes
+• _hemorrhoids (piles).
+• laundice
+• - fever
+_other alleray.
+-venereal disease
+_ulcers
+blood in urine
+_sugar in urine
+•
+•
+varicose veins
+underweight problem
+overweight problem
+injury to limbs)
+•
+_injury to back
+_injury to neck
+0000
+PAGE 2
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 5 of 27
+: •15. Have you ever had a problem with any of the following?
+D Pep pills, diet pills
+• Alcohol
+• Tranquilizers, sedatives
+[ LSD, or other hallucinogen (exclude marijuana)
+• Marijuana
+• Other, please specity
+• Narcotics
+• No
+16. With whom are you living at present?
+• Spouse, or spouse and child(ren)
+• Parents)
+• Minor child(ren)
+• Grown child(ren)
+• Other relative(s)
+• Friend(s)
+• Alone
+• Other, explain
+17. Check the statement which most closely describes. how you are getting along with each of the following
+persons.
+person
+very
+well
+Mother
+Eather
+Sister(s)
+Brother(s)
+Spouse /Partner.
+Female Child(ren)
+Male Child(ren).
+18. What is your present marital status?
+• Single
+• Living together, how long?
+• Married, how long?.
+fairly
+well
+not very
+well
+very
+poorly
+uncertain
+not
+applicable
+• Separated
+• Divorced
+• Widowed
+PAGE 3
+643-0010 (10-92)dih(MPC#351)
+
+
+19.
+Entered on FLSD Docket 08/07/2009 Page 6 of 27
+None OR a
+little of the time
+Some of
+the time
+Good part of Most OR-ALE
+the time
+of the time
+I feel more nervous and anxious than usua
+feel afraid for no reason at all
+get upset easily or feel panicky
+I feel like I'm falling apart and going to pieces
+feel that everything is all right and
+nothing bad will happen
+My arms and legs shake and tremble
+Lam bothered by headaches, neck and back pain
+feel weak and get tired easily
+_ feel calm and can sit still easily
+I can feel my heart beating fast
+Lam bothered by dizzy spells
+L have fainting spells or feel like it
+_ can breath in and out easily
+get feelings of numbness and tingling in my
+fingers
+and
+TOES
+Lam bothered by stomachaches or indigestion:
+L have to empty my bladder often
+My hands are usually dry and warm
+My face gets hot and blushes
+1 fall asleep easily and get a good night's rest
+Lhave nightmares
+20. Check any of the following that apply to you at the present time.
+• hallucinating
+• talented
+• too ambitious
+• nightmares
+• insomnia
+• helpful
+O tense
+• horrible thoughts
+O bed wetting
+• trusting
+• thoughtful
+• lonely
+D easily hurt
+• aggressive
+Devil
+• dont like
+vacations or
+O dizzy
+• stable
+weekends
+O bad temper
+• inferior
+• affectionate
+•forgetful
+• timid
+• headaches
+•calm
+• depressed
+• no appetite
+fainting spells
+O friendly
+D in conflict
+• unloved
+respected
+• modest
+• confused
+•well mannered
+• need help
+•rigid
+• loyal
+• suicidal
+• tired
+•rejected
+unattractive
+• flexible
+•cruel to animals
+• misunderstood
+•unhappy
+• daydreamer
+•lack of confidence
+• capable
+•open
+• guilty
+•easily influenced
+]unable 1o hav
+a good time
+enthusiastic
+•happy
+• shy
+•fire setter
+• indecisive
+• inadequate
+• stupid
+• worthless
+• generous
+• unable to
+concentrate
+• bored
+• restless
+• lovable
+• regretful
+• рапіку
+• soft-hearted
+• ugly
+• agitated
+• cowardly
+• sell-confident
+Dangry
+• full of hate
+"cant do anything right"
+PAGE 4
+643-0010 (10-92/1h(MPC#351)
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 7 of 27
+*21. "Check any of the following which describe your marriage or sexual partnership.
+• Not applicable
+D Friendly
+• Poor sexual adjustment
+• Stormy
+• Lack of communication
+• Mutual respect and love
+• Happy
+• Good sexual adjustment
+• Perfect
+• Insecure
+• indifferent
+• Boring
+• Average
+• Mistake
+• Secure
+• Romantic
+• Good communication
+• Sharing of interest
+• Exciting
+• Lack of common interests
+22. How long did you know you present spouse before marriage?
+I Not married
+23. How many times have you been married? -
+24. How many close friends do you have • Many
+25. Are you able to confide in these friends? • No
+• Few
+• Yes
+• One
+• Not applicable
+• None
+26. How comfortable are you with:
+Year(s)
+very
+comfortable
+moderately
+comfortable
+moderately
+uncomfortable
+very
+uncomfortable
+Joining a group
+Meeting people
+With persons of same sex
+With persons of opposite sex
+Being a leader
+Being a follower
+Expressing an unpopular opinion
+Being disliked
+Asking for help
+Taking advice
+Accepting criticism
+Competitive situations
+Taking initiative.
+27. Does your present work satisty you?Yes
+ONO
+28. Check any of the following which have been a problem for you.
+• Gambling
+• Parents
+• Sex
+• Drinking
+• Trouble with police
+• Temper
+• Marriage
+• Drugs
+• Men
+• Violence
+• Children
+• Religion
+• Women
+• Friends
+• Finances
+•Job.
+• Unemployed
+PAGE 5
+623-0010 (10-52)dI1(MPC#351)
+
+
+Entered on FLSD Docket 08/07/2009 Page 8 of 27
+10
+9
+8
+7
+5
+4
+3
+2
+30. Where on the ladder would you say you stood five years ago? (Circle number.).
+10
+9
+8
+7
+6
+5
+4
+3
+2
+1
+31. Where on the ladder would you say you will stand five years from now? (Circle number.)
+10
+8
+6
+5
+4
+3
+2
+PAGE 6
+643-0010 (10-92)In(MPC#351)
+
+
+* 32.
+Check the most appropriate response.
+Entered on FLSD Docket 08/07/2009 Page 9 of 27
+None or a little
+of the time
+Some
+of the time
+Good part
+of the time
+Most or all
+of the time
+1. I feel down-hearted and blue
+2. Moring is when I feel the best
+3. I have crying spells or feel like it
+4. L have trouble sleeping at night
+5. L eat as much as l used to
+6. still enjoy sex
+1. L notice that 1 am losing weight
+8. have trouble with constipation
+9. My heart beats faster than usual
+10. 1 get tired for no reason
+11. My mind is as clear as it used to be
+12. I find it easy to do the things I used to
+13. 1 am restless and cant keep still
+14. I feel hopeful about the future
+15. I am more irritable than usual
+16. I find it easy to make decisions
+17. I feel that 1 am useful and needed
+18. My life is pretty full
+19. I fil tre deters would be better off
+1 were dead
+20.I still enjoy the things I used to do
+33. Do you know anyone who has been treated by Dr.
+• No • Yes
+34. If so, in your opinion, was the person(s) helped? (Check more than one, if applicable.)
+• Yes, greatly
+• No, not at all
+• Yes, moderately
+• No, became worse
+• Only a little
+• Not applicable
+35. Do you think you need help?
+• Yes No •Dont know
+36. Do others think you need help? DYes No
+• Dont know
+37. How long do you think you should be in treatment?
+• Less than 1 month
+• More than 1 month, less than 6 months
+• More than 1 year
+•Dont know
+•More than 6 months, less than 1 year
+PAGE 7
+643-0010 (10-92)eih(M/PC#351)
+
+
+Case 9:08-cv-80119-KAM
+Document 254-1 Entered on FLSD Docket 08/07/2009 Page 10 of
+PATIENT INFORMATION DATA BASE
+NAME:
+AGE:_
+DATE:
+PREVIOUS PHYSICIAN (NAME AND ADDRESS):
+Yes
+PAST MEDICAL HISTORY (PLEASE CHECK ALL ITEMS TO THE BEST OF YOUR KNOWLEDGE):
+•
+•
+•
+Hypertension
+Arthritis
+Diabetes
+Tuberculosis
+Pneumonia
+Venereal Disease
+Thyroid Disease, Golter
+High Cholesterol or Triglycerides.
+Asthma,
+Fever
+Emphysema
+Bronchitis
+Recurrent Sinusitis
+Skin Disease (Eczema, Psoriasis, Cancer, etc.) -
+Heart Attack
+Abnormal Heart Beat
+Heart Fallure
+Rheumatic Fever
+Heart Murmur
+Congenital Heart Disease
+Breast Lumps -
+Blood Disorders
+Leukemia, Lymphoma
+Anemia.
+Peptic Ulcer
+Gall Bladder problems
+Bowel Disorders (Colitis, Spastic Colon, etc.)
+Hemia
+Hemorrhoids
+Liver Disease (Cirhosis, Hepatitis, etc.) -
+Kidney Disease (Cysts, Stones, Infection, etc.) -
+• Bladder. Infections -
+Prostate Disorders (Males only).
+Female Organ Disorders -
+Stroke _
+Paralysis
+Cancer.
+Epilepsy
+Serious Injuries
+Meningitis.
+Encephalitis
+Polio -
+Sickle Cell Disease
+PAGE 8
+1420010(10-0241/MPC*351)
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 11 of
+•.•
+:
+Radiation treatments to head or neck
+=
+Emotional problems
+Phlebitis
+=
+=
+Glaucoma
+Cataract
+Gout
+Other (Please list)
+Last Hospitalization (date and diagnosis)
+Previous Procedures (approximate date):
+Chest X-ray
+Flu Vaccine
+Tetanus Shot
+Stomach X-ray (UGI)
+Kidney X-ray (IVP)
+Sigmoidoscopic / Proctoscopic Exam
+EKG
+Pneumococcal Vaccine
+Tuberculosis Skin Test
+Colon X-ray (BE)
+Complete Medical Examination_
+Pelvic Exam and Pap Smear (females only)
+PAST SURGICAL HISTORY (List operations, dates and where performed):
+2.
+3.
+5.
+6.
+CURRENT MEDICATIONS (Name and dosage):
+4.
+2..
+3.
+5.
+6.
+OVER-THE-COUNTER MEDICATIONS/HERBALS/VITAMINS:
+1.
+2.
+3.
+4.
+5.
+6.
+ALLERGIES (to drugs). Please give reaction (i.e. shock, hives, chest pain, etc.):
+1.
+3.
+2.
+4.
+SOCIAL HISTORY:
+Do you smoke cigarettes?
+•Yes
+• No
+low many packs per day
+Vhen did you quit
+If no, have you ever smoked?
+•Yes
+For how many years have you smoked?
+-NO
+Do you drink alcohol?
+•Yes
+• No
+How much coffee/tea/caffeinated drinks do you drink?
+WEE HITORY QUERTOHHARE
+PAGE 9
+How much?
+
+
+Case 9:08-cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 12 of
+FAMILY HISTORY: (Please list age and any medical problems:
+Father, age
+How many brothers?
+Any with medical problems?
+DO ANY OF THE DISEASES RUN IN YOUR FAMILY?
+YES
+NO
+YES
+Cancer
+Heart disease
+High blood pressure
+Sickle cell anemia
+Thyroid disease
+Kidney disease - stones
+Mother, age
+How many sisters?
+NO
+• Tuberculosis
+• Strokes
+Diabetes
+0
+Epilepsy
+• Suicide
+• Colitis
+LIFE HISTORY QUESTIONNARE
+PAGE 10
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 13 of
+Richard C. W.
+MD, PA
+2500 W. Lake Mary Blvd; Ste. 219
+Lake Mary, FL 32746
+PATIENT QUESTIONNAIRE (for Forensic Examination)
+ALL QUESTIONS MUST BE ANSWERED
+WARNING: Because you are being examined for purposes of legal action (workers'
+compensation, social security, civil rights, civil or criminal, etc.), please be aware that the
+information you supply in this questionnaire, or tell the doctor, is not confidential.
+Name:
+Address: -
+State, ZIP:
+Phone:
+Which is your dominant hand? (right, left, both):
+Can you read a newspaper? Yes.
+No.
+Current employment:
+Education (highest grade completed):
+Physician, lawyer or person who referred you to this office: -
+GENERAL INFORMATION
+Today's date:-
+City:
+Date of Birth: -
+Social Security Number:
+Age:
+Your present weight:-
+If you are being examined for Workers' Compensation, Social Security, a lawsuit, or criminal
+charges, who is your lawyer?
+Did you drive yourself here today? Yes_
+If no, who brought you? -
+What is the driver's relationship to you (friend, relative, hired by your lawyer, etc.)
+Who do you live with at this time?
+HISTORY OF PRESENTING PROBLEM
+Have you been experiencing any mental or nervous problems in the last month? Yes__
+If yes, describe:
+When did your mental problem first begin?
+Have you been experiencing any physical problems in the last month? Yes
+describe:
+If yes,
+When did your physical problems first begin?
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 14 of
+Page 2
+What time do you get up in the morning? _
+Who fixes your breakfast?
+checkbook?
+Who pays your bills? _
+. Who fixes your meals?
+ACTIVITIES OF DAILY LIVING
+What time do you go to bed at night?
+Do you drive a car or truck?
+Do you use a
+Who cleans your home?
+Do you attend church?
+How often?
+What hobbies do you now have? -
+What do you read?
+What TV shows are presently your favorite(s)?
+What do you do with your children?
+What was your last overnight trip?
+Who mows your yard?
+- What work do you do around your home or farm?
+How many movies do you rent per month? -
+How many times do you go to
+the movie theater a year?
+How many times do you sleep away from
+home in a year?
+- How many ball games do you attend in a year?
+How many times do you hunt in a year? —
+How many times do you fish per
+year?
+How many times do you eat out in a month?
+How many times a month do friends or family visit in your home?
+many times a week do you call someone on your phone?
+How
+What plants do
+you grow?
+Can you dress yourself?
+Can you bathe yourself or shower yourself?
+Can you have
+sex?
+List any serious childhood illnesses you had:
+Were you born prematurely? Yes
+Did you have growth problems? Yes
+child? Sad
+Happy
+Depressed
+PAST MEDICAL HISTORY
+What did you weigh at birth?
+Were you sad or happy or depressed as a
+List any permanent physical or mental problems from
+childhood:
+As a child, did you have trouble sitting still in school? Yes.
+No_
+Did you have trouble
+learning in school? Yes
+Did you have trouble keeping your mind on things as a
+child? Yes
+Did you have trouble learning to read? Yes
+Did teachers
+complain that you were too active? Yes_
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 15 of
+Page 3
+Check any serious illnesses you have now or have been treated for in the past:
+Seizures
+Cancer
+Diabetes
+Thyroid Disease
+Anemia (low blood)
+High blood pressure
+Heart disease
+Lung or breathing problems
+Joint or back disease
+Stomach or bowel disease
+Female problems
+Pregnancy problems
+Urinary tract problems
+Sexual problems
+Prostate problems
+Sleep problems
+If you were hospitalized for these illnesses, list the hospital(s):
+Depression
+Panic disorder
+Nerves
+Alcoholism
+Drug abuse
+Overdoses
+Suicide attempts
+Violence towards others
+• Attention deficit disorder
+Manic depressive
+Schizophrenia
+Eating disorders
+Neurological disease
+Spouse abuse
+Child abuse or neglect
+Have you had any motor vehicle accidents? Yes
+Date
+Your age at the time
+No_
+If yes, list them:
+Type of injury
+Treatment/by whom
+Have you ever been knocked out, lost consciousness or had a brain injury? Yes.
+If yes, describe what happened:
+No_
+Have you ever broken any bones? Yes.
+right or left side:
+- If yes, describe which bones were broken,
+For women: How many pregnancies have you had?
+children have you had?
+Could you be pregnant? Yes-
+How many living
+How many miscarriages have you had?
+When was your last menstrual period?
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 16 of
+Page 4
+Have you had any surgeries or operations? Yes
+Date
+Your age at the time
+Hospital where performed
+If yes, list below:
+Type of surgery
+Are you now taking any medications? Yes.
+you take your medicine.
+Medication
+Please list the milligrams and how often
+Milligrams
+Times per day
+Who keeps track of your medications? You...
+Do you have any drug allergies or reactions? Yes
+Drugs
+Your spouse
+Someone else
+No_ If yes, list below:
+Allergic Reaction
+(Rash, nausea, hives, etc.)
+Do you use tobacco now? Yes
+_ Not now but previously
+tobacco in the past, please describe how much and how long used:
+Not now but in the past
+If yes or have used
+If yes to any use of
+Do you use alcohol now? Yes
+alcohol, describe:
+Type of alcohol (whiskey, beer, wine, etc.):
+Number of alcoholic drinks you have per day:
+How long alcohol was used before you stopped:
+Describe any medical treatment for alcohol problems:
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 17 of
+Page 5
+Describe any present alcohol problems in your life:
+Have you ever taken a medication or drug that you received from friends or family or bought off the
+street? Yes
+If yes, describe:
+Have you ever used illegal drugs, li.e. marijuana, cocaine, uppers, downers, crack, etc.)? Yes
+Have you ever sniffed paint, solvents or gasoline to get high? Yes
+If yes, what did
+you sniff and how long?
+Have you ever used illegal intravenous drugs (IV drugs)? Yes_
+Have you ever received treatment for drug/substance abuse? Yes
+No:
+If yes, what
+hospital, what year?
+Using the chart below, list what type of illegal drugs you have used:
+Drug/Substance
+Age at use
+How long used
+Last date used
+Do you drink coffee or tea? Yes.
+caffeinated soft drinks? Yes
+How many cups per day?
+What soft drinks?
+How many per day?
+Treating
+physician or
+psychiatrist
+Do you drink
+Psychiatric
+hospital
+admission
+1st admission
+2nd admission
+3rd admission
+4th admission
+Year
+hospitalized
+Hospital name
+Diagnosis or
+reason for
+admission
+Have you ever been discharged from any hospital Against Medical Advise (AMA)? Yes.
+If yes, describe?
+Type of
+treatment
+received
+
+
+Case 9:08-cv-80119-KAM
+Document 254-1 Entered on FLSD Docket 08/07/2009 Page 18 of
+Page 6
+Have you ever stopped taking nerve pills without asking the doctor? Yes
+Have you ever been prescribed any form of nerve medicines, antidepressants, or other psychiatric
+medications? Yes
+If yes, describe:
+When is the first time you ever took nerve medicines or antidepressants?
+Have you ever had shock treatments (ECT)? Yes
+If yes describe when and where:
+Have you ever been advised by any doctor or health practitioner to get mental or psychological
+treatment? Yes
+If yes, describe:
+Have you ever been committed to a mental hospital or psychiatric unit? Yes.
+If yes,
+describe:
+Have you ever refused mental treatment: Yes
+If yes, describe:
+Have you ever received any type of office treatment by your family doctor, psychiatrist,
+psychologist or therapist (medication, counseling, therapy) for any nervous condition, psychological,
+psychiatric, family or marital problems? Yes
+No_
+If yes, describe:
+Date
+Your age at the time
+Type of injury
+Treatment/by whom
+Have you ever intentionally overdosed yourself on drugs or medicines? Yes
+If yes, describe:
+Have you ever attempted to take your life? Yes_
+- No_
+If yes, describe:
+Have you ever cut, burned or disfigured yourself? Yes.
+If yes, describe:
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 19 of
+Page 7
+FAMILY HISTORY
+Please check if any of these illnesses have occurred in any of your parents, grandparents, brothers,
+sisters or children:
+cancer
+heart disease
+lung disease
+mental iliness/nerve problems
+violence towards others
+spouse abuse
+high blood pressure
+thyroid illnesses
+alcohol/drug problem
+eating disorders
+suicide
+killing another person
+child abuse
+If you checked any of the above, please explain which relative had the illness:
+Father's age if living:
+Mother's age if living:
+sisters or child has died, list the cause of death and age. at death:
+If father, mother, brothers,
+SOCIAL HISTORY
+Where were you born?
+Date of birth:
+Of your siblings, how many sisters?
+the family (first child, last child, etc.)
+What did your father do for a living?
+What did your mother do for a living?
+Did your family have enough money?
+Is your father living?
+Year he died:
+Are (were) your parents divorced?
+time?
+Who raised you?
+your home? Yes
+Threatening? Yes
+depressed? Yes
+Did your father abuse your mother? Yes_
+Have you ever been sexually abused? Yes
+Have you ever been physically abused? Yes.
+Not enough money?
+Your mother?
+If yes, when?
+Was your home happy? Yes_
+Hard on you? Yes
+No_
+How many children were in your family?
+How many brothers?
+Where do you come in
+Live in poverty?
+_ Year she died:
+How old were you at the
+Did your parents) own
+Abusive? Yes
+Make you feel
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 20 of
+Page 8
+Have you ever been violent to or harmed a person, animal or property? Yes
+Have you ever shot, stabbed, or beaten another person? Yes
+Have you ever threatened to kill another person? Yes
+Have you ever killed another person, even if by accident? Yes.
+Describe your abuse or violence of others, if it occurred.
+No_
+Have you ever been in trouble for your sexual behavior? Yes.
+Have you ever sexually abused or harassed a child or adult? Yes
+Highest grade you completed in school? -
+If you did not finish high school, what was the reason you quit?
+What were your grades in high school?
+education classes? Yes
+Were you in special
+In school, did the teachers think you were hard to control or
+was it hard to get your attention? Yes_
+If you attended any college, list college/university, degree, and date of graduation:
+College/University
+Degree
+Date of graduation
+Are you never married, married, or divorced?
+How long have you been divorced or married?
+Year
+married
+Year
+divorced
+Spouse's
+•name
+Any natural children and
+their ages
+Reason for
+divorce
+Marriage
+First marriage
+Second marriage
+Third marriage
+Fourth marriage
+How many natural children do you have?
+- How many step-children?
+How would you describe your marriage if you are married? Good relationship
+relationship
+Bad relationship
+Terrible or abusive relationship
+Fair
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 21 of
+Page 9
+If you are not married and have a lover, describe your relationship: Good
+Terrible or abusive
+Describe your relationship with your children. Close
+Could be better
+Poor
+If you do not have a relationship, how do you feel about this? Satisfied
+Not satisfied and want a relationship
+Very sad and lonely
+Distant
+Lonely but OK
+LEGAL HISTORY
+Have you had any criminal convictions, drug arrests, DUls or public intoxication arrests? Yes_
+If yes, fill in below:
+Arrest date
+Charge(s)
+Where
+(City or State)
+Were you
+convicted?
+Length of time in
+prison/jail
+Have you been involved in any civil law suits as either the plaintiff or defendant? Yes
+No:
+If yes, describe:
+If you received a monetary award, how much was it?
+Has your spouse, or any one else, ever gotten a restraining order or emergency protective order
+against you? Yes
+If yes, describe:-
+Have you ever gotten a restraining order or emergency protective order against your spouse, or
+anyone else? Yes
+If yes, describe:
+Have you ever filed a Workers' Compensation claim: Yes.
+If yes, how many?
+Describe each injury and the year it occurred:
+Give the amount of your award or the monthly benefit:
+Have you ever been charged with spouse abuse, child abuse or neglect, or terroristic threatening?
+Yes
+If yes, describe:-
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 22 of
+Page 10
+EMPLOYMENT/VOCATIONAL HISTORY
+Part time
+Employment status: (check one) Full time
+If not employed, reason you are not employed:.
+Not employed
+Student
+If employed, who is your present employer?
+Employer's address:
+Length of time on your last permanent job:_
+Job Title/Position of that job:
+If you are disabled, year of and reason for your disability: Year-.
+Reason
+What are your present sources of all monthly income?
+Were you ever fired or asked to resign from a job? Yes
+Have you ever threatened your employer or a coworker? Yes
+Where is your spouse employed?
+If yes, reason:
+Do you plan to return to work at any time in the future? Yes
+List past employment (beginning with your most recent job):
+Employer
+Job Title
+Start
+date
+Finish
+date
+Reason for
+leaving
+Other
+(Continue on page 11.)
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 23 of
+Page 11
+Employment history (cont.)
+Employer
+Job Title
+Start
+date
+Finish
+date
+Reason for
+leaving
+Other
+Have you had any military service? Yes
+Branch of
+Service
+Years served
+MILITARY HISTORY
+If yes, list below:
+Rank at time of
+Type of
+discharge
+discharge
+Job duties
+Where was your basic training?
+Where was your advanced training?.
+If you ever served in a combat zone, list dates and area:
+If wounded in military service, describe:
+List any promotions/advancements and dates:
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 24 of
+Page 12
+List any medals/commendations and dates awarded:
+Were there any disciplinary actions against you?
+Yes
+Were you ever in the brig or stockade? Yes
+Describe any military pension or disability:
+_No_
+If yes, describe:.
+REVIEW OF SYSTEMS
+(Circle those symptoms present)
+GENERAL
+Fever, shaking, chills, change in appetite, loss in weight, change in weight, fatigue,
+change in sleeping patterns, soaking night sweats.
+Explain any circled items. If you have lost or gained weight, how many pounds in
+the last 3 months?
+HEAD, EYES, Headache, changes in vision, double vision, blurred vision, eye pain, excessive
+EARS, NOSE, tearing, discharge from the ayes, changes in hearing, ringing in ears, ear pain,
+THROAT
+discharge from ears, nosebleeds, odd odors, hoarseness, dental pain, sore tongue,
+sore throat, mouth sores.
+Explain any circled items: -
+CHEST
+Cough, sputum production, shortness of breath, wheezing, blood in sputum,
+abnormal chest x-ray, positive TB test, lump(s) in breast, nipple discharge, nipple
+bleeding, breast pain.
+Explain any circled items: -
+HEART
+Chest pain, shortness of breath walking, shortness of breath upon lying down, heart
+murmur, rheumatic fever, shortness of breath that wakes you up at night, swelling
+in legs, fainting.
+Explain any circled items:
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 25 of
+Page 13
+STOMACH,
+BOWEL
+Change in appetite, nausea, vomiting, blood in vomit, dark
+I vomit, diarrhea,
+constipation, change in stool size, blood in stool, dark black tarry-colored stool, food
+intolerance, trouble swallowing, heartburn, indigestion, laxative use, excessive gas,
+abdomen pain, weight loss, weight gain.
+Explain any circled items:
+URINARY,
+GENITAL
+Trouble starting urination, excessive urination, dribbling of urine, pain upon
+urination, blood in urine, excessive urination after going to bed, unable to hold urine,
+bed wetting, sores on genitals.
+Explain any circled items: -
+FEMALE
+Menstrual irregularity, premenstrual distress, menopause symptoms, excessive
+female bleeding.
+Explain any circled items:
+MENTAL
+Depression, nervousness, panic, thoughts of suicide, poor concentration, loss of
+memory, too happy, word-finding difficulty, confusion, inability to know month/year,
+hearing voices, seeing things, paranoid thoughts, irritability, arguing, crying for no
+reason, trouble thinking, flashbacks, thoughts of killing another person, counting
+hings, can coitimes daily, take more than 2 baths or showers daily. Do you have
+afraid of germs, afraid to touch doorknobs, wash hand:
+present plan to kill yourself? Yes
+Do you have a plan to kill someone
+else? Yes
+Explain any circled items:
+NEUROLOGIC Blackouts, seizures, double vision, partial blindness, headaches, numbness, tingling,
+weakness, poor balance, shaking or tremors, abnormal movements of face or body,
+poor coordination, paralysis, loss of reflexes, pain.
+Explain any circled items:
+
+
+Case 9:08-CV-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 26 of
+Page 14
+MUSCLES,
+SKELETAL
+Muscle spasms, joint pain, bone disorders, difficulty walking, difficulty sitting.
+difficulty using hands, difficulty bending, difficulty lifting.
+Explain any circled items: -
+SLEEP
+Cannot fall asleep, cannot stay asleep, wake up too early, fall asleep any time, night
+terrors, nightmares, sleep walking, restless legs before sleep, cannot stay awake
+during or while sitting, severe snoring that bothers others, choking during sleep,
+canriot stay awake to drive, others have observed you to stop breathing during
+Explain any circled items: -
+SEXUAL
+Men: Cannot get erection, cannot ejaculate, ejaculate too soon, no sexual desire,
+partner does not meet your needs.
+Woren: Cannot lubricate, cannot have orgasm, no sexual desire, partner does not
+meet your needs.
+How many times per month do you engage in sexual activity with another person or
+a spouse?
+Explain any circled items:
+HIV
+Could you be HIV positive? Yes.
+
+
+Case 9:08-Cv-80119-KAM Document 254-1 Entered on FLSD Docket 08/07/2009 Page 27 of
+Page 15
+AUTHORIZATION INFORMATION
+I authorize Richard C. W. H
+M.D., to examine and test me. (If you are under 18 years of
+age, your parent or guardian must sign this form.)
+Signature
+Date
+I authorize this office to send a copy of this evaluation to the person or agency who
+requested me to be examined or to those parties involved in my care.
+Signature
+Date
+By my signature, I certify all statements I answered on this Questionnaire are true and
+accurate.
+Signature
+Date
+If this form was filled out by someone other than the patient, please give name and relationship to
+patient (spouse, friend, parent, guardian, etc.)
+Name:
+Relationship:
\ No newline at end of file
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new file mode 100644
index 0000000000000000000000000000000000000000..cdfc9de76e68a5c5c0f18f5b98b4b24d7875dbde
--- /dev/null
+++ b/vision-fixhub/court-01/ffd96c98ce6ef5210e1cbaf156d535e7d3b0887b063acab6f1b9dfbec8e7cc5d.receipt.json
@@ -0,0 +1,14 @@
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.md b/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.md
new file mode 100644
index 0000000000000000000000000000000000000000..21ccfc15af9cce25bffd91ae7af9f7d7f001a643
--- /dev/null
+++ b/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.md
@@ -0,0 +1,62 @@
+IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION AG
+CASE NO. 502009CA040800XXXXMB
+Judge David F.
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+PALM BEACH COUNTY. FL
+CIRCUIT CIVIL 3
+FILED:
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiffs.
+NOTICE OF HEARING
+(Uniform Motion Calendar)
+PLEASE TAKE NOTICE that the undersigned has set down for hearing before the
+Honorable David F. |
+one of the Judges of the above-styled Court, in Courtroom 9C at the
+Palm Beach County Courthouse, 205, North Dixie Highway, West Palm Beach, Florida on
+Thursday, February 2, 2012 at 8:45 a.m., the following:
+PLAINTIFF JEFFREY EPSTEIN'S MOTION TO SCHEDULE HEARING TIME
+I hereby certify that I have made a good faith attempt to resolve this matter prior to my
+noticing this Motion for hearing.
+PLEASE GOVERN YOURSELVES ACCORDINGLY.
+In accordance with the Americans With Disabilities Act, if you are a person
+with a disability who needs any accommodation in order to participate in this
+proceeding, you are entitled, at no cost to you, to the provision of certain
+assistance.
+Please contact Krista Garber, ADA Coordinator, in the
+Administrative Office of the Court, Palm Beach County Courthouse, 205
+North Dixie Highway, Room 5.2500, West Palm Beach, Florida 33401;
+
+
+Epstein v. Rothstein and
+Case No. 502009CA040800XXXXMB/Division AG
+telephone number (561) 355-4380 at least 7 days before your scheduled court
+appearance, or immediately upon receiving this notification if the time before
+the scheduled appearance is less than 7 days; if you are hearing or voice
+impaired call 711.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was served by e-mail
+and U.S. Mail on this 30* day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola
+Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409;
+Jack . Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue
+South, Suite 1400, West Palm Beach, FL 33401-5012; and Mare S. Nurik, Esq., Law Offices of
+Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301.
+Joophf drmandu
+doseph L. Ackerman, Jr
+Florida Bar No. 235954
+NOT A
+BURNETT, P.A.
+901
+Point West
+777 South Flagler Drive
+West Palm Beach, Florida 33401
+Telephone: (561) 802-9044
+Facsimile:
+(561) 802-9976
+Counsel for Plaintiff Jeffrey Epstein
+-2-
diff --git a/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.receipt.json b/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..112fb8346a64608e9c9f01faed43bc76ccd8e7b8
--- /dev/null
+++ b/vision-fixhub/court-02/000a4f7f133a66da86b30b58bb2a4af8b5c876bd4af80cc39fefc293cceeb08c.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d59a823d860adf15bee51fb444cdb479df4214b5b5d8eb09b5e3746aa52375ee",
+  "output_sha256": "97ecbc16be6abb0140a9b69ec5f91261ea35db9f350fb33805b224e2cc6d4f6e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.md b/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.md
new file mode 100644
index 0000000000000000000000000000000000000000..7cbb6b649ee32f90c32889558fda02f273da81ee
--- /dev/null
+++ b/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.md
@@ -0,0 +1,303 @@
+Filing # 67114112 E-Filed 01/26/2018 03:59:55 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+, individually, and
+L.M., individually,
+Defendants.
+'OP
+COPY
+MOTION TO LIFT CONFIDENTIALITY DESIGNATION OF EPSTEIN'S
+DISCLOSURE OF CONFIDENTIAL SETTLEMENT INFORMATION
+Counter-Plaintiff,
+by and through undersigned counsel, hereby files
+this Motion to Lift Confidentiality Designation of Epstein's Disclosure of Confidential Settlement
+Information pursuant to the Court's Order Compelling Epstein to Produce Settlement Amounts
+dated January 5, 2018, and as grounds therefore states as follows:
+On January 5, 2018, the Court entered its Order Compelling Epstein to Produce
+Settlement Amounts, which required Epstein to produce, for attorneys' and client's eyes only, the
+following information: (a) the number of sexual abuse claims that Epstein settled in the two years
+prior to December 7, 2009; (b) the aggregate settlement monies paid for the cases settled in the
+two years prior to December 7, 2009; (c) the number of sexual abuse claims that Epstein settled
+after December 7, 2009; and (d) the aggregate settlement monies paid for the cases settled after
+December 7, 2009. A copy of the Court's Order is attached hereto as Exhibit 'A'.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/26/2018 03:59:55 PM
+
+
+f adv. Epstein
+On January 24, 2018, Epstein produced this court-ordered information tol
+by way of a document titled 'Confidential, for Attorneys' and Client's Eyes Only Epstein's
+Disclosure of Confidential Settlement Information.'
+3.
+Pursuant to paragraph 3 of the Order,
+is required to file an appropriate
+motion to lift the confidentiality designation prior to using any of this information during future
+hearings or at trial. See Ex. 'A'.
+now seeks to lift the confidentiality designation concerning the aggregate
+number of claims settled by Epstein before and after this malicious lawsuit was filed. Specifically,
+intends to rely upon and use the number of claims that Epstein settled in the two years
+prior to December 7, 2009 and the number of claims that were settled after December 7, 2009 at
+future hearings and at trial, as this information is highly relevant to Epstein's motive in filing this
+malicious and unfounded lawsuit against Edwards.
+It has been Edwards' contention from the very beginning that one of Epstein's
+primary motives in filing this lawsuit was to intimidate his child victims into cheaply
+compromising or abandoning their sexual molestation claims against Epstein. The number of
+claims that had already been settled prior to this malicious lawsuit is highly relevant to this motive
+as it demonstrates the predicament that Epstein faced immediately before filing this malicious
+lawsuit against
+Epstein had already settled a considerable number of claims and he knew
+that many more victims were still out there. He was angry, and he sought to go on the offensive
+against the remaining child victims in order to intimidate and silence them. Epstein quite clearly
+2
+
+
+s adv. Epstein
+did not want to repeat the settlement history that pre-dated this maliciously filed lawsuit. He needed
+to change the narrative.
+6.
+The number of sexual misconduct claims that were settled after the filing of this
+malicious lawsuit is relevant to demonstrate the significant financial exposure that Ep
+faced
+on December 7, 2009, which he attempted to reduce by suing an attorney representing some of his
+victims
+) as well as one of the victims herself (L.M.). The Court has already ruled that
+the number of claims Epstein faced at the time he filed and continued this malicious lawsuit is
+admissible. See Order on Plaintiff/Counter-Defendant Jeffrey Epstein's Revised Omnibus Motion
+in Limine Section D (References to Cases Not Litigated by Edwards), entered on January 16, 2018.
+is nonetheless including this request to lift any confidentiality that may exist as to the
+settled claims the post-date the filing of this malicious lawsuit, in an abundance of caution. See
+Ex. 'A'.
+WHEREFORE, Counter-Plaintifi
+i, respectfully requests that the Court
+enter an Order granting this Motion to Lift Confidentiality Designation of Epstein's Disclosure of
+Confidential Settlement Information, as well as awarding any such further relief as the Court
+deems just and proper given the circumstances.
+3
+
+
+adv. Epstein
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 26th day of January, 2018.
+David P. Vitale Jr.
+Attorney E-Mails: jsx@searcylaw.com and
+mmccann@seareylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Attorneys for
+J.
+NOT A
+NOT A CER
+4
+
+
+5 adv. Epstein
+COUNSEL LIST
+J.
+¡, Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+FIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J. Edwards
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com;
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com;
+tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard
+Suite 301 A
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+5
+
+
+adv. Epstein
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
+6
+
+
+•
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+COPY
+ORDER COMPELLING EPSTEIN TO PRODUCE SETTLEMENT AMOUNTS
+THIS CAUSE came before the Court upon Counter-Plaintiff's ore lenus motion on
+December 7, 2017. The Court, having heard argument of counsel does hereby,
+ORDER AND ADJUDGE that:
+Plaintiff/Counter-Defendant
+Jeffrey Epstein ("Epstein") shall produce to
+Defendant/Counter-Plaintiff
+") the following: '
+a. The number of claims settled by Jeffrey Epstein regarding individuals who
+alleged to be victims of sexual misconduct by Epstein, from December 6, 2007
+‹ to December 6, 2009;
+The gross settlement amount paid by Epstein to individuals who alleged to be
+victims of sexual misconduct by Epstein, from December 6, 2007 to December
+6, 2009;
+c. The number of claims settled by Jeffrey Epstein regarding individuals who
+alleged to be victims of sexual misconduct by Epstein, from December 7, 2009
+through the present; and
+Ex.
+A
+
+
+Jeffrey Epstein V. Scolt Rothstein and 1
+15'" Judicial Circuit Case No. 2009CA040800XXXXMBAG
+Order Compelling Epstein to Produce Settlement Amounts
+Page 2
+d. The gross settlement amount paid by Epstein to individuals who alleged to be
+victims of sexual misconduct by Epstein, from December 7, 2009 through the
+present.
+2.
+The number of claims and amounts shall be produced as "Confidential, for
+Attormeys' and Clients' Eyes Only," and shall not, directly or indirectly, be disclosed to anyone
+else or used outside of this litigation.
+If a party intends to quote, disclose, rely on or use in this litigation information or
+documents that have been deemed "Confidential, for Attorneys' and Clients' Eyes Only," whether
+in papers filed with the Court or verbally, in connection with a motion, hearing, deposition or trial,
+before any such information is quoted, disclosed, relied upon or used, the party must file a Motion
+to have the information or documents deemed to be no longer confidential, must file the
+information or documents under seal in accordance with Administrative Order 2.303-9/09 and
+have the proposed quote, disclosure, reliance or use of such information or documents heard and
+approved by the Court.
+4.
+The Court defers rulings on the admissibility of the number of claims and the gross
+settlement amounts disclosed pursuant to this Order and the admissibility of the combined
+settlement amounts of
+three clients for whom
+was prosecuting civil cases
+against Epstein at the time Epstein filed the December 7, 2009 lawsuit against
+production of the underlying Settlement Agreements with each of |
+No
+three clients or with
+any other alleged victim is required by this Order. The Court defers ruling on whether there will
+be any further disclosure of any breakdown of the settlement amounts paid by Epstein.
+Epstein shall file a new Motion addressing separately the admissibility of the
+aggregate settlement amount paid to
+three clients and the gross settlement amounts
+
+
+•
+Jeffrey Epstein v. Scott Rothstein and 1
+15 Judicial Cruit as No. 2i0 A040800X MBAG
+Order Compelling Epstein to Produce Settlement Amounts
+Page 3
+disclosed pursuant to this Order. The Motion should also address Epstein's position as to the
+production of any Settlement Agreements underlying any settlements paid by Epstein and outline
+the confidentiality provisions governing those agreements. To the extent that disclosure of any
+such provisions is subject to confidentiality, disclosure shall be made under seal in accordance
+with Administrative Order 2.303-9/09.
+6.
+The parties shall schedule a 30-minute hearing on Epstein's Motion.
+shall
+respond to the Motion in accordance with this Court's judicial instructions.
+ZONE AND ORDERED in West Palm Beach, Palur Beach Couly. Florida this.
+• 5 day
+of December, 2018
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach. FL 33409
+mep@searcylaw.com
+jsx@scarcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33401
+brad@epllc.com
+staff.efile@pathotojustice.com
+So Counsel for Defendam/ Counter-Plainlif
+THE HONORABLE DONALD W. HAFELE
+CIRCUIT COURT JUDGE
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+
+
+Jeffrey Epstein v. Scott Rothstein and 1
+5 Judicial Circuit Case No. 2009CA040800XXXXMBA(
+Order Compelling Epstein to Produce Settlement Amounts
+Page 4
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+igoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Scott J. Link
+Kara Berard Rockenbach
+Angela M. Many
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+Scott@linkrocklaw.com
+Kara/@linkrocklaw.com
+Angela@linkrocklaw.com
+Iina(@linkrocklaw.com
+Troy@linkrocklaw.com
+Tanya@linkrocklaw.com
+Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendanı
+Jeffrey Epstein
+CERTIFI
+NOT A CERTIFI
\ No newline at end of file
diff --git a/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.receipt.json b/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..15f9796452e13eb9daae62e3d5dd5e84f98d1108
--- /dev/null
+++ b/vision-fixhub/court-02/002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -501,
+  "dataset": "marble-joined",
+  "doc_id": "002ad9f42ec210f5d4acb8569444615722aead2d5a3be848320eb1110b00174f",
+  "engine": "marble-apple-vision",
+  "event_count": 11,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "a370da511b8b85491985ab08d50dedcf14308702ba7d54eff946fd8a52b6d276",
+  "output_sha256": "7e72bc88e2f236b91183c01bf93ab9c4ba4f56035c5982ef5653c640f1c42885",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6.md b/vision-fixhub/court-02/00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6.md
new file mode 100644
index 0000000000000000000000000000000000000000..9cf559d3d421d6660d422426aa679a31c65a93f3
--- /dev/null
+++ b/vision-fixhub/court-02/00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6.md
@@ -0,0 +1,3328 @@
+Filing # 64081089 E-Filed 11/13/2017 10:07:10 AM
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EP
+PRODUCTION FROM NON-PARTIES
+NOTICE OF
+YOU ARE NOTIFIED that after 10 days from the date of service of this notice, if service
+is by delivery, or 15 days from the date of service, if service is by mail, and if no objection is
+received from any party, the undersigned, on behalf of Plaintiff/Counter-Defendant Jeffrey
+Epstein, will issue the attached Subpoenas directed to the following, who are non-parties, to
+produce the items listed at the time and place specified in the Subpoenas:
+2.
+Robert C. Joefsberg
+Podhurst Orseck, PA
+One S.E. Third Avenue, Suite 2700
+Miami, FL 33131
+Charles Lichtman
+Berger Singerman
+300 East Las Olas Boulevard, Suite 100C
+Ft. Lauderdale, FL 33301
+3.
+Spencer Kuvin
+1800 S. Australian Avenue, Suite 400
+West Palm Beach, FL 33409
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/13/2017 10:07:10 AM
+
+
+4.
+Theodore Leopold
+Milstein
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+Adam Horowitz
+425 N. Andrews Ave., Suite 2
+Ft. Lauderdale, FL 33301|
+6.
+Isidro M.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+7.
+Earleen Cote
+Kubicki Draper
+One East Broward Boulevard, Suite
+1600
+Fort Lauderdale, FL 33301
+8.
+William Berger
+Weiss, Handler, Cornwell, P.A.
+2255 Glades Road, Suite 218A
+Boca Raton, FL 33431
+CERTIFIED COPY
+NOT A CER
+2
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on November 13, 2017, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. L
+Iny (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Angela@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Iroy@linkrocklaw.com
+Secondary: Tanya@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@scaroylaw.com
+jsx(@searoylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+West Palm Beach, FL 33401
+nis@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+3
+
+
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+efiling@tonjahaddad.com
+W. Chester
+Jr.
+W. Chester
+Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+igoldberger@agwpa.com
+smahoney@agwpa.com
+NOT A
+NOT
+4
+
+
+NOT A 98,2
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Robert C. Josefsberg
+Podhurst Orseck, P.A.
+One S.E. Third Avenue, Suite 2700)
+Miami, FL 33131
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 301, West Palm Beach, Florida, on
+, 2017, at 9:00 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+condary: Troy @linkrocklaw.co
+condary: Tanya@linkrocklaw.co
+2
+
+
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+mare@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Jack A. Goldberger
+atterbury, Goldberger & Weiss, P.A
+50 Australian Avenue S., Suite 140
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Robert C. Josefsberg and include all employees,
+staff, representatives, attorneys, accountants, agents and any other person acting under his control
+or on his behalf.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+6.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+b.
+C.
+Processing Specifications. For each Native Format file that is converted to
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+5.
+6.
+7.
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+those notes or not.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+D that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+ayment or compensation, or a request for payment or compensation, for your services it
+his Lawsuit or any of the Other Lawsuits
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hig discussed, analyzed or otherwise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+TAB, COPY
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Charles Lichtman
+Berger Singerman
+300 East Las Olas Blvd., Suite 1000
+Ft. Lauderdale. FL 33301\
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 301, West Palm Beach, Florida, on
+, 2017, at 9:30 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Secondary: Tanya@ikkrcklaav.om
+Secondary: Eservice@linkrocklaw.com
+2
+
+
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+mare@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Jack A. Goldberger
+atterbury, Goldberger & Weiss, P.A
+50 Australian Avenue S., Suite 140
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Charles Lichtman and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under his control or on
+his behalf.
+"Relates to" or
+comprising, containing,
+consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+6.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+b.
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+C.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+(or counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+ayment or compensation, or a request for payment or compensation, for your services it
+his Lawsuit or any of the Other Lawsuits
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+TABS COPY
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena),
+THE STATE OF FLORIDA TO:
+TO: Spencer Kuvin
+1800 S. Australian Ave., Suite 400.
+West Palm Beach, FL 33409
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 301, West Palm Beach, Florida, оп
+, 2017, at 10:00 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+
+
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+NOT A
+Copies
+provided
+2
+
+
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+144 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintif)
+J.
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+W. Chester
+Jr.
+W. Chester
+Jr. PA
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Co-Counsel for Plaintifj/Counter-Defendan
+Jack A. Goldberger
+250 Australian Aver 8. Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Spencer Kuvin and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under his control or on
+his behalf.
+6.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+b.
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+C.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+TAB
+IED COPY
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Theodore Leopold
+Milstein
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, FL 33410
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 30k, West Palm Beach, Florida, on
+, 2017, at 10:30 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Secondary: Tany@ikkrcklaw.com
+2
+
+
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+mare@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Jack A. Goldberger
+atterbury, Goldberger & Weiss, P.A
+50 Australian Avenue S., Suite 140
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Theodore Leopold and include all employees,
+staff, representatives, attorneys, accountants, agents and any other person acting under his control
+or on his behalf.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+b.
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+C.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+NOT A CERT
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Adam Horowitz
+425 N. Andrews Ave., Suite 2,
+Ft. Lauderdale, FL 33301
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 301, West Palm Beach, Florida, on
+, 2017, at 11:00 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+
+
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+2
+
+
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+mare@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Jack A. Goldberger
+atterbury, Goldberger & Weiss, P.A
+50 Australian Avenue S., Suite 140
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Adam Horowitz and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under his control or on
+his behalf.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+b.
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+C.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+NOT ACE 180
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Isidro M.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL 33401
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 30k, West Palm Beach, Florida, on
+- 2017, at 11:30 a.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Secondary: Tany@ikkrcklaw.com
+2
+
+
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+139 Palm Beach Lakes Boulevar
+Courthouse Commons, Suite 350
+Vest Palm Beach, FL 33405
+444 West Railroad Avenue
+mep@searcylaw.com
+West Palm Beach, FL 33401
+jsx@searcylaw.com
+njs@FLAppellateLaw.com
+scarolateam@scarcylaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+J.
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+efiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Isidro M. |
+and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under his control or on
+his behalf.
+"Relates to" or
+comprising, containing,
+, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andithout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+6.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+b.
+C.
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+(or counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+NOT A CHA COPY
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: Earleen Cote
+Kubicki Draper
+One East Broward Blvd., Suite 1600
+Ft. Lauderdale, FL 33301~
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 30k, West Palm Beach, Florida, on
+, 2017, at 12:00 p.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Secondary: Tany@ikkrcklaw.com
+2
+
+
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+139 Palm Beach Lakes Boulevar
+Courthouse Commons, Suite 350
+Vest Palm Beach, FL 33405
+444 West Railroad Avenue
+mep@searcylaw.com
+West Palm Beach, FL 33401
+jsx@searcylaw.com
+njs@FLAppellateLaw.com
+scarolateam@scarcylaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+J.
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+efiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of ES/ in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Earleen Cote and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under her control or on
+her behalf.
+6.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+6.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+b.
+C.
+Processing Specifications. For each Native Format file that is converted to
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent ES/ in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
+
+
+ТАВД COPY
+
+
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+(Mail in Subpoena)
+THE STATE OF FLORIDA TO:
+TO: William Berger
+Weiss, Handler, Cornwell, P.A.
+2255 Glades Road, Suite 218A >
+Boca Raton, FL 33431
+YOU ARE COMMANDED to appear at Link & Rockenbach, P.A., 1555 Palm Beach
+Lakes Boulevard, Suite 30k, West Palm Beach, Florida, on
+, 2017, at 12:30 p.m. and to
+have with you at that time and place the following:
+SEE EXHIBIT A
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this Subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this Subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the
+
+
+attorney whose name appears on this Subpoena and thereby eliminate your appearance at the
+time and place specified above. You have the right to object to the production pursuant to this
+Subpoena at any time before production by giving written notice to the attorney whose name
+appears on this Subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE
+TAKEN.
+If you fail to:
+(1) appear as specified; or
+(2) furnish the records instead of appearing as provided above; or
+OPY
+(3) object to this Subpoena,
+you may be in contempt of court. You are subpoenaed to appear by the following attorneys, and
+unless excused from this Subpoena by the attorneys or the Court, you shall respond to this
+Subpoena as directed.
+Dated: November _, 2017.
+NOT A
+LINK & ROCKENBACH, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+[DRAFT]
+By:
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Secondary: Tany@ikkrcklaw.com
+2
+
+
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+139 Palm Beach Lakes Boulevar
+Courthouse Commons, Suite 350
+Vest Palm Beach, FL 33405
+444 West Railroad Avenue
+mep@searcylaw.com
+West Palm Beach, FL 33401
+jsx@searcylaw.com
+njs@FLAppellateLaw.com
+scarolateam@scarcylaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+J.
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+efiling@tonjahaddad.com
+W. Chester Brewer, Jr.
+W. Chester Brewer, Jr. P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+wcblaw@aol.com
+wcblawasst@gmail.com
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+3
+
+
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+4
+
+
+
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings,
+voicemail, instant messages,
+conversations, dialogues,
+discussions,
+interviews,
+conferences,
+meetings,
+consultations,
+agreements, and other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries,
+lists,
+compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies,
+checks, check stubs,
+invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+5
+
+
+devices, and all originals, reproductions, copies, changes, amendments,
+Graphic or auditory records or representations of any kind, including, but
+not limited to: all images, photographs, charts, drawings, sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+electronic communications, text messages, e-mails, instant messages,
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+10
+files, virtual machine files, XML files, webpage files, image files, design
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "ES/"; cach individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+6
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether of not the draft's
+terms are the same as or different from the final document's terms. Please note that "Document"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above.
+"Native Format" means the file format of EST in the application in which such ESI
+was originally created.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean William Berger and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under his control or on
+his behalf.
+"Relates to" or
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+7
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+against Jeffrey Epstein from January 1, 2008 to the
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+Where appropriate:
+a.
+b.
+C.
+use of the singular includes the plural, and vice versa;
+the past tense includes the present tense;
+the words "and" and "or" are both conjunctive and disjunctive;
+the words "all" and any"
+the words all did areams an adi andiahout limitation; and
+use of the masculine includes the feminine, and vice versa.
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+2.
+Unless otherwise specifically stated in each request, the relevant time period shall
+8
+
+
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ES/ document, all metadata must
+remain intact and all parent/child document
+relationships must be maintained. All ES/ shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of ES/ as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+ESI; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+6.
+TIFF Production. EST produced as TIFF image files shall be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file ("Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+9
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of cach TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+b.
+C.
+Processing Specifications. For each Native Format file that is converted to
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent ES/ in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+reserve the right to make a request for a file to be produced in color.
+10
+
+
+Where TIFF Image File Format is Impracticable. In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+Your current curriculum vitae. Cy
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit and your analysis of the Other Lawsuits.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit and your analysis of the Other Lawsuits, whether you relied on
+5.
+6.
+7.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit, as well as your analysis of the Other Lawsuits.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+Any diagrams or drawings made by you or provided to you, which you have examined in
+
+
+13.
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations.
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+James
+for counsel for
+James
+) that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+payment or compensation, or a request for payment or compensation, for your services in
+this Lawsuit or any of the Other Lawsuits.
+All marketing materials that market or advertise your expert witness services.
+A list of all other expert witness services performed for
+James
+, or any
+clients represented by
+James
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+
+
+24.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Copies of all publications, expert reports, depositions or other documents in which you
+hiya discussed, analyzed or othervise referenced the subject of the scope of discovery in
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultatior
+relating directly or indirectly to the issues in this Lawsuit
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+13
\ No newline at end of file
diff --git a/vision-fixhub/court-02/00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6.receipt.json b/vision-fixhub/court-02/00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0f406b05d4708cb63338c9e1c9199f84e424610f
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+  "doc_id": "00e8598f18689cbb0fb7c435c515391b56aa39811502c1f626d9daeb212e42e6",
+  "engine": "marble-apple-vision",
+  "event_count": 125,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "be8cfd959dd2ba0fc608155849ccd69cd5e284cbcadf297566d58e95f41bc40b",
+  "output_sha256": "c992794969e9a68af60185c783780eabeeea4fcb4d40317cb72c19950f66ec33",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.md b/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.md
new file mode 100644
index 0000000000000000000000000000000000000000..12c257fcc1e645f1598943e44bdb60324ae54db5
--- /dev/null
+++ b/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.md
@@ -0,0 +1,72 @@
+Case 9:08-cv-80736-KAM Document 294 Entered on FLSD Docket 01/22/2015 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE #1 and JANE DOE #2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+RESPONDENT'S NON-OPPOSITION TO MOTION FOR LIMITED INTERVENTION
+BY ALAN M. DERSHOWITZ
+Respondent United States, by and through its undersigned counsel, files its Non-
+Opposition to the Motion for Limited Intervention by Alan M. Dershowtiz, and states:
+The Government does not oppose the Motion for Limited Intervention by Alan M.
+Dershowitz (D.E. 282).
+DATED: January 22, 2015
+Respectfully submitted,
+WILFREDO A. FERRER
+UNITED STATES ATTORNEY
+By:
+_s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+Fla. Bar No. 0936693
+99 N.E. 4'' Street, Suite 300
+Miami, Florida 33132
+(305) 961-9320
+Fax: (305) 530-7139
+E-mail: dexter.lee @ usdoj.gov
+ATTORNEY FOR RESPONDENT
+
+
+Case 9:08-cv-80736-KAM Document 294 Entered on FLSD Docket 01/22/2015 Page 2 of 2
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on January 22, 2015, I electronically filed the foregoing
+document with the Clerk of the Court using CM/ECF.
+s/ Dexter A. Lee
+DEXTER A. LEE
+Assistant U.S. Attorney
+SERVICE LIST
+Jane Does 1 and 2 v. United States.
+Case No. 08-80736-CIV-MARRA/
+United States District Court, Southern District of Florida
+E59)
+. Jaffe, Weissing,
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954) 524-2820
+Fax: (954) 524-2822
+E-mail: brad @pathtojustice.com
+Fistos & Lehrman, P.L.
+Paul G. Cassell
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E
+Salt Lake City, Utah 84112
+(801) 585-5202
+Fax: (801) 585-6833
+E-mail: casselp@law.utah.edu
+Attorneys for Jane Doe # 1 and Jane Doe #2
+Roy Black
+Jackie Perczek
+Black, Srebnick, Kornspan & Stumpf, P.A.
+201 South Biscayne Boulevard
+Suite 1300
+Miami, Florida 33131
+(305) 371-6421
+Fax: (305) 358-2006
+E-mail: rblack@royblack.com
+jperczek@royblack.com
+Attorneys for Intervenors
+2
diff --git a/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.receipt.json b/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..db187fa11a49602208a37f251e75cdc4ff541c50
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+++ b/vision-fixhub/court-02/0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81.receipt.json
@@ -0,0 +1,14 @@
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+  "doc_id": "0135365696aabe3111b4c117e1818c002e997c90c9ea3343210e6f42ba88db81",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "23ace3e6bae03ee3d28551efa76a5693f395f5a132c868eeba668ef61936f523",
+  "output_sha256": "f309ceaf864ebe3077a99d2c23310d60b707fc36b39290688b30786085e43c56",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.md b/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.md
new file mode 100644
index 0000000000000000000000000000000000000000..14d044256dd9744f3b8d94d5d6e32fd1de18d6e9
--- /dev/null
+++ b/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.md
@@ -0,0 +1,1097 @@
+Filing # 66635165 E-Filed 01/17/2018 11:57:55 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+COPY
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+REVISED OMNIBUS MOTION IN LIMINE
+SECTION B (
+TRIAL EXHIBITS)
+THIS MATTER came before the Court for hearing on November 29, 2017, and December
+5, 2017, upon Section B (
+Trial Exhibit List') of the Revised Omnibus Motion in Limine
+filed by Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") (D.E. 1070). The Court, having
+reviewed the Motion and the Response filed by Defendant/Counter-Plaintiff
+J.I
+) (D.E. 1089), having heard argument of counsel, and being otherwise fully advised in
+the premises, it is hereby
+ORDERED AND ADJUDGED that:
+'Epstein's Revised Omnibus Motion in Limine was directed at
+• Amended Exhibit List dated
+November 9, 2017. (D.E. 1043.). On December 7, 2017, after two days of hearing and substantive
+Court rulings,
+filed a Second Amended Exhibit List (D.E. 1109) identifying 79 new items
+and modifiving some of his earlier disclosed exhibits. This Order only addresses the exhibits identified
+/ November 9, 2017, Exhibit List. To the extent any exhibit numbers have been replaced
+with different items or new numbers have been added, those will be subject to a separate Order after
+the appropriate motion and hearing. The rulings set forth herein for all exhibits disclosed on
+December 7, 2017, Second Amended Exhibit List that have not been modified will remain unchanged.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/17/2018 11:57:55 AM
+
+
+On or before December 20, 2017,
+shall produce to Epstein all trial exhibits
+that have not been previously produced in the form to be introduced at trial with the exception of
+Exhibit No. 113 which is addressed separately in paragraph 2 below. (12/5/17 Tr. 216, 219, 226,
+228.)
+On or before January 5, 2018, L
+• shall produce to Epstein the specific court
+filings to be used as trial exhibits from the Crime Victims' Rights Act proceeding (Jane Does #1
+and #2 v. United States of America, U.S. District Court, Southern District of Florida, Case No. 08-
+80736-Civ-Marra/
+designated as
+" Trial Exhibit No. 113.)
+shall not
+produce each and every item identified on the Court's docket, but shall cull out the specific items
+he intends to use at trial. The Court hereby sustains Epstein's objection to Exhibit No. 113 as
+being overbroad. The Court will revisit this ruling if Edwards narrows the documents he intends
+to introduce at trial. (12/5/17 Tr. 218:25-226:14.)
+As set forth in more detail below, the Court has sustained Epstein's objections to a
+number of
+'trial exhibits. Those objections will be sustained unless there is a showing at
+trial that the exhibits are relevant and material to the issues to be determined. For example, exhibits
+may be admissible if they relate to
+' three clients (L.M., E. W. and Jane Doe), if they relate
+to issues concerning Edwards' preparation and evaluation of his clients' cases, or for any other
+reason enunciated by the Court on the record at the November 29, 2017 and December 5, 2017
+hearings.
+In those instances,
+will be allowed to speak generically about the facts
+surrounding those exhibits, but will not necessarily be allowed to introduce the exhibits at trial
+without further Order of the Court. The Court will make decisions on an item-by-item basis at the
+appropriate time. Any discussions relating to an exhibit to which an objection has been sustained
+shall be conducted outside the presence of the jury. (12/5/17 Tr. 153:16-160:24; 198:19-199:5.)
+2
+
+
+1.
+2.
+3.
+4.
+5.
+As set forth in more detail below, the Court defers rulings on Epstein's objections
+directed to
+trial exhibits concerning Epstein's net worth and in support of
+punitive damages claim. The Court will address these objections at the appropriate time: (12/5/17
+Tr. 163:17-164:15.)
+5.
+The Court makes the following specific findings:
+LEGEND FOR EPSTEIN'S OBJECTIONS:
+1 - All Objections
+2 - All Objections except Authenticity
+3 - Relevance
+4 - Probative value substantially outweighed by danger of unfair prejudice,
+COPY
+confusion of issues, misleading the jury, or needless presentation of cumulative
+evidence
+5 - Privileged
+6 - Opinion
+7 - Hearsay
+8 - Authenticity
+9 - Other (please identify basis of objection)
+10 - Completeness
+11 - Overbroad
+12 - Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation
+13 - Not a proper exhibit
+14 - Trade secrets/Confidential
+
+All applicable criminal statutes
+All applicable Florida Statutes
+Photos and information of Jeffrey Epstein's
+homes, airplanes and automobiles
+3, 4, 7, 11, 12
+3, 4, 7, 11, 12
+3, 4, 7, 8, 10, 12
+Court's Ruling
+Not addressed at hearing
+Not addressed at hearing
+11/29/17 Tr. 160:6-162:15
+Order confirmation from Amazon.com for
+purchase of books "SM 101: A realistic
+Introduction," «Slave Craft: Roadmap for Erotic
+Servitude-Principles, Skills and Tools" and
+"Training Miss Abernathy:
+A Workbook for Erotic Slaves and Their Owners"
+Non-Prosecution Agreement
+3, 4, 7,8
+11/29/17 Tr. 162:16-167-9
+Sustained
+3,4, 7, 8, 10
+11/29/17 Tr. 167:11-13
+Overruled
+3
+
+
+6.
+
+Jane Doe 102 Complaint
+Messages taken from message pads found at
+Epstein's home
+3, 4, 7, 13
+3, 4, 7, 8, 11, 14
+Court's Ruling
+11/29/17 Tr. 167:14-170:2
+Sustained
+11/29/17 Tr. 171:22-176:9
+eferred. Not to be mentione
+uring opening statements
+8.
+Documents related to Jeffrey Epstein produced by
+Alfredo Rodriguez
+9.
+Jeffrey Epstein flight logs
+10. | Jeffrey Epstein phone records
+3, 4, 7, 8, 11, 14
+3, 4, 7, 8, 10, 11
+3, 4, 10, 11, 14
+11.
+phone records
+3,4, 8, 10,11 14
+12.
+Jail Visitation Logs
+3, 4, 7, 8, 11
+13.
+Jeffrey Epstein's probation file
+3, 4, 7, 8, 11.
+14.
+All probable cause affidavits related to criminal
+investigation of Jeffrey Epstein
+15.
+Victims' statements to the FBI related to criminal
+investigation of Jeffrey Epstein
+16.
+| Video of Search Warrant of Jeffrey Epstein's
+3, 4, 7, 8, 10
+3, 4, 7,8
+3, 4,8
+17.
+18.
+11/29/17 Tr. 176:10-187:8
+duringo. Nine so be mentioned
+12/5/17 Tr. 64:8-81:17; 85:11-22
+Sustained
+12/5/17 Tr. 81:18-82:17: 146:14-
+149:19: 159:12-160:7
+Sustained
+12/5/17 Tr. 149:20-150:1;
+159:12-160:7
+Sustained
+12/5/17 Tr. 150:2-3: 159:12-
+160:7
+Sustained
+12/5/17 Tr. 150:4-152:11:
+159:12-160:7
+Sustained
+12/5/17 Tr. 152:14-153:13
+12/5/17 Tr. 153:16-160:24
+Sustained
+12/5/17 Tr. 160:25-161:21
+Sustained
+Application for Search Warrant of Jeffrey
+3, 4, 7, 8, Cannot 1215/17 Tr. 160:25-162:19
+Epstein's home
+be read
+Sustained
+Complaint Jane Doe v. Epstein and all subsequent | 3, 4, 7, 13, 12 (as
+12/5/17 Tr. 162:20-24
+Amended Complaints
+"subsequer
+mende
+Complaints")
+2 In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+exhibit to: "Video of Epstein Property Inspection 01/18/10." This Order does not make any rulings on
+the new description and may be subject to a new Motion in Limine as Epstein deems appropriate.
+4
+
+
+19.
+
+assets
+20.
+Jeffrey Epstein's passport (or copy)
+21.
+| Jeffrey Epstein's driver's license (or copy)
+22.
+| List of corporations owned by Jeffrey Epstein
+23. Yearbooks of Jane Doe
+24.
+| 2002 |
+Palm Beach High School Year Book
+25.
+| 2001 |
+Palm Beach High School Year Book
+26.
+27.
+| 2003 Palm Beach Gardens High School Year
+Book
+Affidavit and Application for Search Warrant on
+leffrey Epstein's home?
+Court's Ruling
+12
+12/5/17 Tr. 162:25-164:15
+12
+12/5/17 Tr. 163:4-S: 164:16-19
+Sustained
+Cannot be read, 3,
+12/5/17 Tr. 164:20-24
+Sustained
+3, 4, 7, 8, 12
+12/5/17 Tr. 164:25-165:5
+3, 4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16;
+166:25-167:6
+Neferreduced
+3, 4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16
+166:25-167:6
+Not produced
+3, 4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16
+66:25-167:
+Defereduce
+3, 4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16
+166:25-167:6
+Not produced
+3, 4, 7, 8, 10,
+12/5/17 Tr. 166:15-24
+Sustained
+3 In his December 7, 2017, Second Amended Exhibit List,
+_ modified this exhibit to include
+dditional descriptive language: "(from Palm Beach State Attorney's File, Exhibit #29)." The Cou
+inds that this language does not substantially change the exhibit and, thus, the Court's ruling hold:
+5
+
+
+28.
+' Exhibit Description
+Notepads found in Jeffrey Epstein's home and/o
+rimina inesia ioside orhis home during
+3, 4, 7, 8, 10, 11, 14
+Court's Ruling
+Sustained in part and overruled ir
+art. The impact upon the issues
+as to preparedness, knowledge, as
+is concerned
+29.
+The Palm Beach State Attorney's Criminal file
+against Jeffrey Epstein
+3, 4, 6, 7, 8, 10,
+11, 13
+30.
+31.
+32.
+All documents related to Jeffrey Epstein's 6/30/08
+3, 4, 7, 8, 12
+conviction
+Jeffrey Epstein's criminal plea colloquy
+3,4, 7,8,12
+List of properties and vehicles in Larry Visoski's 3,4, 7, 8, 11, 13,
+name
+The exhibit
+provided was an
+entire Motion
+(which was
+denied) not just
+the identified item.
+themselves are excessive and
+would be getting into other
+germane to
+' three
+clients and, therefore, may not be
+used until discussed outside the
+presence of the jury
+12/5/17 Tr. 168:17-175:1
+Sustained in part and overruled in
+part. If
+; had access to
+formulate his positions as to the
+legitimacy of his three clients'
+claims, this file may come into
+play. The sheer amount of the
+criminal file would also be
+relevant to Mr. Epstein's state of
+mind at the time he filed the
+underlying Complaint. The
+individual pages are not subject
+to admission and would need to
+be discussed outside the presence
+of the jury.
+12/5/17 Tr. 175:2-179:25
+12/5/17 Tr. 175:2-180:5
+12/5/17 Tr. 180:23-181:12
+6
+
+
+33.
+34.
+35.
+36.
+
+All of Jeffrey Epstein's Responses to Requests for
+3, 4, 11, 12, 13
+Production, Requests for Admission, Answers to
+Interrogatories in this matter, and cases 08-80119,
+08-80232, 08-80380, 08-80381, 08-80994, 08-
+80811,08-80893, 09-80469, 09-80591, 09-80656,
+09-80802, 09-81092
+All discovery related responses of Jeffrey Epstein
+3, 4, 11, 12, 13
+in this matter and cases 08-80119, 08-80232, 08-
+80380, 08-80381, 08-80994, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-
+81092
+Jeffrey Epstein's Answers and Affirmative
+Defenses in all civil cases against him
+All Complaints in which Jeffrey Epstein is/was
+defendant
+Court's Ruling
+12/5/17 Tr. 188:23-192:17
+Not addressed at hearing
+37.
+3,4, 11, 12, 13
+3, 4, 11, 12, 13.
+This also includes.
+a motion which is
+not part of the
+stated exhibit.
+3, 4, 11, 12, 13
+12/5/17 Tr. 192:18-22
+12/5/17 Tr. 192:23-193:2
+Not addressed at hearing
+38.
+39.
+40.
+41.
+42.
+43.
+44.
+Jeffrey Epstein's Deposition testimony and
+discovery responses in this case and cases 08-
+80119, 08-80232, 08-80380, 08-80381, 08-80994,
+08-80811, 08-80893, 09-80469, 09-80591, 09.
+80656, 09-80802, 09-81092
+Jeffrey Epstein's Deposition testimony and
+discovery responses in State Court cases LM v.
+Jeffrey Epstein, Case No.
+502008CA028051XXXXIMB AB and E.W.v.
+Jeffrey Epstein, Case No.
+502008CP003626XXXXMB
+Jeffrey Epstein Deposition Testimony and
+discovery responses in State Court case Jeffrey
+Epstein v. Scolt Rothstein, et al. Case No
+502009CA040800XXXXMBAG
+Any and all newspaper articles, online articles or
+publications related to Jeffrey Epstein
+Report and Analysis of Jeffrey Epstein's assets
+Video footage (DVD) of walk through site
+inspection of Jeffrey Epstein's home.
+Photos of all of Jeffrey Epstein's properties, cars,
+boats and planes
+Probable Cause Affidavits prepared against
+Jeffrey Epstein and
+3, 4, 11, 12, 13
+Not addressed at hearing
+3, 4, 11, 12, 13
+Not addressed at hearing
+3,4, 7, 8, 11, 12
+3, 4, 7, 8, 14
+3,4, 7, 8, 12
+/ 3,4, 7, 8, 14, 12
+(as to cars and
+boats)
+3, 4, 7, 8, 10
+12/5/17 Tr. 193:3-194:22
+12/5/17 Tr. 194:23-195:1
+12/5/17 Tr. 195:2-195:15
+12/5/17 Tr. 195:16-18
+12/5/17 Tr. 195:19-196:2
+7
+
+
+
+45.
+Documents related to or evidencing Jeffrey
+Epstein's donations to law enforcement
+46.
+Victim Notification Letter from US Attorney's
+Office to Victims*
+47. | Expert Dr. L. Dennison
+Report of Victim
+48.
+Palm Beach Police Department Incident Report
+dated 4/20/06
+49.
+| All reports and documentation generated by Palm
+Beach Police Department related to Jeffrey
+Epstein
+50.
+All Witness Statements generated by Palm Beach
+Police Department relating to Jeffrey Epstein
+51.
+| Passenger Manifests of Jeffrey Epstein's aircraft
+and private plane flight logs
+52.
+| Passenger lists for flights taken by Jeffrey Epstein
+53.
+54.
+Letter from Jeffrey Epstein to Alberto Pinto
+regarding house island project
+Jeffrey Epstein's bank statements
+55.
+56.
+3, 4, 7, 8, 10
+3,4,7, 8, 14
+3, 4, 6, 7, 8, 14
+3,4, 7,8
+3, 4, 7, 8, 12
+3, 4, 7, 8, 12
+3, 4, 7, 8, 10, 11,
+12
+3, 4, 7, 8, 10, 11,
+12
+3,4, 7, 8, 10
+3, 4, 7, 8, 12, 14
+3, 4, 7, 8, 12, 14
+3, 4, 7, 8, 12
+57.
+58.
+59.
+Jeffrey Epstein's tax returns
+MC2 emails involving communications of Jeffrey
+Epstein, Jeff Fuller, Maritza Vasquez, Pappas Suat,
+Jean Luc Brunel and Amanda Grant
+DVD of plea and colloquy taken on 6-30-08
+Transcript of plea and colloquy taken on 6-30-08
+Massage Table
+3, 4,8, 12, 13
+3, 4, 13
+3, 4, 12 (document
+marked as No. 59
+is not a massage
+Court's Ruling
+12/5/17 Tr. 196:3-19
+Sustained
+12/5/17 Tr. 196:20-197:2
+Sustained
+12/5/17 Tr. 197:3-23
+Sustained
+12/5/17 Tr. 197:24-198:10
+Sustained
+12/5/17 Tr. 198:13-199:6
+Sustained
+| 12/5/17 Tr. 198:13-199:6
+Sustained
+12/5/17 Tr. 198:13-199:6
+Sustained
+12/5/17 Tr. 199:8
+Sustained
+12/5/17 Tr. 199:9-25
+Sustained
+12/5/17 Tr. 200:1-3
+12/5/17 Tr. 200:1-3
+12/5/17 Tr. 200:4-18
+Not Produced
+Reserved ruling because
+documents not available
+12/5/17 Tr. 200:19-22
+Sustained
+12/5/17 Tr. 200:23-24
+Sustained
+12/5/17 Tr. 200:25-201:21
+Sustained
+* In his December 7, 2017, Second Amended Exhibit List,
+modified this exhibit to include
+additional descriptive language: "(CW & SR) 07/09/2008." The Court finds that this language does
+not substantially change the exhibit and, thus, the Court's ruling holds.
+' In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+exhibit to: "Palm Beach Police Department Incident Report dated 07/25/06 (unredacted)." This Order
+does not make any rulings on the new description and may be subject to a new Motion in Limine as
+Epstein deems appropriate.
+8
+
+
+60.
+61.
+62.
+63.
+64.
+
+No Contact Orders entered against Jeffrey Epstein
+Criminal Score Sheet regarding Jeffrey Epstein
+Documents evidencing Jeffrey Epstein's
+Community Control and Probation
+Jeffrey Epstein's Sex Offender Registrations
+(from various states)
+Jeffrey Epstein's Booking photograph
+65.
+66.
+CAD calls to 358 EL BRILLO WAY, PALM
+BEACH FL 33480
+List of Jeffrey Epstein's House contacts
+67. | Documents related to Jeffrey Epstein's
+investments
+68.
+Letter from Chief Michael Reiter to Barry
+Krischler
+69. List of planes owned by Jeffrey Epstein®
+3,4,13
+3,4, 7, 8, 12
+3, 4, 7,8
+3, 4, 7, 8
+3, 4, 7, 8,
+Jocument say
+annot rely on thi
+for legal action
+3, 4, 7,8
+3, 4, 7,8,12
+(document
+provided is not
+reflective of
+description)
+3,4, 7, 8, 12, 14
+3,4,7,8
+3, 4, 7, 8, 12
+(document
+provided does not
+mascription), 141
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+Court's Ruling
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 202:9-203:4
+12/5/17 Tr. 203:5-204:2
+12/5/17 Tr. 204:3-11
+Sustained
+2/5/17 Tr. 204:12-205:12
+ustaine
+12/5/17 Tr. 205:13-15
+12/5/17 Tr. 205:16-22: 206:2-
+207:14: 209:15-210:5
+Sustained
+12/15/17 Tr. 205:23-25
+TO.
+71.
+72.
+73.
+Letter from Guy Fronstin to Assistant State
+Attorney dated 1-N1-06
+Letter from Guy Fronstin to Assistant State
+Attorney dated 1-13-06
+Letter from Guy Fronstin to Assistant State
+Attoritey dated 2-17-06
+Letter from Guy Fronstin to Assistant State
+Attorney dated 4-6-06
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+• In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+tos no make any ling one he new descripto and may be sule 10 new Motion in timine st
+Epstein deems appropriate.
+
+
+74.
+75.
+76.
+
+Letter from Guy Fronstin to Assistant State
+Attorney dated 4-10-06
+Letter from Goldberger dated 6-22-06
+All subpoenas issued to State Grand Jury
+3, 4,7, 8, 10
+3, 4, 7,8
+3, 4, 7, 8, 13
+77.
+Documents related to the rental of a vehicle for
+3,4, 7, 8,
+locument
+other icemondin
+identified on list
+78.
+Ted's Sheds Documents
+3, 4, 7, 8,
+document
+prodried contains
+identified on list
+79.
+Documents related to property searches of Jeffrey
+3, 4, 7, 8, 14
+Epstein's properties
+80.
+Arrest Warrant of
+3, 4, 7,8
+81.
+| Police report regarding
+picking up
+13,4, 7,8, 10
+82.
+money dated 11-28-04
+List of Trilateral Commission Members of 2003
+3,4, 7,8, 10
+83.
+Alan Dershowitz Letter dated 4-19-06 and Statute
+3, 4, 7, 8, 12
+90.410
+84.
+| Guy Fronstin letter dated 4-17-06
+85.
+Jeffrey Epstein Account Information
+3, 4, 7,8
+3, 4, 7, 8, 12,14
+10
+Court's Ruling
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 209:10-12; 210:6-21
+Sustained
+12/5/17 Tr. 210:22-211:3
+Sustained in part and overruled in
+part. If Edwards had access to
+Iso be relevant to Mr. Epstein'
+tate of mind at the time he file
+12/5/17 Tr. 211:4-22
+Sustained
+12/5/17 Tr. 211:23-25
+Sustained
+12/5/17 Tr. 212:1-4
+12/5/17 Tr. 212:5-7
+Sustained
+12/5/17 Tr. 212:8-15
+Sustained
+12/5/17 Tr. 212:16-213:1
+Sustained
+12/5/17 Tr. 213:2-214:8
+Not Produced
+12/5/17 Tr. 214:9-11
+Sustained
+12/5/17 Tr. 214:12-20
+
+
+
+86.
+Jeffrey Epstein Criminal Closeout Sheet
+87.
+JEGE, Inc. Passenger Manifest
+88.
+Hyperion Air Passenger Manifest
+89.
+Flight information for
+Passenger List Palm Beach flights 2005
+91.
+| Jeffrey Epstein notepad notes.re Maria
+92.
+| Pleadings of Jane Doe 1 and 2 v. US case
+93.
+Jeffrey Epstein 5" Amendment Speech
+94.
+Reiter letter to Krisher dated 5-1-06
+3, 4, 7, 8, 12
+95.
+Police Report dated, I1-28-04
+3, 4, 7, 8,10
+96.
+Victim's school records and transcripts
+3, 4, 7, 8
+97.
+| Victim Notification letter?
+3, 4, 7,8
+98.
+Police report of Juan Alessi theft at Jeffrey
+3, 4, 7, 8, 12
+Epstein's home
+99.
+Victim's Medical Records from Dr. Randee
+3,4, 6, 7,8
+Speciale
+100.
+All surveillance conducted by law enforcement on | 3, 4, 7, 8, 12
+Jeffrey Epstein's home
+101. Emails received from Palm Beach Records related
+3, 4,7,8,12
+to Jeffrey Epstein
+3, 4, 7, 8, 12
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+Court's Ruling
+12/5/17 Tr. 214:21-24
+Sustained
+12/5/17 Tr. 214:25-215:3
+12/5/17 Tr. 214:25-215:3
+12/5/17 Tr. 215:4-5
+3, 4, 7, 8, 10, 11
+12/5/17 Tr. 215:4-5
+Sustained
+3, 4,7, 8, 10, 12
+12/5/17 Tr. 215:6-8
+Sustained
+3, 4, 12 (document
+| 12/5/17 Tr. 215:9-17
+provided is not
+what is identified
+on list), 13
+3,4,12
+12/5/17 Tr. 215:18-20
+Deferred. References to
+deposition excerpts
+not ruled upon fully; subject to
+specific line reference rulings
+which will be subject to a
+separate order
+12/5/17. Tr. 215:21-216:14
+Not produced
+12/5/17 Tr. 216:15-17
+Sustained
+12/5/17 Tr. 216:18-217:8
+Sustained
+12/5/17 Tr. 217:9-10
+Sustained
+12/5/17 Tr. 217:11
+Sustained
+12/5/17 Tr. 217:12
+Sustained
+12/5/17 Tr. 217:13-15
+Sustained
+12/5/17 Tr. 217:16-24
+Sustained
+" In his December 7, 2017, Second Amended Exhibit List,
+modified this exhibit to include
+additional descriptive language: "to
+does not substantially change exhibi and, thus, lie Cours. The Court finds that this language
+
+
+
+102.
+All items listed on the Palm Beach Police Property 3, 4, 7, 8, 12
+Report Lists®
+(items not
+provided)
+103. All copies of convictions related to Jeffrey
+3, 4, 7, 8, 12
+Epstein
+104. Jeffrey Epstein criminal records
+3, 4, 7, 8, 12
+105. All documents produced by Palm Beach Police
+3, 4, 7, 8, 10, 11,
+Recarinent prior to the deposition of Detective
+106. Statements, deposition transcripts, videotaped
+3, 4, 7, 8, 12, 13
+depositions and transcripts taken in connection
+with this and all related cases and exhibits thereto
+107. Any and all expert witness reports and/or records
+3, 4, 7, 8, 12, 13
+generated in preparation for this litigation by any
+party to this cause
+108.
+Demonstrative aids and exhibits including, but
+12
+not limited to, charts, diagrams and models,
+surveys, photographs and similar material
+including blow-ups of the listed items/exhibits
+109.
+reserves all objections to Epstein's
+Exhibits
+110.
+reserves the right to supplement and/ory
+Not an exhibit
+Not an exhibit
+amend his Exhibit List
+111.
+By listing an Exhibit,
+is not waiving his
+Not an exhibit
+right to object to same at trial and does not waive
+their right to amend same.
+112
+All exhibits listed by Epstein subjeet to
+Not an exhibit
+objections.
+113
+All pleadings and attachments in the action under
+3, 4, 7, 8, 12, 13
+the Crime Victims Rights Act prosecuted by
+Edwards on behalf of victims of
+Epstein's criminal molestations.
+Court's Ruling
+12/5/17 Tr. 217:25-218:2
+Sustained
+12/5/17 Tr. 218:3-10
+Sustained
+12/5/17 Tr. 218:12-17
+Sustained
+12/5/17 Tr. 218:18-22
+Sustained
+12/5/17 Tr. 218:22-23
+No ruling; catch all
+Not addressed at hearing; catch
+Not addressed at hearing; catch
+Not an exhibit
+Not an exhibit
+Not an exhibit
+Not addressed at hearing; catch
+all
+114.
+* Motions for Summary Judgment, all
+attachments thereto, and all Undisputed Facts
+3,4, 7, 8, 12, 13
+12/5/17 Tr. 226:15-227:14
+Overruled
+• In his December 7, 2017, Second Amended Exhibit List, [
+modified this exhibit to include
+additional descriptive language: "and/or Property Receipts." The Court finds that this language does
+not substantially change the exhibit and, thus, the Court's ruling holds.
+12
+
+
+
+115.
+All time records and hourly billing documentation
+| 3,4,7,8, 12
+produced in discovery.
+116. All deposition testimony and discovery responses
+by Epstein submitted in this action.
+117. All pleadings filed by Epstein in the Rothstein
+bankruptcy proceeding.
+118. All submissions by Epstein in connection with the
+Rothstein deposition.
+119. All Settlement Agreements between Epstein and
+victims of his sexual molestations.
+120.
+| Phone Journal taken from Epstein's home and
+produced to the FBI by Alfredo Rodriguez
+121. Photo depicting
+Ghislaine
+Maxwell and Prince Andrew
+122. All flight logs for any Epstein owned or
+controlled aircraft
+123.
+All emails produced by Defendant and/or all
+emails produced by Plaintiff in this case
+124.
+Evidence of contributions to the Palm Beach
+Police Dept.
+125. Dr. Bernard J. Jansen Expert Report, Attachments
+and Back-up Documents, October 20.2017
+126.
+Jeffrey Epstein vs. Scott Rothstein,
+and L.M., Complaint, December 7, 2009
+127.
+Jeffrey Epstein vs. Scott Rothstein,
+J.
+J.
+and L.M., Fourth Amended
+Counterclaim, January 9, 2013
+128.
+Jeffrey Epstein vs. Scott Rothstein,
+J.
+and L.M., Plaintiff/Counter-Defendant
+Jeffrey Epstein's Answer and Affirmative
+Defenses to Defendant/Counter-Plaintiff
+Fourth Amended Counterclaim,
+February 21, 2013
+129.
+Jeffrey Epstein vs. Scott Rothstein,
+and L.M., Notice of Voluntary
+130.
+Dismissal, August 16, 2012
+Brad Edward's [sic] Times Records and Billing
+Records related to this matter.
+3, 4, 7, 8, 12, 13
+3,4, 7, 8, 12, 13
+3, 4, 7, 8, 12, 13
+3, 4, 7, 8, 12, 14
+3,4, 7, 8, 11, 14
+(duplicative of
+Exhibit No. 8)
+3, 4,7,8
+3, 4, 7,8, 10, 11,
+3,4, 7, 8, 10, 12
+3, 4, 7, 8, 10
+duplicative of 45
+3, 4, 6, 7, 8, 10,
+11,13
+3, 4, 7, 13
+3, 4, 7, 13
+3, 4,7, 8, 10, 12
+Court's Ruling
+12/5/17 Tr. 227:15-229:17
+Overruled.
+is ordered to
+roduce/cull out within 15 day.
+f the documents have not alread
+been produced
+Not addressed at hearing; catch
+all
+12/5/17 Tr. 229: 18-20
+12/5/17 Tr. 229:21-24
+~ 12/5/17 Tr. 229:25-231:5
+12/5/17 Tr. 231:6-9
+Deferred. Not to be mentioned
+during opening statement.
+12/5/17 Tr. 231:10-18
+Sustained
+12/5/17 Tr. 231:19-20
+Sustained
+Not addressed at hearing
+12/5/17 Tr. 231:21-232:4
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing; no
+objections
+Not specifically addressed at
+hearing but duplicative to Exhibit
+No. 115 and those rulings are
+incorporated herein
+
+
+
+131. Jeffrey Epstein's NY State Online Sex Offender
+Registry Profile
+3,4, 7,8
+132. New York Post article: Billionaire Jeffrey
+3, 4, 7,8
+Epstein: I'm a sex offender, not a predator,
+February 25, 2011
+133. Any and all responses to Subpoenas Duces Tecum
+7 3, 4, 6, 7, 8, 10,
+with or without deposition?
+11, 12, 13, 14
+134.
+All Interrogatories and Answers thereto, Requests
+3, 4, 7, 8, 12, 13
+to Produce and Responses, Requests for
+Admissions and Responses thereto.
+135. Any and all documents produced in this action.
+136. Any and all depositions taken in this action.
+137. Any documents or other exhibit attached to or
+used during any deposition in this action
+138. Any and all exhibits, documents, etc. referred to
+in any deposition
+139.
+Any and all documents and exhibits designated by
+all parties to this action.
+140. Any and all exhibits needed for impeachment or
+rebuttal
+141. Any and all pleadings filed in this action
+12
+12,13
+12,13
+12, 13
+12, 13
+M2
+12,13
+12,13
+142. Any and all records produced or that will be
+produced by all records custodians relative to this
+action
+DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this .
+day of January, 2018
+Court's Ruling
+Not specifically addressed at
+hearing, but deferred with Exhibit
+12/5/17 Tr. 232:5-235:9
+Not addressed at hearing; catch
+Not addressed at hearing; catch
+- Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+16
+THE HONORABLE DONALD
+CIRCUIT COURT JUDGE
+° In his December 7, 2017, Second Amended Exhibit List,
+has shifted Exhibit Nos. 133
+has also identified new exhibits at Exhibit
+14
+
+
+Copies provided to:
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+isx@searcylaw.com
+scarolateam@scarcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Ft. Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT
+Scott J. Link
+Kara Berard Rockenbach
+Angela M. Many
+Link & Rockenbach, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, FL 33401
+Scott@linkrocklaw.com
+Angela@linkrocklaw.com
+Tina@linkrocklaw.com
+Troy@linkrocklaw.com
+Tanya@linkrocklaw.com
+Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.receipt.json b/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cd49889ec5ea1b3a70c910feaf342523d34c85c5
--- /dev/null
+++ b/vision-fixhub/court-02/0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1021,
+  "dataset": "marble-joined",
+  "doc_id": "0138f38eed988e5c1b897c5af15ad58bb27679c092927de35ff4ee178f3d07ad",
+  "engine": "marble-apple-vision",
+  "event_count": 28,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.flight-log-tables.normalize\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "41fc6fbd843ede789ca93293b3870bcbb5b412613c34070449f0ac05dba67ced",
+  "output_sha256": "45bb742f79e3060e01bcad59eb5446ba773bc5aa40c9944ddda0342d73ce4227",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.md b/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.md
new file mode 100644
index 0000000000000000000000000000000000000000..c84cf5e0d25d5acd47dfb7481013693c7955475a
--- /dev/null
+++ b/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.md
@@ -0,0 +1,18 @@
+Case 9:08-cv-80736-KAM Document 357-1 Entered on FLSD Docket 01/29/2016 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+UNITED STATES
+ORDER GRANTING MOTION TO TEMPORARILY SEAL THEIR
+REPLY IN SUPPORT OF MOTION TO COMPEL ANSWERS TO SUPPLEMENTAL
+REQUESTS FOR ADMISSION AND REQUESTS FOR PRODUCTION
+It is hereby ordered that the victims' request is granted. The victims' Reply in Support of
+Motion To Compel will be placed under seal for ten days or until the Court has ruled on any motion
+by any non-party to seal the motion, whichever is longer.
+DONE AND ORDERED in
+at Palm Beach County, Florida, this _
+_ day of
+, 2016.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
diff --git a/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.receipt.json b/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2241be7d2bd604ce27eda7a14781ec4e4218da79
--- /dev/null
+++ b/vision-fixhub/court-02/013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "013f22c0e03bd4eae6cbe6de07632c44850e5a3a527a1290523cdc7177d9bf88",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "ceca388a40bc5a5d67c9b0e693ded70f3ceb6c37f2ec79a1e0dfebf5ab0d8891",
+  "output_sha256": "54415b8e5386b2775588fca50b250409c8354c4b5c85b112c6ff67ec8911f77a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.md b/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.md
new file mode 100644
index 0000000000000000000000000000000000000000..4834e57eeaec10eda43ad469b3e9baa475cca242
--- /dev/null
+++ b/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.md
@@ -0,0 +1,152 @@
+Filing # 75978002 E-Filed 08/03/2018 04:50:14 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually, and
+L.M., individually,
+Defendants).
+ED COPY
+YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the
+following:
+DATE:
+TIME:
+August 15, 2018
+8:45 a.m.
+JUDGE:
+Honorable Donald Hafele
+PLACE:
+205 N. Dixie Highway, West Palm Beach, FL 33401
+ROOM #:
+(10-D
+SPECIFIC MATTERS TO BE HEARD:
+Motion for Clarification of Trial Order
+Movant's attorney has spoken in person or by telephone with the
+attorney(s) for all parties who may be affected by the relief sought in the
+motion in a good faith effort to resolve or narrow the issues raised.
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 08/03/2018 04:50:14 PM ***
+
+
+Movant's attorney has attempted to speak in person or by telephone with
+the attorneys) for all parties who may be affected by the relief sought in
+the motion.
+Dupree are of the parties who may be affected by the motion are self
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this Bea
+day of _AUGUST 2018.
+JACK SCAROLA
+Flories Mail searcylaw.com; and
+NOT A CER
+mmccann@searcylaw.com
+nary
+E-Mail:
+scarolateam
+@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+561-383-9451
+Attorneys for
+2
+
+
+Ladv. Epstein
+COUNSEL LIST
+J.
+, Esquire
+staff.efile@pathtojustice.com
+125 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Philip Burlington, Esquire
+pmb@tlappellatelaw.com;kbt@Flappellatelaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+ERTIFIED COPY
+Jay Howell, Esquire
+jay@jayhowell.com
+Jay Howell & Associates P.A.
+644 Cesery Boulevard, Suite 250
+Jacksonville, FL 32211
+Phone: (904)-680-1234
+Fax: (904)-680-1238
+Attorneys for Bradley J. L
+Paul G. Cassell, Esquire
+paul.cassell@law.utah.edu
+S.J. Quinney College of Law
+383 S University Street
+Salt Lake City, UT 84112
+Phone: (801)-585-5202
+Fax: (801)-581-6897
+Attorneys for
+3
+
+
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Kara Berard Rockenbach, Esquire
+kara@linkrocklaw.com
+Scott J. Link, Esquire
+Scott@linkrocklaw.com; Angela@linkrocklaw
+.com; Troy @link
+COPY
+tina@linkrocklaw.com; rachel@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 930
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+ERTIFIED
+cklaw.com;
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT
+NOT
+4
+
+
+"If you are a person with a disability who needs any accommodation in order to
+participate in this proceeding, you are entitled, at no cost to you, to the provision of
+certain assistance. Please contact Americans with Disabilities Act Coordinator at least
+7 days before your scheduled court appearance, or immediately upon receiving this
+notification if the time before the scheduled appearance is less than 7 days; if you are
+hearing or voice impaired, call 711."
+"Si usted es una persona minusválida que necesita algún acomodamiento para poder
+partiprove est preced. Tental asted tindad deposis ten coates on pie, agus
+with Disabilities Act Coordinator por lo menos 7 días antes de la cita fijada para su
+comparecencia en los tribunales, o inmediatamente después de recibir esta
+notificación si el tiempo antes de la comparecencia que se ha programado es menos
+de 7 días; si usted tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan pwosedi
+sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kèk èd.
+Tanpri kontakte nan 7 jou anvan dat ou gen randevou pou parèt nan tribinal la
+oubyen imedyatman apre ou fin resevwa konvokasyon an si lè ou gen pou w parèt nan
+tribinal la mwens ke 7 jou; si ou gen pwoblèm pou w tande oubyen pale, rele 711."
+Rev: 8/20/15
+NOT A
+5
\ No newline at end of file
diff --git a/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.receipt.json b/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6ee93212f328e0df5489d2f620c90ddba256c097
--- /dev/null
+++ b/vision-fixhub/court-02/01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -310,
+  "dataset": "marble-joined",
+  "doc_id": "01b0edfdfe954412b6fff532564f3208a2df5e1ef172dd33c8790f48c79d9c02",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "7c30d9c410080c8e0654b21603092874b6b4e7da13e62bd02c356eb24fd6b775",
+  "output_sha256": "38e4024f36998fec38a4fcfe626745872fe6cb1bdb633fdc0588b35aedd6fe32",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.md b/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.md
new file mode 100644
index 0000000000000000000000000000000000000000..a3d44ee3b09ed496cea43cdd82cc753c70404110
--- /dev/null
+++ b/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.md
@@ -0,0 +1,24 @@
+Case 9:08-cv-80736-KAM Document 325 Entered on FLSD Docket 04/07/2015 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:08-CV-80736-KAM
+JANE DOE 1 and JANE DOE 2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+SUPPLEMENTAL ORDER
+This cause is before the Court on its Order Denying Petitioners' Motion to Join Under
+Rule 21 and Motion to Amend Under Rule 15. (DE 324). In accordance with the portion of that
+Order striking materials from the record (see id. at 10), the Court informs the parties of the
+following: The affected docket entries (DEs 279, 280, 291-1, 293, and 310-1) shall be restricted
+from public access on the docket in their entities. Docket entries 279 and 293, which were
+stricken in their entirety, shall remain so restricted. Regarding the docket entries of which
+portions were stricken (DEs 280, 291-1, and 310-1), Petitioners may re-file those documents
+omitting the stricken portions. The re-filed documents must conform to the originally filed
+documents in all respects, but with the stricken portions omitted.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 7" day of April, 2015.
+KENNETH A. MARRA
+United States District Court
diff --git a/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.receipt.json b/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f0ff7cade4e1913823e97803cda4f4325e1c61ad
--- /dev/null
+++ b/vision-fixhub/court-02/01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "01b57cc3f310bef160ba3c40d2591d92647d7e28a6173a94476077649c1a0815",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e325f5b8c0632ed2506c93a42eb4a5e36ae80dfc952599f74e3b393c7c360664",
+  "output_sha256": "c801f57c8b2699cfbd6f315816a278b37d852b200e6eef6a74e7d4f4748cbf0b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.md b/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.md
new file mode 100644
index 0000000000000000000000000000000000000000..3f4c73846b8787938c47d01a0063a2870b9d822a
--- /dev/null
+++ b/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.md
@@ -0,0 +1,87 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants).
+2011 MAY 17 PM 4: 00
+NOTICE OF CANCELLATION OF HEARING
+YOU ARE HEREBY NOTIFIED that the hearing scheduled for May 19, 2011 at 9:30
+a.m. on Defendant/Counter Plaintiff,
+Motion to Dismiss is hereby canceled and will be
+rescheduled by the Court at a later date. O
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+U.S. Mail to all Counsel on the attached list, this
+_ day of/May, 2011.
+NOT
+Ka/Carola
+JACK SCAROLA
+Florida Bar No.: 169440
+Searcy Denney Scarola Barnhart & Shipley,
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for Plaintiff(s)
+FIL
+
+
+Case No.: 502009CA040800XXXXMBAG
+Notice of Hearing
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+20 bui ia weseisie esrpa.com
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+, Jaffe, Weissing,
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Attorneys for Jeffrey Epstein
+L. Ackerman, Jr., Esquire
+1, Fistos & Lehrm
+ian,
+PL
+CERTIFIED
+Burnett, P.A.
+901
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561)-802-9044
+Fax: (561)-802-9976
+Attorneys for Jeffrey Epstein
+Marc S. Nurik
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+fort Lauderdale, FL 3330.
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+COPY
+2
+
+
+Case No.: 502009CA040800XXXXMBAG
+Notice of Hearing
+1 Weinberg, Esquire
+| Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Suffolk,
+02116
+Phone:
+Fax:
+Attorneys for Jeffrey Epstein
+NOT A CERTIFIED COPY
+3
diff --git a/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.receipt.json b/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a708fe0ca358fc45b54702e3df5599824e507718
--- /dev/null
+++ b/vision-fixhub/court-02/01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "01be7b73d5abec2ffc2901a0014f5e9ada1faf0fa418e278550fe3b5b26f5e21",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d342f08a8956d9d0e4d031a5f91d32a276a6034b3652965902ec3fc19c64f18a",
+  "output_sha256": "2c610361fd49763c71233376155592c2d955f6da268a861484e8d97201f2c11c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.md b/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.md
new file mode 100644
index 0000000000000000000000000000000000000000..2d8ca3448ff4311badb234f3924a557253077077
--- /dev/null
+++ b/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.md
@@ -0,0 +1,45 @@
+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+Complex Litigation, Fla. R. Civ. Pro. 1201
+Case No. 50 2009CA040800XXXXMB AG
+JEFFREY EPSTEIN,
+Plaintiff,
+v.
+SCOTT ROTHSTEIN, individually,
+individually, and L.M., individually,
+Defendants.
+SUBPOENA FOR DEPOSITION
+COPY
+THE STATE OF FLORIDA:
+TO:
+360. 1
+Mike Fisten
+1403 Saint Gabrielle Lane, Apt. 3211
+Weston, FL 33326-4032
+YOU ARE COMMANDED to appear before a person authorized by -law to take
+depositions at the law offices of
+Burnett, P.A., One Financial Plaza, 100 S.E. Third
+Avenue, 21" Floor, Fort Lauderdale, FL 33394, on the 19th day of January, 2011, at 9:00 a.m.,
+for the taking of your deposition in this action and to have with you at that time and place the
+following:
+If you fail to appear, you may be in contempt of court.
+You are subpoenaed to appear by the following attorney, and unless excused from this
+subpoena by this attorney or the court, you shall respond to this subpoena as directed.
+Dated on December 22, 2010.
+For the Court
+By:
+Joseph E.
+Ack
+Lilly Ann
+Esq.
+L. Ackerman, Jr., Esq.
+Lilly Ann
+, Esq.
+& Burnett, P.A.
+Attorneys for Plaintiff, Jeffrey Epstein
+Espirto Santo Plaza
+1395 Brickell Avenue, 14" Floor
+Miami, FL 33131
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
diff --git a/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.receipt.json b/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..68c62178ab4abfe0849080687d284bf28b6ba205
--- /dev/null
+++ b/vision-fixhub/court-02/01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "01bee12abce56b117baf55e2434c2027ef57c9d5f2fb6afb9df41ea425397e55",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "a7ae9f5fdaf8d05b8350be13d2a5c4364780100aed915550f78a36102a696c06",
+  "output_sha256": "9441b6b3c5c91a81d0203d64397be2e97124ea6576b9ce1994e914411ad051eb",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.md b/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.md
new file mode 100644
index 0000000000000000000000000000000000000000..90eca13a187e990b522ab86ec2b25836161cf002
--- /dev/null
+++ b/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.md
@@ -0,0 +1,108 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN. individually,
+individually, and
+L.M., individually,
+Defendants).
+FILED
+NOTICE OF CANCELLATION OF HEARING
+YOU ARE HEREBY NOTIFIED that the undersigned has cancelled the following
+hearing:
+DATE: Monday, October 22,2012
+TIME:
+8:45 a.m.
+JUDGE:
+Honorable David F. I
+(Palm Beach County Courthouse)
+PLACE:
+205 N. Dixie Highway, West Palm Beach, FL 33401
+ROOM #:
+9-C
+SPECIFIC MATTERS TO BE HEARD:
+Motion to Reschedule Hearing on Motion to Disqualify Opposing Counsel
+
+
+=
+Case No.: 502009CA040800XXXXMBAG
+Notice of Hearing
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached is, this. 1912 day of October 2012.
+JACK SCAROLA
+Finary E-mail: jsx@scarcylaw.com
+econdary E-mail(s): mep@searcylaw.cor
+earcy Denney Scarola Barnhart & Shipley, P.A
+39 Palm Beach Lakes Bouleva
+est Palm Beach. Florida 3340
+(561) 383-9451
+Attorney for
+|J.
+NOT A CER
+NOT A CERT
+2
+
+
+Case No.: 502009CA040800XXXXMBAG
+Notice of Hearing
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+Esquire
+bje.efile@pathtojustice.com;
+staff.efile@pathtojustice.com
+, Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+haddadfim@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612/
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+rax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+CER
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+Lae O rovar Mard Suic 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Lilly Ann
+,, Esquire
+Isanchez@thelsfirm.com
+The L-S Law Firm
+1441 Brickell Avenue, 15th Floor
+Miami, FL 33131
+Phone: (305)-503-5503
+Fax: (305)-503-6801
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+3
diff --git a/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.receipt.json b/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..875741b9ccef5ef1affb592c57900d72c3a6331f
--- /dev/null
+++ b/vision-fixhub/court-02/01da26ababa660adae634cced128545a26bc83f1fe380b15b6eea6140de3b7ee.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.md b/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.md
new file mode 100644
index 0000000000000000000000000000000000000000..520a78380509d8c66546ea440688f36f7cdba5ce
--- /dev/null
+++ b/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.md
@@ -0,0 +1,91 @@
+Filing # 67299650 E-Filed 01/31/2018 11:07:39 AM
+•
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA.
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants/Counter-Plaintiff.
+COPY
+AGREED ORDER GRANTING DEFENDANT/COUNTER-PLAINTIFF
+REQUEST FOR JUDICIAL NOTICE
+THIS CAUSE came before the Court upon Defendant/Counter-Plaintiff
+J.
+J.
+"')December 4, 2017, Request for Judicial Notice Pursuant to Florida Statutes
+Section 90.202 and 90.203. [D.E. 1104]
+The Court, having reviewed the Request,
+Plaintiff/Counter-Defendant Jeffrey Epstein's Response. in Opposition [D.E. 1157], and having
+been advised of the agreement of the parties, it is hereby
+ORDERED AND ADJUDGED that the Request is GRANTED. The Court hereby takes
+judicial notice of the Complaints filed in the twenty-five lawsuits identified in
+Request
+for Judicial Notice for authenticity purposes. The parties' respective rights to raise any other
+objections, încluding admissibility, are hereby preserved and may be raised at trial.
+DONE AND ORDERED in West Palm Beach, Palm Beach Courty, Florida this 30 day
+of January, 2018.
+THE HONORABLE DONALD W. HAFELE
+CIRCUIT COURT JUDGE
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/31/2018 11:07:39 AM
+
+
+Jeffrey Epstein v. Scott Rothstein and
+J.
+15"h Judicial Circuit Case No. 2009CA040800XXXXMBAG
+Agreed Order Granting Defendant/Counter-Plaintiff
+|J.
+Request for Judicial Notice
+Page 2
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+isx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+J
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Ft. Lauderdale, FL 33401
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT
+SERVICE LIST
+Nichole J. Segal
+Courthouse Commons, Suite 350
+144 West Railroad Avenue
+is@FLAppellateLaw.co
+bt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Scott J. Link
+Kara Berard Rockenbach
+Angela M. Many
+Link & Rockenbach, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+Angela@linkrocklaw.com
diff --git a/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.receipt.json b/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..08fa36fe43e1ac242dbed1bc492b0d325a1f2e87
--- /dev/null
+++ b/vision-fixhub/court-02/01e052bbc19592d3c8527790c63cce4f239a30d60fa7787b723d0a2aebc989fd.receipt.json
@@ -0,0 +1,14 @@
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.md b/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.md
new file mode 100644
index 0000000000000000000000000000000000000000..ee347d57b6925fb68a16a19af3b2936c7dda4188
--- /dev/null
+++ b/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.md
@@ -0,0 +1,68 @@
+Case 9:08-cv-80736-KAM Document 361-49 Entered on FLSD Docket 02/10/2016 Page 1 of 3
+
+49
+
+
+Case 9:08-cv-80736-KAM Document 361-49
+Entered on FLSD Docket 02/10/2016 Page 2 of 3
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+99 N.E. 4 Street
+Miami, FL 33/32
+August 3, 2007
+VIA FACSIMILE
+Lilly Ann
+Esq:
+Bumett
+1395 Brickell Ave Fl 14
+Miami Florida 33131-3300
+Re: Jeffrey Epstein
+Dear Lilly:
+Thank you for your letter of August 2id regarding your proposal on how to resolve the
+Epstein matter.
+As we explained at our meeting on July 31, 2007, the Office believes that the federal
+interest will not be vindicated in the absence of a two-year term of state imprisonment for
+Mr. Epstein. That offer was not meant as a starting point for negotiations, it is the minimum
+term of imprisonment that will obviate the need for federal prosecution. The Office has
+never agreed that a state prison sentence is not appropriate for Mr. Epstein. Rather we
+simply stated that if Mr. Epstein preferred to serve his sentence in a federal penetentiary, we
+would be willing to explore a federal conviction that may allow that in lieu of any state
+resolution. Further, as I made clear in our follow up telephone conversation after the
+meeting, a plea to two federal misdemeanors was never extended or meant as an offer.
+We also would reiterate that the agreement to Section 2255 liability applies to all of
+the minor girls identified during the federal investigation, not just the 12 that form the basis
+of an initial planned charging instrument.
+As you know, the ability to engage in flexible plea negotiations is dramatically
+changed upon the return of an indictment. Once an indictment is returned, the Office does
+not intend to file a Superseding Information containing a lesser charge or to dismiss the case
+in favor of state prosecution.
+08-80736-CV-MARRA
+RFP WPB 001479
+
+
+Case 9:08-cv-80736-KAM Document 361-49 Entered on FLSD Docket 02/10/2016 Page 3 of 3
+LILLY ANN SANCHEZ, ESQ.
+AUGUST 3, 2007
+PAGE 2
+Please let us know your client's decision by no later than August 17. I have conferred
+with U.S. Attorney Acosta who has asked me to communicate that the two-year term of
+incarceration is a non-negotiable minimum to vindicate a federal interest, and, at this time,
+he is not inclined to meet with counsel for Mr. Epstein.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+Matthew Menchel
+Chief, Criminal Division
+cc:
+Roy Black
+Gerald B. Lefcourt
+R. Alexander Acosta
+Jeffrey Sloman
+Andrew Lourie
+A.
+Villafaña
+08-80736-CV-MARRA
+RFP WPB 001480
diff --git a/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.receipt.json b/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8f540f15a3d3c08570b92bf668447132ee2d1c86
--- /dev/null
+++ b/vision-fixhub/court-02/02154882e335721bc15d4c376b4eb200b3572ad030997e6b985f13e5e2cd4a46.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "00845c424b95af9cd945948a6ab88642f398113af6abc0f9bed6f43bea5b265a",
+  "output_sha256": "acc329b234ba8bdc812786274e232b4f11f8f84b79aa92abccfa64bee9b252e8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/02387a1f1216abe6a32027ead246f9195669f2d2d6231116164598898a0c3f4b.md b/vision-fixhub/court-02/02387a1f1216abe6a32027ead246f9195669f2d2d6231116164598898a0c3f4b.md
new file mode 100644
index 0000000000000000000000000000000000000000..940b6ce8958f84f6f6e555c521a759a7c367334d
--- /dev/null
+++ b/vision-fixhub/court-02/02387a1f1216abe6a32027ead246f9195669f2d2d6231116164598898a0c3f4b.md
@@ -0,0 +1,181 @@
+CASE NO: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+V.
+SCOTT ROTHSTEIN, individually.
+J.
+I, individually,
+and L.M., individually,
+Defendants.
+DEFENDANT
+Defendant,
+19
+FILED
+MOTION TO APPOINT COMMISSIONER
+files this Motion to Appoint Commissioner and
+states:
+1. Defendant wishes to depose the Records Custodian of The New York Daily
+AUG.
+News around July 3L, 2010 in New York, NY. The deposition duces tecum notice for
+this witness is attached to this Motion.
+2. New York law does not authorize the issuance of a subpoena for the taking
+of a deposition unless a commission has been appointed. Accordingly, the defendant
+moves for the appointment of Metro Attorney Service, Inc., 305 Broadway, 14" Floor,
+New York, NY 10007 as the commissioner to take the deposition duces tecum of the
+Records Custodian of The New York Daily News.
+WHEREFORE, Defendant,
+J.
+Honorable Court grant his Motion to Appoint Commissioner.
+respectfully requests that this
+
+
+CERTICATE OF SERVICE
+I HEREBY CERTIFY that on July 19. 2010 a copy of the foregoing has been
+served via U.S. Mail and email transmittal to all those on the attached service list.
+Jack Scarola
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+West Palm Beach, FL 33409
+(561) 686-6300
+By:
+JACK SCAROLA
+Florida Bar No.: 169440
+SERVICE LIST
+Robert D. Critton, Jr.
+BURMAN, CRITTON, et al.
+303 Banyan Boulevard, Suite 400)
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger et al.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401
+Gary M.
+Jr.
+Farmer Jaffe, Weissing,
+Fistos & Lehrman, P.L.
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+2
+
+
+CASE NO: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+SCOTT ROTHSTEIN, individually.
+J.
+individually,
+and L.M., individually,
+Defendants.
+COPY
+NOTICE OF TAKING DEPOSITION DUCES TECUM
+PLEASE TAKE NOTICE that Defendant,
+deposition duces tecum (See attached Exhibit "A") of:
+will take the
+NAME
+DATE AND
+›TIME
+PLACE OF TAKING DEPOSITON
+Records Custodian
+New York Daily News
+c/o Legal Department
+Attn: Anne Carrol
+450, West 33rd Street
+[New York, NY 10001
+AUGUST 31,2010
+9:00 A.M.
+US Legal Support
+1 Penn PIz, #1410
+New York, NY 10119-1410
+Phone: (212) 759-6014
+upon oral examination before US Legal Support, Notary Public, or any other notary
+public or officer authorized by law to take depositions in the State of New York. The
+oral examination will continue from day to day until completed. The depositions are
+being taken for the purpose of discovery, for use at trial, or for such other purposes as
+are permitted under the Rules of Court.
+
+
+CERTICATE OF SERVICE
+I HEREBY CERTIFY that on July 19! 2010 a copy of the foregoing has been
+served via U.S. Mail and email transmittal to all those on the attached service list.
+Jack Scarola
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+West Palm Beach, FL 33409
+(561) 686-6300
+(561) 684-5816 (fax)
+By:
+JACK SCAROLA
+Florida
+Bar No: 169440
+CC:
+US Legal (via email)
+SERVICE LIST
+Robert D. Critton, Jr.
+BURMAN, CRITTON, et al.
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger et al.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401
+Gary M.
+Jr.
+Jaffe, Weissing,
+,. Fistos & Lehrman, P.L.
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+2
+
+
+•
+Exhibit "A" - DUCES TECUM
+All taped conversations between
+Rush and Jeffrey Epstein, including
+telephone recordings, all emails to and from Jeffrey Epstein or someone
+representing themselves to be Jeffrey Epstein.
+minute taped conversation that has already been identified between
+and Jeffrey Epstein as well as the transcript of that tape.
+NOT A CERTIFIED COPY
+3
+
+
+CASE NO: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+SCOTT ROTHSTEIN, individually.
+IJ.L
+individually,
+and L.M., individually,
+Defendants.
+SUBPOENA DUCES TECUM FOR DEPOSITION
+COPY
+THE STATE OF FLORIDA
+TO: Records Custodian
+New York Daily News, c/o Legal Department
+Attn: Anne Carrol
+450, West 33rd Street
+New York, NY 10001
+York, NY 10119-1410, on July 8/3L 2010 @
+_ a.m., and to have with you at that
+time and place the following:
+All taped conversations between
+Rush and Jeffrey Epstein, including
+telephone recordings, all emails to and from Jeffrey Epstein or someone representing
+themselves to be Jeffrey Epstein. This request includes the 22 minute taped
+conversation that has already been identified between
+Rush and Jeffrey
+Epstein as well as the transcript of that tape.
+If you fail to appear, you may be in contempt of court.
+You are subpoenaed by the attorney whose name appears on this subpoena and
+unless excused from this subpoena by the attorney or the Court, you shall respond to this
+subpoena as directed.
+Dated July
+19T2
+_, 2010
+Delance
+FOR THE COURT
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+West Palm Beach, FL 33409
+(561) 686-6300
\ No newline at end of file
diff --git a/vision-fixhub/court-02/02387a1f1216abe6a32027ead246f9195669f2d2d6231116164598898a0c3f4b.receipt.json b/vision-fixhub/court-02/02387a1f1216abe6a32027ead246f9195669f2d2d6231116164598898a0c3f4b.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b7c7cde6ceefed7d1f0bd2047c1a78886904c368
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@@ -0,0 +1,14 @@
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/025a3a575fbbb99558e36e051bff03e6dcb06f4b37291abf5a62fa82b35434ac.md b/vision-fixhub/court-02/025a3a575fbbb99558e36e051bff03e6dcb06f4b37291abf5a62fa82b35434ac.md
new file mode 100644
index 0000000000000000000000000000000000000000..16d2df23d6f2e995c039fb962165277d5870097b
--- /dev/null
+++ b/vision-fixhub/court-02/025a3a575fbbb99558e36e051bff03e6dcb06f4b37291abf5a62fa82b35434ac.md
@@ -0,0 +1,29 @@
+*** FILED: PALM BEACH COUNTY, FL SHARON BOCK, CLERK. ***
+Electronically Filed 06/24/2013 02:56:26 PM ET
+JEFFREY EPSTEIN,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+CASE NO. 502009CA040800XXXXMBAG
+VS.
+SCOTT ROTHSTEIN, individually,
+Individually, and L.M., individually.
+Defendants.
+TRIAL EXIBIT AND WITNESS LIST
+Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned
+counsel, hereby certifies that the original list of trial exhibits, trial witnesses, and expert
+witnesses pursuant to the Court's Order date April 2, 2013 was served upon
+Defendant/Counter-Plaintiff via electronie service this June 24, 2013.
+NOT A
+Is/ Tonja Haddad Coleman
+Tonja Haddad Coleman, Esq.
+Fla. Bar No.: 0176737
+LAW OFFICES OF TONJA HADDAD, PA
+315 SE 7* Street
+Suite 301
+Fort Lauderdale, Florida 33301
+954.467.1223
+954.337.3716 (facsimile)
+Tonja@tonjahaddad.com
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@@ -0,0 +1,413 @@
+Filing # 69604444 E-Filed 03/21/2018 02:34:20 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+OBJECTION TO UNILATERAL SETTING OF MARCH 22, 2018
+UMC HEARING
+Plaintiff/Counter-Defendant Jeffrey Ep
+("Epstein") objects to the unilateral setting of
+the March 22, 2018, UMC hearing by Defendant/Counter-Plaintiff
+J.
+"), and brings this matter to the Court's attention pursuant to The Florida Bar's
+Professionalism Expectations (Professionalism Expectations") and the Palm Beach County Bar
+Association's Standards of Professional Courtesy and Civility ("Standards"), and states:
+BACKGROUND
+On March 20, 2018, at 3:50 p.m., the Fourth District Court of Appeal granted
+motion to lift the stay of this case, in part.
+On March 20, 2018, at 4:48 p.m.,
+counsel, David P. Vitale, Jr., of the
+Searcy Denny law firm, requested undersigned counsel's availability on Thursday, March 22,
+2018, for a status conference UMC hearing.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/21/2018 02:34:20 PM
+
+
+3.
+Undersigned counsel promptly responded and advised that they had a conflict on
+March 22, 2018. Counsel thereafter agreed to schedule a UMC hearing on Monday, March 26,
+2018.
+On March 20, 2018, at 5:47 p.m.,
+counsel filed a Motion for Status
+Conference and a Notice of Hearing, setting the Motion for UMC hearing on March 26, 2018, as
+agreed.
+5.
+On March 21, 2018, at 5:21 a.m., Jack Scarola of the Searcy Denny law firm
+demanded to know the basis for unsigned counsel's unavailability on March 22, 2018, stating,
+"In the absence of a reasonable explanation for the delay, I intend to appear before Hafele
+tomorrow to address the rescheduling of pretrial issues and trial."
+6.
+Although not required to provide such a detailed explanation, undersigned
+counsel, in the spirit of professionalism and the conduet expected of both counsel set out in the
+Standards, advised Mr. Scarola of the conflict (out-of-town travel). A copy of the e-mail
+exchange starting with Mr. Vitale's request is attached as Exhibit A.
+Mr. Scarola refused to accept undersigned counsel's representations and instead,
+unilaterally re-noticed the hearing for March 22, 2018, knowing undersigned counsel is not
+available.
+ARGUMENT
+At our statewide level, Professionalism Expectation 6.6 requires Epstein's counsel to
+present this objection and promptly call this scheduling problem to the Court's attention:
+A lawyer should promptly call potential scheduling conflicts or
+problems to the attention of those affected, including the court or
+tribunal.
+2
+
+
+Epstein's counsel fully complied with Professionalism Expectation 6.5 which requires an
+attorney to "promptly agree to a proposed time for a hearing, deposition, meeting or other
+proceeding or make his or her own counter proposal of time.
+Despite Epstein's counsel's efforts and offer of the very next uniform motion calendar
+date held by this Court,
+failed to comply with Professionalism Expectation 6.4:
+A lawyer should accede to all reasonable requests for scheduling.
+rescheduling, cancellations, extensions, and postponements that do
+not prejudice the client's opportunity for full, fair, and prompt
+adjudication.
+Even more close to home, Local Rule 4 requires a Notice of Hearing be served "pursuant
+to the applicable rules of procedure, and the Standards of Professional Courtesy and Civility
+("Standards"), which have been endorsed by the judges of the Fifteenth Judicial Circuit." Those
+Standards provide:
+I. Scheduling
+the reced pete, anger one or potion, enge and
+emergency,.
+echedeing. As a general de amstanes shoell be give eat died
+for hearings.
+2. Attorneys should communicate with opposing counsel prior to
+scheduling depositions, hearings and other proceedings, so as to
+schedule them at times that are mutually convenient for all
+Interested persons. Further, sufficient time should be reserved to
+permit a complete presentation by counsel for all parties. Upon
+receiving an inquiry concerning a proposed time for a hearing,
+deposition, meeting or other proceeding, a lawyer should promptly
+agree to the proposal or offer a counter suggestion that is as close in
+time as is reasonably available, and attorneys should cooperate with
+each other when conflicts and calendar changes are reasonably
+necessary. Only after making a reasonable effort to confer with
+opposing counsel
+should
+attorneys unilaterally schedule
+depositions, hearings or other matters.
+(Emphasis added.)
+3
+
+
+Furthermore, Florida Rule of Civil Procedure 1.090(d) provides, "A copy of any written
+motion which may not be heard ex parte and a copy of the notice of hearing thereof shall be
+served a reasonable time before the time specified for the hearing." (Emphasis added.)
+Undersigned counsel was readily willing to professionally forego the five-business-day
+notice requirements of the Standards and agreed to set the status conference on Monday, March
+26, 2018 - two-business days after the Thursday, March 22, 2018, date initially proposed by
+counsel.
+counsel agreed to the March 26, 2018, date as well, and then aboutfaced and demanded that the hearing be held on March 22, 2018.
+There is no emergency that requires that the hearing be held on March 22, 2018, and
+will not be prejudiced by a two-business day delay. Epstein, on the other hand, will be
+prejudiced if the Court goes forward with the hearing without representation by counsel, who
+will be out of the state. Undersigned counsel was prompt in responding to requests for hearing
+time, and the hearing was initially set on an agreed-upon date on the Court's following motion
+calendar date, Monday, March 26, 2018, ›Edwards' counsel, on the other hand, has acted in
+violation of the Professionalism Expectations identified above, the Standards of Professional
+Courtesy and Civility, Local Rule 4, and the Florida Rules of Civil Procedure by unilaterally
+setting the hearing on a date Epstein's counsel is not available.
+Furthermore,
+counsel stated that one of the purposes of the status conference is
+to address rescheduling of pretrial issues and trial, however the trial setting has not been resolved
+by the Fourth District Court of Appeal and such a request is improper and in violation of the
+Fourth District Court of Appeal's Order.
+Accordingly, Epstein respectfully requests that the March 22, 2018, UMC hearing be
+cancelled and rescheduled to Monday, March 26, 2018.
+4
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on March 21, 2018, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax],
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+ara Berard Rockenbach (FBN 44903
+achel J. Glasser (FBN 577251
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Rachel@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT A CER
+5
+
+
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+mep@searcylaw.com
+isx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+SERVICE LIST
+Philip M. Burlington
+burlington & Rockenbach, P.A
+Courthouse Commons, Suite 35
+44 West Railroad Avenu
+Vest Palm Beach, FL 3340
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Dauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.edu
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+Jay Howell
+Jay Howell & Associates
+and Jane Doe
+6
+
+
+COPY
+
+NOT A CERTIF
+
+
+Tina L.
+From:
+Sent:
+To:
+Cc:
+Subject:
+Scott j. Link
+Wednesday, March 21, 2018 10:06 AM
+Jack Scarola.
+Tina L.
+: Phil Burlington; Paul Cassell; njs@flappellatelaw.com; Mary McCann;
+Kimberly Marsh; Karen E. Terry; Kara Berard Rockenbach;
+Ackerman;
+jay@jayhowell.com; David P. Vitale Jr.; Chris R. Rodgers; brittany@epllc.com;
+brad@epllc.com
+Re: Regarding: L
+_adv: Epstein (File #: 291874)
+Jack I thought we all agreed to reset. Your request is inconsistent with the standards of professionalism. I take it from
+now on we will just challenge each other when we say were unavailable. Kara and I will be in New York. I will see you on
+Monday
+Scott J. Link
+Board Certified Business Litigation
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+office (561) 727-3600 | fax (561) 727-3601 | Email: scott@linkrocklaw.com
+LR
+LINK&
+ROCKENBACH, PA
+CIVIL TRIAL & APPELLATE LAW
+This e-mail may contain privileged or confidential
+information. If it is not meant for you, please
+delete it and notify us immediately. Please
+confirm receipt of time sensitive communications because email deliveries may be
+delayed or unsuccessful. We do not provide tax advice. Our communications may
+not be relied upon to avoid penalties that may be imposed by the Internal Revenue
+Service.
+On Mar 21, 2018, at 5:21 AM, Jack Scarola </SX@SearcyLaw.com> wrote:
+Please inform me of the basis for the unavailability of any of Epstein's lawyers to attend either in person
+or by telephone a simple status conference tomorrow. In the absence of a reasonable explanation fo
+delay, I intend to appear before Hafele tomorrow to address the rescheduling of pretrial issues anc
+trial.
+Every additional day of delay stands the obvious chance of further prejudicing our client.
+On Mar 20, 2018, at 5:03 PM, David P. Vitale Jr. <dvitale@searcylaw.com> wrote:
+Mary.- Please set the Motion for Status Conference for UMC on Monday.
+David P. Vitale Jr., Esq.
+1.
+
+
+Searcy Denney Scarola Barnhart and Shipley, P.A.
+Office: 561-686-6300
+Cell: 561-613-9368
+Fax: 561-383-9465
+dvitale@searcylaw.com
+www.searcylaw.com
+<image001.jpg>
+From: Scott J. Link [mailto:Scott@linkrocklaw.com]
+Sent: March 20, 2018 5:00 PM
+To: David P. Vitale Jr. <dvitale@searcylaw.com>
+Cc: Kara Berard Rockenbach <Kara@linkrocklaw.com>; Tina L.
+<Tina@linkrocklaw.com>:
+Kimberly Marsh <kmarsh@searcylaw.com>; Mary McCann <mmccann@Searcylaw.com>; Jack Scarola
+<JSX@SearcyLaw.com>; Chris R. Rodgers <crodgers@SearcyLaw.com>; Karen E. Terry
+<KET@SearcyLaw.com>
+Subject: Re: Regarding:
+adv. Epstein (File #: 291874)
+I can make that work. Go ahead notice it. Thank you
+Scott J. Link
+Board Certified Business Litigation
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+office (561) 727-3600 | fax (561) 727-3601 |
+Email: scott@linkrocklaw.com
+Y
+<image003.jPg>
+This e-mail may contain privileged or confidential information. If it is not
+meant for you, please delete it and notify us immediately. Please confirm
+receipt of time sensitive communications because email deliveries may
+be delayed or unsuccessful. We do not provide tax advice. Our
+communications may not be relied upon to avoid penalties that may be
+imposed by the Internal Revenue Service.
+On Mar 20, 2018, at 4:54 PM, David P. Vitale Jr. <dvitale@searcylaw.com> wrote:
+Okay. How about Monday?
+David P. Vitale Jr., Esq.
+Searcy Denney Scarola. Barnhart and Shipley, P.A.
+2
+
+
+Office: 561-686-6300
+Cell: 561-613-9368
+Fax: 561-383-9465
+dvitale@searcylaw.com
+www.searcylaw.com
+<image001.jpg>
+From: Scott J. Link [mailto:Scott@linkrocklaw.com]
+Sent: March 20, 2018 4:53 PM
+To: David P. Vitale Jr. <dvitale@searcylaw.com>
+Cc: Kara Berard Rockenbach < Kara@linkrocklaw.com>; Tina L:
+<Tina@linkrocklaw.com>; Kimberly Marsh <kmarsh@searcylaw.com>; Mary McCann
+<mmccann@Searcylaw.com>; Jack Scarola <JSX@SearcyLaw.com>; Chris R. Rodgers
+<crodgers@SearcyLaw.com>: Karen E. Terry <KET@SearcyLaw.com>
+Subject: Re: Regarding: |
+adv. Epstein (File #: 291874)
+Yes David that's what it means.
+Scott J. Link
+Board Certified Business Litigation
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL: 33401
+office (561) 727-3600 | fax (561) 727-3601 |
+Email: scott@linkrocklaw.com
+<image003.jpg>
+This e-mail may contain privileged or confidential information.
+If it is not meant for you, please delete it and notify us
+immediately. Please confirm receipt of time sensitive
+communications because email deliveries may be delayed or
+unsuccessful. We do not provide tax advice. Our
+communications may not be relied upon to avoid penalties
+that may be imposed by the Internal Revenue Service.
+On Mar 20, 2018, at 4:52 PM, David P. Vitale Jr. <dvitale@searcylaw.com> wrote:
+Sorry, but does that mean that neither you or Kara are available for
+hearing on Thursday?
+David P. Vitale Jr., Esq.
+Searcy Denney Scarola Barnhart and Shipley, P.A.
+Office: 561-686-6300
+
+
+Cell: 561-613-9368
+Fax: 561-383-9465
+dvitale@searcylaw.com
+www.searcylaw.com
+<image001.jpg>
+From: Scott J. Link [mailto:Scott@linkrocklaw.com]
+Sent: March 20, 2018 4:50 PM
+To: David P. Vitale Jr. <dvitale@searcylaw.com>
+Cc: Kara Berard Rockenbach <Kara@linkrocklaw.com>; Tina L.
+<Tina@linkrocklaw.com>; Kimberly Marsh <kmarsh@searcylaw.com>;
+Mary McCann <mmccann@Searcylaw.com>; Jack Scarola
+<JSX@SearcyLaw.com>; Chris R. Rodgers < crodgers@SearcyLaw.com>;
+Karen E. Terry <KET@SearcyLaw.com>
+Subject: Re: Regarding:
+adv. Epstein (File #: 291874)
+David this Thursday isn't going to work what availability do you have for
+early next week? Scott
+Scott J. Link
+Board Certified Business Litigation
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+office (561) 727-3600 | fax (561) 727-3601 |
+Email: scott@linkrocklaw.com
+<image003.jpg>
+This e-mail may contain privileged or confidential
+information. If it is not meant for you, please
+delete it and notify us immediately. Please confirm
+receipt of time sensitive communications because
+email deliveries may be delayed or unsuccessful.
+We do not provide tax advice. Our
+communications may not be relied upon to avoid
+penalties that may be imposed by the Internal
+Revenue Service.
+On Mar 20, 2018, at 4:48 PM, David P. Vitale jr.
+<dvitale@searcylaw.com> wrote:
+Scott/Kara,
+4.
+
+
+Thank you,
+David
+David P. Vitale Jr., Esq.
+Searcy Denney Scarola Barnhart and Shipley, P.A.
+Office: 561-686-6300
+Cell: 561-613-9368
+. Fax: 561-383-9465
+dvitale@searcylaw.com
+www.searcylaw.com
+<image001.jpg?
+****************************
+*****************
+***
+OPY
+| Privileged and Confidential | Electronic
+communication is not a secure mode of communication
+and may be accessed by unauthorized persons. This
+communication originates from the law firm of Searcy
+Denney Scarola Barnhart & Shipley, P.A. and is
+protected under the Electronic Communication Privacy
+Act, 18 U.S.C. S2510-2521. The information contained in
+this E-mail message is privileged and confidential under
+Fla. R. Jud. Admin. 2,420 and information intended only
+for the use of the individual(s) named above. If the
+reader of this message is not the intended recipient,
+you are hereby notified that any dissemination,
+distribution, or copy of this communication is strictly
+prohibited. Personal messages express views solely ofthe sender and shall not be attributed to the law firm. If
+you received this communication in error, please notify
+NO:
+the sender immediately by e-mail or by telephone at
+(800) 780-8607 and destroy all copies of the original
+message. Thank you.
+*******************************************
+*****************************
+5
\ No newline at end of file
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diff --git a/vision-fixhub/court-02/029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d.md b/vision-fixhub/court-02/029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d.md
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@@ -0,0 +1,1182 @@
+20094A040800
+Electronically Filed 10/02/2013 11:09:05 AM ET
+38.
+The scheme was predicated on the Principal Conspirators self-professed pipeline
+of pre-suit, confidential settlement agreements as the "preeminent sexual harassment and labor
+employment law firm in the country." Investors were told that the Principal Conspirators had an
+extensive in-house private investigative team, including former F.B.I. and C.I.A. agents, whose
+singular task was to obtain compromising evidence against high-profile putative defendants.
+Rothstein's story was that the evidence and surveillance acquired, often supporting civil causes
+of action ranging from sexual harassment to mass tort cover-ups to whistle-blower claims, was
+presented to the putative defendant who was then offered an opportunity to avoid litigation and
+the negative publicity associated therewith by agreeing to resolve the matter voluntarily by and
+through a confidential settlement with the putative plaintiff.
+Once the putative defendant agreed, the confidential settlement always included
+two main ingredients: (1) that structured payments to a putative plaintiff be made over time,
+generally a three to nine month time period; and (2) that the putative defendant would fund the
+entire settlement up front to be held in RRA's TD Bank trust account and disbursed to the
+putative plaintiff in accordance with the terms of the confidential settlement agreement.
+The Pitch
+40.
+Roth
+informed investors that the putative plaintiffs did not want to wait for
+the structured monthly payouts and would agree to assign their rights to the structured payout for
+a lump-sum payment typically at a discount in the range of 20-40% of the settlements' facevalue. _Rothstein always had a plethora of plausible explanations as to why a putative plaintiff
+wanted their money now and simply could not wait for the structured monthly payments.
+
+
+
+41.
+Rothstein claimed to want nothing from the deal and was only presenting the
+"opportunity" for a putative plaintiff's benefit and to facilitate recovery of RRA's contingent fee.
+Notwithstanding, Rothstein would often boast that if not for his professional and legal conflicts
+he would be the one purchasing these assignments.
+As a means to induce investor action, Rothstein would show investors the
+purported settlement agreement in an attempt to substantiate the deal; however, because the
+settlements were pre-suit and confidential, the names of the putative plaintiffs and putative
+defendants were redacted.
+43. Additionally, the Principal Conspirators would provide: (1) confirmation of
+RRA's trust account balance at TD Bank evidencing the putative defendants fully funded
+settlement proceeds; (2) a "lock letter", drafted and executed by a TD Bank executive,
+irrevocably confirming that the respective settlement proceeds in RA's trust account could only
+be paid directly to the investor's designated account which, in most cases, was an account at TD
+Bank; and (3) opportunițies for an independent third-party verifier to authenticate the underlying
+settlement, assignment and funding of settlement proceeds.
+44. Notably, Rothstein was hyper-vigilant regarding access to RRA accounts under
+the guise of confidentiality. In fact, potential investors could only access TD Bank account
+information in one of two ways. Either Rothstein would invite the investor to his office to view
+the online balance provided by himself or Stay' or, he would "authorize" TD Bank to provide
+copies of account statements and wire transfers prepared and delivered by TD Bank executives
+See Exhibit "W" infra, which is an October 6, 2009 on-line screen shot of RRA's TD Bank accounts
+accessed (logged in) by Irene Shannon which is Irene Stay's maiden name. (Welcome, Irene
+Shannon! You last logged in on Tuesday, October 06, 2009 4:37 PM.")
+
+
+
+: 5 ...
+Spinosa, Kerstetter and Caretsky. On numerous occasions, TD Bank vice-president Spinosa,
+assistant manager Kerstetter, and assistant vice president Caretsky, physically handed the trust
+account statement to Rothstein in the immediate presence of an investor.
+As the final piece to persuade an investment, Rothstein would offer to personally
+guaranty the transaction. This personal guaranty, secured by the significant assets (as discussed;
+supra), was a vital component which tacitly lent credibility and security to the transaction.
+Once an investor was interested, the Principal Conspirators, in conjunction with
+Boden, drafted an agreement for the assignment of the settlement agreement and proceeds.
+47. Upon execution of the assignment, the inyestor would wire transfer to RRA's
+rus accouni the lump sum payment for immediac disurement io the puaiv plainit.
+Thereafter, RRA was obligated to make payment from the funds previously verified and held in
+RRA's trust account at TD Bank directly to the investor's lock letter trust account at TD Bank in
+strict accordance with the terms of the purported settlement agreement.
+NOT A
+
+
+
+"i"
+Case No.: 09-062943 (12)
+Ponzi Scheme In Action
+Fabricated Settlements Premised on Real Cases
+48.
+In certain instances, the purported settlements, albeit fraudulent, were based on
+actual cases being handled by RRA. For example, one of the settlements involved herein was
+based upon facts surrounding Jeffrey Epstein, the infamous billionaire financier. In fact, RRA
+did have inside information due to its representation of one of Epstein's alleged victims in a civil
+case styled Jane Doe v. Jeffrey Esprein, pending in the Southern District of Florida.
+Representatives of D3 were offered "the opportunity" to invest in a pre-suit $30,000,000.00,
+court settlement against Epstein arising from the same set of operative facts as the Jane Doe
+case, but involving a different underage female plaintiff. See e-mail dated October 6, 2009
+referencing Epstein which is attached hereto and incorporate herein as Exhiblt "B." To augment
+his concocted story Rothstein invited D3 to his office to view the thirteen banker's boxes of
+actual case files in Jane Doe in order to demonstrate that the claims against Epstein were
+legitimate and that the evidence against Epstein was real. In particular, Rothstein claimed that
+his investigative team discovered that there were high-profile witnesses onboard Epstein's
+private jet where some of the alleged sexual assaults took place and showed D3 copies of a flight
+log purportedly containing names of celebrities, dignitaries and international figures. Because of
+these potentially explosive facts, putative defendant Epstein had allegedly offered
+$200,000,000.00 for settlement of the claims held by various young women who were his
+victims. Adding fuel to the fire, the investigative team representative privately told a D3
+representative that they found three additional claimants which Rothstein did not yet know about.
+
+
+
+Further, Preve was present for this meeting, despite the fact that he was not involved as an
+investor or representative in the D3 deal.
+49. Additionally, Rothstein used RRA's representation in the Epstein case to pursue
+issues and evidence unrelated to the underlying litigation but which was potentially beneficial to
+lure investors into the Ponzi scheme. For instance, RRA relentlessly pursued flight data and
+passenger manifests regarding flights Epstein took with other famous individuals knowing full
+well that no under age women were on board and no illicit activities took place. RRA also
+inappropriately attempted to take the depositions of these celebrities in a deliberate effort to
+bolster Rothstein's lies.
+50.
+Conspicuously, and contrary l0 Banyon's allegations", Preve and Szafraniski
+shared an office at RRA one floor down from Rotstein providing them access to Rothstein to
+assist in the furthcrance of the Ponzi scheme. This fact helps explain why Preve attended the
+aforementioned D3 meeting despite his lack of involvement as an investor or representative..
+5l.
+Another actual case which Rothstein attempted to use as a false predicate for his
+scheme was a mass tort case against Chiquita Brands International. In this instance, Rothstein
+claimed to be representing plaintiffs in 450 wrongful death cases on the verge of settling for
+$2,000,000.00 cach._Rothstein told investors to begin raising funds in order to purchase this
+settlement. See e-mail dated October 14, 2009 referencing Chiquita which is attached hereto and
+incorporated herein as Exhibit "C." While the cases against Chiquita are real, Rothstein did not
+represent any of the plaintiffs and the cases remain pending.
+* In a November 23, 2009, "Confidential Update From Banyon", Levin erroneously alleges that The
+allegation that Mr. Preve had an office at the Rothstein law firm, or that
+have helped the Rothstein
+firm to mislead potential investors is a total lie. Period."
+
+
+
+Plaintiffs' Investments:
+1. Banyon Income Fund
+52.
+BIF was formed in May 2009, and served as an original feeder fund for. the
+Principal Conspirators settlement deals.
+53.
+According to the offering materials provided by Levin and Preve, BIE's stated
+investment goal was to purchase:
+discount settlements and related periodic revenue stream
+from individual plaintiffs who have settled their labor. and
+employment related lawsuits or claims, and who would
+otherwise receive their settlement amounts over a period of
+time. The purchased settlements are secured by the full
+settlement amounts which will have been deposited in a
+trust account established by the plaintiff's attorney for the
+benefit of the plaintiff prior to purchase by Banyon Income
+Fund, LP.
+These settlements are released to Banyon
+Income Fund, LP over time to liquidate the purchased
+settlement.
+See Confidential Offering Memorandum dated April 30, 2009, a copy of which is attached hereto
+and incorporated herein as Composite Exhibit "D."
+54.
+Not coincidentally, BIF's investment strategy is identical to the purported
+investment vehicle offered by the Principal Conspirators at the center of the Ponzi scheme.
+55.
+In fact, the Confidential Offering Memorandum avers that once a structure of
+formal documentation was put in place and a relationship established with Rothstein, the General
+Partner was able to achieve a large ramp up in business volume,. /which| have stabilized at
+approximately $60,000,000 - $75,000,000 in funded business per month," and that the "Iflunding
+for these activities has come from credit facilities with institutional hedge fund lenders as well as
+the personal capital of Mr. Levin." Id.
+
+
+
+56. Significantly, Banyon's Confidential Offering Memorandum relies heavily upon an
+audited financial statement prepared by Berenfeld which purportedly details Banyon's staggering
+growth and astounding returns verifying, inter alia, that:
+a. Levin, by and through Banyon affiliated companies, was doing as much as
+$75,000,000.00 in business a month with Rothstein;
+b. Through March 2009, Banyon affiliated companies purchased over S1.1
+billion dollars worth of legal settlements front Rothstein for a cost of
+$657,000,000.00;
+c.
+By the end of March 2009, the Banyon affiliated companies had realized
+over $531,000,000.00 million in returns; and
+d.
+Banyon affiliated companies
+listed receivables in excess of
+$559,000,000.00 from pending settlements investments.
+See id,
+57.
+BIF's Confidential Offering Memorandum provided investors a window into the
+Principal Conspirators' house of cards, as the hedge fund was just one of the investment
+consortiums feeding the Ponzi scheme's voracious appetite.
+58.
+All or substantially all of BF's assets were funneled into the Principal
+Conspirators scheme which served as rocket fuel blasting the obscure investment vehicle to
+dizzying heights.
+
+
+
+., 70 .
+In the spring of 2009, Barry Bekkedam from Ballamor Capital Management, LLC
+(hereinafter, "Ballamor") and promoter of BIF, met Doug Von. Allmen (D&L Partners) to
+discuss D&L Partners" participation in BIF.
+60.
+During that discussion, Mr. Von Allmen learned that BIF was started by Levin, a
+professed mentor and confidant of Rothstein, and that the settlements BIF was purchasing were
+through an exclusive arrangement negotiated between Rothstein and Levin on behalf of BIF.
+61. Mr. Von Allmen was told by Mr. Bekkedam that Levin was personally worth in
+excess of $400,000,000.00 and would personally guarantee the settlements.
+62. Additionally, Mr. Bekkedam told Mr. Von Allmen that, the settlements were
+already fully-funded in the attorneys" trust accounts, that a "Big Four'' auditing firm would
+verify them quarterly, and that Ballamor had continuous unfettered access to the trust account
+balances and would oversce Banyon's hiring of an independent verifier to monitor and confirm
+the settlement transaction.
+63.
+Finally, Mr. Von Allmen was told by Mr. Bekkedam that it would take two
+signatures to move the money, one of which would be someone from BIF.
+64.
+In reliance on these purported security and verification procedures, on or about
+May 4, 2009, Mr. Von Allmen (through D&L, Partners) and his wife Linda Von Allmen (through
+Dynasty Trust) first wired BIF funds; approximately one month later, his son and daughter-in-law
+David and Ann Von Allmen. (through the DVA Trust and AVA Trust) and his step-son;
+' Ballamor Capital Management, LLC is an S.E.C. registered investment advisor specializing in managing
+investments on behalf of high and ultra-high net worth individuals
+"As it tums out, the "Big Four" accounting firm referenced was Berenfeld
+
+
+
+Kretschmar (collectively referred to herein as "Banyon Investors") also funded investments as
+directed by Ballamor and Mr. Bekkedam.
+65. Prior to investing, each Banyon Investor received a "the aforementioned
+Confidential Offering Memorandum describing the terms and conditions of the investment structure
+in greater detail. See Composite Exhibit "D."
+66.
+Significantly, the Confidential Offering Memorandum provided that a receipt of the
+putative defendant's wire transfer of the full settlement proceeds into RRA's trust account would be
+verified by an independent third party (sce Szafranski, infra). Id.
+67. Additionally, the Banyon Investors were assured that in cooperation with TD Bank
+executives (which turned out to be Spinosa, Kerstetter and Caretsky), that BIF's third-party verifier
+would have online access to banking records for each deposit account and admission into all records
+related to the purchased settlements and settlement trust accounts. Id.
+68.
+Furthermore, the Memorandum states that while "Ballamor will receive no
+compensation for its participation or investment recommendation.
+Levin has an
+agreement in principle with Ballamor and its principal, Barry R. Bekkedam, with respect to an
+equity investment in Ballamor by Mr. Levin and a loan 1o Mr. Bekkedam, the final terms of
+which have not been determined," Id.
+69.
+Szafranski, president of Onyx Capital Management, acted as an the designated
+independent, third-party verifier for the Banyon Investors and BIF. Prior to and during the course of
+In fact we now know that Ballamor and Mr. Bekkedam received $5,000,000.00 from Levin for their
+involvement in this Ponzi scheme along with a $18,000,000.00 investment through Ballamor into Nova
+Bank, a Pennsylvania bank.
+
+
+
+Amerided Complaint
+his investigation, Szafranski obtained the following information demonstrative of TD Bank's
+involvement:
+October 29, 2008 letter signed by Caretsky, assistant branch manager with
+Commerce Bank® enclosing three trust account statements for RRA: (1) account number
+containing $166,922,339.00; (2) account number
+containing
+$40,125,685.44; and (3) account
+Containing $348,229,463.21. All three trust
+account statements for RRA are attached hereto and incorporated herein as Composite Exhibit
+"E."
+b. March 20, 2009 letter signed by Kerstetter an assistant manager for TD Bank
+enclosing three trust account statement for RRA: (1) account numbe
+balance of $104,211,711.22; (2) account
+numbe
+showing a
+showing a balance of
+$368,333,133.20; and (3) account numbe
+showing a balance of $110,331,563.13. All
+three account statements referenced are attached hereto and incorporated herein as Composite
+
+c. April 17, 2009 letter signed by Caretsky as a TD Bank Assistant Vice
+President, enclosing RRA trust account statement for: (1) account number
+balance of $61,117,11J; (2) RRA trust account statement for account numbe
+, showing a
+Ashowing
+a balance of $80,978,935.31; (3) RRA trust account statement for account numbe
+showing a balance of $136,122,322.87; (4) RRA trust account statement for account number
+showing a balance of $198,644,311.13; and (5) RRA trust account statement for
+account numb
+howing a balance of $483,668,999.39. All five trust account
+• Commerce Bank was a predecessor in interest to TD Bank as a result of #D Bank : $7 billien purchart
+i Gommere Bunti in March 2008 purchase.
+Page 22 or 289
+
+
+statements referenced are attached hereto and incorporated herein as Composite Exhibit "G."
+d. June 22, 2009 Commerce Bank wire transfer to RRA trust account ending x-
+in the amount of $1,957,500.00 and purporting to be a funded settlement, a copy of which is
+attached hereto and incorporated herein as Exhibit "H";
+e.
+June 22, 2009 Commerce Bank wire transfer to RRA trust account ending x-
+the amount of $2,680,000.00 and purporting to be a funded settlement, a copy of which is
+attached hereto and incorporated herein as Exhibit "*";
+f.
+June 22, 2009 Commerce Bank wire transfer to RRA trust account ending x-
+in the amount of $695,000.00 and purporting to be a funded settlement, a copy of which is
+attached hereto and incorporated herein as Exhibit "J";
+June 30, 2009 Commerce Bank wire transfer to RRA trust account ending x-
+in the amount of $2,208,000.00 and purporting to be a funded settlement, a copy of which is
+attached hereto and incorporated herein as Exhibit "K";
+h.
+July 1, 2009 Commerce Bank wire transfer to RRA trust account ending x-
+In the amount of $6,072,000.00 and purporting to be a funded settlement, a copy of which is
+attached hereto and incorporated herein as Exhibit "L";
+July 13, 2009 letter signed by Kerstetter from TD Bank enclosing RRA trust
+account statement for account number
+showing a balance of $14,286,000.00, a copy of
+which is attached hereto and incorporated herein as Composite Exhibit "M"; and
+j.
+July 17, 2009 TD Bank wire transfer to RRA trust account ending
+an
+the amount of $22,348,221.00 and purporting to be a funded settlement, a copy of which is attached
+hereto and incorporated herein as Exhibit "N";
+Pagc 23 of 289
+
+
+:. "
+70.
+In reliance on the foregoing, as confirmed by Szafranski, the Banyon Investors
+collectively invested $60,550,000.00 into BIF and into the Ponzi scheme.
+2. Razorback Funding, LLC
+71.
+Razorback was formed September 24, 2009 for purposes of investing in two RRA
+settlements: (I) a $40,600,000.00 structured settlement, payable in four equal monthly
+instaliments, offered in exchange for a lump sum payment of $23,200,000.00; and (2) a
+$26,100,000.00 structured settlement, payable in three equal monthly installments, offered in
+exchange for a lump sum payment of $17,400,000.00. See Confidential Settlement Agreements
+and Releases which are attached hereto and incorporated herein as Composite Exhibit "O."
+72.
+In particular, the deal was structured so Razorback would fund $32,000,000.00
+towards, the purchase of these settlements by means of a loan to Banyon USVI, LLC. Banyon
+USVI in turn would contribute $8,600,000.00 to purchase the settlement proceeds from the
+Principal Conspirators. See Acknowledgement of Assignment/Purchase of Settlement Proceeds
+and Sale and Transfer Agreements which is attached hereto and incorporated herein as Composite
+
+73.
+On or about September 18, 2009, as part of its due diligence, Razorback obtained a
+copy of a TD Bank "lock letter" signed by Spinosa used in a prior deal. See September 18, 2009
+lock letter from TD Bank which is attached hereto and incorporated herein as Exhibit "Q." The
+lock letter indicates that TD Bank had been irrevocably instructed to pay the fund identified in a
+particular RRA trust account only to the investor's bank account.
+74. On October 1, 2009, Szafranski, who was utilized as the independent reviewer for
+. Razorback as well, met with Rothstein to review and verify all of the documents supporting the
+
+
+
+Case No.: 02-062943 (19)
+Razorback deal. In that meeting, Szafranski purportedly witnessed Rothstein sign on to the TD
+Bank on-line banking website and verified that all of the wire transfers for the underlying
+Razorback settlement deals had been received by RRA and were held in RRA's trust account
+ending in
+A copy of the October 1, 2009 email from Szafranski verifying the abovereferenced account is attached hereto and incorporated herein as Exhibit "R."
+75. Szafranski also verified that a "lock letter" had been received by Spinosa as
+Regional Vice President of TD Bank dated October 1, 2009 stating the following:
+2009, please be advised that all funds contained in the above
+referenced account shall only be distributed upon your or
+to Banyon USVI (Del), LLV, co Razorback Funding, LLC,
+Debt & Equity Re-Payment Account: TD Bank, NA. 319
+Glen Head Road, Old Brookville, NY, ABA
+Your letter is understood not to
+onveyances as follows: conveyances shall only be mad
+rom the account referenced above to the Banyon USV
+See October 1, 2009 letter which is attached hereto and incorporated herein as Exhibit "S."
+Spinosa e-mailed the "lock letter" to Rothstein earlier that day with a message
+stating that at Rothstein's "request and instructions, this account [RA's trust account] has been
+irrevocably locked as to destination of all disbursements [which was Razorback's account, also at
+TD Bank]. The letter confirming same is attached. Please do not deposit any funds into this
+account that are not soley (sic) to be directed to the entity set forth in the inevocable instruction." A
+copy of the October 1, 2009 email from Spinosa is attached hereto and incorporated herein as
+
+
+
+
+. --
+77.
+Also on October 1, 2009, Razorback received copies of two wire transfers from
+Preve, a Banyon USVI representative, demonstrating that a total of $66,700,000.00 (the full
+settlement funding being purchased) had been received by RRA in its trust account with TD Bank.
+A copy of the October 1, 2009 wire transfers is attached hereto. and incorporated herein as
+Composite Exhibit "U."
+78.
+On the same day, Preve forwarded Razorback an email from Rothstein providing:
+(I) confirmation of Preve's purported $8,000,000.00 wire into RRA's trust account; and (2) that
+no disbursement on the deal would be made until he received the $32,000,000.00 from
+Razorback. A copy of the October 1, 2009 email from Rothstein is attached hereto and
+incorporated herein as Exhibit "V."
+79. On October 3, 2009, Razorback attempted to contact Spinosa to verify the details of
+the lock letter. The Razorback representative was unable to reach Spinosa but did receive
+confirmation from Spinosa's assistant that she prepared the lock letter and that Spinosa signed it.
+80. On October 7, 2009, Razorback received an email from Preve which contained an
+• on-line screen shot of an RRA trust account at TD Bank indicating, a balance of $66, 700,000.00. A
+copy of the TD Bank account screen shot is attached hereto as Exhibit "W."
+81.
+Finally, on October 22, 2009, Szafranski met again with Rothstein and verified that
+all of the putative plaintiffs in the Razorback deals received their disbursements by reviewing TD
+Bank's on-line banking website. A copy of Szafranski October 22, 2009 confirming email is
+attached hereto and incorporated herein as Exhibit "X."
+82.
+In reliance on the foregoing, Razorback transferred the sum of $32,000.000.00 to
+RRA's trust account.
+
+
+
+3. D3 Capital Club, LLC
+83. D3 was formed October 4, 2009 for purposes of investing in a $30,000,000.00
+RRA structured settlement, payable in six equal monthly installments of $5,000,000.00, offered
+in exchange for $18,000,000.00. See Confidential Settlement Agreements and Releases which is
+attached hereto and incorporated herein as Composite Exhibit "y."
+84. A D3 representative, who was also a representative of Razorback's management
+team, had knowledge of and relied upon the contacts and representations made by TD Bank in
+connection with the Razorback transaction.
+85. On or about October 15, 2009, as part of its due diligence, D3 obtained a copy of a
+TD Bank "lock letter" signed by Spinosa stating the following:
+Pursuant to your written instructions to us of October 14, 2009,
+please be advised that all funds contained in the above referenced
+account shall only be distributed upon your or Stuart Rosenfeldt's
+instruction and shall only be distributed to D3 Capital Club, LLC,
+2833 NE 35% Court, Fort Lauderdale, FL, 33308, TD Bank NA.
+Account
+Your letter is understood not to convey ownership of the account or
+access to the account to any other party, but rather is meant to
+irrevocably restrict conveyances as follows: conveyances shall only
+be made from the account referenced above to the TD bank account
+See October 15, 2009 lock letter attached hereto and incorporated herein as Exhibit "Z."
+86.
+On October 15, 2009, Spinosa signed another letter enclosing a copy of RRA's trust
+account bank statement showing a balance in excess of $30,000,000.00. See October 15, 2009 letter
+aitached hereto and incorporated herein as Composite Exhibit "AA."
+87.
+Furthermore, on October 15, 2009, Kerstetter drafted a letter to RRA enclosing a
+copy of RRA's trust account bank statement for the D3 settlement showing a balance in excess of
+
+
+
+$30,000.000.00. This letter was personally delivered by Kerstetter to Rothstein in a D3
+representative's presence while inside the TD Bank Fort Lauderdale branch. See October 15, 2009
+letter attached hereto and incorporated herein as Exhibit "AA-1." Later that day, Kerstetter met
+again with that same D3 representative at a location outside of the bank in order to sign the
+paperwork to open a D3 account at TD Bank.
+88.
+On October 16, 2009 and again on October 19, 2009, a D3 representative sent emails
+to Spinosa and Kerstetter advising that D3 had opened its account for purposes of doing business
+with RRA and asked about the mechanics of the irrevocable lock letter that D3 had with RRA
+account number
+A copy of the October 16, 2009 and October 19, 2009 emails are
+attached hereto and incorporated herein as Composite Exhibit "BB."
+89.
+Spinosa responded to the October 19, 2009 email with a phone call to the D3
+representative. During the conversation, the lock letter was acknowledged by Spinosa who
+refuisedto provide any further details about che Principal Conspirators' accounts.
+Finally, on October 19, 2009, Szafranski met with Rothstein and verified that the
+sum of $30,000,000.00 was wired from the putative defendant into the RRA trust account ending x-
+1629. A copy of the October 19, 2009 email is attached hereto and incorporated herein as Exhibit
+"CC."
+91.
+In reliance on the foregoing, D3 transferred the sum of $13,500,000.00 to RRA's
+trust account.
+Pagc 28 of 289
+
+
+4. BFMC Investment, LLC
+92. BFMC was formed in November 1998 to fund investment opportunities.
+93. On September 28 2009, BFMC principal, Barry Florescue ("Florescue") met
+socially with Andrew Barnett ("Barnett"), Director of Corporate Development for RRA.
+94. During this meeting, Barnett described his role at RRA and invited Florescue to
+meet Rothstein later that week to discuss a lucrative investment opportunity.
+Florescue was
+aware of Rothstein given Rothstein's prominence in the Fort Lauderdale business and social
+community, and a meeting was scheduled at RRA on September 30, 2009.
+95.
+Florescue and his employee, Mark Seigel ("Seigel"), arrived in RA's offices and
+were initially introduced to Boden. Coincidentally, Boden had, many years earlier, worked as a
+junior staff member with Florescue's corporate counsel and had actively worked on one of
+Florescue's previous financing transactions.
+96.
+After several minutes,
+Boden and Barnett led Florescue and Seigel into
+Rothstein's private office.
+97.
+After introductions, Rothstein described an investment opportunity involving
+purchasing various settlements with structured payments explaining as follows:
+a.
+RRA is a nationally recognized firm representing whistleblowers in
+whistleblower lawsuits against employers. RRA has specific expertise in a specific type of
+litigation called Qui Tam litigation, in which the defendant is also accused of defrauding the
+United States government. RRA became a magnet for Qui Tam cases following its success as
+co-counsel in a 2008 Eli Lilly Qui Tam case, which resulted in a $1 billion plus settlement.
+Page 29 or 289
+
+
+b. RRA was currently representing whistleblower plaintiffs inside a Fortune
+S00 company that had allegedly defrauded the United States government. Citing confidentiality,
+Rothstein could not share the name of the defendant, but he described it as a large food
+conglomerate that had substituted cheaper ingredients into food supplies sold to the government
+under national contracts. Rothstein was rounding up dozens of whistleblowers inside the
+company who had been threatened by senior management to remain silent regarding the
+company's fraud.
+c.
+RRA had negotiated numerous settlements for $1,400,000.00 for various
+whistleblower clients, but the defendant insisted on paying the settlements out over four months.
+The plaintiffs wanted their cash up front.
+d.
+Rothstein explained that the putative plaintiffs were willing to take a large
+discount up front because: (i) they had a high degree of concern over whether defendant would
+attempt to prevent them from receiving payments after settling and, (ii) Rothstein explained in
+detail a legal concept called "privity" - plaintiff was "in privity" with the defendant which
+subjected their settlement to reversal by the federal government. Rothstein represented that a
+third party buyer of the settlement rights would not be subject to such reversal as the third party
+was not "in privity" with the defendant.
+e.
+The settlement documents were drafted and ready to be settled, but
+Rothstein needed to find an investor to fund the settlement. Rothstein explained that such a
+transaction was legal, because the settlement agreement had no "anti-assignment rights", but that
+any third party investor couldn't be given any details about the parties involved in the settlement,
+because it was by nature highly confidential and did contain strong confidentiality provisions.
+
+
+
+Due to the fact that a "funder" could not be given any information about
+the case, the defendant, or the plaintiff, and given the fact that Rothstein needed a high degree of
+confidentiality about even the existence of the funding arrangement (in order to prevent
+defendants from explicitly prohibiting this type of arrangement going forward), Rothstein could
+only engage in such transaction with local friends with whom he trusted.
+g.
+RRA's clients were willing to accept $800,000.00 up front in exchange for
+their rights to the $1,400,000.00 settlement, payable over 4 months.
+h.
+Rothstein could not personally fund the structured settlements because it
+was illegal for him or his firm to profit from a structured settlement in which he represented the
+plaintiff. However, it was in his firm's interest to find a funder so that the firm could settle the
+case and get paid its contingency fec.
+i.
+Rothstein remarked that the transaction would be substantiated and
+verified, that he would provide evidence of the settlement in his office, and that he would get on
+the phone with Spinosa of TD Bank to confirm that the putative defendant's funds had been
+wired into a Florida Bar trust account with instructions to only release the funds in that account
+to the specified funder.
+98.
+Upon concluding the meeting, Barnett walked Florescue and Seigel out to the
+elevator. During a debrief, Barnett revealed that the defendant was Dole Foods, which had
+knowingly supplied the U.S. Government with impure orange juice in a major juice contract that
+called for 100% pure orange juice. Barnett said that Rothstein had offered to sign a corporate
+and personal guaranty as a further inducement to make the investment.
+
+
+
+99.
+Between September 30, 2009 and October I5, 2009, BFMC worked with. their
+counsel and Boden on various transaction documents necessary to close the deal.
+100. During the first week of October 2009, Florescue telephoned Spinosa, who
+Florescue knew professionally based on various banking activities previously engaged in, to
+inquire about Rothstein. Spinosa said that he could not talk about Rothstein without Rothstein's
+consent.
+101. In early October, 2009, Boden finalized the deal documents for BFMC's
+doment
+investment in three identical RRA settlements: (1) a $1,400,000.00 structured settlement,
+payable in four equal monthly installments, offered in exchange for a lump sum payment of
+$800,000.00; (2) a second $1,400,000.00 structured settlement, payable in four equal monthly
+installments, offered in exchange for a lump sum payment of $800,000.00; and (3) a third
+$1,400,000.00 structured settlement, payable in four equal monthly installments, offered in
+exchange for a lump sum payment of $800,000.00. See correspondence from. David Boden
+which is attached hereto and incorporated herein as Exhibit "DD."
+102. BFMC's explicit understanding from Boden and Rothstein was that the putative
+defendant's funds were to be held in RRA's trust account and could only be released directly to
+BFMC's account pursuant to an irrevocable "lock letter."
+On or abour October 15, 2009, as part of its due diligence, BFMC obtained a copy of
+a TD Bank "lock letter" signed by Spinosa stating that:
+[pursuant to your written instructions to us of October 14, 2009,
+please be advised that all funds contained in the above referenced
+account shall only be distributed upon your or Stuart Rosenfeldt's
+instruction. and shall only be distributed to BB&T (FKA: Colonial
+Bank), Pompano Beach Branch # 32083, (954) 943-6550, ABA#
+
+
+
+for further credit to: BFMC Investment, LLC Account #
+Your letter is understood not to convey ownership of the account or
+ccess to the account to any other party, but rather is meant to
+irrevocably restrict conveyances as follows: conveyances shall only
+be made from the account referenced above to the BB&T (FKA:
+Colonial Bank) account # 1
+Investment, LLC.
+• See October 15, 2009 lock letter attached hereto and incorporated herein as Exhibit "EE."
+104. Later that day, and in reliance on the foregoing, BEMC wired $2,400,000.00 to
+RRA's TD Bank account number
+Implosion of Rothstein's Ponzi Scheme
+105. In October 2009, the Ponzi scheme reached critical mass. October was a huge
+month for investor settlement redemptions and Rothstein knew that the influx of new investor
+capital could not satisfy all previous investor obligations. Sensing that the end was near,
+Rothstein began planning his escape.
+106. On October 17, 2009, Rothstein sent a firm-wide e-mail at RRA asking for help to
+determine whether a "client" who is facing a multitude of criminal charges in the United States--
+including fraud, money laundering and embezzlement--could be extradited to the United States
+or Israel from abroad after renouncing his United States citizenship. Rothstein's email asked for
+countries which did not have extradition treaties with the United States or Israel and concluded
+by stating that "It)his client is related to a very powerful client of ours and so time is of the
+essence. Lets rock and roll... there is a very large fee attached to this case. Thanks Love ya
+"Not coincidentally Morocco, Rothstein's destination on October 27, 2009, was one of the countries that
+/ does not have an extradition treaty with either the United States or Israel,
+
+
+
+Scott." See Sun-Sentinel article dated November 16, 2009 referencing the October 17, 2009
+email which is attached hereto and incorporated herein as Exhibit "FF." Suffice it to say,
+Rothstein was the purported "client" and this is the first clear written indication that he knew his
+fate.
+107. By the end of October 2009, Rothstein and RRA began to default on the
+investors' structured payments and the Ponzi scheme began to unravel.
+108. On October 26, 2009, Linda Von Allmen spoke with Rothstein at Bova restaurant
+who, in between martinis, admitted that he was "having a bad day." Rothstein was joined by a
+woman and his bodyguard, believed to be Joe Alu, who may have witnessed this exchange.
+109. On October 27, 2009, Richard Pearson, who had invested $18,000,000.00 in the
+Ponzi scheme, confronted Rothstein who was sitting with Spinosa inside of Bova restaurant.
+Pearson, in Spinosa's presence, demanded to know why he had not received two scheduled
+payments due to him the week prior/ Rothstein attempted to diffuse the situation leaving Spinosa
+visibly shaken.
+110.
+Shortly thereafter, Rothstein proceeded to methodically drain the TD Bank RRA
+accounts dry, depleting virtually all of the remaining investors" money as well as the money of
+many of the firms' clients.
+On the evening of October 27, 2009, Rothstein secretly boarded a private G-5 jet
+destined for Morocco, but not before completing a $16,000,000.00 wire transfer to a Moroccan
+bank.
+
+
+
+112. By October 30, 2009, investors began to scramble desperately attempting to reach
+Rothstein for answers. Unbeknownst to them Rothstein was already gone, along with their
+investments, as the Ponzi scheme finally buckled under the pressure of obligations due.
+113. Alarmed investors frantically reached out to RRA executives and attorneys
+begging for information as to the whereabouts of Rothstein and their more than $30.000,000.00
+in overdue payments. Stuart Rosenfeldt (hercinafter, "Rosenfelde") assembled a team including
+Boden, Stay and Grant
+at RRA to begin answering the deluge of investor calls by first
+confirming with Stay (RRA's C.F.O.) that RRA's operating and trust accounts contained more
+than 51 billion dollars. Shamefully, Stay refused to provide Rosenfeldt the confirmation
+requested. Growing ever agitated, Rosenfeldt and the others continued to press Stay demanding
+to know what was going on and that she produce current account statements. Eventually Stay
+relented and began inconsolably crying repeating the phrase, "I don't want to go to jail."
+Rosenfeldt proceeded to conference call Spinsoa who initially declined to provide account
+balance verification but after much cajoling finally informed Rosenfeldt that the RRA accounts
+had been almosı completely depleted.
+Devastating Fallout
+114.
+The velocity at which the Ponzi scheme cratered sent a sonic boom felt
+throughout the financial and legal world.
+115. Reeling from its shameful missteps in connection with the Rothstein scandal, an
+emergency receiver was appointed for RRA on November 4, 2009 for the purpose of winding down
+its operations.
+Pagc 35 of 289
+
+
+3*2960
+116. As the dust begins to settle, critical details have emerged revealing the scope and
+magnitude of this the nefarious scheme. By way of example Plaintiffs have discovered that:
+a.
+the entirety of Plaintiffs' more than $100,000,000.00 investment is gone;
+b.
+plaintiffs" "lock letter"" accounts were never funded with the purported
+c.
+settlement money and contained only a nominal deposit of $100.00;
+even after Rothstein's October 27, 2009 departure to Morocco, millions of
+dollars continued to flow out of RRA accounts from the Fort Lauderdale
+TD Bank accounts, indicative of an insider(s) maintaining operations of
+the Ponzi scheme including, but not limited to:
+\
+10
+i.
+ii.
+ili.
+iv.
+V.
+vi.
+vii.
+viii.
+ix!
+x.
+xi.
+xii.
+xili.
+xiv.
+XV.
+xvi.
+xvil.
+xviii.
+xiX.
+XX.
+xxi.
+xxii.
+xxiv.
+Shimon Levy
+Shimon Levy
+Onyx Capital
+Barbe
+Shimon Levy
+Obidia Levy
+Rachel Levy
+Daniel Minkowitz
+Benzion Varon
+Dominic Ponatchio
+Daniel Minkowitz
+Daniel Minkowitz
+Shimon Levy
+Shinion Levy
+Onyx Capital
+Obidia Levy
+Obidia Levy
+• Moty Ban-Adon
+Benzion Varon
+Ahnick Kahlid
+BWS Investments
+Pirulin Group
+Condorde Capital
+National Financial
+$366,000.00
+$287,500.00
+$263,000.00
+$240,000.00
+$225,000.00
+$250,000.00
+$50,000.00
+$235,000.00
+$33,333.00
+$280,000.00
+$200,000.00
+$100,000.00
+$366,666.00
+$337,500.00
+$275.000.00
+$268,000.00
+$175.000.00
+$132,000.00
+$33,333.00
+$16,000,000.00
+$300,000.00
+$.300,000.00
+$.300.000.00
+$150,000.00;
+
+
+
+3437-÷:
+d.
+e.
+f.
+g.
+h.
+in April 2009, $53.060,000.00 in credits and $51,560,000.00 in debits
+NO
+were transacted through four RRA trust accounts at TD Bank;
+in October 2009 $235.000,000.00 in credits and $232,000,000.00 in debits
+were transacted through the RRA accounts at TD Bank;
+the $8,000,000.00 wire transfer confirmation used by Preve and Rothstein
+to induce Razorback's $32,000,000.00 payment was in fact never received
+by RRA or TD Bank;
+on November 1, 2009, Mel Lifshitz of DE Securities whose group
+invested nearly $100,000,000.00 into the Ponzi scheme, advised a group
+of investor!" victims that he personally sat with Spinosa at TD Bank and
+verified investment account balances;
+during that same meeting, Levin informed the group that he reached out to
+Rothstein in Morocco letting him know that Banyon stood ready to
+provide shortfall financing if he was having trouble making payments.
+Astoundingly, Levin's revealing admission took the group by surprise
+because one of the core "deal" tenants insured against any possible deficit
+by requiring a putative defendant's settlement to be funded prior to an
+investors lump sum purchase. Thus, any shortfall, even the smallest one,
+is patently contrary to the investment structure and obvious evidence that
+the monies are either being misused or are a part of a Ponzi scheme.
+'The group of investors attending the November 1, 2009 meeting include:
+Kretschmar. Ted:Morse,
+Ed Morse: Richard Pearson, Ira Socher, Mel Lifshitz. AJ Discala, Mac Melvin, Mark: Nordlicht, Jack
+Simony, Steve Jackel. Laurence King, Steve Levin,
+Levin,
+Preve, Barry Bekkedam, and
+Michael Szafranski,
+
+
+
+i.
+j.
+k.
+I.
+Cave No.: 09-062943 (19)
+Plaintiffs now believe that Levin's statement was a thinly-veiled attempt
+to cover his tracks after Rothstein rejected Levin's last-ditch efforts to
+persuade Rothstein to keep the Ponzi scheme going. In support, Plaintiffs
+rely on a October 31, 2009 email from Preve to Rothstein stating that "We.
+Levin and Prevel understand that the shortage is now 300m which is still
+manageable if we have your cooperation
+Let me know," to which
+Rothstein responds, "It hat is not the shortage /.... that is the amount of
+money needed to give the investors back their moncy. I really just need to
+end it
+It will make it easier for everyone." (emphasis added). The
+attempt to try and "manage" the hole created now presumes that Levin and
+Preve had knowledge of a prior deficit and serves as an unwitting
+admission of their involvement in the perpetuation of the Ponzi scheme;
+sometime in the Spring or Summer of 2009, Ted Morse was personally
+provided with a written account balance statement by Caretsky at TD
+Bank;
+on July 27, 2009 Rothstein transferred a property with an assessed value of
+$407,750.00 10
+for "love and affection" and $100.00.
+Notwithstanding owning the property free and clear,
+who carned
+$250,000.00 a year, decided to pull $100,000.00 out of the property days
+prior to the IRS filing of a forfeiture in rem complaint against the property;
+Berenfeld's audited financial statements for the affiliated Banyon entities
+confirmed finance receivables of $517,404,505.00 due from RRA
+
+
+
+settlements worth more than $1,100,000,000.00. See Composite Exhibit
+"D." As now discovered, these verified finance receivables were pure
+fiction. Incontrovertibly, Berenfeld either willfully participated in this
+fraud or knew or should have known as part of the audit process that the
+finance receivables were fabricated and incapable of heing independently
+verify;
+m.
+Berenfeld's complicity in the Ponzi scheme is further compounded by
+their, role as accountants for RRA and Rothstein and Rosenfeldt
+individually providing, them with first-hand knowledge of the patent
+inconsistencies between Banyon's purported verified audited receivables
+and RRA's actual numbers;
+n.
+due to the vast complexity in maintaining the Ponzi scheme's fraudulent
+accounting, it is only sophisticated accountants could have accounted for
+"phantom" investments over a period of four years allowing the Principal
+Conspirators 1o generate falsified statements necessary to dupe investors;
+Ballamor and Mr. Bekkedam received a $5,000,000.00 "loan" fron Levin
+for procuring investor funds along with a $18,000,000.00 investment
+through Ballamor into Nova Bank, a Pennsylvania bank;
+P.
+the TD Bank account statements provided and verified by Szafranski were
+completely. fabricated and incapable of being confirmed. In most
+instances, there was either no money in the settlement accounts or the
+amounts contained were hundreds of millions less than what was
+
+.i.tr.....
+
+
+represented in the statements (see Comparison Chart of Actual Account
+Balances with Provided Deal Account Statements as attached hereto and
+incorporated herein as Composite Exhibit "GG."); and
+TD Bank either knew or certainly should have known of the criminality
+and/or gross irregularities of RRA's operations. Alternatively, TD Bank's
+actions and/or omissions in not conducting any due diligence inquiry into
+RRA's suspicious activities, unorthodox settlement structures, lack of
+supporting document and vigilant (if not obsessive) control over account
+access was either deliberate or reckless.
+117. A Ponzi scheme cannot be operated without insider help. Plaintiffs believé that
+additional members of RRA, including its non-lawyer investigators, were used by Rothstein to
+perpetuate, promote and facilitate the Ponzi scheme. The details of these individuals or entities
+involvement and participation is presently unknown but further allegations and counts will be
+added as discovery is conducted and information concerning the complicity of these individuals
+or entities is confirmed
+Jurisdiction and Venue
+118.
+This court has jurisdiction over this matter as an action for damages in excess of
+$100,000,000.00 exclusive of attorneys' fees, costs and interest.
+119.
+. Venue is appropriate Broward County, Florida, pursuant to § 47.011, Fla. Stat.,
+because the Defendants' reside in Broward County, Florida and the cause of action accrued in
+Broward County, Florida.
+120.
+All conditions precedent, if any, have been met, waived or excused.
+
+
+
+121. Plaintiffs have retained the undersigned firm and have agreed to pay it a
+reasonable fee.
+COUNT I1 - FRAUDULENT MISREPRESENTATION
+(against Scott Rothstein)
+122. Plaintiffs incorporate the allegations contained in paragraphs | through 107121 as
+if restated herein.
+123. This is a claim for fraudulent misrepresentation.
+124. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+125. In furtherance of the Ponzi scheme, Rothstein knowingly made material false
+statements and representations, including but not limited to representing that the settlement
+agreements purchased by investors were real, that they had been fully funded, and that they
+would be paid out to investors over a predetermined schedule.
+126. Rothstein intended the Banyon Investors to act on his knowingly false
+representations.
+127. The Banyon Investors justifiably relied upon Rothstein's representations to their
+detriment.
+128.
+As a direct and proximate result of Rothstein's false statements, The Banyon
+Investors have sustained damages.
+WHEREFORE, LINDA VON ALLMEN: as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST; ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+
+
+
+:.
+LIVING TRUST; and
+KRETSCHMAR request judgment against SCOTT ROTHSTEIN
+for compensatory damages, together with court costs and such further relief as the Court deems
+proper.
+COUNT H2 - FRAUDULENT MISREPRESENTATION
+(against Jennifer Kerstetter)
+129. Plaintiffs incorporate the allegations contained in paragraphs 1 through 147121 as
+if restated herein.
+130. This is a claim for fraudulent misrepresentation.
+131. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+132. In furtherance of the Ponzi scheme, Kerstetter knowingly made material false
+statements and representations including, but not limited to, supplying investors with false bank
+account statements.
+133. Kerstetter intended the Banyon Investors to act on her knowingly false
+representations.
+134
+The Banyon Investors justifiably relied upon Kerstetter's representations to their
+detriment.
+135. As a direct and proximate result of Kerstetter's false statements, the Banyon
+Investors have sustained damages.
+WHEREFORE, FHE-LINDA VON ALLMEN; as Trustee of ihe VON ALLMEN
+DYNASTY TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID
+
+
+
+YON ALLMEN LIVING TRUST: ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+LIVING TRUST: and
+KRETSCHMAR request judgment against JENNIFER
+KERSTETTER for compensatory damages, together with court costs and such further relief as
+the Court deems proper.
+COUNT #13 - FRAUDULENT MISREPRESENTATION
+OPY
+(against Roseanne Caretsky)
+136. Plaintiffs incorporate the allegations contained in paragraphs 1 through 107121 as
+if restated herein.
+137. This is a claim for fraudulent misrepresentation.
+138. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+139. In furtherance of the Ponzi scheme, Caretsky knowingly made material false
+statements and representations including, but not limited to, supplying investors with false bank
+account statements.
+140.
+Caretsky intended the Banyon Investors to act on her knowingly false
+representations.
+141,
+The Banyon Investors justifiably relied upon Caretsky's representations to their
+detriment.
+142. As a direct and proximate result of Carelsky's false statements, the Banyon
+Investors have sustained damages.
+
+
+
+WHEREFORE, THE-LINDA VON ALLMEN as Trustee of the VON ALLMEN
+DYNASTY TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID
+YON ALLMEN LIVING TRUST; ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+LIVING TRUST; and
+KRETSCHMAR request judgment against ROSEANNE
+CARETSKY for compensatory damages, together with court costs and such further relief as the
+Court deems proper.
+NOT A CERTIFIED CO
+COP
+
+
+
+COUNT +4 - FRAUDULENT MISREPRESENTATION
+(against TD Bank, N.A.)
+143. Plaintiffs incorporate the allegations contained in paragraphs I through 107121 as
+if restated herein.
+144. This is a claim for fraudulent misrepresentation.
+145. At all times material hereto, Kerstetter was acting in the scope of her employment
+as an assistant manager of TD Bank.
+146. At all times material hereto, Caretsky was acting in the scope of her employment
+as an assistant vice president and branch manager of TD Bank.
+147. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA; and through TD Bank.
+148. In furtherance of the Ponzi scheme, TD Bank, through Kerstetter and Caretsky
+knowingly made material false statements and representations including, but not limited to,
+supplying investors with false bank account statements.
+149. TD Bank, through Kerstetter and Caretsky, intended the Banyon Investors to act
+on their knowingly false representations.
+150. The Banyon Investors justifiably relied upon TD Bank's through Kerstetter's and
+Careisky's representations to their detriment.
+151
+As a direct and proximate result of TD Bank's, made through Kerstetter's and
+Caretsky's, false statements, the Banyon Investors have sustained damages.
+WHEREFORE: LINDA VON ALLMEN: as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID. VON
+ALLMEN LIVING TRUST: ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+
+
+
+• Amended Complaint
+LIVING TRUST: and
+KRETSCHMAR request judgment against TD BANK, N.A., for
+compensatory damages, together with court costs and such further relief as the Court deems
+proper.
+COUNT +5 - FRAUDULENT MISREPRESENTATION
+(against
+G. Levin)
+152. Plaintiffs incorporate the allegations contained in paragraphs 1 through 12! as if
+restated herein.
+153. This is a claim for fraudulent misrepresentation.
+154. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+I5S. In furthérance of the Ponzi scheme, Levin knowingly made material false
+• statements and representations including, but not limited to, representing that the settlenient
+• agreements purchased by investors were real, that they had been fully funded, and that they
+would be paid out to investors over a predetermined schedule.
+156. Levin intended the Banyon Investors to act on his knowingly false
+representations.
+157. The Banyon Investors justifiably relied upon Levin's representations to their
+detriment.
+158.
+As a direct and proximate result of Levin's false statements, the Banyon Investors
+have sustained damages.
+WHEREFORE, LINDA VON ALLMEN as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP; DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST: ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+
+
+
+LIVING TRUST: and
+KRETSCHMAR request judgment against
+LEVIN for
+compensatory damages, together with court costs and such further relief as the Court deems
+proper.
+COUNT 6 - FRAUDULENT MISREPRESENTATION
+(against
+Preve)
+159. Plaintiffs incorporate the allegations contained in paragraphs 1 through: 121 as if
+restated herein.
+160. This is a claim for fraudulent misrepresentation.
+161. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+162. In furtherance of the Ponzi scheme, Preve knowingly made material false
+statements and representations including, but not limited to, representing that the settlement
+agreements purchased by investors were real, that they had been fully funded, and that they
+would be paid out to investors over a predetermined schedule.
+163. Preve intended
+the Banyon Investors _to_act on his knowingly false
+representations.
+164. The Banyon Investors justifiably relied upon Preve's representations to their
+detriment.
+165.
+As a direct and proximate result of Preve's false statements, the Banyon Investors
+have sustained damages.
+WHEREFORE, LINDA VON ALLMEN as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST: ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+
+
+
+LIVING TRUST; and
+KRETSCHMAR request judgment against
+PREVE for
+compensatory damages, together with court costs and such further relief as the Court deems
+proper,
+COUNT 7 - FRAUDULENT MISREPRESENTATION
+(against Banyon Income Fund, LP, and Banyon USVI, LLC)
+166. Plaintiffs incorporate the allegations contained in paragraphs 1 through 121 as if
+restated herein.
+167. This is a claim for fraudulent misrepresentation.
+168. At all times material hereto, Levin was acting in the scope of his employment as
+the chief executive officer of Banyon USVI and BIF.
+169. At all times material hereto, Preve was acting in the scope of his employment as
+the chief operating officer or agent of Banyon USVI and BIE.
+170. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+171. In furtherance of the Ponzi scheme, Banyon USVI and BIF, through Levin and
+Preve, knowingly made material false statements and representations including, but not limited
+to, representing that the settlement agreements purchased by investors were real, that they had
+been fully funded, and that they would be paid out to investors over a predetermined schedule.
+172. Banyon USVI and BIF, through Levin and Preve, intended the Banyon Investors
+to act on their knowingly false representations.
+173. The Banyon Investors justifiably relied upon Banyon USVI's and BIF's, through
+Levin's and Preve's, representations to their detriment.
+
+
+
+174. As a direct and proximate result of Banyon USVI's and BIF's, made through
+Levin's and Preve's, false statements and representations, the Banyon Investors have sustained
+damages.
+WHEREFORE, LINDA VON ALLMEN as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS. LP: DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST; ANN VON ALLMEN, as Trustee of the ANN: VON ALLMEN
+LIVING TRUST; and
+KRETSCHMAR request judgment againsi BANYON INCOME
+FUND, LP, and BANYON USVI, LL.C., for compensatory damages, together with court costs
+and such further relief as the Count deems proper.
+COUNT 8 - FRAUDULENT MISREPRESENTATION
+(against Michael Szfranski)
+175. Plaintiffs incorporate the allegations contained in paragraphs 1 through 12l as if
+restated herein.
+176. This is a claim for fraudulent misrepresentation.
+177. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+178. Iu furtherance of the Ponzi scheme,
+Szfranski knowingly made material false
+statements and representations including, but not limited to, verifying false bank statements and
+deal documents.
+179. Szfranski intended the Banyon Investors to act on his knowingly false
+representations.
+180. The Banyon Investors justifiably relied upon Szfranski's representations to their
+detriment.
+
+
+
+181. As a direct and proximate resuli of Szfranski's false statements, the Banyon
+Investors have sustained damages.
+WHEREFORE, LINDA VON ALLMEN as Tristee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP; DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST; ANN VON ALLMEN, as Trustee of the ANN VON ALLMEN
+LIVING TRUST: and
+KRETSCHMAR request judgment against MICHAEL
+SZFRANSKI for compensatory damages, together with court costs and such further relief as the
+Court deems proper.
+COUNT 9 - FRAUDULENT MISREPRESENTATION
+(against Onyx Capital Management)
+182. Plaintiffs incorporate the allegations contained in paragraphs i through 121 as if
+restated herein.
+183. This is a claim for fraudulent misrepresentation.
+184. At all times material hereto, Szfranski was acting in the scope of his employment
+as president of Onyx.
+his firm, RRA, and through TD Bank.
+186
+185. As described more fully above, Rothstein was operating a Ponzi scheme through
+In furtherance of the Ponzi scheme, Onyx, through Szfranski, knowingly material
+false statements and representations, including; but not limited to, verifying false bank
+statements and deal documents.
+187. Onyx, through Szfranski, intended the Banyon Investors to act on its knowingly
+false representations.
+
+
+
+188. The Banyon Investors justifiably relied upon Onyx's. through Szfranski's,
+representations to their detriment.
+189. As a direct and proximate result of Onyx's, made through Szfranski's, false
+representations, the Banyon Investors have sustained damages.
+WHEREFORE, LINDA VON ALLMEN as Tiustee of the VON ALLMEN DYNASTY
+TRUST; D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST; ANN VON ALLMEN, as Trustee of ine ANN VON ALLMEN
+LIVING TRUST; and
+KRETSCHMAR request judgment against ONYX CAPITAL
+MANAGEMENT, for compensatory damages, logether with court costs and such further relief
+as the Court deems proper.
+COUNT 10 - FRAUDULENT MISREPRESENTATION
+(against Berenfeld Spritzer Shechter Sheer, LLP)
+190. Plaintiffs incorporate the allegations contained in paragraphs 1 through 121 as if
+restated herein.
+191. This is a claim for fraudulent misrepresentation.
+192. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+193.
+In furtherance of the Ponzi scheme, Berenfeld knowingly made material false
+statements and representations including, but not limited to, providing false auditing documents
+relating to Banyon and RRA.
+194. Berenfeld intended the Banyon Investors to act on its knowingly false
+representations.
+
+
+
+195. The Banyon Investors justifiably relied upon Berenfeld's representations to their
+detriment.
+196. As a direct and proximate result of Berenfeld's false statements, the Banyon
+Investors have sustained damages.
+WHEREFORE, LINDA VON ALLMEN as Trustee of the VON ALLMEN DYNASTY
+TRUST: D&L PARTNERS, LP: DAVID VON ALLMEN, as Trustee of the DAVID VON
+ALLMEN LIVING TRUST: ANN VON ALLMEN, as Trustee: of the ANN VON ALLMEN
+LIVING TRUST: and
+KRETSCHMAR request judgment against BERENFELD
+SPRITZER SHECHTER SHEER, LLP, for. compensatory damages, together with court costs and
+such further relief as the Court deems proper.
+COUNT 11 -NEGLIGENT MISREPRESENTATION
+(against Jennifer Kerstetter)
+197. Plaintiffs incorporate the allegations contained in paragraphs 1 through t0712l as
+if restated herein.
+198. This is a claim for negligent misrepresentation.
+199. As described more fully above, Rothstein was operating a Ponzi scheme through
+his firm, RRA, and through TD Bank.
+In furtherance of the Ponzi scheme, Kerstetter made material false statements and
+representations including, but not limited to, supplying investors with false bank account
+statements.
+:
+201. When making the false statements and representations, Kerstetter either knew or
+reasonably should have known that they were false.
diff --git a/vision-fixhub/court-02/029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d.receipt.json b/vision-fixhub/court-02/029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..859e223b4a1a2e39c7432be9d7a600a5219550b2
--- /dev/null
+++ b/vision-fixhub/court-02/029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -2616,
+  "dataset": "marble-joined",
+  "doc_id": "029d4f7bb882b1488bb325bd5a9365d8d13614c49ac87afb59dc7f6d2aa8d87d",
+  "engine": "marble-apple-vision",
+  "event_count": 81,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "131fa0b559b2ebf58652033f754469c75fa390752198b3aa2e58dd87167953ef",
+  "output_sha256": "d02ccda4d5fbaf0a02b3ed3834755032078000d98ba046a27abbc09ec3c7e4d3",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.md b/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.md
new file mode 100644
index 0000000000000000000000000000000000000000..bdb10849bae982bcfb046f79cbc9c8829ea475ca
--- /dev/null
+++ b/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.md
@@ -0,0 +1,98 @@
+Filing # 57795130 E-Filed 06/15/2017 10:55:00 AM
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIRCUIT CIVIL DIVISION AG
+CASE NO. 50-2009-CA-040800-XXXX-MB
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN, individually,
+individually, and
+Defendants/Counter-Plaintiffs.
+ORDER SPECIAL SETTING HEARING
+(10 minutes reserved)
+THE COURT hereby sets for hearing Counter-Plaintiff,
+Motion to Set Cause for Trial and the Court's Motion to Determine Need fo
+Discovery/Motion Scheduling Order on July 6, 2017 at 8:45 a.m., at the Palm Beach Count
+Main Courthouse, 205 North Dixie Highway, West Palm Beach, FL 33401 in Courtroom 10 C
+At least one attorney from each side must appear in person and have the trial schedule of lead
+counsel in his or her possession. This matter may not be canceled without a Court Order.
+DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida, this 14th
+day of June, 2017.
+NOT
+Copies furnished to:
+F
+Andrew A. Harris (aah@flappellatelaw.com)
+i James
+(brad@pathtojustice.com)
+Fred Haddad (haddadfm@aol.com)
+DEAL CIRCUIT
+Circult. Judge.
+THE COU
+DONALD HAFELE
+Circuit Judge
+
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 06/15/2017 10:55:00 AM
+
+
+Order Special Set Hearing
+CASE NO. 50-2009-CA-040800-XXXX-MB
+John Scarola (mep@searcylaw.com)
+ILACKERMAN, JR 1
+Maria Kelljchian (maria@pathtojustice.com)
+Matthew D Weissing (matt@pathtojustice.com)
+PHILIP M BURLINGTON (PMB@FLAPPELLATELAW COM)
+service@jurytrial.co
+S, Adler (service@jurytrial.com)
+Tonja Haddad Coleman (tonja@tonjahaddad.com)
+William Bennett
+(wbk@searcylaw.com)
+William Chester
+. Jr. (wcblaw@aol.com)
+ґ
+William B.
+(kingteam@searcylaw.com)
+John Scarola (_scarolateam@searcylaw.com)
+Rodney G
+F
+TINED COMY
+Jack Goldberger (Jgoldberger@agwpa.com)
+Andrew A Harris (irh@flappellatelaw.com)
+Philip M Burlington (kbt@flappellatelaw.com)
+• Marc Nurik (marc@nuriklaw.com)
+Jack Goldberger (smahoney@agwpa.com)
+Edwards (staff.efile@pathtojustice.com)
+W Chester
+j Jr (wcblawasst@gmail.com)
+
+
+
+Order Special Set Hearing
+CASE NO. 50-2009-CA-040800-XXXX-MB
+This notice is provided pursuant to Administrative Order No. 2.207-9/12
+"If you are a person with a disability who needs any accommodation in order
+to participate in this proceeding, you are entitled, at no cost to you, to the
+provision of certain assistance. Please contact Tammy Anton, Americans with
+Disabilities Act Coordinator, Palm Beach County Courthouse, 205 North
+Dixie Highway West Palm Beach, Florida 33401; telephone number (561) 355-
+4380 at least 7 days before your scheduled court appearance, or immediately
+upon receiving this notification if the time before the scheduled appearance is
+less than 7 days; if you are hearing or voice impaired, call 711."
+"Si usted es una persona minusválida que necesita algún acomodamiento para
+poder participar en este procedimiento, usted tiene derecho, sin tener gastos
+propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en
+contacto con 205 N. Dixie Highway, West Palm Beach, Florida 33401; teléfono
+número (561) 355-4380, por lo menos 7 días antes de la cita fijada para su
+comparecencia en los tribunales, o inmediatamente después de recibir esta
+notificación si el tiempo antes de la comparecencia que se ha programado es
+menos de 7 días; si usted tiene discapacitación del oído o de la voz, llame al
+711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan
+pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon
+pou jwen kèk ed. Tanpri kontakte kòodonatè pwogram Lwa pou ameriken ki
+Enfim yo nan Tribinal Konte Palm Beach la ki nan 205 North Dixie Highway,
+West Palm Beach, Florida 33401; telefòn li se (561) 355-4380 nan 7 jou anvan
+dat ou gen randevou pou parèt nan tribinal la, oubyen imedyatman apre ou
+fin resevwa konvokasyon an si lè ou gen pou w parèt nan tribinal la mwens ke
+7 jou; si ou gen pwoblèm pou w tande oubyen pale, rele 711."
+
diff --git a/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.receipt.json b/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f93242c9cf19e9c2e18bff67ba7f16a1429be066
--- /dev/null
+++ b/vision-fixhub/court-02/02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -69,
+  "dataset": "marble-joined",
+  "doc_id": "02ca5dde2ad98917880405d17d5f62c24aebc815fce33d9247cfd2c5ce7e3e9c",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "8cbc2fc04a2ef8ab8b1483fa89b93503ad5419995abdf919b1de0415f97be3b3",
+  "output_sha256": "1aa9ed26ab5a9b321d2f9ad6c7607b88062433f0f111e220d64b42d68ed132ac",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.md b/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.md
new file mode 100644
index 0000000000000000000000000000000000000000..c866b9fe68c1fb50ab21f2a3aa4b13a439622337
--- /dev/null
+++ b/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.md
@@ -0,0 +1,105 @@
+Filing # 61812646 E-Filed 09/21/2017 10:53:55 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendant(s).
+MOTION TO COMPEL SUBSTANTIVE RESPONSES TO
+INTERROGATORIES SERVED DECEMBER 21, 2012
+by and through his undersigned attorneys, moves to compel Jeffrey
+Epstein's substantive responses to the attached Interrogatories over objections asserted by Jeffrey
+Epstein.
+WHEREFORE, Bradley J. |
+moves for an Order compelling Jeffrey Epstein to
+provide substantive tesponses to the attached Interrogatories served December 21, 2012 over
+objections asserted by Jeffrey Epstein.
+Movant counsel certifies, in good faith, they have conferred or attempted to
+confer with the person or party failing to make the discovery in an effort to secure
+the information or material without court action.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/21/2017 10:53:55 AM
+
+
+ADV. EPSTEIN
+Case No.: 502009CA040800XXXXMBAG
+Motion to Compel Substantive Answers to Interrogatories
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 2ist
+day of
+Sept.
+- 2017.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+561-383-9451
+Attorneys for
+J.
+NOT A
+NOT A CER
+2
+
+
+§ ADV. EPSTEIN
+Case No.: 502009CA040800XXXXMBAG
+Motion to Compel Substantive Answers to Interrogatories
+COUNSEL LIST
+William Chester
+, Esquire
+wcblaw@aol.com; wcblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+i, Esquire
+staff.efile@pathtojustice.com
+¡ Jaffe Weissing Edwards Fistos &
+Lehrman, P.L.
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+ax: (954)-524-2822,
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+Fred@FredHaddadLaw.com/
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954) 467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffiey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+3
diff --git a/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.receipt.json b/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4dc50dbfaa9b0c605b5b152515d7fb1749806242
--- /dev/null
+++ b/vision-fixhub/court-02/02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "02dfab56b33671520d98897393478536ff65ea82c36228a99a38ddd234676f8d",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c34531bbdcd1e98f53199d28fedb0009687eecb5c4e67c61dd29864f6a2e490c",
+  "output_sha256": "c4902a621ae45c780773ddfa9643b8817f5a4a6c8366a3bf8a4d607e4305c1e8",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.md b/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.md
new file mode 100644
index 0000000000000000000000000000000000000000..5b0778eba7f97899a2b3ff328c042deee6b2fe22
--- /dev/null
+++ b/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.md
@@ -0,0 +1,144 @@
+*** FILED: PALM BEACH COUNTY. FL SHARON BOCK, CLERK. ***
+Electronically Filed 06/25/2013 11:41:46 AM ET
+#291874/mep
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendant.
+/
+AMENDED WITNESS LIST OF COUNTERPLAINTIFE.]
+COMES NOW the Counterplaintiff, BRADLEY J.
+undersigned attorneys, and hereby lists his witnesses for trial as follows:
+1.
+COPY
+J.
+by and through his
+3.
+4.
+5.
+6.
+Jeffrey Epstein
+Avarell |
+140 W End Avenue, Apt. 30B
+New York, NY 10023
+Alan Dershowitz
+Hauser
+520
+1575 Massachusetts Avenue
+Cambridge,
+02138
+Donnie |
+1242 S.W. Briarwood Drive
+Port St. Lucie, FL 34985
+Robert Josefsberg, Esquire
+Podhurst Orseck, P.A.
+25 West Flagler Street, Suite 800
+Miami, FL 33130
+
+
+Amended Witness List of
+Case No: 50209A040800XXXXVBAC
+7.
+10.
+11.
+12.
+13.
+14.
+Howard Rubinstein
+1345 Avenue of the Americas, 30t* Floor
+New York, NY 10105
+All attorneys currently prosecuting claims against Jeffrey Epstein on behalf of
+other victims.
+All other named victims.
+All persons referenced in
+Motion for Summary Judgment.
+All witnesses listed by the Counterdefendant and Co-Defendant.
+All experts named by the Counterdefendant and Co-Defendant.
+Any and all Witnesses whose names appear in depositions, interrogatories, or
+requests for production provided by
+Impeachment and rebuttal witnesses as necessary, without waiving any objections
+thereto.
+EXPERTS
+Experts include all listed witnesses involved in the prosecution of civil claims against
+Jeffrey Epstein arising out of Epstein's serial abuse of minor females.
+Counterplaintiff reserves the right to amend this list prior to trial upon proper notice to
+the Counterdefendant.
+2
+
+
+Amended Witness List of|
+Case No.: 502009CA040800XXXXMBAG
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+E-Service on this 25 day of June, 2013 to all counsel on the attached list.
+Jack Scarola
+jsx@searcylaw.com; mep@searcylaw.com
+Florida Bar No.: 169440
+Searcy Denney Scarola Barnhart & Shipley
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone/
+CERTI
+(561) 686-6300
+(561) 383-9451
+Aftorneys for
+J.
+)
+NOT A
+3
+
+
+Amended Witness List of
+Case No.: 502002C A0408002XXXMBAC
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger &: Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Esquire
+staff.efile@pathtojustice.com
+Farmer, Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Fistos &
+Fred Haddad, Esquire
+haddadfim@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epl
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Bro
+Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+4
\ No newline at end of file
diff --git a/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.receipt.json b/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f15e7c53ab16db178c9ee4165979c5fc5498e44e
--- /dev/null
+++ b/vision-fixhub/court-02/02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -133,
+  "dataset": "marble-joined",
+  "doc_id": "02f10a09954e2ab08825853922079815068845c7077728ee229e4d6a3dbf8062",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "e603e4da934fd724ee53053d2771c94a325b528854b26b4052e60710ba58118d",
+  "output_sha256": "9eb2c4fcda2d13f84fa053fd0e37d89747b3fdb4c55e9eefa559cd77076a2c26",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0315fec1696a9a90ca6d7696d6096ce5fe7cd159f53ef243d05360ace1cfcacb.md b/vision-fixhub/court-02/0315fec1696a9a90ca6d7696d6096ce5fe7cd159f53ef243d05360ace1cfcacb.md
new file mode 100644
index 0000000000000000000000000000000000000000..58a36c24c0b6c1065699b209aefe4837d938a8dc
--- /dev/null
+++ b/vision-fixhub/court-02/0315fec1696a9a90ca6d7696d6096ce5fe7cd159f53ef243d05360ace1cfcacb.md
@@ -0,0 +1,281 @@
+*** FILED: PALM BEACH COUNTY.
+SHARON R BOCK, CLERK
+Filing # 15398907 Electronically Filed 06/30/2014 03:41:48 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA.
+CASE NO. 502009CA040800XXXXMB
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+-VS-
+COPY
+SCOTT ROTHSTEIN. individual
+and
+individually,
+Defendant/Counter-Plaintiffs.
+LIMITED DIRECTIONS TO CLERK
+TIFIED
+Defendant, BRADLEY J
+pursuant to Fla.R.App.P.
+9.200(a)(3), hereby directs the Clerk to only include in the Record-on-Appeal the
+following documents:
+DE-1 Complaint dated December 7, 2009;
+2.
+DE-8 Answer and Counterclaim dated December 21, 2009;
+DE-9 Answer and Counterclaim dated December 21, 2009;
+4. DE-19 Order dated January 26, 2010;
+5. DE-23 Motion to Dismiss dated February 26, 2010;
+6.
+DE-35 Answer to Counterclaim dated March 26, 2010;
+1
+
+
+DE-36 Reply to Affirmative Defenses dated March 16, 2010;
+8.
+DE-38 Motion for Judgment or Alternative Motion for Summary Judgment
+dated March 29, 2010;
+10.
+DE-62 Order on Epstein's Motion for Judgment on the Pleadings dated
+May 11, 2010;
+DE-102 Order of Dismissal dated August 10, 2010;
+11.
+DE-117 Statement of Undisputed Facts dated September 22, 2010;
+12.
+DE-118 Motion for Final Summary Judgment dated September 22, 2010;
+13.
+DE-127 Motion for Leave to Assert Claim for Punitive Damages dated
+October 19, 2010;
+14.
+15.
+DE-199 Motion for Reconsideration dated January 14, 2011;
+DE-241 Agreed Order
+Motion to Amend Complaint dated
+February 15, 2011;
+16.
+DE-289 Order on Case Management Status date April 12, 2011;
+17.
+DE-292 Amended Complaint dated April 13, 2011;
+18.
+DE-295 Motion to Dismiss dated April 20, 2011;
+19.
+DE-308 Reply in Opposition to Defendant/Counter-Plaintiff's Motion to
+Dismiss Amended Complaint dated May 13, 2011;
+20.
+DE-346 Order Granting Defendant/Counter-Plaintiff's Motion to Dismiss
+Amended Complaint dated July 25, 2011;
+21.
+22.
+DE-357 Second Amended Complaint dated August 22, 2011;
+DE-360
+Motion
+to Dismiss Second Amended Complaint dated
+August 22, 2011;
+2
+
+
+23.
+24.
+25.
+26.
+27.
+28.
+29.
+30.
+31.
+32.
+33.
+34.
+35.
+36.
+37.
+DE-374 Response in Opposition to Defendant/Counter-Plaintiff's Motion to
+Dismiss Corrected Second Amended Complaint dated September 22, 2011;
+DE-375Agreed Order Granting Defendant/Cross-Plaintiff's Ore Tenus
+Motion to Amend Counterclaim dated October 3, 2011;
+DE-377Amended Counterclaim dated October 4, 2011;
+DE-378 Order on Motion to Dismiss Plaintiff's Second Amended
+Complaint dated October 4, 2011;
+DE-380 Motion to Dismiss Amended Counterclaim dated October 21, 2011;
+DE-383 Answer & Affirmative Defenses to Second Amended Complaint
+dated October 28, 2011;
+DE-390 Renewed Motion for Final Summary Judgment dated
+November 4, 2011;
+DE-393 Statement of Undisputed Facts dated November 7, 2011;
+DE-402 Second
+ded Counterclaim dated November 29, 2011;
+DE-415 Motion to Dismiss Second Amended Counterclaim dated
+December 12, 2011;
+DE-473 Order on Damages Claimed in Second Amended Counterclaim
+dated May 8, 2012;
+DE-479 Third Amended Counterclaim dated May 21, 2012;
+DE-486 Answer & Affirmative Defenses Counterclaim dated
+June 14, 2012;
+DE-488 Reply to Affirmative Defenses dated June 19, 2012;
+DE-490 Motion to Compel Proper Response to the Counterclaims dated
+June 19, 2012;
+3
+
+
+38.
+39.
+40.
+41.
+42.
+44.
+45.
+46.
+47.
+48.
+49.
+50.
+DE-493 Motion to Strike Motion to Compel Proper Answer or Deem
+Unanswered Allegations Admitted dated July 3, 2012;
+DE-500 Order Granting Motion to Compel Proper Answer or Deem
+Unanswered Allegations dated July 24, 2012;
+DE-502 Answer & Affirmative Defenses Counterclaim dated
+August 2, 2012;
+DE-506 Motion to Continue Summary Judgment Hearing dated
+August 14, 2012;
+DE-507 Order Denying Plaintiff's Motion to Continue Summary Judgment
+Hearing dated August 16, 2012;
+DE-508 Notice of Voluntary Dismissal dated August 16, 2012;
+DE-516 Motion to File Amendment to Third Amended Counterclaim dated
+August 29, 2012;
+DE-522 Agreed Order Granting Motion to File Amendment to Third
+Amended Counterclaim dated September 5, 2012;
+DE-523 Answer to Amendment to Paragraph 32 of Amended Counterclaim
+dated September 18, 2012;
+DE-538 Motion for Order Granting Leave to Assert Claim for Punitive
+Damages Against the Counter-Defendant dated October 19, 2012;
+DE-554 Response to Memorandum in Opposition to Second Renewed
+Motion for Leave to Assert Claim for Punitive Damages dated
+December 10, 2012;
+DE-558 Order Granting Renewed Motion for Leave to Assert Claim for
+Punitive Damages dated December 18, 2012;
+DE-560 Fourth Amended Counterclaim dated January 9, 2013;
+4
+
+
+51.
+52.
+53.
+54.
+55.
+56.
+57.
+58.
+59.
+60.
+61.
+62.
+63.
+64.
+DE-569 Motion to Dismiss Fourth Amended Counterclaim dated
+January 22, 2013;
+DE-586 Order Dismissing Fourth Counterclaim dated February 11, 2013;
+DE-589 Reply to Affirmative Defenses dated February 22, 2013;
+DE-593 Answer & Affirmative Defenses dated February 26, 2013;
+DE-639 Agreed Order on Plaintiff/Counter-Defendant's Motion to
+Bifurcate Trial dated August 19, 2013;
+DE-673 Motion for Summary Judgment dated September 26, 2013;
+DE-675 Affidavit of Jeffrey Epstein dated September 26, 2013;
+DE-784 Response to Response in Opposition to Motion for Summary
+Judgment dated January 17, 2014;
+DE-785 Notice of Filing Correction to Response in Opposition to Motion
+for Summary Judgment dated January 21, 2014;
+DE-786 Reply to Defendant/Counter-Plaintiff's Response in Opposition to
+Motion for Summary Judgment dated January 22, 2014;
+DE-792 Notice of Supplemental Authority in Support of Motion for
+Reconsideration filed February 7, 2014;
+DE-800 Order Granting Counter-Defendant's Motion for Summary
+Judgment dated May 21, 2014;
+DE-801 Order Denying Counter-Plaintiff's Motions for Reconsideration of
+The Order Granting Motion for Summary Judgment dated May 21, 2014;
+DE-802 Final Judgment dated May 29, 2014.
+5
+
+
+STATEMENT OF JUDICIAL ACTS TO BE REVIEWED
+The judicial act which Defendant/Counter-Plaintiff anticipates to be
+reviewed is the granting of Plaintiff/Counter-Defendant's Jeffrey Epstein's Motion
+for Summary Judgment on the Counterclaim.
+I HEREBY CERTIFY that a true copy of the foregoing was furnished to all
+counsel on the attached service list, by email, on June 30, 2014.
+William B. C
+, Esq.
+SEARCY DENNY SCAROLA
+BARNHART & SHIPLEY, P.A.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+wbk@searcylaw.com
+NOT A CERe
+and
+BURLINGTON & ROCKENBACH, P.A.
+Courthouse Commons/Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+(561) 721-0400
+Attorneys for Defendant/Counter-Plaintiff
+pmb@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+By:_/s/ Philip M. Burlington
+PHILIP M. BURLINGTON
+Florida Bar No. 285862
+6
+
+
+SERVICE LIST
+Epstein v. Rothstein/
+Case No. 502009CA040800XXXXMBAG
+W. Chester
+Jr.. Esq.
+W. CHESTER
+JR., P.A.
+250 S. Australian Ave., Ste. 1400
+West Palm Beach, FL 33401
+(561) 655-4777
+wcblaw@aol.com
+wcbcg@aol.com
+Attorneys for Jeffrey Epstein
+Fred Haddad, Esq.
+FRED HADDAD, P.A
+1 Financial Plaza, Ste. 2612
+Fort Lauderdale, FL 33301
+(954) 467-6767
+haddadfm@aol.com
+Attorneys for Jeffrey Epstein
+Mark Nurik, Esq.
+LAW OFFICES OF MARC S. NURIK
+1 E. Broward Blvd., Ste. 700
+Ft. Lauderdale, FL 33301
+(954) 745-5849
+marc@nuriklaw.com
+Attorneys for Scott Rothstein
+No
+Jack Goldberger, Esq.
+ATTERBURY, GOLDBERGER
+& WEISS, P.A.
+250 So. Australian Ave., Ste. 1400
+West Palm Beach, FL
+(561) 659-8300
+jgoldberger@agwpa.com
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esq.
+TONJA HADDAD, P.A.
+315 SE 7th Street., Ste. 301
+Fort Lauderdale, FL 33301
+(954) 467-1223
+tonja @tonjahaddad.com
+etiling@tonjahaddad.com
+Attorneys for Jeffrey Epstein
+J.
+1, Esq.
+JAFFE, WEISSING,
+FISTOS & LEHRMAN, P.L.
+425 N. Andrews Ave.., Ste. 2
+Fort Lauderdale, FL 33301
+(954) 524-2820
+brad@pathtojustice.com
+Attorneys for Defendant
+7
diff --git a/vision-fixhub/court-02/0315fec1696a9a90ca6d7696d6096ce5fe7cd159f53ef243d05360ace1cfcacb.receipt.json b/vision-fixhub/court-02/0315fec1696a9a90ca6d7696d6096ce5fe7cd159f53ef243d05360ace1cfcacb.receipt.json
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diff --git a/vision-fixhub/court-02/0325f2aad68ecc38d98b5c552499918ef36fd9eee7c8a1e1f9f89d4aec36ad23.md b/vision-fixhub/court-02/0325f2aad68ecc38d98b5c552499918ef36fd9eee7c8a1e1f9f89d4aec36ad23.md
new file mode 100644
index 0000000000000000000000000000000000000000..9bd94344e0787e648c0c8820226124242323ba5b
--- /dev/null
+++ b/vision-fixhub/court-02/0325f2aad68ecc38d98b5c552499918ef36fd9eee7c8a1e1f9f89d4aec36ad23.md
@@ -0,0 +1,40 @@
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
+IN AND FOR PALM BEACH COUNTY
+CIVIL DIVISION
+CASE NO.: 502009CA040800 AG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, etc., et al.,
+•ANW.
+Defendant(s).
+REQUEST TO PRODUCE
+2010 DEC -1 PM 4: 40
+PALM BEACH COUNTY.
+. BOCK. CLEI
+CIRCUIT CIVIL
+ORDER ON PLAINTIFF/COUNTER DEFENDANT EPSTEIN'S
+OBJECTION TO DEFENDANT |
+DATED SEPTEMBER 16, 2010
+THIS CAUSE having come before the Court upon the Plaintiff/ Counter-
+Defendant, JEFFREY EPSTEIN's Objections to Request to Produce dated September 16,
+2010. The Court heard argument of counsel and is otherwise fully advised in the
+premises. Based upon the foregoing, it is
+CONSIDERED, ORDERED AND ADJUDGED that the Plaintiff/Counter-
+Defendant's Objection to Requests No. 1 and 4 are overruled. In all other respects the
+Objections are sustained at present.
+DONE AND ORDERED this
+15t
+day of December, 2010 at West Palm Beach,
+Palm Beach County, Florida.
+Xai
+DAVID F.
+CIRCUIT COURT JUDGE
+CACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FIL. 33409
+Beach, FL 33401
+| E. KNIGHT, ESQUIRE, 777 S. Flagler Dr., 901 |
+Point West, West Palm
+JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401
+VARC NURIK, ESQUIRE, One E. Broward Blvd., Suits
+GARY M.
+, JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301
diff --git a/vision-fixhub/court-02/0325f2aad68ecc38d98b5c552499918ef36fd9eee7c8a1e1f9f89d4aec36ad23.receipt.json b/vision-fixhub/court-02/0325f2aad68ecc38d98b5c552499918ef36fd9eee7c8a1e1f9f89d4aec36ad23.receipt.json
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+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0342cbfae127d563dd4be3e4dd05e7d9e574d6f70571324c889c63409387d321.md b/vision-fixhub/court-02/0342cbfae127d563dd4be3e4dd05e7d9e574d6f70571324c889c63409387d321.md
new file mode 100644
index 0000000000000000000000000000000000000000..1af75afe0539a77b37a2fc2fa40ac8a698d96454
--- /dev/null
+++ b/vision-fixhub/court-02/0342cbfae127d563dd4be3e4dd05e7d9e574d6f70571324c889c63409387d321.md
@@ -0,0 +1,180 @@
+*** FILED: PALM BEACH COUNTY, FL SHARON BOCK, CLERK. ***
+Electronically Filed 09/09/2013 02:37:54 PM ET
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff, Counter-Defendant,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually,
+Defendants/Counter-Plaintiffs.
+Case No. 50 2009 CA 040800XXXXMBAG
+Judge:
+COPY
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+MOTION TO DISQUALIFY DEFENDANT/COUNTER-PLAINTIFF
+J. EDWARDS AS CO-COUNSEL
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his
+undersigned counsel, hereby moves this Court to disqualify Defendant/Counter-Plaintiff
+"*) from acting as his own co-counsel at trial in this matter. In
+support of this Motion, Epstein states:
+INTRODUCTION
+Bradley 5, should be disqualified from acting as his own as co-counsel at
+trial in this matter because he is, irrefutably, a key witness, if not the key witness, in this
+trial. Since the inception of this litigation in November 2009,
+has been
+represented by Searcy Denney Scarola Barnhart & Shipley, P.A.
+did not file his
+Notice of Appearance as co-counsel for himself until March 2012; nearly three years after
+he filed his Counterclaim, which is the only cause of action currently pending.
+is
+listed as a witness on his own witness list, as well as Epstein's. Every issue in this case
+
+
+hinges, in essence, on actions taken by L
+is a featured witness in his case,
+and as such, an indispensable witness. [
+acting as his own co-counsel at trial in this
+case is prohibited by both the Rules Regulating the Florida Bar and prevailing case law.
+Accordingly,
+must be disqualified.
+MEMORANDUM OF LAW
+as the Plaintiff, will be a key witness at the trial of this matter, and his
+knowledge and testimony will concern crucial issues to be determined by the finder of fact.
+The dual role of an advocate and a witness has been found to prejudice the opposing party
+as the testimony by the attorney is bolstered because it comes from an advocate.
+AlliedSignal Recovery Trust v. AlliedSignal, Inc., 934 So. 2d 675, 678 (Fla. 2nd DCA
+2000). This Court has the authority to disqualify him pursuant to Rule 4-3.7 of the Rules
+Regulating the Florida Bar which provides, in pertinent part, as follows:
+(a) When Lawyer May Testify. A lawyer shall not act as advocate at a trial
+in which the lawyer is likely to be a necessary witness on behalf of the
+client except where:
+(1) the testimony relates to an uncontested issue;
+(2) the testimony will relate solely to a matter of formality and there is no
+reason to believe that substantial evidence will be offered in opposition to
+the testimony;
+(3) the testimony relates to the nature and value of legal services rendered in
+the case: or
+(4) disqualification of the lawyer would work substantial hardship on the
+client.
+Rule 4-3.7 R. REG. FLA. BAR. See also comments to Rule 4-3.7 ("[t]he problem can arise
+whether the lawyer is called as a witness on behalf of the client or is called by the opposing
+party.") "When it is shown that the attorney will be an indispensible witness or when the
+attorney becomes a "central figure' in the case, disqualification is appropriate." Fleitman
+V.
+, 691 So. 2d 37, 38 (Fla. 1st DCA 1997).
+2
+
+
+In Columbo v. Puig, 745 So. 2d 1106 (Fla. 3d DCA 1999), the appellate court, in
+analyzing this Rule and its applicability to disqualification, stated:
+Rule 4-3.7 of the Rules of Professional Conduct provides that a "lawyer
+shall not act as advocate at a trial in which the lawyer is likely to be a
+necessary witness on behalf of the client." The key words here are "at a
+trial." Therefore, it follows that a lawyer may act as an advocate at pre-trial
+(before the start of the trial) and post-trial (after the judgment is rendered)
+proceedings. See also ABA Comm. on Ethics and Prof l Responsibility,
+Informal Op. 89-1529 (1989) (lawyer may take depositions of witnesses and
+engage in other pre-trial proceedings as long as other requirements of the
+Rules are met).
+Id. at 1107. Likewise, in
+v. Pirthauer, 700 So. 2d 182 (Fla. 4th DCA 1997), the
+Fourth District Court of Appeal avowed that Rule 4-3.7 "generally prohibits lawyers from
+being advocates at trials at which they will be witnesses on matters of substance." [
+700 So. 2d at 183 (emphasis added). Such is the case here, as it is incontrovertible that the
+crux of
+causes of action against Epstein involves substantial and complex issues
+between the parties during the course of several years of litigation. Irrefutably, not only
+will
+testimony constitute "matters of substance," but it will be the focal point of
+the case, as both
+and Ep
+will be calling
+as a witness at trial.
+Unquestionably, therefore, Edwards's disqualification is mandated.
+For example, Edwards may be forced to testify regarding the credibility of his own
+case filed against Epstein. In Eccles v. Nelson, 919 So. 2d 658, 662 (Fla. Sth DCA 2006),
+the appellate court affirmed a trial court order disqualifying an attorney from trial where
+attorney's knowledge and involvement concerned crucial issues to be determined at trial.
+As in the Eccles case,
+testimony as a witness in the trial of this matter goes
+"well beyond a mere formality," mandating disqualification. See also City of Lauderdale
+Lakes v. Enterprise Leasing Co., 654 So. 2d 645 (Fla. 4th DCA 1995).
+3
+
+
+It is well established law in Florida that an attorney should be prohibited from
+being an advocate at trial where the attorney will be a material witness. Graves v. Lapi,
+834 So. 2d 359, 360 (Fla, 4th DCA 2003); Hubbard v. Hubbard, 233 So. 2d 150, 152 (Fla.
+4th DCA 1970); Cerillo v. Highley, 797 So. 2d 1288, 1289 (Fla. 4th DCA 2001). In fact,
+the Florida Supreme Court has held that the "dual capacity of counsel and witness in the
+trial of a cause, except as to formal matters, should be avoided if possible." Dudley v.
+Wilson, 152 Fla. 752, 754, 13 So. 2d 145, 146 (Fla. 1943). An attorney is an indispensable
+witness when the attorney has "crucial information in his possession which must be
+divulged." Cazares v. Church of Scientology of California, Inc., 429 So. 2d 348, 351 (Fla
+5th DCA 1983). An attorney is essential as a witness if the attorney's testimony could not
+be established in detail by another witness. See Laura McCarthy, Inc. v. Merrill-
+Realty/Cousins, Inc., 516 So. 2d 23, 23-4 (Fla. 3rd DCA 1987).
+Here,
+will be called as a witness by both Epstein and
+may be forced to testify regarding the credibility of his own case filed against Epstein.
+Without
+testimony, Edwards cannot establish his case. Additionally, just like
+the attorney in Eccles, Edwards is a witness as to all of the issues in dispute and is certainly
+an essential one. Further, his testimony would not be mere formality, as it would go to the
+substantive and contested matters of this case. Consequently, this Court must disqualify
+Tas co-counsel at trial in this matter.
+CONCLUSION
+Based on the arguments presented above, Plaintiff/Counter-Defendant Jeffrey
+Epstein
+respectfully
+requests
+that this Court enter an Order disqualifying
+4
+
+
+Defendant/Counter-Plaintiff
+as co-counsel in this matter, and grant such
+other and further relief as deemed necessary and proper.
+WE HEREBY CERTIFY that a true and correct copy of the foregoing was served
+upon all parties listed below, via Electronic Service, this September 9, 2013.
+Is/ Tonja Haddad Coleman
+Tonja Haddad Coleman, Esq.
+Fla. Bar No.: 0176737
+LAW OFFICES OF TONJA HADDAD, PA
+315 SE 7* Street
+Suite 301
+Fort Lauderdale, Florida 33301
+954.467.1223
+954.337.3716 (facsimile)
+Tonja@tonjahaddad.com
+NOT A CERTIFINO
+5
+
+
+SERVICE LIST
+CASE NO. 502009CA040800XXXXMBAG
+Jack Scarola, Esq.
+Searcy Denney Scarola et al.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+Jack Goldberger, Esq.
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+Suite 1400
+West Palm Beach, FL 33401
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+SANTED COPY
+Fred Haddad, Esq.
+1 Financial Plaza
+Suite 2612
+Fort Lauderdale, FL 33301
+CER
+NOT
+6
diff --git a/vision-fixhub/court-02/0342cbfae127d563dd4be3e4dd05e7d9e574d6f70571324c889c63409387d321.receipt.json b/vision-fixhub/court-02/0342cbfae127d563dd4be3e4dd05e7d9e574d6f70571324c889c63409387d321.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "718e51433c23e78223fe2cf7ca1bfee4f6f0ee59909b9922a1b92057520abcd9",
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+}
diff --git a/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.md b/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.md
new file mode 100644
index 0000000000000000000000000000000000000000..128ece0aa67966d8ec8a3b0ba3d89968f3ab6581
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+++ b/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.md
@@ -0,0 +1,67 @@
+JEFFREY EPSTEIN,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 502009CA040800XXXXMBAG
+VS.
+SCOTT ROTHSTEIN, individually,
+and
+individually.
+Defendants.
+2613 AUG 19
+ILED
+AGREED ORDER ON PLAINTIFF/COUNTER-DEFENDANT
+JEFFREY EPSTEIN'S MOTION TO BIFURCATE TRIAL
+THIS CAUSE is before the court upon Plaintiff/Counter-Defendant Jeffrey Epstein's
+Motion to Bifurcate Trial. The Court, having reviewed the Motion and being otherwise fully
+advised in the premises, it is hereby
+ORDERED AND ADJUDGED that Plaintiff/Counter-Defendant Jeffrey Epstein's
+Motion to Bifurcate Trial is hereby GRANTED. The trial shall be bifurcated into two stages.
+During the first stage the jury shall hear evidence regarding liability for actual damages, the
+amount of actual damages, and liability for punitive damages and shall make a determination
+on those issues. If warranted, the same jury shall then hear evidence relevant to the amount of
+punitive damages and shall make a determination as to the amount, if any, for which the
+Counter-Defendant is liable.
+DONE AND ORDERED his 16 ay of Augus l a We Paler, alm
+Beach County, Florida.
+Hand
+DAVID F.
+Circuit Judge
+Copies furnished to:
+All Counsel on attached Service List
+
+
+SERVICE LIST
+CASE NO. 502009CA040800XXXXMBAG/Epstein v. Rothstein, et al.
+Jack Scarola, Esq.
+Searcy Denney Scarola et al.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+Jack Goldberger, Esq.
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+Suite 1400
+West Palm Beach, FL 33401
+COPY
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+J.
+, Esq.
+Jaffe Weissing
+425 N Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301≤
+Fred Haddad, Esq.
+ATIFIED
+1 Financial Plaza
+Suite 2612
+Fort Lauderdale, FL 33301
+Tonja Haddad Coleman, Esq.
+Tonja Haddad, P.A.
+315 S.E. 7" Street
+Suite 301
+Fort Lauderdale, Florida 33301
+2
diff --git a/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.receipt.json b/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..0526fff955971d16742ab11a04739c9734a85778
--- /dev/null
+++ b/vision-fixhub/court-02/036e5ffd70365f10d61c37b10db9d6a4d7077aea723989a3e188aa781352dc71.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e4f0eba547402f325b621a097b7ee3d8ae65fdd4484b00aecbb1e045a5ff8435",
+  "output_sha256": "be523db15c5d97240de20f4cbdde3976a4b1f82a1ae165263cb101de4f24d3b6",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.md b/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.md
new file mode 100644
index 0000000000000000000000000000000000000000..8b738a3e2572363b9fe173735ac46479fbc4997e
--- /dev/null
+++ b/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.md
@@ -0,0 +1,64 @@
+IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION AG
+CASE NO. 502009CA040800XXXXMB
+Judge David F.
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiffs.
+FILED
+2012 MAR 12 PM 1: 16
+SHARON R. BOCK. CLE
+PALM BEACH COUN
+CIRCUIT CIVIL
+NOTICE OF HEARING
+(Uniform Motion Calendar)
+PLEASE TAKE NOTICE that the undersigned has set down for hearing before the
+Honorable David F.
+, one of the Judges of the above-styled Court, in Courtroom 9C at the Palm
+Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on Thursday,
+March 15, 2012 at 8:45 a.m. the following:
+PLAINTIFF JEFFREY EPSTEIN'S
+MOTION TO COMPEL AND AMEND PROTECTIVE ORDER
+I hereby certify that I have made a good faith attempt to resolve this matter prior to my
+noticing this Motion for hearing.
+PLEASE GOVERN YOURSELVES ACCORDINGLY.
+In accordance with the Americans With Disabilities Act, if you are a person with
+a disability who needs any accommodation in order to participate in this
+proceeding, you are entitled, at no cost to you, to the provision of certain
+assistance.
+Please contact Krista Garber, ADA Coordinator, in the
+Administrative Office of the Court, Palm Beach County Courthouse, 205 North
+Dixie Highway, Room 5.2500, West Palm Beach, Florida 33401; telephone
+
+
+Epstein v. Rothstein and
+Case No. 502009CA040800XXXXMB/Division AG
+Notice of Hearing /March 15, 2012
+number (561) 355-4380 at least 7 days before your scheduled court appearance,
+or immediately upon receiving this notification if the time before the scheduled
+appearance is less than 7 days; if you are hearing or voice impaired call 711.
+Dated: March 12, 2012.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and
+U.S. Mail on this 12* day of March, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart
+& Shipley, 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger,
+Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm
+Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward
+Boulevard, Suite 700, Fort Lauderdale, FL 33301.
+for
+NOT
+Sude d Tact #358134
+L. Ackerman, Jr.
+Florida Bar No. 235954
+BURNETT, P.A.
+Attorneys for Plaintiff Jeffrey Epstein
+901 |
+777 South Flagler Drive
+West Palm Beach, Florida 33401
+Telephone: (561) 802-9044
+Facsimile:
+(561) 802-9976
diff --git a/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.receipt.json b/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a4a524444ceca820279e0847845a5294581c1202
--- /dev/null
+++ b/vision-fixhub/court-02/038b29e631362510cdcd20e9336bda9556bc05a467a64fad9b9b7ac65ae01c67.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "1635a8ac502d173872c7c3ba7d7655432aecb1083d166e6c2879a5f4056979bb",
+  "output_sha256": "f0a603ea098ca5481c34ccf4dfa05a32d579585d4752c3d7dd58342ca8ef8e64",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.md b/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.md
new file mode 100644
index 0000000000000000000000000000000000000000..54c0cecfcc32b4f754f81f5134d5b4d5edd4fde1
--- /dev/null
+++ b/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.md
@@ -0,0 +1,118 @@
+Filing # 80850016 E-Filed 11/15/2018 12:58:29 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants.
+NOTICE OF CANCELLATION OF HEARING
+COPY
+YOU ARE HEREBY NOTIFIED that the undersigned has cancelled the following
+hearing:
+DATE:
+TIME:
+JUDGE:
+PLACE:
+ROOM#:
+November 20, 2018
+8:45 a.m.
+Honorable Donald Hafele '
+205 N. Dixie Highway, West Palm Beach, FL 33401
+10.1216
+SPECIFIC TTERS TO BE HEARD: Motion to Strike Jeffrey Epstein's Motion for an In
+Camera Inspection of 30 E-Mails.
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. 11/15/2018 12:58:29 PM ***
+
+
+Madv. Epstein
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 157
+day of November, 2018.
+/s/ David P. Vitale Jr.
+JACK SCAROLA
+Florida Bar No.: 169440
+DAVID P. VITALE JR.
+Florida Bar No.: 115179
+Attorney E-Mail(s): jsx@searcylaw.com and
+mmccann@searcylaw.com
+Primary E-Mail: ScarolaTeam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+IJ.
+NOT A CE.
+NOT A CER
+2
+
+
+adv. Epstein
+COUNSEL LIST
+J.
+Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+[FIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateL.aw.com;kbt@FLAppellatLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+ards
+Berard Rockenbach, Esquire
+kara@linkrocklaw.com; tbermudez@flacivillaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33409
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Scott J. Link, Esquire
+Scott@linkrocklaw.com; Tina@linkrocklaw.com
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+3
+
+
+Hadv. Epstein
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys
+for
+Scott
+Rothstein
+NOT A CERTIFIED COPY
+4
\ No newline at end of file
diff --git a/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.receipt.json b/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9b5f098c4c812d7b5d4091874d47aa5b42d294fe
--- /dev/null
+++ b/vision-fixhub/court-02/03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -250,
+  "dataset": "marble-joined",
+  "doc_id": "03bd71bc4d29d5409c1d4947f7e90bb7c4b50bcf6cfaf90bea74cac00d9b8ad3",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "fcf46db93ff991b5e9639d908325d3d913dbfbfe9bb942df4b96ae168b837f87",
+  "output_sha256": "94d6a9f4ecbdb5360ae7304d2d4fa7237380f7e4482af1ae3099bcc34133b68b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.md b/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.md
new file mode 100644
index 0000000000000000000000000000000000000000..39c58611ed6d3bbb79074a6f13d8d26b8e4b5a4b
--- /dev/null
+++ b/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.md
@@ -0,0 +1,95 @@
+Filing # 80625578 E-Filed 11/09/2018 03:15:25 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+COPY
+NOTICE OF FILING CONFIDENTIAL COURT RECORDS UNDER SEAL
+Counter-Defendant, Jeffrey Epstein ("Epstein"), pursuant to 15" Judicial Circuit
+Administrative Order No. 2.303-3/18 and this Court's November 6, 2018, Order on Briefing for
+In Camera Inspection (9 5) files under seal Epstein's Confidential Memorandum in Support of
+Epstein's Motion for In Camera Inspection of 30 E-mails.
+NOT A
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/09/2018 03:15:25 PM
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on November 9, 2018, through the Court's e-filing portal pursuant to Floridi
+Rule of Judicial Administration 2.516(b)(I) and that a copy of the sealed envelope containing th
+Confidential Memorandum is being hand delivered to Jack Scarola, Searcy, Denny, et al., 2139
+Palm Beach Lakes Boulevard, West Palm Beach, FL 33409.
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 930
+West Palm Beach, Florida 33401
+(561) 847-4408; (561) 855-2891 [fax!
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Counsel for Counter-Defendant Jeffrey Epstein
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J. Edwards
+SERVICE LIST
+Philip M. Burlington
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+pmb@FLAppellateLaw.com
+hii@EtAppellatctav.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+2
+
+
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Paul Cassell
+383 S. University St.
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.edu
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+NOT A CERTAIN ENE
+3
diff --git a/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.receipt.json b/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..fdb02073b013901d741024793290a74bed8bc27f
--- /dev/null
+++ b/vision-fixhub/court-02/03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "03c39d09d47d6b509dc2f4b89a7dbfbf0445334b24f2bf8462bb9eaa1dac9549",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "82edc6a2cec16e15dfafa45e9c8bba310fbe21e35dd8638641a28995a19a911a",
+  "output_sha256": "003ec230103d214e41337561db337a5aeb28759848536ecb13072ca60219a451",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.md b/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.md
new file mode 100644
index 0000000000000000000000000000000000000000..a50285456dda97e605e83b946384a40a8e43ff53
--- /dev/null
+++ b/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.md
@@ -0,0 +1,145 @@
+Filing # 68019321 E-Filed 02/15/2018 01:47:25 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendant,
+COPT
+COPY
+MOTION FOR ADVERSE INFERENCE INSTRUCTIONS REGARDING
+EPSTEIN'S FIFTH AMENDMENT ASSERTIONS TO FINANCIAL DISCOVERY AND
+APRIL 15, 2011 REQUEST TO PRODUCE
+Counter-Plaintiff,
+J. L
+by and through his undersigned counsel,
+hereby files this Motion for Adverse Inference Instructions Regarding Epstein's Fifth Amended
+Assertions to Financial Discovery and April 15, 2011 Request to Produce, and as grounds therefor
+states as follows:
+Epstein has raised his Fifth Amendment privilege against self-incrimination with
+respect to all net worth discovery regarding punitive damages. Pursuant to Judge
+November 15, 2013 Order, the Court deferred on the issue of whether
+is entitled to an
+adverse inference jury instruction as a result of Plaintiff/Counter-Defendant's Fifth Amendment
+assertions.
+2.
+Specifically, Epstein has raised his 5' Amendment privilege as to all net worth
+discovery, including in the following pleadings:
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 02/15/2018 01:47:25 PM
+
+
+|ADV. EPSTEIN
+* Motion for Adverse Inference Jury Instruction
+
+a. 719/13
+Amended Response to Punitive Damage Production Request [all
+objected to on basis of privilege against self-incrimination]
+b. 7/10/13
+Amended Responses to Net Worth Interrogatories [all objected to
+on basis of privilege against self-incrimination]
+c. 3/27/13 Responses to Request for Admissions [requests 3-13 objected to on
+the basis of the privilege against self-incrimination]
+3.
+It is well-settled in Florida that "a court may draw an adverse inference against a
+party in a civil action who invokes the Fifth Amendment privilege against self-incrimination." See
+Atlas v. Atlas, 708 So. 2d 296, 299 (Fla. 4th DCA 1998) (citing Baxter v. Palmigiano, 425 U.S.
+308 (1976).
+4.
+is therefore entitled to an adverse inference jury instruction as to all Fifth
+Amendment assertions concerning punitive damage net worth discovery. See id.
+In addition, Epstein objected to
+¡ April 15, 2011 Request to Produce on the
+basis of his Fifth Amendment privilege. That discovery request sought communications between
+Epstein (and his agents) and any government official which relate to Epstein's sexual molestation
+of children, as follows:
+All documents* constituting, reflecting, or relating to communications between
+Epstein| or any agent of [Epstein], on the one hand, and ... any prosecuting, lav
+enforcement, and/or government entity which communication relates directly or
+indirectly to any allegation of illegal activity or tortuous conduct in which Epstein
+is alleged to have engaged.
+
+
+ADV. EPSTEIN
+J.
+Motion for Adverse Inference Jury Instruction
+
+6.
+By raising his Fifth Amendment privilege in this civil proceeding,
+is
+entitled to an adverse inference jury instruction that communications exist between Epstein and
+the government evidencing that Epstein committed the crimes he was accused of committing.
+WHEREFORE, Counter-Plaintiff
+respectfully requests that this Court
+enter an Order granting this Motion for Adverse Inference Instructions Regarding Epstein's Fifth
+Amended Assertions to Financial Discovery and April 15, 2011 Request to Produce, and awarding
+any such further relief as the Court deems just and proper given the circumstances.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+NOT A
+day of February, 2018.
+Tal Canda
+JACK SCARÓLA
+Florida Bar No.: 169440
+DAVID P. VITALE JR.
+Flørida Bar No.: 115179
+Attorney E-Mail(s): jsx@searcylaw.com and
+mmccann@searcylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+_1.L
+
+
+ADV. EPSTEIN
+
+Scott J. Link, Esq.
+Link & Rockenbach, P.A.
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: 561-727-3600
+Fax: 561-727-3601
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+COUNSEL LIST
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com;
+kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J.
+, Esquire
+statf.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Marc S. Nurik, Esquire
+maculary Cord. Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A
\ No newline at end of file
diff --git a/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.receipt.json b/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6cdf0069c8b7a6aebc997422299ce17706bd442d
--- /dev/null
+++ b/vision-fixhub/court-02/03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "dataset": "marble-joined",
+  "doc_id": "03d699c482a323fc55a2bc3b4fd05f995f7ea61cc95e0d47020f92eb092c83b0",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "2f256f81ba2d8b7bc9e8ebf2c0a24b767deac07aeba400d1c1e111044b92c90d",
+  "output_sha256": "6e9f1b01f5d5476f784fe84980474d40b41097f49dea12ea69835969e4edc484",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.md b/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.md
new file mode 100644
index 0000000000000000000000000000000000000000..914a479ee83b5cbf1e8cf45a271fe70b0e8e171a
--- /dev/null
+++ b/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.md
@@ -0,0 +1,90 @@
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
+IN AND FOR PALM BEACH COUNTY
+CIVIL DIVISION
+CASE NO.: 502009CA040800 AG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, etc., et al.,
+Defendants).
+SHARON R. BOCK. CLERK
+PALM BEACH COUNTY. FL
+CIRCUIT CIVIL 5
+2013 APR -4 PM. 4: 02
+FILED
+ORDER SETTING HEARING
+THIS CAUSE came before the Court in
+upon the Plaintiff/Counter-
+Defendant, JEFFREY EPSTEIN's Motion for Clarification of Court's Order Dated 3/11/13,
+and the Court having reviewed the matter, it is
+ORDERED AND ADJUDGED that a hearing on Plaintiff/Counter-Defendant,
+JEFFREY EPSTEIN's Motion for Clarification of Court's Order Dated 3/11/13 is
+scheduled in the above-entitled matter for Wednesday, April 10, 2013 at 8:15 a.m.
+before the undersigned, at the Palm Beach County Courthouse, 205 N. Dixie Highway,
+Courtroom 9C, West Palm Beach, FL 33401. (15 mins. reserved)
+Please Note:
+1. The JA cannot cancel this hearing unless the issue is resolved.
+2. No add-ons are permitted without contacting the JA
+3. Any Memorandums submitted are limited to 10 double spaced pages and must
+reference the hearing date.
+4. Any materials submitted are due at least 7 days prior to the hearing.
+5. The moving party is required to bring to the hearing a blank proposed order with
+copies and envelopes for all counsel/pafties.
+DONE AND ORDERED at West Palm Boach, Florida th
+day of April,
+2013.
+DAVID
+CIRCUIT COURT JUDGE
+Copy furnished:
+See attached.
+
+
+JACK SCAROLA, ESQUIRE
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+JACK GOLDBERGER, ESQUIRE
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+MARC NURIK, ESQUIRE
+One East Broward Blvd., Suite 700
+Ft. Lauderdale, FL 33301
+J.
+ESQUIRE
+425 North Andrews Ave., Suite 2
+Ft. Lauderdale, FL 33301
+FRED HADDAD, ESQUIRE
+One Financial Plaza, Suite 2612
+Ft. Lauderdale, FL 33301
+TONJA HADDAD COLEMAN, ESQUIRE
+315 S.E. 7th St., Suite 301
+Ft. Lauderdale, FL 33301
+NOT A CERTIFIED COPY
+
+
+This notice is provided pursuant to Administrative Order No. 2.207-2/12
+"If you are a person with a disability who needs any accommodation in order
+to participate in this proceeding, you are entitled, at no cost to you, to the
+provision of certain assistance. Please contact Dominique March, Americans
+with Disabilities Act Coordinator, Palm Beach County Courthouse, 205 North
+Dixie Highway West Palm Beach, Florida 33401; telephone number (561)
+355-4380 at least 7 days before your scheduled court appearance, or
+immediately upon receiving this notification if the time before the scheduled
+appearance is less than 7 days; if you are hearing or voice im paired, call 711."
+"Si usted es una persona minusválida que necesita algún acomodamiento para
+poder participar en este procedimiento, usted tiene derecho, sin tener gastos
+propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en
+contacto con Dominique March, 205 N. Dixie Highway, West Palm Beach,
+Florida 33401; teléfono número (561) 355-4380, por lo menos 7 días antes de
+la cita fijada para su comparecencia en los tribunales, o inmediatamente
+después de recibir esta notificación si el tiempo antes de la comparecencia que
+se ha programado es menos de 7 días; si usted tiene discapacitación del oído o
+de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan
+pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon
+pou jwen kèk èd. Tanpri kontakte Dominique March, kòòdonatè pwogram
+Lwa pou ameriken ki Enfim yo nan Tribinal Konte Palm Beach la ki nan 205
+North Dixie Highway, West Palm Beach, Florida 33401; telefon li se (561)
+355-4380 nan 7 jou anvan dat ou gen randevou pou parèt nan tribinal la,
+oubyen imedyatman apre ou fin resevwa konvokasyon an si lè ou gen pou w
+parèt nan tribinal la mwens ke 7 jou; si ou gen pwoblem pou w tande oubyen
+pale, rele 711.ª
diff --git a/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.receipt.json b/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..243731411ff801b33fc51e6865b7c50c3428a325
--- /dev/null
+++ b/vision-fixhub/court-02/04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "04182f570505385395547a56741c5df3bc0714adc5fb5244bf32402655f42eb0",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e202d32aebc39ed784ddfbfc4cf6a68ef0d22cb1ae5247c894c0f7d762073e32",
+  "output_sha256": "81b29e594ac9f30cc51b52979a936b2a9c421e6867b61260c9cedf647d1c8589",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.md b/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.md
new file mode 100644
index 0000000000000000000000000000000000000000..4a074f8759e0cbe51f1b08191308d156f1a2c8d9
--- /dev/null
+++ b/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.md
@@ -0,0 +1,46 @@
+COURTROOM 10D IN 11A JUDGE DONALD HAFELE
+CASE NO - 2009CA040800
+THE HONORABLE DONALD HAFELE, PRESIDING
+CASE NO.502009CA040800 XXXXMB
+DEPUTY CLERK: NICOLA
+D.C.
+COURT DEPUTY: MICHAEL DELONG, D.S.
+COURT REPORTER: NANCY PAULSEN - PALM BEACH REPT'G (941)468-2779
+COUNTER-PLAINTIFF
+ATTORNEY(S)
+JACK SCAROLA, ESQ.
+SIA BAKER-BARNES, ESQ.
+DAVID P. VITALE, JR., ESQ.
+ESQ.
+COUNTER-DEFENDANT
+JEFFREY EPSTEIN
+ATTORNEY(S)
+SCOTT LINK, ESQ.
+JACK A. GOLDBERGER, ESQ.
+KARA BERARD ROKENBACH, ESQ.
+JURY TRIAL
+CLERK NOTES
+(12/4/2018)
+TUESDAY - DECEMBER 4, 2018
+9:28
+9:29
+9:30
+9:31
+9:34
+9:37
+9:45
+Court in session
+Bench Conference
+Judge announced case for the Record
+Appearances for the Record
+Atty Scarola addressed the court obo CPLTF
+Settlement
+announced
+Atty Link addressed the court obo CDFT Epstein/apology announced
+Judge addressed the court
+COURT ADJOURNED
+FILED
+DEC 0 4 2018,9:4SAM
+SHARON R. BOCK
+CLERK & COMPTROL 2?
+1
diff --git a/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.receipt.json b/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..9e4526c4112951bca897a08ca116062c0ccd87a5
--- /dev/null
+++ b/vision-fixhub/court-02/043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -12,
+  "dataset": "marble-joined",
+  "doc_id": "043bf38d942f92e04f83bab44a06f5362deb3cc2b07adc22ac23ae830859d119",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f595887d4d06ad6a227b2a733364e07c2601726d1a24431e13c09cf33c616b4a",
+  "output_sha256": "7fc09e975df1a65a025a235707a9c5c57618445f4767066fc2e617ba18ad075b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.md b/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.md
new file mode 100644
index 0000000000000000000000000000000000000000..c09127a9e6ffb316b27e524885abd05bd631bf03
--- /dev/null
+++ b/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.md
@@ -0,0 +1,78 @@
+i. $
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants).
+MOTION TO SCHEDULE DEFENDANT/COUNTER-PLAINTIFF'S
+PENDING MOTIONS FOR HEARING
+Defendant/Counter-plaintiff,
+J.
+, moves this Honorable Court to
+set the Defendant/Counter-plaintiff's pending motions for hearing and in support of this motion
+would show that the Plaintiff/Counter-defendant's counsel has been unresponsive and
+uncooperative in multiple attempts to set these matters without the need for Court intervention.
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+Fax and U.S. Mail to all Counsel on the attached list this Wa
+To Fearch
+Jack Scarola
+Florida Bar No.: 169440
+Searey Denney Scarola Barnhart & Shipley
+2739 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for
+SHARON R. BOCK. CLERK
+PALM BEACH COUNTY
+CIRCUIT CIVIL /PROBATE
+2011 AUG 29 PH 4: 05
+
+
+Case No.: 502009CA040800XXXXMBAG
+Motion to Schedule Defendant/Counter-plaintiff's pending motions for hearing
+COUNSEL LIST
+Weinberg, Esquire
+Weinberg, P.C.
+20 Park Plaza, Suite 1000
+Suffolk,
+_ 02116
+Phone: (617) 227-3700
+Fax: (617) 338-9538
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+1 Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Marc S. Nurik, Esquire
+• Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954) 745-5849
+Fax: (954) 745-3556
+H. Ackerman, Jr., Esquire
+Burnett, P.A.
+901
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561) 802-9044
+Fax: (561) 802-9976
+Fistos &
+ERTIFIED COPY
diff --git a/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.receipt.json b/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6d3e6245cb9443f57cfab3eb7d187e8410d0ae4c
--- /dev/null
+++ b/vision-fixhub/court-02/0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "0462f4f2b2e816b84d33bf4985626d52260164001623896b9d38c8f56c54b90f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "9434d120b479aaf2a081617ab4bcfac93a0a0fba2a310b52c64e7cdc586c4919",
+  "output_sha256": "35f57f3f542b78188a3fc45230d46cb33704ed255b88618151aafe3bfa636a87",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0472c8705fb48a6f9bdba668f0594dfbf7d5a62202ed5834a02082bc62a2c092.md b/vision-fixhub/court-02/0472c8705fb48a6f9bdba668f0594dfbf7d5a62202ed5834a02082bc62a2c092.md
new file mode 100644
index 0000000000000000000000000000000000000000..63b822e3cb1a76021aec823211302bbe4fa00dc9
--- /dev/null
+++ b/vision-fixhub/court-02/0472c8705fb48a6f9bdba668f0594dfbf7d5a62202ed5834a02082bc62a2c092.md
@@ -0,0 +1,10505 @@
+Filing # 68802811 E-Filed 03/05/2018 03:26:43 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN. individividually, and
+L.M., individually,
+Defendants.
+COPY
+MOTION TO STRIKE EPSTEIN'S UNTIMELY SUPPLEMENTAL EXHIBITS AND TO
+STRIKE ALL EXHIBITS AND ANY REFERENCE TO DOCUMENTS CONTAINING
+PRIVILEGED MATERIALS LISTED ON
+PRIVILEGE LOG
+Counter-Plaintiff
+through undersigned counsel, hereby files this Motion to Strike
+Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to
+Documents Containing Privileged Materials Listed on
+Privilege Log, and in support
+states as follows:
+Summary
+In a transparent attempt to either conduct trial by ambush or sufficiently muddy the waters
+to request yet another continuance, Epstein has sporadically disclosed new trial exhibits over the
+past month in direct violation of multiple orders of this Court concerning both the deadline to
+disclose exhibits and the prohibition against general, catch-all exhibit categories. On February 6,
+2018,
+was required to file his General Objection to Untimely Composite Exhibits,
+attached hereto as Exhibit "A,' in order to preserve his objections to this highly prejudicial conduct.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/05/2018 03:26:43 PM
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+Finally, on February 28, 2016, undersigned counsel sent the following communication to Epstein's
+counsel:
+Your recent efforts to add documents not specifically identified to earlier listed
+categories prompts me to remind you that Judge Hafele has required that
+documents be identified in a manner that enables the opposing party to know in
+advance exactly which documents are intended to be offered in evidence. We
+assume you have complied with that directive and are relying on that compliance
+On March 2, 2018, only two days later and on the eve of trial, Epstein disclosed for the
+first time 198 new trial exhibits consisting of at least forty-nine (49) privileged e-mails generated
+when
+was at Rothstein Rosenfeldt Adler ("RRA) and engaged in actively prosecuting
+both civil claims against Epstein and the still-pending CVRA challenge to Epstein's extraordinary
+sweetheart plea deal. These e-mails have been listed on Edwards' privilege log since February
+23, 2011. Epstein filed
+I 2011 privilege log with this Court on April 11, 2012 and has not
+obtained an order either overruling these privilege assertions or compelling production of these
+documents. At this time, it is unknown exactly how Epstein obtained these privileged materials,
+although it is clear that he did so in secret and has waited until the last possible moment to reveal
+that he is improperly in possession of
+privileged materials.
+The late disclosure of these trial exhibits is in direct violation of the Court's July 20, 2017
+Order, the Court's December 5, 2017 oral ruling (concerning trial exhibits not-yet-produced and
+prohibiting general, catch-all exhibits) and the Court's January 16, 2018 ruling. Furthermore,
+despite the e-mail correspondence being listed on
+2011 Privilege Log, it is now clear
+that Epstein surreptitiously obtained these privileged communications years ago and his counsel
+failed to comply with their ethical obligations once coming into possession of clearly privileged
+materials listed on
+privilege log to immediately relinquish possession of those materials.
+2
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+Undersigned counsel (as well as Paul Cassell, Esq., as counsel for L.M., E.W. and Jane Doe) has
+since notified Epstein's counsel, Scott Link and Kara Rockenbach, that they are in possession of
+privileged materials and has requested that counsel take all ethically appropriate steps to turn over
+this information. That repeated request has been repeatedly denied.
+requests that the Court strike all late disclosed trial exhibits, including specifically
+but not limited to the privileged materials identified on
+2011 Privilege Log, which
+Epstein's counsel has acknowledged have been in the possession of Epstein lawyers for years,
+Pepsin anyes for years
+since at least 2011.
+further requests that the Court strike and preclude Epstein's counsel
+from making any reference to materials that are clearly attorney-client and work-product
+privileged and which have been listed on Edwards' privilege log for seven (7) years. In addition
+to the violation of multiple Court orders and the unethical possession of these materials, not a
+single e-mail has any relevance whatsoever because: (1) Epstein did not have possession of them
+prior to instituting this malicious lawsuit against
+and therefore could not have relied on
+them to support probable cause, (2) Epl
+has never testified that he relied upon them to continue
+this malicious lawsuit against Edwards, and (3) the communications generated in the course of the
+prosecution of claims against Epstein relate to conduct subject to the absolute protection of the
+litigation privilege.
+Finally,
+requests that the Court require Epstein's counsel to show cause why they
+should not be sanctioned for their attempt to conduct trial by ambush by using improperly obtained
+privileged materials and then unethically refusing to destroy or turn over all copies of the
+privileged materials once being put on notice of same. Any subsequent sanction should include at
+a minimum an award of all costs and fees incurred in dealing with these issues.
+3
+
+
+Motience So Documenis Continy Friendatis i sand or Sike siegend An
+Privilege Log
+The Court Orders Violated by Epstein
+On July 20, 2017, the Court entered its Order Specially Setting Trial, which set the
+case for trial beginning on December 5, 2017.
+In its Order, the Court required that the Pre-Trial Stipulation include "each party's
+numbered list of trial exhibits with specific objections, if any, to schedules attached to the
+stipulation." (emphasis added). The Court made clear that the parties would be "strictly limited
+to exhibits ... disclosed ... on the schedules attached to the Pre-Trial Stipulation ...absent
+agreement specifically stated in the Pre-Trial Stipulation or order of the Court upon good cause
+shown." (emphasis added).
+Thus, the Court's July 20, 2017 Order limited the parties to only those trial exhibits
+that were specifically identified and disclosed on the Pre-Trial Stipulation.
+In October and November 2017, the parties began exchanging Exhibit Lists and
+producing proposed exhibits in connection with the Court's Order. Epstein's Exhibit List listed as
+Exhibit #13, "miscellaneous," the broadest catch-all provision possible:
+All documents produced by any party or non-party in this matter.
+At the December 5, 2017 hearing, the Court instructed that any identified exhibits
+not previously produced must be provided to opposing counsel by no later than December 19,
+2017. See, c.g., 12/5/17 Tr. at 225:21-226:4. The Court also cautioned that general "catch-all"
+exhibit categories would not be permitted and that, instead, the specific documents covered by
+4
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+such exhibits must be separately identified and produced. See, e.g., 12/5/17 Tr. at 223:11 - 225:14.
+The message to the parties was clear: trial by ambush would not be permitted.'
+6.
+On December 19, 2017, Epstein produced copies of certain listed exhibits pursuant
+to that directive.
+emails were listed on
+8.
+Epstein's Exhibit #13 contained twenty-seven (27) RRA emails. None of these
+April 12, 2012 Privilege Log.
+On December 22, 2017, the parties filed the Pre-Trial Stipulation. Epstein's Exhibit
+List was attached to the Pre-Trial Stipulation."
+Thus, pursuant to the Court's December 5, 2017 ruling and the December 19, 2017
+exhibit exchange, Epstein's Exhibit #13 was comprised of the 27 emails that had been specifically
+identified and produced.
+10.
+Moreover, pursuant to the Court's July 20, 2017 Order Specially Setting Trial,
+Epstein was "strictly limited" to those 27 specific documents absent a showing of good cause,
+which would necessarily require the filing of some motion seeking relief from the Court.
+Epstein, as has been consistent over the past few months, chose to ignore these
+Court Orders and instead began piecemeal producing additional proposed exhibits throughout the
+month of February, which finally prompted undersigned counsel to send correspondence to
+Epstein's counsel objecting to these flagrant violations of the Court's rulings. See Ex. 'A'.
+December 19, 2017.
+5
+
+
+Case No. 502009CA040800XXXXMBAG|
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+12.
+Epstein's continued violation of the Court's Orders culminated on March 2, 2018,
+with the eve-of-trial production of 198 new emails under Exhibit #13, which include at least fortynine (49) privileged emails that are listed on
+2012 Privilege Log. This improper,
+prejudicial, and unethical conduct should not be permitted by the Court.
+Timeline of the Privileged Materials at Issue
+13. In order to orient the Court regarding
+2011 Privilege Log,
+has
+compiled the following timeline concerning the privileged e-mail communications at issue.
+Because the privileged materials at issue are e-mail communications from RRA, Epstein originally
+sought these records in the Bankruptcy Court to be produced by the Trustee, appointed to oversee
+the RRA bankruptey proceeding.
+has highlighted the key State Court docket entries for
+the Court's convenience:
+Bankruptcy
+Court
+April 17, 2010
+Bankruptey
+Court
+July 19,2010
+Bankruptey
+Court
+August 13, 2010
+Epstein propounded a broad subpoena to the Trustee for RRA as an interested
+party in the bankruptcy case of In re: Rothstein Rosenfeldt Adler, 09-34791-
+RBR, requesting tens of thousands of emails (the subpoena was directed to the
+bankruptcy trustee because the trustee was in possession of all RRA emails).
+Epstein filed a Motion to Compel that production from the trustee. DE 807.
+EM (one of Epstein's victims) filed an objection and amended motion for
+protective order, DE 819, explaining that the emails requested were barred
+from disclosure based on privilege and relevance grounds.
+he emails to a special
+Bankruptey
+Court
+September 20, 2010
+After having received 27,590 emails, Special |
+larification of the Order and made suggestions that LM's attorneys, whic
+vere in a better position to create a privilege los
+" Copy attached hereto as Exhibit 'B'.
+6
+
+
+Bankruptey
+Court
+Ladv. Epstein
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+September 27, 2010
+moved for protective order through counsel Jack Scarola, adopting
+LM's arguments for a protective order and invoking work-product privilege.
+DE 1022.
+Bankruptey
+Court
+Bankruptcy
+Court
+Bankruptey
+Court
+September 30, 2010
+October 13, 2010
+October 15, 2010
+Bankruptey
+Court
+October 20, 2010
+Bankruptcy
+Court
+November 23, 2010
+December 16, 2010
+Bankruptey
+Court
+December 22, 2010
+Contruptcy
+January 25, 2011
+January 26, 2011
+February 8, 201J
+Bankruptey
+February 15, 2011
+Court
+Conkruptey
+February 23, 2011
+LM joined in that DE 1022 motion and requested further clarification. DE
+1038.
+Hearing on Motion to Clarify before Robert Carney.
+The bankruptcy court entered an Order which clarified its earlier Order, DE
+Loes, regurine that itos she anvide the mails at she to
+Jaffe
+representing LM) and requesting FJWEFL prepare the log. The order also
+provided procodure for ihe special masco fo holds hearing about ascetions
+Bankruptcy court cancelled the hearing on the motion for protective order.
+DE 1077.
+Epstein files his amended privilege log.
+LM filed a motion requesting a stay of the Order directing the preparation of
+a privilege log until after the time when the State court ruled on the then
+pending Motion for Summary Judgment. DE 1236.
+Bankruptcy court entered an order extending the time for production of the
+privilege log until January 31, 2011. DE 1260.
+FJWEFL produced 8,408 pages of non-privileged documents to Epstein.
+FIWEFL served a privilege log, and the sufficiency of that log was challenged
+by Epstein in the bankruptcy court. DE 1442.
+Epstein filed a Motion to Compel/Motion to Determine if Privilege Claims are
+Waived for failure to provide a privilege log.
+FJWEFL filed a privilege log in the Bankruptcy Court.
+FJWEFL filed an updated privilege log (the current privilege log)
+detailing the emails where privilege was being maintained. In
+addition to filing the privilege log, FJWEFL produced to counsel for
+Epstein, 12,711 pages of documents divided into two separate
+categories respectively labeled "attorneys eyes only" and "
+Jaffe Irrelevant E-Mails." Two boxes of "attorneys eyes only"
+documents were produced containing 1,829 pages of documents in the
+first box and 3,198 pages of documents in the second box. Two
+7
+
+
+L adv. Epstein
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+I Privilege Log
+additional boxes of l
+Jaffe Irrelevant E-Mails" were also
+produced containing 3,804 pages of documents in the first box and
+3,880 pages of documents in the second box.
+March 30, 2011
+May 27, 2011
+Judge l
+entered an order staying the subpoena to the trustee.
+Order setting hearing on all motions relating to discovery and privilege issues
+for July 13, 2011.
+July 12, 2011
+Epstein's Motion for Leave to Use Attorneys Eyes Only Documents produced
+under confidentiality agreement.
+July 14, 2011
+I protective order granted. Epstein request for all emails is overbroad
+and not necessarily calculated to lead to admissible evidence.
+March 9, 2012
+Epstein Motion to Compel and Amend Protective Order relating to the
+subpoena to the Bankruptcy Trustee.
+April 10, 2012
+Order requiring Edwards to produce any non-privileged documents as
+identified in paragraph 13 of Edwards's Motion to Compel and Amend
+Protective Order.
+April 11, 2012
+April 11, 2012
+Epstein files Edwards February 23, 2011 Privilege Log from the Bankruptcy
+Court in this case.
+This Privilege Log identifies many of the privileged materials that Epstein is
+now attempting to use at trial.
+Epstein Motion to Compel production of documents from
+and for
+Sanctions.
+April 23, 2012
+May 2, 2012
+May 7, 2012
+Y
+May 8, 2012
+May 15, 2012
+May 15, 2012
+May 30, 2012
+Motion to Withdraw
+Agreed Order on
+_ Withdraw
+produces 163 pages of additional responsive documents in
+compliance with April 10, 2012 Order
+Order Requiring Better Privilege Log
+Motion for Clarification on Discovery Issues.
+To clarify the scope of the May 8, 2012 Order.
+Epstein Motion to Compel Discovery Responses and for Sanctions
+Epstein Amended Motion to Compel Discovery Responses and for Sanctions
+8
+
+
+_adv. Epstein
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+June 19, 2012
+August 3, 2012
+August 14, 2012
+Order Setting hearing on Motion for Clarification.
+Hearing on Motion for Clarification on Discovery Issues.
+Scarola letter to Judge
+enclosing proposed Order on Motion for
+Clarification on Discovery Issues
+Provided before Epstein's voluntarily dismissed his claims against
+Epstein voluntarily dismisses case against |
+without prejudice.
+State
+Court
+August 16, 2012
+August 17, 2012
+I April 12, 2012 Privilege Log remained in full force
+and effect. Epstein never challenged the sufficiency of that
+privilege log or made any attempt to overrule
+assertions or compel production of these privilege materials.
+14.
+To summarize,
+was provided with a total of 27,590 emails to evaluate. On
+January 25, 2011,
+produced 8,408 pages of non-privileged emails to Epstein. On
+February 23, 2011,
+produced an additional 12,711 pages of emails, which included 5,027
+pages of emails that were designated "Attorney's Eyes Only." Between the January 25 and
+February 23, 2011 productions,
+turned over 21,119 pages of emails to Epstein.
+properly listed the remaining 6,471 pages of emails on his privilege log filed on February 23, 2011
+in the Bankruptcy Court. Pursuant to Epstein's July 12, 2011 Motion for Leave to Use Attorneys
+3 Judge
+Order also required
+to "file a written response specifically addressing the production sought
+in Paragraph 13 of Epstein's Motion to Compel and Amend Protective Order of March 9, 2012 ... [the response] shall
+identify, in a proper privilege log as referenced in the Court's May 7, 2012 Order, responsive documents withheld
+from production on the basis of any assertion of privilege." Paragraph 13 of Epstein's Motion to Compel concerned
+e-mails between RRA lawyers and either (1) the Federal Government; (2) |
+reporters. Because Epstein had already voluntarily dismissed his action against
+11
+did not produce
+any written response to Paragraph 13 or any e-mails between RRA and these third-parties. And Epstein made no effort
+to seek production of these e-mails (at least, not through legitimate means).
+9
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+Eyes Only Documents Produced Under Confidentiality Agreement, the Attorney's Eyes-Only
+documents are governed by a confidentiality agreement.*
+15.
+On April 11, 2012, Epstein filed |
+privilege log in this case. Pursuant to
+Judge
+August 17, 2012 Order vacating his prior Order requiring
+to file a better
+privilege log, the February 23, 2011 Privilege Log filed in this case on April 11, 2012 remains in
+full force and effect.
+16.
+As referenced in the chart above, in May 2012, Epstein argued that
+privilege log was insufficiently descriptive resulting in his inability to question the various
+assertions of privilege. Based on this contention alone, it is clear that Epstein was not in possession
+of the documents listed on
+privilege log. Therefore, Epstein could not possibly have
+relied on these privileged documents at any time before the filing or during the continuation of his
+lawsuit against
+, which was voluntarily dismissed only three months later on August 16,
+2012.
+17.
+After voluntarily dismissing his claims against
+Epstein never sought to
+overrule any of these privilege assertions or to compel production of the privileged materials listed
+on the log. Epstein has obviously been on notice of the privileged nature of those documents,
+knew they had been withheld from production, and knew that it was unethical to retain the
+privileged documents regardless of how he had acquired them.
+* Epstein's attempt to "confirm" with David Vitale, Esq., who only recently appeared in this case, that no
+infidentiality agreement exists further demonstrates the trial by ambush strategy of Epstein's counsel. The attorn
+, discuss that issue with, and to specifically identify that it related to RRA emails, was Jack Scarola, Esq., who h
+been handling the case since its inception.
+10
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+[ Privilege Log
+18.
+Yet Epstein now seeks to use at least forty-nine (49) clearly privileged emails listed
+on the February 23, 2011 Privilege Log and has refused repeated requests to identify how he came
+into possession of the privileged materials as well as repeated requests to turn over and to destroy
+the privilege materials, as his counsel is ethically required to do.
+A Comparison of
+Privilege Log and Epstein's March 2, 2018 Untimely Exhibits
+19. Epstein and his counsel are knowingly in possession of at least forty-nine (49)
+privileged e-mails that are designated on
+2012 Privilege Log:
+Number of Privileged Emails
+in Epstein's Possession
+(49 TOTAL)
+1
+1
+1
+1
+1
+Numbers from Epstein's
+Untimely Supplemental
+Exhibit #13
+02645
+00149
+01527
+04493
+04494
+04495
+00014
+00090
+00133
+08006
+00026
+01004
+12289
+11
+Number/Range on
+* February 23, 2011
+Privilege Log
+02633-02646
+00149
+01527
+04491-04518
+04494
+04495
+00014
+00090
+00133
+08000-08011
+00026
+01003-01005
+12289
+
+
+] adv. Epstein
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+1
+1
+1
+1
+3
+1
+3
+26481
+26480
+26356
+26570
+03731
+06406-06408
+01686
+11126
+25925
+25874
+11145
+03191
+04398-04402
+5
+5
+
+08042
+26741
+08059-08061
+26756-26758
+08036-08038
+26762
+01117
+26479-26481
+26479-26481
+26356
+26570
+03719-03736
+06404-06408
+01686
+11123-11136
+11126
+25925
+25874
+11143-11146
+03191-03196
+04387-04402
+04403-04416
+26741-26763
+08033-08070
+26741-26763
+08033-08070
+26741-26763
+08033-08070
+26741-26763
+01112-01117
+12
+
+
+4
+3
+3
+3
+3
+4
+1
+1
+1
+1
+2
+3
+08121-08123
+26749-26752
+08128-08130
+08118-08120
+08131-08133
+08124-08126
+08135-08138
+27494
+26760
+25997
+25937
+26604-26605
+07019-07021
+Privilege Log
+08118-08123
+26741-26763
+08124-08156
+08118-08123
+08124-08156
+08124-08156
+08124-08156
+27494
+26741-26763
+25997
+25937
+26604-26605
+07019-07024
+20.
+Summary of Relief Sought by
+respectfully requests entry of an Order for the following relief:
+a. (1) Striking all exhibits produced by Epstein after December 20, 2017 in violation
+of the Court's July 20, 2017 Order, December 5, 2017 Oral Ruling, and January 16,
+2018 Order;
+b. (2) Striking all proposed Epstein exhibits that contain or reference privileged
+materials specifically listed on
+2011 Privilege Log;
+13
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+Privilege Log
+c. (3) Striking any and all pleadings, motions and portions of deposition transcripts,
+in which Epstein's counsel improperly utilized privileged materials to drive the
+nature of that discovery;
+d. (4) Precluding Epstein's counsel from making any mention or use of any struck
+exhibits or pleadings, including the privileged materials;
+e. (5) Ordering Epstein, and his counsel, to show cause as to how (and when) they
+came into possession of materials listed on
+2011 Privilege Log;
+f. (6) Awarding
+his attorneys' fees and costs from the date Epstein first came
+into possession of privileged materials, used them in defending his case, and failed
+to properly disclose his possession of these materials to
+and the Court; and
+g. (7) Any such further relief as the Court deems just and proper given the
+circumstances.
+WHEREFORE, Counter-Plaintiff respectfully requests that the Court enter an Order
+granting this Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits
+and Any Reference to Documents Containing Privileged Materials Listed on
+Log
+NOT
+Privilege
+14
+
+
+Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any
+Reference to Documents Containing Privileged Materials Listed on
+[ Privilege Log
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 5"h day of March, 2018.
+Calade
+Florida Bar No.: 169440
+DAVID P. VITALE JR.
+Florida Bar No.: 115179
+Attorney E-Mails: isx@searcylaw.com; and
+mmccann@searcylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+561-383-9451
+Attorneys for Bradley J.
+NOT A CER
+15
+
+
+_ adv. Epstein
+Privilege Log
+COUNSEL LIST
+Scott J. Link, Esq.
+Link & Rockenbach, P.A.
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 3340.
+Phone: 561-727-3600
+Fax: 561-727-3601
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+RTIFIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbr@FLAppellateLaw
+Burlington & Rockenbach, P.A,
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for Bradley J.
+J.
+,, Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+16
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendant,
+COPY
+/
+GENERAL OBJECTIONS TO UNTIMELY COMPOSITE EXHIBITS
+Counter-Plaintiff,
+by and through undersigned counsel, hereby files
+this General Objections to Untimely Composite Exhibits, and as grounds therefor states as follows:
+At the December 5, 2017 special-set hearing, the Court ordered Counter-Plaintiff
+to produce copies of any exhibits that had not previously been produced by no later than December
+20, 2017. (12/5/17 Tr. 216, 219, 226, 228).
+That ruling was memorialized in the Court's January 16, 2018 Order on
+Plaintiff/Counter-Defendant Jeffrey Epstein's Revised Omnibus Motion in Limine Section B
+Trial Exhibits), as follows:
+On or before December 20, 2017,
+shall produce to Epstein all trial
+exhibits that have not been previously produced in the form to be introduced
+at trial...
+3.
+Yet on February 2, 2018, undersigned counsel received letter correspondence from
+Epstein's counsel, which enclosed a flash drive "containing additional documents for [Epstein]'s
+
+
+
+
+trial Exhibit Nos. 18, 35, 48, 323 and 324. We are still obtaining additional public records and will
+provide those to you upon our receipt." The numbered exhibits are 'catch-alls' as follows:
+#18 - Court docket and all court filings referenced therein for L.M. v Jeffrey
+Epstein, case no. 50-2008-CA-028051;
+b. #35 - Court docket and all court filings referenced therein for E.W. v. Jeffrey
+Epstein, case no. 50-2008-CA-028058;
+c. #48 - Court docket and all court filings reference therein for Jane Doe v. Jeffrey
+Epstein, case no. 08-cv-80893;
+d. #323 - All public records and news articles relating to Scott Rothstein,
+Rothstein Rosenfeldt Adler, Bradley J.
+and any witnesses listed by
+either party;
+e. #324 - All court dockets and filings in all matters against Jeffrey Epstein
+relating to any victim's claims.
+objects to all such late produced exhibits, whether contained in the
+February 2, 2018 flash drive or intended to be produced in the future, as violative of the Court's
+December 5, 2017 ruling and January 16, 2018 order.
+Additionally, the Court has previously ruled that, with regard to any "catch-all"
+exhibits listed on either party's exhibit list, the party must separately identify and list individually
+each exhibit sought to be relied upon by the listing party.
+6.
+therefore reserves all objections to all composite exhibits that fail to
+comply with this order by the Court.
+
+
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 6' day of February, 2018.
+JACK SCAROLA
+-He Cand
+Florída Bar No.: 169440
+DAVÍD P. VITALE JR.
+Florida Bar No.: 115179
+Attorney E-Mails): jsx@searoylaw.com and
+mmccann(@searcylaw.com
+Primary E-Mail: ScarolaTeam(@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for Plaintiffs)
+NOT A CER
+
+
+Page al Objection to Untimely Composite Exhibiss
+COUNSEL LIST
+, Esquire
+taff.efile@pathtojustice.com
+125 N Andrews Avenue. Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+TIFIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J. Edwards
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com;
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+
+
+
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
+
+
+IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION AG
+CASE NO. 502009CA040800XXXXMB
+Judge David F.
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTH
+J.
+individually, and
+, individually,
+Defendants/Counter-Plaintiffs.
+COPY
+PLAINTIFF JEFFREY EPSTEIN'S NOTICE OF FILING PRIVILEGE LOG OF
+FARMER, JAFFE, WEISSING,
+1, FISTOS & LEHRMAN
+DATED FEBRUARY 23, 2011 IN SUPPORT OF PLAINTIFF'S
+MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM
+DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS
+Plaintiff, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the
+Florida Rules of Civil Procedure, hereby gives notice of filing the Privilege Log of!
+1, Jaffe,
+Weissing, Edwards, Fistos & Lehrman Dated February 23, 2011 (attached hereto as Exhibit I) in
+Support of Plaintiff's Motion to Compel Production of Documents From Defendant
+and for Sanctions.
+Dated: April 10, 2012.
+Respectfully submitted,
+oseph L. Ackerman, Jr.
+Florida Bar No. 235954
+BURNETT, P.A.
+
+
+
+Epstein v. Rothstein and
+Case No. 502009CA040800XXXXMB/Div. AG
+I BURNETT, P.A.
+901|
+Point West
+777 South Flagler Drive
+West Palm Beach, Florida 33401
+Telephone: (561) 802-9044
+Facsimile: (561) 802-9976
+Attorneys for Plaintiff Jeffrey Epstein
+and
+I E. Knight
+Florida Bar. No. 607363
+L BURNETT, P.A.
+Espirito Santo Plaza, 14th Floor
+1395 Brickell Avenue
+Miami, Florida 33131
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Attorneys for Plaintiff Jeffrey Epstein
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via Federal
+Express on this 10#* day of April, 2012 to: Lilly Ann
+, Esq., The L-S Law Firm, Four
+Seasons Tower, 15* Floor, 1441 Brickell Avenue, Miami, FL 33131; Jack Scarola, Esq., Searcy
+Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm
+Beach, FL 33409: Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250
+Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; Marc S. Nurik, Esq.,
+Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL
+33301; and
+J. M
+1. Esq., L
+Jaffe, Weissing, L
+1, Fistos & Lehrman,
+P.L., 425 North Andrews Avenue, Suite 2, Fort Lauderdale, FL 33301.
+2
+
+
+ці,
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+UNITED STATES BANKRUPTCY COURT
+SOUTHERN DISTRICT OF FLORIDA
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+COPY
+FISTOS &
+PRIVILEGE LOG
+JAFFE,
+WEISSING,
+LEHRMAN
+TIF
+Case rate 2, 201
+Total of 159 pages
+NOT A
+EXHIT
+
+
+08076-08089
+08311-08318
+08319-08324
+08398
+08402
+08415
+05/26/2009
+10/16/2009
+09/01/2009
+09/17/2009
+09/16/2009
+08422
+10060
+08/03/2009
+10069-10074
+10077-10079
+08/06/2009
+10099-10102
+08/27/2009
+10192
+10194-10195
+10264-10266
+08/09/2009
+Adam Horowitz
+Adam Horowitz
+Jacquie Johnson
+Adam Horowitz
+r, Jaffe, Weissingu
+¿, Fistos & Lehrman
+FROM
+Spencer Kuvin
+Katherine Ezell
+Amy Ederi
+Kikka Claudio
+Paul Cassell
+Margaret Berk
+Katherine Ezell
+Jacquiel
+Spencer Kuvin
+Mercedes
+Spencer Kuvin
+Jacquie|
+Kikka Claudio
+Jacquie|
+DESCRIPTION
+OBJECTION
+Transcript of Alfredo Rodriguez
+Deposition
+WPB-Confidential-General-
+Financial Disclosure/Discovery
+WPB-General-Confidential
+C.M.A.
+VS.
+Epstein,
+et
+al.(File#:281849)
+Report this as a parole violation
+Scanned
+document
+from
+Margaret Berk
+Subpoena directed
+to
+investigators
+the
+| Joint W/P Priv.
+Epstein-Depo-New York
+RE:Transcript
+of
+Alfredo
+Rodriguez Deposition
+RE:Epstein vs. Jane Doe No.101| Joint W/P Priv.
+& Epstein vs. Jane doe No. 102
+RE: Epstein Depo
+Trump Depo moved 08/18 to
+9/24 in NY
+FW: Out of state subpoenas
+RE: Epstein-Letter
+Leslie Wexner
+regarding| Joint W/P Priv.
+1
+
+
+10279-10291
+18/10/200
+10372-10373
+09/17/2009
+10490-10493
+09/21/2009
+10592-10593
+09/29/2009
+10604-10620
+10/01/2009
+10639-10643
+10/06/2009
+10700-10702
+10/13/2009
+10724-1073
+10/14/2009
+10897
+10/29/2009
+10992-11005
+06/22/2009
+11011-11021
+06/23/2009
+11026-11032
+/ 07/09/2009
+11072-11074
+11166-11169
+06/23/2009
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Katherine Ezell
+1, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Jacquiel
+RE: Epstein-Notice of production Joint W/P Priv.
+from non parties/depo of Jane
+Doe
+Katherine Ezell
+RE: Leslie Wexner
+Amy Ederi
+Katherine Ezell
+FW: Epstein Depo
+RE: Leslie Wexner
+Katherine Ezell
+FW:meeting w/ atty fr wexner
+Stuart Mermelstein
+| Meeting w/Leslie Wexner
+Jacquie
+Dépo
+Jacquie |
+Epstein-depo of Alan Dershowitz
+Stuart Mermelstein
+7 Leslie Wexner
+Amy Ederi
+RE:Regular Monthly Cong. Call
+Katherine Ezell
+RE:Regular Monthly Cong. Call
+Spencer Kuvin
+Katherine Ezell
+RE:Epstein
+appointees
+Possible
+witness
+Switzerland
+RE: Article:Bear Stearns
+commissioner | Joint W/P Priv.
+from Joint W/P Priv.
+2
+
+
+11240-11245
+06/22/2009
+11248-11250
+06/22/2009
+11255-11259
+06/23/2009
+11269-11281
+06/30/2009
+11316-11319
+06/28/2009
+11332-11336
+11340-11341
+08/05/2009
+11348-11358
+08/06/2009
+11430-11434
+08/27/2009
+11443
+09/17/2009
+11541-11542
+09/29/2009
+11551-11559
+10/01/2009
+11585-11586
+10/14/2009
+11675-11676
+10/29/2009
+Katherine Ezell
+Amy Ederi
+Katherine Ezell
+Stuart
+Mermelstein
+Katherine Ezell
+Spencer Kuvin
+Mercedes
+Adam Horowitz
+Spencer Kuvin
+Katherine Ezell
+Katherine Ezell
+Spencer Kuvin Y
+Adam Horowitz
+Stuart
+Mermelstein
+Privilege Log- Dated 2-23-2011
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Article:Bear Stearns
+OBJECTION
+Article:Bear Stearns
+USAO Chose
+conversation
+RE:Epstein
+Depo;possible
+deponents
+Discussion
+about
+possible
+witness from Switzerland
+FW:Transcript
+of Alfrefo | Joint W/P Priv.
+Rodriguez Depo and Copperfeild
+and Clinton's whereabouts
+RE:Epstein vs.Jane Doe No.101 &
+| Joint W/P Priv.
+102
+RE:Motion
+for
+protective
+order/discussion
+Discussion
+RE:Wexner
+involvement
+Wexner served subpoena
+RE:Leslie Wexner & Bob
+RE:Meeting w.Stanely Arkin
+RE:Epstein;Larry
+confirmed
+RE:Leslie Wexner attorney info
+Visoski Joint W/P Priv.
+3
+
+
+15981-15988
+15999-16007
+08/05/2009
+16057-16065
+08/06/2009
+15918-15949
+16066-16069
+08/06/2009
+16095-16098 08/11/2009
+15813-15814
+10/29/2009
+15856
+08/03/2009
+15866-15881
+08/03/2009
+15893-15901
+08/03/2009
+15360-15363
+09/01/2009
+15394-15397
+09/09/2009
+15413-15428
+09/10/2009
+15434-15437
+09/10/2009
+Spencer Kuvin
+Bert Patton
+Mercedes
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Stuart
+Mermelstein
+Adam Horowitz
+Adam Horowitz
+Kikka Claudio
+Jacquie|
+Jacquie Johnson
+Adam Horowitz
+Jacquie
+, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Jacquie
+Attachment:Kellen
+&
+Trump
+subpoena
+Jacquie
+RE: Epstein Depo-New York
+Jacquie
+Jacquie|
+Jacquie
+Jacquie
+Jacquie
+Jacquie Johnson
+Jacquie
+Mercedes
+Katherine Ezell
+Jacquie|
+Katherine Ezell
+Trump and Maxwell Dep dates.
+RE:Epstein Depo's 08/14,17,18 in Joint W/P Priv.
+NY
+Maxwell, Trump, Wexner convo
+RE:Depo dates
+Maxwell, Trumo, Wexner
+Convo
+RE:Depo dates cont..
+Wexler Lawyer's info
+Epstein Depo-NY;2 Attachments
+Epstein Ders 08/1417718 in Joint W/P Priv.
+/PDF of
+Notice of Videotaped Depo
+Depo &subpoena notice
+for Joint W/P Priv.
+Trump
+RE:Alan Dershowitz; Harvard Law Joint W/P Priv.
+Info
+RE:Epstein-Depos of
+RE:Esptein-Notice of Prodcution Joint W/P Priv.
+from Non Parties
+Notice Of Production from Non- Joint W/P Priv.
+Parties discussion
+4
+
+
+15454-15475
+09/15/2009
+01465
+07/13/2009
+15485-15492
+09/17/2009
+15493-15500
+09/18/2009
+15501-15555
+09/18/2009
+15556-15564
+09/22/2009
+15565-15575
+600Z/SZ/60
+88951-48951
+600z/T0/01
+15692-15707
+10/01/2009
+15708-15709
+10/06/2009
+15033-15032
+08/05/2009
+E60ST-480SL
+T08/06/2009
+15094-15100
+08/06/2009
+15109-15112
+08/10/2009
+Adam Horowitz
+Katherine Ezell
+Jacquie
+Jacquie
+Jacquiel
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie|
+Jacquie
+Jacquie Johnson
+Jacquie
+Jacquie
+1, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie
+Critton's notice of depo;Epstein
+notice of hearing,Mark Epstein
+notice of depo
+Epstein
+Mercedes
+Katherine Ezell
+Adam Horowitz
+Margaret Berk
+Lisa
+Lisa
+Katherine Ezell
+Mercedes
+Mercedes
+Mercedes
+Kikka Claudio
+Adam Horowitz
+OBJECTION
+RE:Epstein Depo
+RE:Deposition
+Bruhnel
+RE:Epstein Depo
+of
+Jean
+Luc Joint W/P Priv.
+Epstein Depos
+FW:Deposition of Jean
+Bruhnel
+Depo of David Hart Rogers
+Luc | Joint W/P Priv.
+FW:Meeting w/Sranley Arkin
+REJane Does 2-8v. Epstein-Cross
+Nod's of Oct 6-8 depos
+RE:Epstein-Depo for 8/17
+RE: Epstein-Depo for 8/17
+RE:Epstein Depo-New York
+RE:Epstein
+Depositions
+8/14,17,18 in NY &
+for Joint W/P Priv.
+5
+
+
+15122-15125
+15142-15158
+08/11/2209
+15166-15170
+15171-15172
+15178-15182
+08/12/2009
+15306-15355
+08/25/2009
+14951-14952
+600z/E0/80
+14954-14972
+09/16/2009
+14979-14981
+08/03/2009
+14983-15015
+16501-16519
+09/15/2009
+16520-16547
+09/09/2009
+16355-16384
+08/24/2009
+16554-16568
+09/16/2009
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Adam Horowitz
+Jacquie
+Jacquie
+Adam Horowitz
+Spencer Kuvin 7
+Adam Horowitz
+Kikka Claudio
+,Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Kikka Claudio
+RE: Ms.
+Maxwell
+Depo
+rescheduled
+Kikka Claudio
+FW:out of state subpoenas
+Kikka Claudio
+Kikka Claudio
+Kikka Claudio
+Kikka Claudio
+Kikka Claudio
+| Jacquie
+Kikka Claudio
+Adam Horowitz
+Jacquie
+Jacquie
+| Jacquie
+Jacquie |
+OBJECTION
+RE:out of state subpoenas
+RE:Epstein
+RE:Epstein
+FW: Epstein Depo Notices & Subs
+RE:Epstein Depo-New York
+RE:Epstein-Depo of Mark Epstein
+| Joint W/P Priv.
+on 9/21 in NY will take place as
+scheduled
+RE: Epstein Depo-New York
+RE:Epstein Depositions 8/14.17, Joint W/P Priv.
+&18 in NY &
+Epstein Hearing
+RE:Epstein-Deposition of Jane Joint W/P Priv.
+Doe-9/30/2009
+Epstein Depo Notices and Subs
+RE:Epstein Depo
+6
+
+
+16574-16577
+09/17/2009
+16396-16398
+09/01/2009
+16578-16581
+09/17/2009
+16582-16585
+09/18/2009
+16585-16611
+09/18/2009
+16612-16439
+09/18/2009
+16440
+08/18/2009
+16740-16753
+09/22/2009
+16443-16452
+09/09/2009
+16777-16786
+09/30/2009
+16793-16794
+10/01/2009
+16462-16477
+09/10/2009
+16802-16823
+10/02/2009
+16483-16486
+09/10/2009
+Adam Horowitz
+Margaret
+Katherine Ezell
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Spencer Kuvin
+Margaret Berk
+Katherine Ezell
+Adam Horowitz
+Lisa
+Adam Horowitz
+Margaret Berk
+Katherine Ezell
+, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+Jacquie
+DESCRIPTION
+RE:Epstein Depo
+Jacquie
+| Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie Johnson
+Jacquie|
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+OBJECTION
+Alan Dershowitz
+RE:Depo
+RE:Deposition
+of
+- Jean
+Luc
+Bruhnel
+RE:Epstein Depo
+RE:Epstein Depo of Mark Epstein
+RE:Epstein Sub to Bear Stearn
+RE: Epstein Depos
+RE:Epstein-Depos of
+&
+RE:Epstein
+RE:Depo of David Hart Rogers
+RE:Epstein-Notice of Production | Joint W/P Priv.
+from Non Parties
+RE:Epstein depos
+RE:Epstein-Notice of Production Joint W/P Priv.
+from Non Parties
+
+
+16874-16880
+10/13/2009
+16904-16905
+10/14/2009
+16945
+10/26/2009
+17033-17034
+10/26/2009
+02065-02068
+06/08/2009
+02070
+09/02/2009
+02071
+08/18/2009
+02072-02078
+09/04/2009
+03466-03468
+05/14/2009
+02301-02302
+09/09/2009
+03122-03123
+06/10/2009
+02805-02806
+05/26/2009
+02670-02671
+10/21/2009
+02517-02519
+10/02/2009
+Adam Horowitz
+Spencer Kuvin
+Kikka Claudio
+Kikka Claudio
+Jacquie
+Adam Horowitz
+Jacquie
+Spencer Kuvin
+Paul Cassel
+Adam Horowitz
+Susan Stirling
+L Jaffe, Weissing.
+L, Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie
+Depo
+Jacquiel
+Jacquie
+Jacquie
+Mercedes
+Spencer Kuvin
+Jacquie
+Spencer Kuvin
+Bradley
+Katherine Ezell
+Spencer Kuvin
+Katherine Ezell
+OBJECTION
+RE:Epstein
+RE: Epstein depos on 10/28
+RE:Epstein depos on 10/28
+FW:Epstein-Confirming
+AT&T Joint W/P Priv.
+Dial Telephone Conference for
+Mon 6/8/09 at 2:00 p.m.
+FW:Epstein-Depos
+of Joint W/P Priv.
+&
+RE: Epstein Sub to Bear Sterns
+EW:Epstein-Depos
+of Joint W/P Priv.
+&
+RE:Actvity in
+Case
+9:08-Cv-
+| Joint W/P Priv.
+80893-KAM Doe v. Epstein Order
+on Motion to Stay
+FW.:Epstein
+FW: Motion to Dismiss
+RE: WPB-Confidential-General-
+Financial Disclosure/Discovery
+FW: Subpoena Info
+FW:Meeting w/Stanley Arkin
+8
+
+
+02614-02617
+08/05/2009
+15702-15704
+| 10/02/2009
+15581-15585
+09/28/2009
+15431-15433
+09/10/2009
+15797-15798
+| 10/14/2009
+11560-11562
+10/02/2009
+11444-11448
+| 09/28/2009
+05823
+09/04/2009
+05832
+09/08/2009
+09/08/2009
+05838
+05847
+09/09/2009
+05859
+07/23/2009
+05863-05864
+07/23/2009
+05886-05887
+07/24/2009
+| TO
+Adam Horowitz
+Spencer Kuvin
+Adam Horowitz
+Adam Horowitz
+Jacquiel
+Jacquie|
+, Jaffe, Weissing.
+,, Fistos & Lehrman
+FROM
+Kikka Claudio
+DESCRIPTION
+FW:Proposal Request
+OBJECTION
+Katherine Ezell
+FW:Meeting w/Stanley Arkin
+Amy Ederi
+FW:Epstein Depo
+Jacquie|
+RE:Epstein-Notice of Production | Joint W/P Priv.
+from Non Parties
+RE:Epstein
+Katherine Jacquie FW:Meeting w/Stanley Arkin
+Amy Ederi
+FW:Epstein Depo
+Jacquie Johnson
+RE: Epstein
+Jacquie Johnson
+RE:Epstein
+Jack Hill
+RE:Epstein
+Katherine Ezell
+RE:Epstein
+Katherine Ezell
+RE:Epstein
+Katherine Ezell
+RE:Epstein
+Katherine Ezell
+RE:Epstein
+9
+
+
+05902-05903|07/28/2009
+05906-05907
+05912
+08/27/2009
+05928-05930
+05933-05934
+09/18/2009
+05936
+09/18/2009
+05938
+09/18/2009
+05940-05941
+09/18/2009
+05951
+05/29/2009
+05957-05960
+09/09/2009
+05970-05971
+10/21/2009
+05982-05983
+/ 10/28/2009
+05993-05994
+09/09/2009
+05997
+08/06/2009
+Jacquie
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Katherine Ezell
+RE:Epstein
+Katherine Ezell
+Spencer Kuvin
+Katherine Ezell
+Spencer Kuvin
+Spencer Kuvin
+Adam Horowitz
+Spencer Kuvin
+Spencer Kuvin
+Kikka Claudio
+Margaret Berk
+Spencer Kuvin
+Adam Horowitz
+Kikka Claudio
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE:Epstein
+RE: Epstein
+RE:Epstein
+OBJECTION
+10
+
+
+01029
+10/08/2009
+07707
+09/03/2009
+07708-07709
+06/22/2009
+07734
+07/24/2009
+07218-07219
+10/02/2009
+06861-06863
+05/12/2009
+06876-06879
+600z/zT/50
+06891-06897
+600z/zт/s0
+06901
+09/11/2009
+06902
+09/15/2009
+06903
+09/04/2009
+06806-06807
+09/09/2009
+06712
+10/19/2009
+06713-06714
+09/15/2009
+BradleyEdwards
+,Jaffe, Weissing.
+,, Fistos & Lehrman
+FROM
+DESCRIPTION
+Carolyn
+Brian Ryalls
+OBJECTION
+Kikka Claudio
+Amy Ederi
+RE:Regarding:C.M.A. vs. Epstein.
+Et al.(File# 281849)
+RE:Regular Monthly Cong. Call
+RE:Release
+Katherine Ezell
+Katherine Ezell
+RE:Meeting w/Stanley Arkin
+RE:Jane Doe It v. Epstein
+Stuart Mermelstein
+RE Jane Doe liv. Epstein
+Katherine Ezell
+RE:Jane Doe Il v. Epstein
+Mercedes
+Mercedes
+Mercedes
+Adam Horowitz
+No. 102 vs Epstelo ros Nole 10int W/P Piv.
+Of Depos
+RE: Jane Doe No.101 & Jane Doe | Joint W/P Priv.
+NO.102 vs. Epstein
+RE: Jane Doe No.101 & Jane Doe | Joint W/P Priv.
+NO.102 vs. Epstein-Cross-Notice
+of Taking Video Deposition
+RE: Epstein
+Kikka Claudio
+RE: Igor Zinoview depo
+Robert Josefberg
+RE:Epstein
+11
+
+
+06720-06727
+10/14/2009
+06728
+09/09/2009
+06711
+09/09/2009
+06472
+05/08/2009
+06460-06464
+06455-06459
+05/08/2009
+05/08/2009
+06448-06452
+05/08/2009
+06420-06427
+05/08/2009
+06416-06419
+05/08/2009
+05925-05926
+05883-05584
+07/24/2009
+05022-05025
+09/10/2010
+04724-04725
+05/27/2009
+06990-07002 06/11/2009
+07003-07006 | 06/26/2009
+Kikka Claudio
+Spencer Kuvin
+Spencer Kuvin
+Spencer Kuvin
+Spencer Kuvin
+Spencer Kuvin
+Katherine Ezell
+Katherine Ezell
+Adam Horowitz
+To
+Brád
+Amy Ederi
+¿ Jaffe, Weissing.
+,, Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Jack
+RE: igor Zinoview depo
+Kikka Claudio
+Spencer Kuvin
+Jacquie
+Katherine Ezell
+RE:Epstein
+RE:Epstein
+RE: FYI Epstein Depo
+RE:FYI Epstein Depo
+RE:FYI Epstein Depo
+RE:FY! Epstein Depo
+RE:FYi Epstein Depo
+RE:FYI Epstein Depo
+FW:Epstein
+RE:Epstein
+FROM
+Katherine W. Ezell
+Brad
+RE: Epstein-Notice of Production Joint W/P Priv.
+from Non Parties
+RE:Epstein Cases-depostions in
+federal cases
+DESCRIPTION
+June
+10%
+
+June
+25'
+OBJECTION
+hearing-WPB-
+hearing-WPB- Joint-privilege
+12
+
+
+07030
+[DATE
+09/22/2009
+07090-07091
+9/29/2009
+07092
+10/29/2009
+07093
+09/17/2009
+01484
+05/21/2009
+01503
+08/24/2009
+01517
+09/18/2009
+01514
+08/26/2009
+01515
+08/27/2009
+01477
+07/21/2009
+01489
+08/03/2009
+07110-07112
+09/25/2009
+07113-07114
+09/25/2009
+07115-07116
+09/25/2009
+07145-07146 | 09/22/2009
+07211-07213
+10/01/2009
+07210
+10/06/2009
+1, Jaffe, Weissing.
+1, Fistos & Lehrman
+FROM
+DESCRIPTION
+
+1.
+Spencer Kuvin
+L.M. v. Epstein - defendant,
+Jeffrey Epstein's response to
+1.
+plantiff
+Katherine W. Ezell
+Leslie Wexner
+Stuart
+Mermelstein
+J.
+1.
+Katherine W. Ezell
+Robert
+C.
+Josefsberg
+Spencer Kuvin
+Adam Horowitz;
+Spencer Kuvin
+Spencer Kuvin
+Spencer Kuvin
+Adam Horowitz;
+Stuart
+Mermelstein
+Adam Horowitz
+1).
+J. Edwards
+1. Spencer Kuvin
+Spencer Kuvin
+Spencer Kuvin
+Adam Horowitz
+1. Spencer Kuvin
+Stuart
+Katherine W. Ezell
+Mermelstein;
+Robert
+c.
+Josefsberg;
+Leslie Wexner
+Leslie Wexner
+Epstein
+Epstein
+Epstein
+Epstein
+Epstein
+Epstein
+Epstein
+LM v EPSTEIN hearing 9/22/09
+LM v EPSTEIN hearing 9/22/09
+LM v EPSTEIN hearing 9/22/09
+Mark Epstein
+Meeting with Stanley Arkin
+Meeting with Leslie Wexner
+OBJECTION
+13
+
+
+07214-07215
+10/01/2009
+07216-07217
+10/02/2009
+07220-07223
+10/01/2009
+07224-07225
+10/02/2009
+07226-07227
+10/01/2009
+07228-07229
+10/01/2009
+07280-07283
+08/06/2009
+07633-07634
+08/06/2009
+07710-07733
+06/23/2009
+07740-07746
+09/18/2009
+07748-07757
+_09/18/2009
+07913-07915
+08/27/2009
+07917-07918 08/27/2009
+07965-07966
+08/12/2009
+07977-07978
+| 10/09/2009
+01716
+09/15/2009
+01768
+07/13/2009
+01771-01772
+08/06/2009
+01931
+1, Jaffe, Weissing.
+L, Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+J.
+Robert
+Josefsberg
+C.
+Katherine W. Ezell
+1.
+Katherine W. Ezell
+Meeting with Stanley Arkin
+Meeting with Stanley Arkin
+Spencer Kuvin
+Katherine
+W.
+Ezell
+Robert
+Josefsberg
+Meeting with Stanley Arkin
+Meeting with Stanley Arkin
+Spencer Kuvin
+1. Robert
+Josefsberg.
+Meeting with Stanley Arkin
+C. Meeting with Stanley Arkin
+Adam Horowitz
+Katherine
+Ezell
+W.
+Motion for protective order
+Kikka M. Claudio
+Proposal Request
+J. Edwards
+Regularly Monthly Cong. Call
+Adam Horowitz
+Report this as a parole violation
+Report this as a parole violation
+Adam Horowitz
+1.
+J.
+| Spencer Kuvin
+Spencer Kuvin
+Jacquie R
+Katherine
+w. Bradley.
+Ezell
+1. Spencer Kuvin
+Elizabeth Villar
+Adam Horowitz
+Richard Willits
+Adam Horowitz
+J.
+J.
+J. Lisa
+Subpoena directed to
+the
+investigators
+Subpoena Info
+Epstein: Forensics/Investigations
+INVOICE
+Epstein investigator
+Epstein Investigator
+Alfredo Rodriguez
+14
+
+
+01998-01999
+09/21/2009
+02021
+05/14/2009
+02044
+09/04/2009
+02048
+09/04/2009
+02054
+05/12/2009
+02062
+10/05/2009
+02087
+02140
+02147-02149
+09/17/2009
+09/21/2009
+02174
+07/20/2009
+02209-02210
+07/01/2009
+02215-02217
+07/24/2009
+02290
+09/18/2009
+02355-02356
+06/10/2009
+02362-02363
+06/09/2009
+02374-02375
+09/15/2009
+:.
+1, Jaffe, Weissing.
+• Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Adam Horowitz
+Margaret Berk
+Katherine
+Ezell
+Robert
+Josefsberg
+Spencer Kuvin
+1.
+Mercedes
+W.
+C.
+J.
+C.
+Correct
+Number -
+Epstein
+Deposition
+Doe v. Epstein
+J.
+J. Amy Ederi
+Spencer Kuvin
+Spencer Kuvin
+J.
+Amy Ederi
+E.W., L.M. Doe v. Epstein
+-
+Letter from Bob Critton
+E.W., L.M. Doe V. Ep
+- Joint-privilege
+Letter from Bob Critton
+Emailing Epstein
+deposition
+revised
+Epstein - Confirming AT&T Dial | Joint-privilege
+in Tel.
+Conf. for Monday,
+10/5/09 at 4:00 p.m.
+Epstein- Hearing
+Epstein Depo - New York
+Epstein Depo
+Adam Horowitz
+Bert Patton
+J. Edwards
+William J. Berger
+Mercedes
+1.
+Mercedes
+J. Spencer Kuvin
+C. Susan K. Stirling
+Spencer Kuvin
+Jack
+Katherine W. Ezell
+Epstein Matter - Cross Notice of | Joint-privilege
+Alfredo Rodriguez Deposition
+Epstein v. State of Florida - Joint-privilege
+Emergency petition for Writ of
+Certiorari; Emergency motion to
+review denial of stay
+c.
+Epstein
+Epstein
+Hearing taken on 06/10/09 Joint-privilege
+onmotion to unseal before Judge
+Colbath
+Hearing to Un-seal
+Igor Zinoview depo
+15
+
+
+02420-02421
+02435
+02438
+02462
+05/08/2009
+09/15/2009
+09/18/2009
+09/22/09
+02476-02477
+02516
+09/25/2009
+10/06/2009
+02554-02559
+08/03/2009
+02584
+02618
+02627-02628
+09/18/2009
+02672-02673
+_ 10/09/2009
+02727
+08/03/2009
+02896
+06/08/2009
+03009-03010 | 08/07/2009
+03028-03029
+09/21/2009
+03038
+10/06/2009
+03131-03132
+/ 08/06/2009
+I TO
+[Jaffe, Weissing.
+;, Fistos & Lehrman
+1.
+FROM
+Mercedes
+DESCRIPTION
+Jane Doe ll v. Epstein
+J.
+Lisal
+Jane Does v. Epstein
+OBJECTION
+Adam Horowitz
+Spencer Kuvin
+Spencer Kuvin
+J.
+Katherine W. Ezell
+Adam Horowitz
+.1.
+Kikka M. Claudio
+J.
+Kikka M. Claudio
+J. Adam Horowitz
+Spencer Kuvin
+Spencer Kuvin
+J.
+Bradley J.
+Adam Horowitz
+J.
+Spencer Kuvin
+Jacquie|
+1.
+Adam Horowitz
+Jeffrey Epstein DC# W35755
+L.M. V. Epstein - Defendant,
+Jeffrey Epstein"s Response to
+Plantiff L.M."s
+Motion
+• for
+Protective Order
+LM v EPSTEIN hearing
+Meeting with Leslie Wexner
+NEW
+ASSIGNMENT
+- NEW Joint-privilege
+ALBANY - RUSH? - Fwd: Federal
+Subpoena
+Out of state subpoenas
+Proposal Request
+Report this as a parole violation
+Subpoena info
+Transcript of Alfredo Rodriguez Joint-privilege
+deposition
+Hearing to Un-seal
+Motion to stay
+Mark Epstein
+Adam Horowitz
+Stuart Mermelstein
+Meeting with Leslie Wexner
+Epsteins assets
+16
+
+
+03243-03244
+09/09/2009
+03397-03400
+09/29/2009
+03407-03414
+09/29/2009
+03451-03452
+05/14/2009
+03477-03479|05/15/2009
+03619-03627
+09/15/2009
+03631-03633
+09/15/2009
+03646-03656
+10/19/2009
+03677-03687
+03719-03736
+09/04/2009
+03840-03847
+08/02/2009
+03938-03939
+09/29/2011
+03943-03945
+09/18/2009
+02911-02912
+09/15/2009
+02939
+02977
+07/14/2009
+10/16/2009
+¿, Jaffe, Weissing.
+, Fistos & Lehrman
+I FROM
+DESCRIPTION
+1. Adam Horowitz
+EPSTEIN
+Adam Horowitz
+1.
+| Adam Horowitz
+J.
+Spencer Kuvin
+1. Spencer Kuvin
+J. Spencer Kuvin
+Jacquie
+William J. Berger
+Katherine W. Ezell
+1.
+Adam Horowitz
+J. Spencer Kuvin
+Stuart
+Mermelstein
+Katherine
+Ezell (
+Adam Horowitz
+1.
+Katherine
+W.
+Jacquie
+1. Jack P.
+1. Adam Horowitz
+w.l
+J.
+OBJECTION
+Activity in case 9:08-CV-80119-
+KAM Doe v. Epstein Response in
+Opposition to Motion
+Activity in case 9:08-cv-80119 Joint-privilege
+KAM Doe v. Epstein Response in
+Opposition to Motion
+Activity in Case 9:08-cv-80893-
+KAM Doe. v. Epstein Order on
+Motion to Stay
+Activity in Case 9:08-cv-80893- Joint-privilege
+KAM Doe v. Epstein Order to
+Motion to Stay
+BB v. Epstein/EW v. Epstein
+BB v. Epstein/EW v. Epstein
+Subpoena & Depo
+Bill
+Notice
+Can you
+send me those Joint-privilege
+addresses?
+CMA - depo notices attached.
+Continuing Deposition of Alfredo
+Rodriguez
+Deposition of Bill
+Deposition of Jean Luc Bruhnel
+Igor Zinoview depo
+Jane Does 2-7 v. Epstein
+Leslie Wexner
+17
+
+
+02978
+02994
+10/29/2009
+06/10/2009
+07060
+06202
+10/16/2009
+07/13/2009
+06409-06415
+04/15/2009
+06428-06447
+| 05/06/2009
+06453-06454 | 04/15/2009
+06465-06471
+06476-06490
+05/08/2009
+06630-06632
+09/09/2009
+06636-06639
+09/09/2009
+06702-06705
+09/16/2009
+06706-06708
+| 10/14/2009
+06715-06719
+| 10/09/2009
+06729-06735
+10/13/2009
+06763
+08/19/2009
+06764-06766
+09/10/2009
+06770-06781
+T09/10/2009
+06811-06812|
+108/20/2009
+Ezell
+1, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+1. Stuart Mermelstein
+J.
+Mercedes
+C.
+Sid
+Richard Willits
+J.
+Katherine W. Ezell
+Spencer Kuvin
+Spencer Kuvin
+Katherine
+Ezell
+W.
+J. | Spencer Kuvin
+Spencer Kuvin
+Robert
+Josefsberg
+J. Kikka M. Claudio
+J.
+Kikka M. Claudio
+C.
+Jack P.
+J.
+Jack P.
+OBJECTION
+Leslie Wexner
+Preservation of evidence
+L.M. v. Epstein
+Scheduling various depositions
+regarding Epstein
+FYI
+FYI
+FYI
+FYI
+FYI
+Hearing to Un-seal
+Hearing to Un-seal
+Igor Zinoview & Tommy Matola Joint-privilege
+depos
+Igor Zinoview depo
+İgor Zinoview depo
+Igor Zinoview depo
+Bradley
+/ Stuart Mermelstein
+IME's
+Stuart Mermelstein
+IME's
+Stuart
+Mermelstein
+Katherine
+IME's
+W.
+Is Mark Epstein JE's brother?
+18
+
+
+06817-06819
+09/23/2009
+06820-06822
+07/02/2009
+06841-06860
+05/12/2009
+06864-06875
+05/12/2009
+06880-06890
+05/12/2009
+06898-06900
+05/12/2009
+06933-06934
+06937-06938
+07/14/2009
+10/05/2009
+06944-06952
+09/22/2009
+16123-16124
+16799-16801
+10/02/2009
+02947-02948
+08/03/2009
+02891-20906
+10/01/2009
+20880-20882
+10/02/2009
+06042-06090
+06402-06403
+07/02/2009
+06/10/2009
+01365-01366
+09/15/2009
+01340-01341
+01331
+06/30/2009
+:
+i, Jaffe, Weissing.
+, Fistos & Lehrman
+I TO
+FROM
+DESCRIPTION
+Ezell
+Adam Horowitz
+| OBJECTION
+Is your client being deposed
+tomorrow?
+Jane Doe 2
+) v. Epstein
+1. Margaret Berk
+1. Spencer Kuvin
+Jane Doe Il v. Epstein
+Spencer Kuvin
+1.
+J.
+Katherine W. Ezell
+Jane Doe Il v. Epstein
+Jane Doe lIv. Epsteín
+1. Stuart Mermeistein
+Jane Doe I! v. Epstein
+Adam Horowitz
+Spencer Kuvin
+T.
+Jacquie
+1. Adam Horowitz
+Jane Does 2-7 v. Epstein
+Jane Does 2-8 v. Epstein - Cross
+NOD's of Oct. 6-8 depos
+Jeffrey Epstein DC# W35755
+Adam Horowitz
+Jacquie Johnson
+Kikka M. Claudio
+Jacquie Johnson
+Robert
+Josefbergs
+c.
+Jacquie Johnson
+Spencer Kuvin
+Jacquie Johnson
+J. Katherine W. Ezell
+J.
+Katherine W. Ezell
+William J. Berger
+1.
+Spencer Kuvin
+Katherine W. Ezeli
+Adam Horowitz
+Adam Horowitz
+Stuart
+Jacquie
+Jacquie
+Maxwells deposition
+Maxwells deposition
+Meeting with Stanley Arkin
+Epstein Depo - New York
+Meeting with Stanley Arkin
+Meeting with Stanley Arkin
+Ew 09-22784 cert.4" dca
+Hearing to Un-seal
+Epstein Hearing
+Epstein Depositions
+Epstein depositions
+19
+
+
+01319
+01316
+01314
+01298
+01294
+01273
+08/27/2009
+10/30/2009
+05/26/2009
+08/10/2009
+07/13/2009
+01250
+05/13/2009
+01246
+04/08/2009
+01233-01234
+600z/TE/L0
+01224
+600z/9T/90
+01185
+01186
+01187
+10/30/2009
+10/02/2009
+05/19/2009
+Mermelstein
+Adam Horowitz
+Spencer Kuvin
+Stuart
+Mermelstein
+Jack P.
+Katherine
+Ezell
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Jacquie
+Jacquie
+Epstein Depo
+Epstein Depo
+Epstein Depo of Wexner
+Adam Horowitz
+W.
+Mercedes
+J.
+Mercedes
+J.
+Mercedes
+1.
+Mercedes
+Estrada
+1.
+Mercedes
+Mercedes
+J.
+| Mercedes
+Epstein cases - depositións in
+federal cases
+Epstein Assets
+Epstein 2255 claims
+C.
+Epstein
+C.
+Epstein - Telephone Conference
+C.
+C.
+C.
+. C.
+C.
+Epstein - Monday, 8/3/09 - | Joint-privilege
+Monthly call in
+telephone
+conference - AT&T Call in No:
+(877) 468-2136 - participant
+code: 775593. Kathy is the host.
+Epstein - Monday, 8/3/09 - | Joint-privilege
+Monthly call in
+telephone
+conference - AT&T Call in No:
+(877) 468-2136 - participant
+code: 775593. Kathy is the host.
+Epstein - Confirming AT&T dial | Joint-privilege
+in tel. conf. for Monday, 11/2/09
+at 4:00 p.m.
+Epstein - Confirming AT&T Dial Joint-privilege
+in Tel. Conf. for Monday,
+10/5/09 at 4:00 p.m.
+Epstein - Confirming AT&T Dial Joint-privilege
+in Telephone Conference for
+Monday, 6/8/09 at 2:00 p.m.
+20
+
+
+01188
+05/12/2009
+01189
+09/08/2009
+01095-01096
+| 04/15/2009
+01045
+01649
+01641
+01639
+01619
+07/23/2009
+06/11/2009
+05/29/2009
+10/28/2009
+01660
+07/22/2009
+01666
+01671
+04/20/2009
+07/23/2009
+01680
+08/24/2009
+04355-04358
+09/04/2009
+04446
+09/03/2009
+04200-04201
+04220-
+09/04/2009
+09/04/2009
+04221
+04222-04223
+09/04/2009
+Spencer Kuvin
+i, Jaffe, Weissing.
+2, Flstos & Lehrman
+FROM
+1. Mercedes
+DESCRIPTION
+OBJECTION
+C.
+Epstein - Confirming AT&T Dial Joint-privilege
+in Telephone Conference for
+Tomorrow 5/13/09
+1.
+| lliana Yarzabal
+Epstein - Confirming AT&T Dial Joint-privilege
+in Telephone Conference for
+Wednesday, 9/9/09 at 3:00
+Deposition of Epstein was set for Joint-privilege
+tomorrow
+Richard Willits
+CMA vs. Epstein
+1.
+Mercedes
+C.
+/ Epstein
+1.
+Mercedes
+C.
+Epstein
+Mercedes
+C.
+Epstein
+J.
+Spencer Kuvin
+Epstein
+J.
+Adam Horowitz
+Epstein
+Spencer Kuvin
+Katherine
+W.
+Ezell
+Jack P.
+Jack Scarola
+Epstein
+Epstein
+| Joint-privilege
+liana Yarzabal
+Katherine W. Ezell
+Spencer Kuvin
+Barry
+Epstein
+Epstein - Depos of
+and
+Epstein - Monday 8/3/09 - Joint-privilege
+Monthly Call in Telephone
+Conference
+Letter from Bob Critton
+Letter from Bob Critton
+Joint W/P Privilege
+Joint W/P Privilege
+Letter from Bob Critton
+Joint W/p Privilege
+21
+
+
+04264
+04298-04299
+04304
+04335
+04359-04360
+05/12/2009
+09/16/2009
+09/08/2009
+10/30/2009
+09/04/2009
+04365
+09/15/2009
+04417
+09/17/2009
+04423-04424
+09/09/2009
+04433-04436
+06/16/2009
+04447-04450
+07/31/2009
+04491-04518
+04/08/2009
+04518
+04/08/2009
+04524-04525
+05/13/2009
+04580
+10/14/2009
+04640-04641
+10/14/2009
+04723
+05/26/2009
+04726-04729
+05/26/2009
+04750-04754
+04763-04785
+T08/27/2009
+04797-04799
+09/18/2009
+04806-04813
+04819
+04831-04832
+04835-04836
+07/25/2009
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Jacquie
+Spencer Kuvin
+Jacquie
+Katherine Ezell
+Jacquie
+Adam Horowitz
+Spencer Kuvin
+Spencer Kuvin
+Jacquie
+Jacquie
+Jack Scarola
+Spencer Kuvin
+Katherine Ezell
+-
+1, Jaffe, Weissing.
+1, Fistos & Lehrman
+FROM
+DESCRIPTION
+Spencer Kuvin
+Epstein Depo
+Adam Horowitz
+Depo of Epstein
+Adam Horowitz
+Epstein
+Robert Josefsberg
+Epstein- Confirming AT&T Tel.
+Conf.
+Katherine Ezell
+Depos of
+Adam Horowitz
+Spencer Kuvin
+Adam Horowitz
+Mercedes
+Jack Scarola
+Robert Josefsberg
+Adam Horowitz
+Adam Horowitz
+Katherine Ezell
+Adam Horowitz
+Adam Horowitz
+Jacquie
+Jacquine
+Epstein- Depo in New York
+Epstein- Hearing
+Letter regarding Leslie Wexner
+Monthly Call in Tele. Conf.
+Monthly Call in Tel. Conf.
+Epstein- Tel. Conf.
+Epstein- Tel Conf.
+Epstein Dépo
+Depo of Larry Visoski
+Depo of Larry Visoski
+Epstein cases- Depos
+Epstein cases- Witness depos
+Epstein depo - New York
+Epstein Depo Notice
+Epstein Depo
+Epstein Depos in New York
+Epstein Depos
+Epstein Depos
+Epstein Depos
+22
+OBJECTION
+Joint W/P Privilege
+Joint W/P Privilege
+
+
+04711
+08/10/2009
+04855-04858
+08/18/2009
+04861
+07/24/2009
+04876-04877
+07/27/2009
+04922-04923
+09/16/2009
+04925-04926
+09/15/2009
+04929-04934
+09/25/2009
+04937-04938
+09/15/2009
+04969-04972
+05026-05027
+07/20/2009
+09/10/2009
+05031
+09/25/2009
+05037-05038
+709/25/2009
+05042-05043
+09/25/2009
+05046
+09/25/2009
+05074-05076
+| 08/18/2009
+Lisa
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Spencer Kuvin
+Stuart
+Mermelstein
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Jack
+Epstein assests
+Kikka Claudio
+Epstein Depos
+Jacquie
+Spencer Kuvin
+Jacquie
+Jacquie
+Adam Horowitz
+Jacquie
+Jacquie Johnson
+Spencer Kuvin
+Spencer Kuvin
+Spener Kuvin
+Jacquie
+OBJECTION
+Epstein Depos
+Epstein Depos
+Epstein Hearing
+Epstein Hearing
+Epstein Hearing
+EpL
+Hearing
+Alfredo Rodriguez Depo
+Notice of Production from Non-
+Parties
+Epstein Order
+Epstein Order
+Epstein Order
+Epstein Order
+Epstein Sub. To Bears Stern
+23
+
+
+05100-05102
+05105-05107
+08/05/2009
+04/20/2009
+05110
+08/06/2009
+05118-05119
+09/09/2009
+05157-05158
+09/10/2009
+05167-05168|05/29/2009
+05171-05172 05/29/2009
+05201-05202
+09/10/2009
+05222-05223
+07/10/2009
+05226
+07/10/2009
+05229
+07/10/2009
+05232-05233
+| 07/10/2009
+05247
+07/23/2009
+05251-05252
+T07/24/2009
+05258
+07/25/2009
+05265-05266
+| 07/22/2009
+Mercedes
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Adam Horowitz
+Katherine Ezell
+Kathérine Ezell
+Katherine Ezell
+Adam Horowitz
+, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+Spencer Kuvin
+Kikka Claudio
+Margaret Berk
+Mercedes
+Katherine Ezell
+Spencer Kuvin
+Adam Horowitz
+Adam Horowitz
+Spencer Kuvin
+DESCRIPTION
+Improper Serving of Maxwell
+Hearing on Yellow Cab Objection
+OBJECTION
+Address for
+Motion for Protective Order
+Motion for Protective Order
+Spencer Cross-Examination
+Transcripts
+Rules on Doe no. 4
+File case
+Epstein 5" Amendment rights
+Motions to Compel
+Motions fully briefed
+Answers to the 1" set of ROGS
+Depo dates
+Switzerland Witness regarding
+Epstein Egg Shaped 2 inch PENISI
+Alfredo Rodriguez depo
+24
+
+
+05286-05287
+05293-05294
+05326-05327
+08/24/2009
+05331
+08/06/2009
+05334-05335
+05/29/2009
+05347
+08/24/2009
+05350
+08/10/2009
+05353-05354
+| 09/09/2009
+05367
+09/10/2009
+05373-05374
+08/10/2009
+05391-05393 | 04/20/2009
+05400-05401
+| 10/19/2009
+05414-05415
+08/10/2009
+05437-05439
+04/20/2009
+05444-05445
+08/10/2009
+05451
+05/29/2009
+Katherine Ezell
+Katherine Ezell
+Kikka Claudio
+Kikka Claudio
+Katherine Ezell
+Jacquie
+Kikka Claudio
+Spencer Kuvin
+Adam Horowitz
+Kikka Claudio
+Bradley Edwards
+Mercedes
+„Jaffe, Weissing..
+,, Fistos & Lehrman
+FROM
+DESCRIPTION
+Switzerland Witness regarding
+training of little girls as sex traps
+Calling Switzerland witness
+Spencer Kuvin
+Emails searchable
+Epstein address
+Mercedes
+Spencer Kuvin
+Bradley Edwards
+Spencer Kuvin
+Kikka Claudio
+OBJECTION
+TV Interview that is too explicit
+Seeking Computers
+Current address for Nadia
+Marcinkova
+Distribution of Costs
+Voicemail
+Supoenas for depos
+Yellow Cab stuff
+Religious Dildo Washer
+current address
+Yellow Cab stuff
+Setting Depos
+Motion for Status Conf.
+25
+
+
+05469
+05476-05494
+05546
+08/03/2009
+05579-05581
+08/24/2009
+05613-05618
+09/18/2009
+05633
+10/16/2009
+05638-05639
+10/28/2009
+05647
+07/09/2009
+05656
+05659
+05668
+05705
+08/10/2009
+08/27/2009
+10/16/2009
+09/09/2009
+05724
+05727
+05/29/2009
+05/29/2009
+05730-05731
+08/14/2009
+05734
+05/29/2009
+I TO
+Mercedes
+Spencer Kuvin
+Adam Horowitz
+Spencer Kuvin
+Spencer Kuvin
+Adam Horowitz
+Spencer Kuvin
+Adam Horowitz
+Mercedes
+Bradley Edwards
+Adam Horowitz
+Adam Horowitz
+FROM
+Katherine Ezell
+Kikka Claudio
+Spencer Kuvin
+Adam Horowitz
+Kikka Claudio
+Jack Scarola
+Sid
+Jacquie
+Jacquie
+Fistos & Lehrman
+DESCRIPTION
+Judge Marra's July 6 Order
+NPA from
+Villafana
+Haley's affidavit
+Seeking all of Plaintiff's
+computer
+Non-Pros Agreement
+Motion to freeze assets
+Daliah Weiss
+NPA under seal for in camera
+review
+Supoenas for depo
+Order
+Florida Science Foundation
+Video tape of Epstein
+Motion for Status Conf.
+Motion for Status Conf.
+Motion for Status Conf.
+Motion for status conf.
+26
+OBJECTION
+
+
+05737
+08/12/2009
+05750
+05/29/2009
+05770
+05774-05776
+09/04/2009
+05782-05783
+07/09/2009
+05788-05790
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+Spencer Kuvin
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+29
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+31
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+William Berger
+Rob Buschel
+William Berger
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+33
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+privilege;irrelevant & reasonably calculated to
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+privilege; irrelevant & reasonably calculated to
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+00045
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+William Berger
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+privilege; irrelevant & reasonably calculated to
+39
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+Mike Fisten
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+William Berger
+Rob Buschel
+William Berger
+William Berger
+Adler
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+- Bradley
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+:
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+Rob Buschel
+Paul Cassell
+William Berger
+Rob Buschel
+Adler
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+privilege; Irrelevant & reasonably calculated to
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+Susan Sterling
+Denis Kleinfeld
+:
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+Mike Fisten
+Rob Buschel
+Adler
+Rob Buschel
+Rob Buschel
+Adler
+43
+OBJECTION
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+client b
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+privilege; irrelevant & reasonably calculated to
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+privilege irelevant & reasonably calculated to
+lead to
+the discovery of
+admissible
+evidence;protected by privacy rights
+Work
+privilege:irrelevant & reasonably calculated to
+
+
+13315
+08/03/3009
+01080-01081
+06/22/2009
+01077
+05/28/2009
+02445-02446
+05/05/2009
+03049
+09/21/2009
+02425-02426 06/17/2009
+02669
+09/24/2009
+02647
+03688-03691
+08/06/2009
+04/03/2009
+03692-03693
+05/06/2009
+15678-15680
+09/29/2009
+15689
+10/01/2009
+02546-02547
+09/22/2009
+02809-02810
+09/28/2009
+02262
+07/23/2009
+02807-02808
+03760-03828
+10/01/2009
+04/01/2009
+03759
+08358-08359
+04/01/2009
+09/14/2009
+:
+I TO
+Denis Kleinfeld
+Robert C. Buschel
+Robert C. Buschel
+1.
+Susan K. Stirling
+1.
+D.F.
+Susan K. Stirling
+J.
+J.
+Jacquie
+Mike Fisten
+Robin
+Kempner
+т.
+1.
+Susan K. Stirling
+Jacquie
+Jacquie
+D.F.
+N.R.
+Jacquie
+J.
+J.
+N.R.
+RRA Personnel
+RRA personnel
+Adler
+Pat
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Beth Williamson
+Jane Doe brother
+Doe family member
+/v. Atlantic asphalt
+New addition to the case
+OBJECTION
+lead to
+the discovery of admissible
+Work
+privilege; irrelevant & reasonably calculated to
+to the discovery of admissible
+Jane Doe v. Dukenik
+Subpoena for
+Samantha
+info
+Case number assignments
+Case list
+Subpoena for
+Client information
+Client communication
+Client communication
+Discussion re:
+client/victim
+personal information
+Client communication
+Client names/types of action/
+client information
+Conflict Check for Brad
+files
+Client info
+Attorney/Client privilege and/or work product,
+privacy right privilege, not relevant
+44
+
+
+08364-08368
+08370
+08374-08375
+03878
+02955
+02932
+11544-11545
+07432-07435
+06906-06909
+06913-06914
+06030-06031
+05646
+05573
+05540
+05273-05276
+05264
+05267-05270
+02933
+01292
+01068-01070
+01054-01055
+01033
+01030-01031
+10/01/2009
+09/14/2009
+10/01/2009
+06/12/2009
+04/20/2009
+07/17/2009
+09/28/2009
+09/25/2009
+07/17/2009
+06/22/2009
+05/04/2009
+09/18/2009
+07/31/2009
+07/27/2009
+07/27/2009
+06/17/2009
+09/18/2009
+04/02/2009
+04/02/2009
+05/06/2009
+04/03/2009
+Jacquie
+Susan K. Stirling
+Christina Fitch
+Jacquie
+D.F.
+Christina Fitch
+J.
+Susan K. Stirling
+• J.
+Mike Fisten
+Amy Swan
+Amy Swan
+Amy Swan
+Amy Swan
+All Staff
+All Staff
+Susan K. Stirling
+J.
+FROM
+DESCRIPTION
+Client info
+Pat
+Client info
+J.
+Jacquie
+J.
+Robert C. Buschel
+Susan K. Stirling
+William J. Berger
+J.
+M.G.
+1.
+M.G.
+Robin T. Kempner
+Robin T. Kempner
+Robin T. Kempner
+Fistos & Lehrman
+Client info
+Curtis
+Juskowich
+Jane Doe v. Roe
+Client info
+New addition to the case
+Jane Doe v. Roe
+Jane Doe v. Roe
+Espina - Walmart case
+Client meeting
+Client meeting
+Client info
+Client info
+Client info
+Client info
+Jane Doe v. Roe
+Epstein article
+OBJECTION
+Current case list of Brad
+Updated case list for Brad
+case list
+Case number assignments
+45
+
+
+•.
+:
+01118-01120
+01986-01989
+01984-01985
+25925
+25874
+08356-08357
+16760-16761
+08005
+06915-06920
+08360-08363
+04101-04107
+04708-04710
+06910-06912
+07909
+07637-07642
+06795-06799
+06542-06548
+06404-06408
+08338-08339
+08505
+02241-02242
+02243-02244
+02238-02240
+02204
+09/22/2009
+04/02/2009
+04/02/2009
+09/30/2009
+09/30/2009
+09/16/2009
+09/23/2009
+06/05/2009
+06/17/2009
+09/16/2009
+09/28/2009
+09/18/2009
+06/17/2009
+08/10/2009
+09/10/2009
+08/19/2009
+09/15/2009
+09/10/2009
+09/16/2009
+09/14/2009
+05/28/2009
+07/07/2009
+05/28/20009
+07/14/2009
+All Staff
+All Staff
+MG
+NR
+MG
+Jane Doe
+Anthony P
+NR
+
+Bradley
+, Jaffe, Weissing.
+,, Fistos & Lehrman
+FROM
+DESCRIPTION
+1.
+MG
+Jane Doe v. Roe
+1.
+Robin T. Kempner
+Conflict check
+1.
+Robin T. Kempner
+Conflict check
+Robin T. Kempner
+Robin T. Kempner
+NR
+Conflict check
+Additional name
+conflict check
+Client Meeting
+added to
+Jacquie
+MG
+New Client
+New Client
+Jane Doe v. Roe
+Client Meeting
+MG
+MG
+Jane Doe v. Roe
+Epstein Article
+Jane Doe v. Roe
+Same silver car tag
+NR
+NR Interview
+Client Meeting
+Pat
+Pat
+NR
+Client Meeting
+NR Interview
+New Client
+New Client Meeting
+Other Rape Victims
+Confidential Source
+Other Rape Victims
+Confidential Source
+Confidential Source | Litigation Strategy
+46
+OBJECTION
+Attorney/ Client Privilege
+
+
+[DATE
+02298-02299
+02291
+06/04/2009
+02442-02443
+08/17/2009
+02440-02441
+| 10/02/2009
+04318-04321
+09/24/2009
+05111
+06/02/2009
+05152
+06/03/2009
+05164
+06/03/2009
+05166
+06/03/2009
+05169-05170
+06/03/2009
+05173-05174
+06/03/2009
+05212-05213
+06/23/2009
+05215-05217
+06/23/2009
+05175-05189
+07/02/2009
+05194-05196
+06/23/2009
+05204-05206
+06/23/2009
+
+
+
+
+
+
+FROM
+DESCRIPTION
+Fistos & Lehrman
+Confidential Source
+Other Rape Victims
+Confidential Source
+Additional Information
+RE:
+Epstein Molestations
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Bradley Edwards
+Confidential Source
+Providing New Witnesses
+Providing New Witnesses
+Secret Plea Deal for Epstein
+Providing New Witnesses
+Secret Plea Deal of Epstein
+providing new witnesses
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Other Rape Victims
+Confidential Source
+Other Rape Victims
+47
+OBJECTION
+
+
+05227-05228
+05230-05231
+05303
+08/06/2009
+05344-05346
+06/23/2009
+05408
+07/06/2009
+05425-05429
+05/28/2009
+05433-05436
+05/29/2009
+05433-05436
+05/29/2009
+05446
+07/07/2009
+05452-05464
+05/29/2009
+05535-05536
+05538-05539
+05550-05551
+05577-05578
+08/22/2009
+05619-05620
+09/18/2009
+05650
+08/06/200
+05688-05689
+0/28/2009
+
+
+
+
+
+
+
+
+
+
+
+
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Additional
+Information
+Epstein Molestations
+Additional Information
+Epstein Molestations
+Confidential Source
+Secret Plea Deal for Epstein
+Confidential Source
+| Secret Plea Deal for Epstein
+Providing New Witnesses
+Providing New Witnesses
+Confidential Source
+Bradley Edwards
+Bradley
+Other Rape Victims
+Providing New Witnesses
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source Providing New Witnesses
+48
+OBJECTION
+RE: | W/P Priv.; not reasonably calculated to lead to
+RE:
+W/P. Priv.; not reasonably calculated to lead to
+RE:
+
+
+05693-05695
+05/28/2009
+05698
+08/21/2009
+05706-05709
+05/28/2009
+05720-05721
+05/29/2009
+05738-05739
+05/29/2009
+05743-05745
+05/29/2009
+05754
+08/03/2009
+05759-05762
+06/01/2009
+05765-05768
+06/23/2009
+05771-05773
+06/03/2009
+05777-05779
+06/03/2009
+05784-05786
+06/03/2009
+05791-05794
+06/03/2009
+05803
+07/22/2009
+05836-05837
+05842-05843
+Bradley
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Confidential Source
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+49
+OBJECTION
+RE:
+RE:
+RE:
+
+
+05848
+05852-05853
+07/29/2009
+05857-05858
+07/31/2009
+05952-05953
+08/25/2009
+06192-06197
+06/23/2009
+06198-06201
+| 06/24/2009
+06203
+07/23/2009
+06401
+09/23/2009
+06643-06651
+09/17/2009
+06788-06789
+09/28/2009
+06942-06943
+09/26/2009
+06953
+08/14/2009
+06955-06957
+10/02/2009
+06959-06961
+06963-06980
+06986-06989
+10/03/2009
+07010-07014 | 10/04/2009
+
+
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+Confidential Source
+DESCRIPTION
+Confidential Source
+Confidential Source
+Confidential Source
+Confidential Source
+Secret Plea Deal For Epstein
+Secret Plea Deal For Epstein
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+| Litigation Strategy
+50
+OBJECTION
+RE:
+| W/P Priv.; not reasonably calculated to lead to
+
+
+07017-07018
+/ 09/04/2009
+07143-07144
+10/01/2009
+07147-07150
+09/18/2009
+075089-
+07513
+10/13/2009
+07605-07615 | 09/07/2009
+07646-07647
+09/08/2009
+07674-07697
+09/08/2009
+08376
+10/04/2009
+08380
+09/18/2009
+08427-08430
+09/24/2009
+08450
+05/17/2009
+08507
+10/03/2009
+10092-10098
+08/31/2009
+01610
+06/03/3009
+01612
+06/04/2009
+01451-01458
+05/27/2009
+
+
+
+
+Bradley Edwards
+
+
+
+-
+, Jaffe, Weissing.
+FROM
+DESCRIPTION
+Fistos & Lehrman
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Providing New Witnesses
+51
+OBJECTION
+W/P Priv., not reasonably calculated to lead to
+
+
+01608
+01606
+01510
+01506
+01493
+01488
+01486
+01483
+01479
+01449
+01433
+15207-15208
+19716-19719
+19730-19731
+01683
+01693
+03011
+07/03/2009
+07/02/2009
+08/25/2009
+08/24/2009
+08/10/2009
+08/03/2009
+07/22/2009
+05/22/2009
+10/20/2009
+08/14/2009
+09/25/2009
+10/02/2009
+08/06/2009
+08/21/2009
+09/17/2009
+
+
+
+
+
+
+
+
+
+Jacquie
+
+
+„Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Providing New Witnesses
+Other Rape Victims
+Providing New Witnesses
+Providing New Witnesses
+Additional
+Information
+Epstein Molestations
+Confidential Source
+Secret Plea Deal for Epstein
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Confidential Source | Additional
+Information
+52
+OBJECTION
+RE:
+RE:
+RE: | W/P Prlv.; not reasonably calculated to lead to
+
+
+01755-01756 10/02/2009
+01756
+06/22/2009
+01770
+10/08/2009
+03126
+09/18/2009
+02006
+06/23/2009
+02060
+09/23/2009
+03487-03494
+09/19/2009
+02269
+08/26/2009
+02322-02323
+| 10/16/2009
+02595-02596
+09/07/2009
+02866-02867
+09/25/2009
+02895
+08/31/2009
+02901
+09/16/2009
+03032
+09/18/2009
+03057
+10/13/2009
+03070
+I TO
+
+
+
+
+
+
+
+
+FROM
+Fistos & Lehrman
+DESCRIPTION
+Epstein Molestations
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+Additional
+Information
+Epstein Strategy
+Confidential Source Providing New Witnesses
+Other Rape Victims
+Confidential Source
+Secret Plea Deal For Epstein
+Providing New Witnesses
+Confidential Source
+. Additional Information
+Epstein Molestations
+Providing New Witnesses
+Confidential Source
+Confidential Source
+53
+RE:
+RE:
+RE:
+OBJECTION
+
+
+03081-03082
+09/21/2009
+03144
+10/08/2009
+03189-03190
+10/14/2009
+04015
+09/08/2009
+02913
+09/28/2009
+02956-02957
+08/31/2009
+02975
+10/21/2009
+04031-04055
+08/12/2009
+04057
+04060
+08/12/2009
+02979-02980
+10/02/2009
+02998
+07/21/2009
+05626
+10/12/2009
+05630-05631|10/12/2009
+05664-05665
+T10/12/2009
+07976
+08/14/2009
+06655
+06/09/2009
+
+
+
+
+
+
+Bradley|
+
+
+:
+FROM
+Fistos & Lehrman
+DESCRIPTION
+Confidential Source
+Providing Witnesses
+Providing Witnesses
+Confidential Source
+Additional Information
+RE:
+Epstein Strategies
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Additional Information
+Epstein Molestations
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source
+Providing New Witnesses
+54
+RE:
+RE:
+
+
+19986-19987
+09/28/2009
+04905-04906 07/15/2009
+04946-04951 10/28/2009
+05148
+05/22/2009
+05151
+05/26/2009
+05161
+05/28/2009
+05203
+06/23/2009
+05207-05208
+06/23/2009
+05220-05221
+06/23/2009
+05224-05225
+06/24/2009
+05239
+06/23/2009
+05277-05278
+06/23/2009
+05324-05325
+06/23/2009
+05368-05369
+| 06/23/2009
+05387-05388
+06/23/2009
+02811-02812
+10/03/2009
+
+
+
+
+Confidential.
+Bradley Edwards
+Bradley
+F*
+:
+, Jaffe, Weissing..
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Confidential Source
+Additional
+Information
+Epstein Molestations
+RE:
+Confidential Source
+Confidential Source
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Secret Plea Deal For Epstein
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+Confidential Source
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+Secret Plea Deal For Epstein
+Confidential Source
+Additional Information
+Epstein Molestations
+RE:
+OBJECTION
+W/P. Priv.; not reasonably calculated to lead to
+55
+
+
+01280-01288
+09/18/2009
+01131-01134
+10/08/2009
+00988
+04/25/2009
+10163-10167
+08/12/2009
+10181-10188
+08/12/2009
+10245-10251
+09/08/2009
+10364-10367
+09/17/2009
+10586-10591
+09/24/2009
+10625-10632
+10/02/2009
+10698-10699
+10/13/2009
+10718-10719
+10/13/2009
+10927-10937
+05/28/2009
+10945-10954
+05/29/2009
+10964-10978
+06/02/2009
+10991
+06/22/2009
+11006-11010 | 06/23/2009
+
+Bradley Edwards
+Bradley
+:
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Confidential Source
+Confidential Source
+Additional
+Information
+Epstein Molestations
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+OBJECTION
+w/p Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+RE: | W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+Confidential Source
+Providing New Witnesses
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+Confidential Source
+Providing New Witnesses
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+Confidential Source
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Additional Information
+Epstein Molestations
+Additional
+Information
+Epstein Molestations
+Confidential Source
+Additional Information
+Epstein Molestations
+Confidential Source
+Confidential Source
+Providing New Witnesses
+Confidential Source
+Providing New Witnesses
+RE:
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+RE: | W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+RE: W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+RE: | W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+Confidential Source Additional
+Information
+W/P Privilege; Not reasonably calculated to lead
+Epstein Molestations
+to discovery of admissible evidence.
+Confidential Source
+Additional
+Information
+RE: W/P Privilege; Not reasonably calculated to lead
+Epstein Molestations
+to discovery of admissible evidence.
+Confidential Source
+Additional
+Information
+RE: | W/P Privilege; Not reasonably calculated to lead
+56
+
+
+11075-11076
+07/29/2009
+11080-11082
+07/31/2009
+11085-11097
+09/04/2009
+11123-11136
+09/17/2009
+11140-11142 | 10/04/2009
+11150-11151
+10/12/2009
+10390-10393
+09/19/2009
+11157-11165
+10/25/2009
+11170-11174
+06/23/2009
+11184-11185
+/05/27/2009
+11188-11195
+05/28/2009
+11198-11200
+| 05/28/2009
+11208-11214
+705/29/2009
+11223-11236 06/01/2009
+11260-11266 06/24/2009
+11320-11325
+
+
+
+
+
+
+
+
+
+
+
+
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein Molestations
+Confidential Source
+Additional Information
+RE:
+Epstein Molestations
+Confidential Source
+Additional
+Information
+RE:
+Epstein Molestations
+Providing New Witnesses
+Confidential Source
+Confidential Source
+Additional
+Information
+Epstein Molestations
+Additional
+Information
+Epstein Molestations
+Additional
+• Information
+Epl
+Molestations
+Providing New Witnesses
+Additional Information
+Epstein Molestations
+Additional Information
+Epstein Molestations
+Additional Information
+Epstein Molestations
+57
+RE:
+RE:
+RE:
+RE:
+RE:
+RE:
+OBJECTION
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+
+
+11372-11373
+11380-11383
+08/12/2009
+11438-11442
+09/17/2009
+11549-11550
+10/01/2009
+11574-11579
+10/13/2009
+BOX 2
+08029-08032
+09/14/2009
+08026-08028
+07738-07739
+07747
+05/01/2009
+05/13/2009
+09/17/2009
+07758-07759
+05/05/2009
+
+
+
+
+source
+
+Paul Cassell
+Paul Cassell,
+Paul Cassell
+Jonathan
+Birkman
+:
+• Fistos & Lehrman
+FROM
+DESCRIPTION
+Additional
+Information
+Epstein Molestations
+RE:
+OBJECTION
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+W/P Privilege; Not reasonably calculated to lead
+to discovery of admissible evidence.
+EROM
+Tami Wolfe
+Bradley Edwards
+Bradley
+William Berger
+DESCRIPTION
+58
+OBJECTION
+
+
+07760-07765
+07766
+07767-07784
+07785-07790
+07791
+07792-07793
+07794-07841
+07842-07848
+09/11/2009
+10/11/2009
+05/01/2009
+06/26/2009
+04/04/2009
+04/01/2009
+04/04/2009
+06/16/2009
+Jacquie
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Attorneys at RRA
+Edwards Litigation Strategy
+| Paul Cassell
+Full draft of motion to stay
+Paul Cassell
+OBJECTION
+W/P: Attorney Client Privilege; Irrelevant anc
+privacy right:
+W/P; Attorney Client Privilege; Irrelevant anc
+discovery of admissible evidence: protected by
+59
+
+
+07849-07852
+04/10/2009
+07853-07856
+06/10/2009
+07857-07862
+09/11/2009
+07863-07864
+06/10/2009
+07685-07874
+05/14/2009
+07875-07876
+04/14/2009
+07877-07884
+08/03/2009
+07886-07888
+08/02/2009
+IO
+Paul Cassell
+Paul Cassell
+Jacquie
+Cara
+Y
+FROM
+Fistos & Lehrman
+DESCRIPTION
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Paul Cassell
+OBJECTION
+60
+
+
+07889-07892
+07893-07904
+07905-07908
+07910-07912
+07916
+07919
+07920-07930
+05399
+05355-05357
+05/01/2009
+07/27/2009
+07/22/2009
+08/10/2009
+10/16/2009
+08/27/2009
+10/18/2009
+10/17/2009
+09/09/2009
+IO
+Paul Cassell
+Jacquie
+Jacquie
+Jacquie
+Paul Cassell
+William Berger
+Adler
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Mike Fisten
+Bradley Edwards
+OBJECTION
+privacy right!
+W/P; Attorney Client Privilege; Irrelevant anc
+61
+
+
+05375-05378
+600Z/0T/60
+I PATE
+05372
+600z/0z/t0
+05380-05381
+09/11/2009
+S8ESO-18E5O
+600z/ST/60
+05348
+600Z/ST/60
+05341
+09/04/2009
+05329-05330
+04/09/2009
+05332-05333
+600z/oz/s0
+Marc Nurik
+Jacquie
+Jacquie Johnson
+Beth Williamson
+William Berger
+:
+FROM
+• Fistos & Lehrman
+DESCRIPTION
+Edward
+William Berger
+Bradley
+29
+OBJECTION
+not réasonably calculated to lead to the
+
+
+05320-05323
+1 DATE
+05312-05313
+07/22/2009
+05306-05307
+07/22/2009
+ZOESO
+6002/22/L0
+05281
+05282-05283
+04/09/2009
+6002/60/80
+05288-05291
+07/22/2009
+05292
+07/22/2009
+IO
+Nora Batian
+Nora Batian
+Attorney at RRA
+Beth Williamson
+Attorneys at RRA
+-
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Amy Swan
+Mike Fisten
+Review of litigation materials
+William Berger
+Ken Jenne
+Jane Doe v. Us
+Dr. Swan
+RE: Epstein Meeting
+63
+OBJECTION
+privacy riehts
+W/P; Attorney Client Privilege; Irrelevant anc
+
+
+05295-05297
+05298
+05261
+18358-18359
+04431-04432
+04419-04420
+04403-04416
+04387-04402
+07/23/2009
+08/03/2009
+07/23/2009
+07/24/2009
+08/14/2009
+04/09/2009
+10/17/2009
+08/19/2009
+:
+IO
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Priscilla
+RE: Epstein Conference Room
+Nascimento
+Reserved
+Mike Fisten
+Amy Swan
+Jacquie
+Paul Cassell
+Paul Cassell
+Ken Jenne
+Paul Cassell
+OBJECTION
+Discussion of Epstein strategy
+Victim Psychological Assessment
+Investigation
+planes
+into
+Epstein's
+Edwards RE. Epstein-Maxwell Subpoena
+RICO Statement
+Punitive Damages
+Victim Complaints,
+accountants,
+&
+Forensic W/P; Attorney Client Privilege; Irrelevant and
+Epstein's not reasonably calculated to lead to the
+Fraudulent Transfers
+64
+
+
+01082
+04363
+04343-04344
+04340-04342
+04339
+00989
+04325-04328
+00155
+04312-04313
+600Z/20/60
+600Z/t0/60
+09/14/2009
+09/04/2009
+09/03/2009
+09/04/2009
+06/25/2009
+05/26/2009
+IO
+Jacquie
+Jacquie
+Jacquie
+Mike Fisten
+Paul Cassell
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Subpoenas
+for
+Epstein's BP: Attorney Client Privilege; relevant and
+Housekeepers
+LM
+W/P; Attorney Client Privilege; Irrelevant anc
+Jacquie
+Investigation
+planes
+into
+Epstein's
+Investigation
+planes
+into
+Epstein's
+Investigation
+planes
+into
+Epstein's
+William Berger
+Alessi Depo
+RE: Epstein- beneficiaries
+&
+response to asset freeze motion
+Paul Cassell
+20 Cases & Bond
+Paul Cassell
+RE: Epstein Accounting: Freezing
+65
+
+
+04314-04317
+04307-04308
+04309-04311
+04295
+04305-04306
+04274-04276
+18334-18336
+04216-04219
+09/11/2009
+04/08/2009
+05/26/2009
+09/11/2009
+04/08/2009
+05/06/2009
+07/24/2009
+09/08/2009
+_TO
+Paul Cassell
+Paul Cassell
+Jacquie
+Paul Cassell
+William Berger
+Ken Jenne
+William Berger
+:
+Jaffe, Weissing,
+_ Fistos & Lehrman
+FROM
+DESCRIPTION
+Assets
+RE: Epstein- Add to our motion
+for a protective order
+Paul Cassell
+Motion to stay-response &
+motion to unseal Fed Civil Case
+OBJECTION
+Epstein Assets
+&
+Forensic
+Accounting
+thoughts on Epstein's Victims
+| Motion to Strike references to
+the NPA & Revised response to
+the motion to stay
+Sandy Berger Telephone call
+Investigation
+planes
+into
+Epstein's
+State Judge ordered no contact
+with any underage girl
+66
+
+
+04202-04206
+04207-04215
+04191-04193
+04194-04195
+04196-04199
+25937
+25923
+25832-25838
+25825-25826
+09/08/2009
+09/04/2009
+09/04/2009
+09/04/2009
+09/08/2009
+10/25/2009
+09/09/2009
+06/01/2009
+10/05/2009
+Attorneys at RRA
+Paul Cassell
+Attorneys at RRA
+Scott Rothstein
+Attorneys at RRA
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+William Berger
+Epstein's attorneys
+&
+Bob
+Josephsberg have filed several not reasonably calculated to lead to the
+motions on limits of the no
+contact order
+Paul Cassell
+contec to Crton RE: Protective pia terney Client Privilege; Irrelevant and
+William Berger
+Finding out who is protected by
+the order
+Steven Jaffe
+Seek Court Interyention
+not reasonably calculated to • lead to the
+William Berger
+Finding out who is protected by
+the order
+Ken Jenne
+Epstein's house staff
+Maribel Matiska
+legal opinion RE: Epstein
+William Berger
+contact Information re: who is
+pertinent to the case
+William Berger
+Trial Prep Epstein
+67
+
+
+19649-19651
+07/24/2009
+19658-19661
+08/03/3009
+25809-25810
+10/04/2009
+04466-04469
+08/18/2009
+01296
+10/02/2009
+04439-0442
+09/16/2009
+04445
+07/31/2009
+04425-04428
+09/18/2009
+IO
+William Berger
+Mike Fisten
+Jacquie
+Paul Cassell
+:
+, Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Ken Jenne
+Investigation
+planes
+into
+Ken Jenne
+Copperfield Depo
+Trail Prep
+Paul Cassell
+Epstein Assets Subpoena
+Michael Wheeler
+Subpoena of Detective Recarey
+Paul Cassell
+RE: Epstein-Notice Of IME
+RE:Epstein
+Reminder-Mon
+8/3/09-Monthly
+Call
+in
+Telephone Conference
+Jane Doe Depo Set for the 30*
+OBJECTION
+Epstein's
+/W/P; Attorney Client Privilege; Irrelevant and
+68
+
+
+04429
+25770-25772
+25768-25769
+26716-26717
+26714-26715
+20907-20908
+19857-19860
+19861-19862
+10/07/2009
+10/05/2009
+10/05/2009
+09/04/2009
+10/13/2009
+10/05/2009
+10/17/2009
+10/23/2009
+William Berger
+Mike Fisten
+Attorneys at RRA
+Mike Fisten
+Paul Cassell
+.
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+William Berger
+Ken Jenne
+Adler
+William Berger
+Pat
+Motion for Sanctions
+Victims for Trial
+Victims for Trail
+NR as a victim
+Trial date procured
+Victims for Trial
+Epstein's Palm Beach Property
+Larry Visoski Depo
+OBJECTION
+privacy rignts
+W/P; Attorney Cllent Privilege; Irrelevant and
+69
+
+
+19713-19715
+09/09/2009
+IO
+19720-19729
+09/30/2009
+Mike Fisten
+19706-19707
+09/09/2009
+19693-19695
+09/04/2009
+Mike Fisten
+19696-19697
+09/04/2009
+Jacquie
+19698-19700
+09/04/2009
+Mike Fisten
+19685-19688
+08/27/2009
+19689-19690
+09/02/2009
+Mike Fisten
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie
+OBJECTION
+Copperfield Subpoena
+Jacquie
+Tentative Subpoena dates and Will: torney Client Privilege; Irrelevant and
+people list
+Jacquie
+Dershowitz Subpoena ready to be
+signed
+Investigation
+planes
+into
+Epstein's
+Setting Up Depo Times
+Bradley Edwards
+Investigation in Epstein's planes
+Ken Jenne
+RE: Witness information that we
+need to use
+Jacquie
+Awaiting dates for the 2 other
+pilots, Dershowitz & Copperfield
+70
+
+
+19691-19692
+19673-19674
+19654-19655
+19656-19657
+19662-19663
+19652-19653
+18348-18349
+04272
+19683-19684
+09/02/2009
+08/10/2009
+08/03/2009
+08/03/2009
+08/03/2009
+08/26/2009
+08/27/2009
+06/30/2009
+08/19/2009
+IO
+Mike Fisten
+Jacquie!
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Jacquie
+William Berger
+Mike Fisten
+:
+| Fistos & Lehrman
+FROM
+DESCRIPTION
+Pat
+Bill Subpoena
+OBJECTION
+Ken Jenne
+Pat
+Depo List
+Setting Up Copperfield Depo
+List of péople to subpoena
+Setting Up Copperfield Depo
+Witness information that we
+need to use
+RE: Witnesses information that
+we need to use
+Investigation
+planes
+into
+Epstein's
+Potential New Witnesses
+71
+
+
+19856
+20888
+20946
+05807-05810
+05262-05263
+25829
+25830-25831
+25811-25813
+10/17/2009
+09/12/2009
+05/11/2009
+07/23/2009
+07/22/2009
+05/11/2009
+05/11/2009
+05/11/2009
+IQ
+Mike Fisten
+Adler
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Priscila
+Nascimento
+Jacquie.
+William Berger
+Investigation
+planes
+into
+Potential New witnesses
+Investigation
+planes
+into
+Conference room reserved
+Investigator information
+Motion to unseal criminal records
+Investigation
+planes
+into
+Investigation
+planes
+into
+OBJECTION
+Epstein's W/P; Attorney Client Privilege; Irrelevant and
+Epstein's | W/P; Attorney Client Privilege; Irrelevant and
+Epstein's
+Epstein's
+| W/P; Attorney Client Privilege; Irrelevant and
+72
+
+
+25815-25822
+06/01/2009
+18358-18359
+05382
+07/24/2009
+09/12/2009
+08033-08070
+10/23/2009
+25997
+10/23/2009
+10/23/2009
+26741-26763
+25774-25777
+18177-18179
+05/12/2009
+08/24/2009
+IO
+William Berger
+Attorneys at RRA
+Scott Rothstein
+Attorneys at RRA
+Ken Jenne
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Ken Jenne
+Mike Fisten
+Mike Fistos
+Adler
+Bradley
+Susan Stirling
+OBJECTION
+privacy rights.
+Depo information
+Investigation
+planes
+into
+Epstein's W/P; Attorney Client Privilege; Irrelevant and
+Potential new witnesses
+Legal Research RE: Causes of
+action against Epstein
+Legal Research RE: causes of
+action against Epstein
+Legal Research RE: causes of
+action against Epstein
+Filed Motions
+Epstein Probation
+73
+
+
+18174-18176
+08/24/2009
+18172-18173
+08/24/2009
+18170
+03106
+08/24/2009
+06/03/3009
+02593-02594
+05/13/2009
+08014
+Undated
+27494
+10/23/2009
+18166-18167
+Ken Jenne
+Mike Fisten
+Unknown Staff
+Attorneys at RRA
+Bradley
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Epstein Probation
+Mike Fisten
+Shawn Gilbert
+Shawn Gilbert
+Mike Fistos
+Mike Fisten
+OBJECTION
+Epstein Probation
+Epstein Probation
+W/P; Attorney Client Privilege; Irrelevant anc
+Epsteín Case Info
+Discussion
+with
+secretary
+regarding client information
+discovery of admissible evidence: protected by
+Miscellaneous case info
+Legal Research RE: Causes of W/P; Attorney Client Privilege; Irrelevant and
+action against Epstein
+Copperfield Depo
+74
+
+
+18164-18165
+18771-18773
+18742-18744
+18737-18741
+20263-20282
+20219-20262
+17225-17230
+17038-17040
+16916-16928
+08/03/2009
+04/27/2009
+09/10/2009
+09/10/2009
+10/14/2009
+10/14/2009
+07/22/2009
+10/29/2009
+10/19/2009
+Marc Nurik
+Jacquie|
+Jacquie
+Pat
+Mike Fisten
+Pat
+Mike Fisten
+Cara
+-
+:
+Jaffe, Weissing, Edwards, Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Copperfield Depo
+Ronald Wise
+Ronald Wise
+Jacquie
+Jacquie
+| Jacquie
+OBJECTION
+Legal Research RE: causes of | W/P; Attorney Client Privilege; Irrelevant and
+action against Epstein
+Dershowitz Depo
+Depo technicalities
+Vehicle Registrations-Visoski
+Visoski Research & Questions
+Wayne Black Retainer
+RE: Subpoenas for Epstein's
+attorneys
+Witness List
+75
+
+
+16795-16796
+16455-16759
+16436-16437
+16400-16404
+16394-16395
+01046
+01048-01050
+01052
+10/01/2009
+09.10/2009
+09/09/2009
+600z/20/60
+600Z/TE/80
+600z/sz/80
+010z/8Z/L0
+600Z/60/60
+Mike Fisten
+Cara
+William Berger
+Attorneys at RRA
+Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+PESCRIPTION
+Jacquie
+Jacquie
+Jacquie.
+Jacquie!
+Jacquie
+Trump Depo
+Depo Dates
+Dershowitz Depo
+Investigation
+planes
+into
+Epstein's
+Depo Dates
+Computer information
+Hard drive of Plaintiff's computer
+Maribel Matiska
+legal Opinion RE: Epstein
+OBJECTION
+privacy right!
+N/P; Attorney Client Privilege; Irrelevant anc
+reasonably calculated to lead to the
+76
+
+
+01100
+10/19/2009
+01105
+01111
+01112-01117
+05/13/2009
+05/12/2009
+01139-01142
+01151
+04/29/2009
+09/11/2009
+01167
+09/11/2009
+01216
+05/21/2009
+Adler
+Staff
+Beth Williamson
+-
+:
+„Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Alan Garten
+Paul Cassell
+William Berger
+Jacquie |
+William Berger
+OBJECTION
+privacy rignts
+Dershowitz Involvement
+Potential New Witnesses
+Legal research
+Dr. Swan
+•
+Epstein Depo revised
+Motion for protective order final
+draft
+Epstein MPO
+Immunity for testimony about
+prostitution
+77
+
+
+01247
+09/30/2009
+01268-01269
+10/22/2009
+01293
+08/19/2009
+01299
+04/21/2009
+01305
+08/24/2009
+01313
+09/02/2009
+01333
+08/03/3009
+01335
+08/03/2009
+Ken Jenne
+Paul Cassell
+Attorneys at RRA
+Jacquie
+Jacquie
+Mike Fisten
+Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie.
+Marc Nurik
+Carolyn
+OBJECTION
+Therapy Notes
+Epstein meeting
+orivacy rights
+Epstein Assets
+N/P; Attorney Client Privilege; Irrelevant anc
+Order denying the motion to
+reassign or transfer
+Computers
+Epstein Depo
+Epstein Depo
+Investigation into Epstein planes
+78
+
+
+01337
+01363
+08/10/2009
+09/08/2009
+01414-01416
+98/18/2009
+01417
+01429
+01431
+01432
+08/24/2009
+09/09/2009
+07/31/2009
+09/15/2009
+01434
+10/19/2009
+01461
+04/27/2009
+Jacquie
+Ken Jenne
+& Ken Jenne
+Mike Fisten
+Attorneys at RRA
+Jacquie
+Marc Nurik
+Marc Nurik
+, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein Depo list
+Motion to freeze assets
+Mike Fisten
+Epstein Potential Witness List
+Potential Witnesses
+Epstein telephone conference
+today
+Epstein case info
+Pat
+New Victims
+Epstein Evidence
+Epstein Info
+OBJECTION
+privacy right:
+W/P; Attorney Client Privilege; Irrelevant anc
+79
+
+
+01466
+01471
+01480
+01482
+01491
+01492
+01495
+01498
+07/31/20009
+07/18/2009
+07/22/2009
+07/24/2009
+08/10/2009
+08/10/2009
+08/17/2009
+William Berger
+Wayne Black
+Attorneys at RRA
+Ken Jenne
+Ken Jenne
+Jacquie Johnson
+Marc Nurik
+Marc Nurik
+Privilege Log-Dated 2-23-2011
+Jaffe, Weissing.!
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein Presentation
+Investigation into
+planes
+Epstein Meeting
+Investigation into Epstein planes
+Investigative fees
+Bradley
+The Mar-a-Lago Club Depo
+Potential Witness
+Legal opinion re:Epstein
+OBJECTION
+privacy right:
+Epstein's | W/P; Attorney Client Privilege; Irrelevant anc
+not reasonably calculated to lead to th
+80
+
+
+01502
+01513
+01522
+01522
+01523-01524
+01527
+01540
+01553
+08/21/2009
+08/25/2009
+08/14/2009
+10/08/2009
+10/26/2009
+04/27/2009
+05/01/2009
+09/10/2009
+IQ
+Marc Nurik
+Jacquie
+Ken Jenne
+Marc Nurik
+Marc Nurik
+William Berger
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein Evidence
+Marc Nurik
+Jacquie Johnson
+Discovery for the girls
+Legal opinion
+New Victim
+Meeting on Epstein
+New Victim
+Litigation Strategy on punitive
+damages
+Letter from JP
+Chase
+rivacy right:
+N/P; Attorney Client Privilege; Irrelevant anc
+W/P; Attorney Client Privilege; Irrelevant. and
+lot reasonably calculated to lead to the
+81
+
+
+01566
+98ST0
+
+01607
+01621
+01622
+01624
+01627
+05/11/2009
+ITO
+Wayne Black
+05/26/2009
+Paul Cassell
+6002/T0/0L
+Jacquie
+600z/LT/01
+Paul Cassell
+6002/6T/t0
+Marc Nurik
+06/09/2009
+Susan Stirling
+06/11/2009
+05/06/2009
+Robert Buschel
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+New Victim
+Marc Nurik
+OBJECTION
+Opposition to the continuance of W/P; Attorney Client Privilege; Irrelevant and
+the trial date
+Trump Depo
+Litigation Strategy on motions
+Edwards Potential New Witness
+Important phone call due today
+Motion for bond asset transfer
+Dateline interest into epstein
+82
+
+
+01628
+06/15/2009
+01635
+05/21/2009
+01636
+06/23/2009
+01638
+01644
+01646
+01648
+06/29/2009
+07/06/2009
+07/06/2009
+07/11/2009
+01650
+07/13/2009
+01658-01659
+07/18/2009
+• P
+Robert Buschel
+Susan Stirling
+Paul Cassell
+
+
+Wayne Black
+Carl Linder
+Paul Cassell
+Fistos & Lehrman
+EROM
+DESCRIPTION
+Investigations
+Carolyn
+Personal Conversation
+Motion to unseal
+Litigation Strategy RE: Motion to | W/P; Attorney Client Privilege; Irrelevant and
+unseal
+Edwards Request for admission
+Secret Plea deal for Bear Stearns
+Investigating Epstein's planes
+Epstein's Assets
+I DOJ
+83
+•
+
+
+01663
+01668
+01764
+01676
+01681
+01682
+01684
+01686
+[PATE
+07/18/2009
+07/29/2009
+07/31/2009
+10/17/2009
+08/03/20009
+09/04/2009
+09/11/2009
+09/11/2009
+Mike Fisten
+Paul Cassell
+Mike Fisten
+Paul Cassell
+Jacquie
+Mike Fisten
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein's cars
+Wayne Black
+number
+Carolyn
+Case Numbers
+Motions
+Positing
+regarding
+preparation
+litigation
+Litigation Strategy-Order 242
+Plaintiff firms the notices of
+depos
+Potential new witnesses
+OBJECTION
+W/P; Attorney Cllent Privilege; Irrelevant and
+84
+
+
+01692
+01698
+01702
+01705
+01711
+01737
+01564
+01603
+09/12/2009
+05/05/2009
+09/17/2009
+05/14/2009
+04//01/2009
+07/14/2009
+05/11/2009
+10/15/2009
+William Berger
+Paul Cassell
+Paul Cassell
+William Berger
+Carolyn
+Richard Wolfe
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Proposal for settlement
+Epstein Victim Depos
+Epstein Depos
+Statutory Rape
+/ Third party subs
+(Bradley
+Facebook/Myspace
+Investigation Epstein's planes
+Adam Horowitz
+Testimony RE: Vehicles
+OBJECTION
+W/P; Attorney Client Privilege; Irrelevant anc
+discovery of admissible evidence: protected by
+85
+
+
+01742
+10/12/2009
+01743
+6007/62/01
+01745
+600₴/ST/01
+05726
+08/14/2009
+27395
+08/13/2009
+26356
+04225
+08/13/2009
+06/15/2009
+04229-04233
+06/16/2009
+Beth Williamson
+Beth Williamson
+&
+Jacquie
+Marc Nurik
+Scott Rothstein
+Wayne Black
+...
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Filing fee check
+Paul Cassell
+William Berger
+Scot Rothstein
+Adler
+Wayne Black
+OBJECTION
+privacy rignts
+New folder for Jane Doe Created
+Epstein's Cars
+N/P; Attorney Client Privilege; Irrelevant anc
+Legal opinion
+Legal Research RE: causes of
+/W/P; Attorney Client Privilege; Irrelevant and
+action against Epstein
+Legal Research RE: causes of W/P; Attorney Client Privilege; Irrelevant and
+action against Epstein
+Epstein Victims
+Epstein secret plea deal with
+Bear Stearns
+86
+
+
+04237-04242
+04246
+04250
+04255-04256
+04260
+04523
+05088-05090
+05108
+06/15/2009
+06/15/2009
+06/15/2009
+06/15/2009
+06/15/2009
+05/14/2009
+10/27/2009
+04/01/2009
+Wayne Black
+Wayne Black
+Wayne Black
+Attorneys at RRA
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Epstein secret plea deal with 06/P; Altorney Client Privilege: Irrelevant and
+Bear Stearns
+Epstein secret plea deal for Bear Wilc torney Client Privilege; Irelevant and
+orivacy rights
+Epstein Victims
+N/P; Attorney Client Privilege; Irrelevant anc
+Epstein secret plea deal for Bear
+Stearns
+Wayne Black
+Epstein secret plea deal for Bear
+Stearns
+Wayne Black
+Investigating Epstein's planes
+Ken Jenne
+Epstein's assets
+Carolyn
+Victims employment
+87
+
+
+05145
+05/21/2009
+05237
+07/20/2009
+02651
+05970-81970
+08/10/2009
+07/29/2009
+02661-02662
+05/12/2009
+02674-02677
+08/18/2009
+02678-02679
+04/10/2009
+02682-02683
+08/10/2009
+02718-02720
+06/25/2009
+Wayne Black
+Jacquie
+Adler
+Jacquie
+Adler
+Jacquie
+-
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Carolyn
+Epstein Hearing
+Investigating Epstein's planes
+Wayne Black
+Bradley
+Seth Lehman
+OBJECTION
+W/P; Attorney Client Privilege; Irrelevant anc
+discovery of admissible evidence: protected by
+88
+
+
+02728-02729
+02746
+07/22/2009
+02813-02814
+08/26/2009
+02817-02826
+02827-02832
+05/12/2009
+02833-02835
+08/23/2009
+02874-02876
+05/23/2009
+02887-02888
+08/26/2009
+IO
+Attorneys at RRA
+Jaffe, Weissing.!
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Spencer Kuvin
+Adam Steinberg
+Pat i
+William Berger
+William Berger
+Pat Diaz
+William Berger
+Pat
+Providing New Witnesses
+Other Rape Victims
+89
+OBJECTION
+not reasonably calculated to lead to
+the
+
+
+02889-02890
+02891
+02892
+02894
+02899
+03001-03002
+03003
+03004
+[DATE
+10/14/2009
+10/12/2009
+08/03/2009
+09/09/2009
+09/29/2009
+05/15/2009
+04/15/2009
+06/23/2009
+Mike Fisten
+Susan Stirling
+Paul Cassell
+Wayne Black
+-
+Jaffe, Weissing..
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Paul Cassell
+William Berger
+Paul Cassell
+OBJECTION
+90
+
+
+03005-03006
+] DATE
+08/03/2009
+IQ
+Mike Fisten
+03007
+10/07/2009
+Paul Cassell
+03008
+04/23/2009
+Susan Stirling
+03013
+05/25/2009
+03014
+10/08/2009
+03015
+04/24/2009
+Steven Jaffe
+03017-03018
+08/18/2009
+Mike Fisten
+03019
+09/19/2009
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Cara Holmes
+Susan Stirling
+Pat
+Providing New witnesses
+OBJECTION
+rivacy rights
+N/P; Attorney Client Privilege; Irrelevant anc
+91
+
+
+03020
+03021-03027
+03031-03034
+03035
+03039
+03040
+03044
+03045-03047
+03048
+09/16/2009
+09/19/2009
+09/18/2009
+09/29/2009
+06/05/2009
+09/04/2009
+09/09/2009
+09/30/2009
+04/21/2009
+Pat
+Adler
+Mike Fisten
+Bradley
+| Paul Cassell
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie
+Pat
+Paul Cassell
+William Berger
+Jacquie
+Paul Cassell
+Susan Stirling
+OBJECTION
+W/P; Attorney Client Privilege; Irrelevant anc
+Litiation Strategy
+92
+
+
+03050-03052
+10/16/2009
+03053
+10/17/2009
+03054
+10/13/2009
+03056
+ZLOEO
+03073
+6002/22/90
+09/04/2009
+09/01/2009
+03074-03075
+10/28/2009
+03100
+10/15/2009
+I TO
+Attorneys at RRA
+Jacquie
+-
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Mike Fisten
+Grant
+Mike Fisten
+Wayne Black
+Mike Fisten
+Other Rape Victims
+Michael Wheeler
+Mike Fisten
+OBJECTION
+93
+
+
+_DATE
+07/21/2009
+03102-03103
+03107-03113
+03114
+03115-03118
+07/24/2009
+05/16/2009
+03124
+06/23/2009
+03125
+09/08/2009
+03127-03128
+05/19/2009
+03135-03136
+IO
+William Berger
+Susan Stirling
+Mike Fisten
+-
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Paul Cassell
+Mike Fisten
+Susan Stirling
+Wayne Back
+Other Rape Victims
+94
+OBJECTION
+rivacy right:
+N/P: Attorney Client Privilege; Irrelevant anc
+discovery of admistible edence; prodecte the
+lot reasonably calculated to lead to the
+
+
+03137
+03138
+03146
+03147-03154
+03155-03155
+03158-3159
+03191-03196
+6002/27/80
+600z/80/0т
+6002/0€/0T
+08/22/2009
+10/07/2009
+10/08/2009
+04/28/2009
+10/14/2009
+Wayne Black
+Beth Williamson
+Jacquie.
+Paul Cassell
+...
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Beth Williamson
+Jacquie
+Susan Stirling
+OBJECTION
+95
+
+
+03197-03199
+600г/tT/80
+03205-03211
+09/13/2009
+03212
+600Z/1T/80
+03213
+10/28/2009
+03214-03218
+03223-03232
+03233-03242
+10/27/2009
+04/15/2009
+09/28/2009
+03245
+06/01/2009
+03251-03252
+09/24/2009
+Attorneys at RRA
+Paul Cassell
+Paul Cassell
+William Berger
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Jacquie,
+Ronald Wise
+Paul Cassell
+Paul Cassell
+Berger
+Paul Cassell
+OBJECTION
+W/P; Attorney Client Privilege; Irrelevant anc
+W/P; Attorney Client Privilege: Irrelevant and
+96
+
+
+IO
+03303
+03306-03307
+09/04/2009
+Paul Cassell
+03308-03309
+09/04/2009
+Beth Williamson
+03310-03314
+09/04/2009
+Paul Cassell
+03389
+Beth Williamson
+03392-03393
+09/04/2009
+Williamson
+03461-03463
+09/19/2009
+03464-03465
+06/14/2009
+Paul Cassell
+. Fistos & Lehrman
+FROM
+DESCRIPTION
+Beth Williamson
+Beth Willamson
+Susan Stirling
+97
+OBJECTION
+privacy right:
+W/P; Attorney Client Privilege; Irrelevant anc
+W/P; Attorney Client Privilege; Irrelevant anc
+
+
+03469-03486
+06/15/2009
+03495
+08/27/2009
+03496-03501
+10/28/2009
+03502-03506
+10/27/2009
+03507-03510
+10/28/2009
+03511-03513
+10/28/2009
+10/26/2009
+03514-03516
+03520-03523
+07/04/2009
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Paul Cassell
+, Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie
+Ronald Wise
+Paul Cassell
+Ronald Wise
+Ronald Wise
+Paul Cassell
+/Litigation Strategy
+98
+OBJECTION
+pre Attorney Client Privilege: Irelevant and
+
+
+03524
+03525-03530
+03532
+9ESE0
+OT550-655E0
+03541-03544
+03545-03547
+03548-03549
+09/04/2009
+09/05/2009
+08/24/2009
+600г/6t/L0
+600z/92/80
+10/12/2009
+06/26/2009
+04/11/2009
+IO
+William Berger
+William Berger
+Jacquie
+Pat
+Attorneys at RRA
+Wayne Black
+-
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Ronald Wise
+Paul Cassell
+Providing New Witnesses
+OBJECTION
+prY Attorney Clent Privilege; Irrelevant and
+W/P; Attorney Client Privilege; Irrelevant anc
+lot reasonably calculated to lead to the
+99
+
+
+03550-03574
+03575-03588
+03589-03604
+03605-03606
+01960-40960
+03611-03612
+03613-03615
+03616-03618
+03628-03637
+09/09/2009
+10/19/2009
+04/11/2009
+10/16/2009
+600Z/9T/0T
+10/16/2009
+10/29/2009
+10/01/2009
+09/15/2009
+Attorneys at RRA
+Kendall Coffey
+Paul Cassell
+Attorneys at RRA
+William Berger
+Attorneys at RRA
+Pat Diaz
+Jacquie
+Fistos & Lehrman
+FROM
+Paul Cassell
+DESCRIPTION
+Bradley
+Cara
+Providing New Witnesses
+Litigation Strategy.
+Providing New Witnesses
+OBJECTION
+100
+
+
+03638-03641
+08454
+08118-08123
+09/08/2009
+10/23/2010
+10/23/2009
+08124-08156
+02411-02413
+01913-01914
+10/23/2009
+05/12/2009
+06/15/2009
+01918-01919
+04/15/2009
+01920-01924
+05/20/2009
+/TO
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Susan K. Stirling
+Attorneys at RRA
+Paul Cassell
+...
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Mark Fistos
+Adler
+Steven Jaffe
+Bradley
+OBJECTION
+J.
+Jane Doe Il v. Epstein
+Work
+product;
+attorney/client privilege;
+1. Activity in case 9:08-CV-80893-
+Work
+product; attorney/client
+KAM Doe v. Epstein Motion to
+Dismiss
+J. Activity in case 9:08-CV-80893-
+KAM Doe v. Epstein Motion to
+Compel
+J.
+Activity in case 9:08-CV-80994-
+Work product;
+attorney/client privilege;
+KAM Jane Doe No. 6 v. Epstein
+101
+
+
+01925
+01928-01929
+01930
+01940
+01944-01952
+01969
+01971-01972
+01973-01974
+08/26/2009
+08/03/2009
+6002/50/60
+09/10/2009
+04/10/2009
+05/04/2009
+05/13/2009
+07/23/2009
+IO
+Jacquie
+Jacquie
+Adler
+Adler
+Susan K. Stirling
+Attorneys at RRA
+Mike Fisten
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Motion to Strike
+1.
+Adriana Surveillance/Interview
+J.
+| Alfredo Rodriguez address
+J. William J. Berger
+Client info
+J. Witness Info
+d.
+Epstein assets
+1.
+Call from sources of information
+J.
+Cassell Draft
+J.
+]CMA vs.
+Epstein
+investigator info
+new
+OBJECTION
+Work product; attorney/client
+Work product;
+attorney/client
+Work
+product; attorney/client
+Work
+product;
+attorney/client privilege;
+Work
+product;
+attorney/client
+Work
+: product; attorney/client
+Work product;
+attorney/client
+Work product; attorney/client
+102
+
+
+01975
+01976-01978
+01981-01982
+066T0
+000Z0
+02001-02003
+02009-2010
+02017-02018
+08/10/2009
+07/06/2009
+04/01/2009
+05/14/2009
+600Z/E0/60
+6002/60/60
+10/09/2009
+05/18/2009
+IO
+Jacquie
+Jacquie
+Jacquie
+Pasquale
+William J. Berger
+Fistos & Lehrman
+FROM
+DESCRIPTION
+1. Computers
+J. Paul Cassell
+Conference Call
+OBJECTION
+Work product;
+attorney/client
+Work
+product;
+attorney/client
+J.
+Adler
+1. Paul Cassell
+Conflict check for Brad
+files
+product; attorney/client
+Consolidation order
+Work
+product; attorney/client
+1. Dates for Subpoena - Epstein's Work
+product; attorney/client
+housekeepers
+1.
+David Copperfield
+Work product;
+attorney/client
+1. Deposition of Bill
+Work
+product;
+attorney/client
+1. Doe v. Epstein
+Work product;
+attorney/client
+103
+
+
+02023
+02045-02046
+02049-02053
+02063-02064
+02089-02090
+02091-02092
+02106-02108
+02109
+02110-02111
+05/14/2009
+09/04/2009
+09/04/2009
+05/19/2009
+09/17/2009
+06/16/2009
+04/29/2009
+05/13/2009
+09/15/2009
+IO
+Attorneys at RRA
+Attorneys at RRA
+Paul Cassell
+William J. Berger
+Paul Cassell
+Attorneys at RRA
+Bradley
+Susan K. Stirling
+Wayne Black
+FROM
+PESCRIPTION
+1. Sid's deposition of Epstein
+Fistos & Lehrman
+J. Jacquie
+OBJECTION
+Work
+product;
+attorney/client privilege;
+1. E.W., L.M. Doe v. Epstein - Letter
+from Bob Critton
+J. | E.W., L.M. Doe v. Epstein - Letter
+from Bob Critton
+1. Epstein- Confirming AT&T Dial in
+Work
+product;
+attorney/client privilege;
+Telephone
+Conference for
+Monday, 6/8/09 at 2:00 p.m.
+1.
+/ Epstein hearing
+Work
+product; attorney/client
+1. Epstein
+- Monthly
+Call in
+Telephone Conference
+Work
+product;
+attorney/client
+1. Epstein - Telephone Conference
+1. Epstein info - List of Plaintiff
+lawvers
+Work
+product; attorney/client privilege;
+Epstein - Cancelling depositions
+Work product; attorney/client
+104
+
+
+02112-02116
+02117-02118
+02119-02121
+LETZO-OETZO
+02138-02139
+02143-02146
+02229
+02236-02337
+09/10/2009
+10/23/2009
+09/08/2009
+05/26/2009
+09/28/2009
+05/05/2009
+05/20/2009
+Jacquie
+Beth
+Williamson
+S.
+Susan K. Stirling
+Jacquie
+Jacquie
+Paul Cassell
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+in New York for the following irrelevant and not reasonably calculated to lead
+week
+J. Jacquie
+Epstein - Yearbook picture of Work product; attorney/client
+Epstein rape victims
+1. Epstein (AUSA)
+Work
+product; attorney/client
+1. Epstein info
+'Epstein cases- depositions
+federal cases
+Work
+product; attorney/client
+ys.
+Epstein depo - New York
+Work
+product;
+attorney/client privilege;
+J.
+Epstein Depo
+J. Epstein Depo
+1. Epstein info
+105
+
+
+02256-02257
+02260-02261
+02263-02265
+02266
+02273-02276
+02278-02279
+02284-02855
+01769
+07/22/2009
+07/22/2009
+07/23/2009
+09/18/2009
+07/23/2009
+05/11/2009
+10/30/2009
+Jacquie
+Nora Batian
+Attorneys at RRA
+Jacquie
+Jacquie
+Priscila
+Nascimento
+Susan K. Stirling
+Mike Fisten
+Jaffe, Weissing,
+FROM
+DESCRIPTION
+Fistos & Lehrman
+Nora Batian
+A. Nora Batian
+1. Epstein info
+J.
+Epstein - coordinating meetings
+Epstein info
+1. Epstein - Video Deposition of S.K.
+in NY.
+Epstein info
+Epstein info
+1. Epstein info
+1. Barbara Berg info
+OBJECTION
+Work product; attorney/client
+/Work product; attorney/client
+Work product; attorney/client
+İrelevant and ne
+Work
+product; attorney/client privilege;
+Work product;
+attorney/client privilege;
+Work
+product; attorney/client privilege;
+Work
+product; attorney/client
+106
+
+
+01780
+01787-01788
+01799-01801
+01804-01805
+01806-01807
+01808-01809
+01810-01816
+01817-01818
+09/14/2009
+09/04/2009
+Ken Jenne
+10/14/2009
+09/04/2009
+09/09/2009
+Beth
+Williamson
+Paul Cassell
+09/10/2009
+Paul Cassell
+09/09/2009
+Attorneys at RRA
+06/11/2009
+Paul Cassell
+, Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+DESCRIPTION
+1. William 1. Berger
+1. Paul Cassell
+S.
+OBJECTION
+Discussion of belief that Epsteln
+is transferring assets to avoid
+judgments
+J. 1. Accountants 2. Motion for IME
+Work
+product;
+attorney/client
+work
+product;
+attorney/client
+Activity in case 9:08-CV-80119-
+KAM Doe v. Epstein Notification
+of ninety days expiring
+Work
+product; attorney/client
+1. Activity in case 9:08-cv-80119-
+KAM Doe v. Epstein - Order on
+motion for Medical Exam
+Work product;
+attorney/client privilege;
+J.
+Activity in case 9:08-CV-80119-
+KAM Doe v. Epstein - Motion for
+protective order
+1. Activity in case 9:08-CV-80119-
+KAM Doe v. Epstein - Order on
+Motion for Extension of Time to
+File Response/Reply/Answer
+1.
+Activity in case 9:08-CV-80119-
+KAM Doe v. Epstein - Response
+to Motion
+Work
+product;
+attorney/client
+Work product; attorney/client
+J.
+Activity in case 9:08-CV-80119-
+Work
+product;
+attorney/client
+KAM Doe v. Epstein - Response
+to motion
+107
+
+
+01840-01841
+01867-01868
+03662-03663
+03664-03668
+08166-08168
+08169-08170
+08190-08196
+08265-08300
+08377-08378
+07/16/2009
+09/28/2009
+08/10/2009
+09/18/2009
+10/28/2009
+08/06/2009
+04/07/2009
+09/04/2009
+10/02/2009
+•
+Paul Cassell
+Paul Cassell
+Attorneys at RRA
+Paul Cassell
+Paul Cassell
+Attorneys at RRA
+Jaffe, Weissing..
+• Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Activity in case 9:08-Cv-80119- Work product;
+attorney/client privilege;
+KAM Doe v. Epstein - Order on | Irrelevant and not reasonably calculated to lead
+Motion to Stay
+Activity in case 9:0-cv80119protkcted protected boderivacy rightr
+product; attorney/client
+KAM Doe v. Epstein - Notice
+(Other)
+J.
+| Meeting with clients
+Work product; attorney/client
+1. Litigation
+preparation
+strategy
+and
+1.
+Weds filing
+Work product; attorney/cilent privilege;
+1. Jacquie Johnsón
+Wexner deposition for 14th
+Work
+product; attorney/client privilege;
+1.
+Paul Cassell
+Motion to unseal/Motion to stay
+Work product; attorney/client
+J.
+Witness Information
+1. Paul Cassell
+Zorro Trust research info.
+108
+
+
+08381-08383
+08384-08388
+08389-08397
+08401
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+08426
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+08/01/2009
+06/02/2009
+10/09/2009
+08/10/2009
+IO
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+1.
+- Paul Cassell
+Epstein - complaint
+J.
+Paul Cassell
+Epstein fraudulent transfer
+1. Paul Cassell
+Revisited sexual history memo
+1. Paul Cassell
+Reply memo on asset transfers
+1.
+Cara L
+Rodriguez Deposition
+1. William 1. Berger
+Strategy
+1. Mike Fisten
+Subpoena info
+1. Mike Fisten
+OBJECTION
+protected by privacy rights:
+Work product; attorney/client
+Work product; attorney/client
+Work
+product;
+attorney/client
+protected by privacy right:
+Work
+product; attorney/client
+Synopsis
+109
+
+
+08441-08446
+03672-03673
+03706-03718
+LELEO
+03746-03753
+02335-02338
+02360-02361
+02368-02373
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+08/05/2009
+600Z/Sz/80
+08/02/2009
+05/08/2009
+06/09/2009
+10/14/2009
+Attorneys at RRA
+Wayne Black
+William Berger
+Susan Stirling
+, Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William J. Berger
+Paul Cassell
+Cara
+William Berger
+Jacquie|
+OBJECTION
+Trial Prep
+Work product; attorney/client
+Brunel information
+Work product; attorney/client
+Cf. Response to Motion to File
+Work
+product; attorney/client
+Epstein Affidavit
+Computers
+Work
+product;
+attorney/client
+Computers
+Work
+product;
+attorney/client
+Litigation strategy
+Work
+product; attorney/client
+Hearing to Un-seal- Criminal Plea
+Transcript
+Work product; attorney/client
+igor Zinoview depo
+Work
+product; attorney/client
+110
+
+
+02376-02392
+02401-02410
+02414-02419
+03669-03670
+02288-02289
+02292-02293
+02304-02308
+02313-02316
+10/14/2009
+LIQ
+Mike Fisten
+05/08/2009
+William Berger
+05/12/2009
+Attorneys at RRA
+10/08/2009
+Carolyn
+05/26/2009
+Susan Stirling
+05/19/2009
+Dr.
+09/17/2009
+Bradley Edwards
+[ Jacquie
+07/01/2009
+,Jaffe, Weissing.)
+Fistos & Lehrman
+EROM
+DESCRIPTION
+OBJECTION
+Igor Zinoview depo
+Jane Doe Ii v. Epstein
+Jane Doe II v. Epstein
+Epstein house arrest monitor
+Work product; attorney/client
+Motion date
+rotected bv orivacy right
+Pimp and His Game
+Vork product: attornev/client privilege
+Forensics/Investigations
+William Berger
+Confidential Agreement
+Work product; attorney/client
+111
+
+
+02331-02334
+02173
+02187
+46120-56120
+EOZZ0-66T20
+02211-02214
+02224
+10787-10799
+10901-10902
+05/08/2009
+09/04/2009
+07/26/2009
+600z/LT/60
+09/18/2009
+07/01/2009
+10/19/2009
+05/11/2009
+IO
+Susan Stirling
+Attorneys at RRA
+Jacquie
+Jacquie
+Paul Cassell
+Jacquie
+Bradley
+, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Critton order Transcript
+Mike Fisten
+Wayne Black
+Jacquie
+William Berger
+Work product,
+attorney/client privilege;
+Epstein Juan Alessi
+Work product; attorney/client
+protected by privacy right
+Epstein matter
+Nork product; attorney/client
+Epstein Order
+Work product; attorney/client
+Epstein Order
+Epstein v. State of Florida-
+Work product;
+attorney/client
+Emergency Petition for Writ of | irrelevant and not reasonably calculated to lead
+Certiorari
+Witness of Epstein rapes from
+Work
+product; attorney/client
+Switzerland
+Witness List
+Work
+product; attorney/client privilege;
+RICO Enterprise
+Work product;
+attorney/client
+privilege:
+112
+
+
+I PATE
+S060T-50601
+600Z/TT/SO
+10908-10909
+600Z/TT/S0
+10912-10913
+05/11/2009
+10955-10963
+06/01/2009
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+06/03/2009
+11022-11025
+06/26/2009
+11036-11037
+07/21/2009
+11039-11071
+07/21/2009
+IO
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+Wayne Black
+Wayne Black
+Wayne Black
+Wayne Black
+RICO Enterprise
+RICO Enterprise
+RICO Enterprise
+Plaintiff's Witness List
+Serve Subpoenas
+Info on 2 MC2 Workers
+Serve Subpoenas
+Retainer from the Firm
+113
+OBJECTION
+Workproduct; attorney/client
+Work product; attorney/client
+Work product; attorney/client
+Work
+product;
+attorney/client
+Work
+product;
+attorney/client privilege;
+Work
+product;
+attorney/client
+Work
+product; attorney/client
+Work
+product; attorney/client privilege;
+
+
+11083-11084
+1 DATE
+09/04/2009
+11105-11110
+09/09/2009
+11137-11139
+10/03/2009
+11143-11146
+10/04/2009
+11155-11156
+10/18/2009
+11175-11183
+04/27/2009
+11196-11197
+11205-11207
+05/28/2009
+05/28/2009
+Attorneys at RRA
+Jacquie
+Paul Cassell
+William Berger
+Attorneys at RRA
+Marc Nurik
+Susan Stirling
+Paul Cassell
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Bradley
+OBJECTION
+Witness info
+Disseminate letter from Wexner
+Work product; attorney/client
+attorney
+Zorro Trust research info
+Work • product;
+attorney/client
+11/28 Discovery Cutoff
+New Property
+Work product;
+attorney/client privilege;
+Epstein Case info
+Work
+product; attorney/client privilege;
+Jail Visitors
+Litigation strategy
+Work product; attorney/client
+114
+
+
+11215
+06/01/2009
+11238-11239
+06/03/2009
+11246-11247
+06/22/2009
+11251-11254
+06/23/2009
+11267-11268
+06/30/2009
+11282-11315
+07/18/2009
+11326-11331
+08/03/2009
+11337-11339
+IO
+William Berger
+Wayne Black
+Wayne Black
+Wayne Black
+William Berger
+Wayne Black
+Jacquie Johnson
+Mike Fisten
+FROM
+DESCRIPTION
+Fistos & Lehrman
+Activity in Case
+Depo Info
+Epstein Article
+info on 2 MC2 workers
+Witness List revised
+Confidential info
+Donald Trump depo
+Confidential Info
+OBJECTION
+protected by privacy right:
+Nork product
+attorney/client
+Work
+product; attorney/client
+Work
+product;
+attorney/client
+Work product; attorney/client
+Work product;
+attorney/client privilege;
+Work
+product;
+attorney/client privilege;
+Work
+product; attorney/client privilege;
+Work
+product; attorney/client
+115
+
+
+11359-11362
+08/10/2009
+11366-11371
+11377-11379
+08/12/2009
+11390-11395
+08/17/2009
+11400-11415
+08/18/2009
+11420-11426
+08/24/2009
+11428-11429
+08/26/2009
+11568
+10/07/2009
+11587
+10/23/2009
+IO
+Jacquie
+Jacquie
+Jacquie
+Jacquie|
+Jacquie
+Attorneys at RRA
+Attorneys at RRA
+Paul Cassell
+Paul Cassell
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein depos
+Trump depo info
+Issuing Subpoenas
+Witness depos
+Subpoenas for pilots
+Bradley
+Serving Alan Dershowitz
+Witness info
+Meeting with Leslie Wexner
+OBJECTION
+Work product; attorney/client
+Ito the discovery of the admissible evidence;
+Work
+product; attorney/client privilege;
+Work product; attorney/client
+Work product; attorney/client
+Visoski Depo
+116
+
+
+11861-11865
+6002/Z/01
+11870-11871
+600Z/tZ/80
+11874
+08/24/2009
+11876
+6007/t2/80
+24611-496TL
+600Z/67/01
+08072-08075
+07/22/2009
+08090-08091
+10/05/2009
+08114-08117
+08/18/2009
+Attorneys at RRA
+Attorneys at RRA
+Jacquie
+Attorneys at RRA
+Cara
+Paul Casseli
+William Berger
+Pat
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Ken Jenne
+Jacquie
+Witness List
+Epstein info
+Confidential info
+Confidential Info
+Subpoenas
+Attorneys
+for
+Epstein's
+Total counts for E.W.
+Trial Prep
+OBJECTION
+Work product; attorney/client
+Work product; attorney/client
+Work product; attorney/client - privilege;
+Updated Witness List
+117
+
+
+08157-08159
+08499-08501
+10063-10068
+10090-10091
+TOTOT-FOTOT
+10106-10137
+12569
+15827-15837
+06/03/2009
+08/24/2009
+08/03/2009
+600Z/1E/80
+600Z/LZ/80
+08/24/2009
+07/22/2009
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Carl Linder
+Jacquie
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION,
+Vanity Fair
+Work product; attorney/client
+Witness List
+Work product; attorney/client
+Mike Fisten
+Confidential Info
+Work product; attorney/client
+Jacquie|
+Witness Info
+Work
+product; attorney/client privilege;
+Ken Jenne
+Witness Info
+Work
+product;
+attorney/client privilege;
+Ken Jenne
+Meetings/ Confidential info
+Work
+product; attorney/client
+Epstein Sex Abuse Litigation
+Forum
+Work product; attorney/client
+Retainer for Investigator
+Work product; attorney/client
+118
+
+
+15820-15822
+600z/6Z/01
+15401-15412
+15356-15359
+6002/92/80
+6002/60/60
+14934-14950
+07/22/2009
+13413-13414
+08/06/2009
+13908-13911
+10595-10597
+10621-10624
+08/24/2009
+09/29/2009
+10/02/2009
+IO
+Jacquie
+Jacquie
+Attorneys at RRA
+Jacquie
+Denis Kleinfeld
+Attorneys at RRA
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Cara
+Mike Fisten
+Jacquie
+Jacquie
+OBJECTION
+Subpoenas
+Attorneys
+for
+Epstein's | Work product; attorney/client privilege;
+Disseminate the letter
+from
+wexner atty
+protected by privacy right:
+Witness info
+Work product; attorney/client privilege,
+Investigator Info
+Work
+product; attorney/client privilege;
+Epstein information
+Work
+product; attorney/client privilege;
+Meeting info
+Subpoena for l
+Meeting with Wexner atty
+119
+
+
+10633-10638
+10681-10692
+10777-10786
+04094-04100
+02971
+SIGZO
+02976
+02995
+10172-10178
+10/05/2009
+10/07/2009
+10/16/2009
+04/07/2009
+10/03/2009
+10/14/2009
+09/09/2009
+06/24/2009
+08/12/2009
+Jacquie|
+Attorneys at RRA
+Jacquie
+Jacquie
+Bradley
+„Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+PESCRIPTION
+William Berger
+Trial Prep
+Mike Fisten
+Paul Cassell
+Paul Cassell
+Mike Fisten
+Bradley
+Jacquie
+OBJECTION
+Work product;
+attorney/client privilege;
+Depositions
+New Evidence
+of
+Fraudulent Transfers
+Epstein
+Draft Motion to Strike
+Finances
+Work product; attorney/client
+Larry Visoski depo
+Work
+product; attorney/client privilege;
+Disseminate the letter from
+I Work product; attorney/client
+wexner
+Work
+product; attorney/client
+Trump Depo
+Work
+product; attorney/client
+120
+
+
+10193
+10255
+09/09/2009
+10259-10263
+09/09/2009
+03876-03877
+10/26/2009
+03879-03884
+07/13/2009
+03886-03891
+07/13/2009
+03905-03920
+09/08/2009
+03937
+08/17/2009
+Attorneys of RRA
+Jacquie
+Paul Cassell
+William Berger
+Carolyn
+Jaffe, Weissinge.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Jacquie|
+William Berger
+Paul Cassell
+Paul Cassell
+Trump Depo
+Depo of Alan Dershowitz
+Cooperfield Service
+E.W., L.M. Doe v. Epstein
+121
+OBJECTION
+Work product; attorney/client
+Work
+product;
+attorney/client
+protected by privacy right
+Work product
+attorney/client privilege;
+Work
+product;
+attorney/client
+Work
+product;
+attorney/client
+Work
+product; attorney/client
+
+
+04005-04011
+05/13/2009
+04070-04093
+04/07/2009
+03754
+03848-03858
+09/09/2009
+03642-03643
+09/04/2009
+03657-03661
+09/04/2009
+02475
+06/15/2009
+02494-02515
+09/20/2009
+IO
+Paul Cassell
+Paul Cassell
+Attorneys at RRA
+Paul Cassell
+Susan Stirling
+Privilege Log -Dated 2-23-2011
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+Discovery
+Paul Cassell
+Motion to Strike
+Conference Call
+Jacquie
+Cooperfield Service
+1. Accounts/ 2. Motion for IME
+Pat
+Mark Epstein Info
+122
+OBJECTION
+protected by privacy right
+Nork product; attorney/client privilege
+Work product; attorney/client
+Work
+product; attorney/client
+Work
+product;
+attorney/client
+Work product; attorney/client
+Work
+product;
+attorney/client privilege;
+Work
+product; attorney/client privilege;
+to the discovery of the admissible evidence:
+
+
+02520-02543
+02548-02553
+02560-02565
+02568-02570
+02578-02583
+02619-02622
+02633-02646
+07959-07964
+06/06/2009
+08/03/2009
+07/31/2009
+10/13/2009
+05/28/2009
+09/09/2009
+05/01/2009
+09/24/2009
+IO
+Beth Williamson
+Jacquie
+Paul Cassell
+Jacquie
+Paul Cassell
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+OBJECTION
+Memo of Assest Transfers
+Work product; attorney/client
+Federal Subpoena
+Jacquie
+Federal Subpoena
+New Times Article
+Work product; attorney/client
+Edwards Litigation Strategy
+protected by privacy right:
+New client Retainer
+Rensolidate * Cassel strategy Welvant and not retoraly cliculated toiled
+Memo for Jay
+Paul Cassell
+123
+
+
+07967-07975
+07979-08000
+07735-07736
+07643-07645
+07698-07706
+07620-07632
+07635-07636
+07617-07618
+07550-07589
+09/22/2009
+08/18/2009
+07/24/2009
+09/09/2009
+09/06/2009
+08/14/2009
+10/15/2009
+07/13/2009
+10/30/2009
+Jacquie
+Paul Cassell
+Jacquie
+Mike Fisten
+Paul Cassell
+Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Subpoena on Epstein case
+OBJECTION
+Work product;
+attorney/client
+Jacquie
+Jacquie|
+Jacquie
+Bradley
+Paul Cassell
+Subpoenas for Pilots
+product; attorney/client privilege
+Releases for therapist
+Mork
+product; attorney/client
+New client Retainer
+Work product; attorney/client
+Answer to the Complaint
+Work
+product; attorney/client
+Review of "Notice of Taking Depo
+- RC - Bear Sterns"
+Work
+product;
+attorney/client privilege;
+Questions
+from
+forensic
+Work
+product;
+attorney/client
+accountant detecting Epstein
+fraudulent transfers
+Epstein strategy
+Work
+product; attorney/client
+Work
+product;
+attorney/client
+Motion to Supplement with the
+124
+
+
+07595-07604
+05/20/2009
+07616
+07/22/2009
+07530-07549
+06/11/2009
+07470-07507
+07447-07469
+07/09/2009
+10/13/2009
+07444-07446
+05/01/2009
+07440
+07436
+10/18/2009
+04/11/2009
+IO
+Paul Cassell
+Paul Cassell
+Attorneys at RRA
+Attorneys at RRA
+Adler
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Visoski depo
+Paul Cassell
+Susan Stirling
+Adler
+Paul Cassell
+Overtime
+Motion to Compel
+New Times Article on epstein
+Response to
+Motion
+to
+Consolidate + Cassell Strategy
+Memo for Jay
+New Trump Property
+New cases
+OBJECTION
+Work
+product;
+attorney/cllent privilege;
+Work
+product; attorney/client privilege;
+Work
+product;
+attorney/client privilege;
+Work
+product; attorney/client
+Work
+product; attorney/client
+125
+
+
+07424-07431
+09/26/2009
+07412-07423
+04/08/2009
+07403-07411
+04/08/2009
+07394-07402
+07/10/2009
+07386-07392
+05/28/2009
+07378-07385
+04/07/2009
+07370-07377
+04/07/2009
+07354-07369
+10/28/2009
+Paul Cassell
+William Berger
+Paul Cassell
+Beth Williamson
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Need Depo Transcript
+Paul Cassell
+Draft Motion to Strike
+Draft Motion to Strike
+Paul Cassell
+Multiple 2255 Counts
+Motion to Unseal
+Paul Cassell
+Motion to Unseal
+Motion to Unseal
+Motion to Protect 2'° depo
+OBJECTION
+rotected by privacy right:
+Vork product; attorney/client privilege
+Work
+product;
+attorney/client
+Work product; attorney/client
+Work product;
+attorney/client
+product; attorney/client
+product; attorney/client privilege;
+Work
+product; attorney/client
+Work
+product; attorney/client
+126
+
+
+07346
+07337
+07328
+07319
+07313-07318
+07287-07301
+07252-07278
+07247-07251
+10/28/2009
+10/28/2009
+10/28/2009
+10/28/2009
+04/10/2009
+09/08/2009
+09/08/2009
+IQ
+Beth Williamson
+Paul Cassell
+Bradley Edwards
+Paul Cassell
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Motion to protect 2 depo
+Jacquie|
+Beth Williamson
+Jacquie
+Paul Cassell
+Paul Cassell
+Motion to protect 2'd depo
+Motion to protect 2nd depo
+Motion to protect 2d depo
+Motion to Compel - Photograph
+Motion to Compel - File this
+week?
+Motion for IME + Accountant
+Motion for IME + Accountant
+OBJECTION
+Work product; attorney/client
+Work product; attorney/client
+Work
+product;
+attorney/client privilege;
+protected by privacy rites
+product;
+attorney/client privilege;
+127
+
+
+07230-07233
+06/08/2009
+07157-07158
+09/29/2009
+07128-07141
+07094-07098
+09/14/2009
+07025-07027
+10/29/2009
+07099-07106
+09/14/2009
+07071-07078
+07/23/2009
+07066-07070
+07/23/2009
+07015-07016
+10/13/2009
+IO
+Paul Cassell
+Adler
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Memo on Asset Transfers
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Paul Cassell
+OBJECTION
+RE: Mark
+Motion for bond asset transfer
+and memo final
+Letter to Critton RE: Motions to
+Compel
+Work product; attorney/client
+L.M. and E.W. v. Epstein -
+Work product; attorney/client
+Letter to Critton RE: Motions to
+Compel
+Work
+product;
+attorney/client
+L.M!'s Son's B-day
+product; attorney/client privilege;
+L.M!'s Son's B-day
+Work
+• product; attorney/client privilege;
+Evidence of Asset
+transfers
+[Work product;
+attorney/client
+128
+
+
+07019-07024
+06837-06839
+06826-06836
+06823-06825
+06813-06816
+06808-06810
+06804-06805
+06794
+1 TO
+10/29/2009
+04/08/2009
+Beth Williamson
+04/08/2009
+04/08/2009
+07/02/2009
+Paul Cassell
+09/13/2009
+09/13/2009
+Paul Cassell
+10/23/2009
+Mike Fisten
+Fistos & Lehrman
+FROM
+PESCRIPTION
+and/or liquidations
+Paul Cassell
+Beth Williamson
+Beth Williamson
+Bradley|
+Paul Cassell
+OBJECTION
+L.M. and E.W. v. Epstein - I'm on
+it
+Jane Doe change of address
+Jane Doe change of address
+Work product; attorney/client
+Jane Doe change of address
+Work product; attorney/client
+Doe v. Epstein Motion for
+Work
+product;
+attorney/client privilege;
+Extension of Time to File irrelevant and not reasonably calculated to lead
+Response/Reply/Answer
+protected by privacy right:
+"Is Jeffrey Epstein the new
+Nork product; attorney/client
+Madoff - Running a giant Ponzi
+scheme?"
+"Is Jeffrey Epstein the new
+| Work product; attorney/client
+Madoff - Running a giant Ponzi irrelevant and not reasonably calculated to lead
+scheme?"
+Interesting WebSite
+129
+
+
+06800-06803
+600z/90/60
+06761-06762
+600Z/6T/80
+06767-06769
+09/10/2009
+06782-06787
+04/10/2009
+06744-06747
+05/01/2009
+06736-06739
+05/01/2009
+06709-06710
+10/14/2009
+Attorneys at RRA
+Paul Cassell
+Paul Cassell
+Bradley
+,Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Jacquie |
+OBJECTION
+RE: 1. Accountants 2. Motion for
+IME
+Work product; attorney/client
+IME Rules
+Work product; attorney/client
+IME's
+Bradley Edwards
+Paul Cassell
+Mike Fisten
+Confidential Detailed Strategy
+Work
+product;
+attorney/client privilege;
+Memo on Asset Protection Issues
+Depo of Jeffrey Epstein
+Asset Protection Issue
+Igor Zinoview depo
+130
+
+
+06691-06696
+06683-06686
+06654
+06599-06600
+06574-06590
+06567-06570
+06558-06561
+07/09/2009
+07/24/2009
+04/07/2009
+07/09/2009
+07/09/2009
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Paul Cassell
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+How many 2255 claims?
+Paul Cassell
+Paul Cassell
+Hiding Assets
+Secretary Contact info
+Hiding Assets
+Motion to Unseal
+Motion to Compel
+Motion to Compel
+OBJECTION
+Work product;
+attorney/client
+Work
+product; attorney/client
+Work
+product;
+attorney/client
+131
+
+
+06554-06557
+06549-06553
+06540-06541
+06537
+06529-06530
+06496-06505
+06177-06181
+06149-06153
+05/14/2009
+05/14/2009
+09/21/2009
+10/23/2009
+10/23/2009
+10/20/2009
+09/25/2009
+07/10/2009
+Paul Cassell
+Paul Cassell
+William Berger
+Paul Casseli
+FROM
+Fistos & Lehrman
+DESCRIPTION
+Paul Cassell
+Mike Fisten
+Info on Maxwell
+Paul Cassell
+Doe v. Jeffrey Epstein
+Edwards Doe v. Epstein
+Paul Cassell
+Visoski depo
+Financial discovery
+Federal
+First
+Complaint
+OBJECTION
+Work product; attorney/client privilege
+Amendment
+Work
+product; attorney/client privilege;
+132
+
+
+06118-06146
+09/15/2009
+06113-06117
+07/14/2009
+06106-06112
+05/19/2009
+06091
+06001-06011
+07/18/2009
+05996
+04/08/2009
+05998-06000
+09/17/2009
+05992
+04/19/2009
+Seth Lehrman
+Amy Swan
+William Berger
+Paul Cassell
+Jacquie
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Farnsworth v. Macys case
+Richard Wolfe
+William Berger
+Paul Cassell
+Beth Williamson
+Marc Nurik
+OBJECTION
+Work product; attorney/client
+Facebook/Myspace
+Expert Witness
+EW and LM v. Epstein
+Work
+product; attorney/client
+Epstein's Address and Position of Work product; attorney/client
+Critton on Motion
+Work product;
+attorney/client
+Epstein: Forensics/Investigations
+Work
+product; attorney/client
+INVOICE
+133
+
+
+05968
+10/17/2009
+05944-05947
+05/01/2009
+05927
+05931-05932
+05919-05920
+09/18/2009
+07/27/2009
+05915
+600z/22/t0
+05911
+05/28/2009
+William Berger
+Amy Swan
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+Amy Swan
+Ryan Hall Psychiatrist
+Client's Cell Phone Number
+Amy Swan
+Client's Cell Phone Number
+Marc Nurik
+William Berger
+OBJECTION
+Work
+product; attorney/client privilege;
+134
+
+
+05890
+05893-05894
+05898-05899
+05885
+05874-05879
+05868
+05865
+05860-05861
+07/27/2009
+07/27/2009
+09/15/2009
+07/23/2009
+08/03/2009
+09/10/2009
+09/10/2009
+•
+Bradley Edwards
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Amy Swan
+Amy Swan
+Amy Swan
+Jacquie
+Jacquie |
+Ken Jenne
+Jacquie
+Epstein Litigation Strategy
+Maribel Matiska
+OBJECTION
+Work product; attorney/client privilege
+Work product; attorney/client privilege
+product; attorney/client privilege;
+Work product;
+attorney/client privilege;
+Work
+product; attorney/client
+Litigation strategy
+135
+
+
+05845
+07/24/2009
+05811
+06/09/2009
+05813
+08/15/2009
+05748-05749
+05711
+05/11/2009
+05701-05704
+04/20/2009
+05687
+08/21/2009
+05690-05691
+05/11/2009
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Ken Jenne
+Susan Stirling
+Ken Jenne
+Jacquie
+Rússell Adler
+Marc Nurik
+Plane Tail Numbers
+Witness Numbers
+Subpoena Clinton
+Epstein strategy
+Alfredo Rodriguez
+OBJECTION
+Work product; attorney/cilent privilege;
+Work product;
+. attorney/client privilege;
+[ Susan Stirling
+Motion to Unseal
+136
+
+
+05680-05682
+05676
+05648
+05629
+05621-05622
+05610-05612
+05588-05590
+600z/TT/S0
+600z/tz/80
+07/23/2009
+600Z/E0/80
+09/18/2009
+04/27/2009
+08/24/2009
+IO
+Attorneys at RRA
+Attorneys at RRA
+Amy Swan
+Susan Stirling
+Attorneys at RRA
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+Subpoena Clinton
+Mike Fisten
+Gary
+Mike Fisten
+Bradley
+Topics for Meeting
+OBJECTION
+Work product; attorney/client privilege
+Assemble
+> Epstein
+meeting
+Litigation Work product; attorney/client privilege;
+Law Enforcement cannot release
+juvenile reports
+Work product; attorney/client privilege
+Preparing Motion to take an IME | Work product; attorney/client privilege;
+of Epstein
+Request for Copies
+Travel restrictions
+137
+
+
+05575-05576
+05582
+05569-05570
+05556-05558
+05537
+05534
+05518
+05512-05513
+08/21/2009
+09/11/2009
+08/17/2009
+08/14/2009
+07/24/2009
+07/22/2009
+07/23/2009
+Marc Nurik
+Marc Nurik
+Attorneys at RRA
+Jacquie
+Ken Jenne
+Attorneys at RRA
+Priscila
+Nascimento
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Alfredo Rodriguez
+Mike Fisten
+Nora Batian
+Epstein strategy
+Legal Opinion
+OBJECTION
+Work product; attorney/client
+Communication with legal expert
+No objections from defense
+counsel regarding depo for
+Flight logs for Epstein
+Assemble
+meeting
+Epstein
+Litigation
+Work
+product; attorney/client
+Work product; attorney/client
+Assemble
+meeting
+Epstein
+Litigation Work product; attorney/client privilege;
+138
+
+
+05502-05507
+05475
+05471-05472
+05447
+05420-05423
+05409-05412
+05403-05405
+07/22/2009
+04/21/2009
+08/14/2009
+08/14/2009
+05/20/2009
+08/17/2009
+04/27/2009
+IO
+Jacquie
+Marc Nurik
+Marc Nurik
+Marc Nurik
+William Berger
+Marc Nurik
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+William Berger
+Marc Nurik
+OBJECTION
+Wayne Black's email
+protected by privacy right
+all with Chris Hanson from Work product; attorney/clien
+dateline
+Legal expert regarding legal issue
+Communication with legal expert
+Research on cases saying a judge | Work product; attorney/client privilege;
+can postpone one party's depo
+until the other is completed
+Legal
+opinion
+regarding
+discovery
+Jeffrey Epstein Wikipedia page
+139
+
+
+05399
+05399
+05271-05272
+05259-05260
+05238
+05240-05241
+05197-05199
+10/17/2009
+10/17/2009
+07/22/2009
+07/22/2009
+07/14/2009
+08/24/2009
+08/24/2009
+William Berger
+William Berger
+Attorneys at RRA
+Attorneys at RRA
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+PESCRIPTION
+Proposal for settlement
+Proposal for settlement
+Jacquie
+Jacquie.
+Depo Dates to take SR, LM, and
+cW
+Investigator retainer
+William Berger
+File a request to produce
+Ken Jenne
+Ken Jenne
+Judge's order on the Epstein
+probation
+Michael Reiter info
+OBJECTION
+Work product
+attorney/client
+protected by privacy right:
+Vor
+product; attorney/client
+Work product; attorney/client
+protected by privacy right:
+Work product; attorney/client privilege
+140
+
+
+05155-05156
+05159-05160
+05149-05150
+05153
+05146-05147
+05137-05144
+05133-05136
+01749-01751
+04/20/2009
+05/28/2009
+05/27/2009
+08/24/2009
+05/26/2009
+05/20/2009
+05/11/2009
+10/28/2009
+Adler
+William Berger
+Susan Stirling
+Paul Cassell
+Attorneys at RRA
+William Berger
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Set Epstein's depo duces tecum
+OBJECTION
+Work
+product; attorney/client
+Mike Fisten
+Right to move to reconsider all Work product; attorney/client
+rulings
+Epstein filed a motion
+to
+continue the trial
+Epstein traveling
+The response to the motion to
+continue is due 6/8
+Russell Adler
+Phaedra Xanthos
+Epstein litigation strategy
+Work
+product;
+attorney/client
+Subpoena Clinton and others on
+Sid
+witness list
+Final affidavit
+from
+forensic
+accountant
+141
+
+
+05125-05132
+05115-05117
+01699
+05120-05121
+05095-05098
+01694
+05066-05067
+05/05/2009
+04/27/2009
+09/15/2009
+05/04/2009
+07/01/2009
+10/17/2009
+05/06/2009
+William Berger
+Jacquie
+William Berger
+Jacquie Johnson
+Marc Nurik
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Susan Stirling
+Paul Cássell
+OBJECTION
+rotected by privacy right:
+lesponse to motion to compel all | Work product; attorney/client privilege
+the sex information of his clients
+Epstein depos
+Work
+product; attorney/client privilege;
+VZ depo
+Reporter asking how the depo of
+Work product; attorney/client
+Epstein went
+Epstein v. State of Florida -
+Emergency Petition for Writ of irrelevant and not reasonably calculated to lead
+Certiorari; Emergency Motion to
+Review Denial of Stay
+PFS
+William Berger
+Epstein sealed records and TV
+142
+
+
+05054-05065
+08/18/2009
+Attorneys at RRA
+05049-05053
+08/18/2009
+Mike Fisten
+04957-04964
+09/04/2009
+04952-04953
+10/28/2009
+Attorneys at RRA
+04955-04956
+09/03/2009
+Attorneys at RRA
+04916-04920
+09/11/2009
+Elizabeth Villar
+04899
+09/10/2009
+Bradley
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Scott
+Paul Cassell
+Bradley Edwards
+Jacquie
+Epstein Potential witnesses
+Subpoenas
+witnesses
+for
+OBJECTION
+Work
+product;
+attorney/client
+potential
+Work product; attorney/client
+Juan
+Alessi statement and
+burglary report
+Epstein
+injunction
+filing
+-
+accountant affidavit will be sent
+Epstein Invoice
+Updates on # of victims, billing
+amounts, etc.
+Epstein Discovery
+143
+
+
+04893-04896
+04890
+04884-04885
+01469
+04745-04747
+04738-04744
+04660
+04642-04646
+09/10/2009
+Jacquie
+09/10/2009
+Jacquie
+09/10/2009
+07/17/2009
+Ken Jenne
+08/25/2009
+10/22/2009
+09/11/2009
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Epstein Discovery
+Jacquie
+Jacquie
+Paul Cassell
+Marc Nurik
+Epstein Discovery
+Epstein Discovery
+OBJECTION
+Work ' product; attorney/client privilege
+rotected by privacy rights
+Nork product; attorney/client privilege
+Discussions about the Epstein Work product; attorney/client privilege;
+case
+Epstein depo in New York
+Work product; attorney/client
+Hearing regarding the Epstein
+| Work product; attorney/client privilege;
+computers
+Epstein AUSA - Attorneys Fees
+Beth Williamson
+Discussions
+recovery
+about
+Brad's Work product; attorney/client privilege;
+144
+
+
+04607-04617
+09/11/2009
+04526-04535
+10/17/2009
+04488-04490
+07/18/2009
+01362
+09/11/2009
+04481-04487
+05465-05467
+08/18/2009
+06/26/2009
+05470
+07/11/2009
+05496-05497
+08/10/2009
+Jacquie
+Elizabeth Villar
+Paul Cassell
+Wayne Black
+• Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Paul Cassell
+Wayne Black
+Alfredo
+OBJECTION
+Holding Fed Subs until we get
+Work product; attorney/client
+response on form
+Two ideas regarding strategy
+protected by privacy right
+Vork product; attorney/client
+Taking the 5th
+Work product; attorney/client
+Getting the forensic aspect off Work product;
+attorney/client privilege;
+the ground epstein's asset
+transfers
+Epstein Subpoena
+Subpoenas for trial
+Flight Logs
+Work product; attorney/client
+Phone Numbers
+145
+
+
+05501
+07/21/2009
+05524-05533
+07/23/2009
+05541
+07/31/2009
+05635
+10/22/2009
+Wayne Black
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Rodriguez
+Litigation strategy
+OBJECTION
+product; attorney/client privilege;
+Wayne Black
+Addresses for people involved in
+the case
+Carolyn
+All depos in jane doe's case
+Pat
+New developments that require
+your expertise
+Work
+product; attorney/client privilege;
+protected by privacy rightso
+10,.
+146
+
+
+05640
+05652-05653
+05671
+05696
+05815-05816
+05820-05821
+10/29/2009
+04/01/2009
+10/22/2009
+6002/1T/S0
+04/01/2009
+07/23/2009
+Pat
+Carolyn
+•
+Fistos & Lehrman
+FROM
+DESCRIPTION
+New Epstein victim
+OBJECTION
+Work
+product;
+attorney/client
+Carolyn
+Pat
+Wayne Black
+personal discussion
+Work
+product;
+attorney/client
+Litigation strategy
+Work
+product; attorney/client
+Phone number for one of the
+other girls on the list of irrelevant and not reasonably calculated to lead
+prospective clients
+Taking the depos of everyone
+Wayne Black
+Dates for depos of all witnesses
+Work product;
+attorney/client
+in the case
+147
+
+
+05824-05825
+07/23/2009
+05828-05829
+07/23/2009
+05833-05835
+07/23/2009
+05839-05841
+07/23/2009
+05869-05870
+04/01/2009
+05913-05914
+04/01/2009
+IO
+Carolyn
+Carolyn
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Wayne Black
+Wayne Black
+OBJECTION
+protected by privacy right:
+Paula Heil
+Work product; attorney/client privilege
+Dates for depos of all witnesses
+/Work
+product; attorney/client
+in the case
+FBI has original flight logs and
+they interviewed pilots
+Wayne Black
+Copies of the flight logs
+Personal convo between Brad
+and Mom
+Personal convo between Brad
+and Mom
+Work
+product;
+attorney/client privilege;
+to the discovery of the, admissible evidence;
+148
+
+
+05995
+06513-06523
+06699-06701
+07079-07089
+07437-07439
+07936-07958
+08006-08011
+11186-11187
+04/01/2009
+06/15/2009
+06/17/2009
+09/03/2009
+10/19/2009
+04/28/2009
+06/03/2009
+08/19/2009
+Bradley Edwards
+Wayne Black
+Paul Cassell
+Earleen Cote
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Carolyn
+Third
+party
+subpoenas i
+for Work product; attorney/client privilege;
+Wayne Black
+Pat Diaz
+Ronald Wise
+Wayne Black
+Ghisella Maxwell info
+Epstein litigation
+Discussion about girls involved in
+the case
+New
+evidence of
+Epstein
+Fraudulent transfers + Affidavit
+from you
+Work
+product; attorney/client privilege;
+Cases against mansion nightclub
+Getting addresses for people for
+us to serve subpoenas
+Work
+product;
+attorney/client
+privilege:
+Plaintiff's Witness List
+149
+
+
+26479-26481
+27155-27159
+26604-26605
+26570
+04954
+06665-06670
+06675-06676
+08/19/2009
+10/23/2009
+10/27/2009
+08/13/2009
+10/28/2009
+08/12/2009
+08/26/2009
+IO
+Attorneys at RRA
+Attorneys at RRA
+Phaedra Xanthos
+Scott Rothstein
+Attorneys at RRA
+Shawn Gilbert
+Shawn Gilbert
+Jaffe, Weissing,
+Fistos & Lehrman
+EROM
+DESCRIPTION
+Ken Jenne
+Steven Jaffe
+Ken Jenne
+Marc Nurik
+Jacquie Johnson
+OBJECTION
+Assistance on the Epstein Case
+PACER entries
+Political
+Work product; attorney/client
+Contributions/advertisement for
+the rental on Little St. James
+Island
+Discussions about Epstein
+Creation of another Doe file
+Epstein Costs
+Personal convo in regards to
+moving offices
+Work
+product; attorney/client privilege;
+Work product; attorney/client
+150
+
+
+06679-06682
+08/26/2009
+07590-07594
+05/13/2009
+08451-08453
+08/17/2009
+08455-08456
+06/03/2009
+08466-08479
+08/26/2009
+01767
+07/06/2009
+08379
+06/06/2009
+08399
+07/23/2009
+Shawn Gilbert
+Attorneys at RRA
+Wayne Black
+Bradley Edwards
+Jaffe, Weissing,
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Shawn Gilbert
+Personal convo in regards to Work product; attorney/client
+moving offices
+Office information
+Pat
+Updated Witness List
+Vanity Fair
+Witness info that we need to use
+Info on a guy going to victim's
+boyfriends house
+Wayne Black
+Info on Former FHP trooper
+subcontracted by
+Paul Cassell
+Epstein affidavit to the reply
+memo
+151
+
+
+08406
+10/30/2009
+05697
+08/19/2009
+20330-20334
+08/24/2009
+20327-20329
+10/17/2009
+20100-20102
+08/24/2009
+20283-20326
+10/14/2009
+20092-20099
+08/24/2009
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Adler
+Mike Fisten
+Pat
+Mike Fisten
+Bradley Edwards
+Mike Fisten
+Ken Jenne
+Flying epstein rape survivor to St.
+Louis to see expert
+Meeting with client
+Serving Alan Dershowitz
+Property purchased by Epstein in
+Palm Beach
+OBJECTION
+Work
+product; attorney/client
+Work product; attorney/client
+Epstein's arrival at his building
+Research regarding Mr. Visoski
+and questions to consider during
+the depo
+Epstein travel
+Work
+product;
+attorney/client privilege;
+Work product; attorney/client
+152
+
+
+20085-20091
+10/15/2009
+19996-20084
+10/14/2009
+20217-20218
+20213-20216
+08/03/2009
+20211-20212
+08/03/2009
+08/10/2009
+20201-20204
+08/24/2009
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Questions from accountant
+Attorneys at RRA
+Mike Fisten
+Visoski Research and Questions
+Mike Fisten
+Info on Copperfield
+Attorneys at RRA
+Ken Jenne
+Info on Copperfield
+Mike Fisten
+Pilots depo
+Jacquie
+List of witness
+Attorneys at RRA
+Serving Dershowitz
+Work product; attorney/client privilege
+arotected by privacy rights
+Work product; attorney/client privilege
+153
+
+
+20193-20200
+19982-19985
+19988
+19971-19981
+19969-19970
+19962-19968
+20190-20192
+20187-20189
+08/24/2009
+09/03/2009
+10/07/2009
+08/24/2009
+08/18/2009
+08/03/2009
+08/24/2009
+08/24/2009
+Attorneys at RRA
+Jacquie
+Jacquie
+Attorneys at RRA
+Pat Roberts
+Attorneys at RRA
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+PESCRIPTION
+OBJECTION
+Proof of him being out of FL - Work product; attorney/client
+Violation of the agreement
+Mike Fisten
+Dave Rogers depo
+Work product; attorney/client
+to the discovery of the admissible evidence:
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Ken Jenne
+Depositions
+Serving Dershowitz
+protected by privacy right
+Subpoenas for Pilots
+Work product; attorney/client privilege
+Working with the FBI to get some
+Personal emails regarding Brad's
+surgery
+protected by privacy rignts
+Epstein travel
+154
+
+
+19959-19961
+00156-00157
+15366-15367
+01003-01005
+01013-01014
+01042
+03133-03134
+07/24/2009
+07/09/2009
+09/04/2009
+10/12/2009
+10/29/2009
+07/22/2009
+06/09/2009
+Attorneys at RRA
+Attorneys at RRA
+Marc Nurik
+Josh Roberts
+•
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Paul Cassell
+Cara
+Flight logs for Epstein
+OBJECTION
+Work product; attorney/client
+2255 Problem
+product; attorney/client
+Witness info that we need to use
+Asset
+movement by
+Epstein
+Jeffrey
+Subpoenaing Epstein's attorneys
+for their fees and accompanying | irrelevant and not reasonably calculated to lead
+documents
+New info that our investigators
+obtained from current FBl agents
+Personal conversation
+155
+
+
+03129-03130
+03119-03121
+05440-05441
+02593-02594
+18877-18879
+18344-18347
+06/09/2009
+06/09/2009
+04/01/2009
+05/13/2009
+09/10/209
+08/24/2009
+Josh
+T.
+(wife)
+Marc Nurik
+FROM
+DESCRIPTION
+Personal conversation
+Fistos & Lehrman
+OBJECTION
+Work product;
+attorney/client privilege;
+Josh
+Personal conversation
+Work
+product;
+attorney/client privilege;
+Carolyn
+(Legal CW Personal information
+Asst. to
+Jay
+Howell,
+co-
+Counsel)
+Work
+product;
+attorney/client
+Bradley Edwards
+Regarding personal information.
+Privileged document- irrelevant and not
+calculated to lead to discovery of admissible
+evidence, privacy rights of parties involved,
+spouse privilege
+Concerning
+the names
+of Work product; attorney/client privilege;
+potential witnesses and the irrelevant and not reasonably calculated to lead
+issuance of subpoena's for them.
+Mike Fisten
+Investigative information and Work product; attorney/client privilege;
+techniques on the Epstein case
+are discussed.
+156
+
+
+18339-18340
+18341-18343
+18853-18854
+18337-18338
+18306
+18307
+08/24/2009
+08/24/2009
+09/10/2009
+08/03/2009
+10/16/2009
+10/17/2009
+Ken Jenne
+Mike Fisten
+Pat
+Mike Fisten
+, Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+Jacquie
+Mike Fisten
+Ken Jenne
+OBJECTION
+Investigative information and
+techniques on the Epstein case | irrelevant and not reasonably calculated to lead
+are discussed.
+Investigative information /and Work product; attorney/client privilege;
+techniques on the Epstein case irrelevant and not reasonably calculated to lead
+are discussed.
+Concerning
+the
+names
+of Work product; attorney/client privilege;
+potential witnesses and the Irrelevant and not reasonably calculated to lead
+issuance of subpoena's for them.
+Investigative information and
+• Work product; attorney/client privilege;
+techniques on the Epstein case
+are discussed.
+List of future depo's in Epstein
+Work product;
+attorney/client privilege;
+case and names of potential | irrelevant and not reasonably calculated to lead
+witnesses.
+Investigative Discussion
+finding of Epstein Assets.
+re: Work
+product; attorney/client privilege;
+157
+
+
+18308-18309
+18188-18189
+18184-18185
+18186-18187
+18180-18183
+05256-05257
+10/18/2006
+09/04/2009
+08/26/2009
+08/31/2009
+08/24/2009
+07/21/2009
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Bradley Edwards
+:
+, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+nvestigative
+Discussion
+inding of Epstein Assets
+Jacquie
+Mike Fisten
+Wayne Black
+OBJECTION
+re: Work product;
+attorney/client
+Discussion re: Work
+product;
+attorney/client
+finding of Epstein witnesses and
+names of potential witnesses.
+product;
+attorney/client
+finding of Epstein witnesses and | irrelevant and not reasonably calculated to lead
+names of potential witnesses.
+Discussión of potential witnesses Work
+product;
+attorney/client
+and the process of subpoena for
+depo's.
+Investigative
+Discussion
+Work
+product;
+attorney/client
+finding of Epstein witnesses and | irrelevant and not reasonably calculated to lead
+names of potential witnesses.
+to the discovery of the admissible evidence:
+Investigative Discussion
+strategy of case.
+re:
+Work
+product; attorney/client
+158
+
+
+05253
+05279-05280
+05315-05318
+05209-05211
+08/24/2009
+IQ
+08/24/2009
+07/26/2009
+06/26/2009
+Jaffe, Weissing,
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Investigative
+Discussion
+strategy of case.
+Pat
+Wayne Black
+Wayne Black
+Investigative
+Discussion
+strategy of case.
+investigative
+Discussion
+strategy of case.
+Investigative
+strategy of case.
+Discussion
+OBJECTION
+re: Work product;
+attorney/client
+re: Work
+product;
+attorney/client
+re: Work
+product;
+attorney/client
+re:
+Work
+product;
+attorney/client
+NOT A CE
+159
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0472c8705fb48a6f9bdba668f0594dfbf7d5a62202ed5834a02082bc62a2c092.receipt.json b/vision-fixhub/court-02/0472c8705fb48a6f9bdba668f0594dfbf7d5a62202ed5834a02082bc62a2c092.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2c1c0181b2fc5bd8050effa5ca2faa393ac3574b
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 273,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.confidential\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "e39fc029f0e516372a3491dabccd7f8059a87bfdf37470ea8fa2fc1e17a787f2",
+  "output_sha256": "1dfb1775983b89b8023a6d175f4b0376c72e52fdbf0044c3a4add1ef5c00df64",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.md b/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.md
new file mode 100644
index 0000000000000000000000000000000000000000..120c60c1581d6fcf9e29bf1495f78dad2ab70472
--- /dev/null
+++ b/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.md
@@ -0,0 +1,494 @@
+Filing # 65639210 E-Filed 12/20/2017 12:49:55 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+NOTICE OF TAKING VIDEOTAPED DEPOSITION DUCES TECUM
+YOU ARE HEREBY NOTIFIED that on Friday, January 12 2018, at 9:00 a.m. at the
+Law Offices of
+Pottinger LLC, 425 N. Andrews Avenue, Suite 2, Ft. Lauderdale, Florida
+33301-3268, Plaintiff/Counter-Defendant Jeffrey Epstein will take the videotaped deposition by
+oral examination for purposes of discovery and for use as evidence in said cause, or both, of:
+EARLEEN COTE
+The videotaped deposition will be taken before a court reporter, a Notary Public, or any
+officer authorized to administer oaths by the laws of the state where the deposition is conducted,
+and a person who is neither a relative, nor employee, nor attorney, nor counsel of any of the parties
+and who is neither a relative nor employee of such attorney or counsel, and who is not financially
+interested in the action. The deposition will continue from day to day until complete.
+The witness shall produce by January 5, 2018, those documents identified in the Subpoena
+Duces Tecum attached.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/20/2017 12:49:55 PM
+
+
+Court reporting services shall be provided by Palm Beach Reporting Service (1665 Palm
+Beach Lakes Blvd., Suite 1001, West Palm Beach, Florida 33401; 561-471-2995) and the video
+equipment will be operated by Visual Evidence (601 N. Dixie Hwy., Suite A, West Palm Beach,
+Florida 33401; 561-655-2855).
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on December 20, 2017, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+NOT A CER
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Angela@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Secondary: Tanya@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+Trial Counsel for Plaintif/Counter-Defendant
+Jeffrey Epstein
+2
+
+
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+I Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintif)
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT A
+NOT
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+144 West Railroad Avenuc
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+3
+
+
+:
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+COPY
+SCOTT ROTHSTEIN individual and.
+Defendants/Counter-Plaintiff.
+SUBPOENA DUCES TECUM FOR VIDEOTAPED DEPOSITION
+THE STATE OF FLORIDA TO:
+TO: Earleen Cote
+Kubicki Draper
+One East Broward Blvd., Suite 1600
+Ft. Lauderdale, FL 33301
+YOU ARE COMMANDED to appear before a person authorized by law to take
+depositions on Friday, January 12, 2018, at 9:00 a.m. at the Law Offices of |
+Pottinger
+LLC, 425 N. Andrews Avenue, Suite 2, Ft: Lauderdale, Florida 33301-3268, for the taking of your
+videotaped deposition in this action. If you fail to appear, you may be in contempt of court.
+You are subpoenaed to appear by the following attorneys, and unless excused from this
+Subpoena by the attorneys or the Court, you shall respond to this Subpoena as directed.
+You are further directed to produce to Plaintiff/Counter-Defendant's counsel by January
+5, 2018, the documents identified in the attached Exhibit "A."
+
+
+Dated: December 20, 2017.
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Angela@linkrocklaw.com
+Secondary: Tina@linkroeklaw.com
+Secondary: Troy@linkrocklaw.com
+Secondary: Tanya@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+If you are a person with a disability who needs any accommodation in order to respond to
+this Subpoena, you are entitled, at no cost to you, to the provision of certain assistance. Please
+contact Link & Rockenbach, 1555 Palm Beach Lakes Boulevard, Suite 301, West Palm
+Beach, Florida 33401 (561) 727-3600, at least seven days before your scheduled appearance,
+or immediately upon receiving this notification if the time before the scheduled appearance
+is less than seven days; if you are hearing or voice impaired, call 711.
+Copies provided to:
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL. 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+2
+
+
+s Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant Counter-Plaintio
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+COPY
+NOT A CERTIFIED
+3
+
+
+
+DEFINITIONS
+"Communication" or "communications" mean any oral, written or electronic
+utterance, notation or statement of any nature whatsoever, by and to whomsoever made, including,
+but not limited to, any documents, correspondence, letters, facsimiles, e-mails, text messages,
+voice recordings, video recordings, voicemail, instant messages, conversations, dialogues,
+discussions, interviews, conferences, meetings,
+consultations,
+agreements, and
+other
+understandings or exchanges between or among two or more people.
+"Document" or "documents" mean all paper documents, graphic or auditory records
+or representations, tangible items, and electronically stored information, and shall have the
+broadest possible meaning accorded to it consistent with Florida Rule of Civil Procedure 1.280
+(which is incorporated in this definition as if fully set forth), and includes, by way of illustration
+only and not by way of limitation, the following items which are in your possession, control,
+knowledge, or are known to you:
+a.
+All written, paper or printed material of any kind, including, but not limited
+to: all transmittal slips, memoranda, notes, schedules, agendas, notices,
+books, brochures, calendars, employment files, announcements, meeting
+minutes,
+records of meetings, records of conversations, newsletters,
+telegrams,
+summaries, lists, compilations,
+facsimile transmissions,
+transcripts, diaries, appointment books, agreements, contracts, reports,
+studies, checks,
+check stubs, invoices,
+financial statements, bank
+statements, receipts, communications, interoffice and intraoffice exchanges,
+conversations, inquiries, replies, correspondence, and letters, whether in
+person, by telephone, in writing, or by means of any other transmittal
+4
+
+
+b.
+devices, and all originals, reproductions, copies, changes, amendments,
+drafts and all non-identical copies of the foregoing;
+Graphic or auditory records or representations of any kind, including, but
+not limited. to: all images,
+photographs,
+charts, drawings,
+sketches,
+diagrams, maps, schematics, microfiche, microfilm, slides, videotapes, laser
+discs, digital versatile discs, Blu-ray discs, Ultra Violet discs, cassette tapes,
+reel to reel tapes, recordings, sound bites, motion pictures, voice messages,
+and all originals, reproductions, copies, changes, amendments, drafts and
+all non-identical copies of the foregoing; and
+c.
+Electronically stored information, electronic, mechanical and electrical
+records or representations of any kind including, but not limited to: all
+ectonic communicators, next mesages, e-mail, instant messages
+computer logs, network logs, Internet history, document files, spreadsheet
+files, presentation files, database files, desktop publishing files, source code
+files, object code files, executable files, data files, script files, project
+management files, text files, portable document format files, tabulated data
+files, virtual machine files, XMIL files, webpage files, image files, design
+10
+files, GIS files, system files, compressed files, disk image files, audio files,
+video files, backup files, metadata and all originals, reproductions, copies,
+changes, amendments, drafts, and all non-identical copies of the foregoing
+(defined herein as "EST"; each individual electronically stored document is
+defined herein as an "ESI document").
+For purposes of the foregoing, documents may be located, stored or archived in any
+physical location or on any electronic storage media, including, without limitation, any computer,
+5
+
+
+server, appliance, cloud-based service, web-based service, database, internal hard drive, external
+hard drive, solid-state drive, hard or floppy diskette, compact disc, digital versatile disc, Blue-ray
+disc, UltraViolet disc, flash memory, flash card, thumb drive, cartridge, magnetic tape, mobile
+phone, tablet device, or personal digital assistant. Moreover, for purposes of the foregoing, the
+term "draft" means any earlier, preliminary, preparatory, or tentative version of all or part of a
+document, whether or not such draft was superseded by a later draft and whether or not the draft's
+terms are the same as or different from the final document's terms. Please note that "Documeni"
+and "Documents" as defined herein specifically include "Communication" and "Communications"
+as defined above:
+3.
+was originally created.
+"Native Format" means the file format of ES/ in the application in which such EST
+4.
+"Person" as used herein means any natural person or any entity, including, without
+limitation, any individual, public company, private company, firm, corporation, limited liability
+company, joint venture, trust, proprietorship, tenancy, association, partnership, business, agency,.
+department, governmental body, bureau, board, commission, or any other form of public or private
+entity. With respect to an entity, Person shall include all subsidiaries and affiliates of the entity, as
+well as the present and former directors, officers, employees, attorneys, agents and anyone acting
+on behalf of, at the direction of, or under the control of, the entity or its subsidiaries or affiliates.
+The terms "you" or "your" mean Earleen Cote and include all employees, staff,
+representatives, attorneys, accountants, agents and any other person acting under her control or on
+her behalf.
+"Relates to" or "relating to" mean authorizing, concerning, constituting,
+comprising, containing, consisting of, connected with, describing, disclosing, discussing,
+6
+
+
+evidencing, explaining, mentioning, pertaining to, proposing, reflecting, regarding, referring to,
+directly or indirectly, setting forth, showing, or summarizing.
+"Lawsuit" means the litigation styled Jeffrey Epstein v. Scott Rothstein and
+J.
+Case No. 502009CA040800XXXXMBAG, pending in the Fifteenth Judicial Circuit
+in and for Palm Beach County, Florida.
+8.
+"Other Lawsuits" means all lawsuits filed by Jane Doe, L.M., E.W. or any other
+clients represented by
+J..
+against Jeffrey Epstein from January Y, 2008 to the
+present.
+"Tagged Image File Format" or "TIFF" refer to the CCITT Group IV graphic file
+format for storing bit-mapped images.
+10.
+Where appropriate:
+use of the singular includes the plural, and vice versa;
+a.
+b.
+the words "and" and "or" are both conjunctive and disjunctive;
+INSTRUCTIONS
+General Instructions
+In response to this Subpoena Duces Tecum, you are required to furnish all
+information and documents which are, or have been, in your possession, custody, or control, or in
+your possession, custody, or control.
+Unless otherwise specifically stated in each request, the relevant time period shall
+be from the date
+applied to Kubicki Draper for employment to the present.
+7
+
+
+ESI Instructions
+3.
+ESI Production Format. ESI shall be produced electronically, either in (1) Native
+Format, or (2) as single-page, uniquely and sequentially numbered Group IV TIFF image files.
+For each ESI document, all metadata must remain intact and all parent/child document
+relationships must be maintained. All. ESI shall be collected using methods that prevent the
+spoliation of data.
+4.
+Production Media. The production of EST as described herein shall be made on an
+external hard drive, flash drive, CD or DVD ("Production Media"). The Production Media shall
+include a unique identifying label specifying: (a) your identity; (b) the date of the production of
+EST; and (c) the Lawsuit name and number.
+ESI of Limited Accessibility. If you contend that any ESI document responsive to
+this Subpoena is not reasonably accessible: (1) timely identify such ESI document with reasonable
+particularity; and (2) provide the basis for declining to produce the ESI document, including, for
+example, any limitations on access, the likely costs that might be incurred in accessing and
+producing the ESI document, the method used for storage of the ESI document and all locations in
+which the ESI document is kept.
+TIFE Production. ESI produced as TIFF image files shall. be produced as follows:
+(1) each production of TIFF image files shall be accompanied by a corresponding load file (Image
+Load File"); (2) each TIFF image file must contain the same information and same physical
+representation as the Native Format file from which the TIFF image file was created; (3) each
+TIFF image file must not be less than 300 dpi resolution; (4) each TIFF image file shall be
+accompanied by an extracted text file containing the extracted text of the Native Format file from
+which the TIFF image file was created; (5) each extracted text file shall be named to match the
+endorsed number assigned to the first page of each corresponding TIFF image file; (6) the
+8
+
+
+extracted text files shall be accompanied by a Control List File ("LST"); (7) each production of
+TIFF image files shall be accompanied by an image cross-reference load file, such as Opticon
+("OPT"), which shall provide the beginning and ending endorsed number of each TIFF image file
+and the number of pages it includes; and (8) each production of TIFF image files must be
+accompanied by a data load file ("Data Load File" or "DAT") that contains both the hash value
+and all available metadata of the Native Format files from which the TIFF image files were
+created. Further, the following instructions apply to the production of TIFF image files:
+a.
+Processing Specifications. For each Native Format file that is converted to
+TIFF format: (1) all tracked changes shall be maintained so that all changes
+are visible; (2) OLE Embedded files shall not be extracted as separate
+documents; (3) author comments shall remain or be made visible; (4) hidden
+columns, cells, rows, worksheets and other hidden data shall remain or be
+made visible; (5) presenter notes shall remain or be made visible; and (6) to
+the extent EST in a foreign language is produced, processing of such ESI
+shall be unicode-compliant.
+Document Unitization. If a Native Format file that is converted to TIFF
+format is more than one page, the unitization of the file and any attachments
+or affixed notes must be maintained as it existed when collected. If
+c.
+unitization cannot be maintained, the original unitization must be
+documented in the Data Load File or otherwise electronically tracked.
+Color. If a Native Format file that is converted to TIFF format contains
+color, the TIFF image file need not be produced in color. However, we
+ieserve the right to make a request for a file to be produced in color.
+
+
+2.
+4.
+6.
+d.
+é.
+f.
+Where TIFF Image File Format is Impracticable
+In the event that
+production of a Native Format file as a TIFF image would be impracticable,
+you shall produce such file in Native Format with all metadata intact. You
+shall provide a single page TIFF image placeholder referencing the title of
+the Native Format file not being produced as a TIFF image.
+Spreadsheets. All Microsoft Excel files, similar non-Microsoft spreadsheet
+files, and graphical compilations of spreadsheet data, shall be produced in
+Native Format with all cells, columns, rows and worksheets and other
+information unhidden and expanded.
+Right to Request Native Format files. We reserve the right to demand
+production in Native Format of any file produced by you as a TIFF image
+file.
+REQUESTED DOCUMENTS
+'Kubicki Draper's employment and personnel files for |
+including, but
+not limited to, applications for employment, letters of referral, background checks,
+employment contracts, agreements, promissory notes, evaluations, reviews, summaries,
+notes, and communication (recognizing HIPAA laws, this request does not seek personal.
+medical records).
+Your current curriculum vitae:
+Any reports prepared by you or at your direction, relating to your services or participation
+in this Lawsuit.
+Copies of any notes made by you, or provided to you, relating to your opinions or
+conclusions in this Lawsuit, whether you relied on those notes or not.
+Communications between you and any person relating to your analysis, opinions or
+conclusions in this Lawsuit.
+Any photographs or videos taken by you, or provided to you, that you have observed and
+reviewed in relation to this Lawsuit.
+
+
+Any deposition or hearing transcripts provided to you, or parts of deposition transcripts or
+any other statements or written materials provided to you, which you have examined or
+will examine in relation to this Lawsuit.
+10.
+Any diagrams or drawings made by you or provided to you, which you have examined in
+relation to this Lawsuit.
+Any statements or affidavits taken by you, at your direction, or provided to you for your
+review concerning any of the facts which are involved in this Lawsuit.
+Any memoranda or written notice made by you, or provided to you, concerning the subject
+matter of this Lawsuit.
+11.
+Any documents prepared by you, provided to you, or obtained by you or reviewed by you,
+whether intended for your use or not, and regardless of whether or not you actually
+reviewed or relied on those documents, in connection with this Lawsuit.
+12. All literature and/or documents that you considered relevant to your assignment in this
+Lawsuit and which you considered in the development of your opinions or conclusions
+concerning the subject matter of the lawsuit.
+13.
+All documents prepared by you to illustrate or demonstrate any fact or opinion considered
+relevant to this Lawsuit and/or to your assignment, investigation, or opinions.
+14.
+Copies of any articles, books, papers or other publications prepared by you which relate to
+facts similar to the facts surrounding the subject matter of this Lawsuit.
+15.
+16.
+17.
+18.
+19.
+Any and all materials considered, consulted, and used by you as a basis or predicate for
+your opinions and conclusions in this Lawsuit, including, but not limited to, published
+reports by any private or government agency, textbooks, articles, data or documents
+furnished by the party engaging your services, or government or industry standards or
+regulations,
+Any and all models or demonstrative tools upon which you have or plan to rely, in the
+formulation and expression of your opinions and conclusions concerning the subject matter
+of this Lawsuit.
+A copy of any retainer agreement or other agreement between you and
+(or counsel for
+James
+James
+that sets forth the terms of your
+engagement in this matter, including, but not limited to, the fees for your services in this
+Matter.
+A copy of all statements, bills, invoices, check stubs or any other document that reflects
+pays Lat our compensation, or a request for payment or compensation, for your services in
+All marketing materials that market or advertise your expert witness services.
+11
+
+
+20.
+21.
+22.
+23.
+24.
+25.
+A list of all other expert witness services performed for I
+clients represented by
+James
+in the last ten years.
+A list of other depositions or trials in which you have testified from January 1, 2008 to the
+present.
+All expert reports, testimony, videos and affidavits in which you have testified as an expert
+on any issue in the last ten years.
+Cope or all bicated oper iports, depositions or ode does a bie your
+Your file regarding your opinions, possible opinions, expert testimony, and/or consultation
+relating directly or indirectly to the issues in this Lawsuit.
+All complaints filed against you with the Florida Bar, as well as all communications to you
+by the Florida Bar and all documents relating to any disciplinary proceedings or
+investigations conducted by the Florida Bar, or any committee of the Florida Bar.
+NOT A CERTIF
+12
\ No newline at end of file
diff --git a/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.receipt.json b/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..44d96868a2e19310903ad57ee190da234f02660c
--- /dev/null
+++ b/vision-fixhub/court-02/04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -218,
+  "dataset": "marble-joined",
+  "doc_id": "04a90f84ba958d8a88759c6045ac2742f1786861d7aec776b367de3b8c101863",
+  "engine": "marble-apple-vision",
+  "event_count": 17,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "81e81a4143cb6e3b7511615a05f2c602204640f00e5641de7adbcc2dff18b482",
+  "output_sha256": "e3e9ce1fa2bb7316f5e187f194b1235e835d9dd21a3196c4837875b7f7596259",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.md b/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.md
new file mode 100644
index 0000000000000000000000000000000000000000..ea22fcf263da25eddd56fd747061d67e10819b8d
--- /dev/null
+++ b/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.md
@@ -0,0 +1,67 @@
+Case 9:08-cv-80736-KAM Document 362-49 Entered on FLSD Docket 02/10/2016 Page 1 of 3
+
+119
+
+
+Case 9:08-cv-80736-KAM Document 362-49 Entered on FLSD Docket 02/10/2016 Page 2 of 3
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+July 17, 2008
+VIA FACSIMILE
+Michael R. Tein, Esq.
+Tein, P.L.
+3059 Grand Avenue, Suite 340
+Coconut Grove, FL 33133
+Re:
+Jeffrey Epstein
+Dear Mr. Tein:
+The Office has reviewed your "Notice of Continued Pendency of Federal Criminal
+Action," and we feel that it misrepresents the posture of the federal investigation. For
+example, you cite to
+1(1), as evidence that the federal
+criminal action remains pending. That is a citation to Mr. Epstein's Motion to Quash a
+subpoena for computer equipment removed from Mr. Epstein's home after he and his
+attorneys were aware of the existence of the state investigation. Pursuant to the Non-
+Prosecution Agreement, that motion was supposed to have been withdrawn several months
+ago, and, therefore, is not "pending" in our estimation.
+The Non-Prosecution Agreement calls for deferment of federal prosecution "in favor
+of prosecution by the State of Florida, provided that Epstein abides by the [enumerated]
+conditions and the requirements of th[e] Agreement ..." (Non-Prosecution Agreement, p.
+2 (emphasis added).) One of those conditions is Epstein's agreement that the subject Jane
+Does, while minors, were victims of a violation of an offense enumerated in Title 18, United
+States Code Section 2255, and that they "will have the same rights to proceed under Section
+2255 as [they] would have had if Mr. Epstein had been tried and convicted of an enumerated
+offense." (United States Attorney's December 19, 2007 letter to Lilly Ann
+If, in fact, your position is that the federal criminal action is still pending such that the
+Court must stay the civil proceedings, then the Office proposes that we seek the prompt
+resolution of the Motion to Quash, so that the computer equipment can be analyzed and the
+08-80736-CV-MARRA
+RFP WPB 000470
+
+
+Case 9:08-cv-80736-KAM Document 362-49 Entered on FLSD Docket 02/10/2016 Page 3 of 3
+MICHAEL TEIN, ESQ.
+JULY 17,2008
+PAGE 2
+federal investigation can continue. If, instead, Mr. Epstein intends to fully abide by the Non-
+Prosecution Agreement, then the "federal Grand Jury investigation will remain suspended,
+and all pending federal
+I will be held in abeyance unless and until
+[Epstein] violates any term of [the Non-Prosecution Agreement]." (Non-Prosecution
+Agreement, page S.)
+Please advise whether you intend to correct the representations to the Court regarding
+the status of the federal investigation.
+Sincerely,
+R. Alexander Acosta
+United States Attorney
+By:
+Villafaña
+Assistant United States Attorney
+cc:
+Jack Goldberger, Esq.
+Karen Atkinson, Esq.
+08-80736-CV-MARRA
+RFP WPB 000471
diff --git a/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.receipt.json b/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..8de79685d5f75d1ac27daf940587e0e82f1a561c
--- /dev/null
+++ b/vision-fixhub/court-02/04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -43,
+  "dataset": "marble-joined",
+  "doc_id": "04af5fc5ee3f856f7ff4e34fa638a84e3dd0c09f109c9683e95fc26ce53928f4",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "c3c30cb43ae3075b3a427464a94f6a7601748cff4a7b2167f5f923d45443f115",
+  "output_sha256": "598dc742055f41697e49b5752008191932bd63f9742c7a73fabbbeb187486ebc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.md b/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.md
new file mode 100644
index 0000000000000000000000000000000000000000..891ac8f26057fb24522c83580271c91690527c8f
--- /dev/null
+++ b/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.md
@@ -0,0 +1,57 @@
+Case 9:08-cv-80736-KAM Document 362-20 Entered on FLSD Docket 02/10/2016 Page 1 of 2
+
+90
+
+
+Case 9:08-cv-80736-KAM Document 362-20
+Dec-07-07
+-
+04:54pm
+From-Fu
+Burnett
+Entered on FLSD Docket 02/10/2016 Page 2 of 2
+
+T-865
+P.002/004
+F-976
+FOWLERWHITE
+ATTORNEYS AT LAW
+BURNETT
+MIAMI • FORT LAUDERDALF • WeSTPALM BEACH • ST. PETERSSURG
+ESPRETO SANIO PLAZA
+FOUNDINTH FLOOR
+1395 BACKEL, AVÊNUE
+MIAMI, FLORIDA 33131
+TELE-HONE (305) 789-9800
+FAtaNNE (305) 700-9201
+www.rowL@-wrne.coM
+LILLY ANN
+DIRKoT Prone No.: (305: 789-9279
+DIRECT FACSINILE No.: (308) 728-7879
+LANCHEZ@FOWL-@H-WHITE.COM
+December 7, 2007
+Jeftrey Sloman
+First Assistant United States Attomey
+United States Attorney's Office
+Souther District of Florida
+500 South Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Re: Jeffrey Epsiein
+Dear Jeft:
+Pursuant to your letter dated December 6, 2007, attached is a signed
+Affirmation of the Non-Prosocution Agreement and Addendum to sume dated
+October 30, 2007 (collectively "Agreement") signed by my client Jefthey E. Epstein
+(see attached).
+Moreover, pursuant to the terms of the Agreement, please note that the plea
+and sentencing hearing have been scheduled for January 4, 2008 at 8:30 a.m. before
+Judge Sandra MeSorley (please see attached notice of hearing). In addition, 4s
+expressed in my voicemail message to you earlier, I would request that the Office
+hold off on sending any victim notification letters until we can further discuss the
+contents therein. Please call me at your earliest convenience.
+Sincerely
+Lilly Ann
+.. Alege emota Star
+Dinab| W171300LBT/107k3-alomosn.LA8(12/07-15:51)
+I BURNETT P.A.
+08-80736-CV-MARRA
+RFP WPB 001557
diff --git a/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.receipt.json b/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..7f172e1870ff0535b656491fe4cd74cb113511bf
--- /dev/null
+++ b/vision-fixhub/court-02/04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -41,
+  "dataset": "marble-joined",
+  "doc_id": "04e209dbf96f088c9c95f00ea4796b6cdca0d51ec8566b8f3011a885f6c3af89",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "fd9b8a607f87653f0bc0f50582a6b09b22a98c2c50c215a9a5df794571159fa0",
+  "output_sha256": "00e4ffb3489024758779d85b0159a780e9e1fcd71fc461406d482f540b56be2d",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.md b/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.md
new file mode 100644
index 0000000000000000000000000000000000000000..431393151d242dd2c2fe679210c94708c1dfd8ed
--- /dev/null
+++ b/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.md
@@ -0,0 +1,117 @@
+JEFFREY EPSTEIN,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+1:7
+Plaintiffs),
+• •
+..:
+VS.
+SCOTT ROTHSTEIN, individually,
+_J.L
+, individually, and
+L.M., individually,
+37
+Defendants).
+PLAINTIFFS' REQUEST FOR PRODUCTION TO JEFFREY EPSTEIN
+Defendant/Counterplaintiff,
+J. Edwards by and through his undersigned counsel,
+requests, pursuant to Rule 1.350
+of the Florida Rules of Civil Procedure, that
+Plaintiff/Counterdefendant, Jeffrey Epstein, produce and permit
+J.
+to inspect
+and copy each of the following documents*/
+Any and all documents* reflecting, relating to, or suggesting that
+had
+knowledge about Rothstein's commission of or attempt to commit any fraud prior to the public
+disclosure of Rothstein's criminal conduct.
+Any and all documents* which in any way support the claim or claims that
+Epstein is pursuing against
+3.
+4.
+All emails that Epstein intends to use or may use as a trial exhibit.
+All documents* that rebuts, refutes, and/or contradicts the claims Epstein is
+pursuing against
+
+
+adv. Epstein
+Statements from anyone that in any way support the claims Epstein is pursuing
+against
+*'Documents" shall include, but not be limited to all non-identical copies of writings,
+drawings, graphs, charts, photographs, phono-records, recordings, and/or
+any other data
+compilations from which information can be obtained, translated, if necessary, by the party to
+whom the request is directed through detection devices into reasonably usable form.
+"Documents" also include all electronic data as well as application metadata and system
+metadata. All inventories and rosters of your information technology (IT) systems-e.g.,
+hardware, software and data, including but not limited to network drawings, lists of computing
+devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission
+features), programs, data maps and security tools and protocols.
+It is requested that the aforesaid production be made within thirty days of service of this
+request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach
+Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation,
+examination and/or copying.
+2
+
+
+adv. Epstein
+HERE CERT a an one cop of rein a ben amiable ty.
+Fax and U.S. Mail to all Counsel on the attached list, this
+day of June, 2011,
+Searcy Denney Scarola Barnhart & Shipley
+239 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+- (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+NOT A CER
+3
+
+
+•
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+Attorney For: Jeffrey Epstein
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+. Jaffe, Weissing,
+Lehrman, PL
+Attorney For: Jeffrey Epstein
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+, Fistos &
+COPY
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+Attorney For: Scott Rothstein
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954) 745-5849
+Fax: (954) 745-3556
+'ERTIFIED
+L. Ackerman, Jr., Esquire
+Burnett, P.A.)
+Attorney For: Jeffrey Epstein
+901 /
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561) 802-9044
+Fax: (561) 802-9976
+Weinberg, Esquire
+Weinberg, P.C.
+Attorney For: Jeffrey Epstein
+20 Park Plaza, Suite 1000
+Suffolk,
+02116
+Phone:
+4
\ No newline at end of file
diff --git a/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.receipt.json b/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..bd974cb072384dc80981253eac1f5407b9799cb5
--- /dev/null
+++ b/vision-fixhub/court-02/05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -274,
+  "dataset": "marble-joined",
+  "doc_id": "05173419469d350db825b4174eb5b52e5f1d131b95dacf50b4f3686500e4f2e3",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "cba43e4054c4337cd05d2bd0f0e5b9cc97c2238dc68fbdb86803217c58071ddf",
+  "output_sha256": "36de7e98a45ad0efc8b07966c6a3df766f3027607537688d0676196266a646cc",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/053b74b81a638abb4dd4a8b11fdecebe332a783dec1fc1f4ee945f131bcd14ea.md b/vision-fixhub/court-02/053b74b81a638abb4dd4a8b11fdecebe332a783dec1fc1f4ee945f131bcd14ea.md
new file mode 100644
index 0000000000000000000000000000000000000000..06fcb533791f9d2e8676706247d3e3db052eb4f4
--- /dev/null
+++ b/vision-fixhub/court-02/053b74b81a638abb4dd4a8b11fdecebe332a783dec1fc1f4ee945f131bcd14ea.md
@@ -0,0 +1,420 @@
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 1 of 16
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.:08-CV-80736-KAM
+JANE DOE 1 and JANE DOE 2,
+Petitioners,
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+ORDER DENYING INTERVENOR'S MOTION FOR A PROTECTIVE ORDER
+This cause is before the Court on Intervenor Jeffrey Epstein's Unopposed Motion for a
+Supplemental Protective Order. (DE 261). The once-unopposed motion is now opposed by
+Petitioners (DE 298) and prospective intervenors the Palm Beach Post and Palm Beach Daily
+News (the Media) (DE 305).' Considering the positions of the parties and intervenors, the Court
+concludes that the proposed supplemental protective order should not issue.
+I. Background
+This is a case against the United States for allegedly violating the Crime Victims' Rights
+Act (CVRA), 18 U.S.C. § 3771, by failing to involve Petitioners (and other similarly situated
+victims of Intervenor Epstein) in the process that ultimately led to a federal non-prosecution
+agreement between the Government and Epstein. (DE 1). The parties and intervenors have
+debated, and continue to debate, the discoverability and discloseability of correspondence
+documents that evidence just exactly what transpired between the Government, Epstein, and their
+' The Court is granting the Media's motion to intervene and will consider its arguments
+against the protective order accordingly.
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 2 of 16
+respective attorneys.
+In March 2011, Petitioners moved "to allow use of correspondence between the U.S.
+Attorney's Office and counsel for Jeffrey Epstein" to prove their CVRA case. (DE 51 at 1).
+Petitioners argued that the correspondence was relevant as it "shows that the U.S. Attorney's
+Office was aware of its statutory obligation to inform the victims of the non-prosecution
+agreement," and that they should be allowed to use it "as it sheds important light on the events
+surrounding the non-prosecution agreement, which are central to the victims' arguments that the
+U.S. Attorney's Office violated their rights." (Id. at 5, 6). Intervenor Epstein and his attorneys
+opposed the motion and sought a protective order, arguing that "case law as well as sound and
+substantial policy considerations prohibit disclosure of the letters and emails prepared by Mr.
+Espstein's lawyers during plea negotiations with the government, and require that the letters and
+emails that Jane Doe 1 and Jane Doe 2 already have remain confidential." (DE 162 at 1; see also
+DEs 160, 161).
+On June 18, 2013, this Court rejected the intervenors' concerns and granted Petitioners'
+motion:
+Accordingly, the court rejects the privileges asserted by intervenors
+Findinerati ste coprodes cupie seal in hireding.
+any particular piece of correspondence, a matter expressly reserved
+2
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 3 of 16
+for determination at the time of final disposition.
+(DE 188 at 9-10) (internal citation omitted). The Court then ordered that discovery recommence
+(DE 189 at 14) and ordered the Government to "[p]roduce responsive documents ...
+encompassing any documentary material exchanged by or between the federal government and
+persons or entities outside the federal government (including without limitation all
+correspondence generated by or between the federal government and Epstein's attorneys)" (DE
+190 at 2).
+Intervenor Epstein and his attorneys challenged these orders in an interlocutory appeal to
+the Eleventh Circuit Court of Appeals. (DEs 194, 195, 196). The Eleventh Circuit affirmed this
+Court's orders and lifted its stay on the order compelling the disclosure of the correspondence.
+Jane Doe No. 1 v. United States of America, 749 F.3d 999, 1010 (11th Cir. 2014). The court
+held that "[nJo privilege prevents the disclosure of the plea negotiations." Id. at 1008.
+Specifically, the court held that "Federal Rule of Evidence 410 does not protect against the
+discoverability of plea negotiations," and, even if it did, Petitioners "intend to admit the
+correspondence to prove violations of the Act allegedly committed by the United States, not
+"against' Epstein," whom Rule 410 protects. Id. at 1008. The court also rejected arguments that
+the correspondence was protected under the work-product privilege or a common-law privilege
+for plea negotiations. Id. at 1008-10.
+. "Although plea negotiations are vital to the functioning of
+the criminal justice system, a prosecutor and target of a criminal investigation do not enjoy a
+relationship of confidence and trust when they negotiate. Their adversarial relationship, unlike
+the confidential relationship of a doctor and patient or attorney and client, warrants no privilege
+beyond the terms of Rule 410." Id. at 1009.
+3
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 4 of 16
+Thereafter, Intervenor Epstein moved for a Protective Confidentiality Order, arguing that,
+although the Court (and Eleventh Circuit) ruled that Petitioners could discover the
+correspondence at issue, the Court should "bar the Plaintiffs from disseminating and/or publically
+disclosing the substance of the [correspondence] absent further order of the Court." (DE 247 at
+4). Epstein sought a protective order which "(1) limits the dissemination of [the correspondence
+at issue in the Court's June 18, 2013 Order (DE 188)] to a designated list of the Plaintiffs'
+counsel and support staff, and (2) prohibits any party from filing pleadings, briefs, memorandums
+or exhibits purporting to reproduce, quote, paraphrase or summarize any [of this correspondence]
+or portions thereof, absent leave of the Court to file the document or portion thereof under seal."
+(Id. at 1; see also DE 247-1).
+On September 22, 2014, this Court granted Epstein's request for a protective order in part
+and denied it in part. (DE 255). The Court held as follows:
+Epstein argues that good cause exists for protecting the
+correspondence because this is a "high profile" case, and
+petitioners' counsel has made numerous comments to the press
+about this case in the past. The Court finds that Epstein has shown
+correspondence between the government and the intervenors to the
+press for the purposes of generating publicity. Accordingly, the
+provisions [of the proposed protective order] that would limit
+disclosure of the correspondence in question to the proposed list of
+people are acceptable. However, the Court finds the proposed
+requirement to seek leave of Court to seal the filing every time a
+party files a motion is overly restrictive and that it will inhibit the
+defense of any motion.
+(DE 255 at 4-5). The Court declined to enter the proposed protective order; however, it invited
+4
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 5 of 16
+"the parties or Epstein [to] propose another protective order consistent with this opinion." (Id. at
+5).
+Neither the parties nor Epstein submitted a proposed protective order consistent with the
+Court's September 22, 2014 opinion (DE 255). Rather, on October 8, 2014, Epstein filed the
+instant motion for a "supplemental protective order." (DE 261). The motion proposed the entry
+of a protective order "that would expand the limited Protective Order allowed in [the Court's]
+decision Granting in Part and Denying in Part the Intervenors' Motion for a Protective
+Confidentiality Order. [D.E. 255 at 4]." (Id. at 1). In particular, this expanded protective order
+would "require that any party would be required to file under seal any portion of the plea
+negotiation correspondence between the Government and Epstein's counsel, whether offered as
+an exhibit or quoted from in the content of a pleading or motion." (Id.). As this proviso seemed
+to conflict with the Court's earlier ruling that "[a]ny party may file any document ... in
+connection with any motion" without first seeking leave to seal (DE 255 at 4-5), and the general
+policy that judicial filings be open to the public, the Court requested justification as to why a
+preemptive seal on filed documents was necessary in this case. (DE 286).
+Intervenor Epstein responded with his justifications for a temporary seal on filings that
+utilize the correspondence. (DE 295). Petitioners, who once did not oppose such a seal,
+responded with their position that the correspondence should be filed in the public record. (DE
+298). The Media also responded with their reasons for why a temporary seal on public filings
+should not issue. (DE 305).
+II. Discussion
+A district court has "broad discretion ... to decide when a protective order is appropriate
+5
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 6 of 16
+and what degree of protection is required." Seattle Times Co. v. Rhinehart, 467 U.S. 20, 35
+(1984) (discussing Fed. R. Civ. P. 26(c)); see also F.T.C. v. AbbVie Prods. LLC. 713 F.3d 54, 58
+(11th Cir. 2013) (noting that district court has "considerable discretion to modify its own
+protective order"). Although broad, the court's discretion is not unbounded: the court must take
+care to apply the correct legal standard and follow the proper procedures in determining whether
+a protective order should issue. See Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263
+F.3d 1304, 1309 (11th Cir. 2001).
+A.
+Legal Standard
+Intervenor Epstein argues that the proper legal standard is the "good cause" standard
+found in Federal Rule of Civil Procedure 26(c). (DE 295 at 4-5). He argues that the Court aimed
+too high when it requested that he demonstrate "extraordinary circumstances or particularized
+needs" in its order requesting justification for a protective order. (Id. at 4). The Court agrees
+that, under the principles espoused in Chicago Tribune Co. v. Bridgestone/Firestone, Inc., 263
+F.3d 1304 (11th Cir. 2001), the "good cause" standard governs the request for a protective order
+under these circumstances.
+In Chicago Tribune, the Eleventh Circuit held that, once discovery materials have become
+subject to a protective order under Rule 26, "the fact that [the] sealed material is subsequently
+submitted in connection with a substantive motion does not mean that the confidentiality
+imposed by Rule 26 is automatically foregone." Id. at 1313. The issue of whether previously
+sealed discovery materials should be disclosed when attached to public filings "requires the court
+to balance the respective interests of the parties... [which] may be resolved by the Rule 26 good
+cause balancing test." Id. "This standard requires the district court to balance the party's interest
+6
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 7 of 16
+in obtaining access against the other party's interest in keeping the information confidential." Id
+Whether good cause exists for a protective order "is a factual matter to be decided by the nature
+and character of the information in question," and due regard may be given to media entities"
+"contention that disclosure serves" a legitimate public interest. Id. at 1315.
+These standards guide the Court's determination whether a protective order should issue
+concerning disclosure of the correspondence in the court file. The parties and intervenors operate
+under the assumption that a "Protective Confidentiality Order [is] presently in place" regarding
+the disclosure of the correspondence at issue. (DE 295 at 3 (citing DE 255 at 4); see DE 298 at
+3). Therefore, whether materials subject to that order should now become part of the public
+record is governed by the good cause standard of Rule 26. Chicago Tribune, 263 F.3d at 1313.
+For the following reasons, the Court concludes that the balance of interests does not favor
+imposing the proposed supplemental protective order.
+B.
+Interest in Obtaining Access
+Intervenor Epstein's supplemental protective order seeks to "provide ... protection when
+[correspondence] documents are converted into exhibits and filed as a public record with the
+Court." (DE 295 at 3). That is, he seeks a preemptive seal on exhibits that are attached to a
+motion for the ostensible purpose of aiding the Court in resolution of that motion. When
+"discovery material [is] filed in connection with pretrial motions that require judicial resolution
+of the merits," the common-law right of access attaches. Chicago Tribune, 263 F.3d at 1312.
+Such materials placed in the record to materially advance the judicial resolution of the
+merits— play a key role in informing the public of the grounds upon which the district court bases
+its adjudicative decision. See Travelers Indem. Co. v. Excalibur Reinsurance Corp., No. 11-cv-
+7
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 8 of 16
+1209, 2013 WL 4012772, at *10 (D. Conn. Aug. 5, 2013) (Discovery documents are not judicial
+documents subject to a presumptive right of access because, "prior to admission into the record
+in support of a motion or as evidence at trial, [they] play no role in the performance of Article III
+functions of a federal judge.") (internal quotation marks omitted) (emphasis added). Importantly,
+the common-law right of access imposes a "general presumption that," once materials are
+presented to the court for "judicial resolution of the merits" of a case, the public should be
+afforded the right to inspect and copy those documents. AbbVie Prods. LLC, 713 F.3d at 62-63.
+These principles weigh against the Intervenor's request for a temporary blanket seal on
+public filings. The Media argues that the correspondence in question touches a "question of
+profound public concern," i.e., whether the justice system failed to afford Epstein's victims the
+rights to which they were entitled. (DE 305 at 2). The Court agrees that questions concerning
+the federal justice system are of significant public concern. See, e.g., Hyland v. Wonder, 972
+F.2d 1129, 1137 (9th Cir. 1992) ("[AJbuses, inefficiency, threats to public safety, potential civil
+rights violations, and incompetence of public law enforcement officials .... are of vital interest
+to citizens in evaluating the performance of their government."); Floyd v. City of New York, 283
+F.R.D. 153, 159 (S.D.N.Y. 2012) (case involving the unfair treatment of participants "in the
+criminal justice system" "presents an issue of great public concern"); Comm. On The Judiciary
+U.S. House of Representatives v. Miers, 575 F. Supp. 2d 201, 209 (D.D.C. 2008) (stay pending
+appeal denied because stay "may leave important public concerns regarding the nation's federal
+criminal justice system unaddressed."). The Media's interest in disclosure regarding the
+appropriate resolution of this question is therefore entitled to significant weight.
+Epstein argues that much of the correspondence is irrelevant to answering this question.
+8
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 9 of 16
+(DE 295 at 14). According to him, "[w]hether the plaintiff's CVRA rights were violated is an
+issue that is extrinsic from the detailed exchanges of emails and letters that constitute the plea
+and non-prosecution negotiations between Mr. Epstein's counsel and the government." (Id. at 9).
+The Court disagrees: it is likely that much of the evidence concerning whether the Government
+violated the Petitioners' CVRA rights by allegedly concealing from them the plea negotiations
+will come from the plea negotiations themselves.? As Petitioners point out, "the victims have
+previously alleged that (for example) the defense attorneys pushed prosecutors to agree to a
+confidentiality provision that illegally kept the non-prosecution agreement secret from the
+victims and the public. Allowing the issue to be litigated in public pleadings ... promotes
+public confidence that these important issues are being handled appropriately by the Court." (DE
+298 at 6). The Media agrees that the "plea negotiation correspondence will be relevant to the
+central issue in this case—whether the Plaintiffs were afforded their rights under the Crime
+Victims' Rights Act." (DE 305 at 2). The correspondence at issue cannot be said to be
+altogether "extrinsic" to Petitioners' claim; it is likely that some of what was said touches matters
+of central importance in this case.
+Moreover, the Court finds that the procedure that Epstein proposes-temporarily sealing
+all correspondence filed until a party or the public moves to unseal it (DE 295 at 15)—is overly
+restrictive and threatens to inhibit the administration of this case, especially in light of the
+Petitioners' indication that they now oppose sealing the correspondence in public filings. The
+procedure-
+—filing under seal, with the inevitable accompaniment of a motion to
+= The Court does not decide the relevance or admissibility of any particular piece of
+evidence that this time, and no statement from this Order should be construed a ruling or
+indication in that regard.
+9
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 10 of 16
+unseal—resembles the procedure that the Court rejected in Epstein's initial proposed protective
+order seeking leave to seal each time a party wishes to file a piece of the correspondence.
+In sum, the Court finds that the public has a legitimate interest in the issues presented in
+this case and in having access to the materials presented before the Court for resolution of those
+issues. This interest is entitled to significant weight.
+B.
+Interest in Keeping Correspondence Confidential
+Intervenor Epstein argues that the correspondence, which has been held non-privileged,
+should nonetheless be "afforded protection against public dissemination in [this] high-profile
+case [because] there are valid heightened concerns that voluminous settlement negotiations will
+be dumped in the court record simply to make them available to the gossip media." (DE 295 at
+10). He offers two primary reasons for a seal: (1) the "longstanding tradition" that plea and
+settlement negotiations are confidential, and his expectation that they would remain so (id. at 10,
+12); and (2) the harm that would befall him and his counsel if Petitioners are allowed to engage
+in a wholesale "dump" of sensitive documents into the public record (id. at 13-15). The first set
+of reasons has been rejected as they relate to Epstein's argument that the correspondence was
+privileged, and they remain unavailing as far as confidentiality is concerned. The Court finds
+that the threat of abusive filings is better addressed by means other than a preemptive seal on
+public filings.
+1.
+Plea Negotiation Confidentiality
+Intervenor Epstein argues that "[p]lea negotiations and settlement communications have
+no tradition of being publically accessible," and that "serious Sixth Amendment implications,"
+the spirit of Federal Rule of Evidence 410, and the "environment of confidentiality" fostered by
+10
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 11 of 16
+Rule 410 and Federal Rule of Criminal Procedure 11 indicate that the plea negotiation
+correspondence should "be protected from future use by an adversary." (DE 295 at 10-12).
+These alleged justifications-together or separately—do not support a prevailing interest
+in keeping the plea negotiation correspondence confidential. As the Eleventh Circuit has already
+held, Rule 410 does not bar disclosure of the correspondence (at trial or otherwise) because
+"Epstein cannot invoke Rule 410 because he pleaded guilty to state charges ... and has not
+withdrawn those pleas." Doe No. 1, 749 F.3d at 1008. Rule 11 says nothing about whether plea
+negotiation materials that lead to a guilty plea should be kept confidential. And, although
+Epstein argues that the correspondence should be "protected from future use by an adversary"
+(DE 295), this Court has already held that Petitioners may make such "use" of that
+correspondence as necessary (DE 188 at 10) against their adversary in this case, the Government.
+Ct. Doe No. 1, 749 F.3d at 1008 ("The victims intend to admit the correspondence to prove
+violations of the Act allegedly committed by the United States, not 'against' Epstein. And even
+if rescission of the non-prosecution agreement abuts Epstein's interests, the purpose of the
+admission does not change. Rule 410 does not bar disclosure of the correspondence written by
+the attorney-intervenors."). The Court rejects these grounds for imposing a confidentiality
+protective order in this case. (DE 295 at 10-12).
+Epstein argues that the Court should shield the correspondence from public disclosure
+because he and his counsel had "and continue to have a reasonable expectation of confidentiality
+in their settlement negotiations with the government." (DE 295 at 12). The Eleventh Circuit
+rejected similar reasoning as it related to Epstein's claim that the correspondence was privileged:
+"Although plea negotiations are vital to the functioning of the criminal justice system, a
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 12 of 16
+prosecutor and target of a criminal investigation do not enjoy a relationship of confidence and
+trust when they negotiate. Their adversarial relationship, unlike the confidential relationship of a
+doctor and patient or attorney and client, warrants no privilege beyond the terms of Rule 410."
+Doe No. 1, 749 F.3d at 1009. The Court finds no support (and Epstein cites none) for the
+proposition that a court must respect a suspect's unilateral expectation that he shared a
+"relationship of confidence and trust" with the prosecutor, where no such relationship existed by
+operation of law. In fact, Rule 410 serves to inform suspects (and their attorneys) that plea
+discussions are subject to admissibility in court (and thus open to the light of day) if they
+ultimately lead to a guilty plea that is not later withdrawn. Because this potential is present in
+every plea negotiation, the Court finds no support in Epstein's purported reasons for keeping
+such discussions confidential after a guilty plea is reached. (DE 295 at 13).
+The Court finds no principled reason—
+-in longstanding tradition or otherwise-for
+holding that plea negotiations that lead to a guilty plea, not withdrawn, are confidential,
+especially where things said in those negotiations are potentially relevant to whether the federally
+protected rights of others were violated. Intervenor Epstein's interest in keeping the
+correspondence confidential is thus entitled to little weight.
+Protection Against Abusive Filings
+Intervenor Epstein argues that a preemptive seal is necessary to prevent a wholesale
+"dump" of irrelevant documents into the file, which are offered for no purpose but to further
+sensationalize this case.? (DE 295 at 1-4; 14-15). The Court is cognizant of this concern. Even
+3 The document that Epstein argues exemplifies this concern was previously stricken
+from the record. (DE 324 at 10 (striking DE 293)).
+12
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 13 of 16
+so, the Court does not find that it is necessary to place a preemptive seal on the filing of every
+piece of correspondence that may be pertinent to a matter fairly presented for judicial resolution
+by this Court.
+The Court finds that the parties are in the best position to police their conduct—as
+officers of the Court with sworn professional responsibilities —when it comes to placing material
+in the public record. Every written submission and filing must be submitted for a proper
+purpose, see Fed. R. Civ. P. 11(b)(1), such as materially advancing judicial resolution of an issue
+that is pertinent to this litigation. Relevancy is a broad term; however, it is not without its clearly
+acceptable limitations. Relevant evidence must, for instance, advance the determination of a
+"fact of consequence" in the action. Fed. R. Evid. 401(b). As the Court views it-and
+Petitioners* and the Media' seem to agree the facts of consequence that most clearly relate to
+this action and which therefore have the most support for being made a part of the public
+record—are those statements in the plea negotiations that relate to the rights of the victims, i.e..
+the Government's knowledge, and alleged disregard, of the rights which it owed the victims
+under the CVRA. Parts of the correspondence that relate to the victims' rights in this regard, or
+that raise inferences that the Government had known obligations and disregarded them, are most
+appropriate for public filing as they lead to judicial resolution of this central issue.
+* Petitioners contend that the correspondence may show "that (for example) the defense
+attorneys pushed prosecutors to agree to a confidentiality provision that illegally kept the nonprosecution agreement secret from the victims ...." (DE 298 at 6) (emphasis added).
+" The Media contends that the correspondence "will be relevant to the central issue in the
+-whether the Plaintiffs were afforded their rights under the Crime Victims' Rights Act
+…..." (DE 305 at 2) (emphasis added).
+13
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 14 of 16
+Undoubtedly, the amount of correspondence now made available to Petitioners" contains
+reams of documents that—while interesting on some level—bear no arguable pertinence to any
+issue necessary for judicial resolution of this case. No judicial purpose will be served by placing
+such documents into the court record; therefore, doing so should be avoided. Also, documents
+that may be pertinent by the line, paragraph, or page, may not be pertinent by the entire multipage document, file-folder, or box-full. The pertinent portions —and portions that are in good
+faith necessary for context-
+- should be submitted, and the rest omitted from public filings.
+Wholesale dumps of multi-page documents for the purpose of supporting brief quotations should
+be avoided.
+Counsel
+-as officers of the Court with sworn professional responsibilities—are
+circumscribed by several principles (including those espoused by the Court above) regarding
+what documents should appropriately be made part of the public record. Counsel must not
+present any document, or fail to remove unnecessary portions of a document, "for any improper
+purpose, such as to harass, cause unnecessary delay, or needlessly increase the cost of litigation."
+Fed. R. Civ. P. 11(b)(1). Prior to filing certain motions, counsel is required to confer "with all
+parties or non-parties who may be affected by the relief sought in the motion in a good faith
+effort to resolve by agreement the issues to be raised in the motion." S.D. Fla. Local R. 7.1(a)(3)
+(emphasis added). At this required conferral, counsel should discuss what documents or what
+• The victims report that they "have now obtained the full text of correspondence
+between the defense attorneys and prosecutors." (DE 298 at 6). Nothing within this Order
+should be construed as a ruling regarding the disclosure of documents that are subject to a claim
+of privilege that has yet to be decided by this Court.
+14
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 15 of 16
+portions or documents-
+- are necessary to support the proposed motion.? Dispositive motions are
+not subject to this required conferral; however, counsel should be aware that filings either in
+support or defense of motions for summary judgment should relate to the "material facts" of the
+case. Fed. R. Civ. P. 56(a).
+The Court stands ready to police the filings in this case as well. The parties and
+intervenor may move to sanction or to strike, should they have a good faith basis for believing
+that another party has engaged in abusive filing. And, as the parties are aware, the Court may
+strike on its own "any redundant, immaterial, impertinent, or scandalous matter" from the record.
+(DE 324 at 4) (citing Fed. R. Civ. P. 12(f)). The Court finds that these remedies are sufficient to
+address the potential for abuse that Intervenor Epstein envisions. See F.T.C. v. AbbVie Prods.
+LLC, 713 F.3d 54, 64 (11th Cir. 2013) (noting that Rules 11 and 12(f) may be sufficient
+protections from abusive filings in appropriate cases). The parties should conduct themselves
+accordingly.
+Ill. Conclusion
+In sum, the Court finds that Intervenor Epstein has not demonstrated that good cause
+exists for imposing a supplemental, expanded protective order preemptively sealing the public
+filing of any and all correspondence in this case. The interest in public disclosure outweighs
+Epstein's interest in shielding the non-privileged correspondence from public view. Other
+remedies may prove effective in preventing abusive filings in this case. The Court denies
+Epstein's request for a stay of this order pending appeal. (DE 295 at 16). However, the Court
+" This should not be read as a requirement that counsel must certify whether there is
+agreement regarding what documents may be submitted, or as a grounds for a party or intervenor
+to object to the submission before the motion is filed
+15
+
+
+Case 9:08-cv-80736-KAM Document 326 Entered on FLSD Docket 04/15/2015 Page 16 of 16
+will temporarily stay its ruling giving Epstein time to seek a stay from the Court of Appeals,
+should an interlocutory appeal issue.
+Accordingly, it is hereby ORDERED AND ADJUDGED as follows:
+Intervenor Epstein's Unopposed Motion for a Supplement Protective Order (DE
+261) is DENIED; his request for a stay pending appeal (DE 295 at 16) is also
+DENIED.
+The effect of this Order is temporarily STAYED up to and including Monday,
+April 27, 2015, in order to permit Intervenor Epstein an opportunity to renew his
+request for a stay before the Eleventh Circuit Court of Appeals. If Epstein applies
+for a stay in the Court of Appeals on or before April 27, 2015, the temporary stay
+imposed by this Order shall remain in effect pending the Eleventh Circuit's
+disposition of the application for a stay.
+The Media's Motion to Intervene to Oppose Intervenor Epstein's Motion for
+Entry of a Supplemental Protective Order (DE 305) is GRANTED.
+DONE AND ORDERED in
+at West Palm Beach, Palm Beach County,
+Florida, this 15" day of April, 2015.
+KENNETH A. MARRA
+United States District Judge
+16
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@@ -0,0 +1,226 @@
+FILED
+February 04, 2022 09:45 AM
+SI-2021-RV-00005
+TAMARA CHARLES
+CLERK OF THE COURT
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+AND ST. JOHN
+-
+CASE NO: ST-2021-RV-00005
+Originating Case No: ST-2019-PB-00080
+Deceased.
+)
+Cite as 2022 VI Super ISU
+MEMORANDUM OPINION
+91 Pending before the Court is a Notice of Appeal & Petition for Review filed by the Government of
+the Virgin Islands on March 17, 2021. The Appellant, the Government of the Virgin Islands (hereinafter
+"VI Government"), appeals two Magistrate Orders, both entered on February 26, 2021, which (1) denied
+the Government's Motion to Intervene in the probate action as a claimant against the Estate (entered nunc
+pro tune to February 4, 2020) and (2) struck the Government's Emergency Motion to Freeze All Estate
+Assets and Cash on Hand. For the following reasons, the Magistrate's Orders will be affirmed.
+FACTUAL AND PROCEDURAL HISTORY
+12 On August 10, 2019, Jeffrey Epstein was found dead, while in custody in New York for sex crimes
+and on August 15, 2019, the probate of the Estate of Jeffrey Epstein was created. To "establish an
+independent and voluntary claims resolution program...for purposes of resolving sexual abuse claims
+against Jeffrey E. Epstein," the Executors of the Estate filed an Expedited Motion for Establishment of a
+Voluntary Claims Resolution Program (hereinafter called the Epstein Fund).
+93 On January 15, 2020, the VI Government filed a lawsuit against the Epstein Estate, the 1953 Trust,
+and numerous Epstein business affiliates and associates for violation of the Criminally Influenced and
+Corrupt Organization Act (CICO)', and for civil conspiracy seeking forfeiture and divestment of assets in
+favor of the VI Government, civil penalties, damages, and other remedies.?
+14
+On January 23, 2020, the VI Government filed a Motion to Intervene in the probate matter pursuant
+to Rule 24 of the Virgin Islands Rules of Civil Procedure. Thereafter, on February 4, 2021, the VI
+Government filed an Emergency Motion to Immediately Freeze All Assets and Cash on Hand. The VI
+' 14 V.I.C. § 600 et seg.
+" See VI Government's Notice of Appeal.
+
+
+Memorandum Opinion
+Page 2
+2022 VI Super 15U
+Government asserted that the Emergency Motion was necessary due to the Estate having breached its
+commitment to fund the Epstein Victims Compensation Program.
+95 A hearing on the VI Government's motions was held February 4, 2020, after which the Court
+orally denied the Motion to Intervene without prejudice as well as the Emergency Motion to Immediately
+Freeze All Assets and Cash on Hand reasoning that because the Government is not a party to this action
+and is not permitted to intervene, the Government does not have standing to move the Court to freeze the
+assets and all its cash on hand. Consistent with the Court's ruling that the Government lacked standing,
+the Court issued an Order on February 26, 2021, striking the Government's Emergency Motion and all
+responses thereto from the record. *
+96 In response thereto, the Government filed this Appeal and Petition for Review of Magistrate
+Judge's Orders on March 17, 2021. In the Petition, the Government asserts that the "Probate Court's ruling
+not only fails to recognize the Government's interest, which supports mandatory or permissive
+intervention, but also ignores the complexity of this proceeding and its significance to Epstein's victims
+and to the people of the Virgin Islands more broadly."
+97 On March 29, 2021, the Co-Executors of the Epstein Estate filed the Co-Executors' Response to
+Government of the United States Virgin Islands' Notice of Appeal & Petition for Review of Magistrate
+Judge's Orders. In their response, the co-executors argued that (1) the Government's appeal is untimely,
+(2) that the Government's failure to state a claim further substantiates their lack of standing, and (3) that
+the Government's Motion to Freeze All Estate Assets and Cash on Hand is Moot.
+JURISDICTION
+18 A Superior Court judge has jurisdiction to review judgments and orders issued by Magistrate
+Judges, when they exercise their original jurisdiction as provided for in Title 4 V.I.C. §123(a). See, V.I.
+Super. Ct. Rule 322, et. seq. An order or judgment involving probate is a matter that a Superior Court
+Judge may review if appealed. Title 4 V.I.C. § 123(a)(4).
+99 V.I. Super. Ct. Rule 322(a) provides that final orders or judgments of the Magistrate Division
+resolving completely the merits of the cases which came before them pursuant to their original
+3 A written order was issued on February 26, 2021 (rune pro tunc to February 4, 2020).
+4 A copy of the order was submitted as an Exhibit 2 with the VI Government's Notice of Appeal.
+
+
+Memorandum Opinion
+Page 3
+2022 VI Super 15U
+jurisdiction, as provided by Title 4 V.I.C. § 123(a), are immediately appealable to judges of the Superior
+Court of the Virgin Islands, as well as any interlocutory orders appealable by law.
+910 V.I.R. Civ. P. Rule 54 (a) defines a judgment as a decree or order from which an appeal lies.
+Where an action has multiple claims of reliefs, including third-party claims, the court may direct entry of
+a final judgment as to one or more, but fewer than all, claims or parties if the court expressly determines
+that there is no just reason for delay.
+911 In the February 26, 2021 Order the Court determined that because the VI Government is not a
+party, it lacks standing to move the Court in the present action. Therefore, the Court struck the VI
+Government's Motion to freeze assets and all responses thereto. The determination that the VI
+Government is not a party to the action was made due to the VI Government's failure to intervene as a
+claimant as required by the probate rules. However, the Motion to Intervene was denied without prejudice
+which allowed for the VI Government's error to be corrected and calls into question whether this is a final
+judgment with respect to the VI Government. Further, there was no recitation made by the Court that
+"expressly determines" that there is no just reason for delay. As such, this is not a final judgment eligible
+for appeal.
+912 Title 4 V.I.C. §123(c) states that a judge of the Superior Court may consider any pretrial matter
+handled by the magistrate judge where it has been shown that the magistrate judge's order is clearly
+erroneous or contrary to law. This Court has determined that the magistrate judge's order is not clearly
+erroneous or contrary to law for the foregoing reasons.
+ISSUES RAISED FOR APPEAL BY THE VI GOVERNMENT
+1. Whether the Magistrate Judge properly denied the Government's Motion to Intervene as a claimant
+against the Estate of Jeffrey E. Epstein.
+2. Whether the Magistrate Judge properly denied the Government's Emergency Motion to Freeze All
+Estate Assets and Cash on Hand.
+ANALYSIS
+1. Whether the Magistrate Judge properly denied the Government's Motion to Intervene as a
+claimant against the Estate of Jeffrey E. Epstein.
+5 V.I.R. Civ.P. Rule 54 (b)
+
+
+Memorandum Opinion
+Page 4
+2022 VI Super 15U
+913 In its appeal, the VI Government asserts that "as Plaintiff in the CICO action against the Epstein
+estate and other Epstein businesses, that it has an interest in the assets of the Estate, as well as an interest
+in ensuring that the laws of the Virgin Islands are enforced for the benefit of the VI Government, the
+People of the Virgin Islands and the victims of Epstein crimes."* According to the VI Government the
+Motion to Intervene was filed to ensure that it was adequately represented in the probate matter, but was
+denied stating that the VI Government should enter as a claimant rather than as an intervenor.
+14 In the Co-Executors' Opposition to Government's Motion to Intervene filed on January 31, 2020,
+the Co-Executors assert that it is the Virgin Islands Code and the Virgin Islands Rules for Probate and
+Fiduciary Proceedings (the "Probate Rules") that set forth the specific steps a purported claimant must
+take to bring a claim against an estate and participate in a probate proceeding. Rule 24 has no application
+to this proceeding."?
+915 At the February 4, 2020 hearing, the VI Government was advised by the Magistrate Judge that it
+should enter the proceedings as a claimant as required by Probate Rules. Case law has repeatedly
+established that "when two statutes cover the same situation, the more specific statute takes precedence
+over the more general one...
+398
+916
+In this case, the Magistrate Judge was correct in advising the VI Government to enter as a claimant
+and denying its Rule 24 Motion to Intervene, as the Probate rules are specifically created to address probate
+proceedings as stated in V.I. R. Prob. Rule 1°
+917 Under the Title 15 V.I.C. § 391, all persons having claims against the estate are required to present
+their claims within six months from the date of notice of administration. The VI Government was given
+the opportunity to enter as a claimant, after being so directed at the February 4, 2020 hearing, but failed
+to do so. However, this Court notes that the VI Government is still able to enter as a claimant under Title
+15 V.I.C. § 392 which states in pertinent part that:
+... A claim not presented within six months after the first publication of the notice is not barred,
+but it shall not be paid until the claims presented within that period have been satisfied, and if the
+• See Government of the United Stated Virgin Islands' Notice of Appeal & Petition for Review of Magistrate Judge's Orders filed by
+VI Government on March 17, 2021.
+" See Co-Executors' Opposition to Government's Motion to Intervene filed on January 31, 2020.
+" Edmond v. U.S., 520 U.S. 651, 657, 117 S. Ct. 1573, 1578, 137 L. Ed. 2d 917 (1997))
+" These Virgin Islands Rules for Probate and Fiduciary Proceedings shall apply in probate, guardianship, trust and other fiduciary
+
+
+Memorandum Opinion
+Page 5
+2022 VI Super 15U
+claim is not then due, or if contingent, it shall nevertheless be presented as any other claim. Until the
+administration has been completed, a claim against the estate not barred by the statute of limitations
+may be presented, allowed, and paid out of any assets then in the hands of the executor or
+administrator not otherwise appropriated or liable.
+918 In this instance, the VI Government's failure to enter the probate matter as a claimant within six
+months of the executors' publicized notice of administrations, does not bar it from being able to move
+forward as a claimant in the correct manner as provided by the Rules of Probate. The VI Government
+was directed of the appropriate method to adequately represent its interest by the Magistrate Judge who
+regularly presides over probate proceedings. ' Yet, it inexplicably failed to abide by the guidance which
+was intended to achieve the original purpose of the motions.
+919 The notorious nature and history of the deceased individual in this probate matter coupled with its
+main-stream attention, is not an indication that the case should be treated differently from any other
+probate case.
+2. Whether the Magistrate Judge properly denied the Government's Emergency Motion to Freeze
+All Estate Assets and Cash on Hand.
+920 The Magistrate Judge properly denied the VI Government's Emergency Motion to Freeze All
+Estate Assets and Cash on Hand because the VI Government failed to established standing as a claimant
+as noted above. Failure to take the necessary steps to enter the case as a claimant, prevented the VI
+Government from securing the necessary standing to freeze the assets of the Estate. It would have been
+inappropriate for the Magistrate Judge to grant the Government's Emergency Motion to freeze all assets
+when the VI Government failed to follow the required procedures as set forth in Title 15 V.I.C §§ 391-
+394 and the relevant probate rules.
+CONCLUSION
+922 The premises considered, the Magistrate's Orders entered on February 26, 2021 (nune pro tune to
+February 4, 2020), denying the Government's Motion to Intervene in the Probate action and striking the
+Government's Emergency Motion to Freeze All Estate Assets and Cash on Hand, are AFFIRMED.
+о *Each magistrate judge may: (4) hear all non-felony traffic offenses, litter cases, misdemeanor criminal cases where the maximun
+unishment is limited to not more than 364 days imprisonment; arraignment and probable cause hearings in any criminal or traffic
+offense matter; small claims cases and probate matters" Title 4 V.I.C. 123(a).
+
+
+Memorandum Opinion
+Page 6
+2022 VI Super 15U
+An Order consistent with this Opinion shall follow.
+DATED: February,
+04.2022
+Delu/Wally
+DEBRA S. WATLINGTON
+Judge of the Superior Court
+of the Virgin Islands
+ATTEST:
+Tamara Charles
+Clerk ofthe Court
+By:
+OlMmant
+Brenda Monsanto
+Court Clerk Supervisor 2: 212022
+
+
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+AND ST. JOHN
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+CASE NO: ST-2021-RV-00005
+Originating Case No: ST-2019-PB-00080
+Deceased.
+ORDER
+Consistent with the Memorandum Opinion of even date, it is hereby
+ORDERED that the two Magistrate Orders entered on February 26, 2021 (Nunc pro tunc to February 4,
+2020) and February 26, 2021 are AFFIRMED; and it is further
+ORDERED that Petitioner's Appeal is DISMISSED WITH PREJUDICE; and it is further
+ORDERED that a copy of this Order and the accompanying Opinion shall be directed to Chief Deputy
+Attorney General, Carol
+Esq.; and
+Kroblin, Esq.
+DATED: February
+04
+_ 2022
+Una/ Walle
+DEBRA'S. WATLINGTON
+Judge of the Superior Court
+of the Virgin Islands
+ATTEST:
+Tamara Charles
+millwant
+Brenda Mofsanto
+Court Clerk Supervisor 2 1 2 2002
\ No newline at end of file
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diff --git a/vision-fixhub/court-02/058a57f5ba2ea5791305f21e6e7ceaf5f9fe61c1f6d96d9cfcd5e32a2cc9ecc9.md b/vision-fixhub/court-02/058a57f5ba2ea5791305f21e6e7ceaf5f9fe61c1f6d96d9cfcd5e32a2cc9ecc9.md
new file mode 100644
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@@ -0,0 +1,164 @@
+•
+IN THE CIRCUIT COURT OF THE 15" JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION AG
+CASE NO. 502009CA040800XXXXMB
+Judge David F. L
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiffs.
+CIRCUIT CIVIL
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+SHARON R. BOCK. CL
+FILED
+MOTION FOR ENLARGEMENT OF TIME TO COMPLY WITH COURTE
+DECEMBER 21, 2011 ORDER ON OBJECTIONS TO DISCOVERY REQUESTS
+Plaintiff/Counter-Defendant JEFFREY EP
+("Epstein"), by and through undersigned
+counsel and pursuant to the Florida Rules of Civil Procedure, hereby moves for an enlargement of
+time to respond to this Court's December 21, 2011 Order on Epstein's Objections to
+J.
+Request to Produce Dated 10/28/11. The grounds for this Motion are as follows:
+At a hearing on this matter held on December 21, 2011, this Court considered the
+objections of Epstein to Defendant/Counter-Plaintiff
+Request to Produce Dated 10/28/11.
+The Court overruled the objections except as to privilege and directed the Plaintiff to
+file a complete response within 20 days, together with a privilege log. A copy of the Order is attached
+hereto as Exhibit 1.
+3.
+Counsel for Plaintiff certifies that his office did not receive this Order until the
+afternoon of January 6, 2011, thereby giving him less than 3 business days to comply with the Order.
+
+
+Epstein v. Rothstein and
+Case No. 502009CA040800XXXXMB/Division AG
+For the foregoing reasons, Plaintiff requests an extension of seventeen (17) days, up to
+and including January 23, 2012, within which to comply with the Court's Order.
+The Defendant/Counter-Plaintiff will not sustain any prejudice as a result of a short
+extension being granted to Plaintiff to serve his privilege log and respond to these discovery requests.
+5.
+Undersigned counsel certifies that this request is made in good faith and not for the
+purpose of delay. The undersigned counsel further certifies that he has and will continue to make an
+effort to resolve this matter without the need of a hearing.
+WHEREFORE, the Plaintiff/Counter-Defendant Jeffrey Epstein respectfully requests that this
+Court grant an extension of seventeen (17) days, up to and including January 23, 2012, in which to
+comply with the Court's Order.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail on
+this 10" day of January, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach
+Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger
+& Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; and
+Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort
+Lauderdale, FL 33301.
+Respectfully submitted,
+(Joseph L. Ackerfan, Ji
+Florida Bar No. 235954
+BURNETT, P.A.
+- 2-
+
+
+Epstein v. Rothstein and
+Case No. 502009CA040800XXXXMB/Division AG
+901
+BURNETT, P.A.
+Point West
+177 South Flagler Drive
+Nest Palm Beach, Florida 33401
+Telephone: (561) 802-9044
+Facsimile: (561) 802-9976
+Attorneys for Plaintiff, Jeffrey Epstein
+and
+E. Knight
+Florida Bar. No. 607363
+BURNETT, P.A.
+Espirito Santo Plaza, 14th Floor
+1395 Brickell Avenue
+Miami, Florida 33131
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Attorneys for Plaintiff, Jeffrey Epstein
+NOT A CERTI
+- 3 -
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+COPY
+Defendants).
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+OBJECTIONS TO
+REQUEST TO PRODUCE DATED 10/28/11
+THIS CAUSE having come to be considered upon the Objections of Plaintiff/Counter-
+Defendant, JEFFREY EPSTEIN'S objections to the Request to Produce served by
+Defendant/Counter-Plaintiff,
+J.
+and the Court having reviewed the file
+and being fully advised in the premises, it is hereby,
+ORDERED and ADJUDGED:
+The objectims one overnalid
+exceptanto privile. The Plantift shall file
+DONE AND ORDERED at West Palm Beach, Palm Beachi County, Florida, this 215
+day of_
+Dec. 2011.
+Haunter
+DAVID I
+F.
+CIRCUIT JUDGE
+Copies have been furnished to all counsel on the attached counsel list.
+a complete respase vithin to dia tester a t
+a privelge log.
+1
+
+
+adv. Epsteln
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Alterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos &
+Ackerman, Jr., Esquire
+Burnett, P.A.
+901
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561)-802-9044
+Fax: (561)-802-9976
+Attorneys for Jeffrey Epstein
+Mare S. Nurik, Esquire
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Jack Scarola, Esquire
+Searcy Denney Scaróla Barnhart & Shipley
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Phone: 561-686-6300
+Fax:
+561-383-9451
+Attorneys for
+NOT
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diff --git a/vision-fixhub/court-02/058bd0ffb97dcc907f63aaa782fb19377a03544621a1b040c53e27a91c64e7a5.md b/vision-fixhub/court-02/058bd0ffb97dcc907f63aaa782fb19377a03544621a1b040c53e27a91c64e7a5.md
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@@ -0,0 +1,649 @@
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 1 of 23
+GOVERNMENT
+
+A
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 2 of 23
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE 1 AND JANE DOE 2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+GOVERNMENT'S RESPONSE TO PETITIONERS' STATEMENT OF UNDISPUTED
+MATERIAL FACTS IN SUPPORT OF PETITIONERS' MOTION FOR
+PARTIAL SUMMARY JUDGMENT
+Respondent United States of America, by and through its undersigned counsel, files its
+Response to Petitioners' Statement of Undisputed Material Facts, and states:
+1. Admitted.'
+2. Admitted.
+3. Admitted.
+4. The first sentence of paragraph 4 is admitted. As to the second sentence, respondent
+admits only that the Palm Beach Police Department ("PBPD") conducted an investigation, and
+ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually
+abused by Epstein. The characterizations of the PBPD's investigation as "capably conducted"
+and "thorough" do not appear in the documents cited by Petitioners and are opinions of
+Petitioners' counsel, not facts.
+Statement or temps emied iy fact ten be through out this Response to Sectioners"
+purposes of petitioners' motion for partial summary judgment.
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 3 of 23
+5. Admitted.
+6. The first sentence in paragraph 6 is admitted in part. The FBI determined that Jane
+Doe 1 had been sexually abused by Epstein while she was a minor, and Jane Doe 1 provided
+information to the FBI regarding her sexual abuse on August 7, 2007. As to Jane Doe 2, the FBI
+determined she had been sexually abused by Epstein while she was a minor, although Jane Doe 2
+was openly hostile to the prosecution of Epstein, contended that no crime had been committed by
+Epstein, and declined to be interviewed by the FBI unless she was granted use immunity. See
+6/2/2017 Villafaña Decl. at T9l 6-12. The second sentence in paragraph 6 also is admitted in part.
+During her August 7, 2007 interview with the FBI, Jane Doe 1 provided detailed information
+about her own abuse. However, Jane Doe I's information about Jane Doe 2 was only that Jane
+Doe 2 "started providing Epstein with massages"; Jane Doe 1 did not provide "detailed
+information about ... the abuse of Jane Doe 2." DE361-32 at p. 5.?
+7. The Government admits the first three sentences in paragraph 7. The fourth sentence
+is denied because the August 11, 2006 letter was sent to Jane Doe 2 because she had been
+identified as a potential victim, not because there had yet been a Government determination that
+she was in fact a victim of a federal offense or came under the protection of the CVRA, 6/2/2017
+Villafaña Decl. at 9l 5, and because that fourth sentence presents an opinion and conclusion, not
+an assertion of fact.
+8. Admitted.
+9. The Government admits that from January 2007 through September 2007, discussions
+2 To refer to exhibits to "Jane Doe 1 and Jane Doe 2's Consolidated Statement of
+Undisputed Material Facts and Motion for Partial Summary Judgment with Incorporated
+Memorandum of Law" (DE361), the government uses the CM-ECF headers that appear on the
+documents. Hence, "DE361-32 at p. 5" refers to the fifth page of Exhibit 32 to DE361.
+2
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 4 of 23
+to resolve the federal investigation took place between the U.S. Attorney's Office for the
+Southern District of Florida and Jeffrey Epstein, through the numerous attorneys who
+represented him. Not all of these discussions were "plea discussions" because Epstein was never
+charged with a federal offense. See 6/2/2017 Villafaña Decl. at 9i9l 4, 17-18, 23, 29.
+10. The Government admits the first sentence of paragraph 10. The second and third
+sentences are denied because they are opinions and conclusions, not assertions of fact.
+11. Admitted.
+12. Admitted.
+13. Admitted.
+14. The first sentence in paragraph 14 is denied because Jane Doe 1 was furnished with a
+victim notification letter on or about June 7, 2007, because Jane Doe 1 had been identified as a
+potential victim, not because there had yet been a Government determination that she was in fact
+a victim of a federal offense or came under the protection of the CVRA, 6/2/2017 Villafaña Decl.
+at 9| 5, and because that first sentence is an opinion and conclusion, not an assertion of fact. The
+second sentence is admitted.
+15. The first sentence in paragraph 15 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact.
+16. Admitted.
+17. The government admits the first sentence of paragraph 17. The second sentence is
+disputed because it is an opinion, not an assertion of fact.
+18. The Government denies that no Government representatives had conferred with
+victims regarding their views on the potential negotiated outcome of the investigation. See 2d
+Kuyrkendall Decl. at M 5, 12, 13; 6/2/2017 Villafaña Decl. at 9 10, 12, 19. Otherwise admitted.
+3
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 5 of 23
+19. Admitted.
+20. Admitted.
+21. Admitted.
+22. Admitted.
+23. Admitted.
+24. The Government denies that the Office sought to "contrive to establish jurisdiction
+away from the location where the crimes actually occurred-—and away from where the victims
+actually lived—so as to avoid the public finding out about anything." See 6/2/2017 Villafaña
+Decl. at 9 24. Otherwise admitted.
+25. Admitted.
+26. Denied. See 6/2/2017 Villafaña Decl. at 9| 27.
+27. Admitted.
+28. Admitted.
+29. The first sentence is admitted. The second sentence is disputed, as the government
+has produced emails sent to and from the home e-mail address of one of its prosecutors. See
+6/2/2017 Villafaña Decl. at 9| 28.
+30. Admitted.
+31. Admitted.
+32. Admitted
+33. The first sentence in paragraph 33 is admitted. The second sentence is disputed,
+because the Government had notified victims that the matter was under investigation and the
+matter indeed remained under investigation until Epstein entered his state court guilty pleas, see
+6/2/2017 Villafaña Decl. at 9| 35; 2d Kuyrkendall Decl. at 99l 10-11, and because it is a legal
+4
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 6 of 23
+argument, not an assertion of fact. Petitioners also have not cited any evidence to support the
+allegations that "Epstein's counsel, the U.S. Attorney's Office, and the State of Florida were
+conferring daily."
+34. The first sentence in paragraph 34 is admitted. The Government disputes that the
+agreement would bind the victims or that the NPA in fact binds the victims. DE361-62. The
+remainder of the second sentence is admitted, with the qualification that the Government denies
+that the Government did not confer with any victims about possible resolution of the
+investigation, that potentially included the non-prosecution of Epstein; for example, Jane Doe 2
+specifically told the Government that she did not want Epstein to be prosecuted. See 2d
+Kuyrkendall Decl. at 19l 5, 12, 13; 6/2/2017 Villafaña Decl. at T9 10, 12, 19.
+35. The government admits paragraph 35 but notes that the quoted language does not
+appear in Exhibit 4; it appears at DE361-5.
+36. The government admits paragraph 36 but notes that Exhibit 2 is not an email to
+Humberto Ocariz; the referenced email appears at DE361-3. The second sentence of paragraph
+36 is admitted.
+37. Admitted.
+38. The Government admits that on September 24, 2007, Epstein and the U.S. Attorney's
+Office reached a formal non-prosecution agreement, embodied in the NPA, DE361-62, whereby
+the United States would defer federal prosecution in favor of a state prosecution. The
+Government otherwise disputes the petitioners' characterization of the NPA and its legal impact
+as opinion and conclusion, not an assertion of fact. •
+39. The Government admits that the NPA provided that, upon its execution, "the United
+States, in consultation with and subject to the good faith approval of Epstein's counsel, shall
+5
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 7 of 23
+select an attorney representative for [the victims listed by the U.S. Attorney's Office in
+accordance with the NPA], who shall be paid for by Epstein" and that if any of those listed
+victims "elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida over his person and/or the
+subject matter, and Epstein waives his right to contest liability and also waives his right to
+contest damages up to an amount as agreed to between the identified individual and Epstein, so
+long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees
+to waive any other claim for damages, whether pursuant to state, federal, or common law," but
+the Government otherwise denies the petitioners' characterizations of the agreement's terms.
+DE361-62 at 9l 7-8. The Government admits that these provisions were drafted without the
+knowledge or consent of the victims, but denies that the victims did not have an opportunity to
+reasonably confer about how the Epstein investigation could be resolved, and thus, were not
+denied an opportunity to reasonably confer about the matters addressed in those provisions of the
+NPA. 6/2/2017 Villafaña Decl. at 9l 5, 8, 13.
+40. Admitted.
+41. Admitted, except that the Government denies that the NPA "provided that it was
+confidential." DE361-62.
+42. Admitted, with the qualification that the Government denies that the Government did
+not confer with any victims about possible resolution of the investigation, that potentially
+included the non-prosecution of Epstein; for example, Jane Doe 2 specifically told the
+Government that she did not want Epstein to be prosecuted. See 2d Kuyrkendall Decl. at T9l 5,
+12, 13; 6/2/2017 Villafaña Decl. at 19l 10, 12, 19.
+43. Admitted.
+6
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 8 of 23
+44. Admitted.
+45. Admitted, with the qualification that the Government denies that the Government did
+not confer with any victims about the possible resolution of the investigation, that potentially
+included the non-prosecution of Epstein; for example, Jane Doe 2 specifically told the
+Government that she did not want Epstein to be prosecuted. See 2d Kuyrkendall Decl. at T9l 5,
+12, 13; 6/2/2017 Villafaña Decl. at 19l 10, 12, 19.
+46. Admitted.
+47. Denied. AUSA Villafana met with Jane Doe 1 and Jane Doe 2 and most of the other
+victims when their identities became known. She told them, in written correspondence and
+orally, that she was available for consultation if they wanted to discuss any aspect of the case.
+6/2/2017 Villafaña Decl. at 9I 5, 31.
+48. Admitted.
+49. Admitted.
+50. Admitted.
+51. The first sentence in paragraph 51 is admitted. The second sentence is denied
+because it is an opinion, not an assertion of fact, but the Government admits that the statement
+appears in DE361-68
+52. Admitted, except that the Government denies that the email stated that the
+Government and Epstein's counsel "would negotiate privately.".
+53. Admitted.
+54. The Government admits that paragraph 54 accurately quotes from an email dated
+September 25, 2007 from AUSA |
+_ Villafaña to Jay Lefkowitz, but denies that the email
+"tried] to set up an arrangement whereby Epstein's victims would not be represented by various
+7
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 9 of 23
+private attorneys, and ... arguled] instead for an attorney in Miami who could help keep things
+concealed." See 6/2/2017 Villafaña Decl. at 9| 24.
+55. Admitted.
+56. Admitted, except that the Government denies that the referenced attorney was an
+"attorney appointed by the Office to represent the victims - without the knowledge of the
+victims." The Government enlisted the Hon. Edward B.
+to serve as a Special
+to
+assist the U.S. Attorney's Office in selecting an attorney representative, see DE362-9, and Judge
+selected Robert Josefsberg from the Podhurst Orseck firm, not the attorney referenced in
+paragraph 56. See DE362-12.
+57. Admitted.
+58. Admitted, except that the Government denies that the attorney raising concerns was
+selected by the Government, or paid by Epstein. See I| 56, supra.
+59. The first sentence in paragraph 59 is admitted. The second sentence is denied. See
+6/2/2017 Villafaña Decl. at 9| 38.
+60. Admitted.
+61. Admitted. (citation is incorrect).
+62. Denied. The Thursday, October 18, 2007 email from Mr. Lefkowitz expresses
+thanks to U.S. Attorney Acosta for meeting on Friday.
+63. Admitted.
+64. Admitted.
+65. Admitted.
+66. The government admits that the NPA contained the following language: "The
+parties anticipate that this agreement will not be made part of any public record. If the United
+8
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 10 of
+States receives a Freedom of Information Act request or any compulsory process commanding
+the disclosure of the agreement, it will provide notice to Epstein before making that disclosure."
+DE361-62 at 9l 13. The government further admits that, in the past, it has described that
+provision as an express confidentiality provision.
+67. Denied. See DE 361-62. Paragraph 67 is a legal argument, not an assertion of fact.
+See also 6/2/2017 Villafaña Decl. at 1 30.
+68. Denied. See DE 361-62. Paragraph 68 is a legal argument and opinion, not an
+assertion of fact. See also 6/2/2017 Villafaña Decl. at 9| 30.
+69. Denied. See 6/2/2017 Villafaña Decl. at 19l 21, 32-34; 2d Kurykendall Decl. at 1 9.
+Paragraph 69 is an opinion, not an assertion of fact.
+70. The first and second sentences of paragraph 70 are admitted. With regard to the third
+sentence, the Government admits that the Special Agents told Jane Doe 1, among other things,
+that Epstein would plead guilty to state charges, he would be required to register as a sex
+offender for life, and he made certain concessions related to the payment of damages. The
+Government denies that Agents told Jane Doe 1 that the state charges "involve[ed] another
+victim" or that the Special Agents made any statements to that effect "[dJuring this litigation."
+In support of this paragraph, Petitioners cite DE361-26, which is the Declaration of Jane Doe 1,
+not any statement made by any Special Agent during this litigation. See 2d Kuyrkendall Decl. at
+91 8; DE 361-26.
+71. Denied. See 2d Kuyrkendall Decl. at 9| 8.
+72. Denied. See id. at 99l 7, 8, 13.
+73. Denied. See id.; see also 6/2/2017 Villafaña Decl. at 99l 5, 31.
+74. Denied. See DE361-62. Paragraph 74 is a legal conclusion, not an assertion of fact.
+9
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 11 of
+Moreover, the phrase referenced by petitioners is from I| 13 (page 5 of 7) of the NPA and only
+requires notice to Epstein before making a disclosure under the Freedom of Information Act or
+compulsory process. See DE361-62.
+75. Denied. See 2d Kuyrkendall Decl. at 991 8-11; 6/2/2017 Villafaña Decl. at 9191 34-36.
+76. Admitted, insofar as it addresses the time period before Epstein's entry of his guilty
+plea to state charges.
+77. The first sentence in paragraph 77 is admitted. The second sentence is denied. The
+reason no further notifications to other victims were made at that point, was due to a concern that
+Epstein would breach or otherwise fail to abide by the NPA, and Epstein's attorneys would
+attempt, in any subsequent federal criminal prosecution, to impeach the victims, FBI agents, and
+prosecutors on the basis of the financial incentive created by the NPA. See 2d Kuyrkendall Decl.
+at 99l 8-11; 6/2/2017 Villafaña Decl. at 99 34-36.
+78. Denied. See, e.g., 7/9/2008 Villafaña Decl. (DE14) at 9I 12; 12/22/2008 Villafaña
+Decl. (DE35) at Til 4, 9, 11, 12.
+79. Admitted.
+80. Admitted.
+81. Denied. Exhibit 26 is Jane Doe No. I's affidavit.
+82. The first sentence in paragraph 82 is denied. The government did not inform the
+victims of the NPA, until after Epstein entered his plea, because the Attorney General Guidelines
+For Victim and Witness Assistance (May 2005), provided that CVRA rights did not apply unless
+there was an "offense charged in a Federal court" and because of concerns that, if Epstein failed
+to perform his obligations under the NPA and prosecution of Epstein were to proceed, the
+notifications regarding the NPA would be used to impeach the victims, agents, and the
+10
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 12 of
+prosecutor. See Ex. M; 2d Kuyrkendall Decl. at I 9; 6/2/2017 Villafaña Decl. at T9 21, 34. The
+remainder of paragraph 82 is admitted
+83. Admitted.
+84. Denied. See paragraphs 78 and 82, supra.
+85. Admitted.
+86. The Government denies that the letter referenced in paragraph 86 "recognize[ed] that
+the victims had not yet been afforded any rights." See DE362-18. Otherwise admitted.
+87. The first sentence in paragraph 89 is admitted. The Government additionally admits
+that it held off on sending any victim notification letters in December 2007, but it denies that it
+did so to "complly]" with the request from attorney
+I, and the Government, through the
+FBI, later sent additional victim notification letters in January 2008. 6/2/2017 Villafaña Decl. at
+9191 21, 32-34; 2d Kuyrkendall Decl. at 11 9; Ex. J.
+88. Admitted.
+89. The first sentence in paragraph 89 is admitted, with the qualification that the
+government had stopped notifying victims about the NPA, until after Epstein entered his plea,
+because the Attorney General Guidelines For Victim and Witness Assistance (May 2005),
+provided that CVRA rights did not apply unless there was an "offense charged in a Federal
+court" and because of concerns that, if Epstein failed to perform his obligations under the NPA
+and prosecution of Epstein were to proceed, the notifications regarding the NPA would be used
+to impeach the victims, agents, and the prosecutor. See Ex. M; 2d Kuyrkendall Decl. at 9 9;
+6/2/2017 Villafaña Decl. at Til 21, 34.. The second sentence is denied because it is an opinion
+and conclusion, not an assertion of fact. The third sentence in paragraph 89 is admitted, with the
+qualification that the U.S. Attorney's Office never declined any victim's request to confer.
+11
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 13 of
+6/2/2017 Villataña Decl. at 4| 5.
+90. Admitted.
+91. The first sentence in paragraph 91 is denied because it contains the unsupported
+opinion and conclusion of Jay Lefkowitz (counsel to Epstein), not an assertion of fact. See
+DE362-21. The second sentence is denied because it was Epstein's attorneys, not the United
+States Attorney's Office, who asked the Child Exploitation and Obscenity Section, Department
+of Justice, to review the case. See DE362-16 at 6, 7 (
+Nos. RFP MIA 000505, 000506).
+92. The first sentence of paragraph 92 is admitted. The Government denies that no
+victims were told about the existence of the NPA. Jane Doe 1 and two other victims had been
+informed in October 2007 that a resolution of the case had been reached. See 2d Kuyrkendall
+Decl. at I 8-9. Otherwise admitted.
+93. The Government admits that the referenced letters were sent on January 10, 2008.
+The Government is without knowledge as to the date that the referenced letters were received.
+94. Admitted, with the qualification that there was a single federal investigation, not
+multiple "federal cases." See 6/2/2017 Villafaña Decl. at T9l 4, 20.
+95. The Government admits that letters containing the same information contained in the
+January 10, 2008 letters to Jane Doe 1 and Jane Doe 2 were sent to other persons identified as
+victims of Epstein. The Government denies that the cited pages in Exhibit 63 support that
+factual assertion. The Government also denies that these victims were "similarly situated to Jane
+Doe 1 and Jane Doe 2" because it is an opinion and conclusion, not an assertion of fact, and
+because the interests and circumstances of different victims were different. See, e.g., 6/2/2017
+Villafaña Decl. at 99l 5, 18, 19, 24, 25, 31, 36; 2d Kuyrkendall Decl. at 99l 5, 8, 12, 13.
+96. The government admits only that in January 2008 Jane Doe 1 expressed her view
+12
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 14 of
+that Epstein should be prosecuted, see 6/2/2017 Villafaña Decl. at I| 36; 2d Kuyrkendall Decl. at
+I 13, but otherwise denies the first sentence of paragraph 96. In early January 2008, Jane Doe 2
+was hostile to any prosecution of Epstein, was represented by counsel paid for by Epstein, and
+had spoken of Epstein in the most glowing terms. See 6/2/2017 Villafaña Decl. at 191 6-14, 31.
+The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to
+confer or consult with the FBI or with AUSA Villafaña about the prosecution of Epstein despite
+having been informed of a victim's right to confer and having been provided with contact
+information for Special Agent Kuyrkendall and for AUSA Villafaña. See 6/2/2017 Villafaña
+Decl. at 9| 5; 2d Kuyrkendall Decl. at 99l 6, 7; Exs. 5, 6. The last two sentences in paragraph 96
+are denied because: (a) they are opinions and conclusions, not assertions of fact; (b) the federal
+criminal investigation of Epstein, including the investigation of Epstein's crimes against them,
+remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been
+provided information for contacting AUSA Villafaña if they wanted to confer. See Villafaña
+Decl. at 99l 5, 35-36.
+97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S.
+Attorney's Office. The second attorney who was present was employed by the Child
+Exploitation and Obscenity Section of the U.S. Department of Justice, not the U.S. Attorney's
+Office. Otherwise admitted.
+98. Admitted.
+99. The first sentence in paragraph 99 is admitted to the extent that the Government
+assumes that "Jane Doe 5" refers to an individual with initials S.R. The Government admits that
+the referenced letter made no disclosure about the NPA, but otherwise denies the last two
+sentences in paragraph 99 because they are opinions and conclusions, not assertions of fact and
+13
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 15 of
+because the federal criminal investigation of Epstein, including the investigation of Epstein's
+crimes against them, was on-going in the first half of 2008 in case the NPA was set aside or
+Epstein did not perform his obligations under the NPA. See id. at 99l 35-36.
+100. Admitted to the extent that the Government assumes that "Jane Doe 5" refers to an
+individual with initials S.R. and with the qualification that Jane Doe 1 and two other victims had
+been informed in October 2007 about the NPA. See id. at 99l 32-33; 2d Kuyrkendall Decl. at 99l
+8-9.
+101. The government admits that, in mid-June 2008, Mr.
+contacted the line
+AUSA handling the case to inform her that he represented Jane Doe 1. The government admits
+that, on June 27, 2008, when the line AUSA contacted Mr.
+to inform him of the state
+plea proceeding scheduled for June 30, 2008, Mr.
+informed the line AUSA that he also
+represented Jane Doe 2. See 7/9/2008 Villafaña Decl. (DE14) at 9| 11. The government admits
+that, in mid-June 2008, Mr.
+asked to meet with the line AUSA to provide information
+about Epstein and Jane Doe 1.
+Id. at Il 10. The government further admits that the line
+prosecutor and Mr.
+discussed the possibility of federal charges being filed in the future
+and that the NPA was not mentioned. The government denies the remainder of paragraph 101
+because it contains opinions and conclusions, not assertions of fact. See also 6/2/2017 Villafaña
+Decl. at 9| 37.
+102. The first sentence in paragraph 102 is admitted. The government further admits
+that the line prosecutor did not inform Mr.
+about the NPA, but the second sentence of
+paragraph 102 is otherwise denied because it is an opinion and conclusion, not an assertion of
+fact. See also id. The third sentence in paragraph 102 also is denied. See id.
+103. The government admits that on June 19, 2008, Mr.
+sent an email to the
+14
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 16 of
+line prosecutor requesting to "meet ... and discuss [his] plans." 6/2/2017 Villafaña Decl., Ex.
+11. The government denies the remainder of paragraph 103, including that Mr.
+mentioned more than one client. Id. at 9| 37, Ex. 11.
+104. The first two sentences in paragraph 104 are denied because they are opinions and
+conclusions, not assertions of fact and because on July 3, 2008, Mr.
+did discuss with the
+line prosecutor his concerns regarding how the Epstein investigation had been resolved. Those
+concerns were shared with managers at the U.S. Attorney's Office. See id. at il 39. Mr.
+also did not make it "perfectly clear that his clients wanted to confer with the prosecutor before
+any resolution was reached." Id. at | 37. The last sentence in paragraph 104 is denied. Id.
+105. Admitted.
+106. The first sentence in paragraph 106 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact and because victims, including
+Jane Doe 1, were told about the terms of the NPA, including that the resolution of the federal
+investigation included Epstein's entry of a guilty plea in state court. See 2d Kuyrkendall Decl. at
+91 8; 7/9/2008 Villafaña Decl. (DE14) at I| 12, Exs. 6 &7; 12/22/2008 Villafaña Decl. (DE35) at I
+9,
+107. The first sentence of paragraph 107 is admitted. The second sentence of paragraph
+107 is denied. See 6/2/2017 Villafaña Decl. at 9| 38. The third sentence of paragraph 107 is
+denied because there was no federal plea agreement and the guilty pleas in state court would not
+bring an end to the possibility of federal prosecution under the terms of the NPA. See DE361-
+62.
+108. The Government admits that Jane Doe 1 and Jane Doe 2 did not attend the state
+court plea hearing; paragraph 108 is otherwise denied. See 6/2/2017 Villafaña Decl. at 1 38.
+15
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 17 of
+109. Denied. Paragraph 109 is an opinion and conclusion, not an assertion of fact and
+the plea agreement in state court did not make impossible to prosecute Epstein federally for his
+crimes against Jane Doe 1 and Jane Doe 2. See DE361-62.
+110. Admitted.
+111. The government admits the text of the e-mail cited is accurate. It denies the
+assertion that there were continuing efforts to keep the NPA secret since this is an opinion and
+conclusion, not an assertion of fact.
+112. The first sentence in paragraph 112 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact. See also 2d Kuyrkendall Decl.
+at 91 8-9.
+113. Admitted.
+114. Paragraph 114 is denied because it contains opinions and conclusions, not
+assertions of fact; because Jane Doe 1 had previously been told about the terms of the NPA,
+including that the resolution of the federal investigation included Epstein's entry of a guilty plea
+in state court; and because the state plea did not "block the prosecution of [Jane Doe l's] case."
+See 2d Kuyrkendall Decl. at I 8; 6/2/2017 Villafaña Decl. at 99 37-38; DE361-62
+115. Paragraph 115 is denied because it contains opinions and conclusions, not
+assertions of fact and because the state plea did not "block the prosecution of [Jane Doe 2's]
+case." See 6/2/2017 Villafaña Decl. at 99l 37-38; DE361-62.
+116. Denied. 2d Kuyrkendall Decl. at 99l 8-9.
+117. Paragraph 117 is denied because it is an opinion and conclusion, not an assertion of
+fact.
+118. Admitted.
+16
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 18 of
+119. Paragraph 119 is denied because it is an opinion and conclusion, not an assertion of
+fact. See also 2d Kuyrkendall Decl. at 99l 8-9.
+120. The Government admits that, on July 7, 2008, the line prosecutor corresponded by
+email with Epstein's counsel seeking his signed agreement concerning a notification letter to the
+victims before beginning the distribution of that letter and acknowledging her previous failure to
+include one victim who was still a minor in 2008; paragraph 120 is otherwise denied.
+121. Paragraph 121 is denied. The cited documents are unsworn and do not support the
+assertion that Mr.
+first saw a reference to the NPA on or after July 9, 2008 or that it was
+the first public mention or first disclosure to Mr.
+. See also 2d Kuyrkendall Decl. at 91 8.
+122. Paragraph 122 is denied because it is an opinion and conclusion, not an assertion of
+fact.
+123. Paragraph 123 is denied because it is an opinion, conclusion, and argument, not an
+assertion of fact, and because it is erroneous. See 6/2/2017 Villafaña Decl. at 99l 27, 30.
+124. Paragraph 124 is denied because it is an opinion and conclusion, not an assertion of
+fact. There is no citation to any material supporting this allegation because there is no
+requirement for a state court judge to review a federal non-prosecution agreement and
+"determine whether it was in the public interest."
+125. Paragraph 125 is denied because it is an opinion and conclusion, not an assertion of
+fact, and because it is erroneous. See 6/2/2017 Villafaña Decl. at 19 5, 31, 38; 2d Kuyrkendall
+Decl. at 9 6-9.
+126. The government admits the first sentence of paragraph 126. As to the second
+sentence, the government admits that Jane Doe 1 had not seen the NPA at the time the
+emergency petition was filed, but denies that Jane Doe 1 was unaware of the agreement that had
+17
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 19 of
+been reached between Epstein and the U.S. Attorney's Office. See 2d Kuyrkendall Decl. at 1 8.
+The government denies the third sentence of paragraph 126. There is no citation to any material
+supporting this allegation and the government does not know when Epstein first became aware of
+Jane Doe I's petition.
+127. Admitted.
+128. Admitted.
+129. The government admits that paragraph 129 correctly quotes from DE362-44. The
+government denies that DE362-44 "explain[s] how [the line prosecutor] intended to keep the
+victims from having access to the terms of the NPA." That document actually states that "the
+notification has been slightly modified in order to provide more complete information." DE362-
+44 at p.2.
+130. Admitted to the extent that "Jane Doe 5" refers to an individual with initials S.R.
+131. Admitted.
+132. Admitted.
+133. The government admits that, during the July 11, 2008 hearing, the government
+conceded that all parts of the NPA had been signed by December 2007, but noted that Epstein
+had challenged the NPA and sought further review of the agreement higher up within the
+Department of Justice. See DE361-63 at 14-15. The remainder of paragraph 133 is denied.
+134. Admitted.
+135. The government admits Paragraph 135, with the exception of the term "assured,"
+which reflects an opinion and conclusion not an assertion of fact. DE362-53 informs counsel for
+Epstein of the petitioners' motion and the government's position.
+136. Admitted
+18
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 20 of
+137. Denied. There is no citation to any material supporting this allegation.
+138. Admitted.
+139. Admitted.
+140. Admitted.
+141. Admitted.
+142. Admitted.
+143. Admitted.
+144. Admitted.
+145. Admitted.
+146. Paragraph 146 is denied as to Jane Doe 1, see 2d Kuyrkendall Decl. at 9| 8, and
+admitted as to Jane Doe 2.
+147. Admitted.
+148. Admitted.
+149. Paragraph 149 is denied because it is an opinion and conclusion, not an assertion of
+fact and inaccurately quotes from DE362-66.
+150. Paragraph 150 is denied because there is no citation to any material supporting this
+allegation.
+151. Paragraph 151 is denied because there is no citation to any material supporting this
+allegation. The government admits that DE362-68 is an email from the line prosecutor to the
+State Attorney's Office that references an inquiry from "the Shiny Sheet."
+152. Admitted
+153. Admitted.
+154. Admitted.
+19
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 21 of
+155. The first and second sentences in paragraph 155 are admitted. The remaining
+sentences are denied because they are opinions and conclusions, not assertions of fact.
+156. Paragraph 156 is denied because it is an opinion and conclusion, not an assertion of
+fact, and because it is erroneous. See also 6/2/2017 Villafaña Decl. at 99l 6-13, 15, 19-21, 25, 33-
+34, 38; 2d Kuyrkendall Decl. at 1I 8-9; DE361-62. Furthermore, with regard to
+and
+Jane Doe 5, one had informed the FBI that she did not want to be bothered again about the
+Epstein matter and the other had refused to speak to the government. See Villafaña Decl. at 9 19.
+157. The first sentence in paragraph 157 is admitted but the government notes that
+Epstein's guilty plea did not prevent prosecutions of Epstein for crimes against the victims. See
+DE361-62. The remaining sentences are denied. See 6/2/2017 Villafaña Decl. at 99l 5, 7, 10, 12-
+15, 24-27, 30-31, 36; 2d Kuyrkendall Decl. at T 5-8, 12-13.
+111
+111
+11/
+20
+
+
+Case 9:08-CV-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 22 of
+Respectfully submitted,
+IG. GREENBERG
+ACTING UNITED STATES ATTORNEY
+By: /s/ Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+Fla Bar No. 0936693
+99 N.E. 4* Street, Suite 300
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+| Villafaña
+A.
+Villafaña
+Assistant United States Attorney
+Fla Bar No. 0018255
+500 S. Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Tel: (561) 820-8711: Fax: (561) 820-8777
+E-mail:
+Is/ Eduardo l.l
+Eduardo I.
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9057; Fax: (305) 536-4676
+Email:
+@usdoj.gov
+Attorneys for the Government
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 2, 2017, the foregoing Response to Petitioners'
+Statement of Undisputed Material Facts was filed with the Clerk of the Court and served on counsel
+on the attached service list using CM/ECF.
+Is/ Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+21
+
+
+Case 9:08-cv-80736-KAM Document 401-1 Entered on FLSD Docket 06/02/2017 Page 23 of
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Tel: (954) 524-2820; Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+Tel: (801) 585-5202; Fax: (801) 585-6833
+E-mail: casselp.@law.utah.edu
+Attorneys for Jane Doe 1 and Jane Doe 2
+SERVICE LIST
+Dexter A. Lee
+Assistant United States Attorney
+99 N.E. 4" Street, Suite 300
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+E-mail: dexter.lee @usdoj.gov
+A.
+Villafaña
+Assistant United States Attorney
+500 S. Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Tel: (561) 820-8711: Fax: (561) 820-8777
+E-mail:
+Eduardo I.
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Ema 305) 961-9057: Fax: (305) 536-4676
+Attorneys for the United States
+Jacqueline Perczek
+BLACK SREBNICK KORNSPAN &
+STUMPF
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Tel: (305) 371-6421; Fax: 305-358-2006
+Email: Pleading@royblack.com
+Roy E. Black
+BLACK SREBNICK KORNSPAN &
+STUMPF
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Tel: (305) 371-6421; Fax: 305-358-2006
+Email: Rblack@royblack.com
+Attorneys for Intervenor Jeffrey Epstein
+22
diff --git a/vision-fixhub/court-02/058bd0ffb97dcc907f63aaa782fb19377a03544621a1b040c53e27a91c64e7a5.receipt.json b/vision-fixhub/court-02/058bd0ffb97dcc907f63aaa782fb19377a03544621a1b040c53e27a91c64e7a5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..25dbac109192f92076f8e17545c81837551fc418
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+++ b/vision-fixhub/court-02/058bd0ffb97dcc907f63aaa782fb19377a03544621a1b040c53e27a91c64e7a5.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 24,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "d4ab4f512d62b8bfca8e685337c08cec6d130cb82b2a11a4440a51ec46698223",
+  "output_sha256": "34d5dd11d18b3073f592ca6cbf7f5e9c4f6131b44448466f63050edd3c9885ee",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.md b/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.md
new file mode 100644
index 0000000000000000000000000000000000000000..7cd0aefe8133735797cb05d4cb7bc9e3410a617c
--- /dev/null
+++ b/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.md
@@ -0,0 +1,99 @@
+#291874/mep
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+, individually, and
+L.M., individually,
+Defendant.
+PAT
+20I0 JUN 30 PM 3:50
+/
+WITNESS LIST OF DEFENDANT/COUNTERPLAINTIRE.
+J.
+COMES NOW the Defendant/Counterplaintiff,
+through his undersigned attorneys, and hereby lists non-expert witnesses for trial as follows:
+1.
+2.
+3.
+4.
+5.
+by and
+7.
+All attorneys currently prosecuting claims against Jeffrey Epstein on behalf of
+other victims.
+All other named victims.
+All witnesses listed by the Plaintiff/Counterdefendant and Co-Defendant.
+All experts named by the Plaintiff/Counterdefendant and Co-Defendant.
+Any and all witnesses listed in the Answers to Interrogatories, Responses to
+Requests for Production, Responses to Requests for Admissions, identified in
+deposition and/or exhibits thereto however, by listing these witnesses,
+Defendant/Counterplaintiff does not waive any objections to their testimony at
+Depostian ander exhibi t
+trial if offered by Plaintiff/Counterdefendant).
+Impeachment and rebuttal witnesses as necessary, without waiving any objections
+thereto.
+
+
+Epstein v. Rothstein, et al
+Witness List
+Case No.: 502009CA040800XXXXMBAG
+Defendant/Counterplaintiff reserves the right to amend this list prior to trial upon proper
+notice to the Plaintiff/Counterdefendant.
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+Fax and U.S. Mail on this 30T day of June, 2010 a all e
+_ day of June, 2010 to all counsel on the attached list.
+Scarcy Denney Scarola Barnhart & Shipley
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+(561) 686-6300
+NOT A
+NOT A CER
+Fax:
+(561) 383-9451
+Attorney for Defendant/Counterplaintiff,
+J.
+2
+
+
+Epstein v. Rothstein, et al
+Witness List
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+Attorney For: Jeffrey Epstein
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+Jaffe, Weissing,
+, Fistos &
+Lehrman, PL
+Attorney For: Jeffrey Epstein
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+CERTIFIED
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+Attorney For: Scott Rothstein
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954) 745-5849
+Fax: (954) 745-3556
+Lilly Ann
+Esquire
+Burnett, P.A
+Attorney For: Jeffrey Epstein
+777 S Flagler Drive, Suite 901
+West Palm Beach, FL 33401
+Phone: (561) 802-9044
+Fax: (561) 802-9976
+COPY
+3
diff --git a/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.receipt.json b/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4ddbbb372eb58ffb526743907d6aea0459b95727
--- /dev/null
+++ b/vision-fixhub/court-02/059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "059c20ef04a0634e52009ce3bfe3ee36a8ae352132287ed49dde732f0b1276a7",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e9c864de5f2222ca6d7b66c8db072b013e7f90d8fdc370d9502437bbcf90748a",
+  "output_sha256": "2ecee7f0ad7f049ee26c62dfc47f2c1e8cc46a7a37caf10294f07ab61a2e2011",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.md b/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.md
new file mode 100644
index 0000000000000000000000000000000000000000..41a6341fbea86deb06d480af76f8e93df34be650
--- /dev/null
+++ b/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.md
@@ -0,0 +1,185 @@
+Filing # 68019321 E-Filed 02/15/2018 01:47:25 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants.
+COPY
+RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION IN LIMINE AS TO SEX
+OFFENDER REGISTRY INFORMATION
+Counter-Plaintiff,
+J.
+by and through undersigned counsel, hereby files
+this Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry
+Information, and as grounds therefore states as follows:
+Epstein's Net Worth is a Factual Issue in Dispute
+Epstein's Motion in Limine repeatedly claims that documents containing circumstantial
+evidence of Epstein's net worth are not relevant to any factual issue in dispute pursuant to the
+parties' Joint Pre-Trial Stipulation. That statement is clearly false. Specifically, Part 2(K) of the
+Joint Pre-Trial Stipulation confirms that one of the issues of fact for determination at trial is "[w]hat
+amount, if any, should be assessed against Epstein for punitive damages as punishment for
+instituting or continuing his civil proceeding against
+Land/or as a deterrent to others." See
+Joint Pre-Trial Stipulation at p. 10, 12.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 02/15/2018 01:47:25 PM
+
+
+Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Information
+Although Epstein alleged that he was a billionaire in the Initial Complaint, he has asserted
+his Fifth Amendment privilege as to all punitive damage net worth discovery.
+is entitled
+to an adverse inference jury instruction as a result of these assertions, and that request is the subject
+of a separate motion. See Atlas v. Atlas, 708 So. 2d 296, 299 (Fla. 4th DCA 1998) (citing Baxter
+v. Palmigiano, 425 U.S. 308 (1976)).
+intends to also use the detailed asset information in Epstein's sex offender
+registration as evidence of Epstein's substantial net worth. As part of his registration in New York,
+Epstein was required to list all homes, vehicles, and planes that he owns. The registration page
+submitted by Epstein himself shows that Epstein owns seven residential properties, dozens of
+vehicles, and at least one airplane. Certainly, this is direct evidence that Epstein is a man of
+significant net worth, and is consistent with his claimed status as a billionaire.
+Epstein's sex offender registration information is therefore relevant to a factual issue in
+dispute: the amount of punitive damages that may be awarded by the jury. See Thigpen v. United
+Parcel Servs., Inc., 990 So. 2d 639, 646 (Fla. 4th DCA 2008) ("To be relevant, evidence must tend
+to prove or disprove a material fact.").
+Epstein's Prejudice Argument is Circular Reasoning That Leads Directly Back to Him
+Epstein built the alleged prejudicial playing field he now complains of. In the Initial
+Complaint, Epstein claimed that
+had "manufactured" sexual abuse lawsuits on behalf of
+L.M., E.W., and Jane Doe, lawsuits that were "weak and had minimal value" ... "for the sole
+purpose of continuing [Scott Rothstein's] massive Ponzi scheme." Initial Complaint at 9 42(h) &
+30. Epstein referred to himself as a victimized "Palm Beach Billionaire," as follows:
+2
+
+
+| adv. Epstein
+Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Information
+... the Litigation Team [which included
+I took an emotionally driven set
+of facts involving alleged innocent, unsuspecting, underage females and a Palm
+Beach Billionaire and sought to turn it into a gold mine. Rather than evaluating
+and resolving the cases based on the merits (i.e. facts) which included
+knowledgeable, voluntary and consensual actions by each of the claimants...
+Id. at 9 49 (emphasis added). And Epstein referenced the Non-Prosecution Agréement, which
+establishes his status as a convicted sex offender. Id. at 9| 42(I). So, Epstein alleged that he was a
+billionaire, confirmed the existence of the Non-Prosecution Agreement (which required him to
+plead guilty to sex crimes and register as a sex offender), and alleged that "each of the claimants"
+against him were liars.
+Epstein's Complaint, on which
+malicious prosecution counterclaim is premised,
+therefore injected all of the prejudicial circumstances of which Epstein now complains. Consistent
+with his burden of proof,
+will establish that Epstein lacked probable cause to make these
+malicious allegations. In defense of the malicious prosecution counterclaim, Epstein has listed
+numerous media articles on which he apparently intends to rely. These articles, to which
+has raised no objection, variably label Epstein as a convicted child molester and pedophile. For
+example:
+Epstein's Exhibit 245(: Describing Epstein as a "Palm Beach sex offender."
+Epstein's Exhibit 245(S): Describing Epstein as a "billionaire sex offender"
+Epsiein's Exhibit 246(A): "The Shameful Way Feds Protected Convicted Pedophile
+Billionaire Jeffrey Epstein"
+Epstein's Exhibit 246(C):
+Sweethear Deal Teen Victims Say Deceived Us Abour Billionaire Sex Offender's
+3
+
+
+Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Information
+Epstein's counsel has also made clear that he intends to establish Epstein's probable cause by, in
+part, showing that
+was attempting to unseal the Non-Prosecution Agreement. Thus, not
+only is Epstein responsible for every prejudicial allegation that he chose to make in the
+maliciously-filed Initial Complaint, his defense of this case is putting at issue the very
+circumstances he claims are prejudicial, which are instead relevant and material. See State v. Gad,
+27 So. 3d 768, 770 (Fla. 2d DCA 2010) ("[I]n order for relevant, probative evidence to be deemed
+unfairly prejudicial, it must go beyond the inherent prejudice associated with any relevant
+evidence.").
+Conclusion
+The amount of punitive damages, if any, that may be assessed against Epstein is an issue
+to be determined at trial. The detailed asset information that Epstein provided as part of his
+registration as a sex offender is relevant and material evidence to that contested issue, and there is
+no unfair prejudice from introducing this evidence because Epstein has already put his status as a
+convicted sex offender at issue through the filing of the Initial Complaint and his apparent defense
+strategy. Thus, Epstein's Motion in Limine should be denied.
+4
+
+
+ady. Epstein
+Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Information
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 15 day of February, 2018.
+tal Sanda
+Jack Scarola
+Florida Bar No.: 169440
+David P. Vitale Jr.
+Florida Bar No.: 115179
+Attorney E-Mails: jsx@searcylaw.com and
+mmccann@searcylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+NOT A
+NOT A CER
+CERTIF
+Attorneys for Bradley J.
+
+
+Response in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Information
+COUNSEL LIST
+J.
+Esquire
+staff.etle @pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+FIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys tor
+J. Edwards
+dis
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com;
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com;
+tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+6
+
+
+lesponse in Opposition to Epstein's Motion in Limine as to Sex Offender Registry Informatio
+Case No.: 502009CA040800XXXХMBA(
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
+7
\ No newline at end of file
diff --git a/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.receipt.json b/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ead2a7e7d5bcb4ac9d3465a28b528eec594e6bb9
--- /dev/null
+++ b/vision-fixhub/court-02/05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -302,
+  "dataset": "marble-joined",
+  "doc_id": "05e4606d8651b2ef54d4be85f3669e22bc5224bd11857b0aa1fbb5dab3e7aee1",
+  "engine": "marble-apple-vision",
+  "event_count": 8,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "a36ea361ae6f1838b91f0f3c90fda7c100b2b1285c899a3940de139e51fbbbc2",
+  "output_sha256": "5ffa864b270dd21badc53fd03e9df0223e125d9cac1e25f718b17000eaec487f",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.md b/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.md
new file mode 100644
index 0000000000000000000000000000000000000000..0a0da299d84244259f21d7963a13e0db1ef017c2
--- /dev/null
+++ b/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.md
@@ -0,0 +1,1455 @@
+Filing # 68041244 E-Filed 02/15/2018 04:35:56 PM
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+T.M, individually,
+individually, and
+Defendants.
+COPY
+RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION IN LIMINE ON
+NEWLY DISCLOSED TRIAL EXHIBITS AND TO EXCLUDE DEPOSITION
+TESTIMONY OF WITNESSES WHO WERE NOT DEPOSED IN THIS MATTER
+Counter-Plaintiff,
+J. Edwards, by and through undersigned counsel, hereby files
+this Response in Opposition to Epstein's Motion in Limine on
+Newly Disclosed Trial
+Exhibits and to Exclude Deposition Testimony of Witnesses Who Were Not Deposed in this
+Matter, and as grounds therefore states as follows:
+Epstein's motion is misleading and is nothing more than a pointless attempt to make
+a mountain out of a mole
+•. Pursuant to the Court's July 20, 2017 Pre-Trial Order,
+timely
+produced copies of all 79 trial exhibits that Epstein's motion seeks to categorically exclude. These
+exhibits were produced along with 130+ additional exhibits in November of 2017.
+2.
+Immediately after the December 7, 2017 hearing in this case, undersigned counsel's
+office realized that, through oversight, its November 3, 2017 Amended Exhibit List was the wrong
+version of that pleading because it inadvertently left off the descriptions of 79 exhibits that had
+already been produced to defense counsel. So, although the filed exhibit list needed to be corrected,
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 02/15/2018 04:35:56 PM
+
+
+Ladv. Epstein
+Response in Opposition to Epstein's Motion in Limine as to Newly Filed Exhibits
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+, Esquire
+statf.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+FIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J. Edwards
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com;
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com;
+Link & Rockenbach, P.A.
+tina@linkrocklaw.com
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Mare S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+5
+
+
+adv. Epstein
+Response in Opposition to Epstein's Motion in Limine as
+Case No.: 502009CA040800XXXXMBAG
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Newly Filed Exhibits
+NOT A CERTIFIED COPY
+6
+
+
+1
+FIFTEENTH JUDICIAL CIRCUIT, IN
+AND FOR PALM BEACH COUNTY, FLORIDA
+Case No. 502009CA040800XXXXMB
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually,
+Defendants/Counter-Plaintiff.
+COPY
+VOLUME I
+TRANSCRIPT OF PROCEEDINGS
+DATE TAKEN:
+TIME:
+PLACE
+BEFORE:
+Tuesday,
+December 5th, 2017
+10:02 a.m.
+- 4:35 p.m.
+205 N.
+Dixie Highway, Room 10C
+West Palm Beach,
+Florida
+Donald Hafele,
+Presiding Judge
+This cause came on to be heard at the time and place
+foresaid, when and where the following proceedings were
+reported by:
+Palm Beach Reporting Service, Inc.
+1665 Palm Beach Lakes Boulevard, Suite 1001
+West Palm Beach, FL 33401
+(561) 471-2995
+Palm Beach
+
+Inc. 561-471-2995
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21,
+22
+23
+24
+25
+161
+is the video of the search warrant of my
+client's home -- while being executed, the
+search. I don't have the video, but I
+presume by that -- it wasn't produced, but I
+presume by that description, it is the same
+ruling.
+THE COURT: The same ruling as in 17,
+the application for the search warrant
+is
+sustained.
+MR. SCAROLA: Let me just point out to
+Your Honor that the reason why that's listed
+is because the victims, including these
+three, give detailed descriptions of where
+they were in the house and what the interior
+looked like. And all of that is
+corroborated by the search warrant video.
+THE COURT: Again, it's with the
+proviso and caveat that I will re-examine
+each of these exhibits, if need be, when the
+context is pointed out. But for now, the
+same ruling is being issued.
+MS. ROCKENBACH: Number 18 -- actually,
+17. It's identified on the exhibit list by
+Mr.
+as the application for a search
+warrant of my client's home. And it's
+Palm Beach Reporting Service, Inc. 561-471-2995
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21,
+22
+23
+24
+25
+162
+possible that by mistake Mr. Scarola's
+office produced a different document,
+because what was produced in this context
+was an order sealing affidavit and
+application for search warrant and related
+search warrant and inventory in return. And
+attached to that were the subpoenas to the
+custodian of records for BellSouth, I-Mobile
+and Cingular. So it looks like phone
+records.
+MR. SCAROLA:
+Sounds like the wrong
+exhibit.
+MS. ROCKENBACH:
+Sounds like the wrong
+exhibit, but we would object to -- on the
+same basis that the application for the
+search warrant df Mr. Epstein's home would
+not be releyant, would be prejudicial -
+THE, COURT: I have already indicated
+the same as to number 17.
+MS. ROCKENBACH: Eighteen, Your Honor,
+is the complaint.
+THE COURT: That, again, is typically a
+matter of judiciál notice, so we will deal
+with it, if we need to, at a later time.
+"All records of homes, properties, bank
+Palm Beach Reporting Service, Inc. 561-471-2995
+
+
+Chris R. Rodgers
+From:
+Sent:
+To:
+Subject:
+CaselD:
+CategoryID:
+IntakeCase:
+SentFromSession:
+Chris R. Rodgers
+December 20, 2017 3:59 PM
+Scott J. Link
+RE: Regarding:
+
+_ adv. Epstein (File #: 291874)
+CRODGERSW10.crodgers.12/20/2017 2:49:09 PM
+Thank you.
+From: Scott J. Link [mailto:5cott@linkrocklaw.com]
+Sent: December 20, 2017 3:58 PM
+To: Chris R. Rodgers <crodgers@SearcyLaw.com>
+Cc: Tina L.
+<Tina@linkrocklaw.com>; Jack Scarola <JSX@SearcyLaw.com>; David P. Vitale Jr.
+<dvitale@searcylaw.com>; Kimberly Marsh <kmarsh@searcylaw.com>; Mary McCann <mmccann@Searcylaw.com>;
+Kara Berard Rockenbach <Kara@linkrocklaw.com>
+Subject: Re: Regarding:
+adv. Epstein (File #: 291874)
+COPY
+Of course. Scott
+Scott J. Link
+Board Certified Business Litigation
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+office (561) 727-3600 | fax (561) 727-3601 | Email: scott@linkrocklaw.com
+LINK&
+ROCKENBACH, PA
+CIVIL TRIAL & APPELLATE LAW
+This e-mail may contain privileged or confidential
+information. If it is not meant for you, please
+delete it and notify us immediately. Please
+confirm receipt of time sensitive communications because email deliveries may be
+delayed or unsuccessful. We do not provide tax advice. Our communications may
+not be relied upon to avoid penalties that may be imposed by the Internal Revenue
+Service.
+
+On Dec 20, 2017, at 3:57 PM, Chris R. Rodgers <crodgers@SearcyLaw.com> wrote:
+Hey Tina,
+We are having data download speed issues with some of our exhibits. While we hope to get
+you these exhibits by the end of today, our fear is that the download delay might take longer
+1
+
+
+than expected (actually, it already has). Given that, and in an abundance of caution would you
+be willing to extend to us a one day extension to provide you with the missing
+exhibits?
+Thank you for your understanding with this matter,
+Chris Rodgers
+From: Chris R. Rodgers
+Sent: December 7, 2017 8:47 AM
+To: 'Tina L.
+/'<Tina@linkrocklaw.com>
+Cc: Jack Scarola <JSX@searcylaw.com>; David P. Vitale Jr. <dvitale@searcylaw.com>; Kimberly Marsh
+<kmarsh@searcylaw.com>; Mary McCann <mmccann@Searcylaw.com>; Scott J. Link
+<Şcott@linkrocklaw.com≥: Kara Berard Rockenbach <Kara@linkrocklaw.com>
+Subject: Regarding:
+adv. Epstein (File #: 291874)
+Good Morning Tina,
+Yesterday it was discovered that we inadvertently attached an incorrect version of our Exhibit
+List to our Unilateral Pre-Trial Stipulation which was filed on November 15, 2017. While the
+exhibit list provided in this filing was incorrect, the actual exhibit documents forwarded to you on
+November 9, 2017 were correct. As an example, the 11/09/17 provided exhibits go to number
+207, while the 11/15/17 Exhibit List stops at number 142. You will notice that the correct Exhibit
+List (attached) corresponds correctly to the provided exhibits. To correct this error, we are filing
+this correct Exhibit List today - as our Second Amended Exhibit List. Please e-mail or call with
+any concerns, or questions, regarding this correction.
+<image001.jpg>www.searcylaw.com
+Chris R. Rodger
+senior Litigatio
+Paralegal/Investigator
+F: (361 66-50 xl. 145
+F: (561) 383-9451
+earcy Denney Scarol
+arnhart & Shipley P.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+<image002.png>
+***** L Privileged and Confidential | Electronic communication is not a secure mode of communication
+and may be accessed by unauthorized persons. This communication originates from the law firm of
+Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication
+Privacy Act, 18 U.S.C. S2510-2521. The information contained in this E-mail message is privileged and
+confidential under Fla. R. Jud. Admin. 2.420 and information intended only for the use of the
+individual(s) named above. If the reader of this message is not the intended recipient, you are hereby
+notified that any dissemination, distribution, or copy of this communication is strictly prohibited.
+Personal messages express views solely of the sender and shall not be attributed to the law firm. If you
+received this communication in error, please notify the sender immediately by e-mail or by telephone at
+(800) 780-8607 and destroy all copies of the original message. Thank you.
+ЧЕ ОФЕФЕФОЭОЭЭЭЭЭ********************************************************
+*****
+
+
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+REVISED OMNIBUS MOTION IN LIMINE
+SECTION B (
+TRIAL EXHIBITS)
+THIS MATTER came before the Court for hearing on November 29, 2017, and December
+5, 2017, upon Section B (
+Trial Exhibit List') of the Revised Omnibus Motion in Limine
+filed by Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"') (D.E. 1070). The Court, having
+reviewed the Motion and the Response filed by Defendant/Counter-Plaintiff
+) (D.E. 1089), having h
+the premises, it is hereby
+ORDERED AND ADJUDGED that:
+argument of counsel, and being otherwise fully advised in
+' Epstein's Revised Omnibus Motion in Limine was directed at
+Amended Exhibit List dated
+November 9, 2017. (D.E. 1043.) On December 7, 2017, after two days of hearing and substantive
+Court rulings, I
+filed a Second Amended Exhibit List (D.E. 1109) identifying 79 new items
+and modifying some of his earlier disclosed exhibits. This Order only addresses the exhibits identified
+on l
+[ November 9, 2017, Exhibit List. To the extent any exhibit numbers have been replaced
+with different items or new numbers have been added, those will be subject to a separate Order after
+the appropriate motion and hearing. The rulings set forth herein for all exhibits disclosed on
+December 7, 2017, Second Amended Exhibit List that have not been modified will remain unchanged.
+
+
+
+On or before December 20, 2017, 4 | shall produce to Epstein all trial exhibits
+that have not been previously produced in the form to be introduced at trial with the exception of
+Exhibit No. 113 which is addressed separately in paragraph 2 below. (12/5/17 Tr. 216, 219, 226,
+228)
+2.
+On or before January 5, 2018, 1
+shall produce to Epstein the specific court
+filings to be used as trial exhibits from the Crime Victims' Rights Act proceeding (Jane Does #1
+and #2 v. United States of America, U.S. District Court, Southern District of Florida, Case No. 08-
+80736-Civ-Marra/.
+• designated as !
+Trial Exhibit No. 113.
+shall not
+produce each and every item identified on the Court's docket, but shall cull out the specific items
+he intends to use at trial. The Court hereby sustains Epstein's objection to Exhibit No. 113 as
+being overbroad. The Court will revisit this ruling if Edwards narrows the documents he intends
+to introduce at trial. (12/5/17 Tr. 218:25-226:14.)
+3.
+As set forth in more detail below, the Court has sustained Epstein's objections to a
+number of C
+[ trial exhibits. Those objections will be sustained unless there is a showing at
+trial that the exhibits are relevant and material to the issues to be determined. For example, exhibits
+may be admissible if they relate to Edwards' three clients (L.M., E. W. and Jane Doe), if they relate
+to issues concerning
+preparation and evaluation of his clients' cases, or for any other
+reason enunciated by the Court on the record at the November 29, 2017 and December 5, 2017
+hearings. (In those instances,
+1 will be allowed to speak generically about the facts
+surrounding those exhibits, but will not necessarily be allowed to introduce the exhibits at trial
+without further Order of the Court. The Court will make decisions on an item-by-item basis at the
+appropriate time. Any discussions relating to an exhibit to which an objection has been sustained
+shall be conducted outside the presence of the jury. (12/5/17 Tr. 153:16-160:24; 198:19-199:5.)
+2
+
+
+-
+2.
+3.
+4.
+5.
+As set forth in more detail below, the Court defers rulings on Epstein's objections
+directed to
+" trial exhibits concerning Epstein's net worth and in support of
+punitive damages claim. The Court will address these objections at the appropriate time. (12/5/17
+Tr. 163:17-164:15.)
+The Court makes the following specific findings:
+LEGEND FOR EPSTEIN'S OBJECTIONS:
+1 - All Objections
+2 - All Objections except Authenticity
+3 - Relevance
+4 - Probative value substantially outweighed by danger of unfair prejudice,
+COPY
+confusion of issues, misleading the jury, or needless presentation of cumulative
+evidence
+5 - Privileged
+6 - Opinion
+7 - Hearsay
+8 - Authenticity
+9 - Other (please identify basis of objection)
+10 - Completeness
+11 - Overbroad
+12 - Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation
+13 - Not a proper exhibit
+14 - Trade secrets/Confidential
+' Exhibit Description
+All applicable criminal statutes
+All applicable Florida Státutes
+Photos and information of Jeffrey Epstein's
+homes, airplanes and automobiles
+Order confirmation from Amazon.com fo
+urchase of books "SM 101: A realistic
+Introduction," "Slave Craft: Roadmap for Eroti
+Servitude-Principles, Skills and Tools" and
+"Training Miss Abernathy:
+A Workbook for Erotic Slaves and Their Owners"
+Non-Prosecution Agreement
+Epstein's
+Objections
+3, 4, 7, 11, 12
+3, 4, 7, 11, 12
+3, 4, 7, 8, 10, 12
+3, 4, 7,8
+Court's Ruling
+Not addressed at hearing
+Not addressed at hearing
+11/29/17 Tr. 160:6-162:15
+11/29/17 Tr. 162:16-167-9
+Sustained
+3, 4, 7, 8, 10
+11/29/17 Tr. 167:11-13
+Overruled
+3
+
+
+6.
+7.
+"Exhibit Description
+Jane Doe 102 Complaint
+Messages taken from message pads found at
+Epstein's home
+Epstein'
+bjectior
+3, 4, 7, 13
+3, 4, 7, 8, 11, 14
+Court's Ruling
+11/29/17 Tr. 167:14-170:9
+Sustained
+11/29/17 Tr. 171:22-176:9
+Deferred. Not to be mentioned
+during opening statements.
+8.
+Documents related to Jeffrey Epstein produced by
+Alfredo Rodriguez
+9.
+Jeffrey Epstein flight logs
+10.
+| Jeffrey Epstein phone records
+11.
+phone records
+12.
+Jail Visitation Logs
+13.
+Jeffrey Epstein's probation file
+14.
+15.
+16.
+All probable cause affidavits related to criminal
+investigation of Jeffrey Epstein
+Victims' statements to the FBI related to criminal
+investigation of Jeffrey Epstein
+Video of Search Warrant of Jeffrey Epstein's
+17.
+18.
+3, 4, 7, 8, 11, 14
+3, 4, 7, 8, 10, 11
+3, 4, 10, 11, 14
+3, 4, 8, 10, N| 14
+3, 4, 7, 8, 1|
+3, 4, 7, 8, 11
+3, 4, 7, 8, 10
+3,4, 7,8
+3,4,8
+Application for Search Warrant of Jeffrey
+3, 4, 7, 8, Cannot
+Epstein's home
+be read
+Complaint Jane Doe v. Epstein and all subsequent | 3, 4, 7, 13, 12 (as
+Amended Complaints
+to "subsequent
+Complaints")
+11/29/17 Tr. 176:10-187:8
+Deferred. Not to be mentioned
+during opening statements.
+12/5/12 Tr. 64:8-81:17: 85:11-22
+Sustained
+12/5/17 Tr. 81:18-82:17; 146:14-
+149:19: 159:12-160:7
+Sustained
+12/5/17 Tr. 149:20-150:1:
+159:12-160:7
+Sustained
+12/5/17 Tr. 150:2-3: 159:12-
+160:7
+Sustained
+12/5/17 Tr. 150:4-152:11;
+159:12-160:7
+Sustained
+12/5/17 Tr. 152:14-153:13
+12/5/17 Tr. 153:16-160:24
+Sustained
+12/5/17 Tr. 160:25-161:21
+Sustained
+12/5/17 Tr. 160:25-162:19
+Sustained
+12/5/17 Tr. 162:20-24
+2 In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+exh hew de"rio and min be suby to en Mion in mine as pois dema apro rulings on
+4
+
+
+19.
+20.
+21.
+22.
+23.
+
+Il records of homes, properties, bank accoun
+id any/ all records related to Jeffrey Epstein'
+assets
+Jeffrey Epstein's passport (or copy)
+Jeffrey Epstein's driver's license (or copy)
+List of corporations owned by Jeffrey Epstein
+Yearbooks of Jane Doe
+24.
+2002
+Palm Beach High School Year Book
+25.
+2001|
+[Palm Beach High School Year Book
+Epstein's
+Objections
+Court's Ruling
+1215/17 Tr. 162:25-164:15
+12/5/17 Tr. 163:4-5: 164:16-12
+Sustained
+Cannot be read, 3,
+12/5/17 Tr. 164:20-24
+Sustained
+3, 4, 7,8, 12
+12/5/17 Tr. 164:25-165:5
+3,4, 7,8, 12
+12/5/12 Tr. 165:6-166:16;
+166:25-167:6
+Not produced
+3,4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16
+56:25-167
+ot produc
+3.4,7,8,12
+12/5/17 Tr. 165:6-166:16
+26.
+27.
+2003 Palm Beach Gardens High School Year
+Book
+Affidavit and Application for Search Warrant on
+Jeffrey Epstein's home"
+3, 4, 7, 8, 12
+12/5/17 Tr. 165:6-166:16
+3, 4, 7, 8, 10,
+Sustaine. 166: 15-24
+3 In his December 7, 2017, Second Amended Exhibit List,
+modified this exhibit to include
+additional descriptive language: "(from Palm Beach State Attorney's File, Exhibit #29)." The Court
+finds that this language does not substantially change the exhibit and, thus, the Court's ruling holds.
+5
+
+
+28.
+/Exhibit Description
+Nuring dash puts uside of his home duringdior
+criminal investigation
+Epstein's
+Objections
+3,4, 7, 8, 10, 11, 14
+Court's Ruling
+far as Mr. IN
+29.
+The Palm Beach State Attorney's Criminal file
+against Jeffrey Epstein
+3, 4, 6, 7, 8, 19.
+11,13
+30.
+31.
+32.
+All documents related to Jeffrey Epstein's 6/30/08
+3. 4, 7, 8, 12
+conviction
+Jeffrey Epstein's criminal plea colloquy
+3, 4, 7, 8, 12
+List of properties and vehicles in Larry Visoski's
+3, 4, 7, 8, 11, 13,
+name
+provided was an
+entire Motion
+denied) not just
+the identified item.
+three
+clients and, therefore, may not be
+used until discussed outside the
+presence of the jury
+12/5/17 Tr. 168:17-175:1
+Sustained in part and overruled in
+part. If
+had access to
+formulate his positions as to the
+legitimacy of his three clients"
+claims, this file may come into
+play. The sheer amount of the
+criminal file would also be
+relevant to Mr. Epstein's state of
+mind at the time he filed the
+underlying Complaint. The
+individual pages are not subject
+to admission and would need to
+be discussed outside the presence
+of the jury.
+12/5/17 Tr. 175:2-179:25
+12/5/17 Tr. 175:2-180:5
+12/5/17 Tr. 180:23-181:12
+6
+
+
+33.
+34.
+35.
+36.
+
+All of Jeffrey Epstein's Responses to Requests for
+Production, Requests for Admission, Answers to
+Interrogatories in this matter, and cases 08-80119,
+08-80232, 08-80380, 08-80381, 08-80994, 08-
+80811, 08-80893, 09-80469, 09-80591, 09-80656,
+09-80802, 09-81092
+All discovery related responses of Jeffrey Epstein
+in this matter and cases 08-80119, 08-80232, 08-
+80380, 08-80381, 08-80994, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-
+81092
+Jeffrey Epstein's Answers and Affirmative
+Defenses in all civil cases against him
+All Complaints in which Jeffrey Epstein is/was
+defendant
+Epstein's
+Objections
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13
+37.
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13.
+This also includes
+a motion which is
+not part of the
+stated exhibit.
+3, 4, 11, 12, 13
+38.
+39.
+40.
+41.
+42.
+43.
+44.
+Jeffrey Epstein's Deposition testimony and
+discovery responses in this case and cases 08-
+80119, 08-80232, 08-80380, 08-80381, 08-80994,
+08-80811, 08-80893, 09-80469, 09-80591, 09-
+80656, 09-80802, 09-81092
+Jeffrey Epstein's Deposition testimony and
+discovery responses in State Court cases LM v.
+Jeffrey Epstein, Case No.
+502008CA028051XXXXIMBAB and E.W. v.
+Jeffrey Epstein, Case No.
+502008CP003626XXXXMB
+Jeffrey Epstein Deposition Testimony and
+discovery responses in State Court case Jeffrey
+Epstein v. Scott Rothstein, et al. Case No
+502009CA040800XXXXMBAG
+Any and all newspaper articles, online articles or
+publications related to Jeffrey Epstein
+Repoft and Analysis of Jeffrey Epstein's assets
+Video footage (DVD) of walk through site
+inspection of Jeffrey Epstein's home.
+Photos of all of Jeffrey Epstein's properties, cars,
+boats and planes
+Probable Cause Affidavits prepared against
+Jeffrey Epstein and
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13
+3, 4, 7, 8, 11,12
+3,4, 7, 8, 14
+3, 4, 7, 8, 12
+3, 4, 7, 8, 14, 12
+(as to cars and
+boats)
+3, 4, 7, 8, 10
+7
+Court's Ruling
+12/5/17 Tr. 188:23-192:17
+Not addressed at hearing
+12/5/17 Tr. 192:18-22
+12/5/17 Tr. 192:23-193:2
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing
+12/5/17 Tr. 193:3-194:22
+12/5/17 Tr. 194:23-195:1
+12/5/17 Tr. 195:2-195:15
+12/5/17 Tr. 195:16-18
+1215/17 Tr. 195:19-196:2
+
+
+45.
+46.
+47.
+48.
+49.
+
+Documents related to or evidencing Jeffrey
+Epstein's donations to law enforcement
+Victim Notification Letter from US Attorney's
+Office to Victims*
+Expert Dr. L. Dennison
+Report of Victim
+Palm Beach Police Department Incident Report
+All reports and documentation generated by Palm
+Beach Police Department related to Jeffrey
+50.
+A tess Satement generated by Palm Beach
+Police Department relating to Jeffrey Epstein
+51.
+Passenger Manifests of Jeffrey Epstein's aircraft
+and private plane flight logs
+52.
+Passenger lists for flights taken by Jeffrey Epstein
+53.
+Letter from Jeffrey Epstein to Alberto Pinto
+regarding house island project
+54.
+Jeffrey Epstein's bank statements
+55.
+56.
+Jeffrey Epstein's tax returns
+MC2 emails involving communications of Jeffrey
+Epstein, Jeff Fuller, Maritza Vasquez, Pappas Suat,
+Jean Luc Brunel and Amanda Grant
+57.
+58.
+59.
+DVD of plea and colloquy taken on 6-30-08
+Transcript of plea and colloquy taken on 6-30-08
+Massage Table
+Epstein's
+Objections
+3. 4, 7, 8, 10
+3, 4, 7, 8, 14
+3, 4, 6, 7, 8, 14
+3,4,7,8
+3, 4, 7, 8, 12
+Court's Ruling
+12/5/17 Tr. 196:3-19
+Sustained
+12/5/17 Tr. 196:20-197:2
+Sustained
+12/5/17 Tr. 197:3-23
+Sustained
+12/5/17 Tr. 197:24-198:10
+Sustained
+12/5/17 Tr. 198:13-199:6
+Sustained
+3, 4, 7, 8, 12
+3, 4, 7, 8, 10, 11,
+12
+3, 4, 7,8, 10, 11,
+12
+3,4, 7,8, 10
+3, 4, 7, 8, 12, 14
+- 12/5/17/Tr. 198:13-199:6
+Sustained
+12/5/17 Tr. 198:13-199:6
+Sustained
+12/5/17 Tr. 199:8
+Sustained
+12/5/17 Tr. 199:9-25
+Sustained
+12/5/17 Tr. 200:1-3
+3, 4, 7, 8, 12, 14
+3, 4, 7, 8, 12
+12/5/17 Tr. 200:1-3
+12/5/17 Tr. 200:4-18
+Not Produced
+Reserved ruling because
+documents not available
+3, 4, 8, 12, 13
+12/5/17 Tr. 200:19-22
+Sustained
+3, 4, 13
+12/5/17 Tr. 200:23-24
+Sustained
+3, 4, 12 (document
+| 12/5/17 Tr. 200:25-201:21
+marked as No. 59
+Sustained
+is not a massage
+table)
+modified this exhibit to include
+> In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+exhibit to: "Palm Beach Police Department Incident Report dated 07/25/06 (unredacted)." This Order
+does not make any rulings on the new description and may be subject to a new Motion in Limine as
+Epstein deems appropriate.
+8
+
+
+60.
+6l.
+62.
+63.
+64.
+I Exhibit Description
+Epstein's
+Objections
+No Contact Orders entered against Jeffrey Epstein
+3,4, 13
+Criminal Score Sheet regarding Jeffrey Epstein
+3, 4, 7, 8, 12
+Documents evidencing Jeffrey Epstein's
+3, 4, 7, 8
+3, 4, 7,8
+3, 4, 7, 8,
+Document says
+cannot rely on this
+for legal action
+65.
+CAD calls to 358 EL BRILLO WAY, PALM
+3, 4, 7,8
+BEACH FL 33480
+66.
+List of Jeffrey Epstein's House contacts
+3, 4, 7, 8, 12
+(document
+provided is not
+reflective of
+description)
+67.
+Documents related to Jeffrey Epstein's
+3.4, 7,8, 12, 14
+investments
+68. Letter from Chief Michael Reiter to Barry
+3, 4, 7,8
+Krischler
+69.
+List of planes owned by Jeffrey Epstein"
+7o.
+71.
+72.
+Letter from Guy Fronstin to Assistant State
+Attorney dated 1-11-06
+Letter from Guy Fronstin to Assistant State
+73.
+Letter from Guy Fronstin to Assistant State
+Altorney dated 2-17-06
+Letter from Guy Fronstin to Assistant State
+Attorney dated 4-6-06
+3, 4,7, 8, 12
+(document
+provided does not
+match
+description), 14
+3, 4, 7, 8, 10
+3,4,7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+Court's Ruling
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 201:22-202:8
+Sustained
+12/5/17 Tr. 202:9-203:4
+12/5/17 Tr. 203.5-204:2
+12/5/17 Tr. 204:3-11
+Sustained
+12/5/17 Tr. 204:12-205:12
+Sustained
+12/5/17 Tr. 205:13-15
+1215/17 Tr. 205:16-22: 206:2-
+207:14: 209:15-210:5
+Sustained
+12/15/17 Tr. 205:23-25
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+12/5/17 Tr. 207:15-209:9
+Sustained
+" In his December 7, 2017, Second Amended Exhibit List,
+changed the description of this
+ecio. Pelay rins one be per description and may be st ge 10 ner Notion in timine s
+Epstein deems appropriate.
+
+
+74.
+75.
+76.
+
+Letter from Guy Fronstin to Assistant State
+Attorney dated 4-10-06
+Letter from Goldberger dated 6-22-06
+All subpoenas issued to State Grand Jury
+Epstein's
+Objections
+3, 4, 7, 8, 10
+3, 4, 7, 8
+3, 4, 7, 8, 13
+77.
+78.
+79.
+80.
+81.
+82.
+83.
+84.
+85.
+Documents related to the rental of a vehicle for
+3,4,7,8,
+document
+produced contains
+other items not
+identified on list
+Ted's Sheds Documents
+3,4,7, 8,
+document
+produced contains
+other items not
+identified on list
+Documents related to property searches of Jeffrey
+3, 4, 7,8, 14
+Epstein's properties
+Arrest Warrant of Sarah |
+3, 4, 7,8
+Police report regarding
+picking up
+3, 4, 7, 8, 10
+money dated U1-28-04
+List of Trilateral Commission Members of 2003
+3, 4, 7, 8, 10
+Alan Dershowitz Letter dated 4-19-06 and Statute
+T3, 4, 7, 8, 12
+90.410
+Guy Fronstin letter dated 4-17-06
+3, 4, 7,8
+Jeffrey Epstein Account Information
+3, 4, 7, 8, 12,14
+10
+Court's Ruling
+12/5/17 Tr. 207:15-209:2
+Sustainec
+5253i7 Tr. 209:10-12: 2106-21
+ormulate his positions as to ti
+gitimacy of his three client
+claims, these documents may
+come into play. The sheer
+also be relevant to Mr. Epstein's
+state of mind at the time he filed
+the underlying Complaint. The
+individual pages are not subject
+to admission and would need to
+be discussed outside the presence
+of the jury.
+12/5/17 Tr. 211:4-22
+Sustained
+12/5/17 Tr. 211:23-25
+Sustained
+12/5/17 Tr. 212:1-4
+12/5/17 Tr. 212:5-7
+Sustained
+12/5/17 Tr. 212:8-15
+Sustained
+12/5/17 Tr. 212:16-213:1
+Sustained
+12/5/17 Tr. 213:2-214:8
+Not Produced
+12/5/17 Tr. 214:9-11
+Sustained
+12/5/17 Tr. 214:12-20
+
+
+
+86.
+Jeffrey Epstein Criminal Closeout Sheet
+87.
+JEGE, Inc. Passenger Manifest
+88.
+Hyperion Air Passenger Manifest
+89.
+Flight information for
+90.
+Passenger List Palm Beach flights 2005
+91.
+| Jeffrey Epstein notepad notes.re Maria
+92.
+Pleadings of Jane Doe 1 and 2 v. US case
+93.
+Jeffrey Epstein 5' Amendment Speech
+Epstein's
+Objections
+3, 4, 7, 8, 12
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 12
+3, 4, 12 (document
+provided is not
+what is identified
+on list), 13
+3,4.12
+94.
+Reiter letter to Krisher dated 5-1-06
+3, 4, 7, 8, 12
+95.
+96.
+97.
+98.
+99.
+Police Report dated 11-28-04
+3,4,7, 8, 10
+Victim's school records and transeripts
+3,4, 7,8
+Victim Notification letter'
+3, 4, 7, 8
+Police report of Juan Alessi theft at Jeffrey
+3, 4, 7, 8, 12
+Epstein's home
+Victim's Medical Records from Dr. Randee
+3, 4, 6, 7,8
+Speciale
+100.
+All surveillance conducted by law enforcement on
+73,4,7,8,12
+Jeffrey Epstein's home
+101.
+Emails received from Palm Beach Records related 3, 4, 7, 8, 12
+to Jeffrey Epstein
+Court's Ruling
+12/5/17 Tr. 214:21-24
+Sustained
+12/5/17 Tr. 214:25-215:3
+Sustained
+12/5/17 Tr. 214:25-215:3
+Sustained
+12/5/17 Tr. 215:4-5
+Sustained
+12/5/17 Tr. 215:4-5
+Sustained
+12/5/17 Tr. 215:6-8
+Sustained
+12/5/17 Tr. 215:9-17
+12/5/17 Tr. 215:18-20
+Deferred. References to
+deposition excerpts
+not ruled upon fully; subject to
+specific line reference rulings
+which will be subject to a
+separate order
+12/5/17 Tr. 215:21-216:14
+Not produced
+12/5/17 Tr. 216:15-17
+Sustained
+12/5/17 Tr. 216:18-217:8
+Sustained
+12/5/17 Tr. 217:9-10
+Sustained
+12/5/17 Tr. 217:11
+Sustained
+12/5/17 Tr. 217:12
+Sustained
+12/5/17 Tr. 217:13-15
+Sustained
+12/5/17 Tr. 217:16-24
+Sustained
+' In his December 7, 2017, Second Amended Exhibit List,
+modified this exhibit to include
+, 09/03/08.* The Court finds that this language
+does not substantially change the exhibit and, thus, the Court's ruling holds.
+
+
+
+Epstein's
+Objections
+102. All items listed on the Palm Beach Police Property
+• 3, 4, 7, 8, 12
+Report Lists®
+(items not
+provided)
+103. All copies of convictions related to Jeffrey
+3, 4, 7, 8, 12
+Epstein
+104. Jeffrey Epstein criminal records
+3, 4, 7, 8, 12
+105. All documents produced by Palm Beach Police
+Department prior to the deposition of Detective
+3, 4, 7, 8, 10, 11,
+06. Statements, deposition transcripts, videotaper
+lepositions and transcripts taken in connectior
+with this and all related cases and exhibits thereto
+107.
+Any and all expert witness reports and/or records
+generated in preparation for this litigation by any
+party to this cause
+108.
+Demonstrative aids and exhibits including, but
+not limited to, charts, diagrams and models,
+surveys, photographs and similar material
+including blow-ups of the listed items/exhibits
+109.
+reserves all objections to Epstein's
+Exhibits
+110.
+111.
+112.
+reserves the right to supplement and/or
+amend his Exhibit List
+By listing an Exhibit,
+is not waiving his
+right to object to same at trial and does not waive
+their right to amend same.
+All exhibits listed by Epstein subject fo
+objections
+All pleadings and attachments in the action under
+the Crime Victims Rights Act prosecuted by
+Edwards on behalf of victims of
+Epstein's criminal molestations.
+3, 4, 7, 8, 12, 13
+3, 4, 7, 8, 12, 13
+12
+Not an exhibit
+Not an exhibit
+Not an exhibit
+Not an exhibit
+3, 4, 7, 8, 12, 13
+Court's Ruling
+12/5/17 Tr. 217:25-218:2
+Sustained
+12/5/17 Tr. 218:3-10
+Sustained
+12/5/17 Tr. 218:12-17
+Sustained
+125/17 Tr. 218.18-22
+Sustained
+12/5/17 Tr. 218:22-23
+No ruling; catch all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+Not an exhibit
+Not an exhibit
+Not an exhibit
+Not addressed at hearing; catch
+all
+12/5/17 Tr. 218:25-226:14
+Sustained because of breadth,
+114. Edwards' Motions for Summary Judgment, all
+attachments thereto, and all Undisputed Facts
+3, 4, 7, 8, 12, 13
+the docket may not be identified;
+1215/17 Tr. 226:15-227:14
+Overruled
+" In his December 7, 2017, Second Amended Exhibit List, |
+modified this exhibit to include
+additional descriptive language: "and/or Property Receipts." The Court finds that this language does
+not substantially change the exhibit and, thus, the Court's ruling holds.
+12
+
+
+/' Exhibit Description
+I1S. All time records and hourly billing documentation
+produced in discovery.
+Epstein's
+Objections
+3, 4, 7,8, 12
+116. All deposition testimony and discovery responses
+17. All pleadings filed by Epstein in the Rothstei
+18. An submissions dEsein in connection with th
+119.
+120. Phone Journal taken from Epstein's home and
+produced to the FBI by Alfredo Rodriguez
+121.
+122.
+123.
+124.
+Photo depicting
+Ghislaine
+Maxwell and Prince Andrew
+All flight logs for any Epstein owned or
+controlled aircraft
+All emails produced by Defendant and/or all
+emails produced by Plaintiff in this case
+Evidence of contributions to the Palm Beach
+Police Dept.
+125.
+Dr. Bernard J. Jansen Expert Report, Attachments
+126.
+and Back-up Documents, October 20.2017
+Jeffrey Epstein vs. Scott Rothstein,
+J.
+and L.M., Complaint, December 7, 2009
+127.
+Jeffrey Epstein vs. Scott Rothstein,
+J.
+and L.M., Fourth Amended
+Counterclaim, January 9,2013
+128.
+Jeffrey Epstein vs. Scott Rothstein,
+ps L.M. Plaintitoenter. Defendant
+effrey Epstein's Answer and Affirmativ
+efenses to Defendant/Counter-Plaintiff l
+Fourth Amended Counterclaim,
+February 21, 2013
+129. Jeffrey Epstein vs. Scott Rothstein,
+and L.M., Notice of Voluntary
+Dismissal, August 16, 2012
+130. Brad Edward's [sic] Times Records and Billing
+Records related to this matter.
+3,4, 7, 8, 12, 13
+3, 4, 7, 8, 12, 13
+73,4, 7. 8, 12, 13
+3, 4, 7, 8, 12, 14
+3, 4, 7, 8, 11, 14
+(duplicative of
+Exhibit No. 8)
+3,4,4, 8
+3, 4, 7, 8, 10, 11,
+12
+3.4, 7, 8, 10, 12
+3, 4, 7, 8, 10
+duplicative of 45
+3, 4, 6, 7, 8, 10,
+11,13
+3, 4, 7, 13
+3, 4, 7, 13
+3, 4, 7, 8, 10, 12
+13
+Court's Ruling
+12/5/17 Tr. 227:15-229:17
+Overruled.
+- is ordered to
+roduce/cull out within 15 day:
+f the documents have not alread
+been produced
+Not addressed at hearing; catch
+all
+12/5/17 Tr. 229:18-20
+12/5/12 Tr. 229:21-24
+12/5/17/Tr. 229:25-231:5
+12/5/17 Tr. 231:6-9
+Deferred. Not to be mentioned
+during opening statement.
+12/5/17 Tr. 231:10-18
+Sustained
+12/5/17 Tr. 231: 19-20
+Sustained
+Not addressed at hearing
+12/5/17 Tr. 231:21-232:4
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing
+Not addressed at hearing; no
+objections
+Not specifically addressed at
+earing but duplicative to Exhibi
+No. 115 and those rulings are
+incorporated herein
+
+
+* Exhibit Description
+131. Jeffrey Epstein's NY State Online Sex Offender
+Registry Profile
+Epstein's
+Objections
+3,4, 7,8
+Court's Ruling
+Not specifically addressed at
+hearing, but deferred with Exhibit
+132. New York Post article: Billionaire Jeffrey
+Epstein: I'm a sex offender, not a predator,
+3, 4, 7,8
+12/5/17 Tr. 232:5-235:9
+133. Any and all responses to Subpoenas Duces Tecum
+3, 4, 6, 7, 8, 10,
+Not addressed at hearing; catch
+with or without deposition?
+11, 12, 13, 14
+134. All Interrogatories and Answers thereto, Requests
+3, 4, 7, 8, 12, 13
+Not addressed at hearing; catch
+to Produce and Responses, Requests for
+all,
+Admissions and Responses thereto.
+135. Any and all documents produced in this action.
+136. Any and all depositions taken in this action.
+12
+12,13
+137. Any documents or other exhibit attached to or
+12,13
+used during any deposition in this action
+138. Any and all exhibits, documents, etc. referred to
+12/13
+in any deposition
+139. Any and all documents and exhibits designated by
+12,13
+all parties to this action.
+140. Any and all exhibits needed for impeachment or
+112
+rebuttal
+141. Any and all pleadings filed in this action
+12,13
+142.
+Any and all records produced or that will be
+712,13
+produced by all records custodians relative to this
+action
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+Not addressed at hearing; catch
+Not addressed at hearing; catch
+all
+Not addressed at hearing; catch
+Not addressed at hearing; catch
+DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this.
+day of January, 2018.
+16
+THE HONORABLED
+CIRCUIT COURT JØDGE
+" In his December 7, 2017, Second Amended Exhibit List,
+has shifted Exhibit Nos. 133
+through 142 to Exhibit Nos. 209 through 218.
+has also identified new exhibits at Exhibit
+Nos. 133 through 208. This Order does not make any rulings on the new exhibits which may be subject
+to a new Motion in Limine as Epstein deems appropriate.
+14
+
+
+Copies provided to:
+SERVICE LIST
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Nichole J. Segal
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Ft. Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+mare @nuriklaw.com
+Counsel for Defendant Scolt Rothstein
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+igoldberger@agwpa.com
+smahonev@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+WOT
+Scott J. Link
+Kara Berard Rockenbach
+Angela M. Many
+Link & Rockenbach, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, FL 33401
+Scout@linkrocklaw.com
+Kara@linkrocklaw.com
+Angela@linkrocklaw.com
+Tina@linkrocklaw.com
+Troy@linkrocklaw.com
+Tanya@linkrocklaw.com
+Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.receipt.json b/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a835f0e9975b5487b74856180b03947ee254fb78
--- /dev/null
+++ b/vision-fixhub/court-02/05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -870,
+  "dataset": "marble-joined",
+  "doc_id": "05fa112689cd1534e2c8ab79864776826363dda11215c52feef129c262ac8458",
+  "engine": "marble-apple-vision",
+  "event_count": 34,
+  "fix_ids": "[\"epstein_legal.bates-stamp.digits-only\", \"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "40794964061518c49fabfe409a1792b04929a2871cbd2b0ad712fb20c7406419",
+  "output_sha256": "860a357790583a51234553e56bd230e188a9bf03826c7f186d3fd0439fb4e163",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/05fbce224a07500292347ba0fdbc02c041448bb20f7134fc71acefacd16701e3.md b/vision-fixhub/court-02/05fbce224a07500292347ba0fdbc02c041448bb20f7134fc71acefacd16701e3.md
new file mode 100644
index 0000000000000000000000000000000000000000..535aa0de26b5004bed28aba39c326e1cf6f7c61b
--- /dev/null
+++ b/vision-fixhub/court-02/05fbce224a07500292347ba0fdbc02c041448bb20f7134fc71acefacd16701e3.md
@@ -0,0 +1,1707 @@
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 1 of
+
+63
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 2 of
+Page 1
+THE UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO.
+08-80736-CIV-MARRA
+COPY
+IN RE: JANE DOE,
+Plaintiff,
+VS.
+UNITED STATES OF AMERICA,
+Defendant.
+_'
+Federal Courthouse
+West Palm Beach, Florida
+July 11, 2008
+10:15 a.m.
+The above entitled matter came on for
+Emergency Petitioner for Enforcement of Crime Victim
+Rights before the Honorable Kenneth A. Marra,
+pursuant to Notice, taken before Victoria Aiello,
+Court Reporter, pages 1-32.
+For the Plaintiff:
+Esquire
+For the Defendant: Dexter Lee, AUSA
+Maria Villafana, AUSA
+OFFICIAL REPORTING SERVICES, LIC
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 3 of
+34
+2
+1
+2
+3
+(Call to Order of the Court).
+THE COURT: Good morning. Please be seated.
+This is the case of In Re: Jane Doe, Case
+4 Number 08-80736-Civ-Marra. May I have counsel state
+5
+their appearances, please?
+6
+MR. LEE: Good morning, Your Honor. May it
+7
+8
+please the Court, for the United States of America,
+we have Maria Villafana, Assistant United States
+10
+11
+9 Attorney and Dexter Lee, Assistant United States
+Attorney. And we have seated in the front row FBI
+Special Agent Becker Kendall and Jason Richards.
+12
+Thank you, Your Honor.
+13
+MR.
+: Good morning, Your Honor. Brad
+14
+on behalf of the petitioners. Petitioners
+15
+are also in the courtroom today. This petition is
+16
+styled on her behalf.
+17
+18
+THE COURT: Good morning. All right. We're
+here on the petitioner's motion to enforce her
+19 rights as a victim under 18 USC 3771. I have
+20 received the petition, the government's response and
+21
+the victim's reply, which was filed, I guess, this
+22 morning. So, You want to proceed, counsel?.
+23
+MR.
+: Yes, Your Honor. You prefer me
+24
+at the podium?
+25
+THE COURT: It is easier for us to hear you.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 4 of
+34
+3
+1
+MR.
+: Your Honor, as a factual
+2
+3
+background, Mr. Epstein is a billionaire that
+sexually abused and molested dozens and dozens of
+4
+girls between the ages of 13 and 17 years old. And
+5
+through cooperating victims, that evidence can be
+6
+proven.
+Because of his deviant appetite for young
+girls, combined with his extraordinary wealth and
+8
+power,
+he may just be the most dangerous sexual
+9 predator in U.S. history. This petitioner is one of
+10 the victims and she is in attendance today. Another
+11
+one of Mr. Epstein's victims is also in attendance
+12
+13
+today. She would be able to provide evidence that
+she provided-- that Mr. Epstein paid her to provide
+14
+him over 50 girls for the purposes of him to
+15
+sexually abuse. Therefore, the undercurrents of the
+16 petition are clear. The plea bargain that was
+17
+worked out for Mr. Epstein in light of the offenses
+18 that he committed is clearly unfair to the point
+19 that if anybody looks at the information, it is
+20 unconscionable.
+21
+THE COURT: Well, I mean, is that for me?
+22 That's not my role. That's the prosecutor's role to
+23
+apply, would it not? I can't force them to bring
+24
+criminal charges. What do I have to do with that.
+25
+MR.
+: Okay.
+
+
+Case 9:08-cV-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 5 of
+34
+Page 4
+1
+THE COURT: That may be your opinion, that
+2
+3
+may be your client's opinion, but I presume that the
+government is aware that that's your client's
+4
+5
+opinion. How does that change anything?
+MR.
+: That's my problem. I'm not
+6
+sure that the government is aware that is
+7
+petitioner's opinion and that's why we're here
+8
+today, just to enforce the victim's rights under 18
+9
+USC 3771, Crime Victims Rights Act, and all we are
+10
+asking is to order that the plea agreement that has
+11
+been negotiated in this case--
+12
+THE COURT: How do you know there is a plea
+13
+14
+agreement? The plea agreement is with the State of
+Florida, wasn't it?
+15
+16
+17
+MR.
+: There was a state charge with
+one victim that I'm aware of. And the plea
+agreement as to that one victim was 18 months in the
+18
+county jail. But along with that, the Palm Beach
+19
+County Sheriff investigating this case was getting
+20 no action out of the local authorities and sent this
+21 to the FBI.
+22
+THE COURT: It was actually the Palm Beach--
+23 Town of Palm Beach Police, not the Sheriff's Office.
+24
+MR.
+: I'm sorry, Judge. And that's
+25
+why the FBI got involved because Michael Feeter
+
+
+Case 9:08-cV-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 6 of
+34
+Page 5
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+wrote a
+scathing letter to the State Attorney about
+Mr. Epstein receiving preferencial treatment by
+local authorities.
+Before the FBI took the case, they went
+behind the victim's back, and this is our motion,
+without the victim's input and allowing her the
+right to meaningfully confer with the government,
+which is a right that she can assert at this time.
+They worked out a plea deal where if Mr. Epstein
+would plead to this other charge regarding another
+victim in the state court case, they would agree to
+not prosecute him for all of the federal charges of
+what they were aware of in federal court..
+THE COURT: So that's already apparently
+taken place, correct?
+MR.
+: I don't know if it has taken
+place. I'm not sure exactly what stage it is in. I
+know it is supposed to be attached at some point in
+time to a state court plea.
+THE COURT: Hasn't he already plead guilty,
+though?
+MR.
+: If he did plead guilty, it is
+my understanding and belief that the agreement with
+the federal government and with the U.S. Attorney's
+Office wasn't signed on that day. So it is still my
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 7 of
+34
+6
+1 belief, I could be wrong, but that that agreement
+2 hasn't been completed as of this time.
+3
+THE COURT: So let's assume it hasn't been
+4
+completed.
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+MR.
+: Okay.
+Then petitioner would
+like the right to confer with--
+THE COURT: You can go in the conference
+room. We've got the FBI agents, you've got the
+assigned prosecuting attorney. You have got a
+conference room. You've got your client. Go and
+talk. Confer. And then it is up government to
+decide what to do, correct?
+MR.
+: In a way, Your Honor, that's
+very similar to what happened in In Re:
+and PB
+case where there is a plea agreement negotiated and
+then the victim gets the right to confer.
+THE COURT: It's already negotiated. What
+am I supposed to do?
+MR.
+: Order that the agreement that
+was negotiated is invalid and it is illegal as it
+23
+did not pertain to the rights of the victim.
+THE COURT: I can order you into the
+conference room. Then the government can do what it
+24
+chooses. It can agree to prosecute or it can agree
+25
+to going forward with the agreement it had already
+
+
+Case 9:08-cV-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 8 of
+34
+7
+1
+reached and after consulting your client and in
+2
+taking into consideration your client's views,
+3
+decide to go forward anyway. I can't make them
+4
+prosecute him. I can't-- All I can do is, at best,
+5
+say confer with the victim, consider the victim's
+6
+input before you make a decision or reconsider the
+7
+decision you already made in view of the victim's
+8 input, if it is possible for you to do that. So if
+9 I invalidate the agreement, what's the best you can
+10
+get? The right to confer?
+11
+MR.
+: Exactly. That is all we can.
+12
+THE COURT: So why can't you go into the
+13
+conference room now, take as much time as you feel
+14
+you need and confer?
+15
+MR.
+: Judge, at this time I'd like to
+16
+move ore tenus to add the victim that's in the
+17
+courtroom to this conference with the U.S.
+18
+Attorney's Office.
+19
+THE COURT: So is that Jane Doe 2 for
+20
+purposes of this?
+21
+22
+23
+24
+25
+MR.
+: Exactly, Your Honor.
+THE COURT: All right. Let me hear from the
+government then.
+MR. LEE:. Good morning, Your Honor. May it
+please the Court.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 9 of
+34
+Page 8
+1
+Let me update the Court on the status of
+2
+various matters.
+The agreement to defer prosecution
+3
+4
+to the State of Florida was signed and completed by
+December of 2007. Mr. Epstein's attorneys saught a
+higher review within the Department of Justice and
+it took a number of months for that to come to
+7
+fruition. When it came to fruition, he ended up
+8 pleading guilty on June 30, 2008 to two charges in
+9
+state court, and he was sentenced to a term of
+10
+incarceration of 18 months, with another 12 months
+11
+of community control after the completion of his
+12
+sentence, and he is currently incarcerated as we
+13
+speak.
+14
+15
+16
+17
+We have two arguments, Your Honor. First,
+insofar as the right that they claim under
+3771 (a) (5), their right to confer in the case, we
+respectfully submit that there was no case in
+18
+19
+20
+federal court and, indeed, none was contemplated if
+the plea agreement was to be successfully completed,
+since it contemplated the State of Florida sentence
+21
+22
+on the criminal charges.
+So as long as certain
+conditions were met and certain federal interests
+23
+24
+25
+were vindicated, the federal government was
+satisfied that this was an appropriate disposition.
+Insofar as the best effort, Your Honor, we
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 10 of
+34
+Page 9
+1
+2
+have cited the Attorney General's guidelines. The
+guidelines do say that you should normally advise
+3
+victims of plea negotiations and the terms of the
+4
+plea, but they recognize that there are times when
+5
+they may not be appropriate or could cause some harm
+6
+or prejudice, and they set out six factors which are
+7
+to be considered, non-exhaustive factors.
+8
+We have advised, in the declaration of AUSA
+9 Villafana that when the subject of having Mr.
+10
+Epstein concede that he would be convicted of an
+11
+enumerated offense for purposes of a cause of action
+12
+13
+under 18 USC 2255, there was a rather strenuous
+objection from Mr. Epstein's counsel that the
+14
+federal government was inducing some effort to
+15
+16
+17
+either fabricate claims, enhance claims or embellish
+claims and if this agreement ultimately could not be
+consumated, then we'd have a federal prosecution on
+18
+19
+20
+21
+our hands,
+and we did not want to be in a positin of
+creating additional impeachment material.
+I can't say that the stand by Mr.
+that the arguments of inducement in a subsequent
+22 civil action can be made by any criminal victim,
+23 that is true. It is another thing for that
+24
+inducement to have come before the prosecution
+25
+arguing about the credibility and veracity of the
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 11 of
+34
+Page 10
+1
+2
+individual. That was a considerably strong point, in
+essence, in not discussing those terms with the
+3
+victims as might ordinarily be done if those
+4
+considerations did not exist.
+5
+6
+7
+8
+So, first, Your Honor, we believe that
+3771 (a) (5) does not apply.
+THE COURT: Well, what about the language in
+the statute that suggests that a victim can bring a
+9
+claim or seek enforcement of his or her rights under
+10
+the statute before a case is filed? What does that
+11
+refer to?
+12
+13
+14
+15
+16
+17
+MR. LEE: Your Honor, we believe that's a
+venue provision essentially telling an individual if
+there is no exigent case, there is no case of United
+States versus So And So, then you seek to enforce
+your rights, then you can go in and do so in the did
+court where the offense occurred. This is not
+18
+saying, necessarily, that rights exist, but if you
+19
+believe they exist, here is the place where you're
+20
+going to have to lodge it, and the Court will have
+21
+to decide.
+22
+23
+24
+25
+Now, there are certain of the eight rights
+accorded in 3771(a) that could come up before any
+charge is filed. For instance, let's say somebody
+believes that the perpetrator of the crime is going
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 12 of
+34
+Page 11
+1
+to try to harm them or threatened them or
+2 intimidated them into not testifying or cooperating
+3
+with the government and, of course, no indictment
+has been returned. If an individual went to the
+government and believed that the
+• individual had not
+acted appropriately, they can go to the district
+court and say I need to have my rights under
+8
+3771 (a) (1) enforced because those people are
+9
+threatening me, and the government hasn't done
+10
+enough. That would be a situation.
+11
+But we're talking really here about (a) (5),
+12
+which is the right to consult in the case and we
+13
+respectfully submit that there is not case until a
+14
+charge has been filed.
+15
+THE COURT: So, what about the circuit case
+16
+that was actually pending case had to do with a plea
+17
+agreement in a pending case?
+18
+MR. LEE: Yes. The distinction between the
+19
+case and the instant case, Your Honor, is
+20
+21
+this. In
+, they had negotiated with BP
+Petroleum for a plea and it was always contemplated
+22 that there was going to be a federal prosecution.
+23
+The distinction in this case was that there was
+24
+25
+already a pending state prosecution and the
+objective for both sides was to keep it in state
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 13 of
+34
+Page 12
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+court and the federal government's objective was to
+ensure that there were sufficient safeguards in the
+state court proceedings and concessions made by Mr.
+Epstein so that federal interests, particularly a
+cause of action for damages for the victims of the
+sexual exploitation could be preserved. So that's
+the key distinction because there was no federal
+case, there was no federal criminal charge
+contemplate so long as the agreement could be
+reached.
+THE COURT: All right. So they want me to
+invalidate your non-prosecution agreement.
+MR. LEE: Your Honor, we respectfully submit
+that 3771 does not grant authority of this Court to
+do so. In the
+case, for instance, Your Honor,
+there was a plea agreement that was entered into and
+district court, of course, entertained a plea
+agreement and exercised its judicial discretion in
+terms of whether to accept it or not. The victims
+were encouraged to go to district court and say, you
+know, we didn't hear about this. We should have,
+and we object to it for the following reasons. The
+district court take that into account. There is no
+plea agreement before this Court. There will be no
+plea proceedings in this court. That was all done
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 14 of
+34
+Page 13
+1 in state court several weeks ago. So that's another
+2 basis for distinguishing |
+3
+THE COURT: All right. So is there any
+4
+point in conferring with these victims?
+5
+6
+7
+MR. LEE: Your Honor, I will always confer,
+sit down with Jane Doe 1 and 2, with the two agents
+and Ms. Villafana. We'll be happy to sit down with
+8
+them.
+9
+THE COURT: But it wouldn't make any
+10
+difference in terms of the outcome. Would maybe
+11
+give them the benefit of your explanation of why you
+12
+did what you did and why you came to the conclusion
+13
+you did, but it is not going to change your decision
+14
+in any way.
+15
+MR. LEE: If it is going to change, it would
+16
+have to be done at a level higher than mine, Your
+17
+Honor.
+18
+THE COURT: What was-- I didn't understand
+19
+your statement earlier that Mr. Epstein wanted some
+20 kind of review of higher authority within the
+21
+Department in terms of whether or not the federal
+22
+government was going to insist on preserving any
+23
+civil claims.
+24
+25
+MR. LEE: Your Honor, of the agreement was
+consumated by the parties in December of 2007. Mr.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 15 of
+34
+Page 14
+1
+2
+3
+4
+5
+6
+Epstein's attorneys wanted a further review of the
+agreement higher up within the Department of Justice
+and they exercised their ability to do that.
+THE COURT: Meaning? Again, I'm trying to
+understand. He wasn't happy with the agreement that
+he had signed?
+7
+MR. LEE: Basically, yes. And was trying to
+8
+maintain that the agreement should be set aside or
+more favorable terms.
+10
+THE COURT: Now, in terms of -- You don't
+11
+dispute that Jane Doe 1 and 2-- First of all, do you
+12
+have an objection to Jane Doe 2 being added as a
+13
+petitioner in this case?
+14
+MR. LEE: No, I don't.
+15
+THE COURT: I'll grant that request.
+16
+You don't dispute that they're victims
+17
+within the meaning of the Act.
+18
+MR. LEE: It depends to which -- There is one
+19 Jane Doe-- Well, there is one individual who is one
+20 of Mr.
+clients who we do not believe to
+21
+been a victim. If these are SN and CW, then we have
+22
+no objection and I can discuss-- If I may have a
+23 moment, Your Honor.
+24
+Your Honor, thank you. I have been
+25
+corrected. We have no objection.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 16 of
+34
+Page 15
+1
+THE COURT: Okay.
+2
+MR. LEE: We agree they're victims.
+3
+4
+5
+THE COURT: Now, what is your position,
+then, regarding the right of a victim of a crime
+that is potentially subject to federal prosecution
+to be, to have input with the prosecutor, your
+office, before a resolution or decision not to
+prosecute is made? Do you say that there is no
+9 right to confer under those circumstances because
+10
+there is no "case pending" so any decision not to
+11
+prosecute, there is no right to confer but that
+12
+right to confer only is triggered once there is an
+13
+indictment or an information filed?
+14
+15
+MR. LEE: That is correct, Your Honor. The
+Attorney General guidelines which were published in
+16 May of 2005 provide that the rights in 3771(a) (1
+17
+through 8) accrue when a charge is filed in federal
+18
+court. Now, that my change after the
+19 decision. It is under consideration. But that's
+20 the government's position.
+21
+22
+23
+24
+25
+THE COURT: All right. And so -- Are you
+saying all of the rights--
+MR. LEE: Your Honor, some of the rights
+Clearly will only pertain after a charge has been
+filed. The one that pertains to notice of public
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 17 of
+34
+Page 16
+1
+5
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+hearing, public proceedings, though, can't apply
+until there are public proceedings to be had.
+Of course, these guidelines are a floor and
+not a ceiling. They're to be applied with common
+sense. If somebody-- If charges of assault were
+being investigated and somebody would come in and
+say the perpetrator whom you're investigating is
+getting ready to indict has been threatening me,
+following me, and I need help because he or she is
+going to do something bad to me and try to take care
+of me before I can testify in the grand jury, this
+person would not be turned away because a charge
+hasn't been filed yet. Those guidelines would be
+applied with common sense.
+But specifically insofar as a (a) (5), which
+is the right to consult with the attorney for the
+government in the case, that would not accrue until
+there is a days. And, in our view, a case doesn't
+come into being until charges are filed.
+THE COURT: And are there any reported
+decisions that you are aware of where any court has
+found a right to confer before charges are filed?
+MR. LEE: I'm not aware of any, Your Honor.
+THE COURT: All right. Thank you.
+MR. LEE: Thank you, Your Honor.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 18 of
+34
+Page 17
+1
+THE COURT: Counsel?
+2
+3
+4
+5
+MR.
+: I would just like to address
+that
+decision. They're asking you that you
+just simply ignore it because the decision clearly
+was a decision made because as it is a direct result
+6
+7
+of a plea deal being worked out prior to the victims
+being able to speak.
+8
+THE COURT: But there was a pending case,
+9
+though, correct?
+10
+MR.
+: As I understand the decision--
+11
+12
+13
+THE COURT: As I understand the plea deal, it
+was negotiated prior to charges being filed. Then
+there was a filed case and then the court had the
+14
+ability to accept the plea or not. And at that
+15
+16
+17
+18
+19
+point, you would have the ability to entertain or
+assert an objection because you weren't consulted
+about the plea.
+So there was a proceeding or case in which
+you can assert a right to confer. How do you do
+20
+that before a case is filed? How do you enforce the
+21
+government or force the government to consult about
+22
+not filing a case? Every case they have to consult
+23
+with the victim before they decide not to prosecute?
+24
+MR.
+: No, there are limitations. I
+25
+think in my reply I refer to the case of U.S. V.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 19 of
+34
+Page 18
+1
+2
+3
+5
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Rubin where they discussed that very scenario
+stating there at least has to be criminal charges
+contemplate by the government before these rights
+kick in. The rights under (d) (3) and (a) (5), the
+right to confer and the
+case clearly states
+clearly rights under the CBRA apply before
+prosecution is under way. Logically, this includes
+the CBRA establishments of a victim's reasonable
+right to confer with the attorney for the
+government. And, that's read in the plain reading
+of the statutes as well.
+This first case in interpreting it, I think
+it's pretty clear the distinction they're making
+between BP and this case. Is it a distinction
+withoug a real difference in that the court is
+saying you have this right before the case is filed
+which is exactly what we are saying. And the result
+in that case was they filed the case, later let him
+plea out to some sweet deal. And in this case, what
+we have is they avoid that by deciding not to file.
+Either way, you deprive the victim of their right
+before making that decision.
+And the main problem that the court had in
+• as it states, the victims do have rights when
+there is an impact and the eventual sent is
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 20 of
+34
+Page 19
+1
+2
+substantially less.
+Whereas here, their input is
+received after the parties have reached a tentative
+deal.
+Well, the government just stated the deal was
+reached back in October of 2007. However, attached
+to their response is a letter to my client
+6
+petitioner, dated January 10, 2008, after the time
+then counsel just put on the record that the deal
+8
+10
+11
+12
+13
+14
+15
+16
+17
+was already finalized and it starts, the opening
+paragraph talks about whether they wanted the
+victims to have the right to confer. It says, this
+case is currently under investigation. This is
+January 2008. This case has been a lengthy process
+and we request your continued patience while we
+conduct a thorough investigation. Sounds like the
+exact opposite of, we want you to come in and confer
+and let us know what you really feel about this.
+That is our biggest problem with what has
+18
+happened here, is that she just wasn't given a voice
+19
+and if somebody would have heard her, we believe
+20
+there would have been a different outcome. To go
+21
+22
+back into a room right now and talk, after there has
+already been a plea negotiated without Your Honor
+23
+24
+25
+ordering that in this case the plea deal needs to be
+vacated, it is illegal and give her her rights.
+THE COURT: Well, would you agree or not
+OFFICIAL REPORTING SERVICES, LIC
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 21 of
+Page 20
+1
+4
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+that Mr. Epstein plead guilty to the state charges
+probably at least, in part, in reliance upon the
+fact that he had an agreement with the federal
+government they weren't going to prosecute? Would
+you concede that or would would present evidence to
+that effect?
+MR.
+: Of course we would. Yes, of
+course. Sure.
+THE COURT: So you agree that Mr. Epstein is
+now sitting in the Palm Beach County Jail a
+convicted felon serving 18 months of imprisonment,
+at least in material part, because he relied upon
+the government's non-prosecution agreement?
+MR.
+: Yes. I agree that he is sitting
+there because he is guilty and maybe he took the
+plea rather than going to trial and being found
+guilty later in part because of this non-prosecution
+agreement that was worked out behind the other
+19
+victims' backs. I would agree with that.
+20
+THE COURT: So he accepted the State's deal
+21
+in part because he knew he had an agreement from the
+22
+federal government that they weren't going to
+23
+prosecute.
+24
+MR.
+: I presume. I speculate that is
+25
+true.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 22 of
+34
+Page 21
+1
+THE COURT: So you want me now, then, to set
+2
+aside the government's agreement with him because
+3
+there was
+no conferring, yet he has already accepted
+4
+a plea agreement and is sitting in custody, in part,
+5
+in reliance on that agreement. I mean, I can undo
+7
+the agreement
+in your theory, but how do I-- Mr.
+Epstein, in a sense, would then be adversely
+8
+affected by my actions when he acted in reliance
+10
+11
+12
+9
+upon the agreement. How does that work?
+MR.
+: Certainly, we're only asking
+you to vacate the agreement. I understand and your
+point is well taken. And I believe that at that
+13
+14
+point in time his rights may kick in and say, wait,
+I was relying on this other deal so I wouldn't be
+15
+prosecuted for these hundreds of other girls that I
+16
+molested; that I plead guilty over here to the one
+17
+girl that I will admit to molesting. So maybe I can
+18
+get to withdraw my plea. But the last thing he wants
+19
+to do because if he ends up going to trial, I'll be
+20
+in prison for the rest of his life like any other
+21
+person who ever did this crime would be. He could
+22
+23
+24
+have that argument, I guess, but still wouldn't
+really work well for him.
+25
+THE COURT: All right. So you still think I
+should set aside the agreement, require the
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 23 of
+34
+Page 22
+1
+government to confer?
+2
+MR.
+: Work out a plea negotiation
+3
+commensorate with the crimes that he committed and
+4
+that are favorable after they confer with the
+5
+victims. And it is within their discretion. Of
+6
+course, they can decide on their own that, hey, I
+7
+think that the agreement was fair after they have
+8
+talked with the victims. That could happen.
+9 don't know if a reasonable person that would do
+10
+that, but it could happen.
+11
+THE COURT: Apparently, you are not
+12
+suggesting that that these person are not
+13
+reasonable.
+14
+MR.
+: I'm suggesting they haven't
+15
+conferred with the victims and that if they took
+16
+into consideration what these two in the courtroom
+17
+have to say, I don't think that we'd be in this same
+18
+19
+20
+21
+22
+23
+24
+25
+position right now.
+THE COURT: They have never spoken to your
+client about what happened to them?
+MR.
+: They have spoken to them about
+what happened. Maybe not about what the girls
+wanted to happen as a result of this case, which is
+part of conferring to decide that these girls wanted
+money on their own, which is basically what this--
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 24 of
+34
+Page 23
+this non-prosecution agreement entails that has
+language that he'll agree to liability in a civil
+case. That's not what these girls-- They want
+justice. They want him in prison now more than
+ever. The reason they stated they kept this
+agreement from the girls and they basically conceded
+we didn't tell the girls about this agreement, well,
+8
+the reason is because they would have objected and
+9 they wouldn't have been able to sign off on this and
+10
+the victims would have had a voice, and we'd still
+11
+been going through litigation. The exact problem
+12
+they tried to prevent, at least in their terms which
+13
+was the impeachment of these girls at a later trial,
+14
+is still available to anybody once the civil suits
+15
+are filed anyway.
+16
+They have three arguments. One, we didn't
+17
+have to talk to them. Iwo, we did talk to them sort
+18
+of. And if you don't buy that, the reason we didn't
+19
+talk to them, we were trying to prevent them from
+20
+being impeached later. None of them trump the
+21
+victims' rights to confer prior to plea
+22
+negotiations. That's why, Your Honor, we would ask
+23
+this Court to enter an order vacating that previous
+24
+plea agreement as illegal, ask them to confer with
+25
+the victims once again or for the first time and
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 25 of
+Page 24
+1
+work out a negotiated plea to that accord.
+2
+THE COURT: Well, all you can ask them to do
+3 is confer. I can't ask them to do anything beyond
+4
+that. I mean, it is up to them to negotiate.
+5
+MR.
+: I wouldn't quarrel with that.
+6
+THE COURT: Now, having learned today, I
+7
+guess, that the agreement was signed when, in
+8
+October?
+9
+10
+11
+12
+13
+14
+15
+16
+MR.
+: October 2007, I heard.
+THE COURT: About eight or nine months ago,
+is there any need to rush to a decision in this
+matter? The decision has already been made. You
+filed this, I think, on the presumption that the
+agreement was about to take place and you wanted to
+be able to confer beforehand and you weren't sure
+what was going on.
+17
+MR.
+: Precisely, Your Honor. And I'm
+18
+holding the letters that are exhibits that they were
+19
+writing to my client during the year of 2008 telling
+20
+her how lengthy of a process this was going to be
+21
+and be patient. So, right, I was completely in the
+22 dark about when this agreement was signed.
+23
+THE COURT: In view of the fact that this
+24
+25
+agreement has already been consumated, and you want
+me to set it aside, as opposed to something that's
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 26 of
+Page 25
+1
+about to occur, would you agree that-- and I have
+2
+done this very quickly because of the petition and
+3
+your allegation that something was about to happen.
+4
+I'm not blaming you.
+5
+MR.
+: I was mistaken.
+6
+THE COURT: I'm not blaming you for doing
+7 that. In view of what you know now, is there any
+8
+9
+need to treat this as an emergency that has to be
+decided by tomorrow?
+10
+12
+13
+14
+15
+MR.
+: I can't think of any reason in
+light of what we just heard.
+THE COURT: Mr. Lee, do you have anything
+else you wanted to add? Does either side think I
+need to take evidence about anything? If I do,
+since this is not an emergency anymore, I can
+16
+17
+18
+probably find a more convenient time to do that. I
+don't have the time today to take evidence. But if
+you do believe that I should take evidence on this
+19 issue.
+20
+MR.
+: It may be best if I conferred
+21
+with the U.S. Attorney's Office on that and we can
+22
+make a decision whether it is necessary or whether
+23 Your Honor deemed it was necessary for you to make a
+24
+decision.
+25
+THE COURT: I want to know what your
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 27 of
+34
+Page 26
+1
+respective positions are because it may be something
+in terms of having a complete record, and this is
+going to be an issue that's it going to go to the
+Eleventh Circuit, may be better to have a complete
+record as to what your position is and the
+government's is as to what actions were taken. And
+I don't know if I have enough information, based on
+Ms. Villafana's affidavit or I need additional
+9 information. And because it is not an emergency, I
+10
+don't have to do something quickly, we can play it
+11
+be ear and make this into a more complete record for
+12
+the court of appeals.
+13
+MR.
+: If there is a time where it is
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+necessary to take evidence, Your Honor is correct in
+stating that it is not an emergency and it doesn't
+need to happen today. And, I will confer with the
+government on this and if evidence needs to be
+taken, it be taken at a later date. It doesn't seem
+like there will be any prejudice to any party.
+THE COURT: Mr. Lee, do you have any
+thoughts? You want to consult with Mr.
+?
+MR. LEE: There may be a couple of factual
+matters that I need to chat with petitioner's
+counsel on. If we can reach agreement on those as
+to what was communicated to CW and what time, if
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 28 of
+34
+Page 27
+1
+they don't dispute that, then we don't think it will
+2 be necessary to have an evidentiary hearing. But if
+we can agree, fine or maybe we can't. We'll talk
+4
+about it.
+5
+THE COURT: All right. So why don't you let
+me know if you think an evidentiary hearing is
+7
+necessary. If there are additional stipulations you
+8
+want to enter into or supplement what has already
+10
+9 been presented, you can do that.
+Now, the other issue I want to take up,
+11
+12
+13
+14
+15
+16
+17
+though, is the government filed its response to the
+petition under seal. And so I want to know why.
+What is in there that at this point needs to be
+under seal? Is there anything in there that's
+confidential, privileged, anything that's different
+from what you hve said here in open court that
+requires that to be sealed?
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEE: Well, Your Honor, on our motion to
+seal was based on two reasons. One that dealt with
+individuals or minors at the time that the offense
+occurred.
+So we were attempting to protect the
+privacy of those individuals. And also it dealt
+with negotiations with Mr. Epstein which were in the
+nature of plea negotiations, which we treat as
+confidential. Normally, they're not aired out in
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 29 of
+34
+Page 28
+1
+open court. So those were our two reasons.
+2
+THE COURT: All right. But I guess the
+3
+letters you attached only related to Mr.
+4 client.
+5
+MR. LEE: Three of them, yes, Your Honor.
+6
+THE COURT: Are you prepared, Mr.
+7
+to waive any issues regarding the release of those
+8 documents that relate to your clients?
+9
+MR.
+: Judge, I think it would be
+10
+appropriate to redact the names of the clients as
+11
+they have done.
+12
+THE COURT: I don't think the names are in
+13
+there.
+14
+MR.
+: I think they're redacted.
+15
+They're blacked out. I have no problem with
+16
+releasing those documents. I'm not sure that's part
+17
+of the deal. But if it is--
+18
+19
+20
+21
+22
+23
+24
+25
+MR. LEE: It is.
+MR.
+_: Okay. I'll waive.
+THE COURT: You really don't have any
+objection to those letters that were sent to them
+being released to the public?
+MR.
+: Of course not, Judge.
+THE COURT: Then what is there about the
+plea agreement or the negotiations that is in the
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 30 of
+34
+Page 29
+1
+2
+response that we really haven't already kind of--
+MR. LEE: Your Honor, there was a
+3
+4
+confidentiality agreement in the deferral of
+prosecution to the State of Florida. So we were
+5
+6
+trying to maintain the confidentiality of the
+negotiations that occurred since we had discussions
+7
+during those negotiations as one of the reasons why
+8
+9
+10
+11
+we decided not to tell all of the individuals what
+was going on.
+THE COURT: But is that still necessary,
+that confidentiality or is that kind of moot at this
+12
+point?
+13
+14
+15
+MR. LEE: Well, we would like it sealed.
+Admittedly, what happened today in open court has
+probably weakened our argument. I don't dispute
+16 that.
+17
+18
+19
+20
+21
+22
+23
+24
+25
+THE COURT: In your opinion, anything in
+particular, any paragraph in the response or in Ms.
+Villafana's affidavit that you think is particularly
+troublesome that should remain under seal?
+MR. LEE: May I have a moment, Your Honor?
+THE COURT: Yes.
+MR. LEE: Thank you. Your Honor, one aspect
+of this in the notification letters that were
+dispatched to individuals which were attached to Ms.
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 31 of
+Page 30
+1
+Villafana's declaration, there is a citation to a
+2
+clause in the agreement that was reached regarding
+3
+the damages remedy under 18 USC 2255 that was
+4
+subject to the constitutionality agreement, we
+5
+believe that should still remain confidential.
+6
+THE COURT: But hasn't the fact that this
+7
+8
+provision was part of the agreement again been
+aired? Is there any secret to it anymore?
+9
+10
+MR. LEE: The actual text of it has not been
+aired. The existence of it has been heard but the
+11
+actual text has not and we believe it should still
+12 remain confidential.
+13
+THE COURT: Okay. Any other argument on
+14
+15
+16
+17
+18
+that issue?
+MR. LEE: No, Your Honor. Thank you.
+THE COURT: Ms. Villafana wants to speak to
+you.
+MR. LEE: Your Honor, one item that I'd like
+19
+to bring to the Court's attention. We had advised
+20 Mr. Epstein and his attorneys that if we were to
+21
+22
+dislose some of the agreement, we would give them
+advance notice and ability to lodge an objection. We
+23
+24
+would like an opportunity to do that.
+THE COURT: All right. But you're not
+25
+disclosing. It would be by my order that it would
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 32 of
+Page 31
+1
+be disclosed.
+2
+3
+MR. LEE: Yes, Your Honor. And we just would
+like to register that we believe it should remain
+4
+confidential.
+5
+THE COURT: All right.
+6
+7
+MR.
+: Your Honor, I don't see any
+authority for keeping that under seal.
+8
+THE COURT: I agree. The fact that there is
+9 this preserved right on behalf of the victims to
+10
+11
+pursue a civil action
+is already a matter of public
+record; the exact text of the clause-- I don't see
+12
+that disclosing the text of the clause when the fact
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+that the Clause exists is already a matter of public
+record. It is not harmful in any way to Mr. Epstein
+or the government and the letters to the victim that
+the victim can disclose those letters, they're not
+under any confidentiality obligation or restriction
+and they're free to disclose it themselves if they
+choose to. So I don't see that there is any real
+public necessity to keep the response sealed in view
+of what we discussed already on the record and the
+victim's ability to disclose those provisions of
+their own choosing, if they wish. So, in view of
+the public policy that matters filed in court
+25
+proceedings should be open to the public and sealing
+
+
+Case 9:08-cV-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 33 of
+Page 32
+1
+should only occur in circumstances that justife the
+need to restrict public access, I'm going to deny
+the motion to seal the response and allow that to be
+viewed.
+4
+5
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+All right. So I'll let both of you confer
+about whether there is a need for any additional
+evidence to be presented.
+Let me know one way or
+the other. If there is, we'll schedule a hearing.
+If there isn't and you want to submit some
+additional stipulated information, do that, and then
+I'll take care of this in due course.
+MR.
+: Thank you, Your Honor.
+THE COURT: All right.
+MR. LEE: Thank you, Your Honor.
+MS. VILLAFANA: Thank you, Your Honor.
+THE COURT: You're welcome.
+(Proceedings concluded.)
+OTT
+OFFICIAL REPORTING SERVICES,
+(954)
+467-8204
+
+
+Case 9:08-cv-80736-KAM Document 361-63 Entered on FLSD Docket 02/10/2016 Page 34 of
+Page 33
+1
+2
+3
+4
+5
+6
+7
+8
+9
+I hereby certify that the foregoing is true
+and correct to the best of my ability.
+virenthalle
+Victoria Aiello, Court Reporter
+OTT
+OFFICIAL REPORTING SERVICES,
+(954)
+467-8204
\ No newline at end of file
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diff --git a/vision-fixhub/court-02/06015a4e14975d888e0fe26ba7a37e05386d80540eff1db564c232dd2e54a499.md b/vision-fixhub/court-02/06015a4e14975d888e0fe26ba7a37e05386d80540eff1db564c232dd2e54a499.md
new file mode 100644
index 0000000000000000000000000000000000000000..3477f783d55dec71ac31dfbd167b09ffa4399de6
--- /dev/null
+++ b/vision-fixhub/court-02/06015a4e14975d888e0fe26ba7a37e05386d80540eff1db564c232dd2e54a499.md
@@ -0,0 +1,33 @@
+Case 9:08-cv-80736-KAM Document 356 Entered on FLSD Docket 01/21/2016 Page 1 of 2
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE I AND JANE DOE 2,
+Petitioners.
+VS.
+UNITED STATES OF AMERICA,
+Respondent.
+ORDER GRANTING UNOPPOSED MOTION TO AMEND SCHEDULING ORDER
+This matter is before the Court upon respondent's Unopposed Motion to Amend
+Scheduling Order. It is hereby ORDERED AND ADJUDGED;
+1. The motion (DE 355) is GRANTED.
+2. Petitioners shall file their motion for summary judgment addressing whether a
+violation of the CVRA occurred by February 10, 2016.
+3. The Government shall file its response to Petitioners' motion for summary judgment,
+and its own cross-motion for summary judgment, by March 24, 2016.
+4. Petitioners shall file their reply to the Government's response to Petitioners' motion
+for summary judgment, and their response to the Government's cross-motion for summary
+judgment, by April 12, 2016.
+5. The Government shall file its reply to Petitioners' response to the Government's
+cross-motion for summary judgment by April 26, 2016.
+6. In the event the Court finds that a disputed issue of fact precludes the granting of
+
+
+Case 9:08-cv-80736-KAM Document 356 Entered on FLSD Docket 01/21/2016 Page 2 of 2
+summary judgment, the Court will schedule an evidentiary hearing at a later date.
+DONE AND ORDERED in l
+Florida, this 21" day of January, 2016.
+at West Palm Beach, Palm Beach County,
+KENNETH A. MARRA
+United States District Judge
+2
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+}
diff --git a/vision-fixhub/court-02/0604b6b84e2c58c030067359d89c1d54e630368a14c6b7dcbbc9884c6e950084.md b/vision-fixhub/court-02/0604b6b84e2c58c030067359d89c1d54e630368a14c6b7dcbbc9884c6e950084.md
new file mode 100644
index 0000000000000000000000000000000000000000..13048cd91cd7f957e0c540b13ef92316ade79b80
--- /dev/null
+++ b/vision-fixhub/court-02/0604b6b84e2c58c030067359d89c1d54e630368a14c6b7dcbbc9884c6e950084.md
@@ -0,0 +1,60 @@
+IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA
+FOURTH DISTRICT, 110 SOUTH TAMARIND AVENUE, WEST PALM BEACH, FL 33401
+June 19, 2018
+CASE NO.: 4D18-0762
+L.T. No.:
+5802009CA040800XXXMB
+AG
+JEFFREY EPSTEIN
+v. SCOTT W. ROTHSTEIN, individualy and
+, individually
+Appellant / Petitioner(s)
+Appellee / Respondent(s)
+BY ORDER OF THE COURT:
+ORDERED that the court sua sponte vacates the order entered on April 27, 2018, in
+its entirety. After entry of the order and upon being advised petitioner filed a motion for
+rehearing of the denial of appellate fees, Judge Forst recused himself from the case because
+of matters transpiring after the order was entered. Judge Kuntz was randomly assigned to the
+panel for this case and has fully reviewed the appellate filings and record for this case.
+FURTHER ORDERED that that the petition for writ of mandamus is dismissed as moot.
+Although petitioner correctly asserted that the entire action was not "at issue" within the
+meaning of rule 1.440 when the prior notice for trial was filed, the trial date at issue has
+passed, and respondent has filed a new notice for trial; further,
+ORDERED that this Court's March 29, 2018 order staying the setting of a trial date is
+discharged. The trial court may set a trial date within the time set forth in rule 1.440(c) from
+the March 20, 2018 notice for trial. No motion for rehearing will be entertained; further,
+ORDERED that petitioner's March 19, 2018 request for oral argument is denied;
+further,
+ORDERED that petitioner's March 19, 2018 motion for appellate attorneys' fees and
+costs is denied; further,
+ORDERED that respondent's March 19, 2018 motion for appellate attorneys' fees is
+denied. FURTHER ORDERED that the petitioner's May 14, 2018 motion for rehearing of
+denial of petitioner's motion for appellate fees and costs is denied.
+CIKLIN, CONNER and KUNTZ, JJ., concur.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK. 6/19/2018 9:50:24 AM
+
+
+- AX
+Served:
+CC:
+Kara Berard Rockenbach
+Jack Alan Goldberger
+* Clerk Palm Beach
+John Scarola
+Nichole J. Segal
+Hon. Donald W. Hafele
+di
+Philip M. Burlington
+Rachel Jenny Glasser
+Os
+Weineble
+LONN
+WEISSBLUM,
+Clerk
+Fourth
+District Court of Appeal
+F
+FLORIDA
+NOTA
+CERTIF
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK. 6/19/2018 9:50:24 AM
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diff --git a/vision-fixhub/court-02/0652c9d6f0b895d55b6766f30889c2f856ee14b834aa856a0c30e8cce5c80830.md b/vision-fixhub/court-02/0652c9d6f0b895d55b6766f30889c2f856ee14b834aa856a0c30e8cce5c80830.md
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@@ -0,0 +1,85 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff(s),
+FILED
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+BOCK. CLERK
+Defendant (s).
+/
+I SUPPLEMENTAL RESPONSE TO REQUEST TO PRODUCE
+Defendant/Counterplaintiff,
+J. Edwards, by and through his undersigned
+attorneys, files this supplemental response to the following request of Epstein:
+All emails, data, correspondence, and similar documents dated April 1, 2008
+through August 1, 2010 by and between
+J.
+Marc Nurik, Cara
+Martining Carey Epstein in any way; (d) the us. Attorney ng regarding to
+State Attorney's Office, (c) the Federal Bureau of Investigation, (d)
+I, and (e) any other news employees or reporters.
+Supplemental Response:
+Except as previously delivered to Epstein's counsel or specifically identified on
+the previously delivered privilege log, no additional documents responsive to Epstein's
+request are in
+possession, custody or control.
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Supplemental Response to Request to Produce
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+Electronic and U.S. Mail to all Counsel on the attach
+d list, this & day of June, 2012.
+(561) 383-9451
+Attorney for
+CERTIF
+J. Edwards
+NOT A
+NOT A
+2
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+} Supplemental Response to Request to Produce
+COUNSEL LIST
+Esquire
+, Jaffe, Weissing,
+, Fistos &
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+Marc S. Nurik, Esquire
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954) 745-5849
+Fax: (954) 745-3556
+Tonja Haddad Coleman, Esquire
+Law Offices of Tonja Haddad, P.A.
+CERTIFIED
+524 S Andrews Avenue, Suite 200N
+Fort Lauderdale, FL 33301
+Phone: (954) 467-1223
+Fax: (954) 337-3716
+Lilly Ann Sanchez, Esquire
+Thé L-S Law Firm
+1441 Brickell Avenue, 15th Floor
+Miạmi, FL 33131
+Phone: (305) 503-5503
+Fax: (305) 503-6801
+COPY
+3
diff --git a/vision-fixhub/court-02/0652c9d6f0b895d55b6766f30889c2f856ee14b834aa856a0c30e8cce5c80830.receipt.json b/vision-fixhub/court-02/0652c9d6f0b895d55b6766f30889c2f856ee14b834aa856a0c30e8cce5c80830.receipt.json
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index 0000000000000000000000000000000000000000..b1ab3472a2507152fee16693c2700887f35d3d88
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diff --git a/vision-fixhub/court-02/06840df23a740016a075abfd49e28c086fd9dc8b50952628362a5e92d47a1641.md b/vision-fixhub/court-02/06840df23a740016a075abfd49e28c086fd9dc8b50952628362a5e92d47a1641.md
new file mode 100644
index 0000000000000000000000000000000000000000..5d6a314bca503e50aa529963cbc2d4222d542df4
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+++ b/vision-fixhub/court-02/06840df23a740016a075abfd49e28c086fd9dc8b50952628362a5e92d47a1641.md
@@ -0,0 +1,84 @@
+Electronically Filed 10/02/2013 11:28:04 AM ET
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually,
+Defendant/Counter-Plaintiff.
+Case No. 50 2009 CA 040800XXXXMBAG
+NOTICE OF FILING EXHIBITS
+Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned
+counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby
+files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for
+Summary Judgment on Defendant/Counter-Plaintiff
+Fourth
+Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously
+filed and accepted by the Palm Beach County, Florida Civil Division Filing # 5846906.
+The files accompanying this Notice of Filing Exhibits were previously filed on September
+26, 2013 at 8:36PM, but moved to Pending Queue, Filing Reference Number: # 584947.
+The attached exhibits follow in order of their attachment to the Motion in compliance with
+Rule 2.516 of the Florida Rules of Judicial Administration as to the size of files served on
+opposing counsel. The start of each new exhibit is marked on the bottom of the first page
+of said exhibit.
+
+
+Epstein v. Rothstein, et al.
+WE HEREBY CERTIFY that a true and correct copy of the foregoing was
+served, via electronic service, to all parties on the attached service list, this October
+2, 2013.
+Is/ Tonja Haddad Coleman
+Tonja Haddad Coleman, Esq.
+Florida Bar No.: 176737
+Tonja Haddad, PA
+5315 SE 7* Street
+Suite 301
+NOT A CERTIF an
+Fort Lauderdale, Florida 33301
+954.337.3716 (facsimile)
+2
+
+
+Epstein v. Rothstein, et al.
+SERVICE LIST
+CASE NO. 502009CA040800XXXXMBAG
+jsx@searcylaw.com; mep@searcylaw.com
+Searcy Denney Scarola et al
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+Jack Goldberger, Esq.
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+COPY
+Suite 1400
+West Palm Beach, FL 33401
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+J.
+, Esq.
+brad@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301
+ERTIFIED
+_ Fistos Lehrman
+Fred Haddad, Esq.
+Dee@FredHaddadLaw.com
+1 Financial Plaza
+Suite 2612
+Fort Lauderdale, FL 33301
+Tonja Haddad Coleman, Esquire
+Tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Law Offices of Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Attorneys for Jeffrey Epstein
+3
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "240c265eec1c088d5e6f4eb67cd66bc462b69001a706324b7d5e1443dfd21f4c",
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diff --git a/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.md b/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.md
new file mode 100644
index 0000000000000000000000000000000000000000..8fac253d8dabe8ddddee9b9392b8bb55475ae459
--- /dev/null
+++ b/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.md
@@ -0,0 +1,601 @@
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. ***
+Electronically Filed 10/11/2013 04:08:28 PM ET
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+CASE NO.: 502009CA040800XXXXMBA
+JUDGE:
+DAVID
+VS.
+SCOTT ROTHSTEIN,
+individually,
+J.
+individually,
+Defendants/Counter-Plaintiff,
+COPY
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS
+MOTION TO STRIKE AND FOR SANCTIONS
+Plaintiff/Counter-Defendant Jeffrey
+("Epstein"), by and through his
+undersigned counsel and pursuant to Paragraph IV of this Court's Order Setting Jury Trial
+and Directing Pretrial and Mediation Procedures and the Florida Rules of Civil Procedure,
+moves this Court to strike Defendant/Counter-Plaintiff
+")
+below-listed pleadings, prevent use of any of the materials or witnesses at trial, and enter
+an award of sanctions against him for his repetitive and flagrant disregard of the abovecited Rules and failure to comply with this Court's Order. In support thereof, Epstein
+states:
+INTRODUCTION
+This matter is set for Calendar Call before this Court on October 18, 2013. On
+April 2, 2013, this Court entered its Order Setting Jury Trial and Directing Pretrial and
+Mediation Procedures (hereinafter "Order" or "Exhibit A"), a true and correct copy of
+
+
+which is attached hereto as "Exhibit A." Now, on the eve of trial,
+is engaging in
+repeated and flagrant violations of this Court's Order and the Florida Rules of Civil
+Procedure, mandating that all of the below-listed improprieties be stricken and sanctions
+awarded to Epstein. As demonstrated more fully below, these actions prejudice the
+administration of justice, thwart Epstein's ability to timely receive discovery and
+adequately prepare for trial, blatantly violate the Court's Order, and demonstrate
+bad faith in doing so.
+ITEMS TO BE STRICKEN
+unilateral Notice of taking Deposition of Jeffrey Epstein on
+October 21, 2013; after the discovery cutoff date. See Order, "II, H. This date was
+unilaterally set by
+was repeatedly informed by counsel for Epstein that
+counsel was unavailable on that date and that it was outside of the discovery cutoff.
+However, to date he has refused to either cancel it or offer alternative dates. It is
+noteworthy to mention that Epstein was already deposed twice in this matter; once in 2010
+and again in 2012. As such Edwards had more than liberal time within which to properly
+address the issue and take appropriate measures to attempt to take Epstein's deposition
+again, had he chosen to do so.
+The unilateral and untimely Service of a Notice of Taking Deposition of
+| unilaterally served Epstein with a Notice of Taking
+Deposition on October 2, 2013 for a deposition date of October 15, 2013. A true and
+correct copy of the Notice is attached hereto as "Exhibit B." This "witness" is not listed
+anywhere in either party's trial or witness exhibit list and was noticed for deposition after
+the discovery cutoff date. See Order, 9 II, H. After being notified both of the conflict with
+2
+
+
+the date upon which he set the deposition and the fact that this witness does appear
+anywhere in either party's witness list,
+still refuses to cancel the deposition.
+Further, no witness list was amended to include her. This Court's Order mandates that
+names and addresses of all witnesses be provided "120 DAYS PRIOR TO CALENDAR
+CALL" and that names and addresses of all rebuttal witnesses must be provided "60
+DAYS PRIOR TO CALENDAR CALL." See Order, 9 9II B, C (emphasis in original).
+Because she is not listed on a witness list of any kind, there is irrefutably no compliance
+with this Court's Order.
+The untimely filing an Expert Witness list after the deadline that contains
+not one name of an Expert. On September 27, 2013, over three (3) months after the
+deadline date provided in this Court's Order, Edwards filed an Amended Expert Witness
+list, which provides the following: "Experts include all listed attorneys involved in the
+prosecution of civil claims against Jeffrey Epstein arising out of Epstein's serial abuse of
+minor females." A true and correct copy of this Amended Expert Witness List is attached
+hereto as "Exhibit C." Not only does this Court's Order say that Experts must be disclosed
+"120 DAYS PRIOR TO CALENDAR CALL," see Order, 91 II, A (emphasis in original;
+but it also requires that more detailed information be provided in the Notice, as delineated
+in Paragraph II, C of the Order. Such information includes, but is not limited to, the
+subject matter about which the witness will testify, the substance of the facts and opinions
+to which the expert is expected to testify, a summary of the grounds for each opinion, a
+copy of any written reports, and a copy of the expert's curriculum vitae. See Order, 1 II,
+A. While a one sentence summation of these unnamed people's testimony was provided,
+none of the other information was provided. Furthermore, pursuant to Paragraph II, A,
+3
+
+
+is required to provide "names and addresses of all expert witnesses." See Order,
+9 II, A. The flagrant disregard for Pretrial Procedure and this Court's Order is evident, as
+there is not even a proper name on the list.
+The improper service of discovery requests to which responses will be due
+after the discovery cut off date. See Order, 92, H.
+As detailed below, the law mandates that these items be stricken and that sanctions
+be entered against
+for his incessant and premeditated thwarting of the judicial
+process, his utterly disregarding this Court's Order, and ignoring the very riles of conduct
+pursuant to which attorneys are to govern themselves.
+MEMORANDUM OF LAW
+This Court's Order clearly and unequivocally delineates the Pretrial rules and
+parameters within which the parties must adhere. See Exhibit A. Paragraph IV governs
+Noncompliance, and provides: "NONCOMPLIANCE WITH ANY PORTION OF
+THIS ORDER MAY RESULT IN THE STRIKING OF THE CASE, WITNESSES,
+OR EXHIBTS, OR IMPOSITION OF SUCH OTHER SANCTIONS AS ARE JUST."
+(Emphasis in original). See Exhibit A. In the case at hand, there are multiple violations of
+this Court's Order. As evidenced by the attached Exhibits, Epstein has brought these
+violations to
+attention in an effort to remediate the situation without Court
+intervention; to no avail.
+disregard of this Order, coupled with the either
+inapposite or non-existent responses counsel for Epstein has received in response to her
+attempts to resolve these issues, mandate the implementation of the remedies set forth in
+Paragraph IV of the Order and the Florida Rules of Civil Procedure governing discovery
+violations.
+4
+
+
+The law is clear that "[e]xcept in cases of a clear abuse of discretion prejudicial to
+the affected party, trial courts must be allowed to enforce pretrial orders to achieve the
+orderly and efficient administration of justice, fair to all parties." Fla. Marine Enterprises
+1, 632 So. 2d 649, 651-52 (Fla. 4th DCA 1994). Courts have held that "decisions
+regarding the testimony of improperly disclosed witnesses" is placed squarely "within the
+broad discretion of the trial judge, who is vested with the interpretation and enforcement of
+any pretrial order mandating witness disclosure." Id. at 65l. "Florida courts have
+explained that the rules of discovery are intended to avoid surprise and trial by ambush."
+Agrofollajes, S.A. v. E.I. Du Pont De Nemours & Co., Inc., Nos. 3D07-2322, 3D07-2318,
+3D07-1036, 2009 WL 4828975, at (Fla. 3d DCA Deo. 16, 2009); Escutia v. Greenleaf
+Products, Inc., 886 So. 2d 1059, 1062 (Fla. 1st DCA 2004). "The privilege to practice law
+requires attorneys to conduct themselves in a manner compatible with the administration of
+justice." Visoly v. Security Pacific Credit Corp,, 768 So. 2d 482, 492 (Fla. 3d DCA 2000).
+"While counsel does have an obligation to be faithful to their clients' lawful objectives,
+that obligation cannot be used to justify unprofessional conduct by elevating the perceived
+duty of zealous representation over all other duties." Id.
+CONCLUSION
+Based upon the foregoing, Epstein hereby requests that this Court impose sanctions
+against
+for all of his repeated and flagrant violations of this Court's Order and the
+Florida Rules of Civil Procedure; to wit:
+must be prevented from using of any of
+the materials or witnesses at trial, and an award of sanctions entered against him and such
+other relief that this Court deems just and proper.
+5
+
+
+WE HEREBY CERTIFY that a true and correct copy of the foregoing was served,
+via electronic service, to all parties on the attached service list, this October 11, 2013.
+Is/ Tonja Haddad Coleman
+Tonja Haddad Coleman, Esq.
+Florida Bar No.: 176737
+Tonja Haddad, PA
+5315 SE 7* Street
+Suite 301
+Fort Lauderdale, Florida 33301
+954.467.1223
+954.337.3716 (facsimile)
+Attorneys for Epstein
+NOT A CERTIFIED
+
+
+SERVICE LIST
+CASE NO. 502009CA040800XXXXMBAG
+Jack Scarola, Esq.
+jsx@searcylaw.com; mep@searcylaw.com
+Searcy Denney Scarola et al.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+Jack Goldberger, Esq.
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+Suite 1400
+West Palm Beach, FL 33401
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+J.
+Esq.
+brad@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301
+Fred Haddad, Esq.
+Dee@FredHaddadLaw.com
+1 Financial Plaza
+Suite 2612|
+Fort Lauderdale, FI, 33301
+Tonja Haddad Coleman, Esquire
+Tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Law Offices of Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Attorneys for Jeffrey Epstein
+ERTIFIED COPY
+7
+
+
+W. Chester
+Jr.
+W. Chester
+, Іг., Р.А.
+One Clearlake Centre
+Suite 1400
+250 Australian Avenue South
+West Palm Beach, Florida 33401
+wcblaw@aol.com
+wcbeg@aol.com
+NOT A CERTIFIED COPY
+
+
+IN THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, etc., et al.,
+Defendant(s).
+ORDER SETTING JURY TRIAL AND
+DIRECTING PRETRIAL AND MEDIATION PROCEDURES
+COPY
+I. SCHEDULING
+This action is set for jury trial on the eight week calendar beginning October 28, 2013. YOU
+MUST APPEAR AT 9:00 O'CLOCK A.M. ON FRIDAY, October 18, 2013, IN
+COURTROOM 2C, PALM BEACH COUNTY COURTHOUSE, 205 NORTH DIXIE
+HIGHWAY, WEST PALM BEACH, FLORIDA FOR THE CALENDAR CALL. (12 days
+reserved for the trial of this cause).
+The trial will be scheduled sometime during the calendar, at a date and time to be provided at
+the calendar call, subject to the Court ordering a later case setting. The docket ends 12/20/13.
+II. UNIFORM PRETRIAL PROCEDURE
+A. On the last business day no later than 120 DAYS PRIOR TO CALENDAR CALL. the
+parties shall exchange lists of all trial exhibits, names and addresses of all trial witnesses, and names
+and addresses of all expert witnesses.
+B. On the last business day no later than 60 DAYS PRIOR TO CALENDAR CALL, the
+parties shall exchange lists of names and addresses of all rebuttal witnesses.
+C. In addition to names and addresses of each expert retained to formulate an expert
+opinion with regard to this cause, both on the initial listing and on rebuttal, the parties shall provide:
+the subject matter about which the expert is expected to testify;
+the substance of the facts and opinions to which the expert is expected
+to testify;
+3.
+4.
+5.
+a summary of the grounds for each opinion;
+a copy of any written reports issued by the expert regarding this case; and
+a copy of the expert's curriculum vitae.
+
+
+
+Page 1
+9/18
+parties shall confer and:
+D. On the last business day no later open 30 DAYS PRIOR TO CALENDAR CALL, the
+1. discuss settlement;
+2. simplify the issues and stipulate, in writing, as to as many facts and
+issues as possible;
+4 prepare a Pre-Trial Stipulation in accordance with paragraph E; and
+. list all objections to trial exhibits.
+E. PRETRIAL STIPULATIONS MUST BE FILED. It shall be the duty of counsel for the
+—Plaintiff to see that the Pre-Trial Stipulation is drawn, executed by counsel for all parties, and filed
+with the Clerk no later than 20 DAYS PRIOR TO CALENDAR CALL. UNILATERAL
+PRETRIAL STATEMENTS ARE DISALLOWED, UNLESS APPROVED BY THE COURT,
+AFTER NOTICE AND HEARING SHOWING GOOD CAUSE. Counsel for all parties are charged
+with good faith cooperation in this regard. The Pre-Trial Stipulation shall contain in separately
+numbered paragraphs:
+1. a list of all pending motions including MOTIONS IN LIMINE and FRYE
+MOTIONS requiring action by the Court and the dates those motions are
+set for hearing (MOTIONS IN LIMINE and FRYE HEARINGS shall not be
+heard the day of trial or thereafter.)
+2. stipulated facts which require no proof attrial which may be read to the
+trier of fact;
+3. a statement of all issues of fact for determination at trial;
+4. each party's numbered list of trial exhibits with specific objections, if any,
+to schedules attached to the Stipulation;
+5. each party's numbered list of trial witnesses with addresses (including all
+known rebuttal witnesses); the list of witnesses shall be on separate schedules
+attached to the Stipulation;
+6. a statement of estimated trial time;
+7. names of attorneys to try case; and
+8. number of peremptory challenges per party.
+F. FILING OF PRE-TRIAL STIPULATION. Failure to file the Pre-Trial Stipulation or a
+Court Approved Unilateral Stipulation as above provided may result in the case being stricken from
+the Court's calendar at its sounding or other sanctions.
+G. ADDITIONAL EXHIBITS, WITNESSES OR OBJECTIONS. At trial, the parties shall
+be strictly limited to exhibits and witnesses disclosed and objections reserved on the schedules
+archer specials set in the Pre Triad Stipulion or order of the Cour upon go, bause
+
+
+Page 3
+discovery of the exhibit or witness. Use of the exhibit or witness may be allowed by the Court for
+good cause shown or to prevent manifest injustice.
+H. DISCOVERY. Unless otherwise agreed in the Pre-Trial Stipulation, all discovery must
+be completed no later than 10 DAYS BEFORE THE DATE SET FOR CALENDAR CALL,
+absent agreement for later discovery specifically stated in the Pre-Trial Stipulation or for other good
+cause shown.
+1. PRE-TRIAL CONFERENCE. No pre-trial conference pursuant to Fla. R. Civ. P. 1.200 is
+et by the Court on its own motion. If a pre-trial conference is set upon motion of a party, couns
+hall meet and prepare a stipulation pursuant to paragraphs D and E and file the stipulation no late
+than 5 DAYS BEFORE THE CONFERENCE. Failure to request a pre-trial conference in a timely
+fashion constitutes a waiver of the notice of requirement of Rule 1.200. Motions for Summary
+Judgment will not be heard at any pre-trial conference.
+J. UNIQUE QUESTIONS OF LAW. Prior to calendar call, counsel for the parties are
+directed to exchange and simultaneously submit to the Court appropriate memoranda with citations
+to legal authority in support of any unique legal questions which may reasonably be anticipated to
+arise during the trial.
+K. MODIFICATION TO UNIFORM PRE-TRIAL PROCEDURE. Upon written stipulation
+of the parties filed with the court, the Pre-Trial Procedure, except for items II D-F, inclusive, may be
+modified in accordance with the parties' stipulation, except to the extent that the stipulation may
+interfere with the Court's scheduling of the matter for trial or hinder the orderly progress of the trial.
+L. PREMARKING EXHIBITS. Prior to trial, each party shall meet with and assist the clerk
+in marking for identification all exhibits, as directed by the clerk.
+M. DEPOSITION DESIGNATIONS. No later than 20 DAYS PRIOR TO CALENDAR
+CALL, each party shall serve his, her, or its designation of depositions, or portions of depositions
+each intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO
+HI. MEDIATION
+A. All parties are required to participate in mediation.
+. The appearance of counsel who will try the case and representatives of cach par
+rith full authority to enter into a complete compromise and settlement is mandatory. If insurance i
+involved, an adjuster with authority up to the policy limits or the most recent demand, whichever is
+lower, shall attend.
+
+
+Page 4
+2. At least ONE WEEK BEFORE THE CONFERENCE, all parties shall file with
+the mediator a brief, written summary of the case containing a list of issues as to each party. If an
+attorney or party filing the summary wishes its content to remain confidential, he/she must advise the
+mediator in writing when the report is filed.
+3. All discussions, representations, and statements made at the mediation conference
+shall be privileged consistent with Florida Statutes sections 44.102 and 90.408.
+4. The mediator has no power to compel or enforce a settlement agreement. If a
+settlement is reached, it shali be the responsibility of the attorneys or parties to reduce the agreement
+to writing and to comply with Florida Rule of Civil Procedure 1.730(b), unless waived.
+B. The Plaintiff" s attorney shall be responsible for scheduling mediation. The parties should
+agree on a mediator. If they are unable to agree, any party may apply to the Court for appointment of
+a mediator in conformity with Rule 1.720 (f), Fla. R. Civ. P. The lead altorney or party shall file and
+serve on all parties and the mediator a Notice of Mediation giving the time, place, and date of the
+mediation and the mediator's name. The mediator shall be paid $175.00 per hour, unless otherwise
+agreed by the parties.
+C. Completion of mediation prior to calendar call is a prerequisite to trial. If mediation is
+not conducted, or ii a party fails to participate in mediation, the case, at the Court's discretion, may
+be stricken from the trial calendar, pleadings may be stricken, and other sanctions may be imposed.
+D. Any party opposing mediation may proceed under Florida Rule of Civil Procedure
+1,700(b).
+IV. NONCOMPLIANCE
+NONCOMPLIANCE WITH ANY PORTION OF THIS ORDER MAY RESULT IN
+THE STRIKING OF THE CASE, WITNESSES, OR EXHIBITS, OR IMPOSITION OF
+SUCH OTHER SANCTIONS AS ARE JUST.
+DONE AND ORDERED in West Palm Beach, Palm Beach County, Florida this.
+day
+ol April, 2013.
+AR E i 203
+H#FCROW
+DAVID F.
+Circuit Court Judge
+Copies furnishod:
+JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL. 33409
+JACK GOLDRERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401
+J.
+. ESQUIRE, 425 North Andrews Are., Suite 2, Ft. Lauderdale, FL. 33301
+FRED HADDAD. ESQUIRE, One Financial Plaza, Suite 2612, Pt. Lauderdale, FL. 13394
+MARC . NURIK, ESQUIRE, One F. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301
+TONJA HADDAD COLEMAN, ESQUIRE, 315 S.E. 7* St., Suite 301, Ft. Iauderdale, FL 33301
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+vs.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants).
+COPY
+NOTICE OF TAKING DEPOSITION
+TO:
+All counsel on the attached Counsel List
+PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of:
+NAME AND ADDRESS
+DATE AND TIME
+October 15, 2013
+9:30 a.m.
+LOCATION
+Searcy Denney Scarola
+Barnhart & Shipley
+2139 Palm Beach Lakes
+Boulevard
+West Palm Beach, FL 33409
+upon oral examination before Phipps Reporting, a Notary Public; or any other officer authorized
+by law to take depositions in the State of Florida. The oral examination is being taken for the
+purpose of discovery, for use at trial, or for such other purposes as are permitted under the
+applicable Statutes or Rules.
+
+
+
+Notice of Taking Deposition
+Page 2
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 2nd.
+day of October
+2013.
+Jack Scarola,
+foldene
+Secondary E-mail(s): mep@seareylaw.com
+earcy Denney Scarola Barnhart & Shipley, P.J
+139 Palm Beach Lakes Boulevar
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for Bradley J. L
+CC:
+Phipps Reporting
+E-TRANSCRIPT, ASCIL, CD AND/OR DVD REOVESTED
+NOT A
+
+
+Notice of Taking Deposition
+"If you are a person with a disability who needs any accommodation in
+order to participate in this proceeding, you are entitled, at no cost to
+you, to the provision of certain assistance. Please contact
+English, Americans with Disabilities Act Coordinator,
+English,
+at least 7 days before your scheduled court appearance, or immediately
+upon receiving this notification if the time before the scheduled
+appearance is less than 7 days; if you are hearing or voice impaired, call
+711."
+"Si usted
+es una persona minusválida que
+necesita algún
+acomodamiento para poder participar en este procedimiento, usted
+tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda.
+Tenga la amabilidad de ponerse en contacto con
+English,
+Americans with Disabilities Act Coordinator,
+English, por lo
+menos 7 días antes de la cita fijada para su comparecencia en los
+tribunales, o inmediatamente después de recibir esta notificación si el
+tiempo antes de la comparecencia que se ha programado es menos de 7
+días; si usted tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe
+nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen
+pwovizyon pou jwen kèk èd. Tanpri kontakte
+English,
+Americans with Disabilities Act Coordinator,
+English, nan 7
+jou anvan dat ou gen randevou pou parèt nan tribinal la, oubyen
+imedyatman apre ou fin resevwa konvokasyon an si lè ou gen pou w
+parèt nan tribinal la mwens ke 7 jou; si ou gen pwoblèm pou w tande
+oubyen pale, rele 711."
+
+
+Natice of Traking Deposition
+COUNSEL LIST
+William Chester !
+wcblaw.aol.com; webeg@aol.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Esquire
+staff.efile@pathtojustice.com
+Jaffe, Weissing, Edwards, Fistos &
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+рола ото 6 350 2612
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+_ individually, and
+L.M., individually,
+Defendant.
+OP
+COPY
+AMENDED EXPERT WITNESS LIST OF BRADLEY J.
+J.
+, by and through his undersigned attorneys, hereby amends his expert
+witness list for trial as follows:
+Experts include all listed attorneys involved in the prosecution of civil claims against
+Jeffrey Epstein arising out of Epstein's serial abuse of minor females.
+They will testify based upon their background, training, and experience as civil litigators,
+and the personal involvement that each had in prosecuting claims against Jeffrey Epstein, about
+the legal and ethical propriety of the actions taken by|
+in fulfilling his
+obligations to the victims of Epstein's criminal assaults.
+All expert witnesses timely listed by Jeffrey Epstein, subject to
+objections.
+Impeachment and rebuttal witnesses as necessary, without waiving any objections
+thereto.
+
+
+
+adv. Epstein
+Amended Expert Witness List
+Case No.: 502009CA040800XXXXMBAG
+reserves the right to amend this list prior to trial upon proper notice to
+counsel for Jeffrey Epstein.
+1 all Counsel on the attached list, this. 271-
+Plorida Bar No.: 169440
+Primary E-mail: jsx@searcylaw.com
+Seeóndary E-mails): mep@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+NOT A
+NOT A CER
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+2
+
+
+adv. Epstein
+Amended Expert Witness List
+Case No.: 502009CA040800XXXXMBAG
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+COUNSEL LIST
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Esquire
+staff.efile@pathtojustice.com
+Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+haddadim@aol.com
+Fred Haddad, P.A
+One Financial Plaza, Suite 2612
+NOT
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Aftomeys for Scott Rothstein
+Tonja Haddad Coleman, Esquire
+tenjal@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jettrey Epstein
+3
\ No newline at end of file
diff --git a/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.receipt.json b/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a89ff396cc0640146a7e7b3bfe4aae56dfb837af
--- /dev/null
+++ b/vision-fixhub/court-02/06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -354,
+  "dataset": "marble-joined",
+  "doc_id": "06e4dd7c73e9bf7aadf334a616732b8e49d9552068690b3b599a458a64ffd989",
+  "engine": "marble-apple-vision",
+  "event_count": 24,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "60530c44acfc434a0e0885699cf75a8ce8c8b59326807f127e6615221c9d7815",
+  "output_sha256": "2e6bf7f2133c4a714631f68b018d1b795066224cdd4939bccd23eacec3f110b7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.md b/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.md
new file mode 100644
index 0000000000000000000000000000000000000000..a5474fb08289527bbc32a8334dd687f53eb5b26a
--- /dev/null
+++ b/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.md
@@ -0,0 +1,73 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendant(s).
+CIRCUIT CIVIL 4
+PALM BEACH COUNTY.
+12 JAN -9 PM :4:1
+FL
+NOTICE OF SERVING ANSWERS TO PLAINTIFF'S THIRD SET
+OF INTERROGATORIES TO DEFENDANT/COUNTER-PLAINTIFF
+J.
+FILED
+COMES NOW the Defendant/Counterplaintiff, Bradley J.
+by and through his
+undersigned counsel, and hereby files this Notice with the Court that Answers to Plaintiff's Third
+Set of Interrogatories propounded by the Plaintiff, Jeffrey Epstein, on December 9, 2011, have
+been furnished to the attorney for the Plaintiff.
+I HEREBY CERTIFY that a true copy of the foregoing has been furnished by Fax and
+_ day of January, 20X2 to all counsel on the attached/list.
+mortal anch
+'lorıda Bar No.: 16944|
+earcy Denney Scarola Barnhart & Shipley, P.A.
+139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for
+J.
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Answers to Plaintiff's Third Set of Interrogatories to
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+, Jaffe, Weissing,
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos & Lehrn
+nan, PL
+Ackerman, Jr., Esquire
+Burnett, P.A.
+901
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561)-802-9044
+Fax: (561)-802-9976
+ERTIFIED COPY
+Attorneys for Jeffrey Epstein
+Mare S. Nurik, Esquire
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
diff --git a/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.receipt.json b/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..aeb139fbfd26941356e58a00bace3d3bcaf94a8f
--- /dev/null
+++ b/vision-fixhub/court-02/06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "06ec32972465b396b92588907ca4de58d90975c4346314b2066f27a77c65555f",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "98266cc41f45ab33eef348c6a365a40eb9e719cd8fc377d672962d9a286b1018",
+  "output_sha256": "f8aac33d6f63cdfd77df528f20bdc4a301b1b06ab2e3321e27cca87186f67c44",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/073d93864e57f524fd11e2f32f65003660a190dee24636d2e4c48f9768428296.md b/vision-fixhub/court-02/073d93864e57f524fd11e2f32f65003660a190dee24636d2e4c48f9768428296.md
new file mode 100644
index 0000000000000000000000000000000000000000..0686f4fd34e38842ff5e9707981d8c343f918d53
--- /dev/null
+++ b/vision-fixhub/court-02/073d93864e57f524fd11e2f32f65003660a190dee24636d2e4c48f9768428296.md
@@ -0,0 +1,195 @@
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 1 of 7
+
+50
+
+
+Case 9:08-cv-80736-KAM Document 361-50
+Entered on FLSD Docket 02/10/2016 Page 2 of 7
+Villafana, Ann
+From:
+nt:
+CC.
+Subject:
+C. (USAFLS)
+Villafana, Ann
+C. (USAFLS)
+Monday, September 10, 2007 5:23 PM
+Gerald Lefcourt
+Sloman, Jeff (USAFLS); Lourie, Andrew (USAFLS)
+Jeffrey Epstein
+Gerry:
+As per your discussion with U.S. Attorney Acosta, I have attached the Office's written counterproposal. If you
+have any questions regarding its terms, please do not hesitate to call.
+070910 Epstein
+don-Prosecution..
+A.
+Villafaña
+Assistant U.S. Attorney
+500 S. Australian Ave, Suite 400
+West Palm Beach, FL 33401
+Tracking:
+1
+RFP MIA 000058
+
+
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 3 of 7
+Recipient
+Gerald Lefcourt
+Sloman, Jeff (USAFLS)
+Lourie, Andrew (USAFLS)
+Yera, E.J. (USAFLS)
+Read
+Read: 9/10/2007 5:23 PM
+Read: 9/10/2007 10:47 PM
+2
+RFP MIA 000059
+
+
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 4 of 7
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+NON-PROSECUTION AGREEMENT
+IT APPEARING that Jeffrey Epstein (hereinafter "Epstein") has committed offenses against
+the United States from in or around 2001 through in or around October 2005, including:
+(1)
+(2)
+(3)
+(4)
+knowingly and willfully conspiring with others known and unknown to commit an
+offense against the United States, that is, to use a facility or means of interstate or
+foreign commerce to knowingly persuade, induce, or entice minor females to engage
+in prostitution, in violation of Title 18, United States Code, Section 2422(b); all in
+violation of Title 18, United States Code, Section 371;
+knowingly and willfully conspiring with others known and unknown to travel in
+interstate commerce for the purpose of engaging in illicit sexual conduct, as defined
+in 18 U.S.C. § 2423(f), with minor females, in violation of Title 18, United States
+Code, Section 2423(b); all in violation of Title 18, United States Code, Section
+2423(e);
+using a facility or means of interstate or foreign commerce to knowingly persuade,
+induce, or entice minor females to engage in prostitution; in violation of Title 18,
+United States Code, Sections 2422(b) and 2;
+traveling in interstate commerce for the purpose of engaging in illicit sexual conduct,
+as defined in 18 U.S.C. § 2423(f), with minor females; in violation of Title 18,
+United States Code, Section 2423(b); and
+(5)
+in 18 U.S.C. § 1591(c)(I); in violation of Title 18, United States Code, Sections
+IT APPEARING that Epstein has accepted responsibility for his behavior by his signature
+on this Agreement; and
+
+RFP MIA 000060
+
+
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 5 of 7
+IT APPEARING, after an investigation of the offenses and Epstein's background, that the
+interest of the United States and Epstein's own interest and the interest of justice will be served by
+the following procedure;
+THEREFORE, on the authority of R. Alexander Acosta, United States Attorney for the
+Southern District of Florida, prosecution in this District for these offenses shall be deferred in favor
+of prosecution by the State of Florida, provided that Epstein abides by the following conditions and
+the requirements of this Agreement set forth below.
+Should Epstein violate any of the conditions of this Agreement, the United States Attorney
+may at any time initiate prosecution against Epstein for any offense. In this case, the United States
+Attorney will furnish Epstein with notice specifying the condition(s) of the Agreement that he has
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution for the
+offenses set out on page 1 of this Agreement will be instituted in this District, and the charges
+against Epstein if any, will be dismissed.
+Terms of the Agreement:
+Epstein shall plead guilty (not nolo contendere) to an Information filed by the
+State Attorney's Office for the 15th Judicial Circuit in and for Palm Beach
+County (hereinafter, the "State Attorney's Office") charging violations of the
+following Florida Statutes:
+(a)
+lewd and lascivious battery on a child, in violation of Fl. Stat.
+800.04(4);
+(b)
+solicitation of minors to engage in prostitution, in violation of Fl.
+Stat. 796.03; and
+2.
+(c)
+engaging in sexual activity with minors at least sixteen years of age,
+in violation of Fl. Stat. 794.05.
+Epstein and the State Attorney's Office shall make a joint, binding
+recommendation that the Court impose a thirty (30) month sentence to be
+divided as follows:
+(a)
+Epstein shall begin by serving at least twenty (20) months in prison,
+without any opportunity for withholding adjudication or sentencing,
+and without probation or community control in lieu of imprisonment;
+and
+(b)
+following the term of imprisonment, Epstein shall serve ten (10)
+
+RFP MIA 000061
+
+
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 6 of 7
+months of community control.
+Epstein shall waive all challenges to the Information filed by the State
+Attorney's Office and shall waive the right to appeal his conviction and
+sentence.
+4.
+Epstein shall provide to the U.S. Attorney's Office copies of all proposed
+agreements with the State Attorney's Office prior to entering into those
+agreements.
+6.
+Epstein agrees that, if any of the victims identified in the federal
+investigation file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest
+the jurisdiction of the U.S. District Court for the Southern District of Florida
+ver his person and/or the subject matter, and Epstein will not contest that th
+dentified victims are persons who, while minors, were victims of violation
+of Title 18, United States Code, Sections(s) 2422 and/or 2423.
+The United States shall provide Epstein's attorneys with a list of the
+identified victims, which will not exceed forty, after Epstein has signed this
+agreement and has been sentenced. The United States shall make a motion
+with the United States District Court for the Southern District of Florida for
+the appointment of a guardian ad litem for the identified victims and
+Epstein's counsel may contact the identified victims through that counsel.
+7.
+Epstein shall enter his guilty plea and be sentenced not later than September
+28, 2007, and shall begin service of his sentence not later than October 15,
+2007.
+8.
+With credit for gain time, Epstein shall serve at least 17 months in a state
+correctional institution.
+By signing this agreement, Epstein asserts and certifies that each of these terms is material
+• this agreement and is supported by independent consideration and that a breach of any one o
+lese conditions allows the United States to elect to terminate the agreement and to investigate ar
+prosecute Epstein for any and all federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that the
+Sixth Amendment to the Constitution of the United States provides that in all criminal prosecutions
+the accused shall enjoy the right to a speedy and public trial. Epstein further is aware that Rule
+48(b) of the Federal Rules of Criminal Procedure provides that the Court may dismiss an indictment,
+information, or complaint for unnecessary delay in presenting a charge to the Grand Jury, filing an
+information, or in bringing a defendant to trial. Epstein hereby requests that the United States
+Attorney for the Southern District of Florida defer such prosecution. Epstein agrees and consents
+that any delay from the date of this Agreement to the date of initiation of prosecution, as provided
+
+RFP MIA 000062
+
+
+Case 9:08-cv-80736-KAM Document 361-50 Entered on FLSD Docket 02/10/2016 Page 7 of 7
+for in the terms expressed herein, shall be deemed to be a necessary delay at his own request, and
+he hereby waives any defense to such prosecution on the ground that such delay operated to deny
+him rights under Rule 48(b) of the Federal Rules of Criminal Procedure and the Sixth Amendment
+to the Constitution of the United States to a speedy trial or to bar the prosecution by reason of the
+running of the statute of limitations for a period of months equal to the period between the signing
+of this agreement and the breach of this agreement. Epstein further asserts and certifies that he
+understands that the Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure
+provide that all felonies must be charged in an indictment presented to a grand jury. Epstein hereby
+agrees and consents that, if a prosecution against him is instituted, it may be by way of an
+Information signed and filed by the United States Attorney, and hereby waives his right to be
+indicted by a grand jury.
+By signing this agreement, Epstein asserts and certifies that the above has been read and
+explained to him. Epstein hereby states that he understands the conditions of this Non-Prosecution
+Agreement and agrees to comply with them.
+Dated:
+JEFFREY EPSTEIN
+Dated:
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+
+RFP MIA 000063
diff --git a/vision-fixhub/court-02/073d93864e57f524fd11e2f32f65003660a190dee24636d2e4c48f9768428296.receipt.json b/vision-fixhub/court-02/073d93864e57f524fd11e2f32f65003660a190dee24636d2e4c48f9768428296.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
+{
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+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\"]",
+  "idempotent": true,
+  "input_sha256": "1e94781b642fe5f52a5c38d6238e49dd8a334a85229a3dda8f435f722e0e8c81",
+  "output_sha256": "ad14a72948215eed861a66428f10629f7c894885305a49ffca3b622115ac1fd1",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/079a90301772e4cecfebd4680bb037eded84b93cc819865a4813a36581a30be2.md b/vision-fixhub/court-02/079a90301772e4cecfebd4680bb037eded84b93cc819865a4813a36581a30be2.md
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@@ -0,0 +1,7135 @@
+Filing # 64453296 E-Filed 11/21/2017 09:28:11 AM
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+PART 8
+V.
+SCOTT ROTHSTEIN, individually, and
+BRADLEY J. EDWARDS, individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S APPENDIX OF
+DOCUMENTS IN SUPPORT OF HIS REVISED OMNIBUS MOTION IN LIMINE
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") files this Appendix of Documents
+in support of his revised Omnibus Motion in Limine:
+1
+2
+Date
+1/5/11
+4/9/09
+3
+4/17/09
+4
+4/30/09
+Document
+Epstein's Motion to Amend Complaint (D.E. 195)
+Plaintiff's Motion to Strike References to Non-Prosecution
+Agreement or, in the Alternative, to Lift Protective Order
+arring Jane Doe's Attorneys from Revealing Provisions in th
+Agreement (D.E. 32); Jane Doe v. Jeffrey Epstein; S.D. Fla. Case
+No. 9:08-cv-80893-KAM
+Plaintiff's First Amended Complaint (D.E. 38)
+Jane Doe v. Jeffrey Epstein; S.D. Fla. Case No. 9:08-cv-80893-KAM
+Jeffrey Epstein's Deposition Transcript Excerpts (pp. 148, 151-
+152); E. W. v. Jeffrey Epstein; 15" Judicial Circuit Case No. 50-2008-
+CA-028058-XXXX-MB
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/21/2017 09:28:11 AM
+
+
+6
+7
+8
+9
+10
+15
+16
+Date
+6/19/09
+11/5/09
+7/22/09
+7/27/09
+N/A
+8/11/09
+8/24/09
+8/10/09
+8/24/09
+11/3/09
+11/6/09
+11/9/09
+11/12/09
+Document
+Plaintiff's Motion for Injunction Restraining Fraudulent
+Transfer of Asserts, Appointment of a Receiver to Take Charge
+of Property of Epstein, and to Post a S15 Million Bond to Secure
+Potential Judgment (D.E. 165); Jane Doe 2 v. Jeffrey Epstein; S.D.
+Fla. Case No. 08-cv-80119-MARRA1
+Order Denying Plaintiff's Motion for Injunction, etc. (D.E. 400)
+Jane Doe 2 v. Jeffrey Epstein; S.D. Fla. Case No. 08-cv-80119-
+MARRA/
+Letters from
+re depositions
+Complaint (D.E. 1)
+L.M. v. Jeffrey Epstein; S.D. Fla. Case No. 9:08-cv-81092-KAM
+Court Docket
+L.M. v. Jeffrey Epstein; S.D. Fla. Case No. 9:08-CV-81092-KAM
+Re-Notices of Taking Videotaped Deposition of Donald Trump
+Jane Doe v. Jeffrey Epstein; S.D., Fla. Case No. 9:08-CV-80893-KAM
+Plaintiff's Request for Entry Upon Land (D.E. 143)
+E.W. v. Jeffrey Epstein; 15'" Judicial Circuit Case No. 50-2008-CA-
+028058-XXXX-MB
+Epstein's Motion for Protective Order Regarding Depositions of
+Lawrence Visoski and David Hart Rogers (D.E. 159)
+L.M. v. Jeffrey Epstein; 15th Judicial Circuit Case No. 50-2008-CA-
+028051-XXXX-MB
+Article: South Florida Sun-Sentinel - Scott Rothstein's
+investment deals seemed too good to be true
+Article: New Times Broward-Palm Beach - Scott Rothstein: The
+Jeffrey Epstein and Bill Clinton Ploy
+Verified Complaint for Forfeiture In Rem (D.E. 1)
+United States of America v. Scott W. Rothstein (Forfeiture Action);
+S.D. Fla. Case No. 0:09-CV-61780-WJZ
+Article: South Florida Sun-Sentinel - FBI doubts Rothstein ran a
+Ponzi scheme alone
+2
+
+
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+Date
+11/20/09
+11/23/09
+11/23/09
+11/24/09
+11/25/09
+12/1/09
+12/7/09
+6/30/17
+11/10/17
+3/23/10
+10/10/13
+7/26/09
+8/13/09
+10/23/09
+6/14/12
+Document
+Complaint (without exhibits) (D.E. 3)
+Razorback Funding, LLC v. Rothstein
+17th Jud. Cir. Case No. 062009CA062943AXXXCE
+Amended Verified Complaint for Forfeiture In Rem (D.E. 14)
+United States of America v. Scott W. Rothstein (Forfeiture Action);
+S.D. Fla. Case No. 0:09-CV-61780-WJZ
+Article: South Florida Sun-Sentinel - You're in a town full of
+thieves
+Article: The Miami Herald - Feds: Scott Rothstein Ponzi scheme
+paid salaries at law firm
+Amended Complaint (without exhibits) (D.E. 12)
+Razorback Funding, LLC v. Rothstein
+17th Jud. Cir. Case No. 062009CA062943AXXXCE
+Information (D.E. I)
+United States v. Rothstein, S.D. Ela. Case No. 0:09-cr-60331-JIC
+Complaint (withouf exhibits) (D.E. 5)
+Affidavit of Jeffrey Ep
+(D.E. 931)
+163- 6. p. 227-29, 230-20, 270-78, 31-32, .p.
+Bradley J.
+Deposition Transcript Excerpts (pp.
+N2, 116-117, 123-125, 230-231)
+Deposition Transcript Excerpts (pp.
+205)
+Email from Pricilla Nascimento to Scott Rothstein
+Email from |
+_to Priscilla Nascimento
+Email from Ken Jenne to Scott Rothstein
+Scott Rothstein's Deposition Transeript Excerpts (pp. 23-
+26, 52-53)
+3
+
+
+30
+Date
+12/12/11
+31
+12/21/11
+32
+3/17/10
+33
+34
+35
+36
+11/9/17
+11/15/17
+11/9/17
+1/25/12
+Document
+Scott Rothstein's Deposition Transcript Excerpts (pp. 59-62);
+Razorback Funding, LLC v. Rothstein; 17th Jud. Cir. Case No.
+062009CA062943AXXXCE
+Scott Rothstein's Deposition Transcript Excerpts (p. 2278)
+Razorback Funding, LLC v. Rothstein; 17th Jud. Cir. Case No.
+062009CA062943AXXXCE
+Jeffrey Epstein's Deposition Transcript Excerpts (pp. 13-14, 19-
+20, 23, 25-26, 28-34, 36-39, 48-55, 57, 59-60, 62-69, 73-74, 76-80,
+83-88, 90-95, 116-123)
+Amended Exhibit List (D.E. 1043)
+Epstein's Objections to
+Amended Exhibit List
+(D.E. 1058)
+• Seventh Amended and Supplemental Witness List
+(D.E. 1042)
+Jeffrey Epstein's Deposition Transcript Excerpts (pp. 19-21)
+4
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on November 21, 2017, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax],
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+SERVICE LIST
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL, 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellate.aw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+5
+
+
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+NOT A CERTIFIED
+
+
+NOT A CERTIFIS
+
+
+Page 1
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE No. 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+-vs-
+SCOTT ROTHSTEIN, individually,
+I J.
+_ individually,
+I.M., individually,
+and
+Defendants.
+VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
+Wednesday, March 12, 2010
+10:17 a.ma
+1:27 p.m.
+303 Banyan Boulevard
+Suite 400
+West Palm Beach, Florida 33401
+Reported By:
+Sandra W. Townsend, FPR
+Notary Public, State of Florida
+West Palm Beach Office Job #1358
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+Ectronically signed by Sandra Townsend (401-377-878-2896)
+
+
+1
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+5
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+14
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20.
+21
+22
+23
+24
+25
+Page 10
+that question.
+BY MR. SCAROLA:
+Q. Have you ever acknowledged to --
+A. Excuse me.
+Q.-
+A. Sir, may I suggest that if I say 1 refuse to
+answer, that it means the Fifth, Sixth and 14th or would
+you prefer that I recite it each time?
+Q. I would prefer that you answer the questions,.
+that's my preference. But if you're going to assert a
+privilege, 1 will assume that if you simply say that you
+are refusing to answer, your refusal to answer will be
+on the basis of various Constitutional privileges
+against self-incrimination without the necessity of
+specifying.
+If your refusal to answer is on the basis of
+any other privilege, it will be necessary for you to
+identify that privilege.
+A. Thank you.
+MR. PIKE: And I'm going to instruct you, too,
+when you do invoke, invoke the Fifth, Sixth and the
+14th.
+THE WITNESS: Yes.
+BY MR. SCAROLA:
+Q. Have you ever acknowledged in the presence of
+Page
+11
+that you knew the individual
+identified by the initials L.M.?
+A. Im going to have to refuse to answer that
+question.
+Q. Have you ever acknowledged in the presence of
+that you knew L.M.?
+MR. PIKE: Again, for purposes of the record,
+I'm instructing you to invoke the Fifth, Sixth and
+14th; rather than just simply say
+THE WITNESS: Okay.
+MR. PIKE: -- I tefuse to answer. I want it
+to be clear for the Court that you have invoked
+your Fifth, Sixth and 14th.
+THE WITNESS; Fine.
+Then on advice of Counsel, I'm going to have
+to invoke my Fifth, Sixth and 14th Amendment Right.
+BY MR. SCAROLA:
+Q. Have you ever acknowledged in Brad
+presence that you liked the individual identified by the
+initials L.M.?
+A. Again, I'm going to have to invoke my Fifth,
+Sixth and 14th Amendment Right, Mr. Scarola.
+Q. Have you ever acknowledged in
+presence that you liked L.M.?
+A. Again, Mr. Scarola, I'm going to have to
+1
+2
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
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+17
+18
+19
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+21
+22
+23
+24
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+5
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+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 12
+invoke my Fifth, Sixth and 14th Amendment Right.
+Q. Have you ever acknowledged in the presence of
+Terri Becker, a court reporter present at a deposition
+taken by Brad
+in a - in a case in which the
+individual identified by the initials L.M. was a
+Plaintiff that you knew and/or liked --
+MR. PIKE: Form.
+THE WITNESS: Again, -
+BY MR. SCAROLA:
+Q. - L.M.?
+MR. PIKE: Same objection.
+THE WITNESS: Again, I'm going to have to
+assert my Fifth, Sixth and 14th Amendment Right.
+BY MR. SCAROLA:
+Q. Have you ever acknowledged in the presence of
+Steve Jaffe that you knew and/or liked L.M.?
+A. Again, Mir, Scarola, though I'd like to answer
+each and every one of your questions today, I'm going to
+have to, at the advice of Counsel, invoke my Fifth,
+Sixth and 14th Amendment Right.
+Q. Why are you suing L.M.?
+MR. PIKE: Form.
+MR. SCAROLA: Let me state for the record that
+I don't consider a form objection to be a proper
+objection, unless you specify the defect in the
+Page 13
+form and provide me with an opportunity to correct
+the defect.
+MR. PIKE: That's fine. I believe the rules
+provide otherwise. But, nonetheless, 1 stand on my
+objection to form.
+THE WITNESS: I'm sorry. You have to repeat
+the question.
+BY MR. SCAROLA:
+Q. (Why are you suing L.M.?
+MR. PIKE: Form.
+(THE WITNESS? L.M. is part of a conspiracy
+with Scott Rothstein, Bradley Edwards, creating -
+excuse me -- creating fraudulent cases of a
+sexually charged nature in which the U.S. Attorney
+(has already charged the firm of Rothstein, a firm
+of which Bradley Edwards is a partner, was a
+(partner, with creating, fabricating malicious cases
+Oof a sexual nature, including cases with respect to
+me, specifically, in order to fleece unsuspecting
+(investors in South Florida out of millions of
+(dollars.
+BY MR. SCAROLA:
+Q. What role do you contend L.M. played in that
+conspiracy to create fraudulent cases?
+A. (L.M.'s testimony before she met Mr.
+4 (Pages 10 to 13)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.'
+
+
+1
+2
+3
+4
+5
+6
+7
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+6
+9
+Page 14
+was dramatically -- sworn testimony to the FBI was
+dramatically different after she came in contact with
+"Mr.
+where her testimony then changed to
+sort of a hostile and had claims of - claims never
+before, never made to anyone before, and allegations
+that I've read in her Complaint that that had been
+dramatically different from the ones she had spoken to
+(the FBl about, sir.
+Q. Is it your contention that L.M.'s statement to
+the FBI was true?
+MR. PIKE: Form.
+THE WITNESS: Mr. Scarola, unfortunately,
+today with respect to that question, I'm going to
+have to assert my Fifth, Sixth and 14th Amendment
+Right. Though I know -- I believe you know the
+answer to that question, I can't answer the
+question under advice of Counsel. And he's told me
+if I chose to do so, I risk losing his
+representation.
+BY MR. SCAROLA:
+Q. What is the basis of your belief that I know
+the answer to the question?
+MR. PIKE: Form.
+THE WITNESS: You -- I believe you have seen
+this, because you're supposed to be a decent
+1
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page
+15
+lawyer, you've read the testimony. I would guess
+you've read the difference in her testimony to the
+FBI versus her testimony after she's met your
+client and his partners, who are currently in jail.
+BY MR. SCAROLA:
+Q. How does that respond to my question as to
+1
+2
+3
+4
+5
+6
+. whether you contend that her testimony to the FBI was
+true or false?
+MR. PIKE: Form.
+THE WITNESS: I don't believe that was your
+10
+question. Will you repeat?
+11
+BY MR. SCAROLA:
+12
+Q. Okay. Well, let's - let me rephrase the
+13
+question then.
+14
+Is it your contention that L.M.'s statement to
+15
+the FBI was true?
+16
+A.
+Sir, on advice of Counsel, at least today, I'm
+17
+going to have to assert my Pitth, Sixth and 14th
+18
+Amendment Right.
+19
+Q. Was L.M.'s statement to the FBI false in any
+20
+respect?
+21
+A. Sir, at least, again, today, on advice of
+22
+Counsel, I'm going to have to assert my Fifth, Sixth and
+23
+14th Amendment Right.
+24
+Q. Was L.M's subsequent testimony after,
+25
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+Page 16
+and changed her
+according to you, she met Mr.
+testimony, true?
+A. Did she change her testimony? Is that -- yes,
+her testimony was changed.
+Q. My question to you is: Was her testimony
+which you contend was changed true testimony?
+A. Your question is not a good question. Is it
+her testimony before or after?
+Q. Was the subsequent testimony given by L.M.
+after she met Mr.
+which you contend was
+different from her testimony before the FBI, was the
+subsequent testimony true or false?
+MR. PIKE: Form.
+THE WITNESS: Sir, I'm going, at least today,
+I'm going to have to assert my Fifth, Sixth and
+14th Amendment Right.
+BY MR. SCAROLA:
+Q. Did you ever engage in any sexual conduct with
+L.M.?
+A. I would like to answer that question, but --
+Q. You don't need to tell me what you'd like to
+do, Mir. Epl
+• You just need to do it, please.
+THE WITNESS: Please -
+MR. PIKE: Mr. Scarola, please let the witness
+finish his response.
+Page 17
+MR. SCAROLA: That's not a response to my
+question.
+MR. PIKE: In your mind it may not be a
+response. In a Judge's mind, it may be. We may
+have to certify it to the Court. If such a
+procedure even exists, we can take it up with the
+Court. But please let the witness finish his
+response.
+THE WITNESS: Again, please?
+BY MR. SCAROLA:
+Q. Did you engage -- ever engage in any sexual
+conduct with L.M.?
+A. I would like to answer that question; however,
+today I'm going to have to assert my rights as provided
+by the Fifth, Sixth and 14th Amendment to that question,
+sir.
+Q. Have you ever exchanged anything of value with
+L.M.?
+MR. PIKE: Form.
+THE WITNESS: At least today, I'm going to
+have to assert my Fifth, Sixth and 14th Amendment
+Right, sir.
+BY MR. SCAROLA:
+Q. Did you ever direct anyone to deliver anything
+of value to L.M.?
+5 (Pages 14 to 17)
+• (561) 832-7506
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 18
+MR. PIKE: Form.
+THE WITNESS: At least today, I'm going to
+have to refuse to answer that question based on the
+Fifth, Sixth and 14th Amendment.
+BY MR. SCAROLA:
+Q. Do you know
+A. At least today, sir, I'm going to have to
+refuse to testify about that question. Based on advice
+of Counsel, I'm going to have to assert my Fifth, Sixth
+and 14th Amendment Right.
+Q. Did
+introduce you to L.M.?
+A. Sir, respectfully, I'd like to answer that
+question today. As I said, I'd like to answer each and
+every one of your questions. However, on advice of my
+Counsel today, I'm going to have to assert my Fifth,
+Page 20
+4
+5
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+8
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+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+MR. PIKE: Form.
+THE WITNESS: Could you repeat the question,
+please?
+BY MR. SCAROLA:
+Q. Did L.M. suffer any damage as a consequence of
+any interaction between you and L.M.?
+MR. PIKE: Form.
+Page 19
+THE WITNESS: I'd like to answer each and
+every one of your questions here today,
+Mr. Scarola; however, on advice of Counsel, today,
+I'm going to have to assert my Fifth, Sixth and
+14th Amendment Right.
+BY MR. SCAROLA:
+Q. Your Complaint in this action alleges that
+(L.M. made claims for damages out of proportion to her
+(alleged damages. What does that mean?
+A. It means what it says.
+Q. I don't understand it. Explain it to me.
+MR. PIKE: To the extent you can answer that
+question without disclosing my conversations with
+you or Mir. Critton's conversations with you, as
+well as my work product, you can answer the
+question.
+THE WITNESS: I believe that as part of the
+scheme to defraud investors in South Florida out of
+(millions of dollars, claims of outrageous sums of)
+money were made on behalf of alleged victims across
+the board.
+_And the only way - in fact, Scott
+Rothstein sits in jail. And what I've read in the
+(paper, claims that I've settled cases for
+$200-million, which is totally not true.
+She has made claims of serious sum of money,
+2
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
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+17
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+21
+22
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+24
+25
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+10
+11
+12
+13
+14
+15
+16
+17
+•18
+19
+20
+21
+22
+23
+24
+25
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+which is outrageous
+BY MR. SCAROLA:
+Q. How much have you settled claims for?
+MR. PIKE: I'm going to instruct you not to
+answer that question.
+MR. SCAROLA: And the basis of that
+instruction is?
+MR. PIKE: Confidential settlement agreements,
+to the extent that they exist. And the terms would
+be confidential.
+BY MR. SCAROLA:
+Q. Have you settled claims?
+A. Yes, I have.
+Q. What is the nature of the claims you settled?
+MR. PIKE: I'm going to instruct you not to
+answer that question.
+BY MR. SCAROLA:
+Q. How many claims have you settled?
+MR. PIKE: I'm going to instruct you not to
+answer that question as well.
+MR. SCAROLA: What is the basis for those
+instructions?
+MR. PIKE: Confidential, as well as there is a
+Victim's Right Statute that may - you may be
+tiptoeing into the identity of -
+Page 21
+MR. SCAROLA: I'm not tiptoeing anywhere.
+MR. PIKE: Let me finish my objection,
+Mr. Scarola.
+You may be tiptoeing into the identity of
+various alleged victims underneath the Victims
+Right Statute, as well as ongoing investigations or
+past investigations that have remained open with
+the State, as well as the Federal Government.
+So in that regard, we would have to put the
+State Attorney, as well as the Federal Government
+on notice that you were seeking to potentially back
+door certain identities at this deposition.
+BY MR. SCAROLA:
+Q. Other than having allegedly given different
+testimony before she met Mr.
+then given after
+she met Mr.
+_ did L.M. do anything else that
+forms the basis for your claim against her?
+MR. PIKE: Form. Asked and answered.
+THE WITNESS: I'd like to answer that
+question, as well as every one of your questions
+with respect to L.M. here today; however, on advice
+of Counsel, at least today, Mr. Scarola, I'm going
+to have to assert my Sixth Amendment, Fifth
+Amendment and 14th Amendment Right.
+BY MR. SCAROLA:
+6 (Pages 18 to 21)
+
+
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+Page 22
+Q. Did L.M. fail to do anything that she had an
+obligation, duty or responsibility to do --
+MR. PIKE: Form.
+BY MR. SCAROLA:
+Q. - that forms the basis for your claim against
+her?
+MR. PIKE: I apologize. Form.
+THE WITNESS: Again? I'm sorry. Has she
+failed to do? Can you repeat?
+BY MR. SCAROLA:
+Q. Yes, sir. Lawsuits are generally based, civil
+lawsuits are generally based on a claim that someone has
+done something that they shouldn't have done or failed
+to do something that they should have done.
+I asked you whether L.M. did anything that she
+shouldn't have done and you asserted a Fifth Amendment
+privilege in refusing to answer that question.
+I'm now attempting to find out whether L.M.
+failed to do something that she should have done that
+forms the basis of your claims against her.
+Did L.M. do anything that she should have done
+that forms the basis of your claims against her?
+MR. PIKE: Form.
+THE WITNESS: On advice of Counsel, at least
+today, Mr. Scarola, I'm going to have to refuse to
+Page 23
+answer that question based on my Fifth Amendment,
+Sixth Amendment and 14th Amendment Right.
+BY MR. SCAROLA:
+Q. (Did Brad Edwards do anything that he shouldn't
+(have done that forms the basis of your lawsuit against
+MR. PIKE: Form.
+(THE WITNESS: Yes, many things!
+BY MR. SCAROLA:
+Q. List them for me, please
+A.
+He has -- he has gone to the media out of, l
+(believe, in an attempt to gin up these allegations. He
+(has contacted the media. He has used the media for his
+own purposes. He has brought discovery - he has
+(engaged in discovery proceedings that bear no
+relationship to any case filed against me by any of his
+Clients
+(His firm, which he's the partner of, has been
+accused of forging a Federal Judge's signature.
+Q
+I want to know what Mr.
+MR. PIKE: One second.
+THE WITNESS: Excuse me. I'm answering.
+BY MR. SCAROLA:
+Q. I want to know what Mr.
+did. I'm not
+asking you about allegations concerning his law firm.
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+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+lectronically signed by sandra Townsend (401-377-076-2895
+Page 24
+MR. PIKE: Mr. Scarola, that's the second time
+that I'm going to ask you not to interrupt the
+witness when he's giving a response. He is giving
+a response. When he finishes his response, you can
+go on with your next question or you can -- you can
+elicit any sort of information you intend to elicit
+from the witness.
+MR. SCAROLA: He's being unresponsive.
+MR. PIKE: No, that's your contention.
+MR. SCAROLA: No, that's a fact.
+MR. PIKE: And you can take it up with a
+Judge. And if we want to continue going back and
+forth and bantering, not allowing the witness to
+answer the question -- welre here for you today,
+for you to ask the questions and for you to get
+answers. But if you continue to banter with the
+witness and interrupt the witness, I will adjourn
+the deposition. This is not proper and we
+certainly can take it up with the Judge. So that's
+the second warning, Mr. Scarola. Please --
+MR. SCAROLA: How many do I get?
+MR. PIKE: I'm not sure yet today.
+MR SCAROLA: Okay.
+MR. PIKE: Okay?
+MR. SCAROLA: Good. Then let's move on.
+Page 25
+MR. PIKE: But I can tell you one thing: On a
+professional nature, just because you are
+interrupting the witness and bantering with me, I
+will adjour the deposition.
+BY MR. SCAROLA:
+Q.
+Besides having gone to the media in an attempt
+to, quote, gin up, unquote, these allegations and
+engaged in what you contend to
+want discovery
+(proceedings, what else did Mr.
+personally, do
+that forms the basis for this lawsuily
+Mr.
+personally, engaged with his
+(partners, Scott Rothstein, who sits in a Federal jail
+cell, potentially for the rest of his life, he shared
+information, what I've been told and -- excuse me -
+What I've read in the newspapers, 13 boxes of
+information that had my name on it, with other attorneys
+at his firm
+(He counseled his clients to maintain a
+(position alleging multi-million döllar damages in order
+(for them to scam local investors out of millions of
+(dollars.
+He and his - many of his other partners
+(already under investigation by the FBI and the U.S?
+(Attorney have been accused by the U.S. Attorney of
+(running a criminal enterprise.
+7 (Pages 22 to 25)
+
+
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+Page 26
+Q. Anything else?
+MR. PIKE: Form.
+THE WITNESS: (Not I can think of at the
+moment:
+BY MR. SCAROLA:
+Q. (Okay. What media did Mr. Edwards go to?
+-Tam aware of at least the Daily News in New
+(York City
+(L have been told by other people that there
+were other media, local media!
+I've been told that the - his investigator
+Was sent to California to harass people representing
+(his - Brad Edwards' investigator - representing
+(fictitiously, fraudulently that he was a FBI agent to
+(try to gather information for Mr.
+claims
+Q. Does that have something to do with going to
+the media?
+MR. PIKE: Form.
+THE WITNESS: I've answered your question.
+BY MR. SCAROLA:
+Q. Does the investigator going to California to
+do something have something to do with the media?
+A. I believe I've also told that you that he's
+gone to the Daily News, sir; is that correct?
+MR. PIKE: Form. Mischaracterizes the
+Page
+27
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+Page 28
+Q. Do you understand the question youre supposed
+to be answering, Mr. Epstein?
+MR. PIKE: And I'm going to instruct you not
+to answer that question right now because as your
+Counsel I cannot let you answer that question until
+I understand what question is on the table.
+There's been a lot of bantering back and
+forth, so, Mr. Scarola, if you would respectfully
+repeat the question and then you may be able to ask
+him whether or not he understands the question.
+But I cannot allow him to answer a question that I
+don't understand is on the table.
+BY MR. SCAROLA:
+(What does an investigator going to California
+(have to do with Mr.
+allegedly going to the media
+(in an attempt to, quote, gin up, unquote, these
+Callegations?
+MR. PIKE: Please answer the question.
+(THE WITNESS: Good. It's part of Mr. Edwards
+scheme to involve people who have nothing to do
+(with any of his cases in order to, in fact, go back
+(to the media and gin up his stories and make false
+allegations of people that have sexually charged
+nature cases in order to attempt to fleece
+(investors, local investors out of millions of
+Page 29
+witness' testimony as well.
+1
+dollars
+2
+BY MR. SCAROLA:
+(His firm has been accused by the U.S. Attorney
+Q. Do you understand the question that you're
+of manipulating the media, by hiring investigators,
+supposed to be answering?
+(by illegal wire taps, by illegal methods of
+MR. PIKE: Well, let's go ahead and repeat it.
+5
+eavesdropping in order to go to the media and
+MR. SCAROLA: No, let's get an - let's get an
+(generate cases,
+answer to that question.
+8
+(BY MR. SCAROLA)
+BY MR. SCAROLA:
+Q. Do you understand the question you're supposed
+10
+to be answering?
+11
+A. When -
+12
+MR. PIKE: I'm confused. Wait one second.
+13
+THE WITNESS: Sorry,
+14
+15
+MR. PIKE: I'm confused as to what question is
+on the table.
+16
+MR, SCAROLA: And when your deposition is
+17
+18
+being taken, your confusion is relevant and
+material.
+19
+MR. PIKE: Right. And it's -
+20
+MR. SCAROLA: When Mr.
+- excuse
+21
+22
+me - when Mr. Epstein's deposition is being taken,
+I'm concerned with whether he understands the
+23
+24
+question being asked.
+25
+MR. PIKE: Right. So...
+BY MR. SCAROLA:
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+Q: (When did Mr.
+go to the Daily News?
+I don't know!
+(How did he go to the Daily News?
+I don't know?
+(Q. What did he say to the Daily News?
+(A. I believe Mr, Edwards knows that. I don't
+(know exactly what he said
+(Q. What is the source of your information that he
+(went to the Daily News at all, ever?
+MR. PIKE: To the extent you can answer that
+question without violating any attorney/client
+privileges, you can answer the questions.
+(THE WITNESS: It's attorney/client
+(BY MR. SCAROLA:
+(Q. You said you were told by other people that he
+went to other media representatives?
+(A. Yes, sir.)
+(Q. Who are the other people that told you that?)
+8 (Pages 26 to 29)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+Electronically signed by Sandra Townsend (401-377-676-2895).
+
+
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+A. I don't recall at the moment.
+-(What did these other people who your don't
+(remember tell you Mr
+did with respect to other
+( media representatives besides the Daily News?
+(A. Again, the question again?
+(9. (What did these other people tell you
+Mr. Edwards did with respect to going to other media?
+MR. PIKE: Form.
+THE WITNESS: Mr.; Edwards went to the media to
+(gin up his cases in order that the Rothstein firm
+(could generate profits, falsely taking in
+(investors, creating false stores to the local
+(medias and making statements to local press
+Cregarding false claims made by his clients in order
+(that Scott Rothstein, who currently sits in jail,
+(could defraud, along with his other partners of his
+(firm, local Florida investors, Mr. Scarola, out of
+(millions of dollars.
+(BY MR: SCAROLA:
+(When did these other people whose identity you
+(can't remember tell you these things that Brad
+(did?
+(A. Sometime in the past year.
+Q.- How many other people were there who told you
+(these things about Mr. Edwards?
+Page
+31
+(A (L don't recall with specificity;
+Well, do you recall in any degree how many
+(there were?
+(A (Lwould say, probably five to ten,
+(Where were you when these conversations took
+(place that you can't the identity of whose
+(participants you can't remember?
+(MR. PIKE. So we're clear, within the last
+(year correct? = timewise?
+MRE SCAROLA: Well, that's what your clien
+(said. I don't believe a word he says, but that's
+(what he said?
+MR. PIKE: Form. Objection. Overbroad.
+(THE WITNESS:-Again, sir?
+(BY MR: SCAROLA:
+g (Yes, sir. Where did these conversations with
+(these five to ten people take place whose identity you
+can't remember?
+MR. PIKE: Form.
+THE WITNESS: (On the telephone!
+BY MR. SCAROLA:
+Q. Who initiated the phone calls?
+A. (Sir, these questions, Thave no = I don't
+(have any recollection.
+Q. (Did the people who were on the phone identify)
+1
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+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+Page 32
+themselves or were these anonymous callers?
+(MR PIKE: Form.
+(THE WITNESS. Sifting here today, Mr. Scarola,
+(I'don't recall with specificity.
+(BY MR. SCAROLA:
+Q. (What specifically did Mr. Edwards allegedly
+communicate to the Daily News to, quote, gin up these
+allegations, unquote?
+CA. (The newspapers have quoted Mr.
+- not
+quoted Mr. - newspapers have made allegations referred
+to as Mr.
+statements.
+(MR. SCAROLA. Would you read the question
+(back, please, Sandy?
+(Pending question was read.)
+MR. PIKE: Did he answer your question?
+MR. SCAROLA: No.
+MR. PIKE: Are you asking him again?
+THE WITNESS: So you're asking the question
+again?
+BYMR. SCAR
+Q. Yes.
+THE WITNESS: Sorry. Could you repeat the
+question again?
+(Pending question was read.)
+THE WITNESS. He alleged that third parties
+Page
+33
+(had already been involved in some allegations to do
+with sexual misconduct
+BY MR. SCAROLA:
+Q
+Which third parties?
+"Ton't recall sitting here today.
+(Q (Involved how?
+MR. PIKE: Form.
+(THE WITNESS: If 1 recall with specificity, if
+(I had the articles in front of me, 1 would be able
+(to recall. Maybe next time
+(BY MR. SCAROLA:
+Q.
+(What does "gin up these allegations" mean?
+MR. PIKE: Forn.
+THE WITNESS: It means craft allegations of
+multi-million döllar cases; in fact, alleging in
+(L.M.'s case damages of $50-million, settlements in
+order for Scoff Rothstein and the rest of
+(Mir. Edwards' partners to fleece unsuspecting
+(investors out of millions and millions of dollars
+(based on cases that didn't exist or alleged cases
+that I had settled!
+Can I take a break?
+VIDEOGRAPHER: Going off video record, 10:50.
+(Brief recess.)
+VIDEOGRAPHER: We're now on video record at
+9 (Pages 30 to 33)
+
+
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+Page 34
+10:57 a.m.
+BY MR. SCAROLA:
+Q (Was your reference to, quote, gin up these
+allegations, unquote, a reference to allegations made
+against you?
+MR. PIKE: Form.
+(THE WITNESS: As part of the vast conspiracy
+of the Rothstein firm and Mr. Edwards"
+(participation in it, it has been alleged that many
+cases were fraudulently brought - alleged that
+(have been brought, ginned up, meaning, crafted,
+(multi-million dollar numbers put on cases in order
+(to fleece investors, where his partner, Scott
+(Rothstein, currently sits in jail for just those
+(purposes, Mi. Scarola.
+BY MR. SCAROLA:
+e. My question to you is: Did the reference to
+quote, gin up these allegations refer to allegations
+against you?
+A. (Reported in the newspaper the answer is, yes.
+(And others, but specifically me, yes, by the newspaper
+reports
+Q. Specifically what are the allegations against
+you which you contend Mr.
+ginned up?
+A. I would like to answer that question. A, many
+Page 35
+of the files and documents that we've requested from
+and the Rothstein firin are still
+Mr.
+unavailable.
+With respect to anything that I can point to
+today, I'm, unfortunately, going to have to take the
+Fifth Amendment on that, Sixth and 14th.
+Q. You seemed to be defining ginned up as
+crafted; is that correct?
+A. That's correct.
+Q. Does ginned up or crafted mean fabricated?
+MR. PIKE: Form.
+THE WITNESS: I'm sorry, Mr. Scarola. I
+understand that you are trying to back door your
+way into e waiver of my Fifth Amendment. But
+respect to that question, I'm going to have assert
+my Fifth Amendment, Sixth Amendment and 14th
+Amendment Right.
+BY MR. SCAROLA:
+Q. So you are asserting your Fifth Amendment,
+Sixth Amendment and 14th Amendment Right to remain
+silent about what you mean when you use the words "gin
+up" and "crafted;" is that correct?
+A. I don't believe that was your question.
+Q. Yes, sir, that's exactly my question.
+A. Would you repeat the question for me?
+(561) 832-7500
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+Page 36
+Q. I want to know whether when you use the phrase
+"gin up" and the word "crafted," which you have told us
+is synonymous with gin up, -
+A. Yes.
+Q. - you mean fabricated?
+A. I'm sorry. On advice of Counsel, sir, and
+I've answered that question before, but if you didn't
+hear me the first time, I must assert my Fifth, Sixth
+and 14th Amendment Right.
+Q. (What specific discovery proceedings did
+Mr.
+engage in which you contend form the basis
+for your lawsuit?
+(A.
+The discovery proceedings of bringing my
+(attorneys to various people that had nothing to do with
+any of his clients or these lawsuits
+Q
+Which various people? Who?
+MR. PIKE: Fonn.
+(THE WITNESS: For example, he tried to depose
+(Bill Clinton, strictly as a means of getting
+publicity so that he and his firm could
+(fraudulently steal, craft money from unsuspecting
+(investors in South Florida out of millions of
+dollars
+BY MR. SCAROLA:
+Q. Who else besides Bill Clinton is included in
+Page 37
+your reference to various people?
+A. There are people in California. There are
+people in New York.
+Q. Would you name them for us, please?
+A. I'm sorry. Sitting here today, Mr. Scarola,
+I'm going to have to assert my Fifth Amendment, Sixth
+Amendment and 14th Amendment Right.
+Q. Let's then talk about Bill Clinton, by whom I
+assume you mean former President Clinton; is that
+correct?
+A. That's correct,
+Q. All right. Do you know former President
+Clinton personally?
+A. I'm sorry. As I sit here today, though I'd
+like to answer that question, on advice of my Counsel,
+at least today, I'm going to have to take the Fifth,
+Sixth and 14th Amendment.
+Q
+You said something about Mr. Edwards sharing
+(13 boxes of information with somebody =
+(A.
+Yes.
+- as forming part of the basis for your
+(lawsuit against Mr.
+correct?
+A.
+Correct
+Q
+All right.
+With whom did Mr. Edwards share
+these 13 boxes of information?
+PROSE COURT REPORTING AGENCY, INC.
+10 (Pages 34 to 37)
+lectronically sianed by Sandra Townsend (401-377-676-2895
+
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+A. (It has been reported in the Scherer Complaint
+"that he shared those boxes with the partners of his firm
+(that was then formally accused by the U.S. Attorney,
+sir, of being a criminal enterprise.
+MR. PIKE: And just for purposes --
+(BY MR: SCAROLA:
+(Q. (Do you remember my question?
+A. You asked me who he shared it with?
+C. (Yes.
+(A. The partners of his firm, sir.
+Q. Okay. So part of the basis of your lawsuit is
+"that Mr. Edwards allowed members of his own law firm to
+see 13 boxes of information; is that correct?
+(A. No, that's not correct." My claim is that the
+(13 boxes of information that were shown to investors by
+(Mr: Edwards' partriers, 13 boxes that we've been told by
+(the press contain multiple cases, fraudulently - and if
+(you like the word - fabricated in order to fleece
+(investors out of money. The 13 boxes were shared with
+(investors, Mr. Edwards, Mr. Edwards' partners and some
+(of those partners currently under inditement, the others
+(already sitting in jail.
+Q. I had asked you earlier whether ginned up and
+crafted meant fabricated and you asserted your Fifth
+Amendment privilege.
+Page
+39
+Are you now telling us that there were claims
+against you that were fabricated by Mr.
+A. I'm going to again assert my Fifth, Sixth and
+14th Amendment Right, sir.
+I would respond that the newspapers are very
+clear that the cases were fabricated.
+Q (Which newspaper said which case was
+(fabricated?
+A. (Bob Norman's blog said most of the cases were
+(fabricated, to my best recollection.
+The Scherer Complaint alleged many fabricated
+cases, sir;
+Q. Well, which of Mr. Edwards' cases do you
+contend were fabricated?
+A. Again, we've requested most of the --
+information from the bankruptcy trustee. We've been
+unable - Mi, Edwards has not given us the total file,
+but respect to any individual, I would have -- at the
+moment I would have to assert my Fifth, Sixth and 14th
+Amendment claim, sir.
+Q. So you will not answer questions about whether
+the claim on behalf of L.M. was fabricated; is that
+correct?
+A. I believe I've already answered that, but, if
+again, I'Il have to assert my Fifth, Sixth and 14th
+1
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+(561) 832-7500
+Page 40
+Amendment Right, sir.
+Q. Your Complaint also makes reference to a claim
+on behalf of Jane Doe, referred to as Jane Doe versus
+Epstein, case number 08-CIV-80893, a case pending in the
+United States District Court for the Southern District
+of Florida.
+Is it your contention that the claim on behalf
+of Jane Doe is a fabricated claim?
+A. Sir, though I'd like to answer that question,
+as well as every one of your other questions here today,
+today I'm going to have to assert my rights as under the
+Constitution of the Fifth, Sixth and 14th Amendment.
+Q. Do you know the real name of the person
+referred to as Jane Doe in that case?
+A. I don't know which -- I'm sorry, sir. I do
+not, sitting here today.
+Q. Did you ever have personal contact with the
+person referred to by the name Jane Doe in that lawsuit?
+A. I'm sorry, sir. Sitting here today, I'm going
+to have to assert my Fifth, Sixth and 14th Amendment
+Right.
+Q. When did you first meet the person referred to
+as Jane Doe?
+A. Sir, though I'd like to answer each and every
+one of your questions here today, at least with respect
+Page 41
+to that question, I'm going to have to assert my rights
+under the Sixth Amendment, 14th Amendment and Fifth
+Amendment.
+Q. Where did you first meet the person referred
+to as Jane Doe?
+A. Sir, though I'd like to answer that question
+here today, at least today on advice of Counsel, I'm
+going to have to assert my Fifth Amendment, Sixth
+Amendment and 14th Amendment Right.
+Q. How many times have you been in the physical
+presence of the person referred to as Jane Doe?
+A. The person referred to as Jane Doe?
+Q. Yeah. How many times have you been in her
+physical presence?
+MR. PIKE: Form.
+THE WITNESS: At least -- at least sitting
+here today, Mr. Scarola, I'm going to have to
+assert my Fifth Amendment, Sixth Amendment and 14th
+Amendment Right.
+BY MR. SCAROLA:
+Q. Did you ever have any physical contact with
+Jane Doe?
+MR. PIKE: Form.
+THE WITNESS: Now, for this purposes, you're
+assuming this Jane Doe is somebody I know? I don't
+PROSE COURT REPORTING AGENCY, INC.
+11 (Pages 38 to 41)
+lectronically signed by sandra Townsend (401-571-576-2895
+
+
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+Q. Would your answer be the same with regard to
+L.M. and to Jane Doe?
+MR. PIKE: I'm going to instruct you if your
+answer is the same, to invoke in full.
+THE WITNESS: With respect to, I believe, Jane
+Doe -- and who is the other person? I'm sorry.
+BY MR. SCAROLA:
+Q. L.M.
+A. L.M. Though Id like to answer your claims
+with respect to all three of Mr.
+clients, on
+advice of Counsel, at least today, I'm going to have to
+invoke my Fifth, Sixth and 14th Amendment Rights.
+Though I'd prefer to answer the question, I've been told
+that if I choose to do so, 1 risk losing their
+representation.
+Q. Among those items listed by you as wrongdoing
+on the part of Mr.
+forming the basis for this
+lawsuit is that he, quote, counseled his clients to make
+multi-million dollar claims against you; is that
+correct?
+MR. PIKE: Form. Document speaks for itself.
+THE WITNESS: Document speaks for itself.
+BY MR. SCAROLA:
+Q. I'm not asking about a document. I'm asking
+you about the list of wrongdoing that you gave us during
+Page
+47
+the course of this deposition, which you allege form the
+basis for your claim against Mr.
+Is it your contention that among those things
+Mr.
+did that form the basis for your lawsuit is
+to have counseled his clients to make multi-million
+dollar claims against you?
+MR. PIKE: Form.
+THE WITNESS: What the newspapers have said is
+that the claims purported to have been made by the
+Rothstein firm and its partners allege
+multi-million dollar claims where no claims exist.
+However, respect specifically to my claim
+today, I'm going to have assert my Fifth, Sixth and
+14th Amendment Right.
+MR. PIKE: Also, the question mischaracterizes
+the witness' testimony.
+BY MR. SCAROLA:
+Q. By whom was
+employed when he
+initiated litigation against you?
+A. I would like to know the answer to that
+question.
+Q. So the answer to that question is, 1 don't
+know?
+A. I would like -
+Q. Correct?
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+Page 48
+A. No. 1 answered that question, which is, I'd
+like to know.
+Q. Yes. But that isn't an answer to my question.
+My question is: By whom was Mr.
+employed at the time that he initiated litigation
+against you? Do you know the answer to that question?
+A. Id have no way of knowing the answer to that
+question, sir.
+Q. Among the allegations of wrongdoing against
+Mr
+which you contend form the basis of this
+(Lawsuit is something having to do with sending an
+(investigator to California
+(Would you tell me, please, more specifically
+What it is that Mr. Edwards did with regard to sending
+an investigator to California which you contend
+(justifies a legal claim against Mi. Edwards
+MR. PIKE: Form. And also mischaracterizes
+the witness' testimony.
+THE WITNESS Reported widely in the
+(newspapers is the use of illegal activities, wire
+(taps, and methods by the Rothstein firm while
+Mr. Edwards had basically been bringing these
+cases
+(The investigator, Mr. Fisten, who's mentioned
+(in the Complaint, represented himself as an FBI
+Page 49
+(agent, falsely represented himself as an FBI agent.
+(BY MR. SCAROLA
+Q. Do you have any personal knowledge of anything
+that Mr. Fisten did while Mr. Fisten was in California?
+MR. PIKE: To the extent that you can answer
+that question without disclosing my conversation or
+my firm's conversation or any of your attorneys'
+conversations with you, you can answer the
+question.
+(THE WITNESS: I'm sorry. Based on
+Cattorney/client privilege, 1 can't answer
+BY MR. SCAROLA:
+Q. (Is it your contention that Mr. Edwards was
+(involved in an illegal wire tap?
+(A. It was widely reported in the newspaper -
+(Q) U'm not asking it was reported •
+A (Excuse me.
+- in the newspaper.
+Excuse me.
+Q.
+I want to know whether your contention is that
+(Mr. Edwards was involved in an illegal wire tap
+MR. PIKE: Try once again to answer that
+question.
+(THE WITNESS: It's been widely reported in the
+(newspaper that his firm and his partners were
+13 (Pages 46 to 49)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+
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+Page 50
+(involved in illegal wire taps, eavesdropping, hired
+(former FBI and law enforcement officials in order
+(to fabricate cases of a sexually charged nature
+against me and others.
+(BY MR" SCAROLA
+Q! (Do you have any personal knowledge of
+Mr. Edwards ever having engaged in any illegal wire tap?
+(A. Thave no personal knowledge, however, what I
+read in the newspapers and is widely reported is that
+(his firm, and I believe Mr. Sakowitz went to the FBI
+Cafter he was told that the firm was engaged in illegal
+wire taps and his partners were engaged in illegal wire
+(taps.
+The FBI, the U.S. Attorney has accused his
+(firm of RICO, being the largest criminal fraud
+enterprise in South Florida's history and engaged in
+(illegal wire taps. But the answer specifically to your
+question about personal knowledge, sir, no
+9. Do you have any personal knowledge of
+Mr.
+ever having been involved in any illegal of
+(improper eavesdropping?
+A. (L's been widely reported in the newspapers in
+(South Florida that Mr. Edwards firm, his partners were
+(involved in illegal wire taps, illegal fact gathering)
+using what the newspapers quoted as sophisticated
+Page
+51
+methods. Mr. Sakowitz, who was approached as an
+(investor, and Mr. Scherer, who's filed a Complaint
+Calleges similar activities. But personal knowledgg
+myself, sir, no.
+Q.
+Do you have any personal knowledge that
+was ever involved in obstructions of
+(justice?
+MR. PIKE: To the extent that you can answer
+that question without disclosing any
+attorney/client communications with any of your
+attorneys, you can answer that question.
+(THE WITNESS. It's attorney/client privilege
+I'm afraid.)
+(BY MR. SCAROLA!
+Q. Do you have any personal knowledge that
+(Bradley Edwards was ever involved in any actionable
+(frauds?
+MR. PIKE: Same -- same instruction, with any
+of your lawyers.
+THE WITNESS: Yes. Outside of the newspapers
+which have accused his firm of a monstrous fraud
+purported to be the largest fraud in South
+(Florida's history, accused by the U.S. Attorney)
+Where his partner sits in jail - excuse me -
+reported in the newspapers of boxes of material on
+(561) 832-7500
+10
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+Page 52
+(Jeffrey Epstein, separate and apart from the
+allegations of fraud by his partners, I cannot
+answer that question because of attorney/client
+(privilege
+BY MR. SCAROLA:
+O. Do you have any personal knowledge that
+was involved in any egregious civil
+litigation abuses?
+MR. PIKE: Form. Confusing.
+THE WITNESS: It's widely reported in the
+newspaper that Mr.
+firm engaged in
+discovery processes, illegal activities, illegal
+eavesdropping in order to fleece unsuspecting
+investors in South Florida out of millions in
+dollars by crafting, fabricating malicious cases of
+a sexually charged nature in order to perpetrate a
+fraud.
+BY MR. SCAROLA:
+O. (Do you have any personal knowledge that
+ever forged Federal Court Orders and/or
+Opinions?
+A
+It's attorney/client privilege.
+OF Do you have any personal knowledge that
+was ever involved in the marketing of
+non-existing Epstein settlements?
+Page
+53
+MR. PIKE: Same instruction.
+THE WITNESS. I'm sorry, I would like to
+answer that question, but on attorney/client
+(privilege | cannot today.
+BY MR. SCAROLA:
+Q. If is alleged in your Complaint that you were
+subject to, quote, abusive investigatory tactics.
+Other than those matters previously referred
+(to in earlier questions, is it your contention that
+(Bradley Edwards had any personal involvement in any
+other, quote, abusive investigatory tactics?
+MR. PIKE: Form.
+(THE WITNESS: It's been widely reported in the
+(newspapers that Mr. Edwards firm was engaged in
+widely - wildly abusive practices throughout the
+(State of Florida in order to fleece unsuspecting
+(investors out of millions of dollars.
+The U.S. Attorney's Complaint alleges his firm
+engaged in a corrupt criminal enterprise.
+(Mr. Scherer's Complaint alleges monstrous
+amounts of fraud and discovery abuse.
+(I have no personal khowledge, separate from
+(the attorney/client privileged information,
+(regarding Mr. Edwards.
+BY MR. SCAROLA:
+14 (Pages 50 to 53)
+PROSE COURT REPORTING AGENCY, INC. ' (561) 832-7506
+
+
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+AAR.
+20
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+Page 54
+(Q (Do you have any personal knowledge that
+ever filed legal papers that were
+Bradley
+unsupportable?
+MR. PIKE: I'm going to object to form.
+And to the extent you can answer that question
+without disclosing any attorney/client
+communications with any of your attorneys, I'm
+going to allow you to answer that question.
+THE WITNESS: I'm afraid it's attomey/client
+privilege.
+BY MR. SCAROLA:
+Q
+Do you have any personal knowledge that
+Mr.
+was ever involved in any conduct that,
+quote, compromised the core values of both State and
+Federal justice systems in South Florida?
+MR. PIKE: Form.
+(THE WITNESS: Can you just ask -- can you
+(define for me what you mean by "personal
+(knowledge," Sir?
+BY MR SCAROLA;
+(9 (Yes. Did you ever see, hear, smell, taste, or
+touch anything that communicated to you directly and not
+through the report of some third person of newspaper
+that Bradley
+was personally involved in
+compromising the core values of both State and Federal
+Page
+55
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+(justice systems in South Florida?
+(MR. PIKE: Form
+Same instruction with regard to
+attorney/client)
+(THE WITNESS: Yes. Are you suggesting that
+anyone who told me specifically of things that I
+might have read that specifically relate to him, is
+not what you've been asking me for?
+BY MR. SCAROLA
+(Yes, sir, that's exactly right
+You told me ift hear something, that's not
+(personal knowledge.
+2 (Not if you hear it from somebody else.
+(A, Who else would I hear it from, besides
+(somebody else, sir?
+Q (Well, if you heard it directly yourself.
+From who?
+(Q) (Maybe Mr. Edwards,
+(A.
+"Uh-huh. Is that the only person, sir?
+That's the only person, that's correct
+(A.
+. Well, if it's the only person, separate from
+attorney/client privilege, I cannot answer that.
+Q.
+Your Complaint makes reference to a purpose in
+filing this lawsuit to, quote, "vindicate the
+hardworking and honest lawyers and their clients who
+Page 56
+were adversely affected by the misconduct that is the
+subject of this Complaint," uniquote.
+Who are those hardworking and honest lawyers
+that you are seeking to vindicate?
+MR. PIKE: Form.
+Give me a minute. What page of the Complaint
+are you referring to?
+MR. SCAROLA: Page 2.
+MR. PIKE: Give me one second.
+THE WITNESS: Can we go off the record just
+for a second?
+MR. PIKE: If it's okay with Mr. -
+THE WITNESS: It's a bathroom break.
+MR. PIKE: There's a question pending and
+usually -
+THE WITNESS: Sorry,
+MR. PIKE: Just give me a second.
+Okay.
+THE WITNESS: Where is it?
+MR. PIKE: It's page 2 of the Complaint, which
+has my notes on it down here, the last sentence.
+And to the extent that you have knowledge and
+can answer that question, you can do so.
+THE WITNESS: Could you repeat the question
+for me, sir?
+Page 57
+1
+2
+3
+4
+5
+BY MR. SCAROLA:
+Q. Yes, sir. (Your Complaint makes reference to a
+(purpose in filing this lawsuit -
+A
+Yes_
+-to vindicate the hardworking and honest
+lawyers and their clients who were adversely affected by
+(the misconduct that is the subject of this Complaint
+(A. Yes, sir
+9
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+Q! Who are those hardworking and honest lawyers
+on whose behalf you are bringing this Complaint?
+MR. PIKE: Okay. Formi. Mischaracterizes the
+Complaint itself.
+To the extent you understand that question,
+you can attempt to answer, if you recall.
+(THE WITNESS: Yes
+(The U.S. Attorney, sir, has accused the
+Rothstein firm of misusing the entire legal system,
+a level of abuse never seen before in the United
+(States history, of forging documents, an affront to
+(any decent lawyer, signing Judge's Orders, sending
+(false statements to other lawyers. The people who
+(have been -- excuse me -- the Complaint by the U.S.
+(Attorney, in fact, describes the behavior of the
+(law firm, as well as Mr. - my Complaint says,
+Mr.
+being a part of that
+15 (Pages 54 to 57)
+PROSE COURT REPORTING AGENCY, INC. (561) 832-7506
+(561) 832-7500
+
+
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+Page 58
+BY MR SCAROLA:
+Q. Now, before you answered that question, you
+reviewed a document, right?
+A. The Complaint, sir.
+Q. I'd like to see it, please.
+MR. PIKE: Definitely not, Mr. Scarola.
+My notes are on that and that's
+attorney/client. I allowed the witness to take a
+look at the document and he did not write anything
+on the document. He looked at the document.
+That's my client. And you will certainly not be
+looking at my notes, which are all over this
+document.
+MR. SCAROLA: He didn't look at everything.
+He looked at one page. I would like that one page,
+please,
+MR. PIKE: Absolutely not, Mr. Scarola.
+MR. SCAROLA: I would like that page marked as
+an Exhibit to this deposition.
+MR. PIKE: Absolutely not, Mr. Scarola.
+MR. SCAROLA: I would state for the record
+that it is my intention, since that page with
+handwritten notations on it was reviewed by the
+witness during the course of this deposition while
+a question was pending, I want that page preserved
+Page
+59
+so that the Court can make a determination as to
+whether I am entitled to see it.
+MR. PIKE: I would object based upon
+attorney/client and work product in that regard,
+THE WITNESS: Now can we take a bathroom
+break?
+MR. SCAROLA: No, sir, because you still
+haven't answered my question.
+THE WITNESS: Okay,
+BY MR. SCAROLA:
+(Q. (I want to know who the, quote, "hardworking
+(and honest lawyers" are that are referred to in that
+section of your Complaint,
+(A) (My attorneys, at least, are honest:
+(Which ones
+All of ther
+1º And you say that you want to vindicate the
+(hardworking and honest lawyers and their clients?
+(A- That's correct
+Me, some of the other clients, in fact, abused
+(by the Rothstein firm. I don't know the full extent"
+(Hopefülly when we get to trial, we're going to find out
+the extent of the people, the lawyers, the clients that
+(were abused by Mr. Edwards and the Röthstein firm!
+4
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+Page
+60
+(We have asked for Scott Rothstein's
+(deposition.
+We hopeffilly will get it. Maybe he will
+give us some insight on how other lawyers have, in fact,
+been handled and the abuses they've undergone, including
+forging a Federal Judge's signature, sir.
+Q. Now, was it your intention in this sentence to
+say that you were trying to vindicate the hardworking
+and honest lawyers and their clients?
+A. It's attorney/client, I'm sorry.
+Q. Your intention is attorney/client privileged?
+MR. PIKE: Form. I'm not quite --
+BY MR. SCAROLA:
+Q. Is that what you're telling us?
+MR. PIKE: Wait a second. I'm nót quite sure
+I understand the question.
+THE WITNESS: What's the question?
+BY MR. SCAROLA:
+Q. Were you attempting to communicate in this
+Complaint a desire on your part to vindicate hardworking
+and honest lawyers and their clients?
+MR. PIKE: Form.
+THE WIINESS: In this Complaint, I intend to
+get to the truth of Mr.
+behavior and the
+Rothstein firm, sir.
+BY MR. SCAROLA:
+Page 61
+Q. Well, what this sentence says is, quote, -
+A. Yes.
+Q. - "the Rothstein racketeering enterprise
+endeavored to compromise the core values of both State
+and Federal systems in South Florida and to vindicate
+the hardworking and honest lawyers and their clients who
+were adversely affected by the misconduct that is the
+subject of this Complaint."
+Is that what you meant to communicate?
+A. It says what it says, sir.
+Q. Well, I know it says what it says. I'm trying
+to find out if that's what you meant to say; that is,
+that the Rothstein racketeering enterprise endeavored to
+vindicate the hardworking and honest lawyers and their
+clients who were adversely affected by the misconduct
+that is the subject of this Complaint.
+MR. PIKE: Form. Mischaracterizes the
+language of the document.
+THE WITNESS: Yeah, I think you've misread
+that again. You want to - I certainly didn't ask
+for the Rothstein firm to vindicate the lawyers, is
+what you've just --
+BY MR. SCAROLA:
+Q. Well, that's what I'm trying to find out,
+whether you meant to say what you said in this
+16 (Pages 58 to 61)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+
+
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+Page 62
+Complaint.
+Did you read the Complaint before it was
+filed?
+MR. PIKE: Form. Move to strike.
+THE WITNESS: Thank you, sir.
+BY MR. SCAROLA:
+Q. Did you read the Complaint before it was
+filed?
+A. It was a while ago, yes, sir.
+Q. And did you approve the Complaint prior to its
+filing?
+A. Yes, sir.
+Q. (And did you mean to say what this sentence
+(says, "the Rothstein racketeering enterprise endeavored
+(to vindicate the hardworking and honest lawyers and
+their clients, who were adversely affected by the
+misconduct that is the subject of this Complaint?'
+(MR: PIKE: Okay, I'm going to move to strike.
+(Mischaracterizes the language of the document.
+(The document reads as follows, for purposes Of
+(the record: ""The Rothstein racketeering enterprise
+(endeavored to compromise the core values of both
+(State and Federal justice systems in South Florida
+and to vindicate the hardworking and honest lawyers
+and their clients who were adversely affected by,
+Page
+63
+(the misconduct that is the subject of this
+(Complaint.
+BY MR. SCAROLA:
+Q. (Is that what you meant to say?
+(A. What I meant to'say, it is = seems to me
+somewhat unclear - is that the Rothstein firm, along
+(with Mr. Edwards, is part of a criminal enterprise, the
+(largest - excuse me - the largest criminal enterprise
+(in South Florida's history, forging Judges' signatures,
+engaging in illegal wire taps, illegal behaviors. And
+(part of this lawsuit should vindicate, which means, I
+(believe should set night.
+(And if it's not clear, the Rothstein firm
+(compromised the core values of our legal justice system!
+I abused every - many of the precepts, the most basic
+(values of the American justice system.
+(And, if fact, i believe this lawsuit, part of
+(the reason for filing this lawsuit, it will disclose the
+(various techniques of attorney/client privilege, abuse
+(of technique, abuse of discovery, illegal Wire taps,
+(forging signatures engaged in by both Mr.
+and
+(his firm
+Q. (So it is your contention that Mr.
+Was
+(part of a criminal enterprise?
+A. (Yes, it is!)
+4
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+Page 64
+Q. Knowingly part of a criminal enterprise?
+MR. PIKE: Form.
+(THE WITNESS: Attorney/client privilege.
+MR. SCAROLA: You wanted to take a break and
+before I move on to another subject, we'll do that.
+But I want -- I want to observe for the record that
+the last break was less than an hour ago. While I
+want to try to make reasonable accommodations to
+witnesses so as not to impose unnecessarily upon
+their physical comfort, 1 will object to breaks
+occurring at less than one-hour intervals during
+the course of this deposition.
+VIDEOGRAPHER: We're now off video record. It
+is 11:34 a.m.
+(Brief recess.)
+VIDEOGRAPHER: We are now back on video
+record. It is 11:45 a.m. and we are on media
+number two.
+BY MR. SCAROLA:
+(Q. What knowledge do you have of Brad
+ever having personally engaged in mail fraud?
+A. It's been widely reported in the press-
+CQ. I'm going to withdraw my question
+What personal knowledge do you have of Bradley
+(Edwards ever having been engaged in any mail fraud?
+Page
+65
+A. (Will you describe what you mean by "personal
+(knowledze," sir?
+(Q (I mean direct observation through your senses
+on your part;
+(A. So are you asking me whether or not I've
+(witnessed him sending something directly, putting
+(physically in the mail, sir?
+(Q) (I'm asking whether you have ever personally
+witnessed
+ever having engaged in mail
+fraud:
+I'm not sure how that's possible for anybody
+to witness a mail fraud, so would you inform me how it's
+done?
+So the answer to my question is, you don't
+(know; is that correct?
+A.
+- My answer to your question is -
+(MR. PIKE: Form, Mischaracterizes the
+(witness' testimony,
+(THE WITNESS. I've asked for a clarification.
+(BY MR. SCAROLA
+Q.
+Have you ever personally witnessed Bradley,
+(Edwards engaging in mail fraud?
+MR. PIKE: Form.
+(THE WITNESS: No, sir?
+BY MR. SCAROLA:
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+17 (Pages 62 to 65)
+lectronically signed by Sandra Townsend 401-377-676-2895
+
+
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+Page 66
+Page
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+Q. (Have you ever personally witnessed
+Edward -
+engaged in wire fraud?
+A
+How would one -- I'm not sure how anyone would
+(personal - have personal knowledge, witness someone
+engaging in wire fraud, unless they were simply sitting
+over their computer looking at their bank accounts. So,
+unfortunately, 1 would have to say, no, sir.
+(Q (Have you ever personally witnessed Bradley
+engaged in money laundering?
+MR. PIKE: Form.
+(THE WITNESS: Again, sir, the U.S. Attorney's
+Complaint of the Rothstein firm alleges money
+(laundering, wire fraud, mail fraud, RICO claims of
+(Mr. Edwards' partners and his firm, calling the
+(firm the largest criminal enterprise in South
+Florida's history, accused of fabricating malicious
+cases, sir, of a sexually charged nature in order
+to fleece unsuspecting South Floridians out of
+millions of dollars
+(BY MR: SCAROLA:
+(Q. And I'm trying to find out, Mr. Epstein;
+whether you have any evidence whatsoever that
+Mr.
+ever personally participated in any of that
+wrongdoing?
+MR. PIKE: To that question, to the extent you
+Page
+67
+can answer it without violating attorney/client and
+work product, you can answer the question.
+(THE WITNESS: I'm afraid it will be
+(attorney/client privilege, sir;
+(BY MR. SCAROLA:
+Q.
+Do you have any evidence - Knowledge of any
+evidence whatsoever that Mr. Edwards ever participated
+(in any effort to market any kind of investment in
+(anything?
+(A. I would have to claim attorney/client
+(privilege on that, sir
+MR. PIKE: Form.
+BY MR. SCAROLA:
+(Do you have knowledge of any evidence
+whatsoever that Mr
+was ever a participant in
+devising a plan through which were sold purported
+confidential assignments of a structured payout
+settlement?
+The newspapers and blogs have widely reported
+(that Mr. Edwards' firm crafted - would you repeat the
+question for me, again, sir? I'm sorry.
+Q. (Yes, sir. I want to know whether you have any
+(knowledge of evidence that Bradley Edwards personally
+ever participated in devising a plan through which were
+(sold purported confidential assignments of a structured
+(561) 832-7500
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+(payout settlement?
+MR. PIKE: Form.
+THE WITNESS. Id like to answer that question
+(by saying that the newspapers have reported that
+Chis fimm was engaged in fraudulent structured
+(settlements in order to fleece unsuspecting Florida
+(investors,
+(With respect to my personal knowledge, I'm
+unfortunately going to, today, but I look forward
+(to at some point being able to disclose it, today
+(I'm going to have to assert the attorney/člient
+(privilege
+(BY MR. SCAROLA:
+Q
+Your Complaint alleges that Rothstein and
+others in RRA were using RRA to market investments
+(Who are the others referred to in the
+(Complaint?
+(A (From my understanding of the U.S. Attorney's
+Complaint, from Mr. Scherer's Complaint, if is the
+(partners and people who held themselves out to be
+(partners of the Roth - Scotf Rothstein, including
+(Mr. Berger, Mr. Adler, Mr. Edwards and other peoplè
+associated with the firm like Mr. Fisten, Diane
+if that's how you pronounce her name,
+(Adler, and many of the other partners of his firm
+Page
+: 69
+currently under investigation by either the Florida Bar
+or the U.S. Attorney or FBI or all of the above, sir.
+Q (Which - which source of information
+referenced in that answer specifically made reference to
+Mr. Edwards?
+A
+(I don't recall, sir.
+Q. But you do have a recollection that one or
+more of them did; is that correct?
+A. I don't recall, sir.
+Q. So you want to withdraw the earlier response
+that you made and your real answer is, I don't know; is
+that correct?
+MR. PIKE: Mischaracterizes the witness'
+testimony. Move to strike.
+BY MR. SCAROLA:
+Q. Your response, sir?
+A. My answer stays the same, sir.
+Q. Is it your contention that one or more
+lawsuits was fabricated against you?
+A. It's been widely reported in the newspapers --
+Q. That's not my question.
+A. Excuse me. I was answering.
+MR. PIKE: Please let the witness answer the
+question, Mr. Scarola.
+BY MR. SCAROLA:
+PROSE COURT REPORTING AGENCY, INC.
+18 (Pages 66 to 69)
+
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+Q. No, you're not answering my question.
+MR. PIKE: He's only said three words, so you
+don't know whether he's answering your question or
+not.
+MR. SCAROLA: I didn't ask him anything about
+newspapers, I asked him about his contention. I
+don't know he's not answering my question.
+BY MR. SCAROLA:
+Q. But you can go ahead, Mr. Epstein, and you can
+make your silly speech one more time.
+MR. PIKE: I'm going to move to strike.
+THE WITNESS: You want to repeat the question?
+BY MR. SCAROLA:
+Q. Yes, sir. I would like to know whether it is
+your contention that one or more lawsuits have been
+fabricated against you.
+A. My contention, sir, is that the firm of
+partners, Scott Rothstein, fabricated many
+cases, reported by the press and the U.S. Attorney,
+amongst people like me and others of a sexually charged
+nature in order to fleece investors of South Florida out
+of millions of dollars.
+Do I have a - with respect to my individual
+cases that Mr.
+has filed in these three cases,
+I'm unfortunately today, and only today at least, on
+Page
+71
+advice of Counsel I'm going to have to assert my Fifth,
+Sixth and 14th Amendment, sir.
+Q. Okay. Well, I'm not limiting my question to
+the three cases referenced in your Complaint I want to
+know whether you contend that any claim against you has
+been fabricated?
+MR. PIKE: Form. Overbroad and confusing and
+it's compound.
+THE WITNESS: The question makes no sense to
+me. I'm sure you could do better.
+BY MR. SCAROLA:
+Q. Is there any pending claim against you which
+you contend is fabricated?
+A. At least today, sir, I'm going to have to
+respond by asserting my Fifth, Sixth and 14th Amendment
+Right.
+MR. PIKE: Form, also.
+BY MR. SCAROLA:
+Q. Is it your contention that
+was
+ever personally involved in manufacturing false and/or .
+fraudulent Court Opinions or Orders?
+A. Attorney/client privilege.
+Q. Your Complaint makes reference to someone
+sifting through a potential defendant's garbage looking
+for damaging evidence to use with investors to show how
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+Page 72
+potential defendants could be, in essence, blackmailed.
+MR. PIKE: Would you identify for me,
+Mr. Scarola, what page?
+MR. SCAROLA: Page 8, paragraph 19.
+BY MR. SCAROLA:
+Q. Did anyone ever sift through your garbage
+looking for damaging evidence?
+MR. PIKE: One second.
+In light of clarity, Mr. Scarola, would you
+please read the entire paragraph so Mr. Epstein
+understands the tenor of the paragraph?
+MR. SCAROLA: No. I want to know whether
+anyone ever sifted through Mr.
+garbage -
+through Mr. Epstein's garbage. That's the pending
+question.
+MR. PIKE: Tothe extent you understand the
+question, you can answer,
+THE WITNESS: I think the question is poorly
+phrased. Did anyone ever sift through my garbage?
+What does that mean?
+BY MR. SCAROLA:
+Q. You don't know what sifting through garbage
+means?
+A. Does that mean the garbage man? Does that
+include the garbage man? I'm sure he sifted through my
+Page 73
+garbage.
+Q. Which garbage man sifted through your garbage?
+A. I'm sure people who go through garbage sift
+through the garbage. I have no idea.
+Q. Did anyone ever sift through your garbage
+looking for damaging evidence?
+It's been widely reported in the newspapers
+sir, that the Rothstein firm engaged in sifting through
+many people's garbage in order -- in an attempt to
+(blackmail them.
+Q. Yes. But I didn't ask you what some newspaper
+is alleged to have reported.
+What I did ask you is whether anyone ever
+sifted through your garbage looking for damaging
+evidence.
+And the answer to that question, I think, can
+be either yes, no, or I don't know.
+MR. PIKE: Move to strike. -
+BY MR. SCAROLA:
+Q. Or you could refuse to answer it on the
+grounds that it may tend to incriminate you.
+A. I think you might -*
+MR. PIKE: Move to strike.
+THE WITNESS: I would like to answer my own
+questions. If you'd like to answer all my
+19 (Pages 70 to 73)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+dectronically signed by Sandra Townsend (401-377-676-2895
+1 ddcfb84-b324-4437-a670-76529067145
+
+
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+Page 74
+questions, Mr. Scarola, I'm more than happy to sit
+here and answer them. Would you like to continue?
+BY MR. SCAROLA:
+Q. (Yes. Id like to know what the answer to that
+(question is. Did anyone ever sift through your garbage
+(looking for damaging evidence?
+MR. PIKE: Form.
+(THE WITNESS: I don't know
+BY MR. SCAROLA:
+Q. Did you ever have damaging evidence in your
+garbage?
+A. What's damaging evidence, sir?
+Q. Evidence tending to implicate you in criminal
+conduct.
+MR. PIKE: Form.
+THE WITNESS: At least today, Mr. Scarola,
+with these - with your questions and your claims
+and your defense of Mr.
+and his firm, the
+Rothstein firm, while his partner sits in jail,
+today I'm going to have to assert my Fifth, Sixth
+and 14th Amendment Right, sir.
+BY MR. SCAROLA:
+Q. Did you ever have any evidence in your garbage
+that would subject you to blackmail?
+MR. PIKE: Form. Same - same objection.
+Page
+75
+THE WITNESS: Again, I'll respectfully answer
+the question by asserting my Fifth, Sixth and 14th
+Amendment Right.
+BY MR. SCAROLA:
+Q. Your Complaint in paragraph 21, page 9, says)
+that: "Upon information and belief, Rothstein, David
+Boden, Debbie
+Andrew Barnett, Michael Fisten
+and Kenneth Jenne, all employees of RRA, through brokers
+or middle men would stage regular meetings during which
+false statements were made about the number of
+cases/clients that existed or RRA had against Epstein
+and the value thereof."
+Do you have any knowledge that Mr.
+ever knew about such meetings being conducted?
+MR. PIKE: Form.
+To the extent you understand the question and
+it will not violate any attorney/client or work
+product privilege information, you can answer that
+question.
+MR. SCAROLA: Mr. Pike, it has become evident
+that that speaking instruction to your witness is
+an instruction for him to assert an attorney/client
+privilege, regardless of whether it is or is not
+valid and I object to it.
+MR. PIKE: Let me make the record clear.
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+Page 76
+You've been interchanging knowledge with personal
+knowledge. And many of the objections to which I
+am asserting an attorney/client and work product
+privilege are based upon your malphrased question
+and use of personal knowledge and knowledge
+interchangeably with those questions.
+So if you want to rephrase your question to
+attempt to elicit a response -- let me finish --
+then I have no objection to that. However, I'm not
+going to sit here and allow my client to waive
+attorney/client and work product.
+Now, to the extent you're saying I'm coaching
+the witness, I object to that because I am
+certainly not. The witness is here to answer your
+questions and I believe has been answering your
+questions today to the best of his ability.
+MR. SCAROLA: 1 am saying you're coaching the
+witness.
+BY MR. SCAROLA:
+Q. Could you answer the question?
+MR. PIKE: Same objection.
+THE WITNESS: You'll have to repeat it.
+BY MR. SCAROLA:
+Q Do you have any information indicating that
+(Bradley Edwards ever had any knowledge of anyone
+Page
+77
+associated with the Rothstein firm holding meetings
+(during which, quote,
+"false statements were made about
+(the number of cases/clients that existed or RRA had
+(against Epstein and the value thereof," unquote?
+MR. PIKE: Form. Same objection.
+(THE WITNESS: My best recollection is the U.S
+Attorney has accused the Rothstein firm of just
+those types of meetings where the partners got
+(together, schemed to defraud local investors of
+(millions of dollars by fabricating cases of a
+sexually charged nature. And whether Mr. Edwards
+(personally participated, I'm going to at least
+(today, sir, have to assert the attorney/client
+(privilege, but look forward to one day disclosing
+MR. SCAROLA: Move to strike all unresponsive
+portions of the answer.
+BY MR. SCAROLA:
+Q (Paragraph 23 Of your Complaint says that
+"RRA, Rothstein and
+claiming the need for
+(anonymity with regard to existing or fabricated clients,
+they were able to effectively use initials" etcetern
+Do you have any knowledge that
+(fabricated a client to bring a claim against you?
+MR. PIKE: Form.
+20
+(Pages 74 to 77)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+Electronically signed by Sandra Townsend (401-377-576-2895)
+
+
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+Page 78
+(THE WITNESS: I believe Mr: Scherer's
+(Complaint,
+BY MR SCAROLA:
+(Q. I'm not asking about Mr. Scherer's Complaint.
+(I'm'asking about any evidence that you have
+MR. PIKE: The witness is basically been five
+words into his sentence and you're not allowing him
+to finish, once again.
+So if you recall the question, then please
+respond.
+THE WITNESS: Please repeat it back, please?
+MR. PIKE: Madame Court Reporter, if you
+would.
+(Pending question was read.)
+MR. PIKE: Form.
+(THE WITNESS: The pleadings of Mr. Scherer and
+Chis claim against the Rothstein firm for a massive
+(fraud, as well as Mr. Sakowitz's claims to - at
+(least in the described in the public press,
+(because he went to the FBI, for fabricating cases
+(that included initials.
+(With respect to anything specific with
+(Mr. Edwards, I'm going to have to claim the
+(attomey/client privilege today, sir.
+BY MR. SCAROLA:
+Page
+7,9
+Q. (Do you have any - do you have knowledge of
+(the existence of any evidence that Bradley Edwards knew
+(that Rothstein was utilizing RRA as a front for a Ponzi
+(scheme?
+MR. PIKE: Form.
+(THE WITNESS: That's attorney/client
+(privilege)
+(BY MR: SCAROLA;
+-Do you have knowledge of any evidence that
+would indicate
+s should have known that
+(Rothstein was utilizing RRA as a front for a Ponzi
+(scheme?
+MR. PIKE: Form.
+THE WITNESS: At least today --
+MR. PIKE: Wait.
+THE WITNESS: Sorry.
+MR. PIKE: Form. Same objections. Same
+attorney/client, work product as to the last
+question. Same objections here, attorney/client
+work product.
+(THE WITNESS: And today I'm going to have to
+(assert the attorney/client privilege.
+MR. PIKE: To the extent you can answer that
+question -
+THE WITNESS: I understand.
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+MR. PIKE: - then, please, -
+THE WITNESS: Yes.
+MR. PIKE: - answer Mr. Scarola's question.
+THE WITNESS: Separate from --
+MR. SCAROLA: Objection. Coaching the
+witness.
+(THE WITNESS. Separate from the communication
+(I've had with my attorneys, I can't answer that
+(question.
+MR. PIKE: Mr. Scarola, I'm confused. I
+started objecting to form in the beginning of this
+deposition. You then instructed me, which is
+against the rules, Mr. Pike, I don't know what's
+wrong with the form. I object to you objecting to
+form.
+Then I assert the attorney/elient, work
+product, and now you're telling me I'm coaching the
+witness.
+So tell me, Mr. Scarola, what is the - what
+is the way that you would like me to object in this
+deposition, and maybe I can conform that way for
+you, which may or may not be consistent with the
+Florida Rules of Civil Procedure.
+MR. SCAROLA: Mr. Pike, -
+MR. PIKE: Yes, sir.
+Page 81
+MR. SCAROLA: -- if you don't know the
+difference between a form objection and a privilege
+objection -
+MR. PIKE: Right.
+MR. SCAROLA: -- then this deposition is not
+the proper context in which for you to learn the
+difference between a form objection and a privilege
+action.
+MR. PIKE: I'm pretty clear on what a form
+objection is and what a privilege objection is and
+I'm pretty knowledgeable on that. The problem -
+MR. SCAROLA: Then we don't need to engage in
+any further discussion.
+MR. PIKE: - I want to try to make the record
+clear, because initially you didn't want me to
+object to form. You wanted me to speak. So I'm
+thinking you're conceding to that point.
+What my question is, is: What's wrong with my
+objecting to attorney/client, work product? So I
+guess I'm asking you what you were asking me
+earlier on. What's wrong with the form?
+We can just move forward.
+BY MR. SCAROLA:
+Q. In your Complaint you identify the RRA law
+firm, Rothstein and
+- as the, quote, "litigation
+21 (Pages 78 to 81)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+
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+Page 82
+team," unquote.
+You then go on to say in paragraph 31 of your
+Complaint at page 12 that: "Rothstein and the
+litigation team" --
+MR. PIKE: Wait a minute. Put that down for a
+second. Hold on.
+THE WITNESS: You can read it.
+BY MR. SCAROLA:
+Q. "Individually and in a concerted effort may
+have unethically and illegally engaged in certain
+specified conduct."
+May we correctly conclude from that statement
+that you don't have any knowledge as to whether the,
+quote, "litigation team," including Mr.
+engaged
+in any unethical and illegal conduct?
+MR. PIKE: For now, while I'm reviewing the
+document itself, I'm just going to just tell you to
+hold off -
+THB WITNESS: Sure.
+MR. PIKE: - on answering that question.
+You may want to go off the record, so we don't
+have a lag in -
+MR. SCAROLA: No, I'd like it on the record.
+Thank you.
+MR. PIKE: Mr. Scarola, did you bring an extra
+Page
+83
+copy of the Complaint that you're questioning
+Mr. Epstein on for Mr. Epstein to look at?
+MR. SCAROLA: No.
+MR. PIKE: Okay. I'm going to have to go get
+him a copy so he can -- the paragraphs of this
+Complaint are very long and the Complaint itself is
+in excess of -- it was approximately 35 pages,
+50...
+MR. SCAROLA: I'II withdraw the question.
+BY MR. SCAROLA:
+Q. (Do you have any evidence that Brad Edwards
+(sold allowed to be sold and/or assisted with the sale
+of an interest in non-settled personal injury lawsuits?
+MR. PIKE. Form.
+THE WITNESS: (The newspapers have widely
+(reported that the Rothstein firm engaged in illegal
+(structured settlements of cases of a sexual nature,
+including specifically me We have subpoenaed the
+(documents from Mr.
+and his firm and we have
+(not been able to get them as of yet.
+Tam confident that once we do, I will be able
+(to answer your questions with more specificity
+BY MR. SCAROLA:
+Q. (As you sit here today, do you have any
+¡evidence whatsoever to support an assertion that
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+individually and personally, sold, allowed to
+(be sold and/or assisted with the sale of an interest in
+non-settled personal injury lawsuits?
+MR. PIKE: Before you answer that question,
+Madame Court Reporter, will you please read that
+question back to me?
+(Pending question was read.)
+MR. PIKE: To the extent you can answer that
+question without divulging attorney/client or work
+product information, you may answer that question.
+MR. SCAROLA: Objection. Coaching.
+THE WITNESS: You said, allowed to be sold.
+(I'm going to assert attorney/client privilege to
+the answer, I'm afraid, but Id like to answer that
+question.
+BY MR. SCAROLA:
+Q. (Do you have knowledge of any evidence
+(indicating that Bradley
+ever reached agreements
+to share attorney's fees with non-lawyers?
+MR. PIKE: I'm sorry. Mr. Scarola, can you
+tell me what page of the Complaint you're referring
+to, if you are?
+MR. SCAROLA: I'm not referring to any page of
+the Complaint, although I will tell you that that
+precise allegation is made in the Complaint.
+Page 85
+THE WITNESS: (In fact, Mr. Scarola, we have
+(subpoenaed Mr. Edwards' documents and documents
+(from his firm that I believe will, in fact, give me
+more specificity with the answers to that question.
+I'm looking forward to getting the - that
+(specific evidence. With respect to what we
+currently know, sitting here today, I'm
+unfortunately going to have to claim my
+attorney/client privilege
+(BY MR: SCAROLA:
+(Do you today have any evidence to support an
+(assertion that
+ever used investor money
+to pay L.M., E.W., and/or Jane Doe up-front money, such
+that they would refuse to settle civil actions?
+MR. PIKE: Same instruction.
+THE WITNESS: You'll have to get -- I need to
+hear the first part of the question. Do I have any
+evidence? Do I have knowledge of evidence? I'm
+sorry. What was the -
+BY MR. SCAROLA:
+Q. Do you have knowledge of any evidence to
+support that assertion?
+MR. PIKE: To the extent you can answer that
+question without violating attorney/client, work
+product, please do so.
+22 (Pages 82 to 85)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
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+MR. SCAROLA: Objection. Coaching.
+THE WITNESS: I'm going to have to assert the
+(attorney/client privilege, I'm afraid, though Ta
+"like to answer that question as well, sir.
+BY MR. SCAROLA:
+Q. (Do you have apy evidence to support the
+asseition that
+conducted searches, wife
+(taps or intercepted conversations in violation of State
+or Federal laws and Bar rules?
+A. (Your question, once again, asked did Mr.-
+was Mr. Edwards personally involved in the
+eavesdropping?" Did he walk to someone's house and sort
+of put a bug in their house?" Did he, personally, stand
+outside?
+(The question is, did Mr. Edwards' firm engage
+(in this behavior in an attempt to defraud local
+(unvestors out of millions of dollars? The U.S. attorney
+Chas filed a Complaint saying that they did. The
+Complaints filed by Scherer saying that his fim did.
+(The Scherer Complaint says my name and the
+(boxes of files that we've subpoenaed used my name, sir.
+(We have requested information, but up until
+(today have not received any,
+(To give you a more specific answer, I'm afraid
+(I'cannot
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+O. (Do you have knowledge of any evidence that
+ever conducted searches, wire taps or
+(intercepted conversations in violation of State or
+Federal laws and Bar rules?
+MR. PIKE, Same instruction.
+THE WITNESS: The newspapers and the U.S:
+(Altomey's Complaint widely reported that
+(Mr.
+firm and people hired by his fim,
+investigators hired by his finn fraudulently
+(representing themselves as FBI'agents engaged in
+(Just those activities, sir
+BY MR. SCAROLA:
+Q. (Do you have any knowledge of any evidence that
+(Bradley Edwards was ever aware of any such activities?
+A. (I'm going to have tog
+MR. PIKE: Same objection.
+THE WITNESS: -assert the attorney/client
+privilege to that, sir
+BY MR. SCAROLA:
+Q. (Do you have any knowledge that
+ever participated in or was aware of actions that
+(utilized the judicial process, including, but not
+limited to, unreasonable and unnecessary discovery for
+the sole purpose of furthering a Ponzi scheme?
+MR. PIKE: Same objection.
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+To the extent you can answer the question
+without disclosing attorney/client or work product
+information, do so.
+(THE WITNESS. The pleadings of Mr. Scherer
+with respect to the largest Ponzi scheme in South
+Florida's history engaged in by Mr. Edwards" fim
+and Scott Rothstein, who currently sits in jail,
+probably for the rest of his life for engaging in,
+not only illegal wire taps and eavesdropping, but
+an abuse of the entire legal system, I believe
+(speaks for itself.
+(Unfortunately, with respect to Mr. Edwards
+today, I'm going to have to assert the
+attorney/client, work privilege, sii
+BY MR. SCAROLA:
+Q. (Is it your contention that Mr. Scherer's
+Complaint even contains the name
+(A! (I don't recall, sir.
+Q. Did sexual assaults ever take place on a
+private airplane on which you were a passenger?
+MR. PIKE: Form. Relevance.
+THE WITNESS: At least - I would like to
+answer each and every one of your questions here
+today, Mr. Scarola. But at least today, I'm going
+do have to assert my Fifth, Sixth and 14th
+Page 89
+Amendment Rights as provided by the U.S.
+Constitution.
+BY MR. SCAROLA:
+Q. Does a flight log kept for a private jet used
+by you contain the names of celebrities, dignitaries or
+International figures?
+A. At least today, sir, I'm going to have to
+respectfully decline to answer based on my Fifth, Sixth
+and 14th Amendment Right, though I'd like to answer that
+question.
+Q. Have you ever had a personal relationship with
+Donald Trump?
+A. What do you mean by "personal relationship,"
+sir?
+Q. Have you socialized with him?
+A. Yes, sir.
+Q. Yes?
+A. Yes, sir.
+Q. Have you ever socialized with Donald Trump in
+the presence of females under the age of 18?
+A. Though I'd like to answer that question, at
+least today I'm going to have to assert my Fifth, Sixth
+and 14th Amendment Right, sir.
+Q. Have you socialized with Alan Dershowitz?
+A. Yes, sir. He's my attorney, as well as a
+23 (Pages 86 to 89)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
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+friend.
+Q. (Have you ever socialized with Alan Dershowitz
+(in the presence of females under the age of 18?
+THE WITNESS. Sir, at least here today, Im
+(going to have to assert my Fifth Amendment, Sixth
+Amendment and 14th Amendment Rights.
+BY MR. SCAROLA:
+Q. Have you ever socialized with Tommy Mottola?
+A. This is the type of questions where people who
+have nothing to do with this case whatsoever have been
+brought into the case by Mr.
+in an attempt to
+simply imperil my relationships with social friends and
+serves as an example of why this case has been brought
+against Mr.
+and his firm, sir.
+MR. PIKE: Form as well.
+BY MR. SCAROLA:
+Q. Well, do you know who brought those persons'
+names into this lawsuit?
+(And just to be clear, what Mr. Scarola, !
+(believe, talking about this lawsuit, Epstein versus
+(RRA?
+(BY MR SCAROLA;
+TQ.- Yes, sir, that's the lawsuit Imi talking
+4
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+about. The one in which your deposition is being taken
+today.
+Do you know who brought those persons names
+into this lawsuit?
+A. As a reaction, and only as a reaction to total
+misbehavior on Mr.
+part, and the Complaint was
+obviously written by my attorneys, sir.
+Q. So you know that those names are in your
+Complaint, right?
+A. Yes, sir.
+Q. Okay. So because those names are in your
+Complaint, I'm asking you about the people you named.
+Have you had a social relationship with Tommy
+Mottola?
+A. The names in my Complaint are strictly as a
+reaction to the abusive discovery process by
+Mr.
+his partners, Scott Rothstein, who sits in
+jail, in an attempt to imperil my friendships.
+But, yes, I have socialized with Mr. Mottola.
+Q. Have you ever socialized with Mr. Mottola in
+the presence of females under the age of 18?
+MR. PIKE: Form.
+THE WITNESS: At least today, the typical to
+the
+contention of bringing cases of a
+malicious nature where his partner sits in jail for
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+Page
+: 92
+(this - just this type of behavior, the answer is,
+(today, at least, 1 must assert my Fifth, Sixth and
+(14th Amendment Right, though Ta like to answer
+each and every one of your questions, Mr. Scarola.
+BY MR. SCAROLA:
+Q. Have you had a social relationship with David
+Copperfield?
+A. As a reaction to, once again, the abusive
+discovery process of bringing in names of people that
+have absolutely nothing to do with any of Mr.
+Mr. Rothstein's or their clients' claims, by bringing in
+the names of friends of mine strictly in an attempt to
+stress my relationships, imperil my business
+relationships, I'm going to say, yes, I do know
+Mr. Copperfield.
+Q. (Have you ever socialized with David
+(Copperfield?
+CA.
+Again, ase
+MR. PIKE For
+THE WITNESS: Sorry,
+(It's a typical Edwards/Rothstein strategy of
+trying to involve well-known people in maliciously
+(fabricated cases in order to fleece investors out
+Cof millions of dollars. They brought up names in
+attempts at abuse of discovery process to try and
+Page
+93
+take discovery of people who have nothing to do
+with this case
+Did 1 socialize with David Copperfield? The
+answer is, yes
+(BY MR. SCAROLA;
+(Q. Did you ever socialize with David Copperfield
+(in the presence of females under the age of 18?
+A. I'm sure, again, this question is a typical
+question of Mr. Edwards/Rothstein scheme to defraud
+investors, asking questions knowing it serves no purpose
+Cor relationship relevance to their case whatsoever.
+At least today, though Id like to answer that
+question, on advice of my Counsel, and only on advice of
+(my Counsel, I'm going to have to assert my Fifth, Sixth
+and 14th Amendment Right
+(MR. PIKE: (Form as well.
+BY MR. SCAROLA:
+Q (Have you ever had a social relationship with
+(Bill Richardson, Governor of New Mexico and formerly,
+U.S. Representative and Ambassador to the United
+(Nations)
+(MR. PIKE: (Form.
+THE WITNESS: As is typical of the Edwards
+scheme, along with his partner, Scott Rothstein,
+Who sits in jail, what they attempted to do was
+24 (Pages 90 to 93)
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+(bring in any celebrity I might have known,
+well-known people, in an attempt to strictly
+(imperil my relationships with these people where
+these people have no bearing whatsoever on any of
+(their claims or cases!
+(Yes, Tad have a social relationship,
+(BY MR. SCAROLA:
+(Q. (Have you ever socialized with Mr.
+in the presence of females under the age of 18?
+(MR. PIKE: Form.
+THE WITNESS: Again, typical of the
+(Edwards/Rothstein scheme of bringing in well known
+(people, asking them ridiculous questions,
+(ridiculous questions in an attempt strictly to
+(imperil my relationships with these people where
+they have absolutely nothing to do with anything to
+(do with Edwards, Rothstein or any of their alleged
+victims, the answer to your question is, yes,!
+have socialized.
+(BY MR. SCAROLA;
+Q. (Yes, but that wasn't my question
+My question was: Have you ever socialized
+with Mr. Richards in the presence of females under the
+age of 18?
+(MR. PIKE: Form
+C
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+THE WITNESS: In response to your question,
+again, my full answer was, typical of the
+Rothstein scheme to ask questions of'a
+sexual charged nature, crafted cases, the U.S.
+Attorney has called his firm the largest fraud in
+U.S. history, fleecing investors out of millions of
+dollars by engaging in just these types of
+questions. Though I would like to answer each and
+every question about every one of these people, on
+advice of my Counsel today, I must take -- assert
+my Fifth Amendment, Sixth Amendment and 14th
+Amendment Right: Though Id prefer to answer the
+question, I was told that if I choose to do so, I
+risk losing their representation, sir.
+BY MR. SCAROLA:
+Q. Have you ever sexually abused children?
+MR. PIKE: Form.
+THE WITNESS: On advice of Counsel, and only
+upon advice of Counsel, though I'd like to answer
+that question, as well as every other one of your
+claims brought by Mr.
+and his partner, who
+currently sits in jail, sir, I would like to answer
+those questions. But today at least, I have to
+assert my Sixth Amendment, 14th Amendment and Fifth
+Amendment Right. Though I'd prefer to answer the
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+(question, I'm told by my Counsel that if I choose
+(to do so, which is my preference, risk losing
+their representation
+(BY MR. SCAROLA:
+(Q. (How many children have you sexually abused?
+(MR. PIKE: Form
+And I just want to be clear on the record:
+These types of questions are argumentative and
+(harassing, And, moreover, it's my contention that
+these types of questions are not related to this
+(lawsuit by any stretch of the imagination, In this
+(deposition, while I've been liberal in allowing
+(these questions, are being utilized in an attempt
+to provoke a waiver of the Fifth Amendment Right!
+There has been an Order entered by, I believe,
+Judge Hafele regarding these types of questions.
+So with that caution, Mr. Scarola, I would ask
+you that you refrain from asking abusive and
+harassing questions that are not relevant to this
+case.
+MR. SCAROLA: Well, it's very interesting that
+you claim they're not relevant when they are
+directly taken from the allegations in your
+Complaint.
+And I agree with you that they are not
+96
+Page 97
+relevant because there is no basis whatsoever for
+this claim against Mr.
+- But since you've
+made these baseless allegations, I am obliged to
+pursue the allegations by asking these questions.
+So well move on from there. And whenever you
+think it's appropriate to terminate this deposition
+because you believe that I've acted
+inappropriately, be my guest.
+MR. PIKE: I appreciate your invitation,
+Mr. Scarola.
+I'm going to move to strike.
+The fact is, Mr. Scarola, is that, these types
+of questions have already been ruled upon as being
+argumentative and harassing.
+If you want to direct some questions relevant
+to your lawsuit, I invite you to do so. But
+attempting to use this deposition process as a
+mechanism to provoke a waiver of the Fifth
+Amendment and to obtain information that is more or
+potentialiy more relevant to Mr.
+I cases in
+which he is lead Counsel on, I think is improper.
+BY MR. SCAROLA:
+Q. Did you have staff members that assisted you
+in scheduling appointments with underage females; that
+is, females under the age of 18?
+25 (Pages 94 to 97)
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+Q. What day are you prepared to answer all these
+questions?
+MR. PIKE: Form. Attorney/client and work
+product.
+THE WITNESS: That's attorney - I wish I
+could answer that question as well, but it's
+attorney/client privilege, sir.
+BY MR. SCAROLA:
+Q. Your Complaint says that: "Rather than
+evaluating and resolving the cases based on the merits,"
+open parens, "i.e.., facts," close parens, which
+included knowledgeable, voluntary and consensual actions
+by each of the claimants," etcetera.
+Who are the claimants that are referenced
+there?
+A. It's - I'm sorry. You have to repeat the
+question.
+Q. Yes, sir. Your Complaint says,: -
+MR. PIKE: Page?
+Q. - "rather than evaluating" --
+MR. PIKE: Can you give me a page, sir?
+MR. SCAROLA: Page 27, paragraph 49, second
+sentence.
+BY MR. SCAROLA:
+Q. Quote, "rather than evaluating and resolving
+Page
+115
+the cases based on the merits, that is, facts which
+included knowledgeable, voluntary and consensual actions
+by each of the claimants."
+A. Yes.
+Q. Who are the claimants that you're referencing
+there?
+A. They're the prostitutes you referred to in the
+past, sir.
+Q. What are their names?
+A. I think the prostitutes' names were - the
+prostitute that you desctibed before was L.M.
+With respect to the others, I'm going to have
+to claim the Fifth, Sixth and 14th Amendment, sir.
+Q. So one of the individuals that you're
+referencing there is L.M.; is that correct?
+A. It's -- the individual I've referenced is a
+person who filed a claim against me.
+Q. Is it L.M.7
+A. It is L.M., as far as I know from the claim,
+sir.
+that correct?
+A. With respect to that question, sir, on advice
+of Counsel, I'm going to have to assert my Fifth, Sixth
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+and 14th Amendment.
+Q. What are the voluntary and consensual actions
+by L.M. that you are referencing there?
+A. Sir, though I'd like to answer each one of
+your questions here today, I'm going to have to
+respectfully decline based on advice of my Counsel, and
+have to assert my Fifth, Sixth and 14th Amendment Right.
+Q. What are the damages that you claim to have
+suffered as a consequence of any wrongdoing on the part
+MR. PIKE: Form.
+THE WITNESS: The cost of ridiculous
+(litigation, of having my attorneys prepare
+(responses to wildly irrelevant discovery in various
+(locations at a minimum, sir
+BY MR. SCAROLA:
+Q. Which lawyers?
+A. (Burman Critton, Jack Goldberger, and a bunch
+of the others, sir,
+Q. Which onest (Name them for me, please.
+A,
+Specifically = 1 have so many lawyers
+(defending me here against Mr.
+I can't sit
+(here - at the moment I can't recall it with
+(specificity,
+Q. (You don't remember any of your lawyers' names?
+Page 117
+A. (Oh, I do.
+Q. (Besides Mr. - besides the Burman Critton firm
+(and Mr. Goldberger?
+A. (Are you asking me for the firm, sir, or are
+(you asking me for the names?
+Q. (I want as much information as you can give me
+about this element of damage which you claim; and, that
+(is, the cost of legal services that you claim to be
+damages in this case
+A. Okay.
+MR. PIKE: Form. And move to strike.
+(THE WITNESS: Mr. Roy Black
+BY MR. SCAROLA:
+Q. Okay. Who eise?
+A. (Mr. Marty Weinberger.
+3 (Mr. Alan Dershowitz
+Mr. Jay Lefkowitz. The firm of Burman Critton Luttier.
+That's it for the moment.
+Q. (How much have you paid the law firm of Burman
+Critton and Luttier which you claim is damages?
+A. (Hundreds of thousands of dollars, sir.
+Q. How much?
+A. (I don't have that figure offhand.
+Q. Can you give us any better figure than
+(hundreds of thousands of dollars?
+A. No, not sitting here today.
+30 (Pages 114 to 117)
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+Q. (Are you paying them on an hourly basis?
+(A. Yes, sir.
+(Q. What is the hourly rate at which you are
+compensating members of the law firm?
+(A. They're ordinary rates.
+(Q (What are they?
+(A. I don't know.
+(Q.- How much have you paid Mr. Göldberger?
+(A. I'm not aware total amount, sir
+(Q. (What is the hourly rate at which you're payin
+(Mr. Goldberger?
+(A. His normal hourly rate.
+(Q.- How much is that?
+CA. I don't know.
+(Q.- How much have you paid Mr. Black which you
+claim as damages in this case?
+CA. Hundreds of thousands of dollars
+Are you paying him on an hourly basis?
+Ibelieve so
+(What is the hourly rate?
+(A.
+I'm not - 1 do not know, sir
+"How much have you paid Marty Weinberger?
+A. (L'don't know the exact amount, sir
+What's your best estimate?
+(A. More than a hundred thousand dollars
+24
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+Q. Are you paying him on an hourly basis?
+(A.
+"I believe so!
+Q. What's the hourly rate?
+I don't know, sir
+(Q.- How much have you paid Alan Dershowit2?
+(A. Hundreds of thousands of dollars
+Are you paying him on an hourly basis?
+(A
+I believe so?
+"At what hourly rate?
+(A. I don't know, sir?
+Q.- How much are you paying Jay - how much have
+(you paid Jay Lefkowitz?
+(A. I'm not sure, sir
+Q) (Do you have any idea at all?
+A.
+'More than a hundred thousand dollars.
+(Q. Are you paying him on an hourly basis?
+(A. Yes, sir?
+Q. What's the hourly rate?
+A. I don't know.
+Q) What is the form of payment to your lawyers?
+How do you transfer money to them?
+A. I'don't know, sir
+MR. PIKE: Form.
+BY MR. SCAROLA:
+Q. (Pardon me?)
+GOGGONE
+12
+2.
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+A. I don't know.
+(Q.
+Does someone do that on your behalf?
+A L would guess so.
+(Q.
+Who?
+CA. I'don't know.
+MR. PIKE: Form.
+BY MR. SCAROLA:
+Q. Who are the people who are authorized to make
+payment on your behall?
+A. With respect to that question, I'm going to
+have to assert the Fifth, Sixth and 14th Amendment, sir.
+Q. (Are there any other elements of damage, apart
+(from the money paid to lawyers?
+(A. Yes, sir.
+Q (What?
+The stress and emotional damage of imperiling
+my friendships and business relationships with no
+relevance whatsoever to these cases, brought by a firm
+(that whose partner sits in a Federal prison, who engaged
+in discovery to harass my friends and social contacts
+with no consideration or relevance to this case
+whatsoever, in an attempt to simply fleece - partly
+(fleece investors in South Florida out of millions of
+dollars, sir
+Q! (What is the value of those losses?
+Page 121
+MR. PIKE: Form.
+THE WITNESS: (I'm not sure yet, sir
+BY MR. SCAROLA:
+Q (Do you have any idea at all?
+A
+Not sitting here today.
+Q (More or less than $10?
+MR. PIKE: Form.
+(THE WITNESS? 1 would guess it's more thar
+($10, sir
+(BY MR. SCAROLA:
+Q.
+More or less than a hundred?
+A. (I would guess it's quite an amount of money,
+(Q! (Is it more or less than a hundred?
+Yes, sir
+Q.
+More or less than a thousand?
+A. I would say it's more than 150,000
+Q. More or less than a million?
+(A. I don't know, sir.
+(Q) So somewhere between 150,000 and a million?
+A.
+No, sir. It's not -
+MR. PIKE: Form. Mischaracterizes the
+witness' testimony.
+(THE WITNESS: No, sir. That's not what !
+said. I said, I did not know
+BY MR. SCAROLA:
+31 (Pages 118 to 121)
+(561) 832-7500
+PROSE COURT REPORTING AGENCY, INC.
+
+
+3
+4
+5
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+1
+3
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 122
+Q. Maybe more than a million?
+A.
+ybe
+Q
+" More or less than a billion?
+MR. PIKE: Form.
+(THE WITNESS: Tdon't know.
+BY MR. SCAROLA:
+Q. Maybe more than a billion?
+A. Maybe more.
+Q. How are you going to go about finding out what
+the value of that loss is?
+MR. PIKE: Attomey/client, work product.
+To the extent you can answer without
+disclosing our conversations or the conversations
+with your other attorneys that you've delineated,
+you can do so.
+BY MR. SCAROLA:
+Q. Or you can just take the signal and say, 1
+refuse to answer because it's attorney/client privilege.
+A. I resent that.
+MR. PIKE: Move to strike.
+THE WITNESS: But it's okay. You can continue
+to try to harass me, sir. It doesn't work. The
+ladies and gentlemen of the jury, hopefully when
+they see the deposition will recognize and see
+these pile of tricks. The answer -
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Page 123
+MR. SCAROLA: Hopefully they will.
+THE WITNESS: Yes.
+MR. PIKE: Move to strike.
+1
+2
+3
+THE WITNESS? 1 will respectfully decline to
+answer that!
+5
+(BY MR. SCAROLA:
+Q.
+On what basis?
+Attorney/client privilege.
+(MR. PIKE: And work product
+(BY MR. SCAROLA:
+Any other elements of damage?
+Not -- there might be, but sitting here today,
+(I can't think of them.
+g
+10
+11
+12
+13
+Q Do you have written contracts with any of your
+(lawyers?
+15
+A. 1 don't know.
+Q. Who does?
+(16
+17
+A.
+I don't know.
+18
+MR. SCAROLA: Let's take a short break. We
+19
+may be finished.
+20
+VIDEOGRAPHER: We are now off the record at
+21
+1:12 p.m.
+22
+(Brief recess.)
+23
+VIDEOGRAPHER: We are back on video record at
+24
+1:18 p.m.
+25
+Page 124
+BY MR. SCAROLA:
+Q. Do you attribute all of the damages that you
+have described to Mr.
+conduct?
+MR. PIKE: Form.
+THE WITNESS: As a participant - I don't know
+how to proportion the conduct as opposed to
+Mr.
+and his partner who sits in jail. I
+guess the U.S. Attorney will also make a decision
+to how much the conduct and proportion is relevant
+to both damages and anything else he's done in this
+case, sir.
+BY MR. SCAROLA:
+Q. But I'm not asking you about what the U.S.
+Attorney's opinion is.
+I want to know whether you hold Mr.
+responsible for all of those elements of damage that you
+have described to us.
+A. It's a difficult question to answer,
+Mr. Scarola.
+Q. No, it's easy. Yes, no, or I don't know.
+MR. PIKE: Mr. Scarola, you know as well as I
+do, the witness is attempting to answer your
+question.
+MR. SCAROLA: I don't think so. I think he's
+attempting to evade all of my questions.
+Page 125
+MR. PIKE: And I understand your contention.
+However, if you would, allow Mr. Epstein to finish
+his response.
+THE WITNESS: Could you repeat your question?
+BY MR. SCAROLA:
+Q. Do you hold Mr.
+responsible for all of
+the damages that you have described?
+MR. PIKE: Form.
+THE WITNESS: It's difficult for me to
+proportion the damages that I have described
+between Mr.
+, his partner, who is currently
+in jail, his -- the other people named in the
+Complaint. Hopefully a jury will do that.
+BY MR. SCAROLA:
+Q. Do you hold L.M. responsible for all of the
+damages you have described?
+MR. PIKE: Form.
+THE WITNESS: Again, these questions, these
+ambiguous questions, as opposed to who
+participated, I would let Mr.
+and his
+clients and his partners decide whose proportionate
+responsibility it is, sir.
+BY MR. SCAROLA:
+Q. So you defer to them?
+MR. PIKE: Form.
+32 (Pages 122 to 125)
+(561) 832-7500
+• PROSE COURT REPORTING AGENCY, INC..
+Electronically signed by Sandra Townsend (401-377-576-2895)
+
+
+NOT A CERTIFIES
+
+
+Filing # 64026530 E-Filed 11/09/2017 05:20:40 PM
+FIFTEENTH JUDICIAL CIRCUIT,
+IN AND FOR PALM BEACH
+COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and L.M.,
+individually,
+Defendants,
+HIED COPY
+COUNTER-PLAINTIFF'S,
+AMENDED EXHIBIT LIST
+COMES NOW the Counter-Plaintiff, BRADLEY J. I
+Amended Exhibit List as follows:
+INDEX TO OBJECTIONS
+and hereby files his
+O. No objection
+5. Privileged
+1. All objections
+6. Opinion
+2. All objections, except authenticity
+3. Irrelevant or immaterial
+7. Hearsay
+8. Authenticity lacking
+4. Probatiye value substantially
+outweighed by danger of unfair
+prejudice, confusion of issues,
+misleading the jury, or needless
+presentation of cumulative evidence
+9. Other (please identify basis of objection)
+
+
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+and L.M.
+_ Amended Exhibit List
+Counter-Plaintiff
+Description of Exhibit
+All applicable criminal statutes.
+2.
+All applicable Florida Statutes.
+Photos and information of Jeffrey Epstein's homes,
+airplanes and automobiles.
+Order confirmation from Amazon.com for purchase of
+books SM 101: A Realistic Introduction," "Slave Craft:
+4.
+Roadmap for Erotic Servitude-Principles, Skills and
+Tools" and "Training Miss Abernathy:
+A Workbook for Erotic Slaves and Their Owners".
+Non-Prosecution Agreement.
+6.
+Jane Doe 102 Complaint.
+8.
+10.
+11.
+12.
+13.
+14.
+15.
+16.
+17.
+Messages taken from message pads found at Epstein's home.
+Documents related to Jeffrey Epstein produced by
+Alfredo Rodriguez.
+Jeffrey Epstein's flight logs.
+Jeffrey Epstein's phone records.
+Sarah Kellen's phone records.
+Jail Visitation Logs.
+Jeffrey Epstein's probation file.
+All probable cause affidavits related to criminal
+investigation of Jeffrey Epstein.
+Victims' statements to the FBI related to criminal
+investigation of Jeffrey Epstein.
+Video of Search Warrant of Jeffrey Epstein's
+home being executed.
+Application for Search Warrant of Jeffrey Epstein's home.
+Objection
+
+
+Counter-Plaintiff's,
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+1 Amended Exhibit List
+Counter-Plaintiff
+18.
+19.
+20.
+21.
+22.
+23.
+24.
+25.
+26.
+27.
+28.
+29.
+30.
+31.
+Description of Exhibit
+Complaint Jane Doe v. Epstein and all subsequent
+Amended Complaints.
+All records of homes, properties, bank accounts and
+any/ all records related to Jeffrey Epstein's assets.
+Jeffrey Epstein's passport (or copy).
+Jeffrey Epstein's driver's license (or copy).
+List of corporations owned by Jeffrey Epstein.
+Yearbooks of Jane Doe.
+2002
+Palm Beach High School Year Book.
+2001
+Palm Beach High School Year Book.
+2003 Palm Beach Gardens High School Year Book.
+Affidavit and Application for Search Warrant on
+Jeffrey Epstein's home.
+Notepads found in Jeffrey Epstein's home and/or
+during trash pulls outside of his home during criminal
+investigation.
+The Palm Beach State Attorney's Criminal file against
+Jeffrey Epstein.
+Co documents related to Jeffrey Epstein's 6/30108
+Jeffrey Epstein's criminal plea colloquy.
+3
+Objection
+
+
+Counter-Plaintiff's,
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+, Amended Exhibit List
+Counter-Plaintiff
+32.
+33.
+34.
+35.
+36.
+37.
+38.
+39.
+Description of Exhibit
+List of properties and vehicles in Larry Visoski's name.
+All of Jeffrey Epstein's Responses to Requests for
+Production, Requests for Admission, Answers to
+Interrogatories in this matter, and cases 08-80119, 08-
+80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-
+80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-
+81092.
+All discovery related responses of Jeffrey Epstein in this
+matter and cases 08-80119, 08-80232, 08-80380, 08-80381,
+08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-
+80656, 09-80802, 09-81092.
+Jeffrey Epstein's Answers and Affirmative
+Defenses in all civil cases against him.
+All Complaints in which Jeffrey Epstein is/was
+a defendant.
+Jeffrey Epstein's Deposition testimony and discovery
+responses in this case and cases 08-80119, 08-80232,
+08-80380, 08-80381, 08-80994, 08-80811, 08-80893,
+09-80469, 09-80591, 09-80656, 09-80802, 09-81092.
+Jeffrey Epstein's Deposition testimony and discovery
+responses in State Court cases LM v. Jeffrey Epstein,
+Case No. 502008CA028051XXXXIMB AB and E.W.
+v. Jeffrey Epstein, Case No.
+502008CP003626XXXXMB.
+Jeffrey Epstein Deposition Testimony and discovery
+responses in State Court case Jeffrey Epstein v. Scott
+Rothstein, et al. Case No 502009CA040800XXXXMBAG.
+4
+Objection
+
+
+Counter-Plaintiff's,
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAC
+Counter-Plaintiff's,
+1 Amended Exhibit List
+Counter-Plaintiff
+Description of Exhibit
+40.
+Any and all newspaper articles, online articles or
+publications related to Jeffrey Epstein.
+41.
+Report and Analysis of Jeffrey Epstein's assets.
+42.
+Video footage (DVD) of walk through site inspection of
+Jeffrey Epstein's home..
+43.
+Photos of all of Jeffrey Epstein's properties, cars, boats and
+planes.
+44.
+Probable Cause Affidavits prepared against Jeffrey
+Epstein and |
+45.
+Documents related to or evidencing Jeffrey Epstein's
+donations to law enforcement.
+46.
+47.
+48.
+49.
+50.
+51.
+52.
+Victim Notification Letter from US Attorney's
+Office to Victim.
+Expert Dr. L. Dennison
+Report of Victim.
+Palm Beach Police Department Incident Report dated
+4/20/06.
+All reports and documentation generated by Palm
+Beach Police Department related to Jeffrey Epstein.
+All Witness Statements generated by Palm Beach
+Police Department relating to Jeffrey Epstein.
+Passenger Manifests of Jeffrey Epstein's aircraft and
+private plane flight logs.
+Passenger lists for flights taken by Jeffrey Epstein.
+5
+Objection
+
+
+Counter-Plaintiff's,
+Amended Exhibit List
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+and L.M.
+, Amended Exhibit List
+Counter-Plaintiff
+53.
+54.
+55.
+56.
+57.
+58.
+59.
+60.
+61.
+62.
+63.
+64.
+65.
+66.
+67.
+Description of Exhibit
+Letter from Jeffrey Epstein to Alberto Pinto
+regarding house island project.
+Jeffrey Epstein's bank statements.
+Jeffrey Epstein's tax returns.
+MC2 emails involving communications of Jeffrey
+Epstein, Jeff Fuller, Maritza Vasquez, Pappas Suat,
+Jean Luc Brunel and Amanda Grant.
+DVD of plea and colloquy taken on 6-30-08-
+Transcript of plea and colloquy taken on 6-30-08.
+Massage Table.
+No Contact Orders entered against Jeffrey Epstein.
+Criminal Score Sheet regarding Jeffrey Epstein.
+Documents evidencing Jeffrey Epstein's
+Community Contrel and Probation.
+Jeffrey Epstein's Sex Offender Registrations (from various
+states).
+Jeffrey Epstein's Booking photograph.
+CAD calls to 358 EL BRILLO WAY, PALM
+BEACH FL 33480.
+List of Jeffrey Epstein's House contacts.
+Documents related to Jeffrey Epstein's investments.
+6
+
+
+Counter-Plaintiff's.
+_ Amended Exhibit List
+Case No. 502009CA040800XXXXMBAG
+and L.M.
+Counter-Plaintiff's,
+, Amended Exhibit List
+Counter-Plaintiff
+68.
+69.
+70.
+71.
+72.
+73.
+74.
+75.
+76.
+77.
+78.
+79.
+80.
+81.
+Description of Exhibit
+Letter from Chief Michael Reiter to Barry Krischler.
+List of planes owned by Jeffrey Epstein.
+Letter from Guy Fronstin to Assistant
+State Attorney dated 1-11-06.
+Letter from Guy Fronstin to Assistant
+State Attorney dated 1-13-06.
+Letter from Guy Fronstin to Assistant
+State Attorney dated 2-17-06.
+Letter from Guy Fronstin to Assistant
+State Attorney dated 4-6-06.
+Letter from Guy Fronstin to Assistant
+State Attorney dated 4-10-06.
+Letter from Goldberger dated 6-22-06.
+All subpoenas issued to State Grand Jury.
+Documents related to the rental of a vehicle for
+Ted's Sheds Documents.
+Documents related to property searches of Jeffrey
+Epstein's properties.
+Arrest Warrant of
+'olice report regarding
+noney dated 11-28-04
+picking up
+Objection
+7
+
+
+Case No.: 502009CA040800XXXXMBA(
+Counter-Plaintiff's
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+Amended Exhibit List
+Counter-Plaintiff
+Description of Exhibit
+82.
+List of Trilateral Commission Members of 2003.
+83.
+84.
+Alan Dershowitz Letter dated 4-19-06 and Statute 90.410.
+Guy Fronstin letter dated 4-17-06.
+85.
+Jeffrey Epstein Account Information.
+86.
+87.
+88.
+89.
+90.
+91.
+92.
+93.
+94.
+95.
+96.
+97.
+98.
+99.
+Jeffrey Epstein Criminal Closeout Sheet.
+JEGE, Inc. Passenger Manifest.
+Hyperion Air Passenger Manifest.
+Flight information for
+Passenger List Palm Beach flights 2005.
+Jeffrey Epstein notepad notes.maria.
+Pleadings of Jane Doe 1 and 2 v. US case.
+Jeffrey Epstein 5t' Amendment Speech.
+Reiter letter to Krisher dated 5-1-06.
+Alexandra
+Police Report dated 11-28-04.
+Victim's school records and transcripts.
+Victim Notification letter dated 7-9-08.
+Police report of Juan Alessi theft at Jeffrey Epstein's home.
+Victim's Medical Records from Dr. Randee Speciale.
+8
+
+
+Counter-Plaintiff's,
+J
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+, Amended Exhibit List
+Counter-Plaintiff
+Description of Exhibit
+100.
+All surveillance conducted by law enforcement on
+Jeffrey Epstein's home.
+101.
+Emails received from Palm Beach Records related to
+Jeffrey Epstein.
+102.
+All items listed on the Palm Beach Police Property Report
+Lists.
+103.
+104.
+All copies of convictions related to Jeffrey Epstein.
+Jeffrey Epstein criminal records.
+105.
+106.
+All documents produced by Palm Beach Police
+Department prior to the deposition of Detective
+Recarey.
+Statements, deposition transcripts, videotaped
+depositions and transcripts taken in connection
+with this and all related cases and exhibits thereto.
+107.
+Any and all expert witness reports and/or records
+generated in preparation for this litigation by any
+party to this cause.
+108.
+Démonstrative aids and exhibits including, but not limited to,
+I cha similar materiad moding blv-s softer listed
+items/exhibits.
+109.
+reserves all objections to Epstein's Exhibits.
+110.
+reserves the right to supplement and/or
+amend his Exhibit List.
+Objection
+9
+
+
+Counter-Plaintiff's,
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+Amended Exhibit List
+Counter-Plaintiff
+Description of Exhibit
+By listing an Exhibit,
+I is not waiving his
+111.
+right to object to same at trial and does not waive
+their right to amend same.
+112.
+All exhibits listed by Epstein subject to
+113.
+114.
+115.
+116.
+117.
+118.
+119.
+120.
+121.
+All pleadings and attachments in the action under the
+Crime Victims Rights Act prosecuted by
+on behalf of victims of Epstein's criminal
+molestations.
+Motions for Summary Judgment, all attachments
+thereto and all Undisputed Facts.
+All time records and hourly billing documentation
+produced in discovery.
+All deposition testimony and discovery responses by
+Epstein submitted in this action.
+All pleadings filed by Epstein in the
+Rothstein bankruptcy proceeding.
+All submissions by Epstein in connection with the
+Rothstein deposition.
+All Settlement Agreements between Epstein and
+victims of his sexual molestations.
+Phone Journal taken from Epstein's home and produced to
+the FBI by Alfredo Rodriguez.
+Photo depicting
+Prince Andrew.
+Ghislaine Maxwell and
+10
+
+
+and L.M...
+Counter-Plaintiff's,
+Amended Exhibit List
+and L.M.
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+Amended Exhibit List
+Counter-Plaintiff
+122.
+123.
+124.
+125.
+126.
+127.
+128.
+129.
+130.
+131.
+132.
+Description of Exhibit
+All flight logs for any Epstein owned or controlled aircraft
+All emails produced by Defendant and/or all emails
+produced by Plaintiff in this case.
+Evidence of contributions to the Palm Beach Police Dept.
+Dr. Bernard J. Jansen Expert Report, Attachments and
+Back-up Documents, October 20, 2017.
+Jeffrey Epstein vs. Scott Rothstein, Bradley J. Edwards and
+L.M., Complaint, December 7, 2009.
+and
+L.M, Fourth Amended Counterelaim, January 9, 2013.
+and
+L.M, Plaintiff/Counter-Defendant Jeffrey Epstein's Answer
+and Affirmative Defenses to Defendant/Counter-Plaintiff
+Fourth Amended Counterclaim,
+February 21, 2013.
+and
+L.M, Notice of Voluntary Dismissal, August 16, 2012.
+Brad Edward's Times Records and Billing Records related
+to this matter.
+Jeffrey Epstein's NY State Online Sex Offender Registry
+Profile.
+New York Post article: Billionaire Jeffrey Epstein: I'm a sex
+offender, not a predator, February 25, 2011
+Objection
+
+
+Counter-Plaintiff's,
+J
+Amended Exhibit List
+Case No. 502009CA040800XXXXMBAG
+Counter-Plaintiff's,
+Counter-Plaintiff
+and L.M.
+1 Amended Exhibit List
+133.
+134.
+135.
+136.
+137.
+138.
+139.
+140.
+141.
+142.
+Description of Exhibit
+Any and all responses to Subpoenas Duces Tecum with or
+without deposition.
+All Interrogatories and Answers thereto, Requests to
+Produce and Responses, Requests for Admissions and
+Responses thereto.
+Any and all documents produced in this action.
+Any and all depositions taken in this action.
+Any documents or other exhibit attached to or used during
+any deposition in this action.
+Any and all exhibits, documents, etc. referred to in any
+deposition.
+Any and all documents and exhibits designated by all parties
+to this action.
+Any and all exhibits needed for impeachment or rebuttal.
+Any and all pleadings filed in this action.
+Any and all récords produced or that will be produced by all
+records custodians relative to this action.
+Objection
+12
+
+
+Counter-Plaintiff's,
+, Amended Exhibit List
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+day of
+November 2017.
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+NOT A CER
+13
+
+
+Counter-Plaintiff's,
+_ Amended Exhibit List
+COUNSEL LIST
+Jack Scarola, Esquire
+_scarolateam@searcylaw.com;
+Searcy Denney Scarola Barnhart & Shipley PA
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+Scott J. Link, Esq.
+Link & Rockenbach, P.A.
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, FL 33401
+Phone: 561-727-3600
+Fax: 561-727-3601
+Attorneys for Jeffrey Epstein
+ERTIFIED COPY
+William Chester
+wcblaw@aol.com; weblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Ep
+Jack A, Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+14
+
+
+Counter-Plaintiff' s,
+Amended Exhibit List
+Esquire
+staff.efile@pathtojustice.com
+Farmer Jaffe Weissing|
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos & Lehrman, P.L.
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+CERTIFIED COPY
+15
+
+
+NOT A CERTIFS?
+
+
+Filing # 64203918 E-Filed 11/15/2017 09:05:49 AM
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+SCOTT ROTHSTEIN. individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT'S OBJECTIONS TO DEFENDANT/
+COUNTER-PLAINTIFF'S AMENDED EXHIBIT LIST
+Plaintiff/Counter-Defendant,
+Defendant/Counter-Plaintiff,
+Jeffrey Epstein, files the following
+Objections to
+J. Edwards' Amended Exhibit List dated November 9, 2017:
+LEGEND FOR OBJECTIONS:
+1 - All Objections
+2 - All Objections except Authenticity
+3 - Relevance
+4 - Probative value substantially outweighed by danger of unfair prejudice, confusion of issues,
+misleading the jury, or needless presentation of cumulative evidence
+5 - Privileged
+6 - Opinion
+7 - Hearsay
+8 - Authenticity
+9 - Other (please identify basis of objection)
+10 - Completeness
+11 - Overbroad
+12 - Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation
+13 - Not a proper exhibit
+14 - Trade secrets/Confidential
+
+
+1.
+
+All applicable criminal statutes
+All applicable Florida Statutes
+Photos and information of Jeffrey Epstein's homes,
+airplanes and automobiles
+Order confirmation from Amazon.com for purchase of
+books "SM 101: A realistic Introduction," "Slave Craft:
+Roadmap for Erotic Servitude-Principles, Skills and Tools"
+and "Training Miss Abernathy: A Workbook for Erotic
+Non-Prosecution Agreement
+Jane Doe 102 Complaint
+Messages taken from message pads found at Epstein's
+8.
+Documents related to Jeffrey Epstein produced by Alfredo
+Rodriguez
+Jeffrey Epstein flight logs
+10.
+Jeffrey Epstein phone records
+11.
+phone records
+12.
+Jail Visitation Logs
+13.
+Jeffrey Epstein's probation file
+14.
+All probable cause affidavits related to criminal
+investigation of Jeffrey Epstein
+Victims' statements to the FBI related to criminal
+investigation of Jeffrey Epstein
+16.
+Video of Search Warrant of Jeffrey Epstein's home being
+executed
+17.
+Application for Search Warrant of Jeffrey Epstein's home
+18.
+Complaint Jane Doe v. Epstein and all subsequent
+Amended Complaints
+19.
+All records of homes, properties, bank accounts and any/
+all records related to Jeffrey Epstein's assets
+20.
+Jeffrey Epstein's passport (or copy)
+21.
+Jeffrey Epstein's driver's license (or copy)
+22.
+List of corporations owned by Jeffrey Epstein
+23.
+Yearbooks of Jane Doe
+Epstein's Objections
+3, 4, 7, 11, 12
+3, 4, 7, 11, 12
+3, 4, 7, 8, 10, 12
+3,4, 7,8
+3, 4, 7, 8, 10
+13,4,7,13
+3,4, 7, 8, 11, 14
+3, 4, 7, 8, 11, 14
+3, 4, 7, 8, 10, 11
+3, 4, 10, 11, 14
+3, 4, 8, 10, 11 14
+3, 4, 7, 8, 11
+3, 4, 7, 8, 11
+3, 4, 7, 8, 10
+3, 4, 7, 8
+3,4,8
+3, 4, 7, 8, Cannot be read
+3, 4, 7, 13, 12 (as to
+"subsequent Amended
+Complaints")
+12
+Cannot be read, 3, 14
+3,4,7, 8,12
+2
+
+
+
+24.
+| 2002
+Palm Beach High School Year Book
+25.
+2001
+Palm Beach High School Year Book
+26.
+| 2003 Palm Beach Gardens High School Year Book
+27.
+Affidavit and Application for Search Warrant on Jeffrey
+Epstein's home
+28.
+| Notepads found in Jeffrey Epstein's home and/or during
+trash pulls outside of his home during criminal
+investigation
+29.
+The Palm Beach State Attorney's Criminal file against
+Jeffrey Epstein
+30.
+All documents related to Jeffrey Epstein's 6/30/08
+conviction
+31.
+Jeffrey Epstein's criminal plea colloquy
+32.
+List of properties and vehicles in Larry Visoski's name
+33.
+All of Jeffrey Epstein's Responses to Requests for
+Production, Requests for Admission, Answers to
+Interrogatories in this matter, and cases 08-80119, 08-
+80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-
+80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-
+81092
+34.
+All discovery related responses of Jeffrey Epstein in this
+matter and cases 08-80119, 08-80232, 08-80380, 08-
+80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-
+80591, 09-80656, 09-80802, 09-81092
+35.
+Jeffrey Epstein's Answers and Affirmative Defenses in all
+civil cases against him
+36.
+All Complaints in which Jeffrey Epstein is/was a plaintiff
+or defendant
+37.
+Jeffrey Epstein's Deposition testimony and discovery
+responses in this case and cases 08-80119, 08-80232, 08-
+80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-
+38.
+80469, 09-80591, 09-80656, 09-80802, 09-81092
+Jeffrey Epstein's Deposition testimony and discovery
+responses in State Court cases LM v. Jeffrey Epstein, Case
+No. 502008CA028051XXXXIMB AB and E.W. v. Jeffrey
+Epstein, Case No. 502008CP003626XXXXMB
+3
+Epstein's Objections
+3,4, 7, 8, 12
+3, 4, 7, 8, 10,
+3, 4, 7, 8, 10,11, 14
+3, 4, 6, 7, 8, 10, 11, 13
+3, 4, 7,8, 12
+3,4, 7, 8,12
+3, 4, 7, 8, 11, 13, The
+exhibit provided was an
+entire Motion (which was
+denied) not just the
+identified item.
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13. This
+also includes a motion
+which is not part of the
+stated exhibit.
+3, 4, 11, 12, 13
+3, 4, 11, 12, 13
+
+
+
+39.
+| Jeffrey Epstein Deposition Testimony and discovery
+Epstein's Objections
+3, 4, 11, 12, 13
+responses in State Court case Jeffrey Epstein v. Scott
+Rothstein, et al. Case No 502009CA040800XXXXMBAG
+40.
+Any and all newspaper articles, online articles or
+3, 4, 7, 8, 11, 12
+publications related to Jeffrey Epstein
+41.
+Report and Analysis of Jeffrey Epstein's assets
+3, 4, 7, 8, 14
+42.
+Video footage (DVD) of walk through site inspection of
+3, 4, 7, 8, 12,
+Jeffrey Epstein's home.
+43.
+Photos of all of Jeffrey Epstein's properties, cars, boats and
+• 3,4,7, 8, 14, 12 (as to
+44. Probable Cause Affidavis prepared against Jeffrey Epstein
+cars and boats)
+3,4, 7, 8, 10
+45.
+Documents related to or evidencing Jeffrey Epstein's
+(3,4, 7, 8, 10
+donations to law enforcement
+46.
+Victim Notification Letter from US Attorney's Office to
+3, 4, 7, 8, 14
+Victim
+47.
+Expert Dr. L. Dennison
+Report of Victim
+3, 4, 6, 7, 8, 14
+48.
+Palm Beach Police Department Incident Report dated
+3, 4, 7, 8,
+4/20/06
+49.
+All reports and documentation generated by Palm Beach
+Police Department related to Jeffrey Epstein
+50.
+All Witness Statements generated by Palm Beach Police
+51.
+Department relating to Jeffrey Ep
+Passenger Manifests of Jeffrey Epstein's aircraft and
+3, 4, 7, 8, 10, 11, 12
+private plane flight logs
+52.
+| Passenger lists for flights taken by Jeffrey Epstein
+3, 4, 7, 8, 10, 11, 12
+53.
+Letter from Jeffrey Ep
+to Alberto Pinto regarding
+3, 4, 7, 8, 10
+house island project
+54.
+Jeffrey Ep
+bank statements
+3, 4, 7, 8, 12, 14
+55.
+Jeffrey Epstein's tax returns
+3,4, 7, 8, 12, 14
+56.
+MC2 emails involving communications of Jeffrey Epstein,
+3,4, 7, 8, 12
+Jeff Fuller, Maritza Vasquez, Pappas Suat, Jean Luc
+Brunel and Amanda Grant
+57.
+| DVD of plea and colloguy taken on 6-30-08
+58.
+Transcript of plea and colloquy taken on 6-30-08
+59.
+Massage Table
+60.
+No Contact Orders entered against Jeffrey Epstein
+3,4, 8, 12, 13
+3,4,13
+3, 4, 12 (document
+marked as No. 59 is not a
+massage table)
+3.4,13
+4
+
+
+
+61.
+Criminal Score Sheet regarding Jeffrey Epstein
+62.
+Documents evidencing Jeffrey Epstein's Community
+Control and Probation
+63.
+Jeffrey Epstein's Sex Offender Registrations (from various
+states)
+64.
+Jeffrey Epstein's Booking photograph
+65.
+CAD calls to 358 EL BRILLO WAY, PALM BEACH FL
+33480
+66.
+List of Jeffrey Epstein's House contacts
+67. Documents related to Jeffrey Epstein's investments
+68.
+Letter from Chief Michael Reiter to Barry Krischler
+69.
+List of planes owned by Jeffrey Epstein
+70.
+Letter from Guy Fronstin to Assistant State Attorney dated
+1-11-06
+71.
+Letter from Guy Fronstin to Assistant State Attorney dated
+1-13-06
+72.
+Letter from Guy Fronstin to Assistant State Attorney dated
+2-17-06
+73.
+Letter from Guy Fronstin to Assistant State Attorney dated
+74.
+4-6-06
+Letter from Guy Fronstin to Assistant State Attorney dated
+4-10-06
+75.
+Letter from Goldberger dated 6-22-06
+76.
+All subpoenas issued to State Grand Jury
+77.
+Documents related to the rental of a vehicle for |
+78.
+Ted's Sheds Documents
+79.
+Documents related to property searches of Jeffrey
+Epstein's properties
+80.
+Arrest Warrant of
+5
+Epstein's Objections
+3,4, 7, 8, 12
+3,4, 7,8
+3,4,7,8
+3, 4, 7, 8, Document says
+cannot rely on this for
+legal action
+3, 4, 7,8
+3,4, 7, 8, 12 (document
+provided is not reflective
+of description)
+3,4, 7, 8, 12, 14
+3, 4, 7, 8
+3, 4, 7, 8, 12 (document
+provided does not match
+description), 14
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3, 4, 7, 8, 10
+3,4,7,8
+3, 4, 7, 8, 13
+3,4, 7, 8, document
+produced contains other
+items not identified on
+3, 4, 7, 8, document
+produced contains other
+items not identified on
+3,4, 7, 8, 14
+3, 4, 7,8
+
+
+81.
+
+Police report regarding
+picking up money
+dated 11-28-04
+82.
+| List of Trilateral Commission Members of 2003
+83.
+Alan Dershowitz Letter dated 4-19-06 and Statute 90.410
+84.
+Guy Fronstin letter dated 4-17-06
+85.
+Jeffrey Epstein Account Information
+86.
+Jeffrey Epstein Criminal Closeout Sheet
+87.
+JEGE, Inc. Passenger Manifest
+88.
+Hyperion Air Passenger Manifest
+89.
+Flight information for
+90.
+Passenger List Palm Beach flights 2005
+91.
+Jeffrey Epstein notepad notes.maria
+92.
+Pleadings of Jane Doe 1 and 2 v. US case
+93.
+Jeffrey Epstein 5h Amendment Speech
+94.
+Reiter letter to Krisher dated 5-1-06
+95.
+Police Report dated 11-28-04
+96.
+Victim's school records and transcripts
+97.
+Victim Notification letter dated 7-9-08
+98.
+Police report of Juan Alessi theft at Jeffrey Epstein's home
+99.
+Victim's Medical Records from Dr. Randee Speciale
+100. All survei
+conducted by law enforcement on Jeffrey
+Epstein's home
+101. Emails received from Palm Beach Records related to
+Jeffrey Epstein
+102. Áll items listed on the Palm Beach Police Property Report
+Lists
+103. All copies of convictions related to Jeffrey Epstein
+104. Jeffrey Epstein criminal records
+105. All documents produced by Palm Beach Police
+Department prior to the deposition of Detective Recarey
+6
+Epstein's Objections
+3,4, 7, 8, 10
+3,4, 7, 8,10
+3,4, 7, 8, 12
+3,4,7,8
+3, 4, 7, 8, 12,14
+3,4, 7, 8, 10, 11
+3,4, 7,8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 11
+3, 4, 7, 8, 10, 12
+3, 4, 12 (document
+provided is not what is
+identified on list), 13
+3,4,12
+3, 4, 7, 8, 10
+3, 4, 7,8
+3,4,7,8
+3, 4, 6, 7,8
+3,4, 7, 8, 12
+3, 4,7, 8, 12
+3, 4, 7, 8, 12 (items not
+provided)
+3, 4, 7, 8, 10, 11,
+
+
+
+06. Statements, deposition transcripts, videotaped deposition
+Epstein's Objections
+3,4,7, 8, 12, 13
+nd transcripts taken in connection with this and all relate
+cases and exhibits thereto
+107. Any and all expert witness reports and/or records generated
+3, 4, 7, 8, 12, 13
+in preparation for this litigation by any party to this cause
+108. Demonstrative aids and exhibits including, but not limited
+12
+to, charts, diagrams and models, surveys, photographs and
+similar material including blow-ups of the listed
+items/exhibits
+109.
+110.
+reserves all objections to Epstein's Exhibits
+reserves the right to supplement and/or amend his
+Not an exhibit y
+Not an exhibit
+
+111. By listing an Exhibit,
+is not waiving his right to
+Not an exhibit
+object to same at trial and does not waive their right to
+amend same.
+112. All exhibits listed by Epstein subject to
+Not an exhibit
+objections.
+113.
+All pleadings and attachments in the action under the
+3, 4, 7, 8, 12, 13
+Crime Victims Rights Act prosecuted by Bradley Edwards
+on behalf of victims of Epstein's criminal molestations.
+Motions for Summary Judgment, all attachments
+thereto, and all Undisputed Facts
+115. All time records and hourly billing documentation
+produced in discovery.
+116. All deposition testimony and discovery responses by
+3, 4, 7, 8, 12, 13
+3, 4, 7, 8, 12, 13
+Epstein submitted in this action.
+117. All pleadings filed by Epstein in the Rothstein bankruptcy
+3, 4, 7, 8, 12, 13
+proceeding.
+118. All submissions by Ep
+in connection with the
+3, 4, 7, 8, 12, 13
+Rothstein deposition.
+119. All Settlement Agreements between Epstein and victims of
+3,4, 7, 8, 12, 14
+his sexual molestations.
+120. Phone Journal taken from Epstein's home and produced to
+3, 4, 7, 8, 11, 14
+the FBI by Alfredo Rodriguez
+(duplicative of Exhibit
+No. 8)
+Ghislaine Maxwell and
+121. Photo depicting
+Prince Andrew
+122. All flight logs for any Epstein owned or controlled aircraft
+123. All emails produced by Defendant and/or all emails
+124, Prodeed by Positin this the Palm Beach Police Dept.
+3,4,7,8
+3,4, 7, 8, 10, 11,12
+3,4, 7, 8, 10, 12
+074, 7, 8, 10 duplicative
+
+
+
+Dr. Bernard J. Jansen Expert Report, Attachments and
+Back-up Documents, October 20, 2017
+126. Jeffrey Epstein vs. Scott Rothstein,
+and
+L.M., Complaint, December 7, 2009
+127. Jeffrey Epstein vs. Scott Rothstein,
+and 3,4,7,13
+L.M., Fourth Amended Counterclaim, January 9, 2013
+128. Jeffrey Epstein vs. Scott Rothstein,
+and
+3,4,7,13
+L.M., Plaintiff/Counter-Defendant Jeffrey Epstein's
+Answer and Affirmative Defenses to Defendant/Counter-
+Plaintiff
+Fourth Amended
+Counterclaim, February 21, 2013
+129. Jeffrey Epstein vs. Scott Rothstein,
+L.M., Notice of Voluntary Dismissal, August 16, 2012
+and
+130. Brad Edward's [sic] Times Records and Billing Records
+related to this matter.
+131. Jeffrey Epstein's NY State Online Sex Offender Registry
+Profile
+132. New York Post article: Billionaire Jeffrey Epstein: I'm a
+sex offender, not a predator, February 25,2011
+133. Any and all responses to Subpoenas Duces Tecum with or
+without deposition
+Epstein's Objections
+3, 4, 6, 7, 8, 10, 11, 13
+134. All Interrogatories and Answers thereto, Requests to
+Produce and Responses, Requests for Admissions and
+Responses thereto.
+135. Any and all documents produced in this action.
+136. Any and all depositions taken in this action.
+137. Any documents or other exhibit attached to or used during
+any deposition in this action
+138. Any and all exhibits, documents, etc. referred to in any
+deposition
+139. Any and all documents and exhibits designated by all
+parties to this action.
+140. Any and all exhibits needed for impeachment or rebuttal
+3, 4, 7, 8, 10,12
+3,4,7,8
+3,4,7,8
+3, 4, 6, 7, 8, 10, 11, 12
+(document produced not
+reflective of the
+description), 13, 14
+3, 4, 7, 8, 12 (document
+produced not reflective
+of the description), 13
+12
+12 (document provided is
+not reflective of
+description), 13
+| 12 (document provided is
+not reflective of
+description), 13
+12 (document provided is
+12 (document provided is
+12 (document provided is
+description)
+8
+
+
+
+141. Any and all pleadings filed in this action
+142. Any and all records produced or that will be produced by
+all records custodians relative to this action
+Epstein's Objections
+no receive provided is
+description), 13
+12 (document provided is
+not reflective of
+description), 13
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on November 15, 2017, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, P.A
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: /s/ Scott J. Link
+Scott J, Link (FBN 602991)
+CER
+Kara Berard Rockenbach (FBN 44903)
+NOT A CER
+Angela M. Many (FBN 26680)
+Primary: Scott@linkrocklaw.com
+Primary: Kara @linkrocklaw.com
+Primary: Angela@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Secondary: Tanya@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+9
+
+
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintif)
+Tonja Haddad Coleman
+315 S.E. Seventh Street, Suite 301
+Ft. Lauderdale, FL 33301
+tonja@tonjahaddad.com
+cfiling@tonjahaddad.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+t. Lauderdale, FL 3330
+narc@nuriklaw.cor
+Counsel for Defendant Scott Rothstein
+Fred Haddad
+Haddad & Navarro, PLLC
+1 Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+dee@haddadandnavarrolaw.com
+Co-Counsel for Plaintiff/Counter-Defendan
+Teffrey Epsteir
+10
+
+
+NOT A CERTIFISS
+
+
+Filing # 64026530 E-Filed 11/09/2017 05:20:40 PM
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendant,
+SEVENTH AMENDED AND SUPPLEMENTAL WITNESS LIST
+OF COUNTER-PLAINTIFF BRADLEY J.
+Counter-Plaintiff,
+J. EDWARDS, by and through his undersigned attorneys,
+hereby supplements his list of witnesses for trial as follows:
+WITNESSES EXPECTED TO BE PRESENTED
+Bradley J. Edwards
+Jeffrey Epstein
+e/o John Stephenson
+1201 W. Peachtree Street
+Atlanta, Georgia 30339
+c/o Erica Dubno
+767 Third Avenue, Suite 3600
+New York, New York 10017
+Guiffre
+c/o Stan Pottinger
+49 Twin Lakes Road, Suite 100
+South Salem NY 10590
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+6.
+7.
+10.
+11.
+12.
+13.
+c/o Peter Guirguis, Esq.
+Mintz. & Gold LLP
+600 Third Avenue, 25" Floor,
+New York 10016
+c/o Peter Guirguis, Esq.
+Mintz & Gold LLP
+600 Third Avenue, 25" Floor,
+New York, 10016
+13701 Riverside Drive, Suite
+800
+Sherman Oaks, CA 91423-2449
+c/o Robert C. Josefsberg, Esq.
+DoeS.E. Or AVenue, Suite 7700
+TIFIED COPY
+Robert C. Josefsberg, Esquire
+One S.E. 3rd Avenue, Suite 2700
+Defective Joseph Recarey
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Chief Michael Reiter
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+John Connolly
+c/ol
+& Schuster
+1230 6th Avenue
+New York, New York 10020
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+14.
+15.
+16.
+17.
+18.
+19.
+20.
+21.
+22.
+23.
+Charles Lichtman, Esquire
+Berger Singerman
+300 East Las Olas Boulevard, Suite 1000
+Fort Lauderdale, FL 33301
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+Antonio Figueroa (Tony)
+Palm Coast, Florida
+Records Custodian of Palm Beach Policé Department
+345 South County Road
+Palm Beach, FL 33480
+Records Custodian of United States Attorney's Office
+for the Southern District of Florida
+Records Custodian of the Federal Bureau of Investigations
+Spencer Kuvin, Esquire
+1800 S. Australian Avenue, #400
+West Palm Beach, Florida 33409
+Theodore Leopold, Esquire
+Milstein
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, Florida 33410
+Rinaldo Rizzo
+c/o Robert
+228 East 45th Street | 17th Floor
+New York, NY 10017
+Adam Horowitz, Esquire
+425 N. Andrews Ave., Suite 2
+Ft. Lauderdale, FL 33301
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+24.
+25.
+26.
+27.
+28.
+Isidro M.
+Esquire
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL, 33401
+Earleen Cote, Esquire
+Kubicki Draper
+One East Broward Boulevard, Suite 1600
+Fort Lauderdale, FL 33301
+Bernard J. Jansen, Ph.D.
+c/o Jack Scarola
+SENTED COPY
+WITNESSES WHICH MAY BE CALLED IF THE NEED ARISES
+29.
+30.
+31.
+Landon Thomas
+c/o New York Times
+620 Eighth Avenue
+New York, NY 10018
+Oren Kramer
+c/o Boston Provident, L.P.
+717 5th Avenue #12A
+New York, NY 10022
+Lawrence LaVecchio
+United States Attorney's Office, Southern District of Florida
+Broward Financial Center
+Fort Lauderdale, Florida
+
+
+LADV. EPSTEIN
+Save oF mended and Supplemental Witness List of Counter-Plaintiff
+32.
+33.
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+Evgenia Ignatieva
+1650 Broadway, #910
+New York, NY 10019
+34.
+35.
+36.
+37.
+38.
+39.
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue,
+Fort Lauderdale FL 33301
+c/o Jack Scarola
+Searcy Denney Scarola Barnhart
+2139 Palm Beach Lakes BIvd.
+West Palm Beach, FL 33409
+RTIFIED COPY
+Shipley
+c/o Robert C, Josefsberg, Esq.
+One S.E. 3'd Avenue, Suite 2700
+Brandy Brenson
+c/o Spencer Kuvin
+1800 South Australian Ave #400
+West Palm Beach, Florida, 33409
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3rd Avenue, Suite 2700
+
+
+Sege to Amended and Supplemental Witness List of Counter-Plainti
+40.
+41.
+42.
+43.
+44.
+45.
+46.
+47.
+c/o Spencer Kuvin
+1800 South Australian Ave #400
+West Palm Beach, Florida, 33409
+William Scherer, Esquire
+633 S Federal Hwy #800
+Fort Lauderdale, FL 33301
+Paul Cassell, Esq.
+383 S. University Street
+SATIED COPY
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3rd Avenue, Suite 2700
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3'd Avenue, Suite 2700
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3'd Avenue, Suite 2700
+
+
+Seventh Amended and Suplemental Wines List of Counter Plaini/
+
+48.
+49.
+50.
+51.
+52.
+53.
+Frederic Fekkai
+Address Currently Unknown
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3rd Avenue, Suite 2700
+Lesley Groff
+c/o Mike
+ARTIFIED COPY
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+54.
+55.
+Prince Andrew Albert Christian Edwards
+Duke of York, Buckingham Palace Road
+London SWIA IAA
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3d Avenue, Suite 2700
+Meagan Dorshel
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3rd Avenue, Suite 2700
+
+
+Segento Amended and Supplemental Witness List of Counter-Plaintif
+56.
+58.
+59.
+60.
+61.
+62.
+63.
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3'd Avenue, Suite 2700
+Tod Meister
+101 Seminole Avenue
+AFTED COPY
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3rd Avenue, Suite 2700
+c/o Spencer Kuvin
+1800 South Australian Ave #400
+West Palm Beach, Florida, 33409
+c/o Marshall Dore Louis
+40 NW third Street, Suite 200
+Miami, FL 33128
+Jason Richards
+Federal Bureau of Investigation
+16320 NW 2nd AVE., Miami, FL 33169
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+
+64.
+c/o
+_Esq.
+Pottinger LLC
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+65.
+66.
+67.
+68.
+69.%
+70.
+c/ol
+Esq.
+Pottinger LLC
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+c/o Adam Horowitz.
+Horowitz Law
+25 North Andrews Avenue, Suite
+:2
+Fort Lauderdale FL 38301,
+TIFIED COPY
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue,
+Suite 2
+Fort Lauderdale FL 33301
+Nezbitt Kurkendall
+Federal Bureau of Investigation
+16320 NW 2nd Ave.
+Miami, FL 33169
+c/o Isidro M.
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL, 33401
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff|
+71.
+72.
+73.
+74.
+75.
+76.
+77.
+78.
+79.%
+80.
+81.
+Igor Zinoview
+Address Currently Unknown
+Address Currently Unknown
+9 East 71 Street
+New York, NY 10021
+Seth Lehrman
+425 North Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+Matt Weissing
+425 North Andrews Ave., Suite '
+Fort Lauderdale, FL 33301
+Maria Villatana
+500 S. Australian Avenue, #400
+West Palm Beach. FL 33401
+CIFIED COPY
+Any additional individuals identified as victims by the United States Attorney's
+Office and whose identities were conveyed to Jeffrey Epstein as part of a list
+supplied as it related to the NPA.
+Leslie Wexner
+Three Limited Parkwa
+"olumbus. Ohio 4320
+President Donald J. Trump
+c/o Alan Garten, Esq.
+725 Fifth Avenue
+New York, NY 10022
+Larry Visoski
+1131 Pine Point Road
+Riviera Beach. FL 33401
+Maritza Vasquez
+1293 SW 21" Terrace
+Miami, FL 33145
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff J.
+
+82.
+83.
+84.
+85.
+86.
+Maximilia
+clo William Unroch, Esquire
+140 West End, Apt. 30-BW
+New York, NY 10023
+c/o Spencer Kuvin
+1800 S. Australian Avenue, #400
+West Palm Beach, Florida 33409
+2915 Share Rd. 111
+Tallahassee, FL 31312
+c/o Robert C. Josefsberg, Esq.
+One S.E. 3'd Avenue, Suite 2700
+'IFIED COPY
+David Copperfield (David Seth
+Kokin)
+11675 Glowing Sunset Lane
+Las Vegas, NV 89135
+87.
+88.
+89.
+90.
+91.
+Michael Fisten
+Weston, FL
+Adler
+Delray Beach, FL
+Alessi
+6791 Fairway Lakes Dr.
+Boynton Beach, FL 33472
+Janusz Banasiak
+358 El Brillo Way
+Palm Beach, FL, 33480
+
+
+Sage 12 mended and Supplemental Wines List of Counter-Plaintif
+92.
+93.
+94.
+95.
+96.
+97.
+98.
+Beata Banasiak
+358 El Brillo Way
+Palm Beach, FL, 33480
+Juan Alessi
+6791 Fairway Lakes Dr.
+Boynton Beach, FL 33472
+Michael
+53320 Avenida Madero
+La Quinta, CA 92253
+Jerry Goldsmith
+13285 Silver Fox Lane
+West Palm Beach, FL 33418-7942
+Rosalie
+53320 Avenida Madero
+La Quinta, CA 92253
+Valdson Cotrin
+Let Came ER TIFIED COPY
+99.
+Unknown, South Africa
+100.
+Glenn Dubin
+1040 5th Ave. Unit 15A
+New York, NY 10028-0137
+101.
+Abigail Wexner
+Three Limited Parkway
+Columbus. Ohio 43206
+102.
+Officer Munyan
+Palm Beach Police Department
+345 South County Road
+
+
+[ADV. EPSTEIN
+Sage th omended and Supplemental Winess List of Counter-Plini
+Palm Beach, FL 33480
+103. Officer Minot
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+104. Sgt. Sorge
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+105.
+Address Currently Unknown
+106.
+Joseph Pagnano
+107. Stephan Kosslyn
+108. Cecile Dejongh
+St. Thomas VI 00802
+109. Tommy Mottola
+302 Caribbean Road
+Palm Beach, FL 33480-3012
+110.Mike Sanka
+449 S Beverly Drive, Suite 10
+Beverly Hills, CA 90212
+111.
+112.
+William "Bill"
+5645 Coral Ridge Drive # 391
+Coral Springs, FL 33076
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+113.
+Howard Rubenstein
+1345 Avenue of the Americas
+New York, NY 10105
+114.
+Robert Meister
+101 Seminole Ave.
+Palm Beach, FL 33480
+115. Todd Meister
+101 Seminole Ave
+Palm Beach, FL 33480
+116. President William J. Clinton
+117. William Hammond
+2965 Fontana Place
+Palm Beach, FL
+118.
+5600 North Flagler Dr, #250
+119. Michele Pagan
+ARIFIED COPY
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+120. Michele Dawson
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+Amy Fortimer
+12309 North Old Country Road
+Wellington, FL 33414
+122.
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+123.
+124.
+125.
+126. Latasha Lowe
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+127.
+128.
+Zack Bryan
+1150 Larch Way
+Wellington, Florida
+ERTIFIED COPY
+129.
+130-
+Larry Morrison
+11148 Cobblefield Dr..
+Wellington, FL 33449
+131.
+Story Cowles
+801 S Olive Ave., Unit 201S
+West Palm Beach, FL 33401
+132. Michael Dawson
+Palm Beach Police Department
+345 South County Road
+Palm Beach, FL 33480
+
+
+Sage l6 mended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards
+133.
+Salaam Kahlid Monroe
+119 Menores Ave., Apt. 3
+Coral Gables, FL 33134
+134.
+Jelitza Negrette
+503 Chandlers Warf
+Portland, ME 04101
+135.
+Sergia Cordero
+825 Brickell Bay Drive, #1141
+136.
+Cassandra Rivera
+5011 El Claro Circle
+137.
+138.
+Address Currently Unknown
+139.
+Steven Hoffenberg
+Address Currently Unknown
+140.
+Michael Stroll
+Address Currently Unknown
+141.
+Douglas Shoettle
+243 Riverside, Dr.
+New York, NY 10025
+142.
+Ghislaine Maxwell
+Address Currently Unknown
+143.
+Amazon Records Custodian
+144.
+Yellow Cab Records Custodian
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards
+145. Citrix Systems, Inc. Records Custodian
+146. Federal Bureau of Investigation Records Custodian
+147. Milton Girls Juvenile Facility Records Custodian
+5770 East Milton Road
+3344 Forest Hill Blvd., Suite C-124
+West Palm Beach, FL 33406
+149. St. Mary's Medical Center Records Custodian
+901 45' Street
+West Palm Beach, FL 33401
+150.
+Wellington Reginal Hospital Records Custodian
+10104 Forrest Hill Blvd.
+Wellington, FL 33414
+151. Alinitnesses that Defendants have listed on their Witness List not objected to by
+152. All rebuttal witnesses.
+153.
+All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail.
+WITNESS TESTIMONY EXPECTED TO BE PRESENTED
+BY MEANS OF DEPOSITION
+154,
+Mark Epstein
+30 Vandam Street
+New York, NY 10013
+c/o Alan S. Ross, Esq.
+155.
+156.
+157. Alfredo Rodriguez
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+c/o Federal Public Defender or Bureau of Prisons
+11349 SW 86TH Lane
+Miami, FL
+158.
+Scott Rothstein
+c/o Mark Nurik
+One East Broward Boulevard, Suite 700
+Fort Lauderdale, Florida 33301
+159. Jeffrey Epstein
+160
+c/o Adam Horowitz.
+Horowitz Law
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale FL 33301
+IED COPY
+EXPERT WITNESSES
+161. Bernard J. Jansen, Ph.D.
+c/o Jack Scarola
+Searcy Denney Scarola Barnhart & Shipley
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+The following witnesses are attorneys that are not retained or specially employed to
+rovide expert testimony, but may provide opinions relating to the propriety of Brad Edward
+onduct of diseovery in the prosecution of the Epstein claim:
+162.
+Robert C. Josefsberg, Esquire
+One S.E. 3º Avenue, Suite 2700
+163.
+Charles Lichtman, Esquire
+Berger Singerman
+300 East Las Olas Boulevard, Suite 1000
+Ft. Lauderdale, FL 33301
+
+
+Seventh Amended and Supplemental Witness List of Counter-Plaintiff
+164.
+Spencer Kuvin, Esquire
+1800 S. Australian Avenue, #400
+West Palm Beach, Florida 33409
+165.
+Theodore Leopold, Esquire
+Cohen Milstein
+2925 PGA Boulevard, Suite 200
+Palm Beach Gardens, Florida 33410
+166.
+Adam Horowitz, Esquire
+425 N. Andrews Ave., Suite 2
+Ft. Lauderdale, FL 33301
+167.
+Isidro M. Garcia, Esquire
+Law Firm, P.A.
+224 Datura Street, Suite 900
+West Palm Beach, FL, 33401
+TIFIED COPY
+168.
+Earleen Cote, Esquire
+Kubicki Draper
+One East Broward Boulevard, Suite
+1600
+For Lesterdale, FL 23011
+169.
+William Berger, Esquire
+Weiss, Handler, Cornwell, P.A.
+2255 Glades Road, Suite 218A
+Boca Raton, FL 33431
+Plaintil reserves the right to amend this list.
+NO
+
+
+_ADV. EPSTEIN
+Sege 0 omended and Supplemental Witness List of Counter-Plaintif
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+day of
+November 2017.
+JACK SCAROLA
+Florida Bar No.: 169440
+Attorney E-Mail(s): jsx@searcylaw.com anc
+nep@seafcylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searéy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+NOT A C
+Fax: (561) 383-9451
+Attorneys for
+
+
+Seventh Amended and Supplemental Witness List of Counterplaintiff
+
+COUNSEL LIST
+Jack Scarola, Esquire
+scarolateam@searcylaw.com;
+Searcy Denney Scarola Barnhart & Shipley PA
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+Scott J. Link, Esq.
+Link & Rockenbach, P.A.
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+Phone: 561-727-3600
+ARTIFIED
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australián Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+
+
+Seventh Amended and Supplemental Witness List of Counterplaintiff
+
+Esquire
+statf.efile@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos & Lehrman, P.L.
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+CERTIFIED COPY
+
+
+NOT A CERTIFUS
+
+
+IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+VS.
+SCOTT ROTHSTEIN, individually.
+I, individually,
+and I.M., individually,
+Plaintiff (s),
+Defendant (s) .
+VIDEOTAPED DEPOSITION OF JEFFREY_EPSTEIN
+January 25, 2012
+- 9:34 a.m.
+- 10:03 a.m.
+SEARCY,
+DENNEY, SCAROLA, BARNHART & SHIPLEY, PA
+2139 Palm Beach Lakes Boulevard
+West Palm Beach Florida 33409
+NOT.
+Stenographically Reported By:
+Tammy Nestor, RPR
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+19
+MR. KNIGHT: Okay.
+MR. SCAROLA: -- that's intended to coach
+the witness, Mr. Knight.
+MR. KNIGHT: I'm going to object.
+MR. SCAROLA: So if you say you are
+objecting on the basis that it calls for a
+legal conclusion, that's fine. And now I would
+like the witness's answer unless you are
+instructing him not to answer.
+MR. KNIGHT: I'm not instructing him not
+to answer.
+BY MR. SCAROLA:
+Okay. Then would you please answer the
+question?
+I'm sorry. Would you repeat it?
+Yes, sir. Is it your contention that
+Bradley
+abusively prosecuted the federal
+court action on behalf of IM?
+> A
+(Yes, sir,
+How?
+A
+a 234-count federal
+Complaint in conjunction with his partner Scott
+Rothstein to enable his partners at RRA to defraud
+south Florida investors of millions of dollars.
+His partner Scott Rothstein and his partner
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+20
+Mr. Adler have -- excuse me, Mr. Rothstein_has now_in
+deposition admitted that they needed to file a complaint to
+show investors that there was real action, (in
+Mr. Rothstein's words, going on_in _federal court.
+The
+investors had not been_able to find a filed complaint and
+had complained to Mr. Rothstein that there was no filed
+complaints_two_ days, excuse me, before Mr.
+filed
+the_federal_complaint_for_234.
+Were_you ever_served with that complaint?
+Not to the best of my recollection.
+Q) So one contention is that Mr.
+abusively prosecuted a federal court action on
+behalf_of_IM with which you were never served,
+correct?
+A
+Ihad I was notified that the case was.
+in fact, filed.
+• But_you were_never_served with the case,
+correct?
+[was notified that the case was filed.
+But you were never served with the case,
+correct?
+Not_to the_best of my recollection.
+@ Okay. What damage did you incur as a
+consequence of the filing of a complaint with which
+you were never_served?
+
+
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+21
+A
+• incurred many legal -- much legal fees,
+many legal fees, (in fact) to try to figure out
+why -- what was going on and, (in fact, (getting
+(prepared to defend the case though I had not yet
+been served
+(e Were the allegations in the federal
+Complaint on behalf of IM any different than the
+allegations in the state court case on behalf of LM?
+• I don't recall
+e Did you, in fact, engage in any sexual
+conduct with IM?
+A I'm sorry, but I'm sure - the jury is
+going to recognize this is simply meant to harass
+me, and I'll have to take the Fifth Amendment since
+your client, Mr.
+I, is trying to overturn my
+prosecution agreement.
+How many times did you engage in sexual
+conduct with IM?
+A
+I'm going to have to invoke my Fifth
+Amendment right again, sir.
+Do you know who IM is?
+A
+Again I'm going to assert my right.
+MR. KNIGHT: We are going to go off the
+record and take another break.
+THE VIDEOGRAPHER: The time is 9:58.
+We
\ No newline at end of file
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diff --git a/vision-fixhub/court-02/07c7242e802b7a0e522d9c5b6e321f7b22d99ddca3b77cf90e446d341bdecddd.md b/vision-fixhub/court-02/07c7242e802b7a0e522d9c5b6e321f7b22d99ddca3b77cf90e446d341bdecddd.md
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@@ -0,0 +1,75 @@
+Case 9:08-cv-80736-KAM Document 403-6 Entered on FLSD Docket 06/02/2017 Page 1 of 3
+GOVERNMENT
+
+F
+
+
+Case 9:08-cv-80736-KAM Document 403-6 Entered on FLSD Docket 06/02/2017 Page 2 of 3
+U.S. Department of Justice
+United States Attorney
+Southern District of Florida
+500 South Australian Ave., Suite 400
+West Palm Beach, FL 33401
+(561) 820-8711
+Facsimile: (561) 820-8777
+August I1, 2006
+DELIVERY BY HAND
+Miss
+Re:
+Crime Victims" and Witnesses' Rights
+Dear Miss
+Pursuant to the Justice for All Act of 2004, as a victim and/or witness of a federal offense,
+you have a number of rights. Those rights are:
+(1) The right to be reasonably protected from the accused.
+(2)
+The right to reasonable, accurate, and timely notice of any public court proceeding
+involving the crime or of any release or escape of the accused.
+(3)
+The right not to be excluded from any public court proceeding, unless the court
+determines that your testimony may be materially altered if you are present for other
+portions of a proceeding.
+(4)
+The right to be reasonably heard at any public proceeding in the district court
+involving release, plea, or sentencing.
+The reasonable right to confer with the attorney for the United States in the case.
+The right to full and timely restitution as provided in law.
+The right to proceedings free from unreasonable delay.
+(8)
+The right to be treated with fairness and with respect for the victim's dignity and
+privacy.
+Members of the U.S. Department of Justice and other federal investigative agencies,
+including the Federal Bureau of Investigation, must use their best efforts to make sure that these
+rights are protected. If you have any concerns in this regard, please feel free to contact me at 56l
+209-1047, or Special Agent Nesbitt Kuyrkendall from the Federal Bureau of Investigation at 561
+822-5946. You also can contact the Justice Department's Office for Victims of Crime in
+Washington, D.C. at 202-307-5983. That Office has a website at www.ovc.gov.
+You can seek the advice of an attomey with respect to the rights listed above and, if you
+believe that the rights set forth above are being violated, you have the right to petition the Court for
+relief.
+
+
+Case 9:08-cv-80736-KAM Document 403-6 Entered on FLSD Docket 06/02/2017 Page 3 of 3
+MISS
+AUGUST 11, 2006
+PAGE 2
+In addition to these rights, you are entitled to counseling and medical services, and protection
+from intimidation and harassment. If the Court determines that you are a victim, you also may be
+entitled to restitution from the perpetrator. A list of counseling and medical service providers can
+be provided to you, if you so desire. If you or your family is subjected to any intimidation or
+harassment, please contact Special Agent Kuyrkendall or myself immediately. It is possible that
+someone working on behalf of the targets of the investigation may contact you. Such contact does
+not violate the law. However, if you are contacted, you have the choice of speaking to that person
+. or refusing to do so. If you refuse and feel that you are being threatened or harassed, then please
+contact Special Agent Kuyrkendall or myself.
+You also are entitled to notification of upcoming case events. At thistime, your case is under
+investigation. If anyone is charged in connection with the investigation, you will be notified.
+Sincerely,
+By:
+R. Alexander Acosta
+United States Attorney
+Bail illafon
+* Villafaña
+Assistant United States Attorney
+cc:
+Special Agent Nesbitt Kuyrkendall, F.B.I.
+!!
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+  "idempotent": true,
+  "input_sha256": "3b4f13475d71912633a4c4bed69849d37080e72f9c8c0d67898d2aa52c95ad84",
+  "output_sha256": "9612e40fa188c21c09fa7cb59517bddaf620c5fab4e46ff51ff4330017b95d97",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.md b/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.md
new file mode 100644
index 0000000000000000000000000000000000000000..68a6604ff3ca8ffa552520bf9f6ec42623066f24
--- /dev/null
+++ b/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.md
@@ -0,0 +1,145 @@
+Filing # 56876776 E-Filed 05/24/2017 02:50:08 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+1
+SCOTT ROTHSTEIN, individually,
+J.
+, individually, and
+L.M., individually,
+Defendants).
+MOTION TO SET CASE FOR TRIAL
+, by and through his undersigned counsel, moves this Honorable Court
+to set the above-styled cause for trial by jury. This long delayed matter is now ripe for resolution
+and is expected to take approximately 10 days to try.
+See the attached response by Jeffrey Epstein reflecting that appellate issues with respect to
+this matter have been resolved.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 24T
+Florida Bar No.: 169440
+Aroscare Mai.s. jis@searcylaw.com and
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+J.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 05/24/2017 02:50:08 PM
+
+
+[ADV. EPSTEIN
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+William Chester
+1, Esquire
+wcblaw@aol.com; wcblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+Esquire
+staff.efile@pathtojustice.com
+Jaffe Weissing
+Lehrman, P.L.
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos &
+Fred
+Haddad, Esquire
+Dee@FredHaddadLaw.com;
+Fred@FredHaddadLaw.com
+Fred Haddad, P.A
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja @tonjahaddad.com;
+efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+2
+
+
+Filing # 56646683 E-Filed 05/18/2017 04:49:34 PM
+IN THE SUPREME COURT OF FLORIDA
+CASE NO. SC15-2286
+JEFFREY EPSTEIN,
+Petitioner,
+v.
+et al.,
+COPY
+Respondents.
+PETITIONER'S RESPONSE TO ORDER TO SHOW CAUSE
+The petitioner responds as follows to this Court's order dated May 3, 2017:
+1. On May 3, 2017, this Court issued an order directing the petitioner to show
+cause on or before May 18, 2017 why this Court's decision in Debrincat v. Fischer,
+42 Fla. L. Weekly S141 (Fla. Feb. 9, 2017), is not controlling in this case and why the
+Court should not decline to exercise jurisdiction in this case.
+2. In response to the show cause order, the petitioner would show no cause why
+Debrincat is not controlling as to the basis for this Court's jurisdiction, and no cause
+why this Court should not decline to exercise jurisdiction.
+Respectfully submitted,
+LAW OFFICES OF PAUL MORRIS, P.A.
+9350 S. Dixie Highway
+Suite 1450
+Miami, FL 33156
+
+
+Florida Bar No. 193769
+Tel. (305) 670-1441
+Fax (305) 670-2202
+paulappeal@gmail.com
+paul@paulmorrislaw.com
+s/ Paul Morris
+PAUL MORRIS
+Counsel for Petitioner
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that this response
+was emailed to counsel on the list
+БОРУ
+below this 18th day of May, 2017.
+s/ Paul Morris
+PAUL MORRIS
+SERVICE LIST:
+Philip M. Burlington
+Burlington & Rockenbach, P.A.
+ERTIFIED
+Courthouse Commons/Suite 350
+444 West Railroad Ave.
+West Palm Beach, FL 33401
+NO
+NOT
+2
diff --git a/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.receipt.json b/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..cc40257b226d503943f3724355b9954445ee2221
--- /dev/null
+++ b/vision-fixhub/court-02/07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "07e6695fa2de7bc4e55291fce735b9885b1e4782cc3a41a659bb02310ac77f71",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "c27d4b9ebd38df0b79ea32d167576d13592befc1610cf19a2d29c7017035dfb4",
+  "output_sha256": "e392e9ee8b966faa4f9a337ad5b43ebb82c8741923c12aa02f35dc55fb65706b",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.md b/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.md
new file mode 100644
index 0000000000000000000000000000000000000000..c96fa80cf99bc884907eeed7023eb6b970f150f9
--- /dev/null
+++ b/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.md
@@ -0,0 +1,150 @@
+Filing # 69669112 E-Filed 03/22/2018 01:53:34 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+Plaintiffs),
+VS.
+JEFFREY EPSTEIN,
+Defendants).
+COPY
+RE-NOTICE OF HEARING
+YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the
+following:
+DATE:
+TIME:
+JUDGE:
+March 26, 2018
+8:45 a.m.
+Honorable Donald Hate
+PLACE:
+205 N. Dixie Highway, West Palm Beach, FL 33401
+ROOM #:
+10-Dr
+SPECIFIC MATTERS TO BE HEARD: Motion for Status Conference
+Movant's attorney has spoken in person or by telephone with the
+attorney(s) for all parties who may be affected by the relief sought in the
+motion in a good faith effort to resolve or narrow the issues raised.
+Movant's attorney has attempted to speak in person or by telephone with
+the attorney(s) for all parties who may be affected by the relief sought in
+the motion.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/22/2018 01:53:34 PM
+
+
+Ladv. Epstein
+One or more of the parties who may be affected by the motion are self
+represented.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 22ND
+day of _
+Mach, 2018.
+JACK SCAROLA
+Flórida Bar No.: 169440
+Attorney E-Mail: jsx@searcylaw.com; and
+/mimccann@searcylaw.com
+Primary E-Mail:
+_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+561-383-9451
+Attorneys for
+NOT A
+NOT A CER
+2
+
+
+COUNSEL LIST
+J.
+Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Philip Burlington, Esquire
+pmb@flappellatelaw.com;kbt@Flappellatelaw
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J.
+Jay Howell, Esquire
+jay@jayhowell.com
+Jay Howell & Associates P.A.
+644 Cesery Boulevard, Suite 250
+Jacksonville, FL 32211
+Phone: (904)-680-1234
+Fax: (904)-680-1238
+Attorneys for Bradley J.1
+Paul G. Cassell, Esquire
+paul.cassell@law.utah.edu
+S.J. Quinney College of Law
+383 S University Street
+Salt Lake City, UT 84112
+Phone: (801)-585-5202
+Fax: (801)-581-6897
+Attorneys for |
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+ERTIFIED COPY
+3
+
+
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Kara Berard Rockenbach, Esquire
+kara@linkrocklaw.com
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com;
+Angela@linkrocklaw.com;
+Troy@linkrocklaw.com; tina@linkrocklaw.com;
+rachel@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+CERTIFIED
+NOT
+4
+
+
+"If you are a person with a disability who needs any accommodation in order to
+participate in this proceeding, you are entitled, at no cost to you, to the provision of
+certain assistance. Please contact Americans with Disabilities Act Coordinator at least
+7 days before your scheduled court appearance, or immediately upon receiving this
+notification if the time before the scheduled appearance is less than 7 days; if you are
+hearing or voice impaired, call 711."
+"Si usted es una persona minusválida que necesita algún acomodamiento para poder
+parte parea ese traedimiento, engad tienderical sie pergetos propios, a gue
+se le provea cierta ayuda.
+Americans with Disabilities Act Coordinator por lo menos 7 días antes de la cita fijada
+para su comparecencia en los tribunales, o inmediatamente después de recibir esta
+notificación si el tiempo antes de la comparecencia que se ha programado es menos
+de 7 días; si usted tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan pwosedi
+sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kèk èd.
+Tanpri kontakte nan 7 jou anvan dat ou gen randevou pou parèt nan tribinal la,
+oubyen imedyatman apre ou fin resevwa konvokasyon an si lè ou gen pou w parèt nan
+tribinal la mwens ke 7 jou; si ou gen pwoblèm pou w tande oubyen pale, rele 711."
+Rev: 8/20/15
+NOTA
+5
\ No newline at end of file
diff --git a/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.receipt.json b/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..a7262dc7844296cd625279dcf1d4c5bea9336a5d
--- /dev/null
+++ b/vision-fixhub/court-02/07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -304,
+  "dataset": "marble-joined",
+  "doc_id": "07e67efc37f2c5dd95d2cdd2b6bcb49f3d0e2468eef424d994c47a8d979e19bd",
+  "engine": "marble-apple-vision",
+  "event_count": 6,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "e5afc7a1f06f794f22bd58785fbc4a703d0ec1cfddd9003af3f55de17a7a179c",
+  "output_sha256": "28ec86f35f0da4c91eaa09a34c8e9913b54cc51d6aa9641de1789105e88a0791",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.md b/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.md
new file mode 100644
index 0000000000000000000000000000000000000000..30e36dcda495c4d382495686f14769c5b8d3b5a0
--- /dev/null
+++ b/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.md
@@ -0,0 +1,125 @@
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants).
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+2013 JAN 22 PM 3: 45
+FILED:
+NOTICE OF HEARING
+YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the
+following:
+DATE:
+Monday, January 28, 2013.
+TIME:
+8:45 a.m.
+JUDGE:
+Honorable David F.
+(Palm Beach County Courthouse)
+PLACE:
+205 N. Dixie Highway, West Palm Beach, FL 33401
+ROOM #:
+9-C
+SPECIFIC MATTERS TO BE HEARD:
+Plaintiff's Motion for Protective Order
+
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list this 18 day of Vanuauy. 2013.
+JACK SCAROLA
+Florida Bar No.: 169440
+Pylmary E-mail: jsx@searcylaw.com
+Secondary E-mails): mep@searcylaw.con
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+NOT A CERS
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+or 3839451
+
+
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Esquire
+bje.efile@pathtojustice.com;
+staff.efile@pathtojustice.com
+Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+haddadfm@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Attorneys for Scott Rothstein
+Lilly Ann Sanchez, Esquire
+Isanchez@thelsfirm.com
+The L-S Law Firm
+1441 Brickell Avenue, 15th Floor
+Miami, FL 33131
+Phone: (305)-503-5503
+Fax: (305)-503-6801
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+3
+
+
+"If you are a person with a disability who needs any accommodation in
+order to participate in this proceeding, you are entitled, at no cost to
+you, to the provision of certain assistance. Please contact Krista Garber,
+Americans with Disabilities Act Coordinator, at least 7 days before your
+scheduled court appearance, or immediately upon receiving this
+notification if the time before the scheduled appearance is less than 7
+days; if you are hearing or voice impaired, call 711."
+"Si usted es una persona
+minusválida que necesita algún
+acomodamiento para poder participar en este procedimiento, usted
+tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda.
+Tenga la amabilidad de ponerse en contacto con Krista Garber
+Americans with Disabilities Act Coordinator,, por ló menos 7 días antes
+de la cita fijada para su comparecencia en los tribunales, o
+inmediatamente después de recibir esta notificación si el tiempo antes de
+la comparecencia que se ha programado es menos de 7 días; si usted
+tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe
+nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen
+pwovizyon pou jwen kèk èd. Tanpri kontakte nan 7 jou anvan dat ou
+gen randevou pou parèt nan tribinal la, oubyen imedyatman apre ou fin
+resevwa konvokasyon an si lè ou gen pou w parèt nan tribinal la mwens
+ke 7 jou; si ou gen pwoblèm pou w tande oubyen pale, rele 711."
+NOT
\ No newline at end of file
diff --git a/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.receipt.json b/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..56674f67cee38c3ba10150273e47fac2d3986e85
--- /dev/null
+++ b/vision-fixhub/court-02/07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -202,
+  "dataset": "marble-joined",
+  "doc_id": "07f34da4f7c236019d946eb85f1d73acc5b4a17d5f6fe20be0a6215962362f8d",
+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "0a85f78d726d05b2d079703fb0b0e7fb5519104bc62f44c98502c07e6c056af4",
+  "output_sha256": "7801400e67a7a1536e4d4a3b6458bbce11b6f673dc2f911a5fdbb6cecd3a4a65",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0834976c68442b38ec48abc0626d15fe271ba80de28530916b5a934fb0f02d0b.md b/vision-fixhub/court-02/0834976c68442b38ec48abc0626d15fe271ba80de28530916b5a934fb0f02d0b.md
new file mode 100644
index 0000000000000000000000000000000000000000..4cdc6c8810caa8b14f25c195b67d5d3e3d7ef5c9
--- /dev/null
+++ b/vision-fixhub/court-02/0834976c68442b38ec48abc0626d15fe271ba80de28530916b5a934fb0f02d0b.md
@@ -0,0 +1,101 @@
+*** FILED: PALM BEACH COUNTY. FL SHARON R BOCK, CLERK. ***
+Filing # 9206359 Electronically Filed 01/15/2014 04:25:02 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants).
+COPY
+NOTICE OF SERVING INTERROGATORY TO JEFFREY EPSTEIN
+J.
+hereby gives notice pursuant to Rule 1340(e), Florida Rule of Civil
+Procedure, that an Interrogatory has been directed to Jeffrey Epstein, this
+JANUAM, 2014.
+It is requested that the aforesaid answers be served within thirty (30) days at the offices of
+Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West
+Palm Beach, Florida, 33409.
+I HEREBY CERTIFY that a true a correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+of JANUARY, 2014.
+JACK SCAROLA
+Florida Bar No.: 169440
+Attorney E-Mail: Jsx@searcylaw.com and
+mep @searcylaw.com
+Primary E-Mail: eservice@searcylaw.com
+Secondary E-Mails): _scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+J.
+
+
+Notice of Serving Interrogatory to Jeffrey Epstein
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+William Chester
+Esquire
+wcblaw@aol.com; wcbog@aol.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Esquire
+staff.efile@pathtojustice.com
+, Jatle, Weissing,
+425 North Andrews Avenue, Suité 2
+pistos & ehrman, FL
+RTIFIED COPY
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com; haddadfim@aol.com; fred@fredhaddadlaw.com
+Fred Haddad, P.A
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+2
+
+
+Notice of Serving Interrogatory to Jeffrey Epstein
+Case No.: 502009CA040800XXXXMBAG
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; Debbie@Tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+NOT A CERTIFIED COP
+3
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diff --git a/vision-fixhub/court-02/08711ac080a89747de09ed2460d3ec14d9265d0b01f839e34cec89f2d08697ca.md b/vision-fixhub/court-02/08711ac080a89747de09ed2460d3ec14d9265d0b01f839e34cec89f2d08697ca.md
new file mode 100644
index 0000000000000000000000000000000000000000..477588a56054103287064ec03c9035e968f7593b
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@@ -0,0 +1,119 @@
+Case 9:08-cv-80736-KAM Document 361-7 Entered on FLSD Docket 02/10/2016 Page 1 of 4
+
+7
+
+
+Case 9:08-cv-80736-KAM Document 361-7
+Entered on FLSD Docket 02/10/2016 Page 2 of 4
+"Ann
+Villafana"
+To "Jay Lefkowitz" <JLefkowitz@kirkland.cor
+09/16/2007 03:54 PM
+his messag
+and 0
+CC
+bec
+Subject Re:
+ion feplied
+Hi Jay - This can wait until after the show, but my voice is going
+so I thought I would type it up. I talked to Andy and be still doesn't
+like the factual basis. In his opinion, the plea should only address
+the crimes that we were addressing, and we were not investigating
+Mr. Epstein abusing his girlfriend.
+So, these are the only options that he recommended:
+1. We go back to the original agreement where Mr. Epstein pleads
+only to state charges and serves his time in the state, except that we
+can agree to only 18 months imprisonment.
+2. Mr. Epstein pleads guilty to the state charges and also pleads to
+either two obstruction counts or to one count of violating 47 USC
+223(a)(I)(B), with a joint non-binding recommendation of 18
+months, so that Mr. Epstein can serve his time federally.
+3. (My suggestion only, not Andy's): - go back to the U.S.
+federal facility.
+Or 4. Mr. Epstein pleads to one obstruction count, and serves part
+of his time federally and part state.
+On your other proposed changes, some are fine and some are
+problematic.
+Re your paragraph 2: As to timing, it is my understanding that Mr.
+some of the timing issues be addressed only in the state agreement,
+so that it isn't obvious to the judge that we are trying to create
+federal jurisdiction for prison purposes. My understanding is that
+Mr. Epstein should sign a state plea agreement, plead guilty to the
+US_Atty_Cor_0030
+
+
+Case 9:08-cv-80736-KAM Document 361-7 Entered on FLSD Docket 02/10/2016 Page 3 of 4
+federal offenses, plead guilty to the state offenses, be sentenced on
+the federal offenses, and then be sentenced on the state offenses,
+and then start serving the federal sentence.
+Re your paragraph 3: As to the reservation of Mr. Epstein's right to
+withdraw his state plea or to appeal his state plea or sentence, that
+is fine, but we need the caveat that, if he were to do so, the United
+States could proceed on our charges.
+Re your paragraph 6: With respect to the waiver of the right to
+appeal the federal sentence, given the way we have drafted the
+information, it is possible that getting to the 18 month sentence
+will require an upward departure. The version of the agreement
+that you were working from is a federal non-prosecution
+agreement, the ones I have sent you recently are plea agreements
+that get filed with the court. Please see if the appeal waiver
+language in those versions is alright.
+Re your paragraph 7: As I mentioned, we will not waive the
+presentence investigation. I know that this will delay Mr. Epstein's
+sentencing by 70 days, but that will allow him to get all of his
+affairs in order. As to bail, it will be set at the time of arraignment,
+and we can work out a joint recommendation regarding the amount
+and its limitations.
+I have no objection to making a joint
+recommendation that Mr. Epstein remain out on bond pending his
+sentencing, but I'm not sure that it belongs in a plea agreement,
+especially since I can't bind the court on that issue. However, I can
+assure you, and we can put it on the record during the plea
+collooquy, that I will join in your recommendation that he remain
+out on bond pending sentencing. The same goes for the prison
+camp issue. As 1 mentioned, I have opposed a designation only
+once in a very particular case, I can assure you, and we can put it
+in the record at the plea colloquy that I will not oppose you
+ecommendation for Mr. Epstein's designation
+Re your paragraph 8: As I mentioned over the telephone, I cannot
+bind the girls to the Trust Agreement, and I don't think it is
+US_Atty_Cor_0031
+
+
+Case 9:08-cv-80736-KAM Document 361-7 Entered on FLSD Docket 02/10/2016 Page 4 of 4
+and I will facilitate as much as I can getting the girls' approval of
+this procedure because, as I mentioned, I think it is probably in
+their best interests. In terms of plea agreement language, let me
+suggest the following:
+The United States agrees to make a motion seeking the
+appointment of a Guardian ad Liter to represent the identified
+victims. Following the appointment of such Guardian, the parties
+agree to work together in good faith to develop a Trust Agreement,
+subject to the Court's approyal, that would provide for any
+damages owed to the identified victims pursuant to 18 U.S.C.
+Section 2255. Then include the last two sentences of your
+paragraph 8.
+Re the two paragraphs following your paragraph 8: I will include
+our standard language regarding resolving all criminal liability and
+I will mention "co-conspirators," but I would prefer not to highlight
+for the judge all of the other crimes and all of the other persons that
+we could charge. Also, we do not have the power to bind
+Immigration and we make it a policy not to try to, however, I can
+tell you that, as far as 1 know, there is no plan to try to proceed on
+any immigration charges against either
+Also, on the !
+, I can prepare letters
+withdrawing them as of the signing of the plea agreement, but I
+would prefer to take out that language. In my eyes, once we have a
+plea agreement, the I
+• has ended and there
+can be no more use of the !
+I had hoped that we were far closer to resolving this than it appears
+that we are. Can I suggest that tomorrow we either meet live or via
+tani jury, if necessary, but maybe we can set a time to meet. If
+you want to meet "off campus" somewhere, that is fine. I will
+If we can resolve some of these issues today, let's try to, and then
+save only the difficult issues for tomorrow.
+Sorry for the long e-mail, and for ruining your date with your
+daughter.
+US_Atty_Cor_0032
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diff --git a/vision-fixhub/court-02/087f76444ad0e976572b4235d0205d80b0805353c990b426efcc535b18f365e4.md b/vision-fixhub/court-02/087f76444ad0e976572b4235d0205d80b0805353c990b426efcc535b18f365e4.md
new file mode 100644
index 0000000000000000000000000000000000000000..a1f97d354bc4139e922a251f5771c066c29a4e31
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@@ -0,0 +1,374 @@
+Filing # 64336055 E-Filed 11/17/2017 10:58:06 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+vS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants).
+SUPPLEMENT TO MOTION IN LIMINE ADDRESSING
+SCOPE OF ADMISSIBLE EVIDENCE
+Pursuant to Florida Statute §90.404(2), Bradley
+by and through his undersigned
+counsel, files this Supplement to his November 13, 2017 Motion in Limine to address the scope
+of admissible evidence in the trial of the pending malicious prosecution claim, and as grounds
+therefore states as follows:
+Summary
+In addition to and in furtherance of the reasons set forth in the Motion in Limine
+Addressing Scope of Admissible Evidence, the following allegations from Epstein's Initial
+Complaint filed on December 7, 2009 and questions and answers from Epstein's deposition taken
+request that the Court grant the Motion in Limine and
+on March 17, 2010 support
+confirm that evidence of Epstein's extensive pattern of victimization of minor females is
+admissible in this malicious prosecution case based upon the filing of the Initial Complaint on
+December 7, 2009.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/17/2017 10:58:06 AM
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+A. Epstein's Initial Complaint Alleged that the L.M., E.W., and Jane Doe cases were
+"Manufactured" for the "Sole Purpose" of Funding Rothstein's Ponzi Scheme
+In his Initial Complaint filed on December 7, 2009 against Mr.
+, Epstein made the
+following allegations:
+actions by each of the claimants!
+included
+, as defined] sought through protective orders and objections to
+block relevant discovery regarding their claimants."
+g her co-conspirders used the i br setins des ted as thestoree victim cases
+being pursued by Brad
+I, along with other manufactured lawsuits, as
+a means of obtaining massive amounts of money."
+Epstein therefore alleged that any sexual transgressions between he and L.M., E.W.,
+and Jane Doe were consensual and that there was no valid basis for the lawsuits being
+pursued on those victim's behalf by Bradley
+• Epstein specifically alleged that
+those victims' claims were part of an unknown number of "manufactured lawsuits" being
+pursued against Epstein. The Initial Complaint further stated that Mr.
+pursued his
+clients' "manufactured" claims for the "sole purpose" of funding Rothstein's Ponzi
+scheme:
+used to fund the litigation against Epstein for the sole purpose of continuing
+the massive Ponzi scheme."
+' Unless otherwise stated, all emphasis is supplied.
+2
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+There can therefore be no question that, as it relates to probable cause and malice, one of
+the key issues in this malicious prosecution claim is whether Epstein had a good-faith belief that
+the LM, EW, and Jane Doe claims were "manufactured" for the "sole purpose" of funding a Ponzi
+scheme. In support of this spurious claim, Epstein alleged that any sexual contact with these minor
+children was "knowledgeable, voluntary, and consensual." Mr.
+has the burden of proof
+to establish that Epstein lacked probable cause for these allegations, because Epstein had in fact
+molested and abused these children over the course of years. Mr. Edwards has every intention to,
+and is certainly entitled to, demonstrate to the members of the jury the truth of the claims being
+asserted by these victims against Jeffrey Epstein, which will also provide circumstantial evidence
+that Epstein had actual malice when he brought this claim, which was nothing more than an attempt
+to intimidate his victims and their attorneys.
+B. Epstein Confirmed in His Deposition That Mr.
+"Ginned Up" and "Crafied" the
+False Claims Made By His Clients"
+The following questions and answers took place at the March 17, 2010 deposition of Jeffrey
+Epstein, all of which are consistent with Epstein's underlying claim that Mr.
+"manufactured lawsuits" on behalf of L.M., E.W. and Jane Doe, despite the fact that any sexual
+acts were between these victims and Epstein were "knowledgeable, voluntary and consensual," for
+the "sole purpose" of furthering Rothstein's Ponzi scheme.
+Dep. Tr. Page 13, lines 8-21 (alleging that victim L.M. was part of a conspiracy to create
+"fraudulent" and "fabricated" cases):
+Q. Why are you suing L.M.?
+MR. PIKE: Form.
+3
+
+
+Supplement to Motion in Limine Addressing Seope of Admissible Evidence
+A: L.M. is part of a conspiracy with Scott Rothstein,
+, creating
+-excuse me -- creating fraudulent cases of a sexually charged nature in which
+the U.S. Attorney has already charged the firm of Rothstein, a firm of which
+is a partner, was a partner, with creating, fabricating malicious
+cases of a sexual nature, including cases with respect to me, specifically, in order
+to fleece unsuspecting investors in South Florida out of millions of dollars.
+Dep. Tr. page 25, lines 6-25 (alleging that Mr.
+multi-million dollar damages that were being alleged):
+I clients' claims were not worth the
+Q. Besides having gone to the media in an attempt to, quote, gin up, unquote,
+these allegations and engaged in what you contend to be irrelevant discovery
+proceedings, what else did Mr.
+, personally, do that forms the basis for this
+lawsuit?
+A. Mr.
+, personally, engaged with his partners, Scott Rothstein, who
+sits in a Federal jail cell, potentially for the rest of his life, he shared information,
+what I've been told and -- excuse me —what I've read in the newspapers, 13 boxes
+of information that had my name on it, with other attorneys at his firm. He
+counseled his clients to intain positions alleging multi-million dollar
+damages in order for them to scam local investors out of millions of dollars.
+He and his -- many of his other partners already under investigation by the FBI and
+the U.S. Attorney have been accused by the U.S. Attorney of running a criminal
+enterprise.
+Dep. Tr. page 30, lines 6-18 (alleging that Mr.
+¡ clients' claims were "false"):
+Q.: What did these other people tell you Mr.
+other media?
+did with respect to going to
+MR. PIKE: Form.
+A: Mr. |
+went to the media to gin up his cases in order that the Rothstein
+firm could generate profits, falsely taking in investors, creating false stories to the
+ocal medias and making statements to local press regarding false claims made
+by his clients in order that Scott Rothstein, who currently sits in jail, could defraud
+along with his other partners of his firm, local Florida investors, Mr. Scarola, out
+of millions of dollars.
+4
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+Dep. Tr. Page 12, lines 12-21 (stating that "gin up these allegations" means to "craft"
+allegations, which included those brought by victim L.M.):
+Q. What does "gin up these allegations" mean?
+MR. PIKE: Form.
+A: It means craft allegations of multi-million dollar cases; in fact, alleging in
+L.M.'s case damages of S50-million, settlements in order for Scott Rothstein and
+the rest of Mr.
+partners to fleece unsuspecting investors out of millions
+and millions of dollars based on cases that didn't exist or alleged cases that I had
+settled.
+Epstein also repeatedly asserted his 5'h Amendment privilege with regards to questions
+related to certain questions regarding his sexual molestation of L.M., E.W., and Jane Doe.
+Obviously, the fact that Epstein never intended to waive his 5'" Amendment privilege when he
+brought this underlying claim is relevant and material to whether Epstein had probable cause to
+initiate this proceeding in the first place.
+C. Epstein's Initial Complaint Alleged LM, EW, and Jane Doe's Cases "Were Weak and
+Had Minimal Value
+Along with alleging that the three specific victim cases were "manufactured" for the "sole
+purpose" of funding a Ponzi scheme, Epstein's Initial Complaint repeatedly states that these cases
+had no real value:
+142(h): "Rothstein and the Litigation Team knew or should have known that
+their three (3) filed cases were weak and had minimal value for the following
+reasons ..
+1 Z: "Defendant, L.M., ... was an essential participant in the scheme referenced
+which was completely out of proportion to her alleged damages."
+5
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+143: "Rothstein, with the intent and improper motive to magnify his financial gain
+so [sic] continue to fund the fraudulent and illegal investment and/or Ponzi scheme,
+had
+demand excessive money from Epstein in the Civil Actions."
+146: "
+*... However, the actual facts behind [L.M.'s] action would never support
+such extraordinary damages."
+151: "
+... Plaintiff Epstein has incurred and continues to incur monetary damages
+including, but not limited to, having to pay an amount in excess of the Civil
+Actions' true value..."
+Whether the cases brought by victims L.M., E.W., and Jane Doe were valid claims with
+real value therefore goes directly to both the probable cause and malice elements of Mr.
+malicious prosecution claim. Did Epstein have probable cause to allege that the claims were "weak
+and had minimal value," and that L.M.'s claim in particular was supported by facts that "would
+never support such extraordinary damages"? If, in fact, Epstein's allegation in paragraph 49 is true
+and the contact with those children was *knowledgeable, consensual, and voluntary," then the jury
+may conclude that Epstein had probable cause to allege that those claims were instead
+"manufactured" for the "sole purpose" of furthering Rothstein's Ponzi scheme. But when the jury
+learns that Epstein really did molest these young girls (for which he paid $5.5 million in settlement
+monies), and that based upon their age it was legally impossible to consent to Epstein's sexual
+molestations, the jury will determine that not only did Epstein lack probable cause for his
+allegations, but he had actual malice at the time the allegations were made. That evidence further
+supports the conclusion that the true purpose was to intimidate Epstein's numerous victims and
+their attorneys, specifically Mr.
+from continuing to prosecute victim claims, or to
+6
+
+
+Ladv. Epstein
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+compromise claims below their true value. Those factual issues that Epstein's Initial Complaint
+put directly in contention should be, and will be, decided by the jury?.
+D. Although Epstein Conceded that He Paid L.M. for Some Form of Sex, the Initial
+Complaint Also Alleged that L.M. Was a Liar
+Although Epstein concedes in paragraph 46(a) that he was "one of L.M.'s many 'Johns","
+he nonetheless insists that Mr.
+""manufactured" L.M.'s claim for the "sole purpose" of
+furthering Rothstein's Ponzi scheme. In furtherance of these allegations, Epstein attacked L.M.'s
+credibility in detail throughout the Initial Complaint. Specifically, Epstein claimed that L.M.'s
+case was "weak and had minimal value" because L.M) did not have any type of sex with Epstein
+(see 9| 42(h)(i)), she did not perform oral sex on Epstein (see f 42(i)), and that Epstein did not
+coerce, induce or entice L.M. to commit any acts of sexual misconduct. (see 1| 47(b)). Because
+L.M.'s claim was false, Epstein alleged that "the actual facts behind her action would never support
+such extraordinary damages" (see 1/46), and instead L.M.'s claim was manufactured to further
+Rothstein's Ponzi scheme (see 1 7).
+Certainly, whether Epstein had in fact abused and molested L.M. is therefore clearly
+relevant to both probable cause and malice.
+E. Epstein's Initial complaint Alleged that the Broad Range of Discovery Engaged in By Mr.
+Was Performed Solely to Further Rothstein's Ponzi Scheme
+maintains that at the close of the evidence the material undisputed facts will require the Court to direct a
+verdict in favor of
+on the issue of probable cause. That is, Epstein's lack of probable cause to
+support his claims against
+will be determined as a matter of law in
+favor, particularly given the
+preclusive effect of Epstein's Fifth Amendment assertions.
+7
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+Epstein also alleged that the broad range of the discovery conducted by
+into matters with no direct tie to
+clients supports a reasonable suspicion that
+that Mr.
+was fabricating claims to support the Ponzi scheme. Specifically, Epstein alleges
+pursued "a civil litigation strategy that was unrelated to the merits or value of
+[his] clients' claims." (f Summary of Action). In support thereof, Epstein challenged virtually
+every litigation decision that Mr.
+made in pursuing the claims brought by L.M., E.W. and
+Jane Doe, including for example:
+131(e): "[Mr.
+utilized the judicial process including, but not limited to,
+unreasonable and unnecessary discovery, for the sole purpose of furthering a
+Ponzi scheme."
+134: "[Mr.
+relentlessly and knowingly pursued flight data and passenger
+manifests regarding flights Epstein took with these famous individuals knowing
+full well that no underage women were onboard and no illicit activities took
+place."
+1 41: "The sole purpose for the scheduling of these depositions or listing high
+profile friends/acquaintances as potential witnesses was, again, to "pump' the cases
+to investors."
+142(a)-(L: Challenging a litany of litigation decisions made by Mr.
+being made solely "li]n furtherance of the[] fraudulent scheme against Epstein."
+as
+1 44: "The actions described in paragraph 42 above herein had no legitimate
+8
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+These allegations were made in support of the theme of Epstein's Initial Complaint: that
+had "manufactured" his clients' claims for the "sole purpose" of furthering Rothstein's
+Ponzi scheme. Whether Epstein knew, at the time he made them, that the allegations listed above
+were in fact false therefore goes directly to the elements of probable cause and malice, and Mr.
+is entitled to establish to the members of the jury that Epstein knew these allegations
+were false at the time he made them because (1) underage females were sexually assaulted on
+Epstein's airplane; (2) some of Epstein's high-profile friends/acquaintances were onboard when
+those assaults occurred; (3) because pursuant to Florida Statute §90.404(2) and Federal Rule of
+Evidence 415(G), evidence of other acts of sexual abuse and child molestation by Epstein against
+victims other than the three clients represented by Bradley
+was clearly admissible and
+the discovery into such other criminal conduct was entirely proper; and (4) because L.M., E.W.,
+and Jane Doe had punitive damage claims pending against Epstein, the full scope of his punitive
+conduct was properly subject to discovery.
+F. Epstein's Initial Complaint Alleged That Epstein Had Not Molested Numerous Children,
+and That He Was Damaged By Mr.
+Truthful Assertions to the Contrary
+One of the allegations in paragraph 42 that Epstein alleged had "no legitimate purpose in
+pursuing the Civil Actions against Epstein, but rather [was] meant to further the [Ponzi scheme],"
+was the following statement made by Mr.
+to a Federal Court on July 21, 2009:
+What the evidence is really going to show is that Mr. Epstein - at least dating back
+as far as our investigation and resources have permitted, back to 1997 or "98 - has
+talking about give, we're not talking about 20
+alery single day of his life on ale an attemp 20, sex ra ly buse children 0 wer
+not talking about 400, which, I believe, is the number known to law enforcement,
+we are talking about thousands of children ... and it is through a very intricate and
+complicated system that he devised where he has as many as 20 people working
+9
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+underneath him that he is paying well to schedule these appointments, to locate
+these girls.
+(9 42(e)). Epstein then alleges, in paragraphs 50, 51, and 52, that he has been damaged, in part, by
+Mr.
+contention that Epstein is a serial and unrepentant child molester.
+It is therefore beyond dispute that, in prosecuting his malicious prosecution claim, Mr.
+has the burden of proof to establish that Epstein did not have a good-faith basis to allege
+that he was damaged by Mr.
+proclamation to the Federal Court (along with the host of
+other spurious and malicious allegations contained in the Initial Complaint). Why? Because
+Epstein really did molest all those young, innocent children, heinous crimes that he has callously
+compared to "stealing a bagel."
+Conclusion
+For the foregoing reasons, Edwards respectfully requests that the Court grant his Motion
+in Limine Addressing Scope of Admissible Evidence.
+10,
+10
+
+
+] adv. Epstein
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+_day of
+NoV.
+_ 2017.
+Florída Bar No.: 169440
+DAVID P. VITALE JR.
+Florida Bar No.: 115179
+Attorney E-Mail(s): jsx@searcylaw.com and
+mep@seareylaw.com
+Primary B-Mail:_scarolateam@searcylaw.com
+Searey Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+NOT A CERe
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+J
+11
+
+
+Supplement to Motion in Limine Addressing Seope of Admissible Evidence
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com;
+kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J.
+, Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+NOT A
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com;
+Scott@linkrocklaw.com;
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com;
+Tanya@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+1., Suite 701
+'ort Lauderdale, FL 3330
+hone: (954)-745-5841
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+12
\ No newline at end of file
diff --git a/vision-fixhub/court-02/087f76444ad0e976572b4235d0205d80b0805353c990b426efcc535b18f365e4.receipt.json b/vision-fixhub/court-02/087f76444ad0e976572b4235d0205d80b0805353c990b426efcc535b18f365e4.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.md b/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.md
new file mode 100644
index 0000000000000000000000000000000000000000..3acc693b45ee428d4989941dbb4e6e635ade85c4
--- /dev/null
+++ b/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.md
@@ -0,0 +1,98 @@
+Case 9:08-cv-80736-KAM Document 327 Entered on FLSD Docket 05/14/2015 Page 1 of 4
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:08-80736-Civ-Marra/__
+JANE DOE #1 and JANE DOE #2
+V.
+UNITED STATES
+UNOPPOSED MOTION OF JANE DOE 1 AND 2 TO FILE A SINGLE, 60-PAGE
+MOTION FOR PARTIAL SUMMARY JUDGMENT
+COME NOW Jane Doe 1 and Jane Doe 2, by and through undersigned counsel, to file this
+unopposed motion for leave to file a single, 60-page pleading in support of partial summary
+judgment. The document would include both a statement of undisputed material facts as well as
+additional argument. Because this exceeds the length specified in the local rules, see Rule 56.1,
+this motion is required. The motion is unopposed. A proposed order is attached.
+As the Court is aware, in 2011 the victims attempted to narrow the disputed issues in
+this case by filing a Motion for Finding of Violations of the Crime Victims' Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48 filed March 21, 2011). That document
+was 40 pages long and contained 52 proposed undisputed facts. After a Government response,
+the Court ultimately ruled that "some factual development is necessary to resolve the remaining
+issues in the case." DE 99 at 11. The Court allowed the victims to file requests for documents
+and requests for admission, which the victims propounded on the Government in 2011.
+Before filing their summary judgment motion, the victims have been made to wait year
+for the Government's production of the requested documents. The Government was ordered to
+produce discovery responses in June, 2013. DE 189. A stay of that order was entered while an
+
+
+Case 9:08-cv-80736-KAM Document 327 Entered on FLSD Docket 05/14/2015 Page 2 of 4
+appeal was taken, and that stay was lifted when the appellate mandate issued June, 2014. DE
+254. Now, nearly four years after the discovery requests were made and a year after the stay was
+lifted, the Government has not yet finished producing all of the documents that the victims have
+requested. And, as the Court is aware, a number of documents are currently submitted to the
+Court for in camera review.
+While the victims are due complete discovery responses, and the victims believe these
+additional documents would be helpful to proving and strengthening their case, the victims also
+believe that certain important aspects of the case are now ripe for summary judgment even with
+the limited discovery and information in their possession. In the interests of expediting this
+litigation, the victims believe that they can file a well-founded motion for partial summary
+judgment which would narrow the remaining issues before the Court. The aspects ripe for
+summary judgment, however, revolve around dozens and dozens of emails and letters between
+the prosecutors and Epstein's defense attorney's during the negotiations surrounding the nonprosecution agreement (NPA).
+Accordingly, to set out the full chain of circumstances
+surrounding the NPA, the victims must set out in some detail these materials. In addition, the
+victims must set out related interactions between the Government and the various victims in this
+case. The victims will rely on the 52 previously offered undisputed facts, as well as a number of
+additional facts. To do this will require a pleading of greater length than the 40 page pleading
+the victims filed previously.
+The Court has previously allowed lengthy summary judgment pleadings in complex cases.
+See, e.g., Securities and Exchange Commission v. Lauer, NO. 9:03-cv-80612-KAM (40-page
+statement of material facts). The victims respectfully submit that the issues presented by this
+case are equally complex and equally important, warranting a longer-than-normal pleading.
+2
+
+
+Case 9:08-cv-80736-KAM Document 327 Entered on FLSD Docket 05/14/2015 Page 3 of 4
+For all these reasons, the Court should allow the victims to file a single, 60-page pleading
+in support of partial summary judgment.
+DATED: May 14, 2015
+Respectfully Submitted,
+/sl
+•JAFFE, WEISSING,
+_. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Facsimile (954) 524-2822
+E-mail: brad@pathtojustice.com
+And
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah"
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe #1 and Jane Doe #2
+CERTIFICATE OF SERVICE
+I certify that the foregoing document was served on May 14, 2015, on the following using
+the Court's CM/ECF system:
+Dexter Lee
+A.
+Villafaña
+500 S. Australian Ave., Suite 400
+West Palm Beach, FL 33401
+* This daytime business address is provided for identification and correspondence
+purposes only and is not intended to imply institutional endorsement by the University of Utah
+3
+
+
+Case 9:08-cv-80736-KAM Document 327 Entered on FLSD Docket 05/14/2015 Page 4 of 4
+(561) 820-8711
+Fax: (561) 820-8777
+E-mail: Dexter.Lee @usdoi.gov
+E-mail:
+Attorneys for the Government
+/s/
+4
diff --git a/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.receipt.json b/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..069d77e0ea6b437d7e70ea0dbdc9e640b7ef7526
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+++ b/vision-fixhub/court-02/0880dda4f0524ec85aa35e4db4774503c6a1f48e5fa922ab4bcfab69a5e5b7fd.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 5,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "4a44c71de1576418c7ed52f4537bf4f446355d6833113e532fd0d6910a4e10f7",
+  "output_sha256": "f54d80b597804660ed504f910cc15def0ebbfb47ae2c73c217844ce5a9c9067d",
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+}
diff --git a/vision-fixhub/court-02/08cc7eb9626ce7a4417f085981c5af7810d0b65f439756a2d30fc92b5e49c203.md b/vision-fixhub/court-02/08cc7eb9626ce7a4417f085981c5af7810d0b65f439756a2d30fc92b5e49c203.md
new file mode 100644
index 0000000000000000000000000000000000000000..b472f5027e67d1f92978160593c601205ef44260
--- /dev/null
+++ b/vision-fixhub/court-02/08cc7eb9626ce7a4417f085981c5af7810d0b65f439756a2d30fc92b5e49c203.md
@@ -0,0 +1,918 @@
+Filing # 65026569 E-Filed 12/06/2017 11:08:31 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF FILING
+DOCUMENTS PRESENTED TO COURT AT DECEMBER 5. 2017, HEARING
+Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), hereby gives notice of the filing
+of the following documents that were presented to the Court at the December 5, 2017, hearing:
+In re Investigation of Jeffrey Ep
+, September 24, 2007, Non-Prosecution
+Agreement; October 29, 2007, Addendum; and December 7, 2007, Affirmation (Exhibit A); and
+Jeffrey E. Epstein's June 30, 2008, Plea (Exhibit B).
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 12/06/2017 11:08:31 AM
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on December 6, 2017, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Cara Berard Rockenbach (FBN 44903
+Ingela M. Many (FBN 26680
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Angela@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Secondary: Tanya@linkrocklaw.com
+Secondary: Eservice@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT A CER
+2
+
+
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+I Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+staff.efile@pathtojustice.com
+Co-Counsel for Defendant/Counter-Plaintif)
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT A
+NOT
+SERVICE LIST
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+144 West Railroad Avenuc
+West Palm Beach, FL 33401
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Marc S. Nurik
+Law Offices of Mare S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+3
+
+
+COPY
+
+NOT A CERTIF
+
+
+file
+Place in
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+NON-PROSECUTION AGREEMENI
+IT APPEARING that the City of Palm Beach Police Department and the State
+IT APPEARING that the State Attorney's Office has charged Epstein by indictment
+with solicitation of prostitution, in violation of Florida Statutes Section 796.07;
+IT APPEARING that the United States Attorney's Office and the Federal Bureau of
+Investigation have conducted their own investigation into Epstein's background and any
+offenses that may have been committed by Epstein against the United States from in or
+around 2001 through in or around September 2007, including:
+(1) knowingly and willfully conspiring with others known and unknown to.
+commit an offense against the United States, that is, to use a facility or means
+of interstate or foreign commerce to knowingly persuade, induce, or entice
+minor females to engage in prostitution, in violation of Title 18, United States
+Code, Section 2422(b); all in violation of Title 18, United States Code, Section
+371;
+(2)
+knowingly and willfully conspiring with others known and unknown to travel
+in interstate commerce for the purpose of engaging in illicit sexual conduct, as
+defined in 18 U.S.C. § 2423(f); with minor females, in violation of Title 18,
+United States Code, Section 2423(b); all in violation of Title 18, United States
+Code, Section 2423(e);
+(3)
+using a facility or means of interstate or foreign commerce to knowingly
+persuade, induce, or entice minor females to engage in prostitution; in
+violation of Title 18, United States Code, Sections 2422(b) and 2;
+(4)
+traveling in interstate commerce for the purpose of engaging in illicit sexual
+conduct, as defined in 18 U.S.C. § 2423(D), with minor females; in violation
+
+
+
+of Title 18, United States Code, Section 2423(b); and
+(5)
+commercial sex act as defined in 18 U.S.C. § 1591(c)(1); in violation of Title
+18, United States Code, Sections 1591(a)(1) and 2; and
+IT APPEARING, after an investigation of the offenses and Epstein's background by
+both State and Federal law enforcement agencies, and after due consultation with the State
+Attorney's Office, that the interests of the United States, the State of Florida, and the
+Defendant will be served by the following procedure;
+THEREFORE, on the authority of R. Alexander Acosta, United States Attomey for
+the Southern District of Florida, prosecution in this District for these offenses shall be
+deferred in favor of prosecution by the State of Florida, provided that Epstein abides by the
+following conditions and the requirements of this Agreement set forth below.
+If the United States Attorney should determine, based on reliable evidence, that,
+during the period of the Agreement, Epstein willfully violated any of the conditions of this
+Agreement, then the United States Attorney may, within ninety (90) days following the.
+expiration of the term of home confinement discussed below, provide Epstein with timely
+United States Icarning of facts which may provide a basis for a determination of a breach of
+the Agreement
+After timely fulfilling all the terms and conditions of the Agreement, no prosecution
+for the offenses set out on pages 1 and 2 of this Agreement, nor any other offenses that hav
+en the subject of the joint investigation by the Federal Bureau of Investigation and th
+United States Attorney's Office, nor any offenses that arose from the Federal Grand Jury
+investigation will be instituted in this District, and the charges against Epstein if any, will be
+dismissed.
+
+
+
+Terms of the Agreement:
+Epstein shall plead guilty (not nolo contendere to the Indictment as
+currently pending against him in the 15th Judicial Circuit in and for
+Palm Beach County (Case No. 2006-cf-009495AXXXMB) charging
+196) count of salicitation of prostitution, in violation of FL. Stat. S
+i. In addition, Epstein shall plead guilty to an Information filec
+by the State Attorney's Office charging Epstein with an offense that
+requires him to register as a sex offender, that is, the solicitation of
+ninors to engage in prostitution, in violation of Florida Statutes Sectior
+2.
+3.
+5.
+6.
+Epstein shall make a binding recommendation that the Court impose a
+thirty (30) month sentence to be divided as follows:
+(a)
+Epstein shall be sentenced to consecutive terms of twelve (12)
+months and six (6) months in county jail for all charges, without
+ny opportunity for witholding adjudication or sentencing, an
+vithout probation or
+community control in lieu of
+imprisonment; and
+Epstein shall be sentenced to a term of twelve (12) months of
+community control consecutive to his two terms in county jail
+as described in Term 2(a), supra.
+This agreement is contingent upon a Judge of the 15th Judicial Circuit
+ccepting and executing the sentence agreed upon between the Stat
+Attorney's Office and Epstein, the details of which are set forth in thi
+agreement.
+The terms contained in paragraphs I and 2, supra, do not foreclose
+Epstein and the State Attorney's Office from agreeing to recommend
+any additional charge(s) or any additional terms) of probation and/or
+incarceration.
+Epstein shall waive all challenges to the Information filed by the State
+Ittorney's Office and shall waive the right to appeal his conviction and
+sentence, except a sentence that exceeds what is set forth in paragraph
+(2), supra.
+Epstein shall provide to the U.S. Attorney's Office copies of all
+
+
+
+8.
+9.
+10.
+10
+11.
+proposed agreements with the State Attomey's Office prior to entering
+into those agreements.
+The United States shall provide Epstein's attomeys with a list of
+ndividuals whom it has identified as victims, as defined in 18 U.S.C.
+through that representative.
+If any of the individuals referred to in paragraph (7), supra, elects to
+file suit pursuant to 18 U.S.C. § 2255; Epstein, will fiot contest the
+jurisdiction of the United States District Court for the Southern District
+of Florida over his person and/or the subject matter, and Epstein waives
+his right to contest liability and also waives his right to contest damages
+up to an amount as agreed to between the identified individual and
+Epstein,
+so long as the identified individual elects to proceed
+exclusively under 18 U.S.C. § 2255, and agrecs to waive any other
+claim for damages, whether pursuant to state, federal, or common law.
+Notwithstanding this waiver, as to those individuals whose names
+appear on the list provided by the United States, Epstein's signature on
+this agreement, his waivers and failures to contest liability and such
+damages in any suit are not to be construed as an admission of any
+criminal or civil liability.
+Epstein's signature on this agreement also is not to be construed as an
+admission of civil or criminal liability or a waiver of any jurisdictional
+or other defense as to any person whose name does not appear on the
+list provided by the United States.
+Except as to those individuals who elect to proceed exclusively under
+18 U.S.C. § 2255, as set forth in paragraph (8), supra, neither Epstein's
+provided by the United States.
+Epstein shall use his best efforts to enter his guilty plea and be
+
+
+
+sentenced not later than October 26, 2007. The United States has no
+›bjection to Epstein self-reporting to begin serving his sentence no
+ater than January 4, 2008
+12.
+based on standard rules and regulations that apply in the State of
+Florida. At the United States' request, Epstein agrees to provide an
+accounting of the gain time he carned during his period of
+incarceration.
+13. The parties anticipate that this agreement will not be made part of any
+public record. If the United States receives a Freedom of Information
+Act request or any compulsory process commanding the disclosure of
+the agreement, it will provide notice to Epstein before making that
+disclosure.
+Epstein understands that the United States Attorney has no authority to require the
+State Attorney's Office to abide by any terms of this agreement. Epstein understands that
+it is his obligation to undertake discussions with the State Attorney's Office and to use his
+best efforts to ensure compliance with these procedures, which compliance will be necessary
+to satisfy the United States' interest. Epstein also understands that it is his obligation to use
+his best efforts to convince the Judge of the 15th Judicial Circuit to accept Epstein's binding
+recommendation regarding the sentence to be imposed, and understands that the failure to
+do so will be a breach of the agreement.
+In consideration of Epstein's agreement to plead guilty and to provide compensation
+in the manner described above, if Epstein successfully fulfills all of the terms and conditions
+of this agreement, the United States also agrees that it will not institute any criminal charges
+against any potential co-conspirators of Epstein, including but not limited to
+Adriana Ross, Lesley Groff, or
+Further, upon execution of this
+agreement and a plea agreement with the State Attorney's Office, the federal Grand Jury
+investigation will be suspended, and all pending federal Grand Jury subpoenas will be held
+in abeyance unless and until the defendant violates any term of this agreement. The
+defendant likewise agrees to withdraw his pending motion to intervene and to quash certain
+grand jury subpoenas. Both parties agree to maintain their evidence, specifically evidence
+requested by or directly related to the grand jury subpoenas that have been issued, and
+including certain computer equipment, inviolate until all of the terms of this agreement have
+been satisfied. Upon the successful completion of the terms of this agreement, all
+outstanding grand jury subpoenas shall be deemed withdrawn.
+
+
+
+By signing this agreement, Epstein asserts and certifies that each of these terms is
+federal offenses.
+By signing this agreement, Epstein asserts and certifies that he is aware of the fact that
+the Sixth Amendment to the Constitution of the United States provides that in all criminal
+rosecutions the accused shall enjoy the right to a speedy and public trial, Epstein furthe
+s aware that Rule 48(b) of the Federal Rules of Criminal Procedure provides that the Cou
+may dismiss an indictment, information, or complaint for unnecessary delay in presenting
+a charge to the Grand Jury, filing an information, or in bringing a defendant to trial. Epstein
+hereby requests that the United States Attorney for the Southern District of Florida defer such
+prosecution. Epstein agrees and consents that any delay from the date of this Agreement to
+the date of initiation of prosecution, as provided for in the terms expressed herein, shall be
+deered to be a necessary delay at his own request, and he hereby waives any defense to such
+prosecution on the ground that such delay operated to deny him rights under Rule 48(b) of
+the Federal Rules of Criminal Procedure and the Sixth Amendment to the Constitution of the
+United States to a speedy trial or to bar the prosecution by reason of the running of the statute
+of limitations for a period of months equal to the period between the signing of this
+agreement and the breach of this agreement as to those offenses that were the subject of the
+grand jury's investigation. Epstein further asserts and certifies that he understands that the
+Fifth Amendment and Rule 7(a) of the Federal Rules of Criminal Procedure provide that all
+felonies must be charged in an indictment presented to a grand jury. Epstein hereby ágrees
+and consents that; if a prosecution against him is instituted for any offense that was the
+subject of the grand jury's investigation, it may be by way of an Information signed and filed
+by the United States Attorney, and hereby waives his right to be indicted by a grand jury as
+to any such offense.
+///
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been read
+nd explained to him. Epstein hereby states that he understands the conditions of this Non
+rosecution Apreement and agrees to comply with then
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY.
+Dated:
+Done letoz
+By:
+VILLAFANA
+ASSISTANT U.S. ATTORNEY
+JEFPREY EPSTAI
+Dated:_
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+NOT A CER
+LILLY ANN
+BSQ.
+ATTORNEY FOR JEPFREY EPSTEIN
+Page
+7
+of 7
+
+
+By signing this agrecment, Epstein asserts and certifies that the above has been read
+and explained to him. Epstein hereby states that he understands the conditions of this Non-
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated:
+By:
+A.
+VILLAFAÑA
+ASSISTANT U.S. ATTORNEY
+Dated:_
+JEFFREY EPSTEN
+Dared: 9/24/07
+COUNSBL TO JEFFREY EPSTEIN
+Dated:
+NOT A CER
+LILY ANN
+ESQ.
+
+
+
+By signing this agreement, Epstein asserts and certifies that the above has been rea
+nd explained to him. Epstein bereby states that he understands the conditions of this Nor
+R. ALEXANDER ACOSTA
+UNITED STATES ATTORNEY
+Dated: _
+[VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dated: _
+JEFFREY EPSTEIN
+Dated:_
+GERALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated: 9-24-07
+ANN SAN
+STEZ, ESQ:
+NOT A
+Page 7
+of
+7
+
+
+IN RE:
+INVESTIGATION OF
+JEFFREY EPSTEIN
+ADDENDUM TO THE NON-PROSECUTION AGREEMENT
+IT APPEARING that the parties seck to clarify certain provisions of page 4, paragraph ?
+follow on-Prosecution Agreement hereinafier"paragraph 7), that agreement is modified as
+7A.
+Tho United States has the right to assign to an independent third-party the responsibility
+for consulting with and, subject to the good faith approval of Epstein's counsol, selecting
+the attorney representative for the individuals identified under the Agreement. If the
+United States elects to assign this responsibility to an independent third-party, both the
+United States and Epstein retain the right to make good faith objections to the attorney
+representative suggested by the independent third-party priorto the final designation of
+the attorney representative.
+7B.
+The parties will jointly prepare a short written submission to the independent third-party
+regarding the role of the attorney representative and regarding Epstein's Agreement to
+pay such attorney representative his or her regular customary hourly rate for representing
+such victims subject to the provisions of paragraph C, infra.
+7C.
+Pursuant to additional paragraph 7A. Epstein hes agreed to pay the fees of the attorney
+representative selected by the independent third party. This provision, however, shall not
+obligate Epstein to pay the fees-and costs of contested litigation filed against him. Thus,
+if after consideration of potential settlements, an attorney representative clects to file a
+contested lawsuit pursuant to 18 U.S.C. s 2255 or elects to pursue any other contested
+remedy, the paragraph 7 obligation of the Agreement to pay the costs of the altomey
+representative, as opposed to any statutory or other obligations to pay reasonable
+attorneys fees and costs such as those contained in s 2255 to bear the costs of the attorney
+representative, shall cease.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+Epstein hereby states that he understands the clarifications to the Non
+rosecution Agreement and agrees to comply with ther
+R. ALEXANDER A COSTA
+UNITED SIATES ATTORNEY
+Dated:
+Due /12r/z
+By:
+A.
+VILLAPANA
+ASSISTANT U.S. ATTORNEY
+EFREY APSTEIN
+Dated:
+GERALD LEFCOURI, ESQ.
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+NOT A CER
+LILLY ANN
+ESQ.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+Epstein hereby states that he understands the clarifications to the Noa-
+L. ALEXANDER ACOSTA
+JNITED STATES ATTORNEY
+Dated: _
+By:
+VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dated:
+Da 10/29107
+JEFFREY EPSTEIN
+Petecoul
+COUNSEL TO JEFFREY EPSTEIN
+Dated:
+NOT A CER
+LILLY ANN
+, ESQ.
+
+
+By signing this Addendum, Epstein asserts and certifies that the above has been read and
+explained to him.
+Epstein hereby states that ho understands the clarifications to the Non-
+• ALEXANDER ACOST.
+NITED STATES ATTORNE
+Dated:
+BY:
+AL
+- VILLAFANA
+ASSISTANT U.S. ATTORNEY
+Dated:
+JEFFREY EPSTEIN
+Dated: _
+GBRALD LEFCOURT, ESQ.
+COUNSEL TO JEFFREY EPSTED
+Dated: 10-29-07
+NOT A
+• CER
+LILLY ANN SANCHEZ, ES
+
+
+Dac-07-07
+04:5-pe
+Froe-Fowler-l
+1 Burnett
+
+T-RES P.003/004 - F-875
+Afirmation
+I, Jeffrey B. Epstein do hereby ro-affirm the Noo-Proscoution Agreement and Addendum to
+same dared October 30, 2007.
+12/1/7
+Dato
+NOT A CERTIFIED COPY
+
+
+COPY
+
+NOT A CERTIF
+
+
+PLEA IN THE CIRCUIT COURT
+THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT
+Name: Jeffrey E. Epstein
+Plea: Guilty X
+case No.
+Charge
+Count Lesser Degree
+06CF009454AMB
+Felony Solicitation of Prostitution
+1
+No
+3 FEL
+D8CF009381AMB Procuring Person Under 18 for Prostitution 1
+No
+2 FEL
+PSI: Waived/Not Required _X.
+ADJUDICATION:
+Adjudicate [x]
+Required/Requested_
+SENTENCE:
+06CF009454AMB, the Delendant is sentenced to 12 months in the Palm Beach County
+Detention Facity, with credit for 1 (one) day time served.
+On 08CF008381AMB, the Deiendant is sentenced to 6 months in the Palm Beach County
+Deiention Facilty; with credit for 1 (one) day time served. This 6 month sentence is to be
+served-consacutive-to-the 12 month-sentence in 060F009454AMB. Following this 6
+month sentence, the Defendant will be piaced on 12 months Communky Control 1 (one).
+The conditions of community control are attached hereto and incorporated herein.
+OTHER COMMENTS OR CONDITIONS:
+As a special condition of his community control, the Defendant is to have no unsupervised
+contact with minors, and the supervising adut must be approved by the Department of
+• Corrections.
+The Defendant is designated as a Sexual Offender pursuant to Florida Statute 943,0435 and
+must abice by at the corresponding requirements of the statute, a copy of which is attached
+hereto and incorporated herein.
+The Defendant must provide a DNA sample in court at the time of this ple
+61301/08
+Date of Plea
+Altorney for the Defendant
+Defendant
+
+
+948.101 Terms and conditions of community control and criminal quarantine community
+control.--
+(1) The court shall determine the terms and conditions of community control. Conditions
+spocified in this subsaction do not require oral pronouncament at the time of sontencing and
+may be considered standard conditions of community control.
+(a) The court shall require intonsive suporvision and survalliance for an offender placed into
+community control, which may include but is not limited to:
+1. Specified contact with the parole and probation officer.
+2. Confinemant to an agreed-upon residence during hours awey from employment and public
+service activities.
+• 3. Mandatory public service,
+4. Supervision by the Department of Corrections by means of an electronic monitoring device
+or sysbem.
+5. Tho standard conditions of probation set forth in s. 948.03.
+(b) For an offender placed on criminal quarantina community control, the court shall require:
+1. Eloctronic monitoring 24 hours per day.
+2. Confinement to a designated residence during designated hours.
+(2) The enumeration of specific kinds of terms and conditions does not prevent the court from
+adding thereto any other terms or conditions that the court considers proper. Howevor, the
+sentencing court may only impose a condition of supervision allowing an offender convicted of
+s. 794.011, s. 800.04, s. 827.071, or s. 847.0145 to reside in anothar state if the order
+stipulates that it is contingent upon the approve! of the recaiving state interstate compact
+authority. The court may rescind of modify at any time the terms and conditions theretofore
+imposed by it upon the offender in community control. However, if the court withholds
+adjudication of guilt or imposes a period of incarceration as a condition of community controi,
+the period may not exceod 354 days, and incarceration shall be restricted to a county facility,
+a probation and restitution cenber under the jurisdiction of the Department of Corractions, a
+probation program drug punishment phase i secure residential treatment institution, or a
+community residential facility owned or operated by any entity providing such services.
+(3) The court may place a defendant who is being sentenced for criminal transmission of HIY in
+violation of s. 775.0877 on criminal quarantine community control. The Department of
+Corractions shall develop and administer a criminal quarantine community control program
+amphasizing intensive supervision with 24-hour-per-day electronic monitoring. Criminal
+quarantine community control status must include surveillance and may include other moasures
+normally associated with community control, axcept that specific conditions necassary to
+monitor this population may be ordered.
+
+
+1943.0435 Sexual offendars roquired to ragister with the department; penalty,"
+(1) As used in this section, the term:
+(a)1, "Sexual offender" means a person who moots the criteria in sub-subparagraph ar, subsubparagraph b., sub-subparagraph c., or sub-subparagraph d., as follows:
+a.(l) Has been convicted of committing, or attempting, soliciting, or conspiring to commit, any
+of the criminal offenses proscribed in the following statutes in this state or similar offenses in
+another jurisdiction: s. 787.01, s. 787.0Z, or s. 787.025(2)(c), where the victim is a minor and
+•the defondant is not the victim's parent or guardian; s. 794.011, excluding s. 794.011(10); 5.
+794.05; s. 796.03; s. 796.035; s. 800.04; s. 825.1025; s. 827.071; s. 347.0133; s. 847.0135,
+excluding s. 847.0135(4); s. $47.0137; s. 847.0138; s. 847.0145; or s. 985:701(1); or arry similar
+offense committed in this state which has boen redesignated from a former statute number to
+one of those listed in this sub-sub-subparagraph; and
+(1) Has beeri released on or after October 1, 1997, from the sanction imposed for any
+conviction of an offense described in sub-sub-subparagraph (I). For purposas of sub-subsubparagraph (I), a sanction imposed in this state or in any other jurisdiction includes, but Is
+not limited to, a fine, probation, community control, parola, conditional reloase, control
+reloasa, or incarcoration in a state prison, fedoral prison, private cotractional facility, or local
+detention facility;
+b. Establishes or maintains a residance in this state and who has not baen designabed as a
+sexual prodator by a court of this state but who has boon designated as a sexual pradator, as a
+saxually violent prodator, or by another sexual offender designation in another state or
+jurisdiction and was, as a result of such designation, subjected to registration or community or
+public notification, or both, or would be if the person were a resident of that state or
+jurisdiction, without regard to whether the person otherwise meets the criteria for registration
+as a sexual offender;
+c. Establishes or maintains a residence in this state who is in the custody or control of, or.
+under the supervision of, any other state or jurisdiction as a resuit of a conviction for
+committing, or attempting, soliciting, or conspiring to commit, any of the criminal offenses
+proscribed in the following statutes or similar offense in another jurisdiction: s. 787.01, 5.
+767.02, or s. 787.025(2)(c), where the victim is a minor and the dafendant is not the victim's
+parent or guardian; s. 794.011, excluding s. 794.011(10); s. 794.05; s. 796.03; s. 796.035; 5.
+800.04; 5. 825.1025; 5. 827.071; s. 847.0133; s. 847.0135, excluding s. 847.0135(4); 5,
+• 76.03
+847.0137; s. 347.0138; s. 047.0145; or s. 985.701(1); or any similar offense commitbed in this
+state which has been redesignated, from a former statute number to one of those listad in this
+sub-subparagraph; or
+d. On or after July 1, 2007, has been adjudicated delinquent for committing, or attempting,
+soliciting, or conspiring to commit, any of the criminal offenses proscribed in the following
+statutes in this state or similar offenses in another jurisdiction whon the juvenile was 14 years
+of age or older at the tirie of the offense:
+(1) Section 794.011, excluding s. 794.011(10);
+(It) Section 800.04(4)(b) whore the victim is under 12 years of age or where the court finds
+sexual activity by the use of force or coercion;
+(ill) Section 800.D4(5)(c)1. where the court finds molestation involving unclothed genitals
+
+
+(IV) Soction 800:04(5) (d) where the court finds the use of force or coercion and unclothed
+genitals.
+2. For all qualifying offanses listed in sub-subparagraph (1)(a)1.d., the court shall make a
+writton finding of the age of the offender at the time of the offensa.
+For each violation of a qualifying offense listed in this subsection, the court shall make a
+written finding of the age of the victim at the time of the offense, For a violation of 5.
+800.04(4), the court shall additionally make a written finding indicating that the offense did or
+did hot involve sexual activity and indicating that the offense did or did not imoive force or
+coercion. For a violation of s. 800.04(5), the court shali additionally make a written finding
+that the offense did or did not involve unclothed genitals or genital aree and that the offense
+did or did not involve the use of force or coercion.
+(b) "Convicted means that there has boon a determination of guilt as a result of a trial or the
+entry of a plea of guilty or nolo contendere, regardiess of whethar adjudication is withhole,
+and includes an adjudication of delinquency of a juverfle as specified in this saction.
+Conviction of a similar offense includes, but is not limited to, a conviction by a fadoral or
+military tribunal, including courts-martial conducted by the Armed Forces of the Unfted States,
+and includes a conviction or entry of a plea of guilty or nolo contendiore resulting in a sanction
+in any state of the United States or other jurisdiction. A sanction includes, but is not limited
+to, a fine, probation, community control, parole, conditional release, control reloase, or
+incarcaration in a state prison, fedoral prison, private correctionel facility, or local detention
+facility.
+(c) "Permanent residence" and "tamporary residence" have the same meaning ascribed in 5.
+125.21.
+(d) "Institution of higher education" means a career center, community collago, collage, state
+university, or incapendent postsecondary institution.
+(e) "Change in enroliment or amployment status" means the commancement or termination of
+enrollment or employmant or a change in location of aioliment or ampicyment.
+(f) "Electronic mail address" has the same mesning as provided in s. 668.602.
+(e) "Instant message name" means an identifier that allows a person to communicate in real
+time with another person using the internet.
+(2) A sexual offender shai!:
+(a) Report in person at the sheriffs office:
+1. In the county in which the offender establishes or maintains a permanent of tomporary
+residenco within 46 hours after:
+a. Establishing permanant or temporary residence in this state; or
+b. Being reloased from the custody, control, or supervision of the Department of corractions
+or from the custody of a private correctional faciliby; or
+2. In the county where he or she was convicted within 48 hours after being convicbed for a
+queslifying offense for registration under this section if the offender is not in the custody or
+
+
+control of, or undor the suporvision of, the Departmant of Corroctions, or is not in the custody
+of a prívate correctiona. facility.
+Any change in the sexual offender's parmanent or temporary residence, name, any electronic
+mail address and any instant message name required to be provided pursuant to paragraph
+(4)(d), after the soxual offender reports in person at the sheriff's offica, shall bo accomplished
+in the mannor provided in subsoctions (1), (7), and (8).
+(b) Provide his or her nama, date of birth, social security number, race, sax, hoight, weigne,
+hair and eye color, tattoos or other identifying marks, occupation and place of employmant,
+address of permanent or legal residence or address of any current temporary residence, within
+the state and out of state, including a rural route address and a post office box, any electronic
+mail address and any instant message name required to be provided pursuant to paragraph
+(4)(d), date and place of each conviction, and a briaf description of the crime or crimes
+committed by the offendor. A post office box shall not be provided in lieu of a physical
+residential address.
+1. If the sarual offender's place of residence is a motor vehicle, trailer, mobile home, or
+manufactured homa, as defined in chapter 320, the sexual offender shall also provide to tho
+departmont through the sheriffs office written notice of the vehicle identification number; tho
+licenso tog number; the registration number; and a description, including color schame, of the
+•motor vehicie, trailer, mobile home, or manufactured home, If the sexua! offender's place of
+residonce is a vessol, live-aboard vessol, or housaboat, as defined in chapter 327, the sexuai
+offander shall also provide to the dapartment writton notice of the hull identification number;
+the manufacturer's serial number; the name of the vessel, live-aboard vessel, or houseboat; the
+registration number; and a description, including color scheme, of the vessel, live-aboard
+vessel, or houseboat.
+2. If the sexuel offender is enrolled, employed, or carrying on a vocation at an institution of
+higher education in this state, the sexual offender shall also provide to the departmon: through
+the sheriff's office the name, address, and county of ouch institution, including eech campus
+attended, and the sexun! offender's enrollment of omployment status. Each change in
+•enrollment or employment status shall be reported in person at the sheriffs office, within 10.
+hours after any change in status. The sheriff shall promptly notify each institution of the sexual
+offender's presence and any change in the sexual offender's enroliment or employment status.
+When a soxual offender reports at the sheriffs offica, the sheriff shall take a photograph and a
+set of fingerprints of the offender and forward the photographs and fingerprints to the
+departmont, along with the information provided by the saxual offender. The sheriff stali
+promptly provide to the department the information received from the sexual offender,
+(3) Within 48 hours after the report required under subsoction (2), a sexual offender shall
+report in person at a driver's license office of the Departmont of Highway Safety and Motor
+Vehiclos, unless a driver's license or identification card that complies with the requirements of
+s. 32Z. 141(3) was previously sacured or updated under s. 944.607. At the drivar's licanse office
+the saxual offendor shall:
+(a) If otherwise qualified, sacure a Florida drivar's licansa, renew a Florida driver's licanse, or
+secure an identification card. The sexual offender shall identify himself or harsolf as a sexual
+offender who is required to comply with this section and shall provide proof that the sexual
+offander reported as required in subsection (2). The saxual offender shall provide any of the
+information specified in subsection (2), if requested. The saxual offender shall submit to tho
+taking of a photograph for use in Issuing a drivar's licenso, renewed licensa, or identification
+card, and for use by the department in maintaining current records of sexual offondors.
+
+
+(b), Pay the costs assessed by the Department of Highway Safety and Motor Vehicles for issuing
+or renowing a driver's licenso or idontification card as required by this section. "The driver's
+Licenso or identification card issued must be in compliance with s. 322.141(3).
+(c) Provide; upon roquest, any additional information necessary to confirm the identity of the
+sexual offender, including a set of fingerprints.
+(4)(a) Each time a sexual offender's driver's license or identification card is subject to renowal,
+and, without regard to the status of the offender's driver's license or identification card, within
+48 hours after any change in the offender's permanent or tamporary residence or change in the
+offendar's name by roason of marriage or othor legul process, the offender shall report in
+person to a driver's.license office, and shall be subjoct to the requirements specified in
+subsection (3). The Departmont of Highway Safety and Mator Vehicles shall forward to the
+depertment all photographs and information provided by sexual offenders. Notwithstanding the
+restrictions set forth in s. 322.142, the Department of Highway Safuty and Motor Yohicles is
+authorizod to release a roproduction of a color-photograph or digital-image license to the
+Department of Law Enforcement for purposes of public notification of saxual offenders as
+provided in this section and ss. 943.043 and 944:606.
+(b) A sexual offender who vacates a permanent residence and fails to establish or maintain
+another permanent or temporary residence shall, within 48 hours after vacating the permanent
+residonce, roport in person to the sheriff's office of the county in which he or she is located.
+The sexual offender shall specify the date upon which he or she intends to or did vacate such
+residence. The sexual offender must provide or update all of the registration information
+required under paragraph (2)(b). The sexual offonder must provide an addross for the residence
+or other location that he or she is or will te occupying during the time in which he or she fails
+to establish or maintain a permanent or temporary residence.
+(E) A sexual offendar who remains at a permanent residonce after roporting his or her intent
+to vacate such residence shall, within 48 hours after the date upon which the offender
+indicated he or sho would or did vacate such residence, report in person to the agoncy to which
+he or she reported pursuant to paragraph (b) for the purpose of reporting his or her address at.
+such residence. When the sheriff receives the report, the sheriff shall promptly convey the
+infornation to the department. An offender who makes a report as required undor paragraph
+(b) but fails to make a report as required undar this paragraph commits a felony of the second
+degroo, punishable as provided in s. 775.082, 5. 775.063, or s. 775.0B4.
+(d) A sexual offender must register any electronic mail address or instant message name with
+the departmont prior to using such alectronic mail address or instant message name on or after
+October 1, 2007. The depertment shall establish an online system through which soxual
+offenders may secunely accoss and update all electronic mail address and instant message
+name information.
+(5) This section does not apply to a saxual offonder who is also a sexual predator, as defined in
+s. T75.21. A saxual prodiator must register as required under s. 775.21.
+(6) County and local law enforcement agencies, in conjunction with the department, shall
+verify the addresses of sexual offenders who are not under the care, custady, control, or
+suparvision of the Department of Corrections in a menner that is consistent with the provisions
+of the federal Adam Walsh Child Protection and Safety Act of 2006 and any other federal
+standands applicable to such vorification or required to be mat as a condition for the receipt of
+fedaral funds by the state. Local law enforcoment agencies shall report to the department any
+failure by a sexuni offender to comply with registration requirements.
+
+
+(7) A saxual offender who intands to establish residence in anothor state or juristiction othor
+than the State of Florida shall report in person to the sheriff of the county of current residence
+within 48 hours before the date ho or she intends to loave this state to establish residence in
+another state or jurisdiction. The notification must include the acress, municipality, county,
+and state of intended residence: The sheriff shall promptly provide to the departent the
+information received from the sexual offender. The departmont shall notify the statewide law
+enforcement agoncy, or a comparable apency, in the intended state or jurisdiction of rasidence.
+of the sexual offender's intended residence. The failure of a sexual offender to provide his or
+har intendad place of residence is punishable as provided in subsection (9).
+(8) A sexual offonder who indicates his of hor intent to reside in another state or jurisdiction
+other than the State of Florida and later decides to remain in this state shall, within 48 hours
+aftar the date upon which the saxual offonder indicated he or she would leave this state,
+report in person to the sheriff to which the sexual offonder reported the intended change of
+residence, and report his or her intent to romain in this state. The sheriff shall promptly report
+this information to the dapartment. A saxual offender who reports his or hor intent to reside in
+another state or jurisdiction but who remains in this state without reporting to the sheriff in
+the manner required by this subsection commits a felony of the second dagree, punishable as
+provided in s. 275.082, s. 775.083, or s. 775.084
+(9)(a) A sexual offonder who does nat comply with the requirements of this soction commits a
+folony of the third degroo, punishable as provided in s. 775.082, s. 775.083, or s. 775.064.
+(b) A sexual offender who commits any act or omission in violation of this section may be
+prosecutad for the act or omission in the county in which the act or omission was committed,
+the county of the last registered address of the saxual offender, or the county in which the
+•conviction occurred for-the offonse or offenses that meet the criteria for designating a parson
+"as a sexual offender.
+(c) An arrast on charges of failure to register when the offender has been provided and advised
+of his or her statutory obligations to register uncier subsection (2), the service of an
+information or a complaint for a violation of this section, or an arraignment on charges for à
+violation of this section constitutes actual notice of the duty to register. A sexual offonder's
+failure to immediately register as required by this section following such arrest, service, or
+arraignment constitutes grounds for a subsequent charge of faílure to ragister. A saxual
+offender charged with the crime of fallure to register who asserts, or intends to assert, a lack
+of notico of the duty to register as a defonso to a charge of failure to register shall
+immediately register as required by this saction. A sexual offender who is charged with a
+subsoquent failure to register may not assert the defense of a lack of notice of the duty to
+register.
+(d) Rogistration following such arrest, service, or arraignment is not a dofense and does not
+relievo the soxual offendor of criminal liability for the failure to ragister.
+(10) The departmont, the Department of Highway Safity and Motor Vehicles, the Department
+of Corrections, the Department of Juvanile Justico, any law enforcement agoncy in this stato,
+and the personnel of thoss departments; an electod or appointed official, public employee, or
+school administrator; or an omploype, agency, or any individual or entity acting at the request
+or upon the diraction of any law enforcement agency is immune from civil liabllity for damages
+for food faith compliance with the requirements of this saction or for the release of
+information under this section, and shall be presumed to hava acted in food faith in compiling,
+recording, roporting, or reloasing the information. The presumption of good faith is not
+overcome if a technical or clerical error is made by the department, the Department of
+Highway Safety and Motor Yehicles, the Department of Corrections, the Department of Juvenile
+
+
+Justice, the personnel of those departments, or any individus! or entity acting at the request.
+or upon the direction of any of those dapartments in compiling or providing information, or if
+information is incomplete or incorruct because a saxual offonder falls to report or falsely
+reports his or her current place of permanent or temporary residenco.
+(11) Excopt as provided in s. 943.04354, a saxual offender must maintain registration with the
+dapartmont for the duration of his or her life, unless the sexual offender has rocoivad a full
+pardon or has had a conviction set aside in a postconviction proceeding for any offense that
+moets the critoria for classifying the person as a saxual offender for purposes of registration.
+However, a saxual offendor:
+(a)1. Who has been lawfully released from confinement, supervision, or sanction, whichover is
+later, for at least 25 years and has not been arrestad for arry felony or misdomeanor offenso
+since reloase, provided that the sexual offender's roquirament to register was not based upon
+an adult conviction:
+8. For a violation of s. 787.01 or s. 787.02;
+. b. For a violation of s. 794.011, excluding s. 794.011(10);
+c. For a violation of s. 800.04(4) (b) where the court finds the offense involved a victim under
+12 years of age or sexual activity by the use of force or coarcion;
+d. For a violation of s. 800.04(5) (b);
+. For-a-violation-ofs.-800.04(5)c.2. where the court finds the offense involved unclothed
+genitals or genital aras;
+f. For any attempt or conspiracy to commit any such offense; or
+#. For a violation of similar law of another jurisdiction,
+may petition the criminal division of the circuit court of the circuit in which the saxual
+offender resides for the purpose of ramoving the requirement for registration as a sexual:
+offender.
+2. The court may grant or deny relief if the offender domonstrates to the court that he or she
+has not been arrested for any crime since relasse; the requested relief complies with the
+provisions of the foderal Adam Walsh Child Protection and Safety Act of 2006 and any other
+faderal stanciards, applicable to the removal of registration requirements for a sexual offender
+or required to be met as a condition for the receipt of federal funds by the state; and the court
+is otherwise satisfied that the offender is not a current or potontial threat to public safety. The
+state attornay in the circuit in which the petition is filed must be given notice of the petition
+at last 3 wooks bafore the hearing on the matter. The state attorney may present evidence in
+opposition to the requested relief or may otherwise demonstrate the reasons why the petition
+should be denied, If the court denies the petition, the court may sat a future date at which the
+sexual offender may again petition the court for relief, subjoct to the standards for roliof
+provided in this subsection.
+3. The department shall remove an offender from classification as a sexual offender for
+purposes of registration if the offonder provides to the dapartment a certified copy of the
+court's written findings or order that indicates that the offender is no longer required to
+comply with the requirements for registration as a sexual offender.
+
+
+(b) As defined in sub-subparagraph (1)(a)1.b. must maintain registration with the departmont
+for the duration of his or her life until the person provides the department with an order issued
+by the court that designated the person as a sexual pradator, as a saxually violent predator, or
+by another soxual offendor designation in the stato or jurisdiction in which the order was
+issued which states that such designation has buen removed or demonstrates to the
+departmont that such designation, if not imposed by a court, has boon removed by operation of
+law or court order in the state or jurisdiction in which the designation was macle, and proviced
+: such person no longer maets the criteria for registration as a sexual offender under the laws of
+this stato.
+(12) The Legislature finds that sexual offenders, especially those who have committed offonses
+against minors, often pose a high risk of ongaging in sexual offanses even after being released
+from incarceration or commitment and that protection of the public from sexual offenders is a
+paramount government interest. Sexual offenders have a reduced expectation of privacy
+because of the public's internst in public safety and in the effective operation of governent.
+Roleasing information concerning sexual offenders to law enforcement agencies and to persons
+who request such information, and the release of such information to the public by a law
+enforcement agency or public agency, will further the governmental interests of public safety.
+The designation of a person as a sexual offandor is not a sontance or a punishmont but is simply
+the status of the offender which is the result of a conviction for having cominitted cartain
+crimes.
+(13) Any person who has reason to believo that a sexual offender is not complying, or has not
+complied, with the requirements of this section and who, with the intont to assist the saxual
+offender in eluding a low enforcement agency that is seeking to find the saxual offender to
+question the sexual offender about, or to arrest the sexual offender for, his or her
+noncompliance-with.therequiromonts.of this-sections
+(a) Withholds information from, or does not notify, the law enforcement agency about the
+sexual offender's noncompliance with the requirements of this section, and, if known, the
+wheroabouts of the saxual offender;
+1b) Harbors, or attempts to harbor, or assists another person in harboring or attempting to
+harbor, the saxua! offender; or
+(E) Conceals or attempts to conceal, or assists another person in concosling or attempting to
+concoal, the sexual offender; or
+(d) Provides information to the law enforcement agency regarding the sexual offender that the
+person knows to be false information,
+commits a felony of the third degres, punishable as provided in s. 775.052, s. 775.083, or s..
+775.084.
+(14) (a) A saxual offender must report in porson each yenr during the month of the sexual
+offender's birthday and during the sixth month following the sexual offender's birth month to
+the shoriffs office in the county in which ho or she resides or is otherwise located to rerogister.
+(b) Howavor, a sexual offender who is required to register as a result of a conviction for:
+1. Section 787.01 or 5. 787.02 where the victim is a minor and the offender is not the victim's
+parent or guardian;
+
+
+z. Soction 794.011, excluding s. 794.011(10);
+3. Soction 800:04(4)(b) where the court finds the offense involved a victim under 12 years of
+age of sexual activity by the use of force or coercion;
+4. Soction 800.04(5)(b);
+5. Section 800.04(5)(c)1. whare the court finds molestation involving unciothed genitais or
+gonital area;
+6. Soction 800.04(5)c. 2. where the court finds molestation involving unclothed genitals or
+genital area;
+7. Soction 800. 04(5)(d) where the court finds the use of force or coercion and unclothed
+genitals or genital area;
+B. Any attempt or conspiracy to commit such offense; or.
+9. A violation of a similar law of another jurisdiction,
+must rerogister each your during the month of the sexual offender's birthday and every third
+month thereafter.
+(c) The sheriff's office may determine the appropriate times and days for reporting by the
+sexual offender, which shall be consistent with the reporting requirements of this subsection:
+Roregistration
+include any changes to the following information:
+1. Name; social security number; age; race; sex; date of birth; height; weight; hair and oye
+color; address of any parmanent residence and address of any current temporary residence,
+within the state or out of state, including a rural route address and a post office box; any
+electronic mail address and any instant message name required to be provided pursuant to
+paragraph (4)(d); ciate and place of any employment; vehicle make, model, color, and license
+teg number; fingerprints; and photograph. A post office box shall not be provided in lieu of a
+physical residential address.
+2. If the sexual offender is enrolled, employed, or carrying on a vocation at an institution of
+highar education in this state, the saxual offender shall aiso provide to the department the
+nama, address, and county of oach institution, including each campus attended, and the sexual
+offender's enrollment or employment status.
+3. If the sexual offender's place of residence is a motor vehicle, trailer, mobile home, or
+manufactured home, as defined in chapter 320, the saxual offender shall also provide the
+vehicle identification number; the license tag number; the rogistration number; and a
+description, including color scheme, of the motor vaticle, trailer, mobile home, or
+manufactured home. If the sexual offendor's place of residence is a vessel, live-aboard vessel,
+or houseboat, as tafined in chapter 327, the saxual offendar shall also provide the hull
+identification number; the manufacturer's sarial number; the name of the vassol, live-aboard
+vessel, or houseboat; the registration number; and a description, including color scheme, of
+the vessol, liva-aboard vessel or houseboat.
+4. Any sexual offender who fails to raport in person as required at the sheriffs office, or wis
+fails to respond to any addross verification correspondence from the department within 3
+sooks of the date of the correspondence of who fails to report electronic mail addresses oi
\ No newline at end of file
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@@ -0,0 +1,1339 @@
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 1 of
+
+
+
+Entered on FLSD Docket 01/21/2015 Page 2 of
+Doc 16003
+
+
+Epstein vs. Edwards
+Undisputed Statement of Facts
+
+
+Case 9:08-CV-80736-KAM
+Document 291-15. Entered on FLSD Docket 01/21/2015 Page 3 of
+Doc 1648-3
+
+IN THE CIRCUIT COURT OF THE 15TH
+JUDICIAL CIRCUIT IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+Case No.: 50 2009 CA 040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants,
+Defendant
+STATEMENT OF UNDISPUTED FACTS
+J.
+Esq., offers the following specific facts as the undisputed
+material facts in this case. Each of the following facts is numbered separately and individually to
+facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify
+... any summary judgment evidence on which the adverse party relies.").
+Sexual Abuse of Children By Epstein
+1.
+Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey
+Epstein, Mar, 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment #1).'
+Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous
+' When questioned about this subject at his deposition, Epstein invoked his Fifth Amendment right to remain
+silent rather than make an incriminating admission. Accordingly,
+is entitled to the adverse inference
+against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[lt is well-settled
+that the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to
+testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318
+(1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical
+and utilitarian. A party may not trample upon the rights of others and then escape the consequences by invoking
+a constitutional privilege - at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842
+(Fla. App. 1993).
+
+
+Case 9:08-cv-80736-KAM Document 291-15
+Entered on FLSD Docket 01/21/2015 Page 4 of
+Doc 160003
+
+occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults
+included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times.
+Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex with females under the age
+of 18?" A: [Invocation of the Fifth Amendment]); Deposition of Jane Doe, September 24, 2009 and
+continued March 11, 2010, at 527 (minor girl sexually abused at least 17 times by Epstein) (hereinafter
+"Jane Doe Depo") (Deposition Attachment #2); id. 564-67 (vaginal penetration by Epstein with his
+finger), 568 (vaginal penetration by Epstein with a massager); Deposition of L.M., September 24,
+2009, at 73 (hereinafter "L.M. Depo") (Deposition Attachment #3) (describing the manner in which
+Epstein abused her beginning when LM was 13 years old, touching her vagina with his fingers and
+vibrator) at 74, line 12-13 (she was personally molested by Epstein more than 50 times), at 164, line
+19-23 and 141, line 12-13 and 605, line 3-6 (describing that in addition to being personally molested
+by Epstein she was paid $200 per underage girl she brought Epstein and she brought him more than
+seventy (70) underage girls - she told him that she did not want to bring him any more girls and he
+insisted that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter
+"E.W. Depo") Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse of her
+beginning at age 14 when he paid her for touching her vagina, inserting his fingers and using a vibrator
+and he also paid her $200 for each other underage female E.W. brought him to molest. She brought
+him between 20 and 30 underage females); Deposition of Jane Doe #4, date (hereinafter "Jane Doe #4
+Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes first being taken to Epstein at 15
+years old, "Being fingered by him, having him use a vibrator on [me], grabbing my nipples, smelling
+my butt, jerking off in front of me, licking my clit, several times.").
+2
+
+
+| Document 291-15
+Entered on FLSD Docket 01/21/2015 Page 5 of
+Doc 16403
+
+At all relevant times
+has had a good faith basis to conclude and did conclude?
+that Epstein was able to access a large number of underage girls through a pyramid abuse scheme in
+which he paid underage victims $200-$300 cash for each other underage victim that she brought to
+him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident Report") (Exhibit "A").3 The
+Palm Beach Police Incident Report details Epstein's scheme for molesting underage females. Among
+other things, the Incident Report outlines some of the experiences of other Epstein victims. When S.G,
+a 14 year old minor at the time, was brought to Epstein's home, she was taken upstairs by a woman she
+believed to be Epstein's assistant. The woman started to fix up the room, putting covers on the
+massage table and bringing lotions out. The "assistant" then left the room and told S.G. that Epstein
+would be up in a second. Epstein walked over to S.G. and told her to take her clothes off in a stern
+voice. S.G. states in the report she did not know what to do, as she was the only one there. S.G. took
+off her shirt, leaving her bra on. Epstein, then in a towel told her to take off everything. S.G. removed
+her pants leaving on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave
+Epstein a massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say
+anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted seeing
+Jeffrey Epstein's penis and stated she thought Epstein was on steroids because he was a "really built
+guy and his wee wee was very tiny." Id. at 15.
+The exact number of minor girls who Epstein assaulted is known only to Epstein.
+However,
+had a good faith basis to believe and did in fact believe that Epstein's victims were
+substantially more than forty (40) in number. In addition to the deposition excerpts from two of his
+many victims above about the number of underage girls brought to Epstein and the Palm Beach
+" In support of all assertions concerning the actions
+took, what
+learned in the course of his representatior
+of his clients,
+good faith beliefs and the foundation for those beliefs, see
+Affidavit and specificall
+paragraphs 25 and 25 of that Affidavit.
+For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc., whil
+xhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc
+3
+
+
+| Document 291-15
+Entered on FLSD Docket 01/21/2015 Page 6 of
+Doc 1640-3
+
+incident report, there is overwhelming proof that the number of underage girls molested by Epstein
+through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane
+Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443,
+and 444 (Epstein invoking the 5th on questions about his daily abuse and molestation of children)
+(Deposition Attachment #6).
+5.
+At all relevant times
+has had a good faith basis to believe and did in fact
+believe that Epstein and his attorneys knew of the seriousness of the criminal investigation against him
+and corresponded constantly with the United States Attorney's Office in an attempt to avoid the filing
+of numerous federal felony offenses, which effort was successful. See Correspondence from U.S.
+Attorney's Office to Epstein (hereinafter "U.S. Attorney's Correspondence") (Composite Exhibit "C)
+(provided in discovery during the Jane Doe v. Epstein case).
+6. At all relevant times
+has had a good faith basis to believe and did in fact
+believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for sex
+and also knew that these minors had civil actions that they could bring against him. In fact, there was
+much communication between Epstein's attorneys and the United States Prosecutors in a joint attempt
+to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney
+Villafaña sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with
+regarding handling numerous expected civil claims against
+attached proposed letter to special
+Epstein. The letter reads in pertinent part,
+4
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 7 of
+Doc 1648-3 Filed 04/08/11 Page 6 of 39
+engage in lewd conduct in exchange for money. Based upon the investigation, the
+United States has identified forty (40) young women who can be characterized as
+victims pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's
+home only once, some went there as much as 100 times or more. Some of the
+women's conduct was limited to performing a topless or nude massage while Mr.
+Epstein masturbated himself. For other women, the conduct escalated to full sexual
+intercourse. As part of the resolution of the case, Epstein has agreed that he would
+not contest jurisdiction in the Southern District of Florida for any victim who chose
+to sue him for damages pursuant to 18 USC 2255. Mr. Epstein agreed to provide an
+attorney for victims who elected to proceed exclusively pursuant to that section, and
+agreed to waive any challenge to liability under that section up to an amount agreed
+to by the parties. The parties have agreed to submit the selection of an attorney to a
+Special |
+.."
+7.
+At all relevant times
+has had a good faith basis to believe and did in fact
+believe that L.M. was, in fact, a victim of Epstein's criminal abuse because L.M. was one of the minor
+females that the United States Attorney's Office recognized as a victim. L.M.'s sworn deposition
+testimony and the adverse inference drawn from Epstein's refusal to testify confirm that Epstein began
+sexually assaulting L.M. when she was 13 years old and continued to molest her on more than fifty
+(50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17 ("Q: Did you ... ever engage
+in any sexual conduct with L.M.?" A: [Invocation of the Fifth Amendment].); see also Epstein Depo.,
+April 14, 2010, Attachment #6, at 456 ("Q: LM was an underage female that you first abused when she
+was 13 years old; is that correct?" A: [Invocation of Fifth Amendment].)
+8. Epstein was also given ample opportunity to explain why he engaged in sexual activity
+with L.M. beginning when L.M. was 13 years old and why he has molested minors on an everyday
+basis for years, and he invoked his 5th amendment right rather than provide explanation. See Epstein
+Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7).
+Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so
+on numerous occasions. See E.W. Depo., Attachment #4 at 215-216.
+10.
+Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began
+5
+
+
+Entered on FLSD Docket 01/21/2015 Page 8 of
+Doc 1640-3
+
+when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the 5th amendment
+to questions about him digitally penetrating Doe's vagina, using vibrators on her vagina and
+masturbating and ejaculating in her presence. Epstein Depo., April 14, 2010, Attachment #6, at 420,
+464,468.
+11. When
+clients L.M., E. W., and Jane Doe were 13 or 14 years old, each was
+brought to Epstein's home multiple times by another underage victim. Epstein engaged in one or more
+of the following acts with each of the then-minor girls at his mansion: receiving a topless or
+completely nude massage; using a vibrator on her vagina; masturbating in her presence; ejaculating in
+her presence; touching her breast or buttocks or vagina or the clothes covering her sexual organs; and
+demanding that she bring him other underage girls. Epstein and his co-conspirators used the telephone
+to contact these girls to entice or induce them into going to his mansion for sexual abuse. Epstein also
+made E. W. perform oral sex on him and was to perform sex acts on
+(Epstein's livein sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar
+Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-Cv-80893 (S.D. Fla. 2010), as DE 197,
+(hereinafter "Rule 413 Notice") (Exhibit "F"); Jane Doe Depo., Attachment #2, at 379-380; L.M.
+Depo., Attachment #3, at 416; E.W. Depo, Attachment #4, at 205.
+12. At all relevant times
+has had a good faith basis to believe and did in fact
+believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was
+approximately 15 years old, C.L. was brought to Epstein's home by another underage victim. While a
+minor, she was at Epstein's home on multiple occasions. Epstein engaged in one or more of the
+following acts with her while she was a minor at his house - topless or completely nude massage on
+Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated
+in her presence; Epstein also demanded that she bring him other underage girls. See Rule 413 Notice,
+6
+
+
+• Document 291-15
+Entered on FLSD Docket 01/21/2015 Page 9 of
+Doc 1640-3
+Filed 04/08/11 Page 8 of 39
+Exhibit "E"; Incident Report, Exhibit "A."
+13.
+At all relevant times
+has had a good faith basis to believe and did in fact
+believe that yet another girl Epstein sexually assault was A.H. When she was approximately 16 years
+old, she was brought to Epstein's home by another underage victim. While a minor, she was at
+Epstein's home on multiple occasions. Epstein engaged in one or more of the following acts with her
+while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a
+vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence;
+Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to
+in Epstein's presence.
+perform sex acts on Epstein; made to perform sex acts on
+Epstein also forcibly raped this underage victim, as he held her head down against her will and pumped
+his penis inside her while she was screaming "No". See Rule 413 Notice, Exhibit "E"; Incident Report,
+Exhibit "A", at 41 (specifically discussing the rape):
+*[A.H.] remembered that she climaxed and was removing herself from the massage
+table. [A.H.] asked for a sheet of paper and drew the massage table in the
+and she were. Epstein turned [A.H.] on to her
+stomach on the massage bed and inserted his penis into her vagina. [A.H.] stated
+Epstein began to pump his penis in her vagina. [A.H.] became upset over this. She said
+her head was being held against the bed forcibly, as he continued to pump inside her.
+She screamed no, and Epstein stopped ...."
+"[A.H.] advised there were times that she was so sore when she left Epstein's house.
+[A.H.] advised she was ripped, torn, in her vagina area. [A.H.] advised she had
+difficulty walking to the car after leaving the house because she was so sore."
+Without detailing each fact known about Epstein's abuse of the many underage girls,
+has had a good faith basis to believe and did in fact believe at all relevant times that Epstein
+also abused other victims in ways closely similar to those described in the preceding paragraphs.
+Epstein's additional victims include the following (among many other) young girls: S.G.; A.D.; V.A.;
+N.R.; J.S.; V.Z.; J.A.; F.E.; M.L.; M.D.; D.D.; and D.N. These girls were between the ages of 13 and
+7
+
+
+• Entered on FLSD Docket 01/21/2015 Page 10 of
+Doc 16403
+
+17 when Epstein abused them. See Rule 413 Notice, Exhibit E; Deposition of E.W., Deposition
+Attachment #4.
+15.
+One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous
+underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242-
+44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" and vibrators were found in
+Epstein's bedroom after the purported massages. Id. at 223-28. Rodriguez thought what Epstein was
+doing was wrong, given the extreme youth of the girls he saw. Id. at 230-31.
+16.
+Alfredo Rodriguez took a journal from Epstein's computer that reflected many of the
+names of underage females Epstein abused across the country and the world, including locations such
+as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, France. See Journal
+(hereinafter "The Journal" or "Holy Grail") (Exhibit "F") (identifying, among other Epstein
+acquaintances, females that Rodriguez believes were underage under the heading labeled "Massages").
+17.
+Rodriguez was later charged in a criminal complaint with obstruction of justice in
+connection with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases
+against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 2, U.S.
+v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed
+money because the journal was his "property" and that he was afraid that Jeffrey Epstein would make
+him "disappear" unless he had an "insurance policy" (i.e., the journal). Id. at 3. Because of the
+importance of the information in the journal to the civil cases, Mr. Rodriguez called it "The Holy
+Grail."
+18.
+In the "Holy Grail" or "The Journal," among the many names listed (along with the
+abused girls) are some of the people that Epstein alleges in his Complaint had "no connection
+whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9
+8
+
+
+• Entered on FLSD Docket 01/21/2015 Page 11 of
+Doc 160803 Filed 04/08/11
+
+(Bill Clinton phone numbers listed under "Doug Bands").
+Federal Investigation and Plea Agreement With Epstein
+19. In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern District
+of Florida learned of Epstein's repeated sexual abuse of minor girls. They began a criminal
+investigation into federal offenses related to his crimes. See U.S. Attorney's Correspondence, Exhibit
+"C".
+20.
+At all relevant times
+has had a good faith basis to believe and did in fact
+believe that to avoid the Government learning about his abuse of minor girls, Epstein threatened his
+employees and demanded that they not cooperate with the government. Epstein's aggressive witness
+tampering was so severe that the United States Attorney's Office prepared negotiated plea agreements
+containing these charges.
+For example, in a September 18, 2007, email from AUSA Villafaña to
+Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing
+Epstein's witness tampering as follows:
+"UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER"
+On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards
+traveled to the home of Leslie Groff to serve her with a federal grand jury subpoena
+with an investigation pending in the Southern District of Florida. Ms. Groff works as
+the personal assistant of the defendant. Ms. Groff began speaking with the agents and
+then excused herself to go upstairs to check on her sleeping child. While upstairs, Ms.
+Groff telephoned the defendant, Jeffrey Epstein, and informed him that the FBI agents
+were at her home. Mr. Epstein instructed Ms. Groff not to speak with the agents and
+reprimanded her for allowing them into her home. Mr. Epstein applied pressure to keep
+Ms. Groff from complying with the grand jury subpoenas that the agents had served
+upon her. In particular, Mr. Epstein warned Ms. Groff against turning over documents
+and electronic evidence responsive to the subpoena and pressured her to delay her
+appearance before the grand jury in the Southern District of Florida. This conversation
+occurred when Mr. Epstein was aboard his privately owned civilian aircraft in Miami in
+the Southern District of Florida. His pilot had filed a flight plan showing the parties
+were about to return to Teterboro, NJ. After the conversation with Ms. Groil, Mr.
+Epstein became concerned that the FBI would try to serve his traveling companion,
+with a similar grand jury subpoena. In fact, the agents were
+9
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 12 of
+Doc 160483
+
+preparing to serve
+with a target letter when the flight landed in
+Teterboro. Mr. Epstein then redirected his airplane, making the pilot file a new flight
+plan to travel to the US Virgin Islands instead of the New York City area, thereby
+keeping the Special Agents from serving the target letter on
+1. During
+the flight, the defendant verbally harassed
+1, harassing and pressuring
+her not to cooperate with the grand jury's investigation, thereby hindering and
+dissuading her from reporting the commission of a violation of federal law to a law
+enforcement officer, namely, Special Agents of the FBI. Epstein also threatened and
+harassed_
+against cooperating against him as well.
+learned that the Palm Beach police department investigation ultimately led to
+21.
+
+the execution of a search warrant at Epstein's mansion in October 2005. See Police Incident Report,
+22.
+• learned that at around the same time, the Palm Beach Police Department also
+began investigating Epstein's sexual abuse of minor girls. They also collected evidence of Epstein's
+involvement with minor girls and his obsession with training sex slaves, including pulling information
+from Epstein's trash. Their investigation showed that Epstein ordered from Amazon.com on about
+September 4, 2005, such books as: SM101: A Realistic Introduction, by Jay Wiseman; SlaveCraft:
+Roadmaps for Erotic Servitude - Principles, Skills, and Tools, by Guy Baldwin; and Training with
+Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy. See
+Receipt for Sex Slave Books (Exhibit "T").
+23.
+The Palm Beach incident reports provided
+with the names of numerous
+witnesses that participated in Epstein's child molestation criminal enterprise and also provided
+with some insight into how far-reaching Epstein's power was and how addicted Epstein was
+to sex with children. See Incident Report, Exhibit "A".
+24.
+The Palm Beach Police Department also collected Epstein's message pads, which
+provided other names of people that also knew Epstein's scheme to molest children. See Message
+Pads (Exhibit "") (note: the names of underage females have been redacted to protect the anonymity
+10
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 13 of
+Filed 04/08/11 Page 12 of 39
+of the underage sex abuse victims). Those message pads show clear indication that Epstein's staff was
+frequently working to schedule multiple young girls between the ages of 12 and 16 years old literally
+every day, often two or three times per day. Id.
+25.
+In light of all of the information of numerous crimes committed by Epstein,
+learned that the U.S. Attorney's Office began preparing the filing of federal criminal charges against
+Epstein. For example, in addition to the witness tampering and money laundering charges the U.S.
+Attorney's Office prepared an 82-page prosecution memo and a 53-page indictment of Epstein related
+to his sexual abuse of children. On September 19, 2007, at 12:14 PM, AUSA Villafaña wrote to
+Epstein's counsel, Jay Lefkowitz, "Jay - I hate to have to be firm about this, but we need to wrap this
+up by Monday. I will not miss my indictment date when this has dragged on for several weeks already
+and then, if things fall apart, be left in a less advantageous position than before the negotiations. I have
+had an 82-page pros memo and 53-page indictment sitting on the shelf since May to engage in these
+negotiations.
+There has to be an ending date, and that date is Monday." These and other
+communications are within the correspondence attached as Composite Exhibit "C."
+26.
+learned that rather than face the filing of federal felony criminal charges,
+Epstein (through his attorneys) engaged in plea bargain discussions. As a result of those discussions,
+on September 24, 2007, Epstein signed an agreement with the U.S. Attorney's Office for the Southern
+District of Florida. Under the agreement, Epstein agreed to plead guilty to an indictment pending
+against him in the 15"" Judicial Circuit in and for Palm Beach County charging him with solicitation of
+prostitution and procurement of minors for prostitution. Epstein also agreed that he would receive a
+thirty month sentence, including 18 months of jail time and 12 months of community control. In
+exchange, the U.S. Attorney's Office agreed not to pursue any federal charges against Epstein. See
+Non-Prosecution Agreement (Exhibit "K").
+11
+
+
+Entered on FLSD Docket 01/21/2015 Page 14 ot
+Doc 160303
+
+27. Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in
+which the federal government agreed not to prosecute Epstein's co-conspirators. The co-conspirators
+procured minor females to be molested by Epstein. One of the co-conspirators -
+even participated in the sex acts with minors (including E.W.) and Epstein. See Incident Report,
+Exhibit "A", at 40-42, 49-51; Deposition of
+April 13, 2010, (hereinafter
+Depo.") at 11 (Deposition attachment #9).
+28. Under the Non-Prosecution Agreement, Epstein was to use his "best efforts" to enter
+into his guilty pleas by October 26, 2007. However,
+learned that Epstein violated his
+agreement with the U.S. Attorney's Office to do so and delayed entry of his plea. See Letter from U.S.
+Attorney R. Alexander Acosta to Lilly Ann |
+Dec. 19,2007 (Exhibit "L").
+29. On January 10, 2008 and again on May 30, 2008 E. W. and L.M. received letters from
+the FBI advising them that "[t]his case is currently under investigation. This can be a lengthy process
+and we request your continued patience while we conduct a thorough investigation." Letters attached
+at Composite Exhibit "M". This document is evidence that the FBI did not notify E. W. and L.M. that a
+plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the
+FBI notify E. W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal
+authorities confer with E. W. and L.M. about the plea. See id.
+30.
+In 2008,
+believed in good faith that criminal prosecution of Epstein was
+extremely important to his clients E.W. and L.M. and that they desired to be consulted by the FBI
+and/or other representatives of the federal government about the prosecution of Epstein. The letters
+that they had received around January 10, 2008, suggested that a criminal investigation of Epstein was
+on-going and that they would be contacted before the federal government reached any final resolution
+of that investigation. See id.
+12
+
+
+Entered on FLSD Docket 01/21/2015 Page 15 of
+Doc 160463 Filed 04/08/11
+
+Agrees to Serve as Legal Counsel for Three Victims of Epstein's Sexual Assaults
+Esq., was a licensed attorney in Florida,
+31.
+In about April 2008,
+practicing as a sole practitioner. As a former prosecutor, he was well versed in civil cases that
+involved criminal acts, including sexual assaults. Three of the many girls Epstein had abused - L.M.,
+represent them civilly and secure appropriate
+E. W., and Jane Doe - all requested that
+monetary damages against Epstein for repeated acts of sexual abuse while they were minor girls. Two
+of the girls (L.M. and E.W.) also requested that
+represent them in connection with a concern
+that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office might be arranging a plea
+bargain for the criminal offenses committed by Epstein without providing them the legal rights to
+which they were entitled (including the right to be notified of plea discussions and the right to confer
+with prosecutors about any plea arrangement). See Affidavit of
+(hereinafter "
+Affidavit"') (Exhibit "N").
+Esq. at 91 - 2, 14
+32.
+On June 13, 2008, attorney L
+agreed to represent Jane Doe; and, on July 7, 2008, attorney
+agreed to represent E.W.; on July 2, 2008, attorney
+agreed to represent
+•L.M. in connection with the sexual assaults committed by Epstein and to insure that their rights as
+victims of crimes were protected in the criminal process on-going against Epstein. Mr.
+and
+his three clients executed written retention agreements. See id. at 92.
+33.
+In mid June of 2008,
+contacted AUSA Villafaña to inform her that he
+represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafaña did not advise that a plea agreement
+had already been negotiated with Epstein's attorneys that would block federal prosecution. To the
+contrary, AUSA Villafafia mentioned a possible indictment. AUSA Villafaña did indicate that federal
+investigators had concrete evidence and information that Epstein had sexually molested many
+underage minor females, including E.W., LM, and Jane Doe. See id. at 94.
+13
+
+
+Entered on FLSD Docket 01/21/2015 Page 160
+
+34.
+also requested from the U.S. Attorney's Office the information that they had
+collected regarding Epstein's sexual abuse of his clients. However, the U.S. Attorney's Office,
+It similarly declined to provide any such
+declined to provide any such information to
+information to the other attorneys who represented victims of Epstein's sexual assaults. At the very
+least, this includes the items that were confiscated in the search warrant of Epstein's home, including
+dildos, vibrators, massage table, oils, and additional message pads. See Property Receipt (Exhibit
+"0").
+35.
+On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafaña received a copy
+of Epstein's proposed state plea agreement and learned that the plea was scheduled for 8:30 a.m.,
+Monday, June 30, 2008. AUSA Villafaña called
+to provide notice to his clients regarding the
+hearing. AUSA Villafafia did not tell Attorney
+that the guilty pleas in state court would bring
+an end to the possibility of federal prosecution pursuant to the plea agreement. See
+Affidavit, Exhibit "N", at 16.
+36. Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. § 3771, victims of federal
+crimes - including E.W. and L.M. - are entitled to basic rights during any plea bargaining process,
+including the right to be treated with fairness, the right to confer with prosecutors regarding any plea,
+and the right to be heard regarding any plea. The process that was followed leading to the nonprosecution of Epstein violated these rights of E.W. and L.M. See Emergency Petn. for Victim's
+Enforcement of Crime Victim's Rights, No. 9:08-CV-80736-KAM (S.D. Fla. 2008) (Exhibit "P"').
+37. Because of the violation of the CVRA, on July 7, 2008,
+filed an action in the
+U.S. District Court for the Southern District of Florida, Case No. 9:08-CV-80736, seeking to enforce
+the rights of E. W. and I.M. That action alleged that the U.S. Attorney's Office had failed to provide
+E. W. and L.M. the rights to which they were entitled under the Act, including the right to be notified
+14
+
+
+Entered on FLSD Docket 01/21/2015 Page 17 of
+Doc 164$05
+
+about a plea agreement and to confer with prosecutors regarding it. See id.
+• took E.W. and L.M. with him to the hearing on the CVRA
+38.
+On July 11, 2008,
+action. It was only at this hearing that both victims learned for the first time that the plea deal was
+already done with Epstein and that the criminal case against Epstein had been effectively terminated by
+the U.S. Attorney's office. See Hearing Transcript, July 11, 2008 (Exhibit "Q").
+39.
+learned that Jane Doe felt so strongly that the plea bargain was inappropriate
+that she made her own determination to appear on a television program and exercise her First
+Amendment rights to criticize the unduly lenient plea bargain Epstein received in a criminal case.
+40.
+The CVRA action that
+filed was recently administratively closed and
+filed a Motion to reopen that proceeding. See No. 9:08-CV-80736 (S.D. Fla.).
+Epstein's Entry of Guilty Pleas to Sex Offenses
+41. Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm Beach County,
+Florida, defendant Epstein, entered pleas of "guilty" to various Florida state crimes involving the
+solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution.
+See Plea Colloquy (Exhibit "R").
+42. As a condition of that plea,
+and in exchange for the Federal Government not
+prosecuting the Defendant, Epstein additionally entered into an agreement with the Federal..
+Government acknowledging that approximately thirty-four (34) other young girls could receive
+payments from him under the federal statute providing for compensation to victims of child sexual
+abuse, 18 U.S.C. § 2255. As had been agreed months before, the U.S. Attorney's Office did not
+prosecute Epstein federally for his sexual abuse of these minor girls. See Addendum to Non-
+Prosecution Agreement (Exhibit "S"') (in redacted form to protect the identities of the minors
+involved).
+15
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 18 of
+Doc 160003
+
+43.
+Because Epstein became a convicted sex offender, he was not to have contact with any
+of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge
+Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims.
+She also expressly stated that her no-contact order applied to "all of the victims." Similar orders were
+entered by the federal court handling some of the civil cases against Epstein. The federal court stated
+that it "finds it necessary to state clearly that Defendant is under this court's order not to have direct or
+indirect contact with any plaintiffs ...." Order, Case No. 9:08-cv-80119 (S.D. Fla. 2008), [DE 238] at
+4-5 (emphasis added); see also Order, Case No. 9:08-cv-80893, [DE 193] at 2 (emphasis added).
+Files Civil Suits Against Epstein
+44.
+had a good faith belief that his clients felt angry and betrayed by the criminal
+system and wished to prosecute and punish Epstein for his crimes against them in whatever avenue
+remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad
+filed
+a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See
+Affidavit, "N" at 97. Included in this complaint was a RICO count that explained how Epstein ran a
+criminal conspiracy to procure young girls for him to sexually abuse. See Complaint, Jane Doe v.
+Epstein (Exhibit "T").
+45. On September 11, 2008; at the request of his client E.W., Brad
+filed a civil suit
+against Jeffrey Epstein to recover damages for his sexual assault of E.W. See Complaint, E.W. v.
+Epstein (Exhibit "U"').
+46. On September 11, 2008, at the request of his client L.M.., Brad
+filed a civil suit
+against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, L.M. v.
+Epstein, (Exhibit "V'").
+47. Jane Doe's federal complaint indicated that she sought damages of more than $50,000,000.
+16
+
+
+Entered on FLSD Docket 01/21/2015 Page 19 of
+
+Listing the amount of damages sought in the complaint was in accord with other civil suits that were
+filed against Epstein (before any lawsuit filed by
+See Complaint, Jane Doe #4 v. Epstein
+(Exhibit "W") (filed by Herman and Mermelstein, PA).
+48. At about the same time as
+filed his three lawsuits against Epstein, other civil
+attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another
+law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its
+seven clients who were molested by Epstein. The complaints that attorney Herman filed on behalf of
+his seven clients were similar in tenor and tone to the complaint that
+filed on behalf of his
+three clients. See id.
+49. Over the next year and a half, more than 20 other similar civil actions were filed by various
+attorneys against Epstein alleging sexual assault of minor girls. These complaints were also similar in
+tenor and tone to the complaint that
+filed on behalf of his clients. These complaints are all
+public record and have not been attached, but are available in this Court's files and the files of the U.S.
+District Court for the Southern District of Florida.
+50. In addition to the complaints filed against Epstein in Florida, a female in New York, Ava
+filed a lawsuit against Epstein in New York making similar allegations - that Epstein paid her
+for a massage then forced her to give him oral sex and molested her in other ways when she was only
+16 years old.
+was born a male, and in her complaint she alleges that Epstein told her during
+the "massage", "I love how young you are. You have a tight butt like a baby". See Jeff Epstein Sued
+for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link
+at:
+http://www.nypost.com/p/news/regional/item_44z|WyLUFH7R1OUtKYGPbP:jsessionid=6CA3EBF1
+BEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit "X".
+17
+
+
+• Entered on FLSD Docket 01/21/2015 Page 20 of
+
+51.
+three complaints against Epstein contained less detail about sexual abuse
+than (as one example) a complaint filed by attorney Robert Josephsberg from the law firm of Podhurst
+Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounted in detail in this
+Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to
+Epstein's house. Maxwell and Epstein forced her to have sex with both of them and within weeks
+Maxwell and Epstein were flying her all over the world. According to the Complaint, Jane Doe 102
+was forced to live as one of Epstein's underage sex slaves for years and was forced to have sex with
+not only Maxwell and Epstein but also other politicians, businessmen, royalty, academicians, etc. She
+was even made to watch Epstein have sex with three 12-year-old
+girls that were sent to him for
+his birthday by a
+citizen that is a friend of Epstein's. Luckily, Jane Doe 102 escaped to
+Australia to get away from Epstein and Maxwell's sexual abuse.
+52.
+learned that in addition to civil suits that were filed in court against Epstein, at
+around the same time other attorneys engaged in pre-filing settlement discussions with Epstein. Rather
+than face filed civil suits in these cases, Epstein paid money settlements to more than 15 other women
+who had sexually abused while they were minors. See articles regarding settlements attached hereto as
+Composite Exhibit "Y."
+Epstein's Obstruction of Normal Discovery and Attacks on His Victims
+53.
+Once
+filed his civil complaints for his three clients, he began the normal
+process of discovery for cases such as these. He sent standard discovery requests to Epstein about his
+sexual abuse of the minor girls, including requests for admissions, request for production, and
+interrogatories. See
+Affidavit, Exhibit "N", at 9111-19 and 25.
+Rather than answer any substantive questions about his sexual abuse and his conspiracy for procuring
+minor girls for him to abuse, Epstein invoked his 5th amendment right against self-incrimination. An
+18
+
+
+Entered on FLSD Docket 01/21/2015 Page 21 of
+
+example of Epstein's refusal to answer is attached as Composite Exhibit "Z" (original discovery
+propounded to Epstein and his responses invoking 5th amendment).
+54.
+During the discovery phase of the civil cases filed against Epstein, Epstein's deposition
+was taken at least five times. During all of those depositions, Epstein refused to answer any
+substantive questions about his sexual abuse of minor girls. See, e.g., Deposition Attachments 1, 6 and
+55.
+During these depositions, Epstein further attempted to obstruct legitimate questioning
+by inserting a variety of irrelevant information about his case. As one of innumerable examples, on
+March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you
+rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer
+mostly every question you've asked me here today; however, upon advice of counsel, I cannot answer
+that question. They've advised me I must assert my Sixth Amendment, Fifth Amendment and
+Fourteenth Amendment Rights against self-excuse me, against-under the Constitution. And though
+your partner, Jeffiey Herman, was disbarred after filing this lawsuit [a staterent that was untrue], Mr.
+partner sits in jail for fabricating cases of a sexual nature fleecing unsuspecting Florida
+investors and others out of millions of dollars for cases of a sexual nature with--l'd like to answer your
+questions; however if I--I'm told that if I do so, I risk losing my counsel's representation; therefore I
+must accept their advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10).
+56.
+When
+had the opportunity to take Epstein's deposition, he only asked
+reasonable questions, all of which related to the merits of the cases against Epstein. All depositions of
+Epstein in which Mr.
+participated on behalf of his clients are attached to this motion. See
+Affidavit, Exhibit "N" at 111 and Deposition attachments #1, 6, 7, 10, 11, 12, and 13. Cf.
+with Deposition of Epstein taken by an attorney representing BB (one in which
+was not
+19
+
+
+Entered on FLSD Docket 01/21/2015 Page 22 o
+Doc 160$03
+Filed 04/08/1°
+
+participating),
+http://www.youtube.com/watch?y=V-dqoEyYXx4;
+and
+http://www.youtube.com/watch?v=YCNiYltW-10
+57.
+efforts to obtain information about Epstein's organization for procuring
+young girls was also blocked because Epstein's co-conspirators took the Fifth. Deposition of !
+March 24, 2010 (hereinafter *
+Depo.") (Deposition attachment #14); Deposition of
+April 13, 2010, (Deposition attachment #9); Deposition of.
+March 15, 2010 (hereinafter
+Depo.") (Deposition attachment #15). Each of these coconspirators invoked their respective rights against self-incrimination as to all relevant questions, and
+the depositions have been attached.
+58.
+At all relevant times
+has had a good faith basis to believe and did in fact
+believe
+was an employee of Epstein's and had been identified as a defendant in at least
+one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to be abused.
+At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on all substantive
+questions regarding her role in arranging for minor girls to come to Epstein's mansion to be sexually
+abused. Reinhart had previously been an Assistant United States Attorney in the U.S. Attorney's
+Office for the Southern District of Florida when Epstein was being investigated criminally by
+Reinhart's office. Reinhart left the United States Attorney's Office and was immediately hired by
+Epstein to represent Epstein's pilots and certain co-conspirators during the civil cases against Epstein.
+See!
+Affidavit, Exhibit "N" at 911.
+59.
+also had other lines of legitimate discovery blocked through the efforts of
+Epstein and others. For example,
+learned through deposition that Ghislaine Maxwell was
+involved in managing Epstein's affairs and companies. See deposition of Epstein's house manager
+Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment #16); See
+20
+
+
+Document 291-15. Entered on FLSD Docket 01/21/2015 Page 23 ot
+Doc 160$03
+Page 22 ot 39
+deposition of Epstein's housekeeper
+October 20, 2009, page 9, lines 17-25
+(Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene
+October 6,
+2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7,
+2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince Andrew's Friend, Ghislaine
+Maxwell, Some Underage Girls and A Very Disturbing Story, September 23, 2007 by Wendy Leigh,
+link at http://www.redicecreations.com/article.php?id=18950HANNA
+
+60. Alfredo Rodriguez testified that Maxwell took photos of girls without the girls'
+knowledge, kept the images on her computer, knew the names of the underage girls and their
+respective phone numbers and other underage victims were molested by Epstein and Maxwell together.
+See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236.
+61. In reasonable reliance on this and other information,
+served Maxwell for
+deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented by
+Brett Jaffe of the New York firm of
+and Gresser, and
+understood that her attorney was
+paid for (directly or indirectly) by Epstein. She was reluctant to give her deposition, and
+tried
+to work with her attorney to take her deposition on terms that would be acceptable to both sides. The
+result was the attached confidentiality agreement, under which Maxwell agreed to drop any objections
+to the deposition; attached hereto as Exhibit "CC." Maxwell, however, contrived to avoid the
+deposition. On June 29, 2010, one day before
+was to fly to NY to take Maxwell's deposition,
+her attorney informed
+that Maxwell's mother was deathly ill and Maxwell was consequently
+flying to England with no intention of returning to the United States. Despite that assertion, Ghislaine
+Maxwell was in fact in the country on July 31, 2010, as she attended the wedding of Chelsea Clinton
+(former President Clinton's daughter) and was captured in a photograph taken for OK magazine.
+Photos from Issue 809 of the publication See US Weekly dated August 16, 2010 are attached hereto as
+21
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 24 of
+
+
+Affidavit, Exhibit "N" at 912.
+62. Maxwell is not the only important witness to lie to avoid deposition by
+Upon
+review of the message pads that were taken from Epstein's home in the police trash pulls, see Exhibit
+citizen and one of Epstein's closest pals. He
+"J" supra, many were from Jean Luc Brunel, a
+left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to teach you how to speak
+Russian. She is 2x8 years old, not blonde. Lessons are free and you can have your 1° today if you
+call." See Messages taken from Jean Luc Brunel are attached hereto as Exhibit "EE." In light of these
+circumstances of the case, this message reasonably suggested to
+that Brunel might have been
+procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press
+reports reviewed by
+Brunel is in his sixties and has a reputation throughout the world (and
+especially in the modeling industry) as a cocaine addict that has for years molested children through
+modeling agencies while acting as their agent - conduct that has been the subject of critical reports,
+books, several news articles, and a 60 Minutes documentary on Brunel's sexual exploitation of
+underage models. See http://bradmillershero.blogspot.com/2010/08/women-are-objects.html, attached
+hereto as Exhibit "FF."
+63.
+learned that Brunel is also someone that visited Epstein on approximately 67
+occasions while Epstein was in jail. See Epstein's jail visitor log attached as Exhibit "GG."
+64.
+learned that Brunel currently runs the modeling agency MC2, a company for
+which Epstein provides financial support. See Message Pad's attached as Exhibit "J" supra and Sworn
+Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez Sworn Statement"
+attached at Exhibit "HH" at 1-16.
+65. Employees of MC2 told |
+in New York were used to house young models.
+that Epstein's numerous condos at 301 East 66 Street
+was told that MC2 modeling agency,
+
+
+• Entered on FLSD Docket 01/21/2015 Page 25 of
+
+affiliated with Epstein and Brunel brought underage girls from all over the world, promising them
+modeling contracts. Epstein and Brunel would then obtain a visa for these girls, then would charge the
+underage girls rent, presumably to live as underage prostitutes in the condos. See Maritza Vasquez
+Sworn Statement, Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59-60 and 62-67.
+66.
+In view of this information suggesting Brunel could provide significant evidence of
+had Brunel served in New York for
+Epstein's trafficking in young girls for sexual abuse,
+deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "II." Before the
+deposition took place, Brunel's attorney (Tama Kudman of West Palm Beach) contacted
+to
+delay the deposition date. Eventually Kudman informed
+in January 2009 that Brunel had left
+the country and was back in France with no plans to return. This information was untrue; Brunel was
+actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment
+#16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel
+(JLB) staying at his house during that relevant period of time attached Exhibit "JJ". As a result,
+filed a Motion for Contempt, attached hereto as Exhibit "KK" (Because Epstein settled this
+case, the motion was never ruled upon.)
+67.
+was also informed that Epstein paid for not only Brunel's representation
+during the civil process but also paid for legal representation for
+(Epstein's executive
+assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers
+(Epstein's personal pilot), Larry
+(Epstein's personal pilot),
+(Epstein's
+housekeeper),
+(Epstein's live-in sex slave), Ghislaine Maxwell (manager of
+Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's
+house manager) It was nearly impossible to take a deposition of someone that would have helpful
+information that was not represented by an attorney paid for by Epstein. See
+Affidavit,
+23
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 26 of
+Doc 160403 Filed 04/08/11
+
+
+68. While Epstein and others were preventing any legitimate discovery into his sexual
+abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal questioning of
+the girls who had filed civil suits against him, questioning so savage that it made local headlines. See
+Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts Used Against Them, Palm
+Beach Post News, Jan. 23, 2010, available at http://www.palmbeachpost.com/news/crime/victimsseeking-sex-offenders-millions-see-painful-pasts-192988.html attached hereto as Exhibit "LL."
+Pursues Other Lines of Discovery
+69. Because of Epstein's thwarting of discovery and attacks on
+clients,
+was forced to pursue other avenues of discovery.
+only pursued legitimate discovery
+designed to further the cases filed against Epstein. See
+Affidavit, Exhibit "N" at 911.
+70.
+notified Epstein's attorneys of his intent to take Bill Clinton's deposition.
+possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine Maxwell
+who was Epstein's longtime companion and helped to run Epstein's companies, kept images of naked
+underage children on her computer, helped to recruit underage children for Epstein, engaged in lesbian
+sex with underage females that she procured for Epstein, and photographed underage females in
+sexually explicit poses and kept child pornography on her computer; (b) it was national news when
+Clinton traveled with Epstein aboard Epstein's private plane to Africa and the news articles classified
+Clinton as Epstein's friend. (c) the complaint filed on behalf of Jane Doe No. 102 stated generally that
+she was required by Epstein to be sexually exploited by not only Epstein but also Epstein's "adult male
+peers, including royalty, politicians, academicians,
+businessmen, and/or other professional and
+personal acquaintances" - categories Clinton and acquaintances of Clinton fall into. The flight logs
+showed Clinton traveling on Epstein's plane on numerous occasions between 2002 and 2005. See
+24
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 27 of
+Doc 160363
+
+Flight logs attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine
+Maxwell,
+and
+- all employees and/or co-conspirators of Epstein's
+that were closely connected to Epstein's child exploitation and sexual abuse. The documents clearly
+show that Clinton frequently flew with Epstein aboard his plane, then suddenly stopped - raising the
+suspicion that the friendship abruptly ended, perhaps because of events related to Epstein's sexual
+abuse of children. Epstein's personal phone directory from his computer contains e-mail addresses for
+Clinton along with 21 phone numbers for him, including those for his assistant (Doug Band), his
+schedulers, and what appear to be Clinton's personal numbers. This information certainly leads one to
+believe that Clinton might well be a source of relevant information and efforts to obtain discovery from
+him were reasonably calculated to lead to admissible evidence. See Exhibits "B", "F" "AA", "DD",
+and "MM" and
+71.
+J.
+Donald Trump.
+Affidavit, Exhibit "N" at 115.
+Esq., provided notice that he intended to take the deposition of
+possessed a legitimate basis for doing so: (a) The message pads confiscated
+from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several
+clients' complaints; (b) Trump was
+occasions during the time period most relevant to my
+quoted in a Vanity Fair article about Epstein as saying "I've known Jeff for fifteen years. Terrific guy,"
+"He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of
+them are on the younger side. No doubt about it - Jeffrey enjoys his social life." Jeffrey Epstein:
+International Moneyman of Mystery; He's pals with a passel of Nobel Prize-winning scientists, CEOs
+like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald. Trump. But it wasn't
+until he flew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa on his private Boeing 727 that the
+Jr. (See article attached hereto as Exhibit "NN")
+world began to wonder who he is. By Landon
+(c) Trump allegedly banned Epstein from his Maralago Club in West Palm Beach because Epstein
+25
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 28 of
+
+sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe
+102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell
+and Epstein's underage sex slave; (e) Mark Epstein (Jeffrey Epstein's brother) testified that Trump
+flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have
+sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach; (g) Epstein's phone
+directory from his computer contains 14 phone numbers for Donald Trump, including emergency
+numbers, car numbers, and numbers to Trump's security guard and houseman. Based on this
+information,
+reasonably believed that Trump might have relevant information to provide in
+the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. See
+deposition of Mark Epstein, September 21, 2009, at 48-50 (Deposition Attachment #19); See Jane Doe
+102 v. Epstein, Exhibit "B"; Exhibit "F", "Exhibit"J", "N" and See
+Affidavit, Exhibit "N" at
+913.
+72.
+provided notice that he intended to depose Alan Dershowitz.
+possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstein
+for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th book... The only
+person outside of my immediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By
+Vicky
+on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit "OO*);
+(c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epstein's house during
+the years when Epstein was assaulting minor females on a daily basis; (d) Rodriguez testified that
+Dershowitz was at Epstein's house at times when underage females where there being molested by
+Epstein (see Alfredo Rodriguez deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly
+assisted in attempting to persuade the Palm Beach State Attorney's Office that because the underage
+females alleged to have been victims of Epstein's abuse lacked credibility and could not be believed
+26
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 29 of
+
+that they were at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the
+house; (f) Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not
+only Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians,
+businessmen, and/or other professional and personal acquaintances" — categories that Dershowitz and
+acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was on
+Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot and
+information (described above) suggested that sexual assaults may have taken place on the plane; (h)
+Epstein donated $30 Million one year to the university at which Dershowitz teaches. Based on this
+information,
+had a reasonable basis to believe that Dershowitz might have relevant
+information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a
+possible deposition.
+See Dershowitz letters to the State Attorney's office attached as Exhibit "PP";
+Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit "MM"; Exhibits "B" and "OO"; and
+Affidavit, Exhibit "N" at |14.
+73.
+Epstein's complaint alleges that
+• provided notice that he wished to take the
+deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law
+firm of Searcy Denny Scarola Barnhart and Shipley. See
+Affidavit, Exhibit "N" at 416.
+74.
+gave notice that he intended to take David Copperfield's deposition.
+possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only witnesses who
+did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez, testified that David
+Copperfield was a guest at Epstein's house on several occasions. His name also appears frequently in
+the message pads confiscated from Epstein's house. It has been publicly reported that Copperfield
+himself has had allegations of sexual misconduct made against him by woren claiming he sexually
+abused them, and one of Epstein's sexual assault victims also alleged that Copperfield had touched her
+27
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 30 of
+
+in an improper sexual way while she was at Epstein's house. Mr. Copperfield likely has relevant
+information and deposition was reasonably calculated to lead to the discovery of admissible evidence.
+See
+| Affidavit, Exhibit "N" at 917.
+75.
+Epstein also takes issue with
+identifying Bill
+as a possible witness.
+was properly identified as a possible witness because Epstein's personal pilot testified to
+joining Epstein at Epstein's New Mexico Ranch. There was information indicating that
+Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable
+inference he was sexually abusing these girls as he had abused girls in West Palm Beach and
+elsewhere.
+had also returned campaign donations that were given to him by Epstein,
+indicating that he believed that there was something about Epstein with which he did not want to be
+associated.
+was not called to testify nor was he ever subpoenaed to testify. See
+Affidavit, Exhibit "N" at 918.
+76.
+learned of allegations that Epstein engaged in sexual abuse of minors on his
+private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly,
+pursued discovery
+to confirm these allegations.
+77. Discovery of the pilot and flight logs was proper in the cases brought by
+against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim through
+much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that
+involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at
+clients intended to pursue an
+some point in the federal litigation, the legal team representing
+appeal of that dismissal. Moreover, all of the subjects mentioned in the RICO claim remained relevant
+to other aspects of Jane Doe's claims against Epstein, including in particular her claim for punitive
+damages. See
+Affidavit, Exhibit "N" at 919.
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 31 of
+Doc 160463 Filed 04/08/11
+
+78.
+Discovery of the pilot and flight logs was also proper in the cases brought by
+against Epstein because of the need to obtain evidence of a federal nexus.
+client Jane
+Doe was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255 is a federal
+statute which (unlike relevant state statutes) established a minimum level of recovery for victims of the
+violation of its provisions. Proceeding under the statute, however, required a "federal nexus" to the
+sexual assaults. Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by
+Epstein: first, his use of telephone to arrange for girls to be abused; and, second, his travel on planes in
+anticipated that Epstein would argue
+interstate commerce. During the course of the litigation,
+that Jane Doe's proof of the federal nexus was inadequate. These fears were realized when Epstein
+filed a summary judgment motion raising this argument. In response, the other attorneys and
+representing Jane Doe used the flight log evidence to respond to Epstein's summary judgment motion,
+explaining that the flight logs demonstrated that Epstein had traveled in interstate commerce for the
+purpose of facilitating his sexual assaults. Because Epstein chose to settle the case before trial, Judge
+Marra did not rule on the summary judgment motion.
+79.
+had further reason to believe and did in fact believe that the pilot and flight
+logs might contain relevant evidence for the cases against Epstein. Jane Doe No. 102's complaint
+outlined Epstein's daily sexual exploitation and abuse of underage minors as young as 12 years old and
+alleged that Epstein's plane was used to transport underage females to be sexually abused by him and
+his friends. The flight logs accordingly were a potential source of information about either additional
+girls who were victims of Epstein's abuse or friends of Epstein who may have witnessed of even
+participated in the abuse. Based on this information,
+reasonably pursued the flight logs in
+discovery.
+80.
+In the fall of 2009, Epstein gave a recorded interview to
+Rush, a reporter with
+29
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 32 of
+
+the New York Daily News about pending legal proceedings. In that interview, Epstein demonstrated an
+utter lack of remorse for his crimes (but indirectly admitted his crimes) by stating:
+• People do not like it when people make good and that was one reason he (Epstein) was
+being targeted by civil suits filed by young girls in Florida;
+• He (Epstein) had done nothing wrong;
+• He (Epstein) had gone to jail in Florida for soliciting prostitution for no reason;
+• If the same thing (i.e., sexual abuse of minor girls) had happened in New York, he
+(Epstein) would have received only a $200 fine;
+•
+J.
+was the one causing all of Epstein's problems (i.e., the civil suits
+brought by Jane Doe and other girls);
+• L.M. came to him as a prostitute and a drug user (i.e., came to Epstein for sex, rather
+than Epstein pursuing her);
+• All the girls suing him are only trying to get a meal ticket;
+• The only thing he might have done wrong was to maybe cross the line a little too
+closely;
+• He (Epstein) was very upset that
+had subpoenaed Ghisline Maxwell, that she
+was a good person that did nothing wrong (i.e., had done nothing wrong even though
+she helped procure young girls to satisfy Epstein's sexual desires);
+With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein had
+repeatedly sexually abused a 15-year-old girl, forced her to have sex with his friends,
+and flew her on his private plane nationally and internationally for the purposes of
+sexually molesting and abusing her, he (Epstein) flippantly said that the case was
+dismissed, indicating that the allegations wére ridiculous and untrue.
+See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ."
+81. The Rush interview also demonstrated perjury (a federal crime) on the part of Epstein.
+Epstein lied about not knowing
+Rush. See Epstein Deposition, February 17, 2010, taken in
+L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 line 9, (Deposition
+attachment #7), wherein Jeffrey Epstein clearly impresses that he does not recognize
+Rush
+from the New York Daily News. This impression was given despite the fact that he gave a lengthy
+30
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 33 of
+Case 09-34791-RBR Doc 160368 Filed 04/08/11
+
+personal interview about details of the case that was tape recorded with
+: Rush.
+Epstein's Harassment of Witnesses Against Him
+82. At all relevant times
+has a good faith basis to believe and did in fact believe
+that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82, U.S.
+Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government against Epstein;
+and || | Affidavit, Exhibit "N" at 911.
+83.
+Despite three no contact orders entered against Epstein (see Exhibit C, supra),
+learned that Epstein continued to harass his victims. For example, Jane Doe had a trial set for her civil
+case against him on July 19, 2010. As that trial date approached, defendant Epstein intimidated her in
+violation of the judicial no-contact orders. On July 1, 2010, he had a "private investigator" tail Jane
+Doe - following her every move, stopping when she stopped, driving when she drove, refusing to pass
+when she pulled over. When Jane Doe ultimately drove to her home, the "private investigator" then
+parked in his car approximately 25 feet from Jane Doe house and flashed his high beam lights
+intermittently into the home. Even more threateningly, at about 10:30 p.m., when Jane Doe fled her
+home in the company of a retired police officer employed by Jane Doe's counsel, the "private
+investigator" attempted to follow Jane Doe despite a request not to do so. The retired officer
+successfully took evasive action and placed Jane Doe in a secure, undisclosed location that night.
+Other harassing actions against Jane Doe also followed. See Motion for Contempt filed by l
+in
+Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite
+
+Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children
+84.
+The civil cases
+filed against Epstein on behalf of L.M., E.W., and Jane Doe
+were reasonably perceived by
+|I to be very strong cases. Because Epstein had sexually
+31
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 34 of
+• Doc 16036B Filed 04/08/11 Page 33 of 39
+assaulted these girls, he had committed several serious torts against them and would be liable to them
+for appropriate damages. See Preceding Undisputed Facts. Because of the outrageousness of Epstein's
+sexual abuse of minor girls,
+reasonably expected that Epstein would also be liable for
+punitive damages to the girls. Because
+could show that Epstein had molested children for
+years and designed a complex premeditated scheme to procure different minors everyday to satisfy his
+addiction to sex with minors, the punitive damages would have to be sufficient to deter him from this
+illegal conduct that he had engaged in daily for years. Epstein was and is a billionaire. See Complaint,
+949 (referring to "Palm Beach Billionaire"); see also Epstein Deposition, February 17, 2010, at 172-
+176 (Deposition Attachment #7) (taking the Fifth when asked whether he is a billionaire).
+reasonably believed the punitive damages that would have to be awarded
+Accordingly,
+against Epstein would have been substantial enough to punish him severely enough for his past
+conduct as well as deter him from repeating his offenses in the future. See
+Affidavit, Exhibit
+"N" at 919.
+85. On July 6, 2010, rather than face trial for the civil suits that had been filed against him
+by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of the
+settlement are confidential. The settlement amounts are highly probative in the instant action as
+Epstein bases his claims that
+was involved in the Ponzi scheme on Epstein's inability to settle
+the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to settle the claims
+for "minimal value" after the Ponzi scheme was uncovered would be highly probative in discrediting
+any causal relationship between the Ponzi scheme and
+settlement negotiations. Seel
+Affidavit, Exhibit "N" at 921.
+HH Non-Involvement in Fraud by Scott Rothstein
+86.
+From in or about 2005, through in or about November 2009, Scott Rothstein appears to
+32
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 35 of
+Doc 160468
+
+have run a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler P.A. ("RRA"). This
+Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been
+reached with putative defendants based upon claims of sexual harassment and/or whistle-blower
+actions. Rothstein falsely informed the investors that the potential settlement agreements were
+available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-
+COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit "SS."
+87. It has been alleged that among other cases that Rothstein used to lure investors into his
+Ponzi scheme were the cases against Epstein that were being handled by
+I J.H
+s had no knowledge of the fraud or any such use of the Epstein cases. See
+i, Esq.
+: Affidavit,
+
+88.
+J.L
+2009 - a period of less than one year. L
+Scott Rothstein was running a giant Ponzi scheme at the firm.
+. Esq., joined RRA in about April 2009 and left RRA in November
+would not have joined RRA had he been aware that
+left RRA shortly after learning
+of Rothstein's fraudulent scheme. Id. at 18.
+89. At no time prior to the public disclosure of Rothstein's Ponzi scheme did
+know or have reason to believe that Rothstein was using legitimate claims that
+was
+prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id. at 920.
+90.
+never substantively discussed the merits of any of his three cases against
+J.
+taken March 23, 2010, at 110-16.
+Epstein with Rothstein. See Deposition of l
+(hereinafter "
+Depo") (Deposition Attachment #22).
+91.
+On July 20, 2010,
+received a letter from the U.S. Attorney's Office for
+the Southern District of Florida - the office responsible for prosecuting Rothstein's Ponzi scheme. The
+letter indicated that law enforcement agencies had determined that I
+was "a victim (or potential
+33
+
+
+Entered on FLSD Docket 01/21/2015 Page 36 of
+Doc 16046B
+
+victim)" of Scott Rothstein's federal crimes. The letter informed
+a of his rights as a victim of
+Rothstein's fraud and promised to keep l
+Rothstein's prosecution. See Letter attached hereto as Exhibit "TT."
+informed about subsequent developments in
+92.
+Jeffrey Epstein filed a complaint with the Florida Bar against
+5, Esq.,
+raising allegations that
+s and others were involved in the wrongdoing of Scott Rothstein. After
+investigating the claim, the Florida Bar dismissed this complaint. See
+Affidavit, Exhibit "N"
+at 123.
+Epstein Takes the Fifth When Asked Substantive Questions About His Claims Against
+93. On March 17, 2010, defendant Epstein was deposed about his lawsuit against
+Rather than answer substantive questions about his lawsuit, Epstein repeatedly invoked his Fifth
+Amendment privilege. See Epstein Depo. taken 3/17/10, Deposition Attachment #1.
+94. In his deposition, Epstein took the Fifth rather than answer the question: "Specifically
+what are the allegations against you which you contend Mr.
+ginned up?" Id. at 34.
+95. In his deposition, Epstein took the Fifth rather than name people in California that
+had tried to depose to increase the settlement value of the civil suit he was handling. Id. at
+37.
+96. In his deposition, Epstein took the Fifth rather than answer the question: "Do you know
+former President Clinton personally." Id.
+97.
+In his deposition, Epstein took the Fifth rather than answer the question: "Are you now
+telling us that there were claims against you that were fabricated by Mr. " Id. at 39.
+98.
+of Mr.L
+In his deposition, Epstein took the Fifth rather than answer the question, "Well, which
+" cases do you contend were fabricated." Id.
+99.
+In his deposition, Epstein took the Fifth rather than answer the question: "What is the
+34
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 37 of
+Case 09-34791-RBR Doc 16080
+
+actual value that you contend the claim of E. W. against you has?" Id. at 45.
+100. In his deposition, Epstein took the Fifth rather than answer a question about the actual
+value of the claim of L.M. and Jane Doe against him. Id.
+101. In his deposition, taken prior to the settlement of
+clients claims against
+Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim against you
+which you contend is fabricated?" Id. at 71.
+102. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever
+have damaging evidence in your garbage?" Id. at 74.
+103. In his deposition, Epstein took the Fifth rather than answer the question: "Did sexual
+assaults ever take place on a private airplane on which you were a passenger?" Id. at 88.
+104. In his deposition, Epstein took the Fifth rather than answer the question: "Does a flight
+log kept for a private jet used by you contain the names of celebrities, dignitaries or international
+figures?" Id. at 89.
+105. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever socialized with Donald Trump in the presence of females under the age of 187" Id. at 89.
+106. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id. at 90.
+107. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91-92.
+108. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever
+socialize with David Copperfield in the presence of females under the age of 187" Id. at
+109. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever socialized with Mr.
+[Governor of New Mexico and formerly U.S. Representative and
+35
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 38 of
+Case 09-34791-RBR Doc 16086B Filed 04/08/11 Page 37 of 39
+Ambassador to the United Nations] in the presence of females under the age of 18." Id. at 94.
+110. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever sexually abused children?" Id. at 95.
+111. In his deposition, Epstein took the Fifth rather than answer the question: *Did you have
+staff members that assisted you in scheduling appointments with underage females; that is, females
+under the age of 18." Id. at 97-98.
+112. In his deposition, Epstein took the Fifth rather than answer the question: "On how many
+occasions did you solicit prostitution." Id. at 102.
+113.
+In his deposition, Epstein took the Fifth rather than answer the question: "How many
+minors have you procured for prostitution?" Id. at 104.
+114. In his deposition, Epstein took the Fifth rather than answer the question: "Have you
+ever coerced, induced or enticed any minot to engage in any sexual act with you?" Id. at 107.
+115. In his deposition, Epstein took the Fifth rather than answer the question: "How many
+times have you engaged in fondling underage females?" Id. at 108.
+116. In his deposition, Epstein took the Fifth rather than answer the question: "How many
+times have you engaged in oral sex with females under the age of 187" Id. at 110.
+117. In his deposition, Epstein took the Fifth rather than answer the question: "Do you have a
+personal sexual preference for children?" Id. at 111-12.
+118.
+In his deposition, Epstein took the Fifth rather than answer the question: "Your
+Complaint at page 27, paragraph 49, says that 'RRA and the litigation team took an emotionally driven
+set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach billionaire,
+and sought to turn it into a goldmine, end of quote. Who is the Palm Beach billionaire referred to in
+that sentence?" Id. at 112-13.
+36
+
+
+Document 291-15 Entered on FLSD Docket 01/21/2015 Page 39 of
+Case 09-34791-RBR Doc 160313
+
+119. In his deposition, Epstein took the Fifth rather than answer the question: "Who are the
+people who are authorized to make payment [to your lawyers] on your behalf?" Id. at 120.
+120. In his deposition, Epstein took the Fifth rather than answer the question: "Is there
+anything in L.M.'s Complaint that was filed against you in September of 2008 which you contend to
+be false?" Id. at 128.
+CERTIFICATE OF SERVICE
+I HEREBY CERTIRY that on September 22%, 2010 a copy of the foregoing has been served
+via U.S. Mail and email transmittal to all those on the attached service list.
+Jack Scarola
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+By:
+37
+
+
+Case 9:08-cv-80736-KAM Document 291-15 Entered on FLSD Docket 01/21/2015 Page 40 of
+Case 09-34791-RBR Doc 160303
+
+SERVICE LIST
+E. Knight, Esq.
+L. Ackerman, Esq.
+BURNETT P.A.
+901
+Point West
+777 South Flagler Drive
+West Palm Beach, FL 33401
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger et al.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401
+Marc S. Nurik, Esq.
+Law Offices of Marc S. Nurik
+One E. Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Gary M.
+, Jr.
+Farmer, Jafte, Weissing,
+_ Fistos & Lehrman, P.L.
+425 N. Andrews Ave., Suite 2
+Fort Lauderdale, FL 33301
+38
\ No newline at end of file
diff --git a/vision-fixhub/court-02/08dc602295f8d8ad84b1ee80b5e66159b8222d9b3d84f6e1988f40a4bf9bead4.receipt.json b/vision-fixhub/court-02/08dc602295f8d8ad84b1ee80b5e66159b8222d9b3d84f6e1988f40a4bf9bead4.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..5d0319be69e564514af83e711ea97e5e83377402
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+++ b/vision-fixhub/court-02/08dc602295f8d8ad84b1ee80b5e66159b8222d9b3d84f6e1988f40a4bf9bead4.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 86,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.dehyphenation.join-soft-wraps\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.md b/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.md
new file mode 100644
index 0000000000000000000000000000000000000000..0219b624accc0408cf53a6a16a83790bcb804748
--- /dev/null
+++ b/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.md
@@ -0,0 +1,1642 @@
+Filing # 76326706 E-Filed 08/13/2018 10:27:57 AM
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually, and.
+individually,
+Defendants/Counter-Plaintiff.
+COPY
+COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO UNSEAL
+DISC AND PROPOSED TRIAL EXHIBITS FOR USE AT
+BANKRUPTCY COURT SHOW CAUSE PROCEEDINGS AND DEPOSITIONS
+Counter-Defendant Jeffrey Epstein ("Epstein") moves to unseal the disc labeled "Epstein
+Bate Stamp" and the 47 documents identified on Epstein's March 5, 2018, Clerk's Trial Exhibit
+List that Counter-Plaintiff
+J/ Edwards (*
+) claims are privileged for the limited
+purpose of the Bankruptcy Court's show cause proceedings and depositions, and in support
+thereof, states:
+INTRODUCTION
+Edwards, along with
+Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively,
+the "Bankruptcy Movants") have moved the Bankruptcy Court for an Order to show cause why a
+November 2010 Agreed Order' has not been violated and for sanctions. The subject of those
+'November 30, 2010, Agreed Order Cancelling Hearing on Motion for Relief from the
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 08/13/2018 10:27:57 AM
+
+
+proceedings is a disc labeled "Epstein Bate Stamp" that
+had in its files and turned
+over in February 2018 to Epstein's current trial counsel, Link & Rockenbach. The Bankruptcy
+Movants claim that
+retention of the disc is a violation of the November 2010
+Agreed Order and they seek sanctions against
+and Epstein for that retention. A show
+cause hearing is currently scheduled before the Bankruptcy Court on August 23 and 24, 2018,
+however,
+has moved to continue it to September 2018.
+The Bankruptcy Court has allowed limited depositions of Epstein and representatives of
+Link & Rockenbach and
+Those depositions are currently set on August 17, 20 and
+21, 2018, respectively. This Court also allowed the deposition of Epstein on an additional limited
+basis, which is set on August 17, 2018.
+Because the dise itself and the 47 exhibits Edwards claims are privileged have been sealed
+by this Court, Epstein respectfully moves to unseal those documents for the limited purpose of the
+Bankruptcy Court's show cause proceedings and the upcoming depositions.
+BACKGROUND
+During the March 8, 2018, hearing, the Court instructed Epstein to file under seal Link &
+Rockenbach's copy of the disc and exhibits identified on Epstein's March 5, 2018, Clerk's Trial
+Exhibit List which Edwards claimed were privileged. The exhibits were filed under seal to protect
+Epstein's appellate rights.
+The sealing was accomplished by the Court's April 6, 2018, Agreed
+Order Directing Clerk to Seal Filings.? (Exhibit A.)
+As outlined in Epstein's Notices of Compliance with the Court's March 8, 2018, rulings,
+(Composite Exhibit B) Link & Rockenbach maintains in a sealed box in its offices: (1) the
+unredacted Appendix served in support of Epstein's Response in Opposition to
+Second
+*There was some delay in the sealing because the case was stayed pending appeal.
+2
+
+
+Supplement to Motion in Limine Addressing Scope of Admissible Evidence; and (2) a set of the
+e-mail exhibits Epstein's counsel printed from the dise and identified on Epstein's March 5, 2018
+Clerk's Trial Exhibit List which
+claims were late disclosed and/or identified on his 2011
+privilege log. In addition, Link & Rockenbach has maintained in a sealed envelope with
+original boxes the original dise that was located in |
+files.
+ARGUMENT
+The Bankruptcy Court's Show Cause hearing is an evidentiary hearing and the parties are
+required to submit exhibits to the Bankruptcy Court two days in advance of the hearing. The disc
+located in
+records and the 47 exhibits Epstein identified which were obtained from
+the disc and
+claims are privileged, are the central focus of the hearing. Similarly, the
+witnesses' testimony will be based on the disc and 47 exhibits.
+Epstein asks the Court to allow his counsel to unseal the box and envelope maintained in
+Link & Rockenbach's offices for use solely during the Bankruptcy Court ordered depositions when
+counsel is present. The box and envelope will then be resealed at the conclusion of each
+deposition. Epstein further requests that he be allowed to provide the Bankruptcy Court two days
+in advance of the show cause hearing with copies of the disc and 47 exhibits and that his counsel
+be allowed to unseal the box and envelope for the duration of the show cause evidentiary hearing.
+CONCLUSION
+Accordingly, Epstein seeks permission from the Court to allow his counsel, Link &
+Rockenbach, to unseal the box and envelope maintained in its offices for use as evidence at the
+Bankruptcy Court's show cause proceedings and as exhibits at the upcoming depositions as
+outlined above.
+"The exhibits include both the 47 exhibits
+claims are privileged and other documents
+printed from the disc but which were earlier produced in the case.
+3
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on August 13, 2018, through the Court's e-filing portal pursuant to Florida Rule
+of Judicial Administration 2.516(b)(1).
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@scarcylaw.com
+jsx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J. Edwards
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 930
+West Palm Beach, Florida 33401
+(561) 847-4408; (561) 855-2891 [fax],
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+SERVICE LIST
+Philip M. Burlington
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+pmb@FLAppellatcLaw.com
+njs(@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+4
+
+
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney(@agwpa.com
+Co-Counsel for Plaintif/Counter-Defendant
+Jeffrey Epstein
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.cdu
+Limited Intervenor Co-Counsel for L.M., E.W.
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+Limited Intervenor Co-Counsel for L.M., E.W.
+NOT A
+
+Cop
+5
+
+
+COPY
+
+NOT A CERTIF
+
+
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants/Counter-Plaintiff.
+COPY
+AGREED ORDER DIRECTING CLERK TO SEAL FILINGS
+THIS MATTER,
+coming before the Court upon Plaintiff/Counter-Defendant Jeffrey
+Epstein's ("Epstein") Motion to Make Court Records Confidential. The Court, pursuant to its
+ruling at the March 8, 2018, hearing, and being advised of the agreement of the parties, it is hereby
+ORDERED AND ADJUDGED that the Motion is GRANTED.
+The following information is provided pursuant to Florida Rule of Judicial Administration
+2.420(e)(3) and 1' Judicial. Circuit Administrative Order 2.303-3/18:
+(A)
+Type of Case: Civil.
+Grounds under subdivision (c) for determining the information confidential: The
+(B)
+Court deems the items to be filed under seal confidential pursuant to Florida Rule of Judicial
+Administration 2.420(c)(9) because Defendant/Counter-Plaintiff
+and Intervenors L.M., E.W. and Jane Doe ("Intervenors") have asserted a claim of privilege over.
+the documents.
+
+
+Agreed Order Directing Clerk to Seal Filings
+Page 2
+(C)
+Whether any party's name is determined to be confidential and, if so, the particular
+pseudonym or other terms to be substituted for a party name: The Court is sealing the items listed
+below in their entirety. Should any documents later be unsealed, the documents will be redacted
+and pseudonyms and initials will be used for Intervenors Jane Doe, E.W. and L.M. and any other
+persons the Court deems appropriate.
+(D):
+Whether any progress docket or similar records generated to document activity in
+document acivily in
+the case are determined to be confidential: No.
+(E)
+The particular information that is determined to be confidential:
+• Disc labeled "Epstein 1
+Stamp", and
+• The following documents Epstein identified on his March 5, 2018, Clerk's
+Trial Exhibit List (the gray of which
+and the Intervenors have
+claimed as privileged):
+Ex. No.
+13-1
+13-2
+13-3
+13-4
+13-5
+13-6
+13-7
+13-8
+13-9
+13-10
+13-11
+13-12
+13-13
+13-14
+13-15
+13-17
+App. No.
+02645
+03037
+03036
+00149
+01527
+04493-04495
+00014
+03998-04000
+02231
+01300
+00090
+02906-02908
+00133
+11237
+08006
+00026
+55
+35
+3
+36
+6
+37
+68
+31
+70
+
+
+Agreed Order Directing Clerk to Seal Filings
+Page 3
+13-35
+13-36
+13-37
+13-40
+13-41
+13-43
+13-44
+13-45
+13-46
+13-47.
+13-48
+NOT
+126EE81833
+01464
+01004
+01403
+02684-02685
+01475
+03694
+12289
+01166
+01258
+15113-15114
+26481
+26394
+25922
+26480
+26356
+26570
+00992
+01423
+05071
+02043
+03731-03732
+06406-06408
+01686
+11123-11125
+02088
+11126-11127
+11128-11131
+08459
+25925
+25874
+08348-08349
+08355
+11145
+03191-03192
+27284
+26893
+01255
+26836-26837
+App. No.
+71
+51
+79
+33
+38
+72
+60
+7
+81
+.48
+50
+32
+49
+89
+90,91
+
+
+15"" Judicial Circuit Case No. 2009CA040800XXXXMBAG
+Agreed Order Directing Clerk to Seal Filings
+Page 4
+NOT
+Ex. No.
+13-66
+13-67
+13-68
+13-69
+13-70
+13-71
+13-72
+13-73
+13-74
+13-75
+13-77
+13-78
+13-79
+13-80
+13-81
+13-83
+13-85
+13:86
+13-88
+(13:89
+$13-90
+13-92
+13-93
+13:94
+13-96
+13-97
+13:98
+13-99
+13-100
+13-101
+13-102
+13-103
+13-104
+13-105
+13-106
+13-107
+04398-04402
+04408-04412
+26807
+26808-26809
+27379
+27293
+26021
+27270
+27355
+27325
+27322
+26777-26781,
+26782-26786
+1102, 103, 104
+26088-26089
+105
+25998
+52
+27072
+108
+(Legamaro
+Depo Ex 6
+26747
+08042-08044
+26741-26742
+08059-08061
+27522
+11
+16
+13; 15
+17
+109
+26756-26758
+08036-08038
+19
+Legamaro
+Production
+26762
+8
+01117
+27051-20752
+112
+08121-08123
+26749-26752
+08128-08130
+23
+24
+08118-08120
+08131-08133
+08124-08126
+25
+26
+08135-08138
+27494
+
+
+15 Judicial Circuit Case No. 2009CA040800XXXXMBAG
+Agreed Order Directing Clerk to Seal Filings
+Ex. No.
+13-108
+13-109
+13-110
+13-111
+13-112
+13-113
+13-114
+13-115
+13-116
+13-117
+26760
+27025
+25997
+25937
+26973
+26604-26605.
+26737
+26485
+07019-07021
+27013
+App. No.
+111
+28
+.67
+58
+(F)
+Identification of persons who are permitted to view the confidential information:
+Unless and until ordered by this Court, only this Court and the Fourth District Court of Appeal
+shall be able to view the items under seal.
+(G)
+The Court finds that (i) the degree, duration, and manner of confidentiality ordered
+by the Court are no broader than necessary to protect the interests set forth in Florida Rule of
+Judicial Administration 2.420(c); and (ii) no less restrictive measures are available to protect the
+interests set forth in subdivision (c).
+(H)
+The Clerk of Court is directed to publish the order in accordance with Florida Rule
+of Judicial Administration 2.420(e)(4).
+The items identified above shall remain under seal until further order of this Court.
+DONE AND ORDERED in West Palm Beach, Palm Beach
+ung, Florida this C day
+of April, 2018.
+DONALD W. HAFELE
+CIRCUIT COURT JUDGE
+
+
+Agreed Order Directing Clerk to Seal Filings
+SERVICE LIST
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@searcvlaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suité 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Co-Counsel for Defendant/Counter-Plaintiff
+J. Edwards
+Mare S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+Counsel for Defendant Scolt Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+Lised a mon Co-Counsel for L.M. EM.
+
+
+15'" Judicial Circuit Case No. 2009CA040800XXXXMBAG
+Agreed Order Directing Clerk to Seal Filings
+Page 7
+Scott J. Link
+Kara Berard Rockenbach
+Rachel J. Glasser
+Link & Rockenbach, PA
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33401
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+Rachel@linkrocklaw.com
+Tina@linkrocklaw.com
+Troy@linkrocklaw.com
+Trial Counsel for Plaintif/Counter-Defendant
+Jeffrey Epstein
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+NOT A CERTIFIED COP
+Limited Intervenor Co-Counsel for L.M., EW.
+
+
+COPY
+
+NOT A CERTIF
+
+
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+V.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT NOTICE OF
+SERVICE OF COURT'S MARCH 8. 2018. HEARING TRANSCRIPTS
+AND COMPLIANCE WITH COURT'S RULINGS!
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby serves the transcripts
+(morning and afternoon sessions) of the March 8, 2018, hearing, and provides his Notice of
+Compliance with the Court's rulings. Epstein will file this Notice with the Court once the stay is
+lifted.
+THE COURT'S RULINGS
+'As to Intervenors' (E.W., L.M. and Jane Doe) request to temporarily seal the
+pleadings relating to the e-mails, the Court granted the request and asked for a
+proposed Order. (Morning Session, 3/8/18 4:16-5:1.)
+• The sanitized redacted version of Epstein's Notice of Filing Appendix shall be filed
+under seal. (Afternoon Session, 3/8/18 75:20-23.)
+'Although no written Order has been entered and the proceeding is stayed, Epstein has
+complied with and will continue to comply with the Court's rulings on the record.
+
+
+• In order for Epstein to preserve his rights concerning the Court's rejection of the
+last-minute request for an in-camera inspection and the striking of his newly
+disclosed exhibits, Epstein shall file under seal the newly disclosed trial exhibits
+which
+has claimed are privileged. (Afternoon Session, 3/8/18 62:2-63:1.)
+These do not include exhibits that were already in the Court file or used in this case.
+(Afternoon Session, 3/8/18 76:8-21.)
+• Link & Rockenbach, PA's copy of the disc entitled "Epstein Bate Stamp" that is
+the subject of the dispute will be filed under seal. (Afternoon Session, 3/8/18,
+75:12-18.)
+• Link & Rockenbach, PA to retain
+boxes, including the original disc.
+(Afternoon Session, 3/8/18, 80:8-81:15.)
+On Friday, March 9, 2018, at 4:15 p.m. the Fourth District Court of Appeal entered its
+Order staying the state court action pending its review.
+PLAINTIFF/COUNTER-DEFENDANT'S COMPLIANCE
+Plaintiff/Counter-Defendant Jeffrey Epstein's counsel, Link & Rockenbach, PA, have
+complied with the Court's rulings at the March 8, 2018, hearing as follows:
+• Link & Rockenbach, PA has not made any further dissemination of the documents
+included in the Appendix in Support of Epstein's Response in Opposition to
+Second Supplement to Motion in Limine Addressing Scope of
+Admissible Evidence, trial exhibits or other documents from the disc that
+has asserted privilege claims over.
+• On March 8, 2018, Link & Rockenbach, PA notified its client, its co-counsel (Jack
+Goldberger), its litigation team working on this matter, and its expert, Timothy
+Chinaris, to destroy all hard copies and electronic versions of the documents
+obtained from the dise and any copies of the discs that they had in their possession.
+On March 6, 2018, Epstein filed his Notice of No Objection to Attorney Paul
+Cassell, on Behalf of L.M., E.W. and Jane Doe, or Defendant/Counter-Plaintiff
+Moving to Seal Court Records Until the Court Makes a
+Determination on How the Documents Shall be Treated.
+• Link & Rockenbach, PA is assisting
+counsel to seal the redacted version
+of D.E. 1242, Epstein's Notice of Filing Redacted Appendix in Support of
+Response in Opposition to
+Second Supplement to Motion in Limine
+Addressing Scope of Admissible Evidence, and D.E. 1252, Motion for Court to
+Declare Relevance and Non-Privileged Nature of Documents and Request for
+2
+
+
+Additional Limited Discovery, Evidentiary Hearing and Appointment of Special
+• Link & Rockenbach, PA has destroyed its paper copy of the Redacted Appendix
+that was filed in the Court file and has deleted the electronic version from its system.
+• Link & Rockenbach, PA, has placed the Unredacted Appendix that was served but
+not filed in a sealed box that will be maintained in its office, unopened, for appellate
+purposes.
+• In l
+March 5, 2018, Motion to Strike Epstein's Untimely Supplemental
+Exhibits and to Strike All Exhibits and Any Reference to Documents Containing
+Privileged Matters Listed on
+Privilege Log, Edwards alleged the
+following exhibits identified by Epstein were privileged:
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15|
+16}
+17
+18
+19
+20
+21
+22
+23
+24
+25
+26
+27
+28
+29
+Ex. No.
+13-1
+13-4
+13-5
+13-6
+13-7
+13-11
+13-13
+13-15
+13-171
+13-19
+13-251
+13-30
+13-34
+13-35
+13-36
+13-44
+13-45
+13-46
+13-47
+13-49
+13-52
+13-53
+13-56
+13-60
+13-66
+13-67
+13-86
+13-88
+13-89
+App. No.
+02645
+00149
+01527
+04493-4495
+00014
+00090
+00133
+08006
+00026
+01004
+12289
+26481
+26480
+26356
+26570
+03731-03732
+06406-06408
+01686
+11123-11125
+11126-11127
+25925
+25874
+11145
+03191-03192
+04398-04402
+04408-04412
+
+08042-08044
+26741-26742
+35
+3
+36
+37
+70
+71
+60
+48
+50
+32
+4
+2,34
+16
+13,15
+3
+
+
+31
+32
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+Ex. No.
+13-90
+13-93
+13-94
+13-97
+13-98
+13-100
+13-101
+13-102
+13-103
+13-104
+13-105
+13-106
+13-107
+13-108
+13-110
+13-111
+13-113
+13-116
+08059-08061
+26756-26758
+08036-08038
+26762
+01117
+08121-08123
+26749-26752
+08128-08130
+08118-08120
+08131-08133
+08124-08126
+08135-08138
+27494
+26760
+25997
+25937
+26604-26605
+07019-07021
+App. No.
+17
+28
+67
+56
+also objected to the following additional exhibits as being late disclosed:
+1
+2
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+Ex. No.
+13-2
+13-3
+13-8
+13-9
+13-10
+13-12
+13-14
+13-18
+13-20
+13-21
+13-22
+13-24
+13-26
+13-27
+13-28
+13-31
+13-33
+13-37
+13-40
+13-41
+13-43
+03037
+03036
+03998-04000
+02231
+01300
+2906-2908
+11237
+01464
+01403
+02684-02685
+01475
+03694
+01166
+01258
+15113-15114
+26394
+25922
+00992
+01423
+05071
+02043
+App. No.
+54
+55
+6
+51
+79
+38
+72
+7
+4
+
+
+22
+23
+24
+25
+26
+27
+28
+29
+30
+31
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+48
+49
+50
+51
+52
+53
+Ex. No.
+13-48
+13-50
+13-51
+13-54
+13-55
+13-61
+13-62
+13-64
+13-65
+13-68
+13-69
+13-70
+13-71
+13-72
+13-73
+13-74
+13-75
+13-77
+13-78
+13-79
+13-80
+13-81
+13-83
+13-85
+13-92
+13-96
+13-99
+13-109
+13-112
+13-114
+13-115
+13-117
+02088
+11128-11131
+08459
+08348-08349
+08355
+27284
+26893
+01255
+26836-26837
+26807
+26808-26809
+27379
+27293
+26021
+27270
+27355
+27325
+27322
+26777-26781
+26782-26786
+26088-26089
+25998
+27072
+Legamaro
+Depo Ex 6
+27522
+Legamaro
+Production
+27051-20752
+27025
+26973
+26737
+26485
+27013
+App. No.
+49
+87
+89
+63
+96
+100
+101
+102, 103, 104
+105
+52
+108
+109
+58
+Link & Rockenbach, PA has marked the exhibits identified above and placed them
+in a sealed envelope for filing with the Court under seal once the stay is lifted in
+order to preserve Epstein's appellate record. Link & Rockenbach, PA will retain a
+set of these exhibits in a sealed envelope in the sealed box maintained in its offices
+for appellate purposes.
+With the exception of those documents it is maintaining in a sealed box fo
+ppellate purposes, Link & Rockenbach, PA has destroyed all hard copies of th
+documents it reproduced from the disc that
+5
+
+
+• Link & Rockenbach, PA has placed its copy of the disc in a sealed envelope, which
+will be filed under seal with the Court once the stay is lifted.
+• Link & Rockenbach, PA has placed
+original disc in a sealed
+envelope which will be maintained with its original records at the offices of Link
+& Rockenbach, PA until further rulings by the Court.
+• Link & Rockenbach, PA will maintain control of the
+further rulings by the Court.
+boxes until
+• Link & Rockenbach, PA has deleted the clectronic duplicate of the disc and the
+electronic version of the exhibits identified above from its computer system and
+Dropbox.
+• Link & Rockenbach, PA will work with its IT personnel to remove copies of any
+documents
+has claimed as privileged from its e-mail servers.
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on March 11, 2018, via e-mail and will be served with the Court once the stay
+is lifted.
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Rachel J. Glasser (FBN 577251)
+NOT A
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+SERVICE LIST
+6
+
+
+Jack Scarola
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+scarolateam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+njs@FLAAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+| Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+fort Lauderdale, FL 33301-326
+rad@epllc.com
+staff.efile@pathotojustice.com
+Co-Counsel for Defendant/Counter-Plaintif
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.edu
+Limited Intervenor Co-Counsel for L.M., E.W.
+NOT A
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+Limited Intervenor Co-Counsel for L.M., E.W.
+7
+
+
+Filing # 69743011 E-Filed 03/23/2018 03:36:48 PM
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+UPDATED NOTICE OF COMPLIANCE WITH COURT'S RULINGS'
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby updates his March 8,
+2018, Notice of Compliance with the Court's March 8, 2018, rulings and states:
+THE COURT'S RULINGS
+At that hearing, the Court made the following rulings:
+• As to Intervenórs' (E.W., L.M. and Jane Doe) request to temporarily seal the
+pleadings relating to the e-mails, the Court granted the request and asked for a
+proposed Order. (Morning Session, 3/8/18 4:16-5:1.)
+The sanitized redacted version of Epstein's Notice of Filing Appendix shall be
+filed under seal. (Afternoon Session, 3/8/18 75:20-23.)
+In order for Epstein to preserve his rights concerning the Court's rejection of the
+last-minute request for an in-camera inspection and the striking of his newly
+' Although no written Order has been entered yet on Defendant/Counter-Plaintiff
+March 5, 2018, Motion to Strike Epstein's Untimely Supplemental Exhibits and to
+Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on
+Privilege Log, Epstein has complied with and will continue to comply with the Court's
+rulings on the record.
+
+
+disclosed exhibits, Epstein shall file under seal the newly disclosed trial exhibits
+which
+has claimed are privileged. (Afternoon Session, 3/8/18 62:2-
+63:1.) These do not include exhibits that were already in the Court file or used in
+this case. (Afternoon Session, 3/8/18 76:8-21.)
+• Link & Rockenbach, PA's copy of the disc entitled "Epstein Bate Stamp" that is
+the subject of the dispute will be filed under seal. (Afternoon Session, 3/8/18,
+75:12-18.)
+• Link & Rockenbach, PA to retain
+disc. (Afternoon Session, 3/8/18, 80:8-81:15.)
+boxes, including the original
+On Friday, March 9, 2018, at 4:15 p.m. the Fourth District Court of Appeal entered its
+Order staying the state court action pending its review. That stay was lifted, in part, on March
+20, 2018, and Epstein hereby updates his Notice of Compliance.
+PLAINTIFF/COUNTER-DEFENDANT'S COMPLIANCE
+Plaintiff/Counter-Defendant Jeffrey Epstein's counsel, Link & Rockenbach, PA, has
+complied with the Court's rulings at the March 8, 2018, hearing as follows:
+• Link & Rockenbach, PA has not made any further dissemination of the
+documents included in the Appendix in Support of Epstein's Response in
+Opposition to Edwards' Second Supplement to Motion in Limine Addressing
+Scope of Admissible Evidence, the newly disclosed trial exhibits in which
+claims a privilege, or other documents from the disc that
+has
+asserted privilege claims over.
+• Neither Epstein nor his general counsel (Darren Indyke), were ever provided with
+a copy of the disc nor did they review or have access to the disc or the disc's
+contents. Epstein and his general counsel also never received the disc or alleged
+"priyileged" documents from the
+firm or any other former counsel.
+Rather, Epstein and his general counsel were provided with select e-mails by Link
+& Rockenbach, PA that were included in the Appendix or identified as trial
+exhibits. Immediately after the hearing on March 8, 2018, Link & Rockenbach,
+PA notified its client, its client's general counsel (who was at the hearing), its cocounsel (Jack Goldberger, who was at the hearing), and its litigation team
+working on this matter to destroy all hard copies and electronic versions of the
+documents obtained from the disc.
+• Timothy Chinaris, a former Ethics Director of the Florida Bar who provided an
+expert affidavit in this action, was also not provided with a copy of the disc but,
+rather, received a binder (in paper form) containing the unredacted Appendix.
+2
+
+
+Mr. Chinaris was instructed to destroy the binder along with any electronic copies
+he may have had. Mr. Chinaris confirmed his compliance with this request.
+• Neither the disc nor any of its contents were ever provided to the Gunster firm or
+any of its attorneys nor were the contents of the disc ever discussed with them.
+NOT A CERTIFIED COPY
+3
+
+
+• On March 6, 2018, Epstein filed his Notice of No Objection to Attorney Paul
+Cassell, on Behalf of L.M., E.W. and Jane Doe, or Defendant/Counter-Plaintiff
+Moving to Seal Court Records Until the Court Makes a
+Determination on How the Documents Shall be Treated.
+Mr. Cassell's request was addressed, and granted by stipulation, at the March 8,
+2018, hearing. Both Mr. Cassell and
+counsel, however, failed to
+provide the Court with a proposed order at the hearing, which would have resulted
+in the immediate sealing of two docket entries that had not yet been opened to the
+public. While Mr. Cassell and
+counsel had ample time during the
+hearing to have an Order prepared and signed by the Court, a proposed order was
+not circulated to Epstein's counsel until the following afternoon, Friday, March 9,
+2018. Judge Hafele had made known to the parties that he would not be in Court
+on March 9, 2018, because of the Bench Bar Conference, but he advised where he
+could be found, if needed. Nevertheless, the Fourth DCA's stay was entered on
+March 9, 2018,
+within hours of the transmittal of the proposed order.
+Furthermore, on the evening of March 9, 2018, the Clerk opened the two docket
+entries that are at issue to the public.
+During the weekend of March 10 and |1, 2018, Epstein's counsel worked
+tirelessly with
+seal the two docket entries at isste. The duty judge, however, deferred the matter
+to Judge Hafele. Accordingly, on the morning of March 12, 2018, Epstein's and
+'counsel went before the Court at 8:30 a.m. and obtained an Order, nunc
+pro tunc, sealing the two docket entries at issue:
+Epstein's Notice of Filing Redacted Appendix in Support of
+Response in Opposition to Defendant/Counter-Plaintiff
+Edwards' Second Supplement to Motion in Limine Addressing
+Scope of Admissible Evidence (D.E. 1242, a 353-page filing with
+attachments containing actual emails as well as a summary of its
+contents); and
+Epstein's Motion for Court to Declare Relevance and Non-
+Privileged Nature of Documents and Request for Additional
+Limited Discovery, Evidentiary Hearing and Appointment of
+Special
+I (D.E. 1252).
+The Clerk then sealed the two docket entries which had been open to the public
+for more than 48 hours.
+• Link & Rockenbach, PA destroyed its paper copy of the Redacted Appendix that
+was filed in the Court file and deleted the electronic filed version from its system.
+4
+
+
+• Link & Rockenbach, PA placed the Unredacted Appendix that was served but not
+filed in a sealed box that will be maintained in its office, unopened, for appellate
+purposes.
+• In
+March 5, 2018, Motion to Strike Epstein's Untimely Supplemental
+Exhibits and to Strike All Exhibits and Any Reference to Documents Containing
+Privileged Matters Listed on
+• Privilege Log
+following exhibits identified by Epstein were privileged:
+1
+2
+3
+4
+5
+6
+7
+Ex. No.
+13-1
+02645
+13-4
+00149
+13-5
+01527
+App. No.
+35
+3
+13-6
+04493-4495
+13-7
+00014
+36
+13-11
+00090
+37
+13-13
+00133
+68
+13-15
+08006
+9
+31
+13-17
+00026
+70
+10
+13-19
+01004
+71
+11
+13-25
+12289
+33
+12
+13-30
+26481
+13
+13-34
+26480
+60
+14
+13-35
+26356
+15
+13-36
+26570
+16
+13-44
+03731-03732
+17
+13-45
+06406-06408
+18
+13-46
+01686
+19
+13-47
+11123-11125
+20
+13-49
+11126-11127
+48
+50
+32
+13-52
+25925
+13-53
+25874
+13-56
+11145
+13-60
+03191-03192
+13-66
+04398-04402
+13-67
+04408-04412
+13-86
+
+13-88
+08042-08044
+13-89
+26741-26742
+13-90
+08059-08061
+13-93
+26756-26758
+4
+2,34
+1
+11
+16
+13, 15
+17
+13-94
+08036-08038
+13-97
+26762
+13-98
+01117
+13-100
+08121-08123
+5
+
+
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+46
+47
+Ex. No.
+13-101
+13-102
+13-103
+13-104
+13-105
+13-106
+13-107
+13-108
+13-110
+13-111
+13-113
+13-116
+26749-26752
+08128-08130
+08118-08120
+08131-08133
+08124-08126
+08135-08138
+27494
+26760
+25997
+25937
+26604-26605
+07019-07021
+App. No.
+23
+28
+67
+56
+also objected to the following additional exhibits which were printed
+from the disc as being late disclosed:
+Ex. No.
+03037
+03036
+03998-04000
+02231
+01300
+2906-2908
+11237
+01464
+01403
+02684-02685
+01475
+03694
+01166
+01258
+15113-15114
+26394
+25922
+00992
+01423
+05071
+02043
+02088
+11128-11131
+08459
+08348-08349
+08355
+JApp. No.
+54
+55
+6
+51
+38
+72
+7
+81
+49
+6
+
+
+27
+28
+29
+30
+32
+33
+34
+35
+36
+37
+38
+39
+40
+41
+42
+43
+44
+45
+Ex. No.
+13-61
+13-62
+13-64
+13-65
+13-68
+13-69
+13-70
+13-71
+13-72
+13-73
+13-74
+13-75
+13-77
+13-78
+13-79
+13-80
+13-81
+13-83
+13-85
+46
+47
+13-92
+13-96
+48
+49
+50
+51
+52
+53
+13-99
+13-109
+43-112
+13-114
+13-115
+13-117
+27284
+26893
+01255
+26836-26837
+26807
+26808-26809
+27379
+27293
+26021
+27270
+27355
+27325
+27322
+26777-26781
+26782-26786
+26088-26089
+25998
+27072
+Legamaro
+Depo Ex 6
+27522
+I camaro
+Production
+27051-20752
+27025
+26973
+26737
+26485
+27013
+App. No.
+87
+89
+90,91
+92
+
+101
+102, 103, 104
+52
+108
+109
+112
+111
+84
+57
+57
+58
+Edwards objected to other documents Epstein identified as newly disclosed trial
+exhibits, but those were obtained from public sources over which
+and
+Mr. Cassell cannot assert privilege claims and, therefore, they are not included as
+part of this Notice of Compliance.
+Link & Rockenbach, PA placed an exhibit sticker on the 100 newly disclosed
+exhibits identified above to correspond with Epstein's Clerk's Trial Exhibit List.
+Two sets of those exhibits were made. One has been retained by Link &
+Rockenbach, PA in a sealed envelope in a sealed box maintained at its offices for
+appellate purposes. The other set was initially retained in a sealed envelope at
+Link & Rockenbach, PA, however, on March 21, 2018, in light of the lifting of
+the Fourth District Court of Appeal's stay, in part, those exhibits were filed under
+seal. Epstein has also moved the Court to Make the Court Records Confidential
+in compliance with the 15" Judicial Circuit's Administrative Order 2.303-9/09
+7
+
+
+and set that Motion for hearing on April 9, 2018.
+With the exception of the trial exhibits and appendix items identified above which
+Link & Rockenbach, PA is maintaining in a sealed box for appellate purposes,
+Link & Rockenbach, PA has destroyed all hard copies of the documents it
+reproduced from the disc that
+has identified as privileged.
+• Link & Rockenbach, PA placed its copy of the disc in a sealed envelope, which it
+retained at its offices until the stay was lifted. In that regard, on March 21, 2018,
+Link & Rockenbach, PA filed the disc under seal and moved the Court to make
+the court records confidential in compliance with the 15" Judicial Circuit's
+Administrative Order 2.303-9/09. That Motion is set for hearing on April 9,
+2018.
+• Link & Rockenbach, PA placed.
+which will be maintained with
+Link & Rockenbach, PA until further rulings by the Court.
+original disc in a sealed envelope
+original records at the offices of
+• Link & Rockenbach, PA will maintain control of the
+further rulings by the Court.
+boxes until
+• Link & Rockenbach, PA has deleted the electronic duplicate of the disc and the
+electronic version of the exhibits identified above from its computer system and
+Dropbox, the online service by which those documents were transmitted to
+counsel of record.
+• Link & Rockenbach, PA began deleting electronic documents from its system and
+planned to work with I personnel to remove copies of any documents
+has claimed as privileged from its e-mail servers. In light of
+objection
+to the deletion of electronic documents, however, Link & Rockenbach, PA has
+not taken further steps to delete electronic documents. The Court made no rulings
+on the preservation of these documents and Link & Rockenbach, PA does not
+demanded is appropriate. Until the Court rules
+Otherwise, however, Link & Rockenbach, PA will not delete any further
+electronic documents and will work with its IT personnel to preserve those
+documents.
+8
+
+
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on March 23, 2018, through the Court's e-filing portal pursuant to Florida
+Rule of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax|
+By: Is/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Rachel J. Glasser (FBN 577251)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Rachel@linkrocklaw.com
+Secondary: Ima@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+SERVICE LIST
+Philip M. Burlington
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@scarcylaw.com
+jsx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+West Palm Beach, FL 33401
+pmb@FLAppellateLaw.com
+njs@FL.AppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+
+
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+Marc S. Nurik
+Law Offices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+., E.W
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+Limited Intervenor Co-Counsel for L.M., E. W.
+NOT A
+10
\ No newline at end of file
diff --git a/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.receipt.json b/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ac2349bb0e6424085c56b56087549007f62072ac
--- /dev/null
+++ b/vision-fixhub/court-02/08e0c3fd3fcea9f617b7619658a6df9ed4d64e6971efe9d0823712d8e342228c.receipt.json
@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-02/092edac96ede7c0d63b337e09c7cd3679a9a840829c42c8c584a714054d91ad3.md b/vision-fixhub/court-02/092edac96ede7c0d63b337e09c7cd3679a9a840829c42c8c584a714054d91ad3.md
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@@ -0,0 +1,4141 @@
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+IN THE CIRCUIT COURT OF THE 15TH
+JUDICIAL CIRCUIT IN AND FOR PALM
+BEACH COUNTY, FLORIDA
+Case: 50 2009 CA 040800XXXXMBAG
+FILED
+2010 DEC -1 PM 3: 11
+BOCI
+K.
+SCOTT ROTHSTEIN, individually, and
+J.
+individually,
+Defendants,
+MOTION FOR A STAY OF SUBPOENA PENDING RULING ON PREVIOUSLY-FILED
+MOTION FOR SUMMARY JUDGMENT, FOR A PROTECTIVE ORDER, AND FOR
+SCHEDULING ORDER ON CREATING A PRIVILEGE LOG
+Defendant,
+J.
+, Esq., pursuant to Rule 1.280(c), Florida Rules of Civil
+Procedure, hereby moves for protection from an abusive subpoena issued by plaintiff Jeffrey
+Epstein through this Court and served on him and on bankruptcy trustee Herb Stettin.
+Epstein has served a subpoena on
+and Stettin that will require
+review more than 70,000 pages of materials to identify responsive documents and to assert
+appropriate privileges.
+• Moreover, Epstein has contrived to have issues regarding this Court's
+subpoena Titigated in the Bankruptcy Court for the Southern District of Florida through the
+happenstance that possession of the documents (records of a law firm) rests in the hands of
+Stettin.
+Epstein apparently contemplates that the bankruptcy court will make rulings on
+privilege issues that properly should be made by this Court.
+Epstein's maneuvers threaten to burden both this Court and the bankruptcy court with
+making duplicative, potentially conflicting, and likely unnecessary rulings. Accordingly,
+
+
+asks this Court to stay enforcement of its subpoenas for a brief period of time to permit
+this Court to first rule on the pending motion for summary judgment on all of Epstein's claims
+that have been filed by
+If any of Epstein's claims somehow survive the pending
+summary judgment motion, then this Court could rule on the proper scope of the subpoena and
+any privilege or other issues which remain to be litigated.
+proposes a schedule to
+rapidly bring these issues to resolution and urges the Court to adopt it.
+also requests a
+protective order, narrowing the scope of the production requests made by Epstein and requiring
+billionaire Epstein to pay all reasonable costs associated with responding to his discovery
+requests.
+BACKGROUND FACTS
+As this court is well aware from a summary judgment motion filed by |
+, Plaintiff
+Jeffrey Epstein (a convicted sex offender) has-sued legal counsel
+J.
+, Esq., for
+conduct that occurred in the course of
+representation of multiple young female victims
+of Epstein's sexual abuse. Edwards filed and pursued civil lawsuits against Epstein to recover
+damages for Epstein's extensive pattern of molestations. In retaliation and to try and intimidate
+and his young clients, Epstein brought this lawsuit in this court alleging that
+had somehow fabricated and/or exaggerated the claims.
+has now filed a comprehensive
+motion for sum
+ry judgment against Epstein, detailing how he is entitled to judgment on each
+and every one of Epstein's frivolous claims.
+Epstein has yet to file any response to
+comprehensive summary judgment
+motion. Nonetheless, he continues to harass
+through discovery requests connected with
+this case. In particular, on April 12, 2010, Epstein propounded an extremely broad Request for
+2
+
+
+Production (RFP) to
+See Exhibit "A." Containing some 27 different requested items,
+the RFP seeks all sorts of electronically stored information, including a raft of internal emails
+between
+and other attorneys, paralegals, expert witnesses, investigators, and others who
+worked on the civil lawsuits against Epstein. On May 11, 2010,
+request for production. Through his legal counsel,
+duly responded to the
+noted that many of the requests
+sought attorney-client or work-product privileged information and others were overly broad and
+unduly burdensome. See Exhibit "B."
+While
+was raising his objections to the subpoena lodged against him, Epstein
+duplicated his requests by serving a separate subpoena for the same information. On April 16,
+2010, four days after making the requests to
+requests, much less a court ruling on
+- without waiting for his responses to the
+objections - Epstein served a subpoena duces
+tecum for documents on bankruptcy court-appointed trustee, Herb Stettin.
+A bit of background may be helpful here. Mr. Stettin never represented any of the
+underage females who had been sexually abused by Epstein. Instead, Mr. Stettin has possession
+of certain records related to this case - and many more entirely unrelated to this case - because
+he was court-appointed as bankruptcy trustee for the now-defunct law firm of Rothstein
+Rosenfeldt Adler (RRA).
+during his representation of his young clients,
+had a brief connection to RRA. For a short period of time
+was employed by RRA. It was then
+revealed that the law firm president, Scott Rothstein, had been running a criminal Ponzi scheme
+out of the law firm. Shortly after learning of the fraud,
+left RRA. Later, RRA declared
+bankruptcy and the bankruptcy court appointed Herb Stettin trustee of the estate of RRA,
+charging him with handling financial claims regarding the assets of the firm. RRA's electronic
+3
+
+
+database, including all electronically stored files and emails, were left in the possession of
+Stettin. Because Stettin was not involved in the sexual abuse litigation against Epstein, he does
+not have detailed knowledge of the persons or subjects discussed in the various e-mails and other
+records.
+On June 28, 2010, a hearing was set before this court on Epstein's Motion to Compel the
+Trustee to produce the documents responsive to Epstein's subpoena. On that date, Stettin's
+counsel,
+counsel, and counsel for Epstein all met in the hallway outside the courtroom
+and worked out an agreed resolution to the dispute. All counsel agreed that Stettin would turn
+over to
+counsel all documents responsive to the subpoena and that
+counsel
+would then prepare a privilege log and produce all documents that are not subject to objection or
+privilege. At that point, Epstein could pursue any further arguments that he wanted in this Court
+regarding materials not produced. As a result of the agreement, the Court never held the hearing
+on the Motion to Compel. Epstein's counsel agreed to draft a proposed consent order for all the
+parties.
+Despite the agreement between the parties, Epstein's counsel never prepared that agreed
+order. Instead, Epstein decided to launch litigation in yet another forum - the United States
+Bankruptcy Court for the Southern District of Florida. On July 14, 2010, Epstein filed a Motion
+to Compel production of numerous documents from Trustee Stettin in the bankruptcy proceeding
+being overseen by the bankruptcy court (Judge Raymond Ray). See Jeffrey Epstein's Motion to
+Compel Production of Documents from Trustee Pursuant to Document Production Protocol
+Established by DE #672, In re: Rothstein Rosenfeldt Adler, Case No. 09-34791-BKC-RBR (DE
+807) (attached as Exhibit "C"'). In his motion, Epstein recounted that he had served a subpoena
+4
+
+
+on the trustee. See id. at 2. Epstein did not inform the bankruptcy court, however, that he was
+seeking the same information from
+and that
+had raised claims of privilege.
+Nor did Epstein mention that he had previously filed a motion to compel before this Court.
+Instead, Epstein claimed to the bankruptcy court that "[p]roduction of these documents from the
+Trustee is critical to issues in the state court lawsuit. Without access to the emails in question,
+Movant will suffer unfair prejudice and will be unable to obtain information critical to his
+lawsuit." Id. at 3. Epstein also stated that he was "willing to reimburse the Estate for its
+reasonable expenses incurred in reviewing the documents for privileged matters and preparing a
+Privilege Log." Id. at 4.
+In response, on July 19, 2010,
+filed a Motion for Protective Order (DE 818)
+(Exhibit "D") and an amended Motion for Protective Order (DE 819) (Exhibit "E.") to restrict
+this production so that privileged or other non-discoverable material was not produced. A
+hearing was held on that Motion and on August 13, 2010, the bankruptcy court entered an Order
+that appointed as Special
+former Broward County Circuit Judge Robert Carney to take all
+materials responsive to the subpoena from Stettin and to prepare a privilege log (DE 888)
+(Exhibit "F").
+Special Master Carney did take possession of the materials; however, after reviewing the
+materials he immediately realized that there were obvious problems if he (the Special
+prepared a privilege log. Specifically, lacking familiarity with the sexual abuse litigation, the
+Special
+had no way to determine which materials were relevant and of those relevant
+materials, which were privileged. Moreover, the privileges were not the Special
+assert or waive. Rather, the attorney-client privilege and other privileges were held by clients of
+5
+
+
+and
+himself. As a result of these problems, on September 20, 2010, Special
+Carney filed a Motion to Clarify Order Appointing Special
+(DE 1013). (Exhibit
+"G."
+On September 27, 2010,
+then filed another Motion for Protective Order (DE
+1022) (attached as Exhibit "H"). In that motion,
+explained that "Epstein asks this
+[Bankruptcy] Court to usurp the properly exercised jurisdiction of the Circuit Court over a
+subpoena duces tecum issued by the state court in connection with an action pending before the
+state court." Id. at 1.
+further noted that he had previously objected to this information
+being turned over in state court and that this was Epstein's "attempt to backdoor his way into
+obtaining information to which he is not entitled." Id. at 4.
+On October 10, 2010, the bankruptcy court entered an amended order modifying the
+production procedures and the role of the Special
+ster (DE 1068) (attached as Exhibit "T"). In
+this Amended Order Respecting Production of Documents Regarding Jeffrey Epstein, the
+bankruptcy court directed the Trustee to produce all of the materials in question to
+law
+firm -
+, Jaffe, Weissing, Edwards, Fistos & Lehrman.
+Jaffe was then directed to
+produce a privilege log of all materials. The privilege log was to be provided to the Special
+The Special
+was, in turn, to "schedule a hearing ... where all parties in interest
+will have the opportunity to provide written submissions respecting the privilege log and to make
+argument on all issues relevant to the applicability of privilege as to the documents listed on the
+Jaffe privilege log. That hearing shall be transcribed by a court reporter." Id. at 3. Then,
+"[following completion of the aforementioned hearing, the Special
+shall prepare a report
+making all appropriate findings and recommendations to the Court, which shall be served on all
+6
+
+
+parties in interest and filed with the Court, along with the transcript of the Special
+hearing.... If an objection to the report is filed by any party in interest, then this Court shall
+schedule and hold a hearing to resolve with finality the issues of privilege as consistent with the
+appropriate law and procedures set forth herein." Id.
+Following the entry of this order, Trustee's counsel delivered several disks containing
+more than 70,000 pages of materials to
+Jaffe. Some of these materials are e-mails from
+the RRA computers and other materials are electronically stored case files containing pleadings,
+discovery, correspondence between counsel and other case related materials. While some of
+these materials are connected with the Epstein litigation, many of them are not. Most of the
+materials do not appear to be responsive to the Epstein subpoena originally served.
+On November 2, 2010,
+filed a motion in bankruptcy court requesting relief from
+the Amended Order. See Motion for Relief from Amended Order [DE1068] and to Compel
+Jeffrey Epstein to Pay for the Production of all Documents in Response to His Request (DE
+1120) (Attached as Exhibit "J"). It was then also discovered that the disks provided to
+were not identical to those provided to Special
+Carney and a meeting was set up between
+Special
+Carney and
+to compare the disks and get the correct disks in
+hands to begin review of the materials. As a result, on November 10, 2010, Special
+Carney met with Edwards. The disk problem was sorted out, and
+same materials that Special
+Carney had, from which
+was then provided the
+was ordered pursuant to
+DE 1068 to begin preparing a privilege log.
+During the meeting with Special
+Carney, it became apparent that the result of
+creation of a privilege log and his anticipated objections to the production of
+7
+
+
+irrelevant and privileged materials was on a path for a hearing ultimately before the bankruptcy
+court ruling on the scope of this Court's subpoena and possible restrictions from it.
+DISCUSSION
+THIS COURT, RATHER THAN THE BANKRUPTCY COURT, IS THE PROPER
+FORUM FOR LITIGATING THE SCOPE OF SUBPOENAS SERVED IN THIS CASE.
+As is apparent from the foregoing recitation of the facts, Epstein has taken his meritless
+retaliatory lawsuit against
+into a different court - the bankruptcy court - and then
+sought to have rulings on the application of privileges in this Court's case made by that court.
+This backdoor approach is not proper, as the issues surrounding this Court's subpoenas belong
+before this Court for several reasons.
+First and foremost, Epstein is now deploying his retaliatory lawsuit to burden
+and other lawyers at his firm with requests to review tens of thousands of pages of documents for
+privilege claims and other discovery issues Because the Trustee has produced what amounts to
+every single piece of paper that even remotely relates to an Epstein case rather than just those
+documents responsive to the subpoena,
+is now forced to review more than 70,000
+documents to create a privilege log.
+While it might be appropriate to force the attorneys to review some portion of those
+documents if a viable lawsuit were at hand, Epstein's lawsuit is entirely meritless. As explained
+at length in
+pending motion for summary judgment, Epstein's case should be
+summarily rejected for three separate reasons: First, under the well-established "sword and
+shield" doctrine, Epstein cannot assert a Fifth Amendment privilege to deny access to relevant
+discovery about his lawsuit while simultaneous trying to force
+to pay damages.
+Second, because Epstein has repeatedly taken the Fifth when asked numerous relevant questions
+8
+
+
+about his lawsuit, no reasonable jury could find in his favor. And third and most fundamentally,
+Epstein's lawsuit completely lacks any factual basis whatsoever and does not even make an
+attempt at alleging a viable damage theory.
+If the Court were to agree with
+and grant his summary judgment motion on any
+of these three separate grounds, then it seems likely that the entire discovery dispute surrounding
+Epstein's subpoenas to
+and the trustee would be considerably narrowed or perhaps even
+eliminated entirely. It makes no sense that extensive satellite litigation is on-going in the
+bankruptcy court about subpoenas in Epstein's case when Epstein's case itself is meritless and
+malicious. Of course, the bankruptcy court has to assume that Epstein's case has merit - as it is
+bound to recognize a presumptively valid subpoena that Epstein has issued through this Court.
+Only this Court can rule on the lack of merit to Epstein's case and then narrow or eliminate this
+separate litigation about the subpoenas.
+Second, even assuming arguendo that
+case could survive the pending summary
+judgment motion, the bankruptcy court is simply not the proper forum for determining privilege
+claims in this case. Without in any way challenging the legal acumen of the bankruptcy court,
+the ultimate issues of privilege in this case must be decided by this Court. Whatever the
+bankruptcy court may conclude about certain privilege arguments in the context of discovery,
+this Court will have to ultimately rule on those privilege claims at trial. It makes no sense to
+have two different judges taking time to rule on the same issues. Rather, one court should make
+one binding ruling one time on the privilege issues. The only court that can issue a final ruling
+Even if the Court grants summary judgment for
+counterclaim against Epstein.
+this case will continue before this Court on
+9
+
+
+controlling at trial is this Court. Therefore, this Court should rule on the discovery issues as
+well.
+Third, only this Court can fairly evaluate
+claims regarding the scope of the
+subpoenas. Epstein has issued through this Court extremely broad subpoenas which are unduly
+burdensome on
+and his law firm. Yet the bankruptcy court does not have authority to
+grant relief from those subpoenas - only this Court can do that. Under rule 1.280(c) of the
+Florida Rules of Civil Procedure, the trial judge may limit or prohibit discovery "to protect a
+party or person from annoyance, embarrassment, oppression, or undue burden or expense." As
+explained in Rasmussen v. South Florida Blood Service, Inc., 500 So.2d 533, 535 (Fla. 1987),
+under this rule trial judges possess "broad discretion" to restrict discovery. But that discretion
+rests in the "trial court," id., which obviously is familiar with the litigation pending before it.
+The bankruptcy court cannot exercise discretion to restrict this Court's subpoenas.
+Finally, the bankruptcy court simply lacks jurisdiction to rule regarding privilege issues
+that have arisen in this Court's case. It is well settled that the bankruptcy court's jurisdiction is
+limited to "(1) cases under title 11 .);(2) 'core' bankruptcy proceedings that either arise under'
+the Bankruptcy Code or "arise in' a case under the Code, or (3) cases in which all interested
+parties "consent' to the bankruptcy court having jurisdiction to enter a final order in a matter that
+is 'related to a case under the Bankruptcy Code." In re Ray, --- F.3d --., 2010 WL 4160135at *
+4 (9'* Cir. 2010) (internal quotations omitted). Ruling on privilege claims from a subpoena
+issued by this Court in a tort suit filed by Epstein (who is not a party to the bankruptcy
+proceeding) against
+(who is likewise not a party to the bankruptcy proceeding) does not
+10
+
+
+fall within any of these grants of jurisdiction to the bankruptcy court and therefore Epstein's
+proposed procedure is without jurisdictional foundation.
+THIS COURT SHOULD ENTER A PROTECTIVE ORDER AND ESTABLISH A
+SCHEDULE FOR RESOLVING THE PENDING SUMMARY JUDGMENT MOTION
+AND THEN ANY SURVIVING PRIVILEGE ISSUES.
+While
+could file a jurisdictional objection to the bankruptcy court ruling on this
+issue, he does not want to spawn further litigation that could delay a resolution of the privilege
+issues. Instead,
+proposes that this Court simply assert jurisdiction over its subpoena
+and the litigation that has arisen from it. The subpoena to
+and to the trustee that Epstein
+has propounded were issued on the authority of this Court. Accordingly, it is indisputable that
+this Court can simply withdraw or stay enforcement of its subpoena, thereby simply
+consolidating the litigation surrounding its subpoena into this Court. This Court could then make
+binding rulings on both the merits (or lack thereof) of Epstein's lawsuit and any surviving
+privilege issues concerning the subpoenas.
+therefore respectfully proposes that the Court take the following actions:
+Hold its scheduled hearing on
+• summary motion on January 5, 2011.
+The Court shall then rule on whether any of Epstein's claims survive
+summary
+judgment motion, After making those rulings, the Court should then rule on whether Epstein's
+subpoenas should be quashed in light of its rulings.
+If the Court concludes that parts of the
+subpoenas remain viable, then the Court could rule on any remaining claims of privilege or other
+objections that have not been mooted by its summary judgment rulings.
+11
+
+
+Stay further enforcement of its subpoenas to the trustee and to
+pending
+further rulings by this Court on the merits of Epstein's underlying lawsuit and any privilege or
+other issues that
+might raise to the subpoenas.
+Direct
+to prepare a privilege log regarding documents that are actually
+responsive to the subpoenas. Such privilege log shall be prepared within 30 days following this
+Court's ruling on
+pending summary judgment motion assuming any claim by Epstein
+survives. At that time,
+shall also produce to Epstein any documents that are responsive
+to the subpoenas to
+and to the trustee and for which there is no privilege or other
+objection to production (i.e., vagueness in the subpoena or not reasonably calculated to lead to
+discovery of admissible evidence).
+4.
+Epstein shall then file any objections to claim of privilege or other objections
+within 15 days following
+response.
+5.
+shall file any response to Epstein within 10 days following receipt of the
+objections.
+In addition, it is clear that there is an imbalance of financial resources between billionaire
+Jeffrey Epstein and the parties on whom he is serving subpoenas. This Court possesses the
+authority to "direct|] the requesting party to pay the costs and expenses of providing discovery."
+PHILIP J. PADOVANO, FLORIDA CIVIL PRACTICe, § 10.3 at 354 (2007-08 edition) (citing CBS, Inc.
+1, 578 So.2d 698 (Fla. 1991); Mt. Sinai Med. Ctr., Inc. v.
+-Torbay, 555 So.2d 1300
+(Fla. 3d DCA 1990)). Given the vast sums available to Epstein to pursue his meritless litigation,
+he should be directed to pay to
+, Jaffe and Stettin all costs associated with responding to
+12
+
+
+his discovery requests, including reasonable costs of attorney's time and any copying or other
+expenses.
+Because proceedings are on-going in the bankruptcy court regarding these issues,
+is simultaneously giving notice to the bankruptcy court, the trustee, and the Special
+that this pleading is being filed and providing a copy of this pleading to each of them.
+CONCLUSION
+This Court should stay further enforcement of its subpoena to Edwards and to the trustee
+Stettin pending further ruling on the pending summary judgment motion regarding Epstein's
+lawsuit. This Court should also enter a protective order narrowing the scope of Epstein's
+requests and requiring Epstein to pay all reasonable expenses associated with responding to his
+requests. This Court should then grant
+pending summary judgment motion against
+Epstein, and then rule on any surviving privilege or other issues concerning Epstein's subpoenas.
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+Fax and U.S. Mail to all Counsel on the attached list, thi
+Searcy Denney Scarola Barnhart & Shipley
+2y39 Palm Beach Lakes Boulevarc
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for
+J.
+
+
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 659-8300
+Fax: (561) 835-8691
+, Jaffe, Weissing,
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Marc S. Nurik, Esquire
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954) 745-5849
+Fax: (954) 745-3556
+. Ackerman, Jr., Esquire
+Burnett, P.A.
+901
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561) 727-2423
+Fax: (561) 802-9976
+Fistos & Lehrman, PL
+'ERTIFIED COPY
+The Honorable Herbert M. Stettin, Trustee
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+Robert Carney, Special |
+2281 Saratoga Lane
+West Palm Beach, FL 33409
+14
+
+
+JEFFREY EPSTEIN
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT,
+, IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+Complex Litigation, Fla. R. Civ.
+Pro. 1201
+Case No. 50 2009CA040800XXXXMB
+AG
+V.
+Plaintiff,
+SCOTT ROTHSTEIN, individually,
+individually, and L.M., individually,
+Defendants.
+/
+EPSTEIN'S REQUEST TO PRODUCE TO
+Defendant, JEFFREY EPSTEIN ('Epstein"), pursuant to Fla. R. Civ. P. 1.350,
+requests that Defendant,
+J. EDWARDS ("
+), produce or make
+available for inspection documents responsive to the requests below within thirty (30)
+days from the date of service:
+DEFINITIONS AND INSTRUCTIONS
+A.
+"Document" means any written or graphic matter or other means of
+preserving thought or expression, and all tangible things from which information can be
+processed or transcribed, including the originals and all non-identical copies, whether
+different from the original by reason of any notation made on such copy or otherwise,
+including, but not limited to, correspondence, memoranda, notes, messages, letters,
+purchase orders, telegrams, teletype, telefax bulletins, e-mails, electronic data,
+meetings, reports, or other communications, interoffice and intra-office telephone calls,
+diaries, chronological
+data, minutes, books, reports, charts, ledgers, invoices,
+worksheets, receipts, returns, trade information regarding fabric, carpets, samples
+
+
+
+etc... computer printouts, prospectuses, financial statements, schedules, affidavits,
+contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper
+articles, releases (and any and all drafts, alterations and modifications, changes and
+amendments of any of the foregoing), graphs or aural records or representations of any
+kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm,
+video tape, recordings, motion pictures and electronic, mechanical or electric recordings
+or representations of any kind (including, without limitation, tapes, cassettes, discs and
+recordings), and including the file and file cover.
+The term "Document" also means any and all computer records, data, files,
+directories, electronic mail, and information of whatever kind whether printed out or
+stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or
+magnetic-optical disk, computer memory, hard drive, zip drive, jaz drive, orb drive,
+microdisk, external memory stick, software, or any other fixed or removable storage
+media, including without limitation, all back-up copies, dormant or remnant files, and any
+and all miscellaneous files and/or file fragments, regardless of the media on which they
+reside and regardless of whether the data consists in an active file, deleted file, or file
+fragment.
+"Communications" means any oral or written statement, dialogue,
+colloquialism, discussion, conversation or agreement.
+C.
+"Plaintiff" means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County
+Case
+: #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach
+County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein,
+United States District Court Case #08-civ-80893-Marra/.
+), and any other
+person who is or was represented by Rothstein Rosenfeldt & Adler that has not
+2
+
+
+yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for
+any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her
+authority and control.
+D. "RRA" means Rothstein Rosenfeldt & Adler, P.A.
+E. "Money" means any tangible thing of value.
+F.. "Costs" include, but are not limited to, court costs, filing fees, Sheriff's
+service and any other necessary service of legal papers or notices or subpoenas, court
+reporters' charges, long distance telephone charges, postage, courier services or
+Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes,
+Westlaw computerized research, travel expenses, and witness fees and expert witness
+fees and costs.
+"Trustee" means Herbert Stettin as bankruptcy trustee for RRA.
+REQUEST FOR PRODUCTION'
+1.
+For the time period from March 1, 2009 to present, any and all documents
+between, or on behalf of RRA, its employees or agents or clients, and any third party
+regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA
+client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA
+client or Plaintiff
+f, (whether existing clients or fabricated clients), including but not limited
+to:
+a.
+Documents indicating that litigation with Jeffrey Epstein has been
+b.
+C.
+d.
+e.
+settled;
+Soliciting or receiving money in return for settlement funds allegedly
+paid or to be paid by Jeffrey Epstein;
+Soliciting money to help finance ongoing litigation against Jeffrey
+Epstein;
+Soliciting money to be given to, or used on behalf of, the Plaintiffs
+in litigation against Jeffrey Epstein;
+Communication between third party investors or potential investors
+and the Plaintiffs or their attorneys involved in litigation against
+* Due to the potential volume of documents involved, the parties and the Court should consider
+appointment of a special
+and/or an in camera inspection to address any objections, claims of
+privilege and generally manage the production of documents.
+3
+
+
+f.
+Jeffrey Epstein;
+Payments made by RRA to or on behalf of any Plaintiff.
+2.
+following:
+Any and all fee agreements that exist or have existed between the
+a.
+b.
+Any Plaintiff and
+has been associated;
+Any Plaintiff and the law firm RRA.
+or any entity with which he
+J.
+All emails, data, correspondence, memos, or similar documents between
+, Scott W. Rothstein, William Berger and
+Adler and/or any
+attorney or representative of RRA and any investor or third party (person or entity)
+regret defrey Enstein or which ick (Rich) Fafdrey Epstein including Mike Fisten,
+or Rick (Rich) Fandrey).
+J.
+All emails, data, correspondence, memos, or similar documents between
+1, Scott W. Rothstein, and/or any attorney or representative of RRA
+regarding Jeffrey Enstein or which mentions Jeffrey Epstein (including Mike Fisten,
+Kenneth Jenne,
+or Rick (Rich) Fandrey)
+All agreements or documents of any nature which were provided to or
+received from an investor or potential investor relating to any case (real or fabricated)
+involving Jeffrey Epstein and any of the following:
+a.
+b.
+c.
+e.
+Scott W. Rothstein
+J. Edwards
+RRA
+any entity formed by RRA or
+J.
+or Scott W.
+rotnstein to create investment opportunities for third party
+investors to invest in any plaintiff's case against Jeffrey Epstein
+All tee sharing agreements between
+RRA, or Scott
+W. Rothstein and/or any other attorney or investor relating to any aspect of any
+Plaintiff's case.
+All documents made available to any investor or potential investor by
+|. RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to
+solicit "investors" for any case involving Jeffrey Epstein.
+All document reflecting the names and addresses of all individuals or
+entities who invested or purported to invest in any aspect of any case against Jeffrey
+Epstein.
+9.
+All documents evidencing the Costs and payment of any bill or Costs in
+each Plaintiff's case against Jeffrey Epstein, and the source(s) for said payments of any
+Costs.
+4
+
+
+All documents received by you or your current firm wherein the Trustee of
+RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs
+incurred related to the Plaintiffs' cases during the time Plaintiffs' were represented by
+RRA.
+All documents and tangible things retrieved from the trash at 358 El Brillo
+Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein.
+All conversations recorded from any telephones which purported to be that
+of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives,
+hard drives or any other electronic format and any written transcriptions).
+All conversations recorded from any telephones which purported to be
+from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack
+Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard
+drives or any other electronic format and any written transcriptions).
+14. All intercepted phone conversations authorized by RRA including but not
+limited to any one of its attorneys or investigators or anyone retained by or working for
+RRA related to Jeffrey Epstein that are saved or stored in any media (audio tapes, CDs,
+DVDs, zip drives, hard drives or any other electronic format and any written
+transcriptions).
+15.
+All intercepted or acquired electronic mail (e-mails) to or from Jeffrey
+Epstein authorized by RRA including but not limited to any one of its attorneys or
+investigators or anyone retained by or working for RRA.
+All intercepted or acquired electronic mail (e-mails) to and from the
+attorneys for Jeffrey Epstein including but not limited to: Roy Black, Alan Dershowitz or
+Jack Goldberger, authorized by RRA including but not limited to any one of its attorneys
+or investigators or anyone retained by or working for RRA.
+All documents supporting the contention that a sexual assault took place
+on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any
+time between 1998 and 2005.
+All documents related to the amount of all Costs that were incurred by you
+in the répresentation of you and/or your law firm in representing Jane Doe, L.M. and
+E.W. prior to joining RRA.
+All documents setting forth to the amount of Costs were incurred by RRA
+in its representation of Jane Doe, L.M. and E.W. during the time you were employed by
+RRA (or that is being claimed by the Trustee).
+20.
+In the attached transcript dated July 31, 2009, you stated to Judge Hafele
+with regard to the E.W. and L.M. cases the following:
+5
+
+
+"What the evidence is really going to show is that Mr. Epstein - at
+least dating back as far as our investigation resources have permitted,
+back to 1997 or '98 - has every single day of his life, made an attempt to
+sexually abuse children.
+We're not talking about five, we're not talking about 20, we're not
+talking about 100, we're not talking about 400, which I believe, is the
+number known to law enforcement, we are talking about thousands of
+children, and it is through a very intricate and complicated system that he
+devised where he has as many as 20 people working underneath him that
+he is paying well to schedule these appointments, to locate these girls."
+Provide all documents to support this assertion including an
+locuments which are the source of the information
+21.
+All documents related to or mentioning potential deponents in the Jane
+Doe, L.M. or E.W. cases.
+22.
+All documents that support your claim of damages in your counterclaim in
+this case.
+23.
+The written fee agreement with the Searcy Denney firm for their
+representation of you in this case.
+All emails exchanged between you (or anyone of your behalf) and one or
+more of the following individuals wherein Epstein, a Palm Beach billionaire or a similar
+reference was mentioned:
+a.
+b.
+C.
+e.
+f.
+g.
+h.
+i.
+J.
+k.
+Scott Rothstein
+Adler
+William Berger
+Michael Fisten
+Kenneth Jenne
+David Boden
+Deborah
+Andrew Barnett
+Richard (Rick) Fandrey
+Christina Kitterman.
+25.
+A copy of your RRA business card.
+by RA Or a repy enlimen are rente deter agreement or nation ee o
+at RRA.
+6
+
+
+27. All documents and communications from Herbert Stettin, as bankruptcy
+Trustee for RRA, asserting liens against recoveries in:
+L.M. v. Epstein, Case No. 502008CA028051XXXXMB
+E.W. v. Epstein, Case No. 502008CA028058XXXXMB
+c.
+Jane Doe v. Epstein, Case No. 08-CV-80119-MARRA/JOHNSON
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
+Mail to the following addressees on this 12th day of _April
+_, 2010:
+Gary M.
+,Jr., Esq
+1 Jaffe, Weissing,
+& Lehrman, PL
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+954-524-2820
+954-524-2822 - fax
+Attorneys for Defendant, L.M.
+Jack Scarola, Esq.
+Searcy
+Denney Scarola
+Shipley, P.A
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+686-6300
+383-9424 F
+Attorneys for Defendant
+, Fistos
+Jack Alan Goldberger, Esq.
+Atterbury Goldberger & Weiss, P.A
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401-5012
+Fax: 561-835-8691
+Co-Counsel for Defendant Jeffrey Epstein
+MARC S. NURIK, ESQ.
+Barnhart &
+Law Offices of Marc S. Nurik
+One East Broward Boulevard
+Suite 700
+Fort Lauderdale, FL 33301
+954-745-5849
+954-745-3556 Fax
+Attorneys for Defendant Scott Rothstein
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Banyan Boulevard
+Suite 400
+West Palm Beach, FL 33401
+(561) 848-2820
+NOT
+Robert D. Critton, Jr.
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+(Counsel for Defendant Jeffrey Epstein)
+7
+
+
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually,
+and L.M., individually,
+Defendant.
+DEFENDANT
+J. EDWARDS RESPONSE TO PLAINTIFF'S REQUEST
+FOR PRODUCTION DATED APRIL 12, 2010
+Defendant,
+J.
+hereby files his. Response to Request for
+Production propounded by Plaintiff on April 12, 2010 as follows:
+None.
+a.
+3.
+5.
+Objection, relevance, not reasonably calculated to lead to the
+discovery of admissible evidence.
+None.
+Objection as to communications to or from investigators as that is
+protected by the work-product and or attorney-client privilege.
+Objection; any such communications are protected by the work-product
+and /or attorney-client privilege.
+None.
+Objection, relevance, not reasonably calculated to lead to the
+discovery of admissible evidence; vague; overbroad, without waiving
+objection, there are no fee agreements with any investor.
+
+
+
+None.
+8.
+10.
+None.
+Divery of admisle, evde reasonably calculated to
+lead
+to
+r the
+Objection, relevance, not reasonably calculated to
+lead to the
+discovery of admissible evidence.
+11.
+12.
+None.
+None.
+13.
+None.
+14.
+None.
+TIFIE
+15.
+None.
+16.
+None.
+17.
+Objection,
+relevance, not reasonably calculated to lead to the
+discovery of admissible evidence; vague; overbroad, ambiguous.
+18.
+Objection, relevance, not reasonably calculated to lead to the
+discovery of admissible evidence.
+19.
+Objection, relevance,
+not reasonably calculated to lead to the
+discovery of admissible evidence and protected by the work-product
+privilege.
+20,
+Objection, vague overbroad and any and all such documents are
+protected by the work-product privilege.
+21.
+Objection, vague overbroad and any and all such documents are
+protected by the work-product and attorney-client privilege.
+22.
+Not yet determined
+2
+
+
+Case No: 502009CA040800XXXXMBAG
+23.
+Objection.
+24.
+Objection; attorney-client privilege and/or work-product privilege.
+25.
+None in Defendant's possession.
+26.
+None.
+27.
+None in Defendant's possession.
+3
+
+
+* Response to Request for Production dated 4/12/10
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been
+furnished via U.S. Mal to all counsel on the attached list on pal.
+- 2010
+Jack Scarola
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+Attorneys for Defendant,
+2139 Palm Beach Lakes Boulevard
+W
+lest Palm Beach, Florida 33409
+Phone: (561) 686-6300
+By:
+(
+NOT A CERTAIN
+4
+
+
+COUNSEL LIST
+Robert D. Critton, Jr., Esquire
+West Palm Beach, FL 33401
+Phone: (561)-842-2820
+Fax: (561)-844-6929
+Attorneys for Jeffrey Epstein
+Jack Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Gary M.
+Jaffe, Weissing, Edwards,
+Fistos & Lehrman, P.L.
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+Attorneys for L.M.
+Marc Nurik,
+Law Offices of Marc S. Nurik
+One East Broward Boulevard, Suite 700
+Fort Lauderdale, FL 33301
+Phone:
+954-745-5849
+Fax: 954-745-3556
+Counsel for Scott Rothstein
+ERTIFIED COPY
+5
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 1 of 8
+Fort Lauderdale Division
+www.flsb.uscourts.gov
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+Chapter 11
+Op
+JEFFREY EPSTEIN'S MOTION TO COMPEL
+PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO
+DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE #672
+JEFFREY EPSTEIN ("EPSTEIN"), by and through undersigned counsel, respectfully moves
+this Honorable Court pursuant to the provisions of Fed.R.Civ.37(a) (which is incorporated into
+bankruptcy practice by Fed.R.Bankr.P. 7037), for an Order compelling HERBERT STETTIN
+("STETTIN"), the Chapter 11 Trustee for the Estate of ROTHSTEIN ROSENFELDT ADLER, P.A.
+("RRA"), (a) to comply with the Document Production Protocol established by this Court at his
+request; (b) to produce documents pursuant to a Subpoena served upon him in a state court matter
+on April 17,2010, and (e) where apropriate to fumish a Privilege Log In suppor thereof,
+EPSTEIN would respectfully submit the following:
+This Court, by virtue of the Order which established the Document Production
+Protocol (DE #672) has taken jurisdiction over all discovery sought of the Trustee. This Court
+generally has jurisdiction over such matters by virtue of 28 U.S.C.§§ 152 and 1334.
+2.
+On May 6, 2010, STETTIN moved for expedited relief sceking a Protective Order
+with respect to discovery which had been served upon him by one group of creditors, and in doing
+BURNET
+
+ORIDA 33131-3302 - (305) 789-9200
+
+
+Case 09-34791-RBR Doc 807
+Filed 07/14/10 Page 2 of 8
+so requested approval of a proposed Document Production Protocol to be used across the board with
+respect to future document requests that he anticipated receiving from third parties, both within and
+outside this bankruptcy case (DE #617).
+3.
+On May 18, 2010, this Court entered an "Order Granting Trustee's Motion Seeking
+a Protective Order and Approving Proposed Document Production Protocol" (DE #672). This Order
+established the process for anyone wishing discovery from the Trustee. Its operation is not limited
+to discovery in the bankruptcy case. Moreover, that Order at paragraph 7, retained jurisdiction with
+respect to all matters arising from or related to the implementation or interpretation of said Order;
+i.e., all discovery sought from the Trustee, without any limitation on the forum.
+EPSTEIN is currently a party Plaintiff to a lawsuit in the Circuit Court of the
+Fifteenth Judicial Circuit, in and for Palm Beach County, Florida, Case No. 50-2009 CA
+040800XXXX MB AG. The action is entitled Jeffrey Epstein, Plaintiff vs. Scott Rothstein,
+individually,
+, individually, and L.M., individually.
+5.
+On or about April 17, 2010, counsel for EPSTEIN in the state court had served a
+Subpoena Duces Tecum for Déposition - Documents Only, on STETTIN in his capacity as Trustee,
+in an attempt to obtain documents relevant to issues in the state court case. A paralegal from
+BERGER SINGERMAN P.A., counsel for the Trustee, wrote to one of the counsel involved in the
+state court indicating that the Trustee had retrieved approximately six-thousand (6,000) emails that
+might be responsive to the Subpoena described above. The paralegal, one LUIS|
+2
+BURNETT P.A. - ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14" FLOOR, MIAMI, FLORIDA 33131-3302 • (305) 789-9200
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 3 of 8
+'), indicated that he anticipated finalizing review of the emails for attorney/client
+privilege information by May 28, 2010, and intended to produce the documents along with the
+Privilege Logby May 31, 2010 (Exhibit "A" attached -
+letter). He verbally indicated that
+he had further responsive documents other than emails.
+6.
+It did not happen.
+In the meantime, on May 6, 2010, the Trustee had filed his Motion in this Court
+seeking to establish the Document Production Protocol and this Court entered its Order (DE #672
+supra).
+8.
+On the strength of the "Document Production Protocol" Trustee's counsel now
+demanded that Movant enter into a Joint Motion for Entry of Stipulated Protective Order and a
+Protective Order - the forms established by the Order setting the Document Production Protocol.
+Movant's counsel forwarded to TORRES, the paralegal, and CHARLES LICHTMAN, ESQ., the
+executed Joint Ex Parte Motion and the proposed Stipulated Protective Order. Counsel for the
+Trustee did not file them, nor have they ever produced the required information (notwithstanding that
+had written that the materials would be ready before the end of May 2010).
+9.
+Production of these documents from the Trustee is critical to issues in the state court
+lawsuit.
+Without access to the emails in question, Movant will suffer unfair prejudice and will be
+unable to obtain information critical to his lawsuit. To date, the Trustee apparently claims privilege
+over all of these documents, but no Privilege Log has ever been provided. In addition, there is the
+potential that the "crime-fraud exemption" to the attorney/client privilege would ultimately apply
+rendering any claimed privilege, even one that is improperly claimed, to be moot.
+3
+| BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14"I FLOOR, MIAMI, FLORIDA 33131-3302 • (305) 789-9200
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 4 of 8
+10.
+Movant is willing to reimburse the Estate for its reasonable expenses incurred in
+reviewing the documents for privileged matters and preparing a Privilege Log.
+Counsel for Movant certifies that we have communicated with Trustee and his
+counsel in an effort to resolve this issue prior to filing this Motion.
+WHEREFORE, Movant respectfully prays that this Court (a) enter the standard stipulated
+Protective Order so that Movant will be in compliance with the Document Production Protocol; and
+(b) order the Trustee to comply with the Subpoena originally served on April 17, 2010 - almost three
+(3) months ago.
+espectfully submitte
+Rorald G. Neiwirth
+CE
+• Fla. Bar No. 152175
+BURNETT P.A
+Espirito Santo Plaza, 14* Floor
+1395 Brickell Avenue
+Miami, Florida 33131-3302
+Telephone: (305) 789-9200
+Facsimile: (305) 789-9201
+Attorneys for Jeffrey Epstein
+4
+BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14" FLOOR, MIAMI, FLORIDA 33131-3302 • (305) 789-9200
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 5 of 8
+CERTIFICATE OF SERVICE
+IHEREBY CERTIFY that on July 14, 2010, I electronically filed the foregoing document with
+the Clerk of the Court using CM/ECF. I also certify that the foregoing document is being served this
+day on all counsel of record or pro se parties identified on the attached Service List in the manner
+specified, either via transmission of Notices of Electronic Filing generated by CM/ECF or in some
+other authorized manner for those counsel or parties who are not authorized to receive electronically
+Notices of Electronic Filing.
+Ronald
+tonald
+G.
+Neiviwith
+CERTIFI
+5
+BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14T* FLOOR, MIAMI, FLORIDA 33131-3302 • 305) 789-9200
+
+
+Case 09-34791-RBR Doc 807. Filed 07/14/10 Page 6 of 8
+CELE
+STING
+4 reas
+BERGER SINGERMAN
+attorneys at law
+ACK.
+MOVING
+FOBWARD
+Boca Raton Fort Lauderdale Miami Tallahassee
+(934) 713-5127
+Lones @bergersingerman.com
+May 21, 2010
+VIA FACSIMILE AND E-MAIL
+Lobert D. Critton, Jr., Esq
+David A. Yarema, Esq
+BURMAN, CRITTON, LUTTIER & COLEMAN
+515 N. Flagler Drive, Suite 400
+West Palm Beach, FL 33401
+COPY
+Re:
+Subpoena Directed to Herbert Stettin in the case styled L.M. V. Jeffrey Epstein,
+Case No. 502008CA028051XXXXMB AD
+Dear Mr. Critton and Mr. Yarema:
+Pursuant to the subpoena directed to Herbert Stettin ("Trustee") dated April 16, 2010
+("Subpoena") and the various communications we have had regarding the search parameters to
+be utilized in order to comply with the Subpoena, please be advised that the Trustee has retrieved
+approximately 6000 e-mails that might be responsive to the Subpoena: We want to make clear
+that the Trustee does not have the capability to run electronic searches over all of RRA's
+documents. Therefore, the 6000 e-mails which have been identified are from Scott Rothstein's
+Edward's e-mail accounts/ We anticipate finalizing the review of e-mails for
+attorney-client privilege information by Friday, May 28, 2010, and we intend to produce
+responsive documents, along with a privilege log, by Monday, May 31, 2010.
+Should you
+have
+any questions or concerns, please feel free to contact me at
+954.712.5127.
+Sincerely,
+BERGER SINGERMAN
+Luis
+Litigation Paralegal
+cc:
+James C. Cunningham, Jr., Esq.
+ANDREW HANKUS
+
+360 East Las Olas Boulevard Suite 1000 Fort Lauderdale, Florida 33301 Telephone 954-525-9900 Facsimile 9.
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 7 of 8
+Berger Singerman P.A.
+350 East Las Olas Blvd., # 1000
+Ft. Lauderdale, FL 33301 (Via CM/ECF and email)
+Marianella Morales, Esq.
+Avenida Francisco de Miranda
+Torre Provincial "A", Piso 8
+Caracas, Venezuela
+(Via CM/ECF)
+John H. Genovese, Esq.
+Bank of America Tower at International Place
+100 S.E. 2* Street, # 4400
+Miami, FL 33131
+(Via CM/ECF)
+Office of the U.S. Trustee
+51 S. W. First Avenue, # 1204
+Miami, FL 33130
+(Via CM/ECF)
+Tew
+Tew, Esq.
+1, LLP
+Four Seasons Tower, 15 FL
+1441 Brickell Avenue
+Miami, FL 33131
+(Via CM/ECF)
+Conrad & Scherer, LLP
+Ft. Lauderdale, FL 33301
+(Via CM/ECF)
+Michael D. Seese, Esq.
+Hinshaw & Culbertson, LIP
+1 E Broward Blvd., # 1010
+Ft. Lauderdale, FL 33301 (Via CM/ECF)
+William
+Salim, Jr.
+Moskowitz Mandell & Salim
+800 Corporate Dr., # 510
+Ft. Lauderdale, FL 33334 (Via CM/ECF)
+Special Assistant U.S. Attorney
+P.O. Box 9 Stop 8000
+51 S.W. 1ª Avenue, # 1114
+Miami, FL 33130
+(Via U.S. Mail)
+Kendall Coffey, Esq.
+Office in the Grove - Penthouse
+2699 South Bayshore Drive
+Miami, FL 33133
+(Via CM/ECF)
+The Honorable Herbert Stettin
+One Biscayne Tower, # 3700
+Two South Biscayne Blvd.
+Miami, FL 33131
+(Via U.S. Mail and email)
+John G. Bianco, Esq.
+Tripp Scott
+110 S.E. Sixth Street, 15* FL
+Fl. Lauderdale, FL 33301
+(Via CM/ECF)
+Alison W. Lehr, Esq.
+Assistant U.S, Attorney
+99 N.E. 4" Streei, 7' FL
+Miami, FL 33132
+(Via CM/ECF)
+Jeffrey S. Sonn, Esq.
+Sonn & Erez, PLC
+Broward Financial Center
+500 E. Broward Blvd., # 1600
+Ft. Lauderdale, FL 33394
+(Via CM/ECF)
+Honorable Jeffrey HI. Sloman
+Acting U.S. Attorney
+99 N.E. 4" Street
+Miami, FL. 333132
+(Via U.S. Mail)
+Internal Revenue Service
+Centralized Insolvency Operations
+POB 21126
+Philadelphia, PA 19114
+(Via U.S. Mail
+Daniel Mink
+Ovadia Levy
+c/o Renato Watches, Inc.
+14051 N.W. 14 Street
+Sunrise, FL 33323
+(Via U.S. Mail)
+6
+BURNETT P.A. « ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14"' FLOOR, MIAMI, FLORIDA 33131-3302 - (305) 789-9200
+
+
+Case 09-34791-RBR Doc 807 Filed 07/14/10 Page 8 of 8
+USI
+Attn: Anthony Gruppo
+200 West Cypress Creek Road, # 500
+Ft. Lauderdale, FL 33309
+Anthony.gruppo@usi.biz.
+United Healthcare
+Department CH 10151
+Palatine, IL 60055
+Special Assistant U.S. Attorney
+IRS District Counsel
+1000 S. Pine Island Road, # 340
+Plantation, FL 33324-3906
+(Via email)
+(Via U.S. Mail)
+(Via U.S. Mail)
+County Tax Collector
+315 S. Calhoun Street, #210
+Tallahassee, FL 32301
+Miami-Dade County Tax Collector
+140 W. Flagler Street, 14* Floor
+Miami, FL 33130
+(Via U.S. Mail)
+(Via U.S. Mail)
+Palm Beach County Tax Collector
+P.O. Box 3715
+West Palm Beach, FL 33402-3715 (Via U.S. Mail)
+Carpenter & Berger, PL
+6400 N. Andrew Avenue, # 370
+Ft. Lauderdale, FL 33309
+(Via U.S. Mail)
+Mark S. Haltzman, Esq.
+Lamm Rubenstone, LIC
+3600 Horizon Blvd., # 200
+Trevose, PA 19053
+mhaltzman@lammrubenstone.com (Via email and
+U.S. Mail)
+John Scarola, Esq.
+2139 Palm Beach Lakes Blyd.
+West Palm Beach, FL 33409-6661
+mep@searchlaw.com
+(Via email and U.S. Mail)
+The Honorable Eric H. Holder, Jr.
+Attorney General of the U.S.
+50 Pennsylvania Avenue, NW, Room 440(
+Nashington, DC 20530-0001
+(Via U.S. Mail)
+Marc Nurik, Esq.
+1 East Broward Blvd., # 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+(Via email)
+Bast Amron LIP
+SunTrust International Center
+One S.E. Third Avenue, # 1440
+Miami, FL 33131
+(Via CM/ECF)
+F. McGinn, Esq.
+Barlett Hackett Feinberg, P.C.
+155 Federal Street, 9* FL
+Boston, MA 02110
+(Via CM/ECF)
+Darol H.M. Carr, Esq.
+99 Nesbit Street
+Punta Gorda, FL 33950
+(Via CM/ECF)
+Jane A. Bee, Esq.
+Blank Rome LLP
+130 North 18" Street
+Philadelphia, PA 19103-6998
+bee@blankrome.com
+(Via email)
+Roderick F. Coleman, Esq.
+400 S. Dixie Highway, # 121
+Boca Raton, FL 33432
+(Via CM/ECF)
+Robert C. Buschel, Esq.
+100 S.E. Third Avenue, # 1300
+Ft. Lauderdale, FL 33394
+buschel@bglaw.pa.com (Via email and U.S. Mail)
+7
+BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14'' FLOOR, MIAMI, FLORIDA 33131-3302 • (305) 789-9200
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 1 of 10
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+MOTION FOR PROTECTIVE ORDER TO EXCLUDE THE PRODUCTION FROM
+TRUSTEE STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO
+JEFFREY EPSTEIN
+Movant, L.M., moves this Court pursuant to 11 U.S.C. §105(a), Federal Rules of
+Bankruptcy Procedure Rule 7026 (which expressly incorporates Fed.R.Civ. P. 26(c)), and L.R.
+7026-1 to request that the Court enter a protective order excluding the Trustee's production of
+any documents to Jeffrey Epstein because all requested documents are subject to a claim of
+attorney-client privilege and/or attorney work product, and in support thereof, states as follows:
+I.
+Introduction
+1.
+Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this
+honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the
+Circuit Court over a subpoena duces tecum issued by the state court in connection with an action
+pending before the state court.
+Movant, L.M., respectfully requests that this honorable Court enter a protective order,
+consistent with the document production methodology already ordered by the Court [D.E. 672],
+deny Epstein's motion to compel, and prevent the Trustee's production to Epstein of any
+documents or ESI sought through his state court subpoena since such production consists entirely
+of documents and ESI which are subject to proper claims of attorney-client communications
+
+
+
+Case 09-34791-RBR Doc 818
+Filed 07/19/10 Page 2 of 10
+privilege and/or attorney work product.
+II. Background
+3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey
+Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when
+she was a minors. The parties recently reached a confidential settlement of this lawsuit on the
+eve of trial.
+4.
+Movant's counsel, Brad
+was employed by RRA. During this time Attorney
+securely and confidentially maintained hard-copies of certain file materials and
+maintained substantial parts of client case files and investigative files in the Qtask application
+and other software systems maintained by RRA.?
+5.
+This Court has entered other Orders in this case to preserve the privileges of RRA's
+former clients. See Order Granting Motion for Protective Order, D.E. 672.
+6. Epstein filed a lawsuit against Scout W. Rothstein, L.M.'s counsel Brad |
+- and
+L.M. individually.? Epstein has sought to prove up his meritless claims against Attorney
+and L.M., in part, by invoking his Fifth Amendment privilege in deposition in this case
+seventy-seven times.*
+7.
+On Date, Ep
+counsel had a subpoena duces tecum issued from the Circuit Court in
+'L.M. v. Epstein, Case #08-CA-28051, 15"* Judicial Circuit in and for Palm Beach County,
+Florida. Attorney Brad
+is plaintiff's counsel in this lawsuit. Epstein was also a party
+defendant in dozens of other civil lawsuits prosecuted by other woman who allege that Epstein
+sexually exploited, abused, and/or assaulted them when they were minors.
+' See Motion for Protective Order to Exclude Production of Privileged Documents and
+Testimony from Qtask, Inc. [D.E. 355].
+3 Epstein v. Rothstein, et al., Case #09-CA-040800-MBAG, 15"h Judicial Circuit in and for Palm
+Beach County, Florida.
+"Dep. Jeffrey Epstein, Epstein v. Rothstein, et al., March 17, 2010, p. 6 - 128.
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 3 of 10
+Epstein v. Rothstein, et al. seeking production from Trustee Herbert Stettin of Attorney |
+case files and investigative files which relate to L.M. and his other legitimate clients who
+possessed bona fide claims or potential claims against Epstein.
+8. On Date, L.M., through counsel, filed objections to the subpoena in the Circuit Court.
+9. Likewise, L.M. filed a motion for protective order in the Circuit Court where the subject
+subpoena had been issued.
+10. In addition, the Trustee filed a motion for protective order in the Circuit Court.
+11.
+Thereafter, the Circuit Court entered an agreed order on these motions for protective
+order protecting privileged and work product materials from production to Epstein.
+12.
+Now, Epstein has come to the Bankruptcy Court to pursue the discovery of privileged
+and attorney work product materials which the Circuit Court would not allow. See Epstein's
+Motion to Compel, DE 807.
+III.
+Memorandum of Law
+A. Discovery Issues Related to the State Court Issued Subpoena Are
+Not Properly Before the Bankruptcy Court
+Despite Epstein's stated position to the contrary, neither 28 U.S.C. §§ 152 or 1334 confer
+jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state
+law claims filed in state court which are not before the Bankruptcy Court. Epstein seeks to
+perform an end run around the Circuit Court's proper exercise of its jurisdiction to adjudicate
+matters pending before it, including subpoenas issued from that court. Moreover, the honorable
+Circuit Court has already ruled on a motion for protective order on the subject state court issued
+subpoena duces lecum. Accordingly, for reasons of comity, this honorable Court should deny
+Epstein's motion to compel.
+3
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 4 of 10
+B. The Discovery Sought is Privileged and/or Attorney Work Product and Beyond
+the Permissible Scope of Discovery
+Privileges are invoked by the client who possesses the privilege or by the attorney on
+behalf of the client.
+i.
+Scope of Permissible Discovery
+Rule 26(b) excludes privileged matters from the scope of permissible discovery, Epstein
+seeks the production of documents from clients' privileged case files and investigative files.
+These documents are beyond the scope of discovery permitted by Rule 26(b).
+ii. Protective Orders
+Rule 26(c) states that a court may protect a party or person from whom discovery is
+sought, based on "good cause shown:"
+A party or any person from whom discovery is sought may move for a
+protective order in the court where the action is pending — or as an alternative
+on matters relating to a deposition, in the couft for the district where the
+deposition will be taken. The motion must include a certification that the
+movant has in good faith conferred or attempted to confer with other affected
+parties in an effort to resolve the dispute without court action. The court may,
+for good cause, issue an order to protect a party or person from annoyance,
+embarrassment, oppression, or undue burden or expense, including one or
+more of the following:
+(A) forbidding the disclosure or discovery;
+(B) specifying terms, including time and place, for the disclosure or
+discovery; y
+(C) prescribing a discovery method other than the one selected by the
+party seeking discovery;
+(D) forbidding inquiry into certain matters, or limiting the scope of
+disclosure or discovery to certain matters;
+(E) designating the persons who may be present while the discovery is
+conducted;
+(F) requiring that a deposition be sealed and opened only on court
+(G) requiring that a trade secret or other confidential research,
+development, or commercial information not be revealed or be
+revealed only in a specified way; and
+4
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 5 of 10
+(H) requiring that the parties simultaneously file specified documents
+or information in sealed envelopes, to be opened as the court directs.
+Fed.R.Civ.P. 26(c)
+Epstein seeks the production from the Trustee of privileged, confidential, and attorney
+work product materials from the case files and investigative files of L.M. and other clients who
+possess claims against Epstein. The requested documents, relating to the bona fide cases of
+clients are not relevant or calculated to lead to the discovery of admissible evidence in the instant
+bankruptcy action or any adversary proceeding presently before this Court. Therefore, the
+requested documents are beyond the scope of permissible discovery.
+The requested materials
+are not discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil
+Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of
+rules. Moreover, the document production methodology established by order of this Court was
+not intended to be a conduit of privileged and work product of RRA's former clients to the
+clients' litigation adversaries. Epstein's counsel distorts and misrepresents the purpose of the
+document production methodology by arguing that it was created to facilitate such improper
+discovery.
+Epstein's counsel further attempts to skirt the issue of privilege by failing to meaningfully
+identify the nature of the requested materials, other than describing "emails" and documents
+"other than emails". The materials requested by Epstein, essentially case files, client files, and
+investigative files are patently and obviously privileged. Epstein's counsel offers no argument,
+cognizable under any set of possibly applicable rules, to demonstrate entitlement to these
+privileged and work product materials.
+WHEREFORE, based on the foregoing, Epstein is not permitted to obtain production of
+5
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 6 of 10
+documents and ESI from the Trustee which comprise the privileged, confidential, or attorney
+work product portions of case files or investigative files, and Movant requests that the Court
+deny Epstein's motion to compel, grant the foregoing motion for protective order, and enter a
+protective order excluding the production of any documents or ESI by the Trustee which relate to
+any cases or matter of L.M. or other clients and granting any other relief the Couft deems
+appropriate to protect the clients of
+Jaffe Weissing.
+I HEREBY CERTIFY that, pursuant to L.R. 9073-1(D), Movant's counsel has
+contacted Epstein's counsel in a good faith attempt to resolve the matter without a hearing and I
+further certify that a true and correct copy of the foregoing was served on electronically to the
+examinee, the debtor, the attorney for the debtor, the trustee, all CM/ECF subscribers, and by
+email or U.S. Mail on those parties listed on the attached service list this 19th day of July, 2010.
+I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court
+for the Southern District of Florida and I am in compliance with the additional qualifications to
+practice in this court set forth in Local Rule 2090-1(A).
+JAFFE, WEISSING,
+_, FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+(954)524-2820 Telephone
+(954)524-2822 Facsimile
+By: Is/Seth Lehrman
+Seth Lehrman FLBN 132896
+seth@pathtojustice.com
+6
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 7 of 10
+Marianella Morales, Esquire (VIA EMAIL)
+Alison W. Lehr (VIA EMAIL)
+Authorized Agent For Joining Creditors
+Assistant United States Attorney
+Avenida Francisco de Miranda
+99 N.E. 4th Street
+Torre Provincial "A"
+7th Floor
+Piso 8
+Miami, Florida 33132
+Caracas, Venezuela
+Phone: (305) 961-9176
+Fax: (305) 536-7599
+Alison.Lehr@usdoj.gov
+John H. Genovese, Esq. (VIA CM/ECF)
+Robert F. Elgidely, Esq.
+Theresa M.B. Van Vliet, Esq.
+Genovese Joblove & Battista, PA
+Bank Of America Tower at International
+Place
+100 S.E. 2nd Street
+Suite 4400
+Miami, Florida 33131
+Phone: (305) 349-2300
+Fax (305) 349-2310
+Kendall Coffey, Esq. (VIA EMAIL)
+Coffey Burlington,
+Office in the Grove
+Penthouse
+2699 South Bayshore Drive
+Miami, Florida 33133
+kcoffey@coffeyburlington.com
+Hon. Herbert M. Stettin (VIA EMAIL)
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+John G. Bianco, Esq. (VIA CM/ECF)
+John M. Multi, Esquire
+Tripp Scott
+110 Southeast Sixth Street
+Fifteenth Floor
+Fort Lauderdale, Fl. 33301
+jgb@trippscott.com
+Stuart A. Rosenfeldt, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, PA
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, Florida 33301
+srosenfeldt@rra-law.com
+Jeffrey R. Sonn, Esq. (VIA EMAIL)
+Sonn & Erez, PLC
+Bro
+Financial Center
+500 E. Broward Boulevard
+Suite 1600
+Fort Lauderdale, Florida 33394
+Phone: (954) 763-4700
+Fax (954) 763-1866
+jsonn@sonnerez.com
+Office of the US Trustee (VIA CM/ECF)
+51 Southwest First Avenue
+Suite 1204
+Miami, Florida 33130
+Tew, Esq. (VIA EMAIL)
+Maynard Gollin, Esq.
+Tew-
+I, LLP
+Four Seasons Tower
+15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131-340
+t@tewlaw.com
+Img@tewlaw.com
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 8 of 10
+Conrad & Scherer, LLP (VIA EMAIL)
+Fort Lauderdale, FL 33301
+Tel: 954-462-5500
+bs@conradscherer.com
+JSilver@conradscherer.com
+Michael D. Seese, Esq. (VIA EMAIL)
+Hinshaw & Culbertson, LLP
+1 E Broward Blvd Ste 1010
+Ft Lauderdale, Florida 33301
+Tel: 954.4677900
+Fax: 954.4671024
+mseese@hinshawlaw.com
+Internal Revenue Service
+Centralized Insolvency Operations
+P.O. Box 21126
+Philadelphia, PA 19114
+(Via U.S. Mail)
+Internal Revenue Service
+Special Procedures - Insolvency
+7850 SW 6th Court
+Plantation, FL 33324
+Tel.: (954) 423-7300
+Fax.: (305) 982-5406
+(Via U.S. Mail)
+Special Asst. U.S. Attorney
+P.O. Box 9, Stop 8000
+51 SW Ist Avenue, #111
+Miami, FI 33130
+Faia U5. 130-7139
+(Via U.S. Mail)
+Grant J. Smith, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, P.A.
+401 East Las Olas Blvd
+Suite 1650
+Fort Lauderdale, FL 33301
+gsmith@rra-law.com
+United Healthcare
+Dept. CH 10151
+Palatine, IL 60055
+Plantation, FL 33324-3906
+(Via U.S. Mail)
+The Honorable Eric H. Holder, Jr.
+ttorney General of the U.
+50 Pennsylvania Avenue, NW Room 44(
+Washington, DC 20530-0001
+(Via U.S. Mail)
+Honorable Jeffrey H. Sloman,
+Acting U.S. Attorney
+99 NE 4th Street
+Miami, FI33132
+(Via U.S. Mail)
+Daniel Mink
+Ovadia Levy
+c/o Renato Watches, Inc
+14051 NW 14th Street
+Sunrise, Florida 33323
+(Via U.S. Mail)
+William
+Salim, Jr. (VIA CM/ECF)
+Moskowitz Mandell & Salim
+800 Corporate Dr Ste 510
+Fort Lauderdale, Florida 33334
+wsalim@mmsslaw.com
+Tel: 954.491-2000
+Fax: 954.4912051
+USI (VIA EMAIL)
+Attn: Anthony Gruppo
+200 West Cypress Creek Road
+Suite 500
+Fort Lauderdale, FL 33309
+Tel: 954-607-4000
+Anthony.gruppo@usi.biz
+8
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 9 of 10
+Marc Nurik, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, P.A
+401 East Las Olas Blvd
+Fort Lauderdale, FL 33301
+mnurik@rra-law.com
+BAST AMRON LLP (VIA CM/ECF)
+SunTrust International Center
+One Southeast Third Avenue
+Suite 1440
+Miami, Florida 33131
+Telephone: (305) 379-7904
+Facsimile: (305) 379-7905
+bamron@bastamron.com
+jbast@bastamron.com
+Mark Bloom, Esq. (VIA EMAIL)
+Greenberg Traurig, LLP
+1221 Brickell Avenue
+Miami, FL 33131
+T 305.579.0500
+F 305.579.0717
+bloomm@gtlaw.com
+Robert D. Critton, Esq. (VIA EMAIL)
+Burman, Critton, Luttier & Coleman
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+rcrit@bclclaw.com
+Roth & Scholl (VIA EMAIL)
+Attn: Jeffrey C. Roth, Esq.
+Attorneys For Creditor Blue
+Capital Us East Coast Properties, L.P.
+866 South Dixie Highway
+Coral Gables, FI 33146
+Telephone: (305) 662-4141
+jeff@rothandscholl.com
+Rogers, Morris & Ziegler, LLP (VIA
+EMAIL)
+1401 East Broward Blvd
+Suite 300
+Fort Lauderdale, FL 33301
+Tel: (954) 462-1431
+Fax: (954) 763-2692
+mfbooth@rmzlaw.com
+Arthur C. Neiwirth, Esq. (VIA CM/ECF)
+One E. Broward Blvd., Suite 1400
+Ft. Lauderdale, FL 33301
+Tel: (954) 523-7008
+Fax: (954) 523-7009
+aneiwirth@apwblaw.com
+The Florida Bar (VIA EMAIL)
+Adria E. Quintela, Esq.
+Alan Anthony Pascal, Esq
+Lake Shore Plaza I
+1300 Concord Terrace, Suite 130
+Sunrise, FL 33323
+aquintel@flabar.org
+apascal@flabar.org
+Micheal w. Moskowitz, Esq. (VIA E-
+MAIL)
+800 Corporate Drive, Suite 500
+Ft. Lauderdale, FL 33234
+mmoskowitz@mmsslaw.com
+Francis L. Carter, Esq. (VIA E-MAIL)
+Katz Barron Squitero Faust
+2699 S. Bayshore Drive, 7th Floor
+Miami, Florida 33133
+Tel: 305-856-2444
+Fax: 305-285-9227
+flc@katzbarron.com
+S. Shraiberg, Esq. (VIA EMAIL)
+2385 NW Executive Drive
+Suite 300
+Boca Raton, Florida 33431
+Tel: 561-443-0800
+Fax: 561-998-0047
+bshraiberg@sfl-pa.com
+9
+
+
+Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 10 of 10
+Henry S. Wulf, Esq. (VIA EMAIL)
+CARLTON
+P.A.
+525 Okeechobee Blvd., Suite 1200
+West Palm Beach, Florida 33401
+Telephone: (561) 659-7070
+Facsimile: (561) 659-7368
+E-Mail: hwulf@carltonfields.com
+Ira Sochet, Trustee (VIA EMAIL)
+c/o Phil Hudson, Esq.
+200 South Biscayne Blvd, Suite 3600
+Miami, Florida 33130
+Telephone: (305) 374-3330
+Facsimile: (305) 374-4744
+E-Mail: pmhudson@arnstein.com
+EMESS Capital, LLC (VIA EMAIL)
+c/o Bruce A. Katzen, Esq.
+201 S. Biscayne Blvd., 17th Floor
+Miami, Florida 33131
+Telephone: (305) 379-9000
+Facsimile: (305) 379-3428
+E-Mail: bkatzen@klugerkaplan.com
+Coquina Investments (VIA EMAIL)
+c/o Patricia A. Redmond, Esq.
+150 West Flagler Street, Suite 2200
+Miami, Florida 33130
+Telephone: (305) 789-3553
+Facsimile: (305) 789-3395
+E-Mail: predmond@steatnsweaver.com
+Ronald Neiwirth, Esq. (VIA EMAIL)
+L. Ackerman, Jr., Esq.
+& Burnett, P.A.
+777 S. Flagler Dr. ,Ste 901
+W. Palm Beach, FL 334016170
+Email:
+meiwirth@
+CERTIFIED
+10
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 1 of 10
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+PRODUCTION TO SOR TO ORDERED NISAND
+TESTIMONY TO JEFFREY EPSTEIN
+Movant, L.M., moves this Court pursuant to 11 US.C, §105(a), Federal Rules of
+Bankruptcy Procedure Rule 7026 (which expressly incorporates Fed.R.Civ. P. 26(c)), and L.R.
+7026-1 to request that the Court enter a protective order exeluding the Trustee's production of
+any documents to Jeffrey Epstein because all requested documents are subject to a claim of
+attorney-client privilege and/or attorney work product, and in support thereof, states as follows:
+1.
+Introduction
+1.
+Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this
+honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the
+Circuit Court over a subpoena duces tecum issued by the state court in connection with an action
+pending before the state court.
+Movant, L.M., respectfully requests that this honorable Court enter a protective order,
+consistent with the document production methodology already ordered by the Court [D.E. 672),
+deny Epstein's motion to compel, and prevent the Trustee's production to Epstein of any
+documents or ESI sought through his state court subpoena since such production consists entirely
+of documents and ESI which are subject to proper claims of attorney-client communications
+
+
+
+Case 09-34791-RBR Doc 819
+Filed 07/19/10 Page 2 of 10
+privilege and/or attorney work product.
+II. Background
+3.
+Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey
+Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when
+she was a minors. The parties recently reached a confidential settlement of this lawsuit on the
+eve of trial.
+4.
+Movant's counsel, Brad
+was employed by RRA. During this time Attorney
+securely and confidentially maintained hard-copies of certain file materials and
+maintained substantial parts of client case files and investigative files in the Qtask application
+and other software systems maintained by RRA.?
+This Court has entered other Orders in this case to preserve the privileges of RRA's
+former clients. See Order Granting Motion for Protectiye Order, D.E. 672.
+6. Epstein filed a lawsuit against Scott W. Rothstein, L.M.'s counsel Brad
+and
+L.M. individually.? Epstein has sought to prove up his meritless claims against Attorney
+and L.M., in part, by invoking his Fifth Amendment privilege in deposition in this case
+seventy-seven times.*
+On April 16, 2010, Epstein's counsel had a subpoena duces tecum issued from the Circuit
+'L.M. v. Epstein, Case #08-CA-28051, 15'* Judicial Circuit in and for Palm Beach County,
+Florida. Attorney Brad
+s plaintiff's counsel in this lawsuit. Epstein was also a par
+efendant in dozens of other civil lawsuits prosecuted by other woman who allege that Epste
+sexually exploited, abused, and/or assaulted them when they were minors.
+- See Motion for Protective Order to Exclude Production of Privileged Documents and
+Testimony from Qtask, Inc. [D.E. 355].
+' Epstein v. Rothstein, et al., Case #09-CA-040800-MBAG, 15" Judicial Circuit in and for Palm
+Beach County, Florida.
+' Dep. Jeffrey Epstein, Epstein v. Rothstein, et al., March 17, 2010, p. 6 - 128.
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 3 of 10
+Court in Epstein v. Rothstein, et al. seeking production from Trustee Herbert Stettin of Attorney
+case files and investigative files which relate to L.M. and his other legitimate clients
+who possessed bona fide claims or potential claims against Epstein.
+On June 18, 2010, L.M., through counsel, filed objections to the subpoena in the Circuit
+8.
+Court.
+9.
+Likewise, L.M. filed a motion for protective order in the Circuit Court where the subject
+subpoena had been issued.
+10.
+In addition, the Trustee filed a motion for protective order in the Circuit Court.
+11.
+Thereafter, the Circuit Court entered an agreed order on these motions for protective
+order protecting privileged and work product materials from production to Epstein.
+12.
+Now, Epstein has come to the Bankruptcy Court to pursue the discovery of privileged
+and attorney work product materials which the Circuit Court would not allow. See Epstein's
+Motion to Compel, DE 807.
+Ill.
+Memorandum of Law
+A. Discovery Issues Related to the State Court Issued Subpoena Are
+Not Properly Before the Bankruptcy Court
+Despite Epstein's stated position to the contrary, neither 28 U.S.C. §§ 152 or 1334 confer
+jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state
+law claims filed in state court which are not before the Bankruptcy Court. Epstein seeks to
+perform an end run around the Circuit Court's proper exercise of its jurisdiction to adjudicate
+matters pending before it, including subpoenas issued from that court. Moreover, the honorable
+Circuit Court has already ruled on a motion for protective order on the subject state court issued
+subpoena duces lecum. Accordingly, for reasons of comity, this honorable Court should deny
+3
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 4 of 10
+Epstein's motion to compel.
+B. The Discovery Sought is Privileged and/or Attorney Work Product and Beyond
+the Permissible Scope of Discovery
+Privileges are invoked by the client who possesses the privilege or by the attorney on
+behalf of the client.
+i.
+Scope of Permissible Discovery
+Rule 26(b) excludes privileged matters from the scope of permissible discovery. Ep
+seeks the production of documents from clients' privileged case files and investigative files.
+These documents are beyond the scope of discovery permitted by Rule 26(b),
+ii.
+Protective Orders
+Rule 26(c) states that a court may protect a party or person from whom discovery is
+sought, based on "good cause shown:"
+A party or any person from whom discovery is sought may move for a
+protective order in the court where the action is pending — or as an alternative
+on matters relating to a deposition, in the court for the district where the
+deposition will be taken. The motion must include a certification that the
+movant has in good faith conferred or attempted to confer with other affected
+parties in an effort to resolve the dispute without court action. The court may,
+for good cause, issue an order to protect a party or person from annoyance,
+embarrassment, oppression, or undue burden or expense, including one or
+more of the following:
+(A) forbidding the disclosure or discovery;
+(B) specifying terms, including time and place, for the disclosure or
+discovery;
+(C) prescribing a discovery method other than the one selected by the
+party seeking discovery;
+(D) forbidding inquiry into certain matters, or limiting the scope of
+disclosure or discovery to certain matters;
+(E) designating the persons who may be present while the discovery is
+conducted;
+(F) requiring that a deposition be sealed and opened only on court
+order;
+4
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 5 of 10
+(G) requiring that a trade secret or other confidential research,
+development, or commercial information not be revealed or be
+revealed only in a specified way; and
+(H) requiring that the parties simultaneously file specified documents
+or information in sealed envelopes, to be opened as the court directs.
+Fed.R.Civ.P. 26(c)
+Epstein seeks the production from the Trustee of privileged, confidential, and attorney
+work product materials from the case files and investigative files of L.M. and other clients who
+possess claims against Epstein. The requested documents, relating to the bona fide cases of
+clients are not relevant or calculated to lead to the discovery of admissible evidence in the instant
+bankruptcy
+action
+or any adversary proceeding presently before this Court. Therefore, the
+requested documents are beyond the scope of permissible discovery. The requested materials
+are not discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil
+Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of
+rules. Moreover, the document production methodology established by order of this Court was
+not intended to be a conduit of privileged and work product of RRA's former clients to the
+clients' litigation adversaries
+Epl
+s counsel distorts and misrepresents the purpose of the
+document production methodology by arguing that it was created to facilitate such improper
+discovery.
+Epstein's counsel further attempts to skirt the issue of privilege by failing to meaningfully
+identify the nature of the requested materials, other than describing "emails" and documents
+"other than emails". The materials requested by Epstein, essentially case files, client files, and
+investigative files are patently and obviously privileged. Epstein's counsel offers no argument,
+cognizable under any set of possibly applicable rules, to demonstrate entitlement to these
+privileged and work product materials.
+5
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 6 of 10
+WHEREFORE, based on the foregoing, Epstein is not permitted to obtain production of
+documents and ESI from the Trustee which comprise the privileged, confidential, or attorney
+work product portions of case files or investigative files, and Movant requests that the Court
+deny Epstein's motion to compel, grant the foregoing motion for protective order, and enter a
+protective order excluding the production of any documents or ESI by the Trustee which relate to
+any cases or matter of L.M. or other clients and granting any other relief the Court deems
+appropriate to protect the clients of
+Jaffe Weissing.
+I HEREBY CERTIFY that, pursuant to L.R. 9073-1(D), Movant's counsel has
+contacted Epstein's counsel in a good faith attempt to resolve the matter without a hearing and I
+further certify that a true and correct copy of the foregoing was served on electronically to the
+examinee, the debtor, the attorney for the debtor, the trustee, all CM/ECF subscribers, and by
+email or U.S. Mail on those parties listed on the attached service list this 19th day of July, 2010.
+I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court
+for the Southern District of Florida and Tam in compliance with the additional qualifications to
+practice in this court set forth in Local Rule 2090-1(A).
+JAFFE, WEISSING,
+• FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+(954)524-2820 Telephone
+(954)524-2822 Facsimile
+By: Is/Seth Lehrman
+Seth Lehrman FLBN 132896
+seth@pathtojustice.com
+6
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 7 of 10
+Marianella Morales, Esquire (VIA EMAIL)
+Alison W. Lehr (VIA EMAIL)
+Authorized Agent For Joining Creditors
+Assistant United States Attorney
+Avenida Francisco de Miranda
+99 N.E. 4th Street
+Torre Provincial "A"
+7th Floor
+Miami, Florida 33132
+Caracas, Venezuela
+Phone: (305) 961-9176
+Fax: (305) 536-7599
+Alison.Lehr@usdoj.gov
+John H. Genovese, Esq. (VIA CM/ECF)
+Robert F. Elgidely, Esq.
+Theresa M.B. Van Vliet, Esq.
+Genovese Joblove & Battista, PA
+Bank Of America Tower at International
+Place
+100 S.E. 2nd Street
+Suite 4400
+Miami, Florida 33131
+Phone: (305) 349-2300
+Fax (305) 349-2310
+Kendall Coffey, Esq. (VIA EMAIL)
+Coffey Burlington,
+Office in the Grove
+Penthouse
+2699 South Bayshore Drive
+Miami, Florida 33133
+kcoffey@coffeyburlington.com
+Hon. Herbert M. Stettin (VIA EMAIL)
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+John G. Bianco, Esq. (VIA CM/ECF)
+John M. Mulli, Esquire
+Tripp Scott
+110 Southeast Sixth Street
+Fifteenth Floor
+Fort Lauderdale, FI. 33301
+jgb@trippscott.com
+Stuart A. Rosenfeldt, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, PA
+401 East Las Olas Boulevard
+Suite 1650
+Fort Lauderdale, Florida 33301
+srosenfeldt@rra-law.com
+Jeffrey R. Sonn, Esq. (VIA EMAIL)
+Sonn & Erez, PLC
+Broward Financial Center
+500-E. Broward Boulevard
+Suite 1600
+Fort Lauderdale, Florida 33394
+Phone: (954) 763-4700
+Fax (954) 763-1866
+jsonn@sonnerez.com
+Office of the US Trustee (VIA CM/ECF)
+51 Southwest First Avenue
+Suite 1204
+Miami, Florida 33130
+Tew, Esq. (VIA EMAIL)
+Maynard Gollin, Esq.
+Tew-
+LLP
+Four Seasons Tower
+15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131-3407
+tt@tewlaw.com
+Img@tewlaw.com
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 8 of 10
+Conrad & Scherer, LLP (VIA EMAIL)
+Fort Lauderdale, FL 33301
+Tel: 954-462-5500
+bs@conradscherer.com
+JSilver@conradscherer.com
+Michael D. Seese, Esq. (VIA EMAIL)
+Hinshaw & Culbertson, LLP
+1 E Broward Blvd Ste 1010
+Ft Lauderdale, Florida 33301
+Tel: 954.4677900
+Fax: 954.4671024
+mseese@hinshawlaw.com
+Internal Revenue Service
+Centralized Insolvency Operations
+P.O. Box 21126
+Philadelphia, PA 19114
+(Via U.S. Mail)
+Internal Revenue Service
+Special Procedures - Insolvency
+7850 SW 6th Court
+Plantation, FL 33324
+Tel.: (954) 423-7300
+Fax.: (305) 982-5406
+(Via U.S. Mail)
+Special Asst. U.S. Attorney
+P.O. Box 9, Stop 8000
+51 SW Ist Avenue, #111
+Miami, FI 33130
+Fai: (3S5302139
+(Via U.S. Mail)
+Grant J. Smith, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, P.A.
+401 East Las Olas Blvd
+Suite 1650
+Fort Lauderdale, FL 33301
+gsmith@rra-law.com
+United Healthcare
+Dept. CH 10151
+Palatine, IL 60055
+Special Asst. U.S. Attorney
+IRS District Counsel
+1000 S. Pine Island Rd., Ste 340
+Plantation, FL 33324-3906
+(Via U.S. Mail)
+The Honorable Eric H. Holder, Jr.
+Attorney General of the U.S.
+950 Pennsylvania Avenue, NW Room 4400
+Washington, DC 20530-0001
+Honorable Jeffrey H. Sloman,
+Acting US. Altorney
+99 NE 4th Street
+Miami, FI 33132
+(Via U.S. Mail)
+Daniel Mink
+Ovadia Levy
+c/o Renato Watches, Inc
+14051 NW 14th Street
+Sunrise, Florida 33323
+(Via U.S. Mail)
+William
+Salim, Jr. (VIA CM/ECF)
+Moskowitz Mandell & Salim
+300 Corporate Dr Ste 51(
+Fort Lauderdale, Florida 3333-
+wsalim@mmsslaw.com
+Fax: 954.4912051
+USI (VIA EMAIL)
+Attn: Anthony Gruppo
+200 West Cypress Creek Road
+Suite 500
+Fort Lauderdale, FL 33309
+Tel: 954-607-4000
+Anthony.gruppo@usi.biz
+8
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 9 of 10
+Marc Nurik, Esq. (VIA EMAIL)
+Rothstein Rosenfeldt Adler, P.A
+401 East Las Olas Blvd
+Fort Lauderdale, FL 33301
+mnurik@rra-law.com
+BAST AMRON LLP (VIA CM/ECF)
+Sun Trust International Center
+One Southeast Third Avenue
+Suite 1440
+iami, Florida 331.
+elephone: (305) 379-79
+Facsimile: (305) 379-7905
+bamron@bastamron.com
+jbast@bastamron.com
+Mark Bloom, Esq. (VIA EMAIL)
+Greenberg Traurig, LLP
+1221 Brickell Avenue
+Miami, FL 33131
+T 305.579.0500
+F 305.579.0717
+bloomm@gtlaw.com
+Robert D. Critton, Esq. (VIA EMAIL)
+Burman, Critton, Luttier & Coleman
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+rcrit@bclclaw.com
+Roth & Scholl (VIA EMAIL)
+Attn: Jeffrey C. Roth, Esq.
+Attorneys For Creditor Blue
+Capital Us East Coast Properties, L.P.
+866 South Dixie Highway
+Coral Gables, FI 33146
+Telephone: (305) 662-4141
+jeff@rothandscholl.com
+Rogers, Morris & Ziegler, LLP (VIA
+EMAIL)
+1401 East Broward Blvd
+Suite 300
+Fort Lauderdale, FL 33301
+Tel: (954) 462-1431
+Fax: (954) 763-2692
+mfbooth@rmzlaw.com
+Arthur C. Neiwirth, Esq. (VIA CM/ECF)
+One E. Broward Blvd., Suite 1400
+Ft. Lauderdale, FL 33301
+Tel: (954) 523-7008
+Fax: (954) 523-7009
+aneiwirth@qpwblaw.com
+The Florida Bar (VIA EMAIL)
+Adria E. Quintela, Esq.
+Alan Anthony Pascal, Esq.
+Lake Shore Plaza I|
+1300 Concord Terrace, Suite 130
+Sunrise, FL 33323
+aquintel@flabar.org
+apaścal@flabar.org
+Micheal w. Moskowitz, Esq. (VIA E-
+MAIL)
+800 Corporate Drive, Suite 500
+Ft. Lauderdale, FL 33234
+mmoskowitz@mmsslaw.com
+Francis L. Carter, Esq. (VIA E-MAIL)
+Katz Barron Squitero Faust
+2699 S. Bayshore Drive, 7th Floor
+Miami, Florida 33133
+Tel: 305-856-2444
+Fax: 305-285-9227
+flc@katzbarron.com
+S. Shraiberg, Esq. (VIA EMAIL)
+2385 NW Executive Drive
+Suite 300
+Boca Raton, Florida 33431
+Tel: 561-443-0800
+Fax: 561-998-0047
+bshraiberg@sfl-pa.com
+9
+
+
+Case 09-34791-RBR Doc 819 Filed 07/19/10 Page 10 of 10
+Henry S. Wulf. Esg. (VIA EMAIL)
+CARLTON
+, P.A.
+525 Okeechobee Blvd., Suite 1200
+West Palm Beach, Florida 33401
+Telephone: (561) 659-7070
+Facsimile: (561) 659-7368
+E-Mail: hwulf@carltonfields.com
+Ira Sochet, Trustee (VIA EMAIL)
+c/o Phil Hudson, Esq.
+200 South Biscayne Blyd, Suite 3600
+Miami, Florida 33130
+Telephone: (305) 374-3330
+Facsimile: (305) 374-4744
+E-Mail: pmhudson@arnstein.com
+EMESS Capital, LLC (VIA EMAIL)
+c/o Bruce A. Katzen, Esq.
+201 S. Biscayne Blvd., 17th Floor
+Miami, Florida 33131
+Telephone: (305) 379-9000
+Facsimile: (305) 379-3428
+E-Mail: bkatzen@klugerkaplan.com
+Coquina Investments (VIA EMAIL)
+c/o Patricia A. Redmond, Esq.
+150 West Flagler Street, Suite 2200
+Miami, Florida 33130 (
+Telephone: (305) 789-3553
+Facsimile: (305) 789-3395
+E-Mail: predmond@stearnsweaver.com
+Ronald Neiwirth, Esq. (VIA EMAIL)
+L. Ackerman, Jr., Esq.
+& Burnett, P.A.
+777 S. Flagler Dr. ,Ste 901
+W. Palm Beach, FL 334016170
+Email:
+CERTIFIED
+10
+
+
+Case 09-34791-RBR Doc 888 Filed 08/13/10
+
+COURT
+BUTEN TECT OF ROND
+ORDERED in the Southern District of Florida on August 13, 2010.
+Raymond B. Ray, Judge
+United States Bankruptcy Court
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+ORDER RESPECTING PRODUCTION OF
+DOCUMENTS REGARDING JEFFREY EPSTEIN
+THIS CAUSE came before the Court for hearing on August 4, 2010 upon (i) Motion to
+Compel Production of Documents from Trustee Pursuant to Document Production Protocol, as
+established by D.E. #672 (D.E. #807); (ii) Motion for Protective Order filed by Interested Party
+Farmer, Jaffe, Weissing,
+Fistos and Lehrman, P.L. (*
+‚Jaffe") (D.E. #818) and
+its related amendment (D.E. #819). The Court heard argument of all counsel present at the
+hearing, and being otherwise duly advised in the premises,
+
+
+
+Case 09-34791-RBR Doc 888
+Filed 08/13/10 Page 2 of 3
+DOES HEREBY ORDER:
+Special |
+1. The Court appoints former Broward County Circuit Judge Robert Carney as
+who shall work with counsel for the Trustee to obtain documents responsive to
+the subpoena served upon the Trustee by Jeffrey Epstein to: (i) review all electronically stored
+information ("EST") and other documents in the Trustee's possession, including Qtask data for
+purposes of determining the applicability of the attorney/client and work product privileges that
+may inure to the benefit of L.M.., Brad
+, and other current or former clients of
+Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in
+accordance with standard practice and law.
+2.
+Prior to engaging in this document review, the Special
+shall meet with
+counsel for Epstein, counsel for
+, Jaffe and counsel for the Trustee to hear their respective
+positions concerning these matters. Upon completion of the review by the Special
+the
+Special
+shall prepare and file a privilege log with the Court. No documents. or ESI shall
+be released to anyone until such time as the Special
+has notified the Court that he has
+concluded his review of the responsive documents and is in a position to report to the Court his
+findings and to obtain further instruction. Upon the filing of such notice by the Special
+the Court shall set a continued hearing on the pending motions identified above. All legal fees
+and costs incurred by the Special
+shall be paid by Epstein, who has agreed to pay directly
+all such fees and costs.
+
+2
+
+
+Case 09-34791-RBR Doc 888
+Filed 08/13/10
+
+Submitted by:
+BERGER SINGERMAN, P.A.,
+350 East Las Olas Boulevard, Suite 1000
+ort Lauderdale, FL 3330
+'elephone: (954) 525-990
+Facsimile: (954) 523-2872
+clichtman@bergersingerman.com
+Copy furnished to:
+3
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 1 of 10
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,'
+Debtor.
+MOTION TO CLARIFY ORDER APPOINTING SPECIAL MASTER
+Robert B. Carney, this Court's appointed Special |
+by Order dated August 13, 2010
+[D.E. #888], moves for clarification of the above referenced order in the following material
+respects:
+1.
+Does Paragraph 1 of the Order envision that the Special
+alone prepare a
+privilege log?
+Discussion: While a first blush reading of the Order would seem to indicate that the
+Special
+solely would prepare the privilege log, this likely would create appellate issues
+later in the civil action. A strict
+ding would preclude Messieurs
+and
+not only
+from seeing the documents, but from having any hand in asserting the privilege that is theirs to
+assert. Such a strict interpretation would permit them only to argue the privileges asserted by the
+Because they could not see the documents, the
+alone, would decide which
+documents and what privilege. Your Special
+is not aware of any case law or rule that
+would support such an interpretation and felt it prudent to bring this to the court's attention.
+' The address and last four digits of the taxpayer identification number of the Debtor, Rothstein Rosenfeldt Adler,
+P.A., is 6600 NW 16th Street, Suite I1,
+7961).
+2 The content of this motion was written by the Special
+However, the Trustee's counsel was asked to format
+and file this motion for the Special
+who is not on this Court's Electronic Filing System. Submission of this
+motion by Trustee's counsel does mean that the Trustee takes a position on the issues raised herein.
+
+
+
+Case 09-34791-RBR Doc 1013
+Filed 09/20/10 Page 2 of 10
+Suggestion: That the Order appointing Special
+be clarified to insure that Messieurs
+and
+have the opportunity to review the documents and themselves make the
+decision regarding whether to assert a privilege. Since your Special
+would also have the
+documents any concerns of loss or tampering should be alleviated.
+2.
+Does Paragraph 2 of the order envision that the job of the Special Master end with
+the preparation of the Privilege Log?
+Discussion: Once the privilege log is prepared the next step would be line item review of
+each privilege and the context in which it asserted as well as the opposing reasons why it should
+not exist or why it should be abrogated. A strict reading of the Order would terminate the
+function of the Special
+upon completion of the privilege log and would leave the
+Bankruptcy Court with the task of sorting out the arguments and conducting hearings relative to
+the privileges. Since this is in the context of a state court civil action involving matters arguably
+outside the interest of the Bankruptcy Court, it might be more efficient for the arguments to be
+made to the Special
+with the Special
+then including in his report
+recommendations to the Bankruptcy judge regarding disposition.
+Suggestion: That the Order appointing Special
+be clarified to encompass
+conducting a hearing regarding privileges asserted by Messieurs
+and
+The
+Report of the Special
+would include the arguments from both sides regarding any
+privileges asserted and the recommended disposition of these claims.
+Your Special
+has met with attorneys Lichtman,
+and
+separately and together. Not all attorneys are in agreement with either the Request for
+Clarification or the suggestions of the Special
+outlined above which is the reason for
+requesting this hearing.
+2
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 3 of 10
+I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court
+for the Southern District of Florida and that I am in compliance with the additional qualifications
+to practice in this court set forth in Local Rule 2090-1(A).
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing was seryed via
+Regular U.S. Mail, postage prepaid, fax, email and/or overnight delivery, as indicated, upon all
+parties on the attached Service List this 20th day of September, 2010.
+Dated: September 20, 2010.
+Respectfully submitted,
+BERGER SINGERMAN, P.A
+Attorneys for the Chapter 11 Trustee
+350 East Las Olas Boulevard, Suite 1000
+Fort Lauderdale, FL 33301
+(Telephone: (954) 712-5138
+(954) 525-9900
+Facsimile: (954) 523-2872
+
+By: Is/ Charles H. Lichtman
+Charles H. Lichtman
+clichtman@bergersingerman.com
+Florida Bar No. 501050
+3
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10
+
+Authorized Agent For Joining Creditors
+Avenida Francisco de Miranda
+Torre Provincial "A"
+Piso 8
+Caracas, Venezuela
+Alison W. Lehr, Esq.
+Grisel Alonso, Esq.
+Assistant United States Attorney
+99 N.E. 4th Street, 7th Floor
+Miami, Florida 33132
+Alison.Lehr@usdoj.gov
+Grisel.alonso@usdoj.gov
+John H. Genovese, Esq.
+Robert F. Elgidely, Esq.
+Theresa M.B. Van Vliet, Esq.
+Genovese Joblove & Battista, PA
+Bank Of America Tower at International
+Place
+100 S.E. 2nd Street, Suite 4400
+Miami, Florida 33131
+Kendall Coffey, Esq.
+Coffey Burlington,
+Office in the Grove
+Penthouse
+2699 South Bayshore Drive
+Miami, Florida 33133
+kcoffey@coffeyburlington.com
+The Honorable Herbert M. Stettin
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+(VIA U.S. MAIL and EMAIL)
+John G. Bianco, Esq.
+John M. Mulli, Esquire
+Tripp Scott
+110 Southeast Sixth Street
+Fifteenth Floor
+Fort Lauderdale, FI. 33301
+jgb@trippscott.com
+Jeffrey R. Sonn, Esq.
+Sonn & Erez, PLC
+Broward Financial Center
+500 E. Broward Boulevard
+Suite 1600
+Fort Lauderdale, Florida 33394
+jsonn@sonnerez.com
+Office of the US Trustee
+51 Southwest First Avenue
+Suite 1204
+Miami, Florida 33130
+Tew, Esq.
+Tew-
+1. LLP
+Four Seasons Tower
+15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131-3407
+tt@tewlaw.com
+Conrad & Scherer, LLP
+Fort Lauderdale, FL 33301
+bs@conradscherer.com
+JSilver@conradscherer.com
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 5 of 10
+Michael D. Seese, Esq.
+Honorable Jeffrey H. Sloman,
+Hinshaw & Culbertson, LLP
+Acting U.S. Attorney
+1 E Broward Blvd Ste 1010
+99 NE 4th Street
+Ft Lauderdale, Florida 33301
+Miami, Fl 33132
+mseese@hinshawlaw.com
+(Via U.S. Mail)
+Daniel Mink
+Internal Revenue Service
+Ovadia Levy
+Centralized Insolvency Operations
+c/o Renato Watches, Inc
+P.O. Box 21126
+14051 NW 14th Street
+Philadelphia, PA 19114
+Sunrise, Florida 33323
+(Via U.S. Mail)
+(Via U.S. Mail)
+Internal Revenue Service
+William
+Salim, Jr.
+Special Procedures - Insolvency
+Moskowitz Mandell & Salim
+7850 SW 6th Court
+800 Corporate Dr Ste 510
+Plantation, FL 33324
+Fort Lauderdale, Florida 33334
+(Via U.S. Mail)
+wsalim@mmsslaw.com
+Special Asst. U.S. Attorney
+P.O. Box 9, Stop 8000
+USI
+51 SW Ist Avenue, #1114
+Attn: Anthony Gruppo
+Miami, Fl 33130
+200-West Cypress Creek Road
+(Via U.S. Mail)
+Suite 500
+Fort Lauderdale, FL 33309
+United Healthcare
+Anthony.gruppo@usi.biz
+Dept. CH 10151
+(VIA EMAIL)
+Palatine, IL 60055
+Special Asst. U.S. Attorney
+IRS District Counsel
+1000 S. Pine Island Rd., Ste 340
+Plantation, FL 33324-3906
+(Via U.S. Mail)
+Marc Nurik, Esq.
+1 East Broward Blyd
+Suite 700
+Fort Lauderdale, FL 33301
+marc@nuriklaw.com
+(VIA EMAIL)
+The Honorable Eric H. Holder, Jr.
+Attorney General of the U.S
+950 Pennsylvania Avenue, NW Room 4400
+Washington, DC 20530-0001
+(Via U.S. Mail)
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 6 of 10
+The Florida Bar
+Adria E. Quintela, Esq.
+Alan Anthony Pascal, Esq.
+Lake Shore Plaza II
+1300 Concord Terrace, Suite 130
+Miami, FL 33131
+bloomm@gtlaw.com
+huttonj@gtlaw.com
+Robert D. Critton, Esq.
+Burman, Critton, Luttier & Coleman
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+Roth & Scholl
+Attn: Jeffrey C. Roth, Esq.
+Attorneys For Creditor Blue
+Capital Us East Coast Properties, L.P.
+866 South Dixie Highway
+Coral Gables, FI 33146
+jeff@rothandscholl.com
+Rogers, Morris & Ziegler, LLP
+1401 East Broward Blvd
+Suite 300
+Fort Lauderdale, FL 33301
+mfbooth@rmzlaw.com
+Arthur C. Neiwirth, Esq
+One E. Broward Blvd., Suite 1400
+Ft. Lauderdale, FL 33301
+aneiwirth@qpwblaw.com
+aquintel@flabar.org
+apascal@flabar.org
+Micheal W. Moskowitz, Esq.
+800 Corporate Drive, Suite 500
+Ft. Lauderdale, FL 33234
+mmoskowitz@mmsslaw.com
+Francis L. Carter, Esq.
+Katz Barron Squitero Faust
+2699 S. Bayshofe Drive, 7th Floor
+Miami, Florida 33133
+flc@katzbarron.com
+S. Shraiberg, Esq.
+2385 NW Executive Drive
+Suite 300
+Boca Raton, Florida 33431
+bshraiberg@sfl-pa.com
+Henry S. Wulf, Esg.
+CARLTON
+1. P.A.
+525 Okeechobee Blvd., Suite 1200
+West Palm Beach, Florida 33401
+E-Mail: hwulf@carltonfields.com
+EMESS Capital, LLC
+c/o Bruce A. Katzen, Esq.
+201 S. Biscayne Blvd., 17" Floor
+Miami, Florida 33131
+E-Mail: bkatzen@klugerkaplan.com
+jberman@klugerkaplan.com
+3
+
+
+c/o Phil Hudson, Esq.
+200 South Biscayne Blvd, Suite 3600
+Miami, Florida 33130
+E-Mail: pmhudson@arnstein.com
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 7 of 10
+Steven J.
+Esq.
+Gray
+P.A
+1221 Brickell Ave, Suite 1600
+Miami, Florida 33131
+E-Mail -
+Coquina Investments
+c/o Patricia A. Redmond, Esq.
+150 West Flagler Street, Suite 2200
+Miami, Florida 33130
+E-Mail: predmond @stearnsweaver.com
+Michael I. Goldberg, Esq.
+Las Olas Centre - Suite 1600
+350 East Las Olas Blvd
+Fort Lauderdale, FL 33301
+E-Mail: Michael.goldberg@akerman.com
+Eyal.berger@akerman.com
+LMB Funding Group
+c/o Robert C. Furr, Esq.
+2255 Glades Road, Suite 337W
+Boca Raton, Florida 33431
+E-Mail: rfurr@furrcohen.com
+A. Gordich, Esq.
+Melissa Alagna, Esq.
+SEGALL/GORDICH P.AY
+801 Brickell Avenue, Suite 900
+Miami, Florida 33131
+Email: lag@segallgordich.com
+Email: mma@segallgordich.com
+Broward County
+Attn: Hollie N. Hawn, Esq.
+Government Center
+115 South Andrews Avenue
+Fort Lauderdale, FL 33301
+E-Mail: hhawn@broward.org
+Peter F. Valori, Esq.
+DAMIAN & VALORI LLP
+1000 Brickell Avenue, Suite 1020
+Miami, FL 33131
+E-mail: pvalori@dvllp.com
+Canon Financial Services, Inc.
+158 Gaither Drive, #200
+Mount Laurel, NJ 08054
+CIT Technology Financing Services I,
+LLC
+10201 Centurion Parkway North
+Jacksonville, FL 32256
+Gibraltar Private Bank & Trust
+Company
+220 Alhambra Circle, Suite 500
+Coral Gables, FL 33134
+Inter-Tel Leasing, Inc.
+1140 West Loop North
+Houston, TX 77055
+Florida Department of Revenue
+501 S. Calhoun Street
+Room 201
+Carlton Building
+Tallahassee, FL 32399
+4
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 8 of 10
+County Tax Collector
+Roderick F. Coleman, Esq.
+315 S. Calhoun Street
+400 South Dixie Highway, Suite 121
+Suite 210|
+Boca Raton, FL 33432
+Tallahassee, FL 32301
+rfc@colemanattorneys.com
+Miami-Dade County Tax Collectors
+140 West Flagler Street, 14th Floor
+Miami, FL 33130
+Palm Beach County Tax Collector
+Mark S. Haltzman, Esq.
+Lamm Rubenstone, LLC
+3600 Horizon Blvd, Suite 200
+Trevose, PA 19053
+mhaltzman@lammrubenstone.com
+P.O. Box 3715
+West Palm Beach, FL 33402-3715
+Robert C. Buschel, Esq.
+100 S.E. Third Ave, Suite 1300
+Fort Lauderdale, FL 33394
+THE LAW OFFICES OF
+buschel@bglaw-pa.com
+GEOFFREY D. ITTLEMAN, P.A.
+440 North Andrews Avenue
+Fort Lauderdale, Florida 33301
+Carpenter & Berger, PL
+6400 N. Andrew Ave, suite 370
+Fort Lauderdale, FL 33309
+Berkowitz Dick Pollack & Brant
+Certified Public Accountants & Consultants,
+LLP
+200S Biscayne Boulevard, Sixth Floor
+Miami, FL 33131-2310
+Attn: Richard Pollack
+(Via Email and U.S. Mail)
+F. McGinn, Esq.
+Bartlett
+Feinberg, P.o
+155 Federal Street, 9" Floor
+Boston,
+02110
+ffm@bostonbusinesslaw.com
+MELAND RUSSIN & BUDWICK, P.A.
+3000 Wachovia Financial Center
+200 South Biscayne Boulevard
+Miami, Florida 33131
+Attn: James C. Moon, Esq.
+jmoon@melandrussin.com
+Attn: Peter D. Russin, Esq.
+Darol H. M. Carr, Esq.
+prussin@melandrussin.com
+99 Nesbit Street
+Attn: Michael S. Budwick, Esq.
+Punta Gorda, FL 33950
+mbudwick@melandrussin.com
+dcarr@farr.com
+Jane A. Bee, Esq.
+Blank Rome LLP
+130 North 18" Street
+Philadelphia, PA 19103-6998
+bee@blankrome.com
+Gary S. Blake, Esq.
+1499 W. Palmetto Park Rd
+Suite 300
+Boca Raton, FL 33486
+gblake@lglaw.net
+(VIA EMAIL)
+5
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10 Page 9 of 10
+New York, NY 10178-0061
+Melinda S. Thornton, Esq.
+Assistant County Attorney
+County Attorney's Office
+2810 Stephen P. Clark Center
+111 N.W. First Street
+Miami, FI 33128-1993
+mail: cao.bkc@miamidade.go
+VIA CM/ECF and EMAIL
+E-mail: mgallagher@curtis.com
+(Via Email and U.S. Mail)
+ILEANA CRUZ BONGINI, ESQ.
+icruz@stearnsweaver.com
+STEARNS WEAVER
+WEISSLER ALHADEFF & SITTERSON,
+P.A.
+Coquina Investments
+SLATKIN &
+I, P.A.
+Attorneys for
+Adler and Katie Adler
+One East Broward Boulevard, Suite 609
+Fort Lauderdale, Florida 33301
+Telephone 954.745.5880
+Facsimile 954.745.5890
+jslatkin@slatkinreynolds.com
+Museum Tower, Suite 2200,
+150 West Flagler Street
+Miami, Florida 33130
+Maynard Gollin
+Igollin@gordonrees.com
+Gordon & Rees LLP
+Four Seasons Tower
+ASSOULINE & BERLOWE, P.A.
+213 East Sheridan Street, Ste. 3
+Dania Beach, FL 33004
+Attn: Eric N. Assouline, Esq.
+ena@assoulineberlowe.com
+15th Floor
+1441 Brickell Avenue
+Miami, FL 33131
+Steven J. Reisman, Esq.
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: sreisman@curtis.com
+(Via Email and U.S. Mail)
+Robert P. Avolio, Esq.
+Crossroads Corporate Center
+3150 Brunswick Pike, Ste. 120
+Turner P. Smith, Esq.
+Lawrenceville, NJ 08648
+CURTIS, MALLET-PREVOST,
+ravolio@avoliohanlon.com
+COLT & MOSLE LLP
+(Via Email and U.S. Mail)
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: tsmith@curtis.com
+(Via Email and U.S. Mail)
+Maryann Gallagher, Esq.
+Mark S. Shipman, Esq.
+20 Batterson Park Road, Suite 120
+Farmington, CT 06032
+mark@shipso.com
+(Via Email and U.S. Mail)
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+Paul J. McMahon, Esq.
+Paul
+McMahon, P.A.
+2840 S.W. Third Ave
+Miami, Florida 33129
+pjm@pjmlawmiami.com
+6
+
+
+Case 09-34791-RBR Doc 1013 Filed 09/20/10
+
+Heather L. Ries, Esq.
+Fox Rothschild, LLP
+222 Lakeview Ave, Suite 700
+West Palm Beach, FI 33401
+hries@foxrothschild.com
+244
+794-1
+7
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 1 of 14
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+MOTION FOR PROTECTIVE ORDER TO EXCLUDE THE PRODUCTION FROM
+TRUSTEE STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO
+JEFFREY EPSTEIN
+Movant,
+moves this Court pursuant to 11 U.S.C. §105(a), Federal
+Rules of Bankruptcy Procedure Rule 7026 (which expressly incorporates Fed.R.Civ. P. 26(c)),
+and L.R. 7026-1 to request that the Court enter a protective order excluding the Trustee's
+production of any documents or information to Jeffrey Epstein in the Deposition Duces Tecum
+served on Herbert Stettin, Trustee in the Bankruptcy for Rothstein Rosenfeldt Adler, P.A.
+("RRA") because all requested documents are subject to a claim of attorney-client privilege
+and/or attorney work product, and in support thereof, states as follows:
+1.
+Introduction
+1. Jeffrey Epstein ("EPSTEIN"), through his counsel, seeks to pull the wool over the eyes of
+this honorable Court, Epstein asks this Court to usurp the properly exercised jurisdiction of the
+Circuit Court ovér a subpoena duces tecum issued by the state court in connection with an action
+pending before the state court.
+2.
+Movant,
+") respectfully requests that this honorable
+Court enter a protective order, consistent with the document production methodology already
+ordered by the Court [D.E. 672], deny Epstein's motion to compel, and prevent the Trustee's
+production to Epstein of any documents or ESI sought through his state court subpoena since
+
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 2 of 14
+such production consists entirely of documents and ESI which are subject to proper claims of
+attorney-client communications privilege and/or attorney work product.
+Background
+II.
+3.
+was legal counsel for several young females that were molested by
+EPSTEIN and is currently legal counsel for additional females who were molested by EPSTEIN.
+4.
+filed lawsuits against EPSTEIN on behalf of three females, LM, EW, and
+Jane Doe, who were molested by EPSTEIN numerous times when they were as young as 13 and
+14 years old. Each of those lawsuits was originally filed in August or September of 2008, while
+was a sole practitioner.
+5.
+In or about March or April of 2009,
+was hired to work at RRA, and as such
+he took his cases, which included cases against EPSTEIN, to RRA with him.
+6.
+In November 2009, RRA collapsed when it was discovered that the firm's president,
+Scott Rothstein, was running a Ponzi scheme and otherwise engaging in criminal activity.
+and the vast majority of RRA attorneys and employees, were unaware of
+Rothstein's criminal activity.
+8.
+EPSTEIN, in an effort to exploit Rothstein's criminal activity, filed a lawsuit against
+ROTHSTEIN, and LM, alleging that there was a conspiracy to fabricate cases
+against him, including the case filed on behalf of LM. Notwithstanding the foregoing, EPSTEIN
+has settled all suits filed by
+to date, paying significant sums to resolve said cases.
+Prior to settling these cases, EPSTEIN was deposed in the underlying litigation filed by the child
+victims, and in this case, and in all depositions he has asserted his 5th Amendment privilege
+against self-incrimination. Despite all the foregoing, EPSTEIN has filed his frivolous claims
+against
+and his client.
+2
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 3 of 14
+EPSTEIN served a deposition duces tecum on Herbert Stettin, trustee for RRA,
+requesting documents and information that are clearly protected by attorney-client and work
+product privilege and/or which are the private property of |
+or his clients or request
+information that is not reasonably calculated to lead to the discovery of admissible evidence.
+10.
+Epstein is attempting to use his lawsuit against
+as a vehicle to pierce the
+attorney-client and work product privileges and gain access to privileged information related to
+civil actions against him.
+11. Epstein served Requests for Production on
+that discovery requested
+identical information to that sought by the duces tecum served on Herbert Stettin.
+12. Appropriate work product and attorney-client privilege objections were made to those
+requests and responses were provided where there was no objection.
+13. The Trustee for RRA is merely the custodian of these records and stands in the shoes of
+the former RRA attorneys and clients on issues such as this; in other words, the Trustee,
+LM and all other current and former clients are essentially one and the same for
+purposes of attorney-client and work product issues. Therefore, EPSTEIN cannot request
+discovery from the RRA Trustee to circumvent any privilege already claimed by
+or
+his clients or to obtain information to which he is not entitled under the Rules.
+14.
+EPSTEIN set a hearing on his Motion to Compel production of these materials before
+Judge Crow, the Court in which this case is pending.
+15.
+Prior to Judge
+hearing that Motion, an agreement was reached amongst the parties
+(including Trustee) that the materials responsive to the requests would be turned over by the
+Trustee to
+and that
+would then file a privilege log or make other
+appropriate objections.
+3
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 4 of 14
+16.
+EPSTEIN's counsel said he would prepare the Agreed Order to that effect but failed to do
+SO.
+17. EPSTEIN has now argued his entitlement to these documents before this Bankruptcy
+Court.
+18.
+counsel understands that a Special
+, Judge Robert Carney, has been
+appointed and delegated certain duties to monitor Electronically Stored Information to assist in
+the preparation of a privilege log.
+19.
+The discovery Epstein is seeking should not be allowed as it is not discoverable because
+it is irrelevant and/or clearly protected by privilege.
+20.
+The discovery requested also contains information that is the private property of
+or his clients.
+21.
+An objection and Amended Motion for Protectiye Order [D.E. 819] was lodged on behalf
+of LM, invoking certain privileges, and the objections on behalf of
+and his current
+clients should also be recognized by this Court.
+adopts and incorporates by
+reference herein the Amended Motion for Protective Order filed by LM, but also asserts his own
+attorney-client and work product privileges as he is a named Defendant in EPSTEIN's frivolous
+lawsuit.
+22.
+While objections on behalf of
+have already been made before Judge |
+who is presiding over this case, this Court should be aware of EPSTEIN's attempt to backdoor
+his way into obtaining information to which he is not entitled.
+Memorandum of Law
+A. Discovery Issues Related to the State Court Issued Subpoena Are
+Not Properly Before the Bankruptey Court
+4
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 . Page 5 of 14
+Despite Epstein's stated position to the contrary, neither 28 U.S.C. §§ 152 or 1334 confer
+jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state
+law claims filed in state court which are not before the Bankruptcy Court. Epstein seeks to
+perform an end run around the Circuit Court's proper exercise of its jurisdiction to adjudicate
+matters pending before it, including subpoenas issued from that court. Moreover, the honorable
+Circuit Court has already ruled on a motion for protective order on the subject state court issued
+subpoena duces tecum. Accordingly, for reasons of comity, this honorable Court should deny
+Epstein's motion to compel.
+B. The Discovery Sought is Privileged and/or Attorney Work Product and Beyond
+the Permissible Scope of Discovery
+Privileges are invoked by the client who possesses the privilege or by the attorney on
+behalf of the client.
+i.
+Scope of Permissible Discovery
+Rule 26(b) excludes privileged matters from the scope of permissible discovery. Epstein
+seeks the production of documents from clients' privileged case files and investigative files.
+These documents are beyond the scope of discovery permitted by Rule 26(b).
+il.
+Protective Orders
+Rule 26(c) states that a court may protect a party or person from whom discovery is
+sought, based on *good cause shown:"
+A party or any person from whom discovery is sought may move for a
+protective order in the court where the action is pending — or as an alternative
+on matters relating to a deposition, in the court for the district where the
+deposition will be taken. The motion must include a certification that the
+movant has in good faith conferred or attempted to confer with other affected
+parties in an effort to resolve the dispute without court action. The court may,
+for good cause, issue an order to protect a party or person from annoyance
+5
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 6 of 14
+embarrassment, oppression, or undue burden or expense, including one or
+more of the following:
+(A) forbidding the disclosure or discovery;
+(B) specifying terms, including time and place, for the disclosure oi
+discovery;
+(C) prescribing a discovery method other than the one selected by the
+party seeking discovery;
+(D) forbidding inquiry into certain matters, or limiting the scope of
+disclosure or discovery to certain matters;
+(E) designating the persons who may be present while the discovery is
+conducted;
+(F) requiring that a deposition be sealed and opened only on court
+order;
+(G) requiring that a trade secret or other confidential research,
+development, or commercial information not be revealed or be
+revealed only in a specified way; and
+(H) requiring that the parties simultaneously file specified documents
+or information in sealed envelopes, to be opened as the court directs.
+Fed.R.Civ.P. 26(c)
+Epstein seeks the production from the Trustee of privileged, confidential, and attorney
+work product materials. The requested documents, relating to the bona fide cases of clients are
+not relevant or calculated to lead to the discovery of admissible evidence in the instant
+bankruptcy action or any adversary proceeding presently before this Court. Therefore, the
+requested documents are beyond the scope of permissible discovery. The requested materials
+are not discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil
+Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of
+rules. Moreover, the document production methodology established by order of this Court was
+not intended to be a conduit of privileged and work product of RRA's former clients to the
+clients' litigation adversaries. Epstein's counsel distorts and misrepresents the purpose of the
+document production methodology by arguing that it was created to facilitate such improper
+6
+
+
+Case 09-34791-RBR Doc 1022
+Filed 09/27/10 Page 7 of 14
+discovery.
+Epstein's counsel further attempts to skirt the issue of privilege by failing to meaningfully
+identify the nature of the requested materials, other than describing "emails" and documents
+"other than emails". The materials requested by Epstein, essentially case files, client files, and
+investigative files are patently and obviously privileged. Epstein's counsel offers no argument,
+cognizable under any set of possibly applicable rules, to demonstrate entitlement to these
+privileged and work product materials.
+WHEREFORE, based on the foregoing, Epstein is not permitted to obtain production of
+documents and ESI from the Trustee which comprise the privileged, confidential, or attorney
+work product portions of case files or investigative files, and Movant requests that the Court
+deny Epstein's motion to compel, grant the foregoing motion for protective order, and enter a
+protective order excluding the production of any documents or ESI by the Trustee which relate to
+any cases or matter of
+clients and granting any other relief the Court deems
+appropriate.
+I HEREBY CERTIFY that, pursuant to L.R. 9073-1(D), Movant's counsel has
+the only toco
+further certify that a true and correct copy of the foregoing was served on electronically to the
+examinee, the debtor, the attorney for the debtor, the trustee, all CM/ECF subscribers, and by
+email or U.S. Mail on those parties listed on the attached service list this 27" day of September,
+2010.
+I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court
+for the Southern District of Florida and I am in compliance with the additional qualifications to
+practice in this court set forth in Local Rule 2090-1(A).
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 8 of 14
+Is/ Seth M. Lehrman
+Seth M. Lehrman
+seth@pathtojustice.com
+Florida Bar No.: 132896
+JAFFE, WEISSING,
+_ FISTOS & LEHRMAN, P.L
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+(954) 524-2820
+(954) 524-2822 (fax)
+Jack Scarola
+Florida Bar No.: 169440
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+West Palm Beach, FL 33409
+(561) 686-6300
+(561) 684-5816 (fax)
+Attorney for Bradley J. I
+NOT A CERTITE
+in the matter of
+8
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 9 of 14
+Authorized Agent For Joining Creditors
+Avenida Francisco de Miranda
+Torre Provincial "A"
+Caracas, Venezuela
+John H. Genovese, Esq.
+Robert F. Elgidely, Esq.
+Theresa M.B. Van Vliet, Esq.
+Genovese Joblove & Battista, PA
+Bank Of America Tower at International
+Place
+100 S.E. 2nd Street, Suite 4400
+Miami, Florida 33131
+Kendall Coffey, Esq.
+Coffey Burlington,
+Office in the Grove
+Penthouse
+2699 South Bayshore Drive
+Miami, Florida 33133
+kcoffey@coffeyburlington.com
+The Honorable Herbert M. Stettin
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+(VIA U,S. MAIL and EMAIL)
+John G. Bianco, Esq.
+John M. Mulli, Esquire
+Tripp Scott
+110 Southeast Sixth Street
+Fifteenth Floor
+Fort Lauderdale, FI. 33301
+jgb@trippscott.com
+Alison W. Lehr, Esq.
+Grisel Alonso, Esq.
+Assistant United States Attorney
+99 N.E. 4th Street, 7th Floor
+Miami, Florida 33132
+Alison.Lehr@usdoj.gov
+Grisel.alonso@usdoj.gov
+Jeffrey R. Sonn, Esq.
+Sonn & Erez, PLC
+Broward Financial Center
+500 E. Broward Boulevard
+Suite 1600
+Fort Lauderdale, Florida 33394
+jsonn@sonnerez.com
+(VIA CM/ECP and EMAIL)
+Office of the US Trustee
+51 Southwest First Avenue
+Suite 1204
+Miami, Florida 33130
+Tew, Esq.
+Tew-
+LLP
+Four Seasons Tower
+15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131-3407
+tt@tewlaw.com
+Conrad & Scherer, LLP
+Fort Lauderdale, FL 33301
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 10 of 14
+Michael D. Seese, Esq.
+Hinshaw & Culbertson, LLP
+1 E Broward Blvd Ste 1010
+Ft Lauderdale, Florida 33301
+mseese@hinshawlaw.com
+Internal Revenue Service
+Centralized Insolvency Operations
+P.O. Box 21126
+Philadelphia, PA 19114
+(Via U.S. Mail)
+Internal Revenue Service
+Special Procedures - Insolvency
+7850 SW 6th Court
+Plantation, FL 33324
+(Via U.S. Mail)
+Special Asst. U.S. Attorney
+P.O. Box 9, Stop 8000
+51 SW Ist Avenue, #1114
+Miami, FI 33130
+(Via U.S. Mail)
+United Healthcare
+Dept. CH 10151
+Palatine, IL 60055
+Special Asst. U.S. Attorney
+IRS District Counsel
+1000 S. Pine Island Rd., Ste 340
+Plantation, FL 33324-3906
+(Via U.S. Mail)
+The Honorable Eric H. Holder, Jr.
+Attorney General of the U.S
+950 Pennsylvania Avenue, NW Room 4400
+Washington, DC 20530-0001
+(Via U.S. Mail)
+Honorable Jeffrey H. Sloman
+Acting U.S. Attorney
+99 NE 4th Street
+Miami, FI 33132
+(Via U.S. Mail)
+Daniel Mink
+Ovadia Levy
+c/o Renato Watches, Inc
+14051 NW 14th Street
+Sunrise, Florida 33323
+(Via U.S. Mail)
+William
+Salim, Jr.
+Moskowitz Mandell & Salim
+OPY
+800 Corporate Dr Ste 510/
+Fort Lauderdale, Florida 33334
+wsalim@mmsslaw.com
+UST
+Altn. Anthony Gruppo
+200 West Cypress Creek Road
+Suite 500
+Fort Lauderdale, FL 33309
+Anthony gruppo@usi.biz
+(VIA EMAIL)
+farc Nurik, Esc
+East Broward Blv
+VA ENA 2023301
+BAST AMRON LLP
+SunTrust International Center
+One Southeast Third Avenue
+Baron lorsanron.com
+jbast@bastamron.com
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 11 of 14
+John B. Hutton, Esq.
+Greenberg Traurig, LLP
+1221 Brickell Avenue
+Miami, FL 33131
+bloomm@gtlaw.com
+huttonj@gtlaw.com
+Robert D. Critton, Esq.
+Burman, Critton, Luttier & Coleman
+303 Banyan Blvd., Suite 400
+West Palm Beach, FL 33401
+rcrit@bclclaw.com
+Roth & Scholl
+Attn: Jeffrey C. Roth, Esq.
+Attorneys For Creditor Blue
+Capital Us East Coast Properties, L.P.
+866 South Dixie Highway
+Coral Gables, FI 33146
+jeff@rothandscholl.com
+Rogers, Morris & Ziegler, LLP
+1401 East Broward Bivd
+Suite 300
+Fort Lauderdale, FL 33301
+mfbooth@rmzlaw.com
+Arthur C. Neiwirth, Esq.
+One E. Broward Blvd., Suite 1400
+Ft. Lauderdale, FL 33301
+aneiwirth@qpwblaw.com
+\dria E. Quintela, Esq
+lan Anthony Pascal, Esc
+Lake Shore Plaza II
+1300 Concord Terrace, Suite 130
+Sunrise, FL 33323
+aquintel@flabar.ors
+pascal@flabar.org
+Micheal W. Moskowitz, Esq.
+800 Corporate Drive, Suite 500
+Ft. Lauderdale, FL 33234
+mmoskowitz@mmsslaw.com
+Francis L. Carter, Esq.
+Katz Barron Squitero Faust
+2699 S. Bayshore Drive, 7th Floor
+Miami, Florida 33133
+flc@katzbarron.com
+Bradley S. Shraiberg, Esq.
+2385 NW Executive Drive
+Suite 300
+Boca Raton, Florida 33431
+bshraiberg@sfl-pa.com
+Henry S. Wulf, Esq.
+CARLTON
+P.A.
+525 Okeechobee Bivd., Suite 1200
+West Palm Beach, Florida 33401
+E-Mail: hwulf@carltonfields.com
+EMESS Capital, LLC
+c/o Bruce A. Katzen, Esq.
+201 S. Biscayne Blvd., 17th Floor
+Miami, Florida 33131|
+E-Mail: bkatzen@klugerkaplan.com
+erman@klugerkaplan.cor
+JIA CM/EČF and EMAI
+11
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 12 of 14
+c/o Phil Hudson, Esq.
+200 South Biscayne Blvd, Suite 3600
+Miami, Florida 33130
+E-Mail: pmhudson@arnstein.com
+Coquina Investments
+c/o Patricia A. Redmond, Esq.
+150 West Flagler Street, Suite 2200
+Miami, Florida 33130
+E-Mail: predmond@stearnsweaver.com
+Michael I. Goldberg, Esq.
+Las Olas Centre - Suite 1600
+350 East Las Olas Blvd
+Fort Lauderdale, FL 33301
+E-Mail: Michael.goldberg@akerman.com
+Eyal.berger@akerman.com
+LMB Funding Group
+c/o Robert C. Furr, Esq.
+2255 Glades Road, Suite 337W
+Boca Raton, Florida 33431
+E-Mail: rfurr@furrcohen.com
+A. Gordich, Esq.
+Melissa Alagna, Esq.
+SEGALL/GORDICH P.A.y
+801 Brickell Avenue, Suite 900
+Miami, Florida 33131
+Email: lag@segallgordich.com
+Email: mma@segallgordich.com
+Broward County - Attn: Hollie N. Hawn, Esq.
+Government Center
+115 South Andrews Avenue
+Fort Lauderdale, FL 33301
+E-Mail: hhawn@broward.org
+Steven J.
+, Esq.
+Gray
+P.A
+1221 Brickell Ave, Suite 1600
+Miami, Florida 33131
+E-Mail -
+com
+Peter F. Valori, Esq.
+DAMIAN & VALORI LLP
+1000 Brickell Avenue, Suite 1020
+Miami, FL 33131
+3-mail: pvalori@dvllp.con
+VIA CM/ECF and EMAIL
+Canon Financial Services, Inc.
+158 Gaither Drive, #200
+Mount Laurel, NJ 08054
+CIT Technology Financing Services I,
+LLC
+10201 Centurion Parkway North
+Jacksonville, FL 32256
+Gibraltar Private Bank & Trust
+Company
+220 Alhambra Circle, Suite 500
+Coral Gables, FL 33134
+Inter-Tel Leasing, Inc.
+1140 West Loop North
+Houston, TX 77055
+Florida Department of Revenue
+501 S. Calhoun Street
+Room 201
+Carlton Building
+Tallahassee, FL 32399
+
+
+Case 09-34791-RBR Doc 1022 Filed 09/27/10 Page 13 of 14
+/ County Tax Collector
+315 S. Calhoun Street, Suite 210
+Tallahassee, FL 32301
+Miami-Dade County Tax Collectors
+140 West Flagler Street, 14th Floor
+Miami, FL 33130
+Palm Beach County Tax Collector
+P.O. Box 3715
+West Palm Beach, FL 33402-3715
+THE LAW OFFICES OF
+GEOFFREY D. ITTLEMAN, P.A.
+440 North Andrews Avenue
+Fort Lauderdale, Florida 33301
+Carpenter & Berger, PL
+6400 N. Andrew Ave, suite 370
+Fort Lauderdale, FL 33309
+F. McGinn, Esq.
+Bartlett /
+Feinberg, P.C.
+155 Federal Street, 9th Floor
+Boston,
+02110
+ffim@bostonbusinesslaw.com
+Darol H. M. Caft, Esq.
+99 Nesbit Street
+Punta Gorda, FL 33950
+dcarr@farr.com
+Jane A. Bee, Esq.
+Blank Rome LLP
+130 North 18th Street
+Philadelphia, PA 19103-6998
+bee@blankrome.com
+(VIA EMAIL)
+Roderick F. Coleman, Esq.
+400 South Dixie Highway, Suite 121
+Boca Raton, FL 33432
+rfc@colemanattorneys.com
+Mark S. Haltzman, Esq.
+Lamm Rubenstone, LLC
+3600 Horizon Blvd, Suite 200
+Trevose, PA 19053
+mhaltzman@lammrubenstone.com
+Robert C. Buschel, Esq.
+100 S.E. Third Ave, Suite 1300
+Fort Lauderdale, FL 33394
+busehel@bglaw-pa.com
+Berkowitz Dick Pollack & Brant
+Certified Public Accountants & Consultants,
+LLP
+200 S Biscayne Boulevard, Sixth Floor
+Miami, FL 33131-2310
+Attn: Richard Pollack
+(Via Email and U.S. Mail)
+MELAND RUSSIN & BUDWICK, P.A.
+3000 Wachovia Financial Center
+200 South Biscayne Boulevard
+Miami, Florida 33131
+Attn: James C. Moon, Esq.
+jmoon@melandrussin.com
+Attn: Peter D. Russin, Esq.
+prussin@melandrussin.com
+Attn: Michael S. Budwick, Esq
+mbudwick@melandrussin.com
+gblake@|glaw.net
+13
+
+
+Case 09-34791-RBR
+Doc 1022 Filed 09/27/10 Page 14 of 14
+Melinda S. Thornton, Esq.
+Assistant County Attorney
+County Attorney's Office
+2810 Stephen P. Clark Center
+111 N. W. First Street
+Miami, FI 33128-1993
+Email: cao.bkc@miamidade.gov
+SLATKIN &
+P.A.
+Attorneys for
+Adler and Katie Adler
+One East Broward Boulevard, Suite 609
+Fort Lauderdale, Florida 33301
+jslatkin@slatkinreynolds.com
+ASSOULINE & BERLOWE, P.A.
+213 East Sheridan Street, Ste. 3
+Dania Beach, FL 33004
+Attn: Eric N. Assouline, Esq.
+ena@assoulineberlowe.com
+Steven J. Reisman, Esq.
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: sreisman@curtis.com
+(Via Email and U.S. Mail)
+Turner P.
+Esq.
+CURTIS, MALLET-PREVOST, COLT &
+MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: tsmith@curtis.com
+(Via Email and U.S. Mail)
+Heather L. Ries, Esq.
+Fox Rothschild, LLP
+222 Lakeview Ave, Suite 700
+West Palm Beach, FI 33401
+hries@foxrothschild.com
+Maryann Gallagher, Esq.
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: mgallagher@curtis.com
+(Via Email and U.S. Mail)
+ILEANA CRUZ BONGINI, ESQ.
+icruz@stearnsweaver.com
+STEARNS WEAVER MILLER
+WEISSLER ALHADEFF & SITTERSON, P.A.
+Coquina Investments
+Museum Tower, Suite 2200
+150 West Flagler Street
+Miami, Florida 33130
+Maynard Gollin
+Igollin@gordonrees.com
+Gordon & Rees LLP
+Four Seasons Tower, 15th Floor
+1441 Brickell Avenue
+Miami, FL 33131
+Paul J. McMahon, Esq.
+Paul
+McMahon, P.A.
+2840 S. W. Third Ave
+Miami, Florida 33129
+pjm@pjmlawmiami.com
+Robert P. Avolio, Esq.
+Crossroads Corporate Center
+150 Brunswick Pike, Ste. 12
+awrenceville, NJ 0864
+ravolio@avoliohanlon.com
+(Via Email and U.S. Mail)
+Mark S. Shipman, Esq.
+20 Batterson Park Road, Suite 120
+Farmington, CT 06032
+mark@shipso.com
+(Via Email and U.S. Mail
+14
+
+
+Case 09-34791-RBR Doc 1068 Filed 10/15/10
+
+ED
+ORDERED in the Southern District of Florida on October 15, 2010.
+Raymond B. Ray, Judge
+United States Bankruptcy Court
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts/gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+AMENDED ORDER RESPECTING PRODUCTION OF
+DOCUMENTS REGARDING JEFFREY EPSTEIN
+THIS CAUSE came before the Court for hearing on October 13, 2010 upon the Motion to
+Clarify Order Appointing Special
+(D.E. #1013) which pertains to this Court's Order
+Respecting Production of Documents Regarding Jeffrey Epstein (D.E. #888) ("Order 888"). The
+Court heard argument of all counsel present at the hearing, and being otherwise duly advised in
+the premises,
+DOES HEREBY ORDER:
+Order 888 is amended solely as follows:
+
+
+
+Case 09-34791-RBR Doc 1068 Filed 10/15/10 Page 2 of 3
+a.
+Within two business days following receipt of this order, Berger
+Singerman, as counsel for the Trustee, Herbert Stettin (Trustee"), shall deliver to Gary
+at the
+Jaffe, Weissing,
+, Fistos & Lehrman, P.L. law firm ("
+Jaffe), a
+copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special |
+and
+which contains all electronically stored information ("EST") and other documents in the Trustee's
+possession, respecting the subject matter of the subpoena previously served upon the Trustee
+related to L.M., Scott Rothstein, Brad
+and Jeffrey Epstein.
+Jaffe shall review all documents contained on the CD and prepare
+a detailed privilege log within thirty (30) days of receipt of the CD.
+Jaffe shall serve the
+privilege log on all parties in interest to these proceedings and file same with the Court.
+c.
+Contemporaneous with the service and filing of the privilege log,
+Jaffe shall provide to a reputable copy service an unredacted copy of the Trustee's CD of
+documents, and that copy service shall duplicate and bate stamp all documents on the CD, and
+return all materials to
+Jaffe, who shall forthwith notify Trustee's counsel and the Special
+of the bate stamp rangé of documents.
+Jaffe shall then extract from the hard copy
+duplicated documents solely those documents which it listed on the privilege log, and segregate
+those documents for submission to the Special
+and the Trustee's counsel.
+Jaffe
+shall furnish copies of the segregated documents to which it asserts a privilege both to the
+Special Master and the Trustee at |
+Jaffe's cost.
+d.
+To the extent that documents on the CD are duplicated and not subject to
+an assertion of privilege, they shall be forthwith provided to counsel for Epstein, counsel to the
+Razorback creditors, as well as to any other party who requests such documents, all at their own
+respective cost.
+2
+
+
+Case 09-34791-RBR Doc 1068
+Filed 10/15/10 Page 3 of 3
+e.
+Following service and filing of the privilege log, the Special
+shall
+schedule a hearing to occur at the offices of Berger Singerman where all parties in interest will
+have the opportunity to provide written submissions respecting the privilege log and to make
+argument on all issues relevant to the applicability of privilege as to the documents listed on the
+Jaffe privilege log. That hearing shall be transcribed by a court reporter.
+f.
+Following completion of the aforementioned hearing, the Special
+shall prepare a report making all appropriate findings and recommendations to the Çourt, which
+shall be served on all parties in interest and filed with the Court, along with the transcript of the
+Special
+hearing.
+g.
+Any party may file a written objection to the Special
+report
+within ten days after service of same. If no party files an objection to the report, the Court shall
+approve the report and adopt same into a court order without further notice to the parties. If an
+objection to the report is filed by any party in interest, then this Court shall schedule and hold a
+hearing to resolve with finality the issues of privilege as consistent with the appropriate law and
+procedures set forth herein.
+
+Submitted by:
+BERGER SINGERMAN, P.A.,
+350 East Das Olas Boulevard, Suite 1000
+Fort Lauderdale, FL 33301
+Telephone: (954) 525-9900
+Facsimile: (954) 523-2872
+clichtman@bergersingerman.com
+Copy furnished to:
+(Charles H. Lichtman is directed to serve this Order to all parties of interest and to file a
+Certificate of Service.)
+2996606-3
+3
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 1 of 11
+FORT LAUDERDALE DIVISION
+www.flsb.uscourts.gov
+CASE NO.: 09-34791-RBR
+CHAPTER 11
+IN RE:
+ROTHSTEIN ROSENFELDT ADLER, P.A.,
+Debtor.
+MOTION FOR RELIEF FROM AMENDED ORDER ID.E. 10681
+AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE
+PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REQUEST
+Movants, LM and
+J.
+, move this Court for relief from Amended Order
+[D.E. 1068] related to the production of documents requested by Jeffrey Epstein and to Compel
+Jeffrey Epstein to Pay for the Production of all Documents which he has requested, and in
+support thereof, states as follows:
+Brad
+an attorney employed by
+Jaffe, Weissing,
+Fistos
+& Lehrman, P.L. ("
+Jaffe Weissing"), has represented LM and other women who allege
+that they were sexually exploited, sexually abused, and otherwise victims of intentional and
+despicable conduct of Jeffrey Epstein. Epstein's conduct has been the subject of several lawsuits
+vigorously litigated by Mr.
+, as well as similar lawsuits filed by other well-known
+attorneys and law firms on behalf of other victims.
+Epstein filed a frivolous lawsuit against Attorney |
+and his client LM, who
+is one of Epstein's former victims, and through this lawsuit has sought voluminous discovery
+from the Trustee, including many documents which are patently subject to claims of privilege
+and/or attorney work product and/or privacy. Epstein's requests were so overbroad that they
+include the entire legitimate case files and investigative files of Attorney
+The Court previously entered Amended Order [D.E. 1068] which crafted a
+
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 2 of 11
+procedure by which the undersigned counsel would have a reasonable opportunity to review
+those documents in the Trustee's possession which are responsive to Epstein's request.
+Accordingly, the Amended Order directed the Trustee to provide the undersigned counsel with
+documents and ESI in response to a state court subpoena duces tecum served by Jeffrey Epstein.
+This Amended Order directs the undersigned counsel to prepare and file a privilege log and
+imposes the expense associated with printing all documents produced by the Trustee on
+undersigned counsel.
+4.
+Prior to receiving the CD from Trustee's counsel the undersigned, as well as
+perhaps all parties involved, was under the impression that the production consisted of
+approximately 6,000 pages of documents.
+In fact, it was during, or just after, the hearing on Special
+Motion to
+Clarify Order Appointing Special
+when Trustee's counsel realized that the Trustee may
+be in possession of additional ESI stored in a Fortis file system.
+Consequently, the Trustee has now produced to the undersigned counsel two
+compact discs ("CDs") which contain approximately 74,000 pages of documents.
+7.
+Additionally, one of the files produced by Trustee was a corrupt and unworkable
+file; on October 25, 2010 Movants requested that this corrupted file be resent to their office. In
+addition, Movants requested that the files be
+stamped electronically so that a better record
+for the privilege log can be created. To date Movants still have not received the new disc(s).
+8
+Once Movants receive all files in a workable format, reviewing 74,000 pages of
+documents and creating a privilege log will take considerable more attorney time than was
+anticipated.
+Consequently, Movants are requesting an additional 30 days to complete this
+process.
+2
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 3 of 11
+In accordance with this Court's order, undersigned counsel have obtained an
+estimate of the printing and
+stamping costs associated with printing this 74,000 page
+collection of documents requested by Epstein. The cost of printing these documents exceeds
+$7,000 ($0.10 per page x 74,000 pages).
+Epstein, through counsel, has previously represented to the Trustee that he is
+willing to bear the reasonable expense associated with this production, and in fact the original
+Order that contemplated Special
+• Carney preparing the Privilege log (DE 888) directly
+stated, "All legal fees and costs incurred by the Special
+shall be paid by Epstein, who has
+already agreed to pay directly all such fees and costs."
+11.
+With approximately 74,000 pages to print,
+stamp, review, and create a
+privilege log that can only be done by the attorneys that handled or are handling the Epsteinrelated cases, it will take many full days for the atforneys to complete, and the attorneys
+engaging in this exercise should be compensated for their time.
+12.
+It is entirely reasonable that Epstein, the party seeking this discovery, bear the
+printing expense and other reasonable costs and attorney's fees associated with his discovery
+request.
+WHEREFORE, based on the foregoing, LM and Attorney
+request that the
+Court grant this motion for relief from amended order [DE 1068] and enter an order which
+compels Ep
+to prepay the cost of printing all documents responsive to his request as well as
+reasonable attorney's fees for this time-consuming task and enlarging the time for the
+undersigned counsel to file a privilege log by thirty days from the date that Epstein pays the
+printing costs, and granting any other relief the Court deems appropriate.
+1 HEREBY CERTIFY that, pursuant to L.R. 9073-I(D), Movant's counsel has
+3
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 4 of 11
+contacted Epstein's counsel in a good faith attempt to resolve the matter without a hearing and I
+further certify that a true and correct copy of the foregoing was served on electronically to the
+examinee, the debtor, the attorney for the debtor, the trustee, all CM/ECF subscribers, and by
+email or U.S. Mail on those parties listed on the attached service list this 2nd day of November,
+2010.
+I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court
+for the Southern District of Florida and I am in compliance with the additional qualifications to
+practice in this court set forth in Local Rule 2090-I(A).
+•JAFFE, WEISSING,
+_. FISTOS & LEHRMAN, P.L.
+By:
+Is/ Seth Lehrman
+Seth Lehrman FLBN 132896
+Gary M. Farmer FLBN 914444
+Brad J. Edwards FLBN 542075
+NOT A CERe
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+(954)524-2820 (954)524-2822 Fax
+seth@pathtojustice.com
+JACK SCAROLA Florida Bar No.: 169440
+Searcy, Denney, Scarola, Barnhart & Shipley
+2139 Palm Beach Lakes Blvd
+West Palm Beach, FL 33409
+(561) 686-6300
+(561) 684-5816 (fax)
+4
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 5 of 11
+Authorized Agent For Joining Creditors
+Avenida Francisco de Miranda
+Torre Provincial "A"
+Caracas, Venezuela
+VIA CM/ECF and EMAIL
+John H. Genovese, Esq.
+Robert F. Elgidely, Esq.
+Theresa M.B. Van Vliet, Esq.
+Genovese Joblove & Battista, PA
+Bank Of America Tower at International
+Place
+100 S.E. 2nd Street, Suite 4400
+Miami, Florida 33131
+Kendall Coffey, Esq.
+Coffey Burlington,
+Office in the Grove
+Penthouse
+2699 South Bayshore Drive
+Miami, Florida 33133
+kcoffey@coffeyburlington.com
+The Honorable Herbert M. Stettin
+One Biscayne Tower
+Suite 3700
+Two South Biscayne Boulevard
+Miami, Florida 33131
+(VIA U,S. MAIL and EMAIL)
+John G. Bianco, Esq.
+John M. Mulli, Esquire
+Tripp Scott
+110 Southeast Sixth Street
+Fifteenth Floor
+Fort Lauderdale, FI. 33301
+jgb@trippscott.com
+Alison W. Lehr, Esq.
+Grisel Alonso, Esq.
+Assistant United States Attorney
+99 N.E. 4th Street, 7th Floor
+Miami, Florida 33132
+Alison.Lehr@usdoj.gov
+Grisel.alonso@usdoj.gov
+Jeffrey R. Sonn, Esq.
+Sonn & Erez, PLC
+Broward Financial Center
+500 E. Broward Boulevard
+Suite 1600
+Fort Lauderdale, Florida 33394
+jsonn@sonnerez.com
+Office of the US Trustee
+51 Southwest First Avenue
+Suite 1204
+Miami, Florida 33130
+Tew, Esq.
+Tew-
+,, LLP
+Four Seasons Tower
+15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131-3407
+tt@tewlaw.com
+Conrad & Scherer, LLP
+5
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 6 of 11
+Michael D. Seese, Esq.
+Hinshaw & Culbertson, LLP
+1 E Broward Blvd Ste 1010
+Ft Lauderdale, Florida 33301
+mseese@hinshawlaw.com
+Internal Revenue Service
+Centralized Insolvency Operations
+P.O. Box 21126
+Philadelphia, PA 19114
+(Via U.S. Mail)
+Internal Revenue Service
+Special Procedures - Insolvency
+7850 SW 6th Court
+Plantation, FL 33324
+(Via U.S. Mail)
+Special Asst. U.S. Attorney
+P.O. Box 9, Stop 8000
+51 SW Ist Avenue, #1114
+Miami, FI 33130
+(Via U.S. Mail)
+United Healthcare
+Dept. CH 10151
+Palatine, IL 60055
+Special Asst. U.S. Attorney
+IRS District Counsel
+1000 S. Pine Island Rd., Ste 340
+Plantation, FL 33324-3906
+(Via U.S. Mail)
+The Honorable Eric H. Holder, Jr.
+Attorney General of the U.S.
+950 Pennsylvania Avenue, NW Room 4400
+Washington, DC 20530-0001
+(Via U.S. Mail)
+Honorable Jeffrey H. Sloman
+Acting U.S. Attorney
+99 NE 4th Street
+Miami, FI 33132
+(Via U.S. Mail)
+Daniel Mink
+Ovadia Levy
+c/o Renato Watches, Inc
+14051 NW 14th Street
+Sunrise, Florida 33323
+(Via U.S. Mail)
+William |
+Salim, Jr.
+Moskowitz Mandell & Salin
+300 Corporate Dr Ste 510
+Fort Lauderdale, Florida 33334
+wsalim@mmsslaw.com
+UST.
+Attn: Anthony Gruppo
+200 West Cypress Creek Road
+Suite 500
+Marc Nurik, Esq.
+1 East Broward Blvd
+Fort Lauderdale, FL 33301
+marc@nuriklaw.com
+(VIA EMAIL)
+BAST AMRON LLP
+SunTrust International Center
+One Southeast Third Avenu
+Suite 1440
+liami, Florida 3313
+amron@bastamron.cor
+jbast@bastamron.com
+6
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 7 of 11
+John B. Hutton, Esq.
+Greenberg Traurig, LLF
+1221 Brickell Avenue
+Miami, FL 33131
+bloomm@gtlaw.com
+huttonj@gtlaw.com
+Robert D. Critton, Esq.
+rcrit@bclclaw.com
+Roth & Scholl
+Attn: Jeffrey C. Roth, Esq.
+Attorneys For Creditor Blue
+Capital Us East Coast Properties, L.P.
+866 South Dixie Highway
+Coral Gables, FI 33146
+jeft@rothandscholl.com
+Rogers, Morris & Ziegler, LLP
+1401 East Broward Blvd
+Suite 300
+Fort Lauderdale, FL 33301
+mfbooth@rmzlaw.com
+Arthur C. Neiwirth, Esq.
+One E. Broward Blvd., Suite 1400
+Ft. Lauderdale, FL 33301
+aneiwirth@qpwblaw.com
+(VIA CM/CF and EMAIL)
+apascal@flabar.org
+Micheal W. Moskowitz, Esq.
+800 Corporate Drive, Suite 500
+Ft. Lauderdale, FL 33234
+mmoskowitz@mmsslaw.com
+Francis L. Carter, Esq.
+Katz Barron Squitero Faust
+2699 S. Bayshore Drive, 7th Floor
+Miami, Florida 33133
+fle@katzbarron.com
+Bradley S. Shraiberg, Esq.
+2385 NW Executive Drive
+Suite 300
+Boca Raton, Florida 33431
+bshraiberg@sfl-pa.com
+Henry S. Wulf, Esq.
+CARLTON
+, P.A.
+525 Okeechobee Blvd., Suite 1200
+West Palm Beach, Florida 33401
+E-Mail: hwulf@carltonfields.com
+EMESS Capital, LLC
+c/o Bruce A. Katzen, Esq.
+201 S. Biscayne Blvd., 17th Floor
+Miami, Florida 33131
+E-Mail: bkatzen@klugerkaplan.com
+jberman@klugerkaplan.com
+7
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 8 of 11
+c/o Phil Hudson, Esq.
+200 South Biscayne Blvd, Suite 3600
+Miami, Florida 33130
+E-Mail: pmhudson@arnstein.com
+Coquina Investments
+c/o Patricia A. Redmond, Esq.
+150 West Flagler Street, Suite 2200
+Miami, Florida 33130
+E-Mail: predmond@stearnsweaver.com
+Michael 1. Goldberg, Esq.
+Las Olas Centre - Suite 1600
+350 East Las Olas Blvd
+Fort Lauderdale, FL 33301
+E-Mail: Michael.goldberg@akerman.com
+Eyal.berger@akerman.com
+LMB Funding Group
+c/o Robert C. Furr, Esq.
+2255 Glades Road, Suite 337W
+Boca Raton, Florida 33431
+E-Mail: rfurr@furrcohen.com
+A. Gordich, Esq.
+Melissa Alagna, Esq.
+SEGALL/GORDICH P.A,
+801 Brickell Avenue, Suite 900
+Miami, Florida 33131
+Email: lag@segallgordich.com
+Email: mma@segallgordich.com
+Broward County - Attn: Hollie N. Hawn, Esq.
+Government Center
+115 South Andrews Avenue
+Fort Lauderdale, FL 33301
+E-Mail: hhawn@broward.org
+Steven J.l
+, Esq.
+Gray
+P.A.
+1221 Brickell Ave, Suite 1600
+Miami, Florida 33131
+E-Mail -
+com
+Peter F. Valori, Esq.
+DAMIAN & VALORI LLP
+1000 Brickell Avenue, Suite 1020
+Miami, FL 33131
+E-mail: pvalori@dvllp.com
+Canon Financial Services, Inc.
+158 Gaither Drive, #200
+Mount Laurel, NJ 08054
+CIT Technology Financing Services I,
+LLe
+10201 Centurion Parkway North
+Jacksonville, FL 32256
+Gibraltar Private Bank & Trust
+Company
+220 Alhambra Circle, Suite 500
+Coral Gables, FL 33134
+Inter-Tel Leasing, Inc.
+1140 West Loop North
+Houston, TX 77055
+Florida Department of Revenue
+Learn tun sued
+Tallahassee, FL 32399
+8
+
+
+Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 9 of 11
+County Tax Collector
+315 S. Calhoun Street, Suite 210
+Tallahassee. FL 32301
+Miami-Dade County Tax Collectors
+140 West Flagler Street, 14th Floor
+Miami, FL 33130
+Palm Beach County Tax Collector
+P.O. Box 3715
+West Palm Beach, FL 33402-3715
+THE LAW OFFICES OF
+GEOFFREY D. ITTLEMAN, P.A.
+440 North Andrews Avenue
+Fort Lauderdale, Florida 33301
+Carpenter & Berger, PL
+6400 N. Andrew Ave, suite 370
+Fort Lauderdale, FL 33309
+F. McGinn, Esq.
+Bartlett
+155 Federal Street, 9th Floor
+Boston,
+02110
+ffim@bostonbusinesslaw.com
+Darol H. M. Carr, Esq.
+99 Nesbit Street
+Punta Gorda, FL 33950
+dcarr@farr.com
+Jane A. Bee, Esq.
+Blank Rome LLP
+130 North 18th Street
+Philadelphia, PA 19103-6998
+bee@blankrome.com
+(VIA EMAIL)
+Roderick F. Coleman, Esq.
+400 South Dixie Highway, Suite 121
+Boca Raton, FL 33432
+rfc@colemanattorneys.com
+Mark S. Haltzman, Esq.
+Lamm Rubenstone, LLC
+3600 Horizon Blvd, Suite 200
+Trevose, PA 19053
+mhaltzman@lammrubenstone.com
+Robert C. Buschel, Esqu
+100 S.E. Third Ave, Suite 1300
+Fort Lauderdale, FL 33394
+buschel@bglaw-pa.com
+Berkowitz Dick Pollack & Brant
+Ceftified Public Accountants & Consultants,
+LLP
+200 $ Biscayne Boulevard, Sixth Floor
+Miami, FL 33131-2310
+Attn: Richard Pollack
+(Via Email and U.S. Mail)
+MELAND RUSSIN & BUDWICK, P.A.
+3000 Wachovia Financial Center
+200 South Biscayne Boulevard
+Miami, Florida 33131
+Attn: James C. Moon, Esq.
+jmoon@melandrussin.com
+Attn: Peter D. Russin, Esq.
+prussin@melandrussin.com
+Abut wickens andrusin com.
+9
+
+
+Case 09-34791-RBR Doc 1120
+Filed 11/02/10 Page 10 of 11
+Melinda S. Thornton, Esq-
+Assistant County Attorney
+County Attorney's Office
+2810 Stephen P. Clark Center
+111 N.W. First Street
+Miami, FI 33128-1993
+Email: cao.bkc@miamidade.gov
+SLATKIN &
+P.A.
+Attorneys for
+Adler and Katie Adler
+One East Broward Boulevard, Suite 609
+Fort Lauderdale, Florida 33301
+jslatkin@slatkinreynolds.com
+ASSOULINE & BERLOWE, P.A.
+213 East Sheridan Street, Ste. 3
+Dania Beach, FL 33004
+Attn: Eric N. Assouline, Esq.
+ena@assoulineberlowe.com
+Steven J. Reisman, Esq.
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: sreisman@curtis.com
+(Via Email and U.S. Mail)
+Turner P.
+Esq.
+CURTIS, MALLET-PREVOST, COLT &
+MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: tsmith@curtis.com
+(Via Email and U.S. Mail)
+Heather L. Ries, Esq.
+Fox Rothschild, LLP
+222 Lakeview Ave, Suite 700
+West Palm Beach, FI 33401
+hries@foxrothschild.com
+Maryann Gallagher, Esq.
+CURTIS, MALLET-PREVOST,
+COLT & MOSLE LLP
+101 Park Avenue
+New York, NY 10178-0061
+E-mail: mgallagher@curtis.com
+(Via Email and U.S. Mail)
+ILEANA CRUZ BONGINI, ESQ.
+icruz@stearnsweaver.com
+STEARNS WEAVER MILLER
+WEISSLER ALHADEFF & SITTERSON, P.A.
+Coquina Investments
+Museum Tower, Suite 2200
+150 West Flagler Street
+Miami, Florida 33130
+Maynard Gollin
+Igollin@gordonrees.com
+& Rees LLP
+Four Seasons Tower, 15th Floor
+144| Brickell Avenue
+Miami, FL 33131
+Paul J. McMahon, Esq.
+Paul
+McMahon, P.A.
+2840 S.W. Third Ave
+Miami, Florida 33129
+pjm@pjmlawmiami.com
+Robert P. Avolio, Esq.
+Crossroads Corporate Center
+3150 Brunswick Pike, Ste. 120
+Lawrenceville, NJ 08648
+ravolio@avoliohanlon.com
+(Via Email and U.S. Mail)
+Mark S. Shipman, Esq.
+20 Batterson Park Road, Suite 120
+Farmington, CT 06032
+mark@shipso.com
+(Via Email and U.S. Mail)
+10
+
+
+Case 09-34791-RBR
+Doc 1120
+Filed 11/02/10 Page 11 of 11
\ No newline at end of file
diff --git a/vision-fixhub/court-02/092edac96ede7c0d63b337e09c7cd3679a9a840829c42c8c584a714054d91ad3.receipt.json b/vision-fixhub/court-02/092edac96ede7c0d63b337e09c7cd3679a9a840829c42c8c584a714054d91ad3.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b29964e4e07b3cba7f9afe0d84895b06d4822199
--- /dev/null
+++ b/vision-fixhub/court-02/092edac96ede7c0d63b337e09c7cd3679a9a840829c42c8c584a714054d91ad3.receipt.json
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+  "page_markers": false,
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.md b/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.md
new file mode 100644
index 0000000000000000000000000000000000000000..ddabe8afe9534f9d9df5747b7c1c92b2dea9e57d
--- /dev/null
+++ b/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.md
@@ -0,0 +1,110 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendants).
+SHARON R. BOCK. CLERK
+20L1 DEC -5 PM 3: 47
+FILED
+NOTICE OF TAKING DEPOSITION
+TO:
+All counsel on the attached Counsel List
+PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of:
+NAME AND ADDRESS
+DATE AND TIME
+LOCATION
+Howard Rubenstein
+January 23, 2012
+1:30 p.m.
+Location to be determined
+New York City, NY
+upon oral examination before Esquire Reporting, a Notary Public; or any other officer authorized
+by law to take depositions in the State of New York. The oral examination is being taken for the
+purpose of discovery, for use at trial, or for such other purposes as are permitted under the
+applicable Statutes or Rules.
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+Fax and U.S. Mail to all Counsel on the attached list, this 2nd day of December, 2011.
+
+
+..
+Notice of Taking Deposition
+So than
+ack Scarol:
+Flonda Bar No.: 169440
+Searcy Denney Scarola Barnhart & Shipley
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone:
+(561) 686-6300
+Fax:
+Attorney for
+650 33454
+CC:
+Esquire Reporting
+E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED
+NOT A CERT
+
+
+Notice of Taking Deposition
+"If you are a person with a disability who needs any accommodation in order
+to participate in this proceeding, you are entitled, at no cost to you, to the
+provision of certain assistance. Please contact Krista Garber, Americans with
+Disabilities Act Coordinator, at least 7 days before your scheduled court
+appearance, or immediately upon receiving this notification if the time before
+the scheduled appearance is less than 7 days; if you are hearing or voice
+impaired, call 711"
+"Si usted es una persona minusválida que necesita algún acomodamiento para
+poder participar en este procedimiento, usted tiene derecho, sin tener gastos
+propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en
+contacto con Krista Garber Americans with Disabilities Act Coordinator, ,
+por lo menos 7 días antes de la cita fijada para su comparecencia en los
+tribunales, o inmediatamente después de recibir esta notificación si el tiempo
+antes de la comparecencia que se ha programado es menos de 7 días; si usted
+tiene discapacitación del oído o de la voz, lame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan
+pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon
+pou jwen kèk èd. Tanpri kontakte nan 7 jou anvan dat ou gen randevou pou
+parèt nan tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon
+an si lè ou gen pou w parèt nan tribinal la mwens ke 7 jou; si ou gen pwoblèm
+pou w tande oubyen pale, rele 711."
+NOT
+
+
+Notice of Taking Deposition
+4
+COUN
+SE
+LIST
+Jack A. Goldberger, Esquire
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Jaffe, Weissing,
+Lehrman, PL
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Ackerman, Jr., Esquire
+Burnett, P.A.
+Point West
+777 S Flagler Drive
+West Palm Beach, FL 33401-6170
+Phone: (561)-802-9044
+Fax: (561)-802-9976
+Fistos &
+ERTIFIED COPY
+Marc S. Nurik, Esquire
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.receipt.json b/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..970879a751e78f450e3e8436ad8880f2af168dba
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+++ b/vision-fixhub/court-02/0932f5cfdcd9dd121b0a32c0e10dd56d7fc1b11b953d35ca91cb89211ca63211.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "da96997f4b0640afafdf8febc87b87695e51d53733398351df5d36bfa10f683c",
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514.md b/vision-fixhub/court-02/09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514.md
new file mode 100644
index 0000000000000000000000000000000000000000..be6a7c1b3bde01f721feca90e9021550923b37bf
--- /dev/null
+++ b/vision-fixhub/court-02/09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514.md
@@ -0,0 +1,19 @@
+Case 9:08-cv-80736-KAM Document 365-1 |
+Entered on FLSD Docket 02/11/2016 Page 1 of 1
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 9:08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2
+UNITED STATES
+/
+ORDER GRANTING PLAINTIFFS' MOTION TO REDACT/STRIKE
+It is hereby ordered that the clerk shall remove/strike [DE 361-70], [DE 362-24], [DE 362-
+26], which are exhibits to Plaintiffs' Consolidated Statement of Undisputed Material Facts and
+Motion for Partial Summary Judgment, [DE 361] from the docket and public view due to
+confidential information inadvertently filed.
+DONE AND ORDERED in
+at Palm Beach County, Florida, this _
+_ day of
+, 2016.
+KENNETH A. MARRA
+UNITED STATES DISTRICT JUDGE
diff --git a/vision-fixhub/court-02/09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514.receipt.json b/vision-fixhub/court-02/09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
+{
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+  "doc_id": "09463cffa2bab6d5ff183608554ef3a33a4f2f1b2ca402a938493e55f0139514",
+  "engine": "marble-apple-vision",
+  "event_count": 1,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "69526652d382c904440051d449f23ec4d1146fe808463f86c70b2744d5900e76",
+  "output_sha256": "09a94018ad8f5954c0bde52f9bf010dc5e0e67360fd3a81c41c559948e4fa204",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/094bfc7d91e395fcce015b2d026c9628a8c0cd589b3e2a691ecba3e7f0f18d93.md b/vision-fixhub/court-02/094bfc7d91e395fcce015b2d026c9628a8c0cd589b3e2a691ecba3e7f0f18d93.md
new file mode 100644
index 0000000000000000000000000000000000000000..d8f219810bff79c1e8d095a64b67c1b3cbad659c
--- /dev/null
+++ b/vision-fixhub/court-02/094bfc7d91e395fcce015b2d026c9628a8c0cd589b3e2a691ecba3e7f0f18d93.md
@@ -0,0 +1,53 @@
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Complex Litigation, Fla. R. Civ. Pro. 1201
+Case No. 50 2009 CA 040800XXXXMBAG
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and L.M., individually,
+Defendants/Counter-Plaintiffs.
+MARON R.
+2011 JUL 25
+ORDER ON DEFENDANT/COUNTER-PLAINTIFF,
+THIS CAUSE, having come before
+the
+Court on July 13, 2011, upon
+Defendant/Counter-Plaintiff,
+J. Edwards' Motion for Leave to Assert Claim for Punitive
+Damages. The Court having reviewed the Motion, hearing argument of counsel and being
+otherwise fully advised in the premises, it is hereby
+ORDERED AND ADJUDGED that Defendant/Counter-Plaintiff,
+Motion for Leave to Assert Claim for Punitive Damages is hereby Denied without prejudice.
+DONE AND ORDERED HIS 13025
+day of July, 2011 at West Palm Beach, Palm
+Beach County, Florida.
+Circuit Judge
+Copies furnished:
+All Counsel on attached Service List
+
+
+Epstein v Rothstein,
+etc.
+Case No. S0 2009 CA 040800XXXXMBAG
+Order on
+I M/for Leave to Assert Punitive Damage Claims
+SERVICE LIST
+Epstein v Rothstein - 502009CA040800XXXXMBAG
+L. Ackerman, Esq.
+Burnett, P.A.
+901
+Point West
+777 South Flagler Drive
+West Palm Beach, Florida 33401
+Jack Scarola, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, Florida 33409
+Marc S. Nurik, Esq.
+NO
+NOT
+2
diff --git a/vision-fixhub/court-02/094bfc7d91e395fcce015b2d026c9628a8c0cd589b3e2a691ecba3e7f0f18d93.receipt.json b/vision-fixhub/court-02/094bfc7d91e395fcce015b2d026c9628a8c0cd589b3e2a691ecba3e7f0f18d93.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..b3fa08e81fe91d1a98b03131eb9aa9698dd7513f
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "output_sha256": "55c5a3cffa3b7973668e8e691837ab82fc51cf83449156c23af4178bd9b0e29e",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/095914c1d56e01db1fc1eebc1f46442e1728aec2c7b42874c1cc7d12682a321d.md b/vision-fixhub/court-02/095914c1d56e01db1fc1eebc1f46442e1728aec2c7b42874c1cc7d12682a321d.md
new file mode 100644
index 0000000000000000000000000000000000000000..88046409f93b120b0f0032e5fe7ab107f5e2a845
--- /dev/null
+++ b/vision-fixhub/court-02/095914c1d56e01db1fc1eebc1f46442e1728aec2c7b42874c1cc7d12682a321d.md
@@ -0,0 +1,171 @@
+i...u.i
+JEFFREY EPSTEIN,
+Plaintiff,
+FILED
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+2012 DEC 10 PM 4:09
+SHARON R. BOCK: BEERI
+BALL BEACH COUNT
+CIRCUIT CIVIL
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+individually, and
+L.M., individually,
+Defendant,
+COUNTER-PLAINTIFF,
+J.
+REPLY TO JEFFREY EPSTEIN'S
+MEMORANDUM IN OPPOSITION TO SECOND RENEWED MOTION FOR LEAVE
+TO ASSERT A CLAIM FOR PUNITIVE DAMAGES
+The principal attack on the sufficiency of
+Motion for Leave to Assert a Claim
+for Punitive Damages is to point out the similarity between the proffer supporting that motion
+and
+Motion for Summary Judgment. Epstein either fails to appreciate or chooses to
+ignore the fact that the evidence supporting a summary judgment in favor of the defense on the
+claims the form ste ais for a malicious prosecution action is, of neceiy, the idenical
+evidence necessary to support a claim for punitive damages on the malicious prosecution claim
+itself. In other words, for
+to establish his entitlement to summary judgment on the
+various claims asserted by Epstein against him, it was necessary for
+to establish that
+there were no disputed facts and that the undisputed facts established the propriety of all of
+actions against Epstein. That same evidence is essential in establishing Epstein's
+absence of probable cause to support any of Epstein's claims against
+While the
+
+
+•
+Reply to Epstein's Memorandum in Opposition to Second Renewed Motion for Leave to Assert a Claim for Punitive
+Page 2 08 5
+absence of probable cause is admittedly not sufficient standing alone to establish the foundation
+for a malicious prosecution claim, it is an essential element of such a claim and a relevant
+circumstance in considering the existence of malice.
+As Epstein's opposition memorandum acknowledges at page 15:
+Malice is not only an essential element of a malicious prosecution
+but it is the gist of the cause of action.
+Malice, being an operation of the mind is rarely subject to direct proof. Rather it is established
+circumstantially, and here the circumstances established by the proffer are not only adequate to
+support a finding of malice, they compel such a finding:
+• Epstein lacked probable cause to believe that
+conduct;
+had engaged in any wrongful
+• Epstein suffered no damage except for the self-inflicted consequences of his own
+criminal conduct;
+• Epstein faced (and faces) ongoing adverse consequences arising out of his criminal
+conduct, consequences which
+was and continues to be instrumental in
+enforcing;
+• Success in deterring
+from his vigorous prosecution of claims against Epstein
+would serve to protect Epstein from both civil and criminal liability;
+could deter or distract
+from the continued
+• False claims against
+prosecution of Epstein;
+• The intentional filing of knowingly false claims to extort the abandonment of legitimate
+claims is clearly a malicious purpose;
+• Epstein sued
+in the absence of probable cause;
+
+
+•
+Reply to Epstein's Memorandum in Opposition to Second Renewed Motion for Leave to Assert a Claim for Punitive
+Page 3085
+• Epstein sued
+intending to refuse to comply with his own discovery obligations,
+Amendment privilege;
+• The only remaining purpose for pursuing baseless claims against Edwards was to
+intimidate and extort him.
+Epstein grossly misconstrues the scope of the litigation privilege as described in Levin,
+Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So,2d 606 (Fla. 1994). The
+privilege affords immunity for conduct that occurs in the course of the prosecution or defense of
+legitimate claims. The Supreme Court's holding in Levin was not intended to abolish causes of
+action for malicious prosecution or abuse of process, and no court has ever interpreted that
+holding as having such an effect.
+The balance of Epstein's opposition is a recycling of all the arguments he has previously
+raised in multiple, unsuccessful attacks on the propriety of
+claims. This Court has
+repeatedly rejected each of these arguments in the past and Epstein offers no justification for
+reconsidering those earlier rejections.
+Motion is procedurally proper and substantively far more than adequate to
+support leave to amend to assert a claim for punitive damages. The motion should be granted.
+
+
+Reply to Epstein's Memorandum in Opposition to Second Renewed Motion for Leave to Assert a Claim for Punitive
+Damages
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 10"*
+_ day of December, 2012.
+Primaty
+Secondary E-mail(S): mep@searcylaw.com
+Seatcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorney for Bradley J. L
+NOT A CER
+
+
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Esquire
+bje.efile@pathtojustice.com;
+stafff.efile@pathtojustice.com
+,, Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+haddadfim@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954) 467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Lilly Ann
+Esquire
+Isanchez@thelsfirm.com
+The L-S Law Firm
+1441 Brickell Avenue, 15th Floor
+Miami, FL 33131
+Phone: (305)-503-5503
+Fax: (305)-503-6801
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
\ No newline at end of file
diff --git a/vision-fixhub/court-02/095914c1d56e01db1fc1eebc1f46442e1728aec2c7b42874c1cc7d12682a321d.receipt.json b/vision-fixhub/court-02/095914c1d56e01db1fc1eebc1f46442e1728aec2c7b42874c1cc7d12682a321d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..4b45968d7e699192e517f690153e0e212d0c6cd5
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@@ -0,0 +1,14 @@
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+}
diff --git a/vision-fixhub/court-02/0962f70844dd4d42aff98d02d6ac024edc803cfdad5d8c9adb019afd276e87d4.md b/vision-fixhub/court-02/0962f70844dd4d42aff98d02d6ac024edc803cfdad5d8c9adb019afd276e87d4.md
new file mode 100644
index 0000000000000000000000000000000000000000..4069a9d37c80d271e8223ab40561c8f21427fa30
--- /dev/null
+++ b/vision-fixhub/court-02/0962f70844dd4d42aff98d02d6ac024edc803cfdad5d8c9adb019afd276e87d4.md
@@ -0,0 +1,191 @@
+Filing # 71382787 E-Filed 04/29/2018 11:27:37 AM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+COPY
+SCOTT ROTHSTEIN, individually, and
+individually,
+Defendants/Counter-Plaintiff.
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S
+RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") respectfully renews his request to
+be allowed to disclose an expert witness, and states:
+INTRODUCTION
+This case is currently not set for trial and, therefore, Counter-Plaintiff
+(
+"') will not be prejudiced by Epstein's renewed request to disclose his expert witness to
+opine on matters of legal ethics and responsibility, probable cause and
+professional
+reputation,
+BACKGROUND
+Pursuant to this Court's July 20, 2017, Order Specially Setting Jury Trial (D.E.
+938), the disclosure of experts retained to formulate an expert opinion was due 60 days prior to
+trial. At that time, trial was set on December 5, 2017, making the deadline October 6, 2017.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 04/29/2018 11:27:37 AM
+
+
+Epstein's current trial counsel were retained after this deadline and, on November
+6, 2017, in light of the uncertainty of what issues would be tried and the numerous outstanding
+evidentiary issues, moved for a continuance of the trial and to extend the pre-trial deadlines,
+including an extension of expert disclosures. (D.E. 1035.)
+On November 14, 2017, the Court granted the continuance request and continued
+the special set trial to March 13, 2018. The Court's Order, however, did not address Epstein's
+request for an extension of the pre-trial deadlines. (D.E. 1057.) If that request were granted, the
+new deadline for expert disclosures would have been January 12, 2018.
+Counsel went before the Court on November 27, 2017, to clarify the Court's
+ruling. The Court granted
+Motion to reconfirm the existing pre-trial deadlines because
+of his concern over additional discovery. The Court noted, however, that it would permit
+additional limited discovery upon further motion. (D.E. 1086.)
+On November 29, December 5 and December 7, 2017, the parties participated in
+extensive special set hearings wherein the Court made rulings relating to the issues and evidence
+to be presented at trial. Although the Court did not reach all of the issues, in light of the rulings
+made during those hearings, Ep
+believed he needed to retain an expert to testify about legal
+ethics and responsibility, probable cause and Mr.
+professional reputation. Epstein
+retained C. Culver Smith, IIl for this purpose and disclosed him on December 15, 2017.
+On December 15, 2017, Epstein also filed his initial Motion for Leave to Disclose
+Expert Witness. (D.E. 1119.) The Motion was heard on January 17, 2018, but denied because
+the Court found the request untimely, not because of any undue prejudice to
+7.
+On January 18, 2018, Epstein served his Updated Answers to Expert
+Interrogatories which expounded upon the opinions Mr.
+would testify about.
+2
+
+
+8.
+The March 13, 2018, trial was postponed in light of the appellate proceedings. To
+date, the trial has not been reset.
+ARGUMENT
+was not prejudiced by Epstein's initial request, and he again will not be
+prejudiced. At most,
+may desire to take Mr.
+deposition, as Epstein did of
+expert witness in December 2017. Astutely, this Court recognized at the March 8,
+2018, hearing, striking an expert witness is a drastic measure:
+[A] request to strike a witness is a drastic and extreme measure
+reserved only in rare circumstances, especially where here we're
+dealing with an expert which is otherwise qualified to testify to
+what he's going to testify.
+(3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger y.
+Pest Control, 401 So. 2d
+1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which
+should pertain in only the most compelling circumstances. ... Binger further indicates that
+when the opposing party is not prejudiced by the late disclosure, and compelling circumstances
+are not otherwise shown, the witness should generally be allowed to testify." Walters v. Keebler
+Co., 652 So. 2d 976, 977 (Fla. Ist DCA 1995).
+Here, there is no question that Mr.
+is qualified to testify. Further, due to
+bifurcation of his Counterclaim and ensuing appeal, there is sufficient time before
+Counterclaim is reset for trial for
+to take the witness's deposition. Epstein will not
+object to opening discovery for that limited purpose. Significantly,
+can claim no
+surprise because he has known since December 2017 the opinions of which Mr.
+will
+testify.' Because there is no showing nor can there be any genuine assertion of prejudice or
+first disclosed his expert's name on October 6, 2017, but did not disclose the
+subject matter of his testimony until October 20, 2017, after the disclosure deadline. The Court,
+3
+
+
+other compelling circumstances, excluding Mr.
+would be a drastic measure, and this Court
+should allow him to testify. See Walters, 652 So. 2d at 977.
+CONCLUSION
+Accordingly, Epstein respectfully requests that the Court grant this renewed Motion and
+allow his disclosure of Mr.
+as an expert witness.
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on April 29, 2018, through the Court's e-filing portal pursuant to Florida Rule
+of Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, Florida 33401
+(561) 727-3600; (561) 727-3601 [fax]
+By: Is/ Scott J. Link
+Scott J. Link (FBN 602991)
+NOT A CER
+Kara Berard Rockenbach (FBN 44903)
+Rachel J. Glasser (FBN 577251)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Primary: Rachel@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+Trial Counsel for Plaintif/Counter-Defendant
+Jeffrey Epstein
+however, denied Epstein's request to strike
+months after
+expert's report was disclosed.
+i expert. Epstein disclosed his expert a mere two
+4
+
+
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+dvitale@scarcylaw.com
+scarolateam@searcylaw.com
+terryteam@)searcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+SERVICE LIST
+Philip M. Burlington
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+pmb@FLAppellateLaw.com
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400
+West Palm Beach, FL 33401
+igoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT
+Mare S. Nurik
+Law Offices of ic S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.edu
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+5
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new file mode 100644
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diff --git a/vision-fixhub/court-02/097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497.md b/vision-fixhub/court-02/097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497.md
new file mode 100644
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@@ -0,0 +1,299 @@
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 1 of 9
+ATTACHMENT 2
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 2 of 9
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+Case No. 08-80736-Civ-Marra/
+JANE DOE #1 and JANE DOE #2,
+Plaintiffs
+V.
+UNITED STATES,
+Defendants
+JANE DOE #1 AND JANE DOE #2'S SUPPLEMENTAL REQUEST
+FOR PRODUCTION TO THE GOVERNMENT REGARDING CO-CONSPIRATOR
+IMMUNITY PROVISION AND RELATED SUBJECTS
+COME NOW Jane Doe #1 and Jane Doe #2 ("the victims), by and through undersigned
+counsel, and request the defendant United States (hereinafter "the Government") to produce
+within 30 days the original or best copy of the items listed herein below for inspection and/or
+copying, pursuant to the Court's Order (DE 99) directing discovery in this case, the Court's
+Order denying the Government's motion to dismiss and lifting stay of discovery (DE 189), the
+Court's Omnibus Order (DE 190), and the Court's Order Denying Motion to Join (DE 324):
+BACKGROUND
+As the Government will recall, the victims have repeatedly asked the Government to
+stipulate to undisputed facts in this case. The Government has declined. Accordingly, the
+victims filed their Motion for Finding of Violations of the Crime Victims' Rights Act and
+Request for a Hearing on Appropriate Remedies (DE 48) (the victims' "summary judgment
+motion"). On September 26, 2011, the Court denied the victims' motion to have their facts
+accepted (DE 99 at 11). At the same time, however, the Court has ordered discovery to develop
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 3 of 9
+the factual record concerning the summary judgment motion (DE 99 at 11). Following various
+other proceedings, on June 1, 2013, the Court denied the Government's motion to dismiss. DE
+189. That denial also lifted stay of discovery proceedings. DE 189 at 14 ("The stay of discovery
+pending ruling on the Government's motion to dismiss entered on November 8, 2011 [DE# 123]
+is also lifted."). The Court also entered an Omnibus Order (DE 190) that, among other things,
+granted the victims motion to compel (DE 130).
+On April 7, 2015, the Court denied a motion by two victims - Jane Doe No. 3 and Jane
+Doe No. 4 - to join in the action. At the same time, however, the Court ruled that "the merits of
+this case will be decided based on a determination of whether the Government violated the rights
+of Jane Doe 1, Jane Doe 2, and all 'other similarly situated victims' under the CVRA." DE 324
+at 9. The Court also ruled that Jane Doe 3 and Jane Doe 4 may participate in the case "by
+offering their properly supported ... affidavits ... to support the relevancy of discovery requests
+...." Id. at 8. The Court noted that Jane Doe 3, in particular, "is free to reassert these factual
+details through proper evidentiary proof, should Petitioners demonstrate a good faith basis for
+believing that such details are pertinent to a matter presented for the Court's consideration.
+A motivating reason for the Government failing to confer with the victims, in addition to
+those already outlined in pleadings in this case, would be the immunity provision obtained by all
+Epstein co-conspirators through the NPA. To meet its CVRA obligations, the identities of the
+various co-conspirators who could no longer be charged with crimes they committed against the
+victims would need to be identified to the victims at which time the victims would have the right
+to confer about the possible resolution of crimes committed by those co-conspirators prior to the
+resolution being made. The prosecutor/victim conference on this issue would have made this coconspirator immunity clause very difficult to insert into the NPA. In light of the relevancy of
+2
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 4 of 9
+this information to this action, the rulings in this case, and information learned by Jane Doe 1
+and Jane Doe 2 since their last discovery requests, they now propound the following
+supplemental discovery requests. They hope that the Government will voluntarily provide the
+requested information without need for intervention by the Court.
+SUPPLEMENTAL DISCOVERY REQUESTS
+The numbered discovery requests below should all be construed in light of the definition
+of terms provided at the end of the requests.
+Supplemental Discovery Request 1. Throughout their pending summary judgment
+motion and their originally-filed complaint, Jane Doe 1 and Jane Doe 2 contend that they
+received inadequate notifications from the Government (and, in particular, the U.S. Attorney's
+Office acting through FBI agents) about the plea negotiations that occurred with Jeffrey Epstein
+and the non-prosecution agreement that was ultimately reached. They have also contended that
+the same inadequate notifications were provided to other similarly situated victims. Please
+provide all documents, correspondence, and other information regarding victim notifications in
+this case, including (but not limited to):
+(a) All crime victim notifications sent to Jane Doe 3 (and all drafts of the notifications);
+(b) All crime victim notifications sent to Jane Doe 4 (and all drafts of the notifications);
+(c) All crime victim notifications sent to other victims similarly situated to Jane Doe 1
+and Jane Doe 2, including those victims listed in the annex or appendix to the nonprosecution agreement (and drafts of the notifications); and
+(d) Victim notifications sent on or about September 3, 2008, that described this action as
+"litigation between the United States and two other victims regarding the disclosure
+of the entire agreement between the United States and Mr. Epstein."
+Supplement Discovery Request 2. The Non-Prosecution Agreement in this case contains
+a provision that provides immunity in the Southern District of Florida not only to Epstein, but
+also to "any potential co-conspirators of Epstein." Please provide all documents,
+correspondence, and other information regarding this co-conspirator immunity provision,
+including any draft agreement containing or not containing this provision and any
+communications or documents regarding this provision and the identity of persons covered by
+this provision. Please also indicate from these documents which were shared with Doe 1, Doe 2
+and all other similarly situated victims notifying them of this provision.
+Supplemental Discovery Request 3. Jane Doe 3 has filed a sworn affidavit regarding her
+allegations that one of Epstein's defense attorneys, Alan Dershowitz, sexually abused her in the
+Southern District of Florida and elsewhere (and also witnessing abuse) before being involved in
+the plea negotiations in this case. Based on this information, Jane Doe 1 and Jane Doe 2 intend
+to argue (among other things) that the facts surrounding these allegations provided an additional
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 5 of 9
+motive for Epstein's defense team (including Dershowitz) and the Government to try to keep the
+non-prosecution agreement secret from the victims as well as providing an improper reason for
+Dershowitz to lobby the Justice Department in support of an agreement that had not been
+disclosed to the victims. Please provide all documents, correspondence, and other information
+regarding Alan Dershowitz's sexual abuse of Jane Doe 3 or other under-age girls, as well as his
+witnessing of sexual abuse or possible sexual abuse of under-age girls by Epstein, as well as him
+being in the same vicinity with Epstein while possible sexual abuse of under-age girls by Epstein
+was occurring, including (but not limited to):
+(a) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses suggesting that Dershowitz had contact with
+or was in proximity to Jane Doe 1, 2, 3, or 4;
+(b) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses suggesting that Dershowitz was present in
+Epstein's mansion in Palm Beach, Florida;
+(c) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses suggesting that Dershowitz was present in
+Epstein's mansion in New York, New York;
+(d) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses suggesting that Dershowitz was present in
+Epstein's "Zorro" ranch in New Mexico or elsewhere with Epstein in New Mexico;
+(e) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses suggesting that Dershowitz was present on
+Epstein's island in the U.S. Virgin Islands or elsewhere in the U.S. Virgin Islands;
+(f) Any documents, correspondence, witness statements, and similar information that the
+Government possesses regarding Dershowitz receiving or witnessing a massage from
+a female or "massage therapist" employed by Epstein or present at any of Epstein's
+properties;
+(g) Any documents, correspondence, witness statements, and similar information that the
+Government possesses regarding Dershowitz being in the presence of females under
+the age 18 in the company or Epstein, on any property owned or controlled by
+Epstein, or who were introduced to him (Dershowitz) by Epstein;
+(h) Any documents, correspondence, witnesses statements, and similar information that
+the Government has developed or possesses regarding Dershowitz being observed or
+in proximity to Epstein employee Juan Alessi;
+(i) Any documents, correspondence, witnesses statements, and similar information that
+the Government has developed or possesses regarding Dershowitz being observed or
+in proximity to Epstein employee Alfredo Rodriguez;
+(i) Any documents, correspondence, witnesses statements, and similar information that
+the Government has developed or possesses regarding the circumstances and reasons
+that lead to Alfredo Rodriguez circling for FBI agents telephone and other
+information related to Dershowitz in Epstein's contacts book (sometimes referred to
+as the "Holy Grail");
+(k) Any documents, correspondence, witness statements, and similar information that the
+Government has developed or possesses regarding a close personal relationship
+between Epstein and Dershowitz;
+4
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 6 of 9
+(1) Any flight logs, flight manifests, documents, correspondence, witness statements,
+and similar information that the Government possesses regarding Dershowitz being
+on an aircraft that was owned or controlled by Epstein or that also had as a passenger
+Jeffrey Epstein, Jane Doe 3,
+1. Adrianna
+Ghislaine Maxwell, Jean Luc Brunel, or a person identified only as a "female"; and
+(m) Any other documents, correspondence, witness statements and similar information
+suggesting that Dershowitz had a motive for approval of, or would receive a benefit
+from, a non-prosecution agreement with Epstein that extended to any "potential coconspirator of Epstein."
+Supplemental Discovery Request 4. As the Government is aware, in 2011, Jane Doe 3
+met with FBI agents at the U.S. Consulate in Sydney, Australia, to discuss the criminal
+prosecution of Jeffrey Epstein and others who were associated with him. Please provide:
+(a) Any unredacted FBI 302's or witness statements made of the meeting and any related
+meetings;
+(b) Any FBI 302's, witness statements, documents, correspondence, or similar
+information later collected regarding information provided by Jane Doe 3 at the
+meeting;
+(c) Any documents, correspondence, or similar information developed in anticipation of
+the meeting with Jane Doe 3, including questions to be asked and persons of interest
+to inquire about;
+(d) Any photographs or similar evidence taken to show Jane Doe 3 at the meeting;
+(e) Any photographs or similar evidence collected from Jane Doe 3 at or after the
+meeting; and
+(f) Any FBI 302's, witness statements, documents, correspondence, or similar
+information developed as a result of Jane Doe 3's contact with the FBI in and around
+April 2014 following up on her meeting in Sydney.
+Supplemental Discovery Request 5. As the Government is aware, Jane Doe 3 has
+previously requested that she receive copies of video surveillance or other pictures of her that the
+FBI or and other federal agencies have acquired as a result of their investigation into crimes
+committed by Jeffrey Epstein or any of his co-conspirators, so that she can know all of the
+crimes to which was a victim. The Government has declined in the past but certainly recognizes
+the relevance now. Please provide a copy of all videos, photographs, or other recordings of Jane
+Doe 3 that the Government (including the FBI) has obtained as a result of its investigation into
+Jeffrey Epstein or his co-conspirators, including surveillance videos, photographs, or similar
+images taken in Epstein's Florida and New York mansions, New Mexico Ranch, or on Epstein's
+island in the U.S. Virgin Islands. Please also provide the same for Jane Doe 1, 2, and 4. If any
+of the videos, photographs or images constitute child pornography as defined in 18 U.S.C. §
+2256(8), please provide a general description (including a description of the persons involved in
+the images) rather than actual images themselves.
+Supplemental Discovery Request 6. As the Government is aware, on around March 13,
+2001, a photograph was taken of Jane Doe 3 appearing in the presence of Prince Andrew and
+Ghislaine Maxwell. Jane Doe 3 has alleged that this photograph provides corroborating evidence
+5
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 7 of 9
+of a conspiracy by Epstein and others to engage in international sex trafficking in the Southern
+District of Florida and elsewhere in violation of 18 U.S.C. § 1591, as well as a motivation for
+powerful persons to want to secure a broad non-prosecution agreement of Epstein and to
+negotiate the NPA in violation of the victims' rights. Please provide:
+(a) Any witness statements, documents, correspondence, or similar information regarding
+Prince Andrew being in the presence of or in proximity to Jane Doe 3 in London,
+New York, or the U.S. Virgin Islands;
+(b) Any witness statements, documents, correspondence, or similar information regarding
+Ghislaine Maxwell being in the presence of or in proximity to Jane Doe 3 in London,
+New York, Florida, or the U.S. Virgin Islands;
+(C) Any witness statements, documents, correspondence, or similar information regarding
+Jean Luc Brunel being in the presence of or in proximity to Jane Doe 3 in London,
+New York, Florida, or the U.S. Virgin Islands;
+(d) Any witness statements, documents, correspondence, or similar information,
+including immigration records regarding entry into or exit from the United States in
+March 2001 by Jane Doe 3;
+(e) Any witness statements, documents, correspondence, or similar information regarding
+Prince Andrew being at Jeffrey Epstein's New York mansion at the same time as Jane
+Doe 3; and
+(f) Any witness statements, documents, correspondence, or similar information regarding
+Prince Andrew being on Jeffrey Epstein's island in the U.S. Virgin Islands at the
+same time as Jane Doe 3.
+Supplemental Discovery Request 7. In answer to requests for admissions, the
+Government admitted that it possesses or has knowledge or information (including telephone
+logs, photographs, emails, or statements) of other credible sources) about a personal or business
+relationship between Jeffrey Epstein and Matthew Menchel. Please provide all witness
+statements, documents, correspondence, or similar information regarding this personal or
+business relationship.
+DEFINITIONS
+For the purpose of construing the foregoing discovery requests, the following terms are
+defined:
+The term "documents" means and includes, without limitation, all writings of any kind,
+including the originals and all non-identical copies or drafts, whether different from the original
+by reason of any notation made on such copy or draft or otherwise including, without limitation,
+correspondence, memoranda, notes, diaries, statistics, letters, e-mails, electronic computer files,
+telegrams, minutes, contracts, reports, studies, checks, statements, receipts, returns, summaries,
+pamphlets, books, prospectuses, interoffice communications, offers, notations of any sort of
+conversation, telephone calls, meetings or other communications, bulletins, printed matter,
+computer print-outs, teletypes, facsimiles, invoices, work sheets, flight logs, flight manifests, and
+all drafts, alterations, modifications, changes, and amendments of any of the foregoing, graphic
+or aural writs, records or representations of any kind including, without limitation, photographs,
+6
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 8 of 9
+charts, graphs, microfiche, microfilm, videotape, recordings, motion pictures; and electronic,
+mechanical or electric records or representations of any kind including, without limitation, tapes,
+cassettes and dise recordings, and writings and printed material of every kind.
+The term "correspondence" means any tangible object that conveys information or
+memorializes information that was conveyed in tangible or oral form including, but not limited
+to, writings, letters, memoranda, reports, notes, e-mails, telephone logs, telephone billing
+information, telephone recordings, and interoffice communications.
+The term "victim" means any person that the Government identified as a possible victim
+of a sex offense committed by Jeffrey Epstein, including Jane Doe 1, 2, 3, and 4, all victims
+identified in attachment to the non-prosecution agreement entered into by Epstein, and any other
+person that the Government investigated as a possible victim of Epstein's sex offenses.
+The term "Government" means the federal government, including all employees of and
+components of the United States Department of Justice (such as, the Office of the Attorney
+General, the Office of the Deputy Attorney General, the Criminal Divisions, the Office of
+Professional Responsibility, the Child Exploitation and Obscenity Section, the U.S. Attorney's
+Offices for the Southern District and Middle District of Florida, New Mexico, the Virgin Islands,
+and the Southern District of New York, and the Federal Bureau of Investigation) and other
+federal government agencies with law enforcement responsibilities related to the Epstein case
+(such as the Internal Revenue Service). This request for production seeks all documents,
+correspondence, and other information held by all of these entities, including all employees of
+and components of the Justice Department that worked on or were in any way involved the
+Epstein investigation and/or that possess information relevant to the victims' claims. For
+purposes of the request for production of flight logs and related travel information, this request
+includes the Federal Aviation Administration and Bureau of Immigrations and Customs
+Enforcement.
+The term "including" means containing within the request, but not limiting the request.
+The term "witness statement" means any document or other recording in any form
+(including oral form) reflecting, recording, or otherwise memorializing a statement made or
+information conveyed by a potential witness, including for example FBI 302's. The term
+ncludes information collected by any law enforcement, prosecuting or government agency
+ncluding all federal, state, and local law enforcement agencies located in Washington, D.C., ¿
+PRIVILEGE LOG
+consistent with Local Rule 26.1(g)(3)(B). Your privilege log should include the type of
+7
+
+
+Case 9:08-cv-80736-KAM Document 348-2 Entered on FLSD Docket 12/28/2015 Page 9 of 9
+document, general subject matter of the document, date of the document, and author and
+addressee of the document or correspondence.
+REDUCING ANY UNDUE BURDEN
+If you believe that complying with any of the foregoing requests would be unduly
+burdensome, please contact victims' counsel
+- to discuss ways to reduce
+any such burden.
+DATED: April 11, 2015
+Respectfully Submitted,
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+ort Lauderdale, Florida 33301
+Telephone (954) 524-2820
+Florida Ba No: S4-252
+E-mail: brad@pathtojustice.com
+and
+Paul G. Cassell
+332 S. 1400 E.
+Salt Lake City, UT 84112
+Telephone: 801-585-5202
+Facsimile: 801-585-6833
+E-Mail: cassellp@law.utah.edu
+Attorneys for Jane Doe 1, 2, 3 and 4
+"This daytime business address is provided for identification and correspondence purposes only and is
+not intended to imply institutional endorsement by the University of Utah
diff --git a/vision-fixhub/court-02/097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497.receipt.json b/vision-fixhub/court-02/097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..ca7e6696859b93ec376d2785915eb6cd48c85d75
--- /dev/null
+++ b/vision-fixhub/court-02/097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -114,
+  "dataset": "marble-joined",
+  "doc_id": "097df06118f552d0d95cf36aa28b8a88f1623609494a7dd69e3e5cfdb702f497",
+  "engine": "marble-apple-vision",
+  "event_count": 12,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"swarm.dehyphenation.join-soft-wraps\"]",
+  "idempotent": true,
+  "input_sha256": "da4a9f69141d7fa90aa5a7d3e40386c9aeb158d7c18d290d953f2598c257b768",
+  "output_sha256": "65676c4c7dc82a8dd2efed4b13e0d5b23b5a3c94afb982f48c1aa80dbfe6d888",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.md b/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.md
new file mode 100644
index 0000000000000000000000000000000000000000..d2fbf778ba7228788d13016caa4fa77254ce7874
--- /dev/null
+++ b/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.md
@@ -0,0 +1,53 @@
+& IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
+IN AND FOR PALM BEACH COUNTY
+CIVIL DIVISION
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+COREUI
+Il Fi
+17
+SCOVT ROTHSTEN, eG, and
+J.1
+Defendant(s),
+ORDER GRANTING PLAINTIFF'S MOTION TO CONTINUE TRIAL AND
+SCHEDULING CASE MANAGEMENT CONFERENCE
+THIS CAUSE came before the Court upon the Plaintiff's Motion to Continue
+Jury Trial, and the Court having heard argument of counsel, and being otherwise fully
+advised in the premises, it is hereby
+CONSIDERED, ORDERED AND ADJUDGED that Plaintiff's Motion is granted
+and this case is stricken from the March 7, 2011 trial docket. It is further
+ORDERED AND ADJUDGED that this case is scheduled for a Case
+Management Conference on Friday, April 15, 2011 at 11:00 a.m. in Courtroom 9C of
+the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach,
+Florida.
+At least twenty (20) days prior to the Case Management Conference, counsel
+shall file an Initial Case Management Statement pursuant to Fla. R.Civ.P. 1.201(). The
+Court will reset the matter for trial at the time of the Case Management Conference.
+DONE AND ORDERED in Chambers, at West Palm Beach, Palm Beach
+County, Florida this1? day of February, 2011. .
+suct
+DAVID F.
+Circuit Court Judge
+Copies by mail furnished to:
+See attached list.
+
+
+SERVICE LIST
+Epstein v Rothstein - 502009CA040800XXXXMBAG
+. Ackerman, Esq.
+Burnett, P.A.
+901|
+Point West
+777 South Flagler Drive
+West Palm Beach, Florida 33401
+Jack Scarola, Esq.
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, Florida 33409
+Marc S. Nurik, Esq.
+Law Offices of Marc S. Nurik
+One E. Broward Blvd., Suite 700
+Fort Lauderdale, Florida 33301
+NOT A CERTIFIED COPY
diff --git a/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.receipt.json b/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..3e62cbdb9f6cb65f01306a7c17a043c04b3a5c8e
--- /dev/null
+++ b/vision-fixhub/court-02/09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -24,
+  "dataset": "marble-joined",
+  "doc_id": "09b658efe187589f6dc3c2c2492df143657df3f15eb567abd6f5a450953fd6aa",
+  "engine": "marble-apple-vision",
+  "event_count": 2,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "d4aa7c2aa8c68999a9e238be2a6f8e5fdd5dff33ae2810a999ba8b91b69c490b",
+  "output_sha256": "98ae5d1f1f295826055845bcbc2c9ea43fa2063388b4227e2e39979c6603ea16",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.md b/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.md
new file mode 100644
index 0000000000000000000000000000000000000000..ab0726336c288d2ae4b27212a0cf58e7be379c63
--- /dev/null
+++ b/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.md
@@ -0,0 +1,1679 @@
+05845
+05811
+05813
+05748-05749
+05711
+05701-05704
+05687
+05690-05691
+PATE
+07/24/2009
+06/09/2009
+08/15/2009
+08/11/2009
+05/11/2009
+04/20/2009
+08/21/2009
+05/11/2009
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+, Jaffe, Weissing.
+EROM
+, Fistos & Lehrman
+DESCRIPTION
+Ken Jenne
+Susan Stirling
+Ken Jenne
+Jacquie
+Edwards
+Adler
+Marc Nurik
+| Susan Stirling
+Plane Tail Numbers
+Witness Numbers
+Litigation Strategy
+Litigation Strategy
+Subpoena Clinton
+Epstein strategy
+Alfredo Rodriguez
+OBJECTION
+Work product; attorney/client
+privilege;
+Work
+product;
+attorney/client
+privilege;
+Work product; attorney/client privilege;
+Work
+product;
+attorney/client
+privilege;
+Irrelevant and not reasonably calculated to lead
+Work product; attorney/client privilege;
+Work product; attorney/client
+privilege;
+Work
+product;
+attorney/client privilege;
+Work product;
+attomey/client privilege;
+2009CA040800
+] Motion to Unseal
+136
+Electronically Filed 10/02/2013 11:41:20 AM ET
+
+
+05680-05682
+05676
+05648
+05629
+05621-05622
+05610-05612
+05588-05590
+PATE
+05/11/2009
+08/24/2009
+07/23/2009
+08/03/2009
+09/18/2009
+04/27/2009
+08/24/2009
+Attorneys at RRA
+Attorneys at RRA
+Amy Swan
+Susan Stirling
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+1, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+relevant and not reasonably calculated to lea
+o the discovery of the admissible evidence
+William Berger
+Subpoena Clinton
+Workproduct; attorney/client privilege;
+Mike Fisten
+Topics for Meeting
+Work product; attorney/client
+privilege;
+Irrelevant and not reasonably calculated to lead
+Gary
+Mike Fisten
+Assemble
+-Epstein
+meeting
+Litigation Work product;
+attorney/client privilege;
+Law Enforcement cannot release
+juvenile reports
+Work product; attorney/client privilege;
+Preparing Motion to take an IME Work product; attorney/dient privilege:
+of Epstein
+Request for Copies
+Work product; attorney/dient privilege;
+Irrelevant and not reasonably calculated to lead
+Travel restrictions
+Work product; attorney/client
+privilege;
+137
+
+
+05575-05576
+05582
+05569-05570
+05556-05558
+LESSO
+05534
+05518
+05512-05513
+DATE
+08/21/2009
+09/11/2009
+08/17/2009
+600z/tT/80
+07/30/2009
+07/24/2009
+07/22/2009
+07/23/2009
+Marc Nurik
+Marc Nurik
+Attorneys at RRA
+Jacquie
+Ken Jenne
+Attorneys ar RRA
+Priscila
+Nascimento
+Privilege Log - Dated 2-23-2011
+, Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Alfredo Rodriguez
+Mike Fisten
+Epstein strategy
+Legal Opinion
+OBJECTION
+product;
+attomey/client privilege;
+Work product;
+attorney/client
+privilege;
+Work
+product;
+attorney/client
+privilege;
+Communication with legal expert
+Work product; attorney/client privilege;
+No objections from
+defense
+Work
+product; attorney/client
+privilege;
+counsel regarding depo for Sarah
+Kellen
+| irrelevant and not reasonably calculated to lead
+Flight logs for Epstein
+Work product; attorney/client privilege;
+Assemble
+meeting
+Epstein
+Litigation
+| Work product; attorney/client privilege;
+Nora Batian
+Epstein
+Litigation
+Weevan rodeo earlie calculated lead.
+Assemble
+meeting
+138
+
+
+05502-05507
+05475
+05471-05472
+05447
+05420-05423
+05409-05412
+05403-05405
+DATE
+07/22/2009
+04/21/2009
+08/14/2009
+08/14/2009
+05/20/2009
+08/17/2009
+04/27/2009
+Jacquie
+Marc Nurik
+Marc Nurik
+Marc Nurik
+William Berger
+Marc Nurik
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+_ Fistos & Lehrman
+FROM
+DESCRIPTION
+William Berger
+William Berger
+Edwards
+Marc Nurik
+OBJECTION
+Wayne Black's email
+Work product;
+attorney/client privilege;
+Call with Chris Hanson from Work
+product;
+attorney/client
+privilege;
+Legal expert regarding legal issue
+Work product; attorney/client
+privilege;
+Communication with legal expert
+Work product;
+attorney/client privilege;
+Irrelevant and not reasonably calculated to lead
+Research on cases saying a judge
+product; attorney/client privilege;
+can postpone one party's depo
+until the other is completed
+Legal
+discovery
+opinion
+regarding
+Work product; attorney/client privilege;
+Jeffrey Epstein Wikipedia page
+Work product; attorney/client privilege;
+139
+
+
+05399
+05399
+05271-05272
+05259-05260
+05238
+05240-05241
+05197-05199
+DATE
+10/17/2009
+10/17/2009
+07/22/2009
+07/22/2009
+07/14/2009
+08/24/2009
+08/24/2009
+William Berger
+William Berger
+Attorneys at RRA
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Proposal for settlement
+Jacquie
+Jacquie
+William Berger
+Ken Jenne
+Ken Jenne
+OBJECTION
+Work
+product;
+attorney/client
+privilege;
+Proposal for settlement
+Work product; attorney/client
+privilege;
+Depo Dates to take SR, LM, and Work
+product; attorney/client
+privilege;
+CW
+Investigator retainer
+Work
+product;
+attorney/client
+privilege;
+File a request to produce
+Work
+product; attorney/client
+privilege;
+Irrelevant and not reasonably calculated to lead
+Judge's order on the Epstein Work
+product; attorney/client
+privilege;
+probation
+Michael Reiter info
+Work product; attorney/client privilege;
+Irrelevant and not reasonably calculated to lead
+140
+
+
+05155-05156
+05159-05160
+05149-05150
+05153
+05146-05147
+05137-05144
+05133-05136
+IS20-67210
+DATE
+04/20/2009
+05/28/2009
+05/27/2009
+600Z/vZ/80
+05/26/2009
+600z/0z/50
+600Z/TT/S0
+600z/8Z/0I
+Adler
+William Berger
+Susan Stirling
+Paul Cassell
+Attorneys at RRA
+William Berger
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+_ Fistos & Lehrman
+FROM
+PESCRIPTION
+Set Epstein's depo duces tecum
+Mike Fisten
+Edwards
+Russell Adler
+Phaedra Xanthos
+OBJECTION
+Work product;
+attorney/client privilege;
+Right to move to reconsider all Work
+product;
+attorney/client privilege;
+rulings
+Epstein filed a motion to
+Work product; attorney/client
+privilege;
+continue the trial
+Epstein traveling
+Work
+product;
+attorney/client
+privilege;
+The response to the motion to
+Work product;
+attorney/client
+privilege;
+continue is due 6/8
+Epstein litigation strategy
+Work product; attorney/client privilege;
+Subpoena Clinton and others on
+Work product; attorney/client
+privilege;
+Sid
+witness list
+Final affidavit
+from
+forensic
+Work product;
+attorney/client
+privilege;
+accountant
+141
+
+
+05125-05132
+05115-05117
+01699
+05120-05121
+05095-05098
+01694
+05066-05067
+DATE
+05/05/2009
+04/27/2009
+09/15/2009
+05/04/2009
+07/01/2009
+10/17/2009
+05/06/2009
+LIO
+William Berger
+Jacquie
+William Berger
+Jacquie
+Mare Nurik
+Privilege LoR -Dated 2-23-2011
+Jaffe, Weissing.
+FROM
+Fistos & Lehrman
+DESCRIPTION
+Susan Stirling
+Paul Cassell
+OBJECTION
+Response to motion to compel all i
+Work product; attorey/client privilege;
+the sex information of his clients
+Epstein depos
+VZ depo
+Work product; attorney/client
+privilege;
+Work product; attorney/client
+privilege;
+Reporter asking how the depo of Work product; attorney/client
+privilege;
+Epstein went
+protected by privacy nights
+Work product;
+22222
+PFS
+William Berger
+Epstein sealed records and TV
+Work product; attorney/client privilege;
+Work product; attorney/client
+privilege;
+142
+
+
+05054-05065
+05049-05053
+04957-04964
+04952-04953
+04955-04956
+04916-04920
+04899
+PATE
+08/18/2009
+08/18/2009
+09/04/2009
+10/28/2009
+09/03/2009
+09/11/2009
+09/10/2009
+Attorneys at RRA
+• Mike Fisten
+Attorneys at RRA
+Attorneys at RRA
+Elizabeth Villar
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Epstein Potential witnesses
+Subpoenas
+witnesses
+for
+OBJECTION
+Work product; attorney/client privilege;
+potential Work
+product; attorney/client privilege;
+_irrelevant and not reasonably calculated to lead
+Scott
+Paul Cassell
+Juan
+Alessi statement
+burglary report
+and Work
+product;
+attorney/client privilege;
+protected by privacy nights
+Epstein
+injunction
+filing
+- Work product; attorney/client
+privilege;
+accountant affidavit will be sent
+Edwards
+/ Epstein Invoice
+Work
+product;
+attorney/client privilege;
+Updates on # of victims, billing | Work product; attorney/client privilege;
+amounts, etc.
+Jacquie
+Epstein Discovery
+Work product; attorney/cilent privilege:
+143
+
+
+04893-04896
+04890
+04884-04885
+01469
+04745-04747
+04738-04744
+04660
+04642-04646
+DATE
+09/10/2009
+09/10/2009
+09/10/2009
+07/17/2009
+08/04/2009
+08/25/2009
+10/22/2009
+09/11/2009
+Jacquie
+Jacquie.
+Ken Jenne
+Edwards
+Privilege LoR-Dated 2-23-2011
+Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Epstein Discovery
+Work
+product;
+attorney/client privilege;
+Epstein Discovery
+Work product; attorney/client privilege;
+Jacquie.
+Epstein Discovery
+Work product; attorney/client privilege;
+Jacquie Johnson
+Paul Cassell
+Marc Nurik
+Beth Wiliamson
+Discussions about the Epstein Work
+product;
+attorney/client
+privilege;
+case
+Epstein depo in New York
+Work product;
+attorney/client privilege;
+Hearing regarding the Epstein
+Work product; attorney/client privilege;
+computers
+Epstein AUSA - Attorneys Fees
+Work product; attorey/client privilege;
+Discussions
+recovery
+about
+Brad's Work product; attorney/client privilege;
+144
+
+
+04607-04617
+04526-04535
+04488-04490
+01362
+04481-04487
+05465-05467
+05470
+05496-05497
+DATE
+09/11/2009
+I TO
+Jacquie
+10/17/2009
+07/18/2009
+09/11/2009
+Elizabeth Villar
+08/18/2009
+Paul Cassell
+06/26/2009
+Wayne Black
+07/11/2009
+Bradiey Edwards
+08/10/2009
+Privilege Log - Dated 2-23-2011
+. Jatte, Weissing.
+L Fistos & Lehrman
+EBOM
+PESCRIPTION
+Paul Cassell
+Paul Cassell
+OBJECTION
+Holding Fed Subs until we get
+Work
+product; attorney/client privilege;
+response on form
+Two ideas regarding strategy
+Work product; attorney/client privilege;
+Taking the 50
+Work
+product;
+attorney/client
+privilege;
+Bradley Edwards,
+Wayne Black
+Alfredo
+Getting the forensic aspect off work
+product;
+attorney/client privilege;
+the ground -epstein's asset | irrelevant and not reasonably calculated to lead
+transfers
+Epstein Subpoena
+Work
+product; attorney/client privilege;
+Subpoenas for trial
+Work product; attorney/client privilege;
+Flight Logs
+Work product;
+attorney/client
+privilege;
+Work product;
+attorney/client privilege:
+Phone Numbers
+145
+
+
+PATE
+05501
+07/21/2009
+Wayne Black
+Privilege Log - Dated 2-23-2011
+_Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Rodriguez
+Litigation strategy
+QBJECTION
+Work product;
+attorney/client
+privilege;
+05524-05533
+07/23/2009
+Wayne Black
+05541
+07/31/2009
+Carolyn
+05635
+10/22/2009
+Pat
+Bradley Edwards
+Addresses for people involved in Work
+product; attorney/client
+privilege;
+the casé
+All depos in jane doe's case
+Work product; attorney/client privilege;
+lew developments that require Work product; attorney/client
+privilege;
+your expertise
+irrelevant and not reasonably calculated to lea
+protected by privacy rightso
+NOT
+146
+
+
+05640
+05652-05653
+05671
+05696
+05815-05816
+05820-05821
+DATE
+10/29/2009
+04/01/2009
+10/22/2009
+05/11/2009
+04/01/2009
+07/23/2009
+Pat
+Carolyn
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+New Epstein victim
+OBJECTION
+Work
+product;
+attorney/client
+privilege;
+Carolyn
+Pat
+Wayne Black
+personal discussion
+Work
+product;
+attorney/client
+privilege;
+Litigation strategy
+Work
+product;
+attomey/client
+privilege;
+Phone number for one of the
+attorney/client
+other girls on the list of irrelevant and not reasonably calculated to lead
+prospective clients
+Taking the depos of everyone
+Wayne Black
+Dates for depos of all witnesses
+Work product; attorney/client privilege;
+in the case
+147
+
+
+05824-05825
+_DATE
+07/23/2009
+05828-05829
+07/23/2009
+05833-05835
+07/23/2009
+05839-05841
+07/23/2009
+05869-05870
+6002/t0/t0
+05913-05914
+04/02/2009
+Carolyn
+Carolyn
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+_ Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Wayne Black
+Wayne Black
+OBJECTION
+Paula Heil
+product; attorney/client
+Dates for depos of all witnesses | Work product; attorney/client privilege;
+in the case
+Irrelevant and not reasonably calculated to lead
+FBI has original flight logs and Work product; attorney/client privilege;
+they interviewed pilots
+Wayne Black
+Copies of the flight logs
+Work product;
+attorney/client privilege;
+Irrelevant and not reasonably calculated to lead
+Personal convo between
+Brad Work product; attorney/client privilege;
+and Mom
+Personal convo
+and Mom
+between
+Brad Work product; attorney/client privilege;
+148
+
+
+05995
+06513-06523
+06699-06701
+07079-07089
+07437-07439
+07936-07958
+08006-08011
+11186-11187
+DATE
+04/01/2009
+LIQ
+06/15/2009
+06/17/2009
+Wayne Black
+09/03/2009
+10/19/2009
+Paul Cassell
+04/28/2009
+Earleen Cote
+06/03/2009
+08/19/2009
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Carolyn
+Third
+party
+subpoenas
+/Courtney
+Wayne Black
+Pat
+Ronald Wise
+Wayne Black
+OBJECTION
+for
+Work
+product;
+attorney/client privilege;
+Ghisella Maxwell info
+Work
+product; attorney/client
+privilege;
+Irrelevant and not reasonably calculated to lead
+Epstein litigation
+Work product; attorney/client privilege;
+Discussion about girls involved in
+Work
+product;
+attorney/client
+privilege;
+the case
+New
+evidence
+of
+Epstein Work
+product; attorney/client privilege;
+Fraudulent transfers + Affidavit irrelevant and not reasonably calculated to lead
+from you
+Cases against mansion nightclub
+Work product; attorney/client privilege;
+Getting addresses for people for
+product; attorney/client
+privilege;
+us to serve subpoenas
+Work product; attorney/client privilege:
+Plaintiff's Witness List
+149
+
+
+26479-26481
+27155-27159
+26604-26605
+0L592
++5600
+06665-06670
+06675-06676
+PATE
+6002/6T/80
+600z/EZ/01
+600z/LZ/01
+600Z/ET/80
+6002/87/01
+600z/2T/80
+08/26/2009
+Attorneys at RRA
+Attorneys at RRA
+Phaedra Xanthos Ken Jenne
+Scott Rothstein
+Attorneys at RRA
+Jacquie
+Shawn Gilbert
+Shawn Gilbert
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissinge
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Ken Jenne
+Assistance on the Epstein Case
+product; attorney/client privilege;
+Steven Jaffe
+PACER entries
+Work product;
+attorney/client
+privilege;
+Work product; attorney/client
+privilege;
+Contributions/advertisement for | irrelevant and not reasonably calculated to lead
+the rental on Little St. James
+Island
+Marc Nurik
+Discussions about Epstein
+Work
+product; attorney/client
+privilege;
+Creation of another Doe file
+Work product; attorney/client privilege;
+Epstein Costs
+Work product;
+attorney/client privilege;
+Personal convo in regards to
+Work product; attorney/client
+i privilege:
+moving offices
+150
+
+
+06679-06682
+07590-07594
+08451-08453
+08455-08456
+08466-08479
+01767
+08379
+08399
+PATE
+08/26/2009
+05/13/2009
+08/17/2009
+600Z/€0/90
+08/26/2009
+07/06/2009
+06/06/2009
+07/23/2009
+TO
+Shawn Gilbert
+Attorneys at RRA
+Wayne Black
+Bradley Ed
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+_ Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Shawn Gilbert
+Personal convo in regards to Work
+product;
+attorney/client privilege;
+moving offices
+Office information
+Work product; attorney/client
+privilege;
+Pat
+Wayne Black
+Paul Cassell
+Updated Witness List
+Work
+product; attorney/client privilege;
+Vanity fair
+Work product; attorney/client
+privilege;
+Edwards
+Witness info that we need to use
+Work product; attorney/dient privilege;
+Info on a guy going to victim's
+Work product; attorney/dient privilege;
+boyfriends house
+Info on Former FHP trooper
+Work product; attorney/client privilege;
+subcontracted by|
+Epstein affidavit to the reply
+Work product; attorney/client privilege;
+memo
+151
+
+
+08406
+05697
+20330-20334
+20327-20329
+20100-20102
+20283-20326
+20092-20099
+DATE
+10/30/2009
+08/19/2009
+08/24/2009
+10/17/2009
+08/24/2009
+10/14/2009
+08/24/2009
+TO
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+• Fistos & Lehrman
+FROM
+DESCRIPTION
+Adler
+Mike Fisten
+Pat
+Mike Fisten
+Mike Fisten
+Ken Jenne
+OBJECTION
+Flying epstein rape survivor to St.
+Work
+product;
+attomey/client
+privilege;
+Louis to see expert
+Meeting with client
+Work product;
+attorney/client
+privilege;
+Serving Alan Dershowitz
+Work
+product;
+attorney/dient privilege;
+Property purchased by Epstein in
+Palm Beach
+Work
+product;
+attorey/client
+privilege;
+Epstein's arrival at his building
+Work
+product;
+attorney/client
+privilege;
+Irrelevant and not reasonably calculated to lead
+Research regarding Mr. Visoski
+Work product; attomey/client privilege
+and questions to consider during | irrelevant and not reasonably calculated to lead
+the depo
+Epstein travel
+Work
+product;
+attorney/client privilege;
+152
+
+
+20085-20091
+19996-20084
+20217-20218
+20213-20216
+20211-20212
+20207-20210
+20201-20204
+600Z/SI/OI
+TIVO
+10/14/2009
+08/04/2009
+08/03/2009
+600Z/E0/80
+08/10/2009
+08/24/2009
+TO
+Attorneys at RRA
+Attorneys at RRA
+Mike Fisten
+Jacquie
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+_ Fistos & Lehrman
+FROM
+DESCRIPTION
+Mike Fisten
+Questions from accountant
+Mike Fisten
+Mike Fisten
+Ken Jenne
+OBJECTION
+Work product;
+attorney/client privilege;
+Visoski Research and Questions
+Info on Copperfield
+Info on Copperfield
+Pilots depo
+List of witness
+Serving Dershowitz
+Work product;
+attorney/client privilege;
+Work product; attorney/client
+privilege;
+Work product; attorney/client privilege;
+Work
+product;
+attorney/client
+privilege;
+Work
+product;
+attorney/client privilege;
+Work
+product; attorney/client privilege;
+to the discovery of the admissible evidence
+protected by privacy right
+153
+
+
+00Z0Z-6702
+S8661-28661
+88667
+19971-19981
+02661-69661
+19962-19968
+20190-20192
+20187-20189
+600z/tZ/80
+600Z/E0/60
+600z/L0/0T
+600z/vz/80
+600z/8T/80
+600Z/E0/80
+08/24/2009
+08/24/2009
+IO
+Attorneys at RRA
+Jacquie
+Attorneys at RRA
+Pat Roberts
+Attorneys at RRA
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing..
+Fistos & Lehrman
+FROM
+DESCRIPTION
+OBJECTION
+Proof of him being out of FL -
+Work product; attorney/client privilege;
+Violation of the agreement
+Mike Fisten
+Dave Rogers depo
+Work product; attorney/client
+privilege;
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Mike Fisten
+Ken Jenne
+Depositions
+Work
+product; attorney/client
+privilege;
+Serving Dershowitz
+Work
+product; attorney/client
+privilege;
+Subpoenas for Pilots
+Work product; attomey/client privilege;
+Working with the FBI to get some Work product; attorney/client privilege;
+info
+Personal emails regarding Brad's Work product;
+attorney/client privilege;
+surgery
+Epstein travel
+Work product; attorney/client privilege:
+154
+
+
+19959-19961
+_ PATE
+07/24/2009
+00156-00157
+600Z/60/L0
+15366-15367
+09/04/2009
+01003-01005
+10/12/2009
+01013-01014
+10/29/2009
+01042
+07/22/2009
+03133-03134
+06/09/2009
+IO
+Attorneys at RRA
+Attorneys at RRA
+Marc Nurik
+Josh Roberts
+Privilege LoR - Dated 2-23-2011
+, Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Paul Cassell
+Paul Cassell
+Cara
+Flight logs for Epstein
+2255 Problem
+Witness info that we need to use
+Asset movement
+Epstein
+by
+OBJECTION
+Work product; attorney/client
+privilege;
+Work product; attorney/client privilege;
+itrelevant and not reasonably calculated to lead
+Work
+product; attorney/client privilege;
+Jeffrey Work
+product; attorney/client
+privilege;
+Subpoenaing Epstein's attorneys
+product;
+attorney/client privilege;
+for their fees and accompanying | irrelevant and not reasonably calculated to lead
+New Info that our investigators Work product; attorney/client
+privilege;
+obtained from current FBl agents | irrelevant and not reasonably calculated to leac
+Personal conversation
+Work product; attorey/client privilege;
+155
+
+
+03129-03130
+03119-03121
+05440-05441
+02593-02594
+18877-18879
+18344-18347
+PATE
+06/09/2009
+06/09/2009
+04/01/2009
+05/13/2009
+09/10/209
+08/24/2009
+TO
+Josh
+T.
+(wife)
+Marc Nurik
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing, Edwards, Fistos & Lehrman
+FROM
+DESCRIPTION
+Personal conversation
+Josh |
+Carolyn
+(Legal
+Asst. to
+Jay
+Howell,
+Co-
+Counsell
+Bradley Edwards
+Mike Fisten
+OBJECTION
+Work product; attorney/client
+privilege;
+Personal conversation
+Work product; attorney/client
+privilege;
+CW Personal information
+Work product; attorney/client privilege;
+Irrelevant and not reasonably calculated to lead
+Regarding personal information.
+Privileged document. irrelevant and not
+calculated to lead to discovery of admissible
+evidence, privacy rights of parties involved,
+spouse privilege
+Concerning
+the names of Work product; attorney/client privilege;
+otential witnesses and the irrelevant and not reasonably calculated to lear
+ssuance of subpoena's for them. to the discovery of the admissible evidence
+Investigative information and Work product; attomey/client privilege;
+techniques on the Epstein case
+T irrelevant and not reasonably calculated to lead
+are discussed.
+156
+
+
+18339-18340
+18341-18343
+18853-18854
+18337-18338
+18306
+18307
+DATE
+08/24/2009
+08/24/2009
+09/10/2009
+08/03/2009
+10/16/2009
+10/17/2009
+Ken Jenne
+Mike Fisten
+Pat |
+Mike Fisten,
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing..
+_ Fistos & Lehrman
+FROM
+RESCRIPTION
+OBJECTION
+Investigative
+information
+and
+| Work
+product;
+attorney/client privilege;
+techniques on the Epstein case
+| irrelevant and not reasonably calculated to lead
+are discussed.
+Jacquie
+Mike Fisten
+Ken Jenne
+Investigative information
+/ product; attorey/client privilege;
+techniques on the Epstein case irrelevant and not reasonably calculated to lead
+are discussed.
+Concerning
+the
+names
+of Work product; attorney/client privilege;
+potential witnesses
+and the irrelevant and not reasonably calculated to lead
+issuance of subpoena's for them. to the discovery of the admissible evidence;
+Investigative information and Work product; attorney/client privilege;
+techniques on the Epstein case
+| irrelevant and not reasonably calculated to lead
+are discussed.
+product;
+attorney/client privilege;
+case and ne mes of potential relevant and not reasonably calculated to read
+Investigative
+Discussion
+finding of Epstein Assets.
+product; attorney/client privilege;
+Irrelevant and not reasonably calculated to lead
+157
+
+
+18308-18309
+18188-18189
+18184-18185
+18186-18187
+18180-18183
+05256-05257
+DATE
+10/18/2006
+TO
+Mike Fisten
+09/04/2009
+Mike Fisten
+08/26/2009
+Mike Fisten
+08/31/2009
+08/24/2009
+07/21/2009
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+Fistos & Lehrman
+FROM
+DESCRIPTION
+Investigative
+Discussion
+finding of Epstein Assets.
+Jacquie|
+Mike Fisten
+Wayne Black
+OBJECTION
+re: Work product;
+attomey/client privilege;
+Investigative
+Discussion
+re: i Work product; attorney/client privilege;
+finding of Epstein witnesses and
+I irrelevant and not reasonably calculated to lead
+names of potential witnesses.
+to the discovery of the admissible evidence:
+Investigative
+Discussion
+re: Work product; attorney/client privilege;
+inding of Epstein witnesses and irrelevant and not reasonably calculated to lea
+ames of potential witnesses
+Discussion of potential witnesses Work product; attorney/client privilege;
+and the process of subpoena for
+depo's
+re: Work product; attorney/client privilege;
+finding of Epstein witnesses and | irrelevant and not reasonably calculated to lead
+names of potential witnesses.
+Investigative
+Discussion
+strategy of case.
+re: Work product; attorney/client privilege;
+158
+
+
+05253
+PATE
+08/24/2009
+TO
+05279-05280
+08/24/2009
+05315-05318
+07/26/2009
+05209-05211
+06/26/2009
+Privilege Log - Dated 2-23-2011
+Jaffe, Weissing.
+, Fistos & Lehrman
+FROM
+DESCRIPTION
+Wayne Black
+Investigative
+Discussion
+strategy of case.
+Pat
+Wayne Black
+Wayne Black
+OBJECTION
+re:
+Work product;
+attorney/dient
+privilege;
+Investigative
+Discussion
+strategy of case.
+Investigative
+strategy of case.
+Discussion
+Work product; attomey/client privilege;
+TWork product; attorney/client privilege;
+Investigative
+strategy of case.
+Discussion
+re:
+Work
+. product;
+attomey/client
+privilege;
+NOT A CE
+159
+
+
+..Emails01
+.Emails01
+..Emails01-
+02
+..Emailso2
+..Emails03
+..Emails03
+DATE
+05/22/2010
+9:53am
+05/22/2010
+9:10am
+05/22/2010
+8:47am
+05/21/2010
+12:44pm
+6/2/2010
+11:50 am
+6/2/2010
+10:49 am
+BRAD
+- PRIVILEGE LOG
+EMAILS DATED NOVEMBER 2009 TO AUGUST 2010
+FROM
+Conchita
+Sarnoff
+Spencer
+Kuvin; Mike
+Fisten
+Spencer
+Kuvin; Mike
+Fisten
+DESCRIPTION
+OBJECTION
+Epstein moving | Irrelevant- not reasonably
+assets and sex calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Epstein moving irrelevant- not reasonably
+assets and sex
+calculated to lead to the
+trafficking
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Epstein
+moving
+Irrelevant- not reasonably
+assets and sex
+calculated to lead to the
+traffic
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Epstein
+moving
+Irrelevant- not reasonably
+assets and sex
+calculated to lead to the
+trafficking
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Epstein moving Irrelevant- not reasonably
+assets and sex
+calculated to lead to the
+trafficking
+discovery of admissible
+evidence and outside the
+complaint. Work product
+Epstein moving
+Irrelevant- not reasonably
+assets and sex
+calculated to lead to the
+trafficking
+discovery of admissible
+evidence and outside the
+1
+
+
+
+..Emails05
+...Emails06
+...Emails06
+..Emails06
+...Emails06
+DATE
+6/2/2010
+10:42 am
+6/7/2010
+8:01pm
+6/8/2010
+11:30am
+6/8/2010
+10:13am
+6/8/2010
+9:52am
+6/8/2010
+9:27am
+BRAD EUWADS - PRIVILEGE LOG
+EMAILS DATED NOVEMBER 2009 TO AUGUST 2010
+TO
+EROM
+[DESCRIPTION
+OBJECTION
+Epstein moving frilevant. not reasonably
+assets and sex
+calculated to lead to the
+Spencer Kuvin; | trafficking
+discovery of admissible
+Mike Fisten
+evidence and outside the
+complaint. Work product
+privilege
+Brad
+Conchita
+Investigation
+of
+Irrelevant- not reasonably
+other potential
+calculated to lead to the
+witnesses.
+discavery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Brad
+Conchita
+Location
+Witnesses
+of Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Conchita
+Brad
+Location
+Witnesses
+of | Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+Brad
+Conchita
+Location
+Witnesses
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+Conchita
+Brad
+Location
+Witnesses
+of
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+2
+
+
+..Emails07
+...Emails07
+..Emails07
+..Emails07
+..Emails08
+..Emails08
+DATE
+6/8/2010
+9:27am
+6/8/2010
+8:55am
+6/8/2010
+8:40am
+6/8/2010
+8:26am
+6/8/2010
+8:10am
+6/7/2010
+21:57 am
+Brad
+BRAD EUWARUS - PHIVILEGE LOG
+EMAILS DATED NOVEMBER 2009 TO AUGUST 2010
+FROM
+DESCRIPTION
+Location
+Witnesses
+Conchita
+Brad
+Location
+Witnesses
+Brad
+Conchita
+Location
+Witnesses
+Conchita
+Brad
+Location
+Witnesses
+Brad
+Conchita
+Location
+Witnesses
+Conchita
+Brad
+Location
+Witnesses
+OBJECTION
+_ Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+of
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint.
+. Work product
+of
+privilege
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+of
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+of
+Irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
+privilege
+of | irrelevant- not reasonably
+calculated to lead to the
+discovery of admissible
+evidence and outside the
+complaint. Work product
\ No newline at end of file
diff --git a/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.receipt.json b/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..68278968c27ddcb81d942e2180d6fef0666b5ec9
--- /dev/null
+++ b/vision-fixhub/court-02/09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -18529,
+  "dataset": "marble-joined",
+  "doc_id": "09e11b65269f45d94c2aefacf32bc06ae21be469c72fc8ddbc5423eabb4d46e1",
+  "engine": "marble-apple-vision",
+  "event_count": 29,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
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diff --git a/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.md b/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.md
new file mode 100644
index 0000000000000000000000000000000000000000..965abad1790df505edafd9e9cd0c7be89cbf036b
--- /dev/null
+++ b/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.md
@@ -0,0 +1,132 @@
+Filing # 64110846 E-Filed 11/13/2017 02:49:14 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants).
+NOTICE OF SERVING ANSWERS TO EXPERT INTERROGATORIES
+COMES NOW the Defendant,
+J. Edwards, by and through undersigned counsel,
+and hereby files this Notice of Serving Answers, to Expert Interrogatories with the Court
+propounded by the Plaintiff/Counter-Defendant, Jeffrey Epstein, on October 13, 2017.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 13th
+day of_
+Mov.
+- 2017.
+NOT
+Attorney E-Mail(s): jsx@searcylaw.com and
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorney for Plaintiffs)
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 11/13/2017 02:49:14 PM
+
+
+Case No.: 502009CA040800XXXXMBAG
+Notice of Serving Answers to Interrogatories
+William Chester
+, Esquire
+weblaw@aol.com; weblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Andrew A. Harris, Esquire
+aah@FLAppellateLaw.com; jew@FLAppellatel.
+aw.com;
+Burlington & Rockenbach
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Fax: (561)-721-0465
+Attorneys for Jeffrey Epstein
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Fax:
+Attorneys for Jeffrey Epstein
+TIFIED COPY
+
+
+J.
+, Esquire
+staff.efile@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Attorneys for Jeffrey Epstein
+Fistos & Lehrman, P.L.
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com;
+Scott@linkrocklaw.com;
+ED COPY
+Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkroeklaw.com
+Link & Rockenbach, P.A.
+1555 palm Beach Lakes Boulevard, Suite 302y
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Paul Morris, Esquire
+paulappeal@gmail.com; paul@paulmorrislaw.com
+Paul Morris, P.A.
+9350 S Dixie Higbway, Suite 1450
+Miami, FL 33156
+Phone: (305)-670-1441
+Fax: (305)-670-2202
+Attorneys for Jeffrey Epstein
+3
+
+
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Mare S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys
+for
+Scott
+Rothstein
+NOT A CERTIFIED COPY
diff --git a/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.receipt.json b/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.receipt.json
new file mode 100644
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+++ b/vision-fixhub/court-02/09ea5012cedb3d4df1b5805bb4a46078e7f8ef5b474a83f33a717d93d5aa3de0.receipt.json
@@ -0,0 +1,14 @@
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+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.md b/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.md
new file mode 100644
index 0000000000000000000000000000000000000000..d9a0bf95fe2b783342eeccc32a00df8842bd9a3a
--- /dev/null
+++ b/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.md
@@ -0,0 +1,128 @@
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
+IN AND FOR PALM BEACH COUNTY
+CIVIL DIVISION
+JEFFREY EPSTEIN,
+Plaintiffs),
+CASE NO.: 502009A040800XXXXMBAG
+VS.
+SCOTT ROTHSTEIN, etc., et al.,
+• Defendant(s).
+FILED
+2013 NOV 15 PM 3: 47
+CHARONR. BOCK. CLERT
+PALM BEACH COUNTY
+GIRCUIT CIVIL
+ORDER ON COUNTER-PLAINTIFF
+MOTION TO DETERMINE STATUS OF PUNITIVE DAMAGE DISCOVERY
+AND APPLICABILITY OF ADVERSE INFERENCE
+THIS CAUSE came before the Court upon the Counter-Plaintiff,
+Motion to Determine Status of Punitive Damage Discovery. The Court heard
+argument of counsel, has reviewed the submittals and is otherwise fully advised in the
+premises. At hearing, counsel for
+advised the Court that certain "net worth"
+discovery in regard to the punitiye damage count against EPSTEIN had been objected to
+on the basis of the constitutional privilege against self-incrimination. All other objections
+to such discovery had been withdrawn. As such,
+now seeks a ruling from the
+Court in regard to an adverse inference (presumption) jury instruction and evidence
+preclusion at the time of trial. Based upon the foregoing, it is
+CONSIDERED, ORDERED AND ADJUDGED as follows:
+To the extent that the issue of amount of punitive damages is submitted to
+the jury at the bifurcated trial of this matter, the Court rules as follows:
+1. The Counter-Plaintiff
+request for jury instruction adverse
+inference instruction is deferred until the time of trial. At the time of trial, upon specific
+analysis of the specific question and answers, including those propounded in discovery,
+the Court will determine whether an adverse instruction will, or will not, be given and the
+
+
+•
+Epstein v. Rothstein
+Case No. 502009CA040800XXXXMBAG
+Order
+Page 2
+i .
+specific instruction, if any, that will be given. Counsel for the parties shall be prepared at
+trial to propose such jury instructions.
+2. The Motion to Preclude Evidence is also deferred until the time of trial. At
+0211
+the time of trial, this Court will determine whether certain testimony and/or documents
+will be precluded based upon non-compliance with this Court's Pretrial Order and/or a
+Binger analysis conducted by the Court at the time of trial.
+3. Nothing in this Order shall be construed in and of itself as precluding the
+use of any answers submitted by EPSTEIN during discovery at trial if they are otherwise
+admissible.
+DONE AND ORDERED this
+Palm Beach County, Florida.
+day of November, 2013 at West Palm Beach,
+DAVID F.
+CIRCUIT COURT JUDGE
+Copy furnished:
+See attached list.
+Copies
+: fumished
+by oma
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+COUNSEL LIST
+Jack Scarola, Esquire
+jsx@searcylaw.com; mep@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley PA
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+William Chester
+Esquire
+wcblaw@aol.com; wcbcg@aol.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+ARTIFIED COPY
+250 Australian Avenue South, Suite 1400
+Attorneys for Jeffrey Epstein
+Esquire
+staff.efile@pathtojustice.com
+Jaffe, Weissing,
+,, Fistos & Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com; haddadfm@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+2
+
+
+s adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+m; efiling@tonjahaddad.com
+ED COPY
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; Debbie@Tonjahaddad
+.C
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+NOT A CERTI
diff --git a/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.receipt.json b/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..46a69f902f511e61ae5bec800a76fe1ce52b215e
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+++ b/vision-fixhub/court-02/0a2c46b511cd825534ad69f9e3f15c51a63f3c868ca21de3d266462d48a67739.receipt.json
@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "e54b49c52a0cd3c74256dfd44f164182f2ee640e969249a5f57c3322a8717bba",
+  "output_sha256": "0e02fcad410922002f189b47736a9f5937ddc115d51c9f93ad32b6308bb5a36a",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0a4c01d267563e71de866fb3bf6260121d5aacf43aedf9a6176c86dfb495b24e.md b/vision-fixhub/court-02/0a4c01d267563e71de866fb3bf6260121d5aacf43aedf9a6176c86dfb495b24e.md
new file mode 100644
index 0000000000000000000000000000000000000000..e5ad99fb7a8e8f5e875e7c70f924ae69b92b4db8
--- /dev/null
+++ b/vision-fixhub/court-02/0a4c01d267563e71de866fb3bf6260121d5aacf43aedf9a6176c86dfb495b24e.md
@@ -0,0 +1,239 @@
+Filing # 68851713 E-Filed 03/06/2018 12:43:49 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually, and
+L.M., individually,
+Defendants.
+OP
+COPY
+RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM
+TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN
+RULE 1.440
+Counter-Plaintiff
+by and through undersigned counsel, hereby files this Response
+in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to Comply with
+the Mandate Set Forth in Rule 1.440, and in support states as follows:
+As
+has argued for months, Epstein has no intention of ever trying this
+malicious prosecution case. At the eve of every trial date, Epstein files a host of motions in an
+effort to avoid answering to a jury for his malicious lawsuit against
+In his latest attempt to continue that trial, Epstein misrepresents the remaining
+claims by using the term "Action" without defining what he is referring to. As can be seen from
+the record, however, there are two separate and independent Actions involving different parties
+and different claims, and it is undisputable that
+action against Epstein for Malicious
+Prosecution, to which Rothstein is not a party, is at issue.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/06/2018 12:43:49 PM
+
+
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to
+Comply with the Mandate Set Forth in Rule 1.440
+Action #1 - Epstein v. Rothstein (Second Amended Complaint)
+First, Epstein has a claim for Conspiracy to Commit Abuse of Process against Scott
+Rothstein. That claim is pled in the Second Amended Complaint, which was filed on August 21,
+2011.
+4.
+however, is not a party to that case as Epstein voluntarily dismissed
+from the Second Amended Complaint on August 16, 2012.' That point alone nullifies
+Epstein's entire argument that
+* Motion to Set Case for Trial was not ripe. Rule 1.440(b),
+on which Epstein relies, unequivocally states that only a party
+Ly notice an action for trial:
+Thereafter, any party may file and serve a notice that the action is at issue and
+ready to be set for trial...
+As a non-party to the Second Amended Complaint,
+clearly had no ability
+to notice Epstein's case against Rothstein for trial, and he never attempted to do so. Epstein,
+however, has conceded that his action against Rothstein may not be set for trial given, inter alia,
+the Motion for Default Against Rothstein that was filed yesterday. Thus, if Epstein would like to
+try his action against Rothstein (assuming Epstein has finally figured out what case he is actually
+pursuing against that uncollectible defendant in federal prison), he apparently has a lot of work left
+to do, including demonstrating that the Second Amended Complaint and this latest Motion for
+Default were properly served on Rothstein and that Rothstein was given opportunity to respond.
+6.
+however, has no dog in that fight because he is not a party to the Second
+Amended Complaint.
+' Among other reasons, Epstein's voluntary dismissal of
+in
+favor, a necessary element for
+I resulted in a "bona fide termination" of Action #1
+independent malicious prosecution claim in Action #2.
+
+
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to
+Comply with the Mandate Set Forth in Rule 1.440
+Action #2 -
+v. Epstein (Fourth Amended Counterclaim)
+The second action pending is a claim for Malicious Prosecution filed by
+against Epstein. That claim is pled in the Fourth Amended Counterclaim, filed on January 9, 2013,
+after
+was dismissed from Action #1. Rothstein is not a party to this separate action.
+8.
+There is no question that
+Malicious Prosecution claim against Epstein
+has been properly set for trial. Epstein does not even attempt to argue otherwise in his spurious
+motion.
+The case law cited by Epstein is also factually distinguishable for the simple reason
+that all of the claims or counterclaims in those cases involved the same parties that were involved
+in the underlying complaint.
+10.
+For example, in Gawker Media, LLC v. Bollea, 170 So. 3d 125 (Fla. 2d DCA 2015),
+the case primarily relied upon by Epstein, the plaintiff, Bollea, sued multiple defendants, one of
+whom, Blogwire, contested Florida's long arm-jurisdiction over it. After an initial unsuccessful
+attempt to sever the claims against Blogwire and go forward with a trial on his claims against the
+remaining defendants, Bolllea dismissed his claims against Blogwire with prejudice. He then filed
+an amended complaint seeking punitive damages against the remaining defendants and requested
+that the trial court reset the case for trial. Although none of the remaining defendants had answered
+the
+ded complaint, the trial court set the case for trial. The defendants then sought a writ of
+mandamus in the appellate court, which granted the petition on the basis that the trial court's order
+setting the trial before the defendants answered the amended complaint violated Rule 1.440's
+requirement of a minimum of 50 days between service of the last pleading and commencement of
+trial.
+3
+
+
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to
+Comply with the Mandate Set Forth in Rule 1.440
+11.
+Gawker is simply inapplicable here. The Fourth Amended Counterclaim is an
+independent action filed after
+was dismissed from Action #1 (a necessary element to the
+Malicious Prosecution claim). The pleadings in Action #2, the Malicious Prosecution claim, have
+been closed for years, and it is undisputed that the case is at issue.
+is simply no longer a
+party to Action #1, having been dismissed from that Action long ago. Contending that Edwards
+could notice Action #1 for trial is equivalent to saying that defendant Blogwire in the Gawker case
+could have noticed the case there for trial after having been dismissed from the case. Therefore,
+Action #2 is more akin to a crossclaim, which is exempt from Rule |.440.
+12.
+In any event, given that
+is actually a party to the Fourth Amended
+Counterclaim, he properly moved to notice that cause for trial. The Court granted that motion and
+entered its Order Specially Setting Trial on July 20, 2017. The parties to Action #2,
+and
+Epstein, have proceeded under that valid Order for months and are ready to try
+Malicious
+Prosecution claim against Epstein, The fact that Epstein has failed to pursue his claim against
+Rothstein in Action #1 is, to be blunt, irrelevant.
+Epstein's Counsel Continues to Knowingly Inject Privileged Materials
+into the Public Record
+13.
+Edwards asks the Court to direct its attention to page 7 of Epstein's Motion to
+Remove Case from Trial Docket, in which Epstein's counsel again references privileged e-mail
+correspondence listed on
+2011 Privilege Log. Both Mr. Link and Ms. Rockenbach have
+been notified repeatedly that they are in possession of privileged materials listed on
+2011
+Privilege Log. Both have ignored requests to turn over or destroy that information. And it appears
+that they will continue to use these privileged materials without regard for their ethical obligations
+not to do so.
+4
+
+
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to
+Comply with the Mandate Set Forth in Rule 1.440
+14.
+Contemporaneous with this filing
+will be filing a Response in Opposition
+to Epstein's Motion for Court to Declare Relevance, et al, in which Epstein's counsel once again
+cites to privileged materials despite being on notice that these communications are on
+2011 privilege log and were never produced in this case. As the Court will see, Epstein's counsel
+has "jumped the shark" and are claiming to have evidence that Brad Edwards (as well as other
+RRA attorneys and certain other individuals) were in fact knowingly involved in Roth
+Ponzi
+scheme. What the F.B.I and Justice Department missed in their years' long investigation into
+Rothstein's criminal enterprise, and their review of every aspect of RRA's internal documents and
+servers, Epstein and his counsel have possessed for years (without explanation as to how they
+obtained it), overlooked (without explanation as to how or why) for years, and have now found
+days before the scheduled start of trial.
+15.
+Obviously, Epstein's ploy is a desperate attempt to avoid what is clearly the case:
+that he lacked probable cause to either institute or continue the underlying proceeding against
+But Epstein will not admit his wrongdoing and is once again attempting to drag Brad
+name and reputation through the mud, and this time wants to drag many others in as
+well.
+16.A
+Epstein and his counsel, however, benefit (so far) from Florida's absolute litigation
+privilege, which prevents
+and the other victims from pursuing an independent tort claim
+for actions that occur in this proceeding. So, although the litigation privilege dooms Epstein on
+probable cause, it provides cover for his ridiculous and embarrassing claim to have found proof
+that
+(and apparently a host of others) were actually involved in Rothstein's Ponzi scheme.
+5
+
+
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order t
+Comply with the Mandate Set Forth in Rule 1.44(
+Conclusion
+For the foregoing reasons, Epstein's attempt to once again continue the Malicious
+Prosecution Action should be denied.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this Go a
+day of March, 2018.
+JACK SCAROLA
+Floyda Bar No.: 169440
+D
+AVID P. VITALEUR
+Elorida Bar No4 115179
+Attorney E-Mails: jsx@searcylaw.com; and
+mmccann@searcylaw.com
+Primary E-Mail:
+scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+NOT A
+C
+Fax:
+561-383-9451
+Attorneys for
+6
+
+
+¡ adv. Epstein
+Response in Opposition to Epstein's Motion to Remove Case from Trial Docket in Order to
+Comply with the Mandate Set Forth in Rule 1.440
+COUNSEL LIST
+Scott J. Link, Esq.
+Link & Rockenbach, P.A.
+Scott@linkrocklaw.com
+Kara@linkrocklaw.com
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: 561-727-3600
+Fax: 561-727-3601
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+RTIFIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLApppllateL.aw.
+Burlington & Rockenbach, P.Al
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for Bradley J. Edwards
+J. Edwards, Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+7
\ No newline at end of file
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+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 1 of 22
+UNITED STATES DISTRICT COURT
+SOUTHERN DISTRICT OF FLORIDA
+CASE NO. 08-80736-CIV-MARRA
+JANE DOE 1 AND JANE DOE 2,
+Petitioners,
+VS.
+UNITED STATES,
+Respondent.
+GOVERNMENT'S RESPONSE TO PETITIONERS' STATEMENT OF UNDISPUTED
+MATERIAL FACTS IN SUPPORT OF PETITIONERS' MOTION FOR
+PARTIAL SUMMARY JUDGMENT
+Respondent United States of America, by and through its undersigned counsel, files its
+Response to Petitioners' Statement of Undisputed Material Facts, and states:
+1. Admitted.'
+2. Admitted.
+3. Admitted.
+4. The first sentence of paragraph 4 is admitted. As to the second sentence, respondent
+admits only that the Palm Beach Police Department ("PBPD") conducted an investigation, and
+ultimately identified approximately 20 girls between the ages of 14 and 17 who were sexually
+abused by Epstein. The characterizations of the PBPD's investigation as "capably conducted"
+and "thorough" do not appear in the documents cited by Petitioners and are opinions of
+Petitioners' counsel, not facts.
+Statement or temps emied iy fact ten be through our this Response to Sectio fors"
+purposes of petitioners' motion for partial summary judgment.
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 2 of 22
+5. Admitted.
+6. The first sentence in paragraph 6 is admitted in part. The FBI determined that Jane
+Doe 1 had been sexually abused by Epstein while she was a minor, and Jane Doe 1 provided
+information to the FBI regarding her sexual abuse on August 7, 2007. As to Jane Doe 2, the FBI
+determined she had been sexually abused by Epstein while she was a minor, although Jane Doe 2
+was openly hostile to the prosecution of Epstein, contended that no crime had been committed by
+Epstein, and declined to be interviewed by the FBI unless she was granted use immunity. See
+6/2/2017 Villafaña Decl. at T9l 6-12. The second sentence in paragraph 6 also is admitted in part.
+During her August 7, 2007 interview with the FBI, Jane Doe 1 provided detailed information
+about her own abuse. However, Jane Doe I's information about Jane Doe 2 was only that Jane
+Doe 2 "started providing Epstein with massages"; Jane Doe 1 did not provide "detailed
+information about ... the abuse of Jane Doe 2." DE361-32 at p. 5.?
+7. The Government admits the first three sentences in paragraph 7. The fourth sentence
+is denied because the August 11, 2006 letter was sent to Jane Doe 2 because she had been
+identified as a potential victim, not because there had yet been a Government determination that
+she was in fact a victim of a federal offense or came under the protection of the CVRA, 6/2/2017
+Villafaña Decl. at 9l 5, and because that fourth sentence presents an opinion and conclusion, not
+an assertion of fact.
+8. Admitted.
+9. The Government admits that from January 2007 through September 2007, discussions
+2 To refer to exhibits to "Jane Doe 1 and Jane Doe 2's Consolidated Statement of
+Undisputed Material Facts and Motion for Partial Summary Judgment with Incorporated
+Memorandum of Law" (DE361), the government uses the CM-ECF headers that appear on the
+documents. Hence, "DE361-32 at p. 5" refers to the fifth page of Exhibit 32 to DE361.
+2
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 3 of 22
+to resolve the federal investigation took place between the U.S. Attorney's Office for the
+Southern District of Florida and Jeffrey Epstein, through the numerous attorneys who
+represented him. Not all of these discussions were "plea discussions" because Epstein was never
+charged with a federal offense. See 6/2/2017 Villafaña Decl. at 9i9l 4, 17-18, 23, 29.
+10. The Government admits the first sentence of paragraph 10. The second and third
+sentences are denied because they are opinions and conclusions, not assertions of fact.
+11. Admitted.
+12. Admitted.
+13. Admitted.
+14. The first sentence in paragraph 14 is denied because Jane Doe 1 was furnished with a
+victim notification letter on or about June 7, 2007, because Jane Doe 1 had been identified as a
+potential victim, not because there had yet been a Government determination that she was in fact
+a victim of a federal offense or came under the protection of the CVRA, 6/2/2017 Villafaña Decl.
+at 9| 5, and because that first sentence is an opinion and conclusion, not an assertion of fact. The
+second sentence is admitted.
+15. The first sentence in paragraph 15 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact.
+16. Admitted.
+17. The government admits the first sentence of paragraph 17. The second sentence is
+disputed because it is an opinion, not an assertion of fact.
+18. The Government denies that no Government representatives had conferred with
+victims regarding their views on the potential negotiated outcome of the investigation. See 2d
+Kuyrkendall Decl. at MI 5, 12, 13; 6/2/2017 Villafaña Decl. at 99 10, 12, 19. Otherwise admitted.
+3
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 4 of 22
+19. Admitted.
+20. Admitted.
+21. Admitted.
+22. Admitted.
+23. Admitted.
+24. The Government denies that the Office sought to "contrive to establish jurisdiction
+away from the location where the crimes actually occurred-—and away from where the victims
+actually lived —so as to avoid the public finding out about anything." See 6/2/2017 Villafaña
+Decl. at 9 24. Otherwise admitted.
+25. Admitted.
+26. Denied. See 6/2/2017 Villafaña Decl. at I[ 27.
+27. Admitted.
+28. Admitted.
+29. The first sentence is admitted. The second sentence is disputed, as the government
+has produced emails sent to and from the home e-mail address of one of its prosecutors. See
+6/2/2017 Villafaña Decl. at 9| 28.
+30. Admitted.
+31. Admitted.
+32. Admitted
+33. The first sentence in paragraph 33 is admitted. The second sentence is disputed,
+because the Government had notified victims that the matter was under investigation and the
+matter indeed remained under investigation until Epstein entered his state court guilty pleas, see
+6/2/2017 Villafaña Decl. at 9| 35; 2d Kuyrkendall Decl. at 99l 10-11, and because it is a legal
+4
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 5 of 22
+argument, not an assertion of fact. Petitioners also have not cited any evidence to support the
+allegations that "Epstein's counsel, the U.S. Attorney's Office, and the State of Florida were
+conferring daily."
+34. The first sentence in paragraph 34 is admitted. The Government disputes that the
+agreement would bind the victims or that the NPA in fact binds the victims. DE361-62. The
+remainder of the second sentence is admitted, with the qualification that the Government denies
+that the Government did not confer with any victims about possible resolution of the
+investigation, that potentially included the non-prosecution of Epstein; for example, Jane Doe 2
+specifically told the Government that she did not want Epstein to be prosecuted. See 2d
+Kuyrkendall Decl. at 19l 5, 12, 13; 6/2/2017 Villafaña Decl. at T9 10, 12, 19.
+35. The government admits paragraph 35 but notes that the quoted language does not
+appear in Exhibit 4; it appears at DE361-5.
+36. The government admits paragraph 36 but notes that Exhibit 2 is not an email to
+Humberto Ocariz; the referenced email appears at DE361-3. The second sentence of paragraph
+36 is admitted.
+37. Admitted.
+38. The Government admits that on September 24, 2007, Epstein and the U.S. Attorney's
+Office reached a formal non-prosecution agreement, embodied in the NPA, DE361-62, whereby
+the United States would defer federal prosecution in favor of a state prosecution. The
+Government otherwise disputes the petitioners' characterization of the NPA and its legal impact
+as opinion and conclusion, not an assertion of fact. •
+39. The Government admits that the NPA provided that, upon its execution, "the United
+States, in consultation with and subject to the good faith approval of Epstein's counsel, shall
+5
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 6 of 22
+select an attorney representative for [the victims listed by the U.S. Attorney's Office in
+accordance with the NPA], who shall be paid for by Epstein" and that if any of those listed
+victims "elects to file suit pursuant to 18 U.S.C. § 2255, Epstein will not contest the jurisdiction
+of the United States District Court for the Southern District of Florida over his person and/or the
+subject matter, and Epstein waives his right to contest liability and also waives his right to
+contest damages up to an amount as agreed to between the identified individual and Epstein, so
+long as the identified individual elects to proceed exclusively under 18 U.S.C. § 2255, and agrees
+to waive any other claim for damages, whether pursuant to state, federal, or common law," but
+the Government otherwise denies the petitioners' characterizations of the agreement's terms.
+DE361-62 at 9l 7-8. The Government admits that these provisions were drafted without the
+knowledge or consent of the victims, but denies that the victims did not have an opportunity to
+reasonably confer about how the Epstein investigation could be resolved, and thus, were not
+denied an opportunity to reasonably confer about the matters addressed in those provisions of the
+NPA. 6/2/2017 Villafaña Decl. at 91 5, 8, 13.
+40. Admitted.
+41. Admitted, except that the Government denies that the NPA "provided that it was
+confidential." DE361-62.
+42. Admitted, with the qualification that the Government denies that the Government did
+not confer with any victims about possible resolution of the investigation, that potentially
+included the non-prosecution of Epstein; for example, Jane Doe 2 specifically told the
+Government that she did not want Epstein to be prosecuted. See 2d Kuyrkendall Decl. at T9l 5,
+12, 13; 6/2/2017 Villafaña Decl. at 19 10, 12, 19.
+43. Admitted.
+6
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 7 of 22
+44. Admitted.
+45. Admitted, with the qualification that the Government denies that the Government did
+not confer with any victims about the possible resolution of the investigation, that potentially
+included the non-prosecution of Epstein; for example, Jane Doe 2 specifically told the
+Government that she did not want Epstein to be prosecuted. See 2d Kuyrkendall Decl. at T9l 5,
+12, 13; 6/2/2017 Villafaña Decl. at 19l 10, 12, 19.
+46. Admitted.
+47. Denied. AUSA Villafana met with Jane Doe 1 and Jane Doe 2 and most of the other
+victims when their identities became known. She told them, in written correspondence and
+orally, that she was available for consultation if they wanted to discuss any aspect of the case.
+6/2/2017 Villafaña Decl. at 9l 5, 31.
+48. Admitted.
+49. Admitted.
+50. Admitted.
+51. The first sentence in paragraph 51 is admitted. The second sentence is denied
+because it is an opinion, not an assertion of fact, but the Government admits that the statement
+appears in DE361-68
+52. Admitted, except that the Government denies that the email stated that the
+Government and Epstein's counsel "would negotiate privately.".
+53. Admitted.
+54. The Government admits that paragraph 54 accurately quotes from an email dated
+September 25, 2007 from AUSA |
+_ Villafaña to Jay Lefkowitz, but denies that the email
+"tried] to set up an arrangement whereby Epstein's victims would not be represented by various
+7
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 8 of 22
+private attorneys, and ... arguled] instead for an attorney in Miami who could help keep things
+concealed." See 6/2/2017 Villafaña Decl. at 9| 24.
+55. Admitted.
+56. Admitted, except that the Government denies that the referenced attorney was an
+"attorney appointed by the Office to represent the victims - without the knowledge of the
+victims." The Government enlisted the Hon. Edward B.
+to serve as a Special
+to
+assist the U.S. Attorney's Office in selecting an attorney representative, see DE362-9, and Judge
+selected Robert Josefsberg from the Podhurst Orseck firm, not the attorney referenced in
+paragraph 56. See DE362-12.
+57. Admitted.
+58. Admitted, except that the Government denies that the attorney raising concerns was
+selected by the Government, or paid by Epstein. See I| 56, supra.
+59. The first sentence in paragraph 59 is admitted. The second sentence is denied. See
+6/2/2017 Villafaña Decl. at 9| 38.
+60. Admitted.
+61. Admitted. (citation is incorrect).
+62. Denied. The Thursday, October 18, 2007 email from Mr. Lefkowitz expresses
+thanks to U.S. Attorney Acosta for meeting on Friday.
+63. Admitted.
+64. Admitted.
+65. Admitted.
+66. The government admits that the NPA contained the following language: "The
+parties anticipate that this agreement will not be made part of any public record. If the United
+8
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 9 of 22
+States receives a Freedom of Information Act request or any compulsory process commanding
+the disclosure of the agreement, it will provide notice to Epstein before making that disclosure."
+DE361-62 at 9l 13. The government further admits that, in the past, it has described that
+provision as an express confidentiality provision.
+67. Denied. See DE 361-62. Paragraph 67 is a legal argument, not an assertion of fact.
+See also 6/2/2017 Villafaña Decl. at 1 30.
+68. Denied. See DE 361-62. Paragraph 68 is a legal argument and opinion, not an
+assertion of fact. See also 6/2/2017 Villafaña Decl. at 9| 30.
+69. Denied. See 6/2/2017 Villafaña Decl. at T9l 21, 32-34; 2d Kurykendall Decl. at 1 9.
+Paragraph 69 is an opinion, not an assertion of fact.
+70. The first and second sentences of paragraph 70 are admitted. With regard to the third
+sentence, the Government admits that the Special Agents told Jane Doe 1, among other things,
+that Epstein would plead guilty to state charges, he would be required to register as a sex
+offender for life, and he made certain concessions related to the payment of damages. The
+Government denies that Agents told Jane Doe 1 that the state charges involve[ed] another
+victim" or that the Special Agents made any statements to that effect "[dJuring this litigation."
+In support of this paragraph, Petitioners cite DE361-26, which is the Declaration of Jane Doe 1,
+not any statement made by any Special Agent during this litigation. See 2d Kuyrkendall Decl. at
+91 8; DE 361-26.
+71. Denied. See 2d Kuyrkendall Decl. at 9l 8.
+72. Denied. See id. at 99l 7, 8, 13.
+73. Denied. See id.; see also 6/2/2017 Villafaña Decl. at 99l 5, 31.
+74. Denied. See DE361-62. Paragraph 74 is a legal conclusion, not an assertion of fact.
+9
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 10 of 22
+Moreover, the phrase referenced by petitioners is from I| 13 (page 5 of 7) of the NPA and only
+requires notice to Epstein before making a disclosure under the Freedom of Information Act or
+compulsory process. See DE361-62.
+75. Denied. See 2d Kuyrkendall Decl. at 991 8-11; 6/2/2017 Villafaña Decl. at 91 34-36.
+76. Admitted, insofar as it addresses the time period before Epstein's entry of his guilty
+plea to state charges.
+77. The first sentence in paragraph 77 is admitted. The second sentence is denied. The
+reason no further notifications to other victims were made at that point, was due to a concern that
+Epstein would breach or otherwise fail to abide by the NPA, and Epstein's attorneys would
+attempt, in any subsequent federal criminal prosecution, to impeach the victims, FBI agents, and
+prosecutors on the basis of the financial incentive created by the NPA. See 2d Kuyrkendall Decl.
+at 99l 8-11; 6/2/2017 Villafaña Decl. at 99 34-36.
+78. Denied. See, e.g., 7/9/2008 Villafaña Decl. (DE14) at I 12; 12/22/2008 Villafaña
+Decl. (DE35) at Til 4, 9, 11, 12.
+79. Admitted.
+80. Admitted.
+81. Denied. Exhibit 26 is Jane Doe No. I's affidavit.
+82. The first sentence in paragraph 82 is denied. The government did not inform the
+victims of the NPA, until after Epstein entered his plea, because the Attorney General Guidelines
+For Victim and Witness Assistance (May 2005), provided that CVRA rights did not apply unless
+there was an "offense charged in a Federal court" and because of concerns that, if Epstein failed
+to perform his obligations under the NPA and prosecution of Epstein were to proceed, the
+notifications regarding the NPA would be used to impeach the victims, agents, and the
+10
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 11 of 22
+prosecutor. See Ex. M; 2d Kuyrkendall Decl. at I 9; 6/2/2017 Villafaña Decl. at T1 21, 34. The
+remainder of paragraph 82 is admitted
+83. Admitted.
+84. Denied. See paragraphs 78 and 82, supra.
+85. Admitted.
+86. The Government denies that the letter referenced in paragraph 86 "recognize[ed] that
+the victims had not yet been afforded any rights." See DE362-18. Otherwise admitted.
+87. The first sentence in paragraph 89 is admitted. The Government additionally admits
+that it held off on sending any victim notification letters in December 2007, but it denies that it
+did so to "complly]" with the request from attorney
+, and the Government, through the
+FBI, later sent additional victim notification letters in January 2008. 6/2/2017 Villafaña Decl. at
+99| 21, 32-34; 2d Kuyrkendall Decl. at 1 9; Ex. J.
+88. Admitted.
+89. The first sentence in paragraph 89 is admitted, with the qualification that the
+government had stopped notifying victims about the NPA, until after Epstein entered his plea,
+because the Attorney General Guidelines For Victim and Witness Assistance (May 2005),
+provided that CVRA rights did not apply unless there was an "offense charged in a Federal
+court" and because of concerns that, if Epstein failed to perform his obligations under the NPA
+and prosecution of Epstein were to proceed, the notifications regarding the NPA would be used
+to impeach the victims, agents, and the prosecutor. See Ex. M; 2d Kuyrkendall Decl. at 9 9;
+6/2/2017 Villafaña Decl. at Til 21, 34.. The second sentence is denied because it is an opinion
+and conclusion, not an assertion of fact. The third sentence in paragraph 89 is admitted, with the
+qualification that the U.S. Attorney's Office never declined any victim's request to confer.
+11
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 12 of 22
+6/2/2017 Villataña Decl. at 4| 5.
+90. Admitted.
+91. The first sentence in paragraph 91 is denied because it contains the unsupported
+opinion and conclusion of Jay Lefkowitz (counsel to Epstein), not an assertion of fact. See
+DE362-21. The second sentence is denied because it was Epstein's attorneys, not the United
+States Attorney's Office, who asked the Child Exploitation and Obscenity Section, Department
+of Justice, to review the case. See DE362-16 at 6, 7 (
+Nos. RFP MIA 000505, 000506).
+92. The first sentence of paragraph 92 is admitted. The Government denies that no
+victims were told about the existence of the NPA. Jane Doe 1 and two other victims had been
+informed in October 2007 that a resolution of the case had been reached. See 2d Kuyrkendall
+Decl. at II 8-9. Otherwise admitted.
+93. The Government admits that the referenced letters were sent on January 10, 2008.
+The Government is without knowledge as to the date that the referenced letters were received.
+94. Admitted, with the qualification that there was a single federal investigation, not
+multiple "federal cases." See 6/2/2017 Villafaña Decl. at T9l 4, 20.
+95. The Government admits that letters containing the same information contained in the
+January 10, 2008 letters to Jane Doe 1 and Jane Doe 2 were sent to other persons identified as
+victims of Epstein. The Government denies that the cited pages in Exhibit 63 support that
+factual assertion. The Government also denies that these victims were "similarly situated to Jane
+Doe 1 and Jane Doe 2" because it is an opinion and conclusion, not an assertion of fact, and
+because the interests and circumstances of different victims were different. See, e.g., 6/2/2017
+Villafaña Decl. at 99l 5, 18, 19, 24, 25, 31, 36; 2d Kuyrkendall Decl. at 99l 5, 8, 12, 13.
+96. The government admits only that in January 2008 Jane Doe 1 expressed her view
+12
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 13 of 22
+that Epstein should be prosecuted, see 6/2/2017 Villafaña Decl. at I| 36; 2d Kuyrkendall Decl. at
+I 13, but otherwise denies the first sentence of paragraph 96. In early January 2008, Jane Doe 2
+was hostile to any prosecution of Epstein, was represented by counsel paid for by Epstein, and
+had spoken of Epstein in the most glowing terms. See 6/2/2017 Villafaña Decl. at 191 6-14, 31.
+The second sentence in paragraph 96 is denied as Jane Doe 1 and Jane Doe 2 never asked to
+confer or consult with the FBI or with AUSA Villafaña about the prosecution of Epstein despite
+having been informed of a victim's right to confer and having been provided with contact
+information for Special Agent Kuyrkendall and for AUSA Villafaña. See 6/2/2017 Villafaña
+Decl. at 9| 5; 2d Kuyrkendall Decl. at 99l 6, 7; Exs. 5, 6. The last two sentences in paragraph 96
+are denied because: (a) they are opinions and conclusions, not assertions of fact; (b) the federal
+criminal investigation of Epstein, including the investigation of Epstein's crimes against them,
+remained on-going in the first half of 2008; and (c) Jane Doe 1 and Jane Doe 2 had been
+provided information for contacting AUSA Villafaña if they wanted to confer. See Villafaña
+Decl. at 99 5, 35-36.
+97. The Government denies that Jane Doe 1 met with multiple AUSAs from the U.S.
+Attorney's Office. The second attorney who was present was employed by the Child
+Exploitation and Obscenity Section of the U.S. Department of Justice, not the U.S. Attorney's
+Office. Otherwise admitted.
+98. Admitted.
+99. The first sentence in paragraph 99 is admitted to the extent that the Government
+assumes that "Jane Doe 5" refers to an individual with initials S.R. The Government admits that
+the referenced letter made no disclosure about the NPA, but otherwise denies the last two
+sentences in paragraph 99 because they are opinions and conclusions, not assertions of fact and
+13
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 14 of 22
+because the federal criminal investigation of Epstein, including the investigation of Epstein's
+crimes against them, was on-going in the first half of 2008 in case the NPA was set aside or
+Epstein did not perform his obligations under the NPA. See id. at 99l 35-36.
+100. Admitted to the extent that the Government assumes that "Jane Doe 5" refers to an
+individual with initials S.R. and with the qualification that Jane Doe 1 and two other victims had
+been informed in October 2007 about the NPA. See id. at 99| 32-33; 2d Kuyrkendall Decl. at 99l
+8-9.
+101. The government admits that, in mid-June 2008, Mr.
+contacted the line
+AUSA handling the case to inform her that he represented Jane Doe 1. The government admits
+that, on June 27, 2008, when the line AUSA contacted Mr.
+to inform him of the state
+plea proceeding scheduled for June 30, 2008, Mr.
+informed the line AUSA that he also
+represented Jane Doe 2. See 7/9/2008 Villafaña Decl. (DE14) at 9| 11. The government admits
+that, in mid-June 2008, Mr.
+asked to meet with the line AUSA to provide information
+about Epstein and Jane Doe 1. Id. at Il 10. The government further admits that the line
+prosecutor and Mr.
+discussed the possibility of federal charges being filed in the future
+and that the NA was not mentioned. The government denies the remainder of paragraph 101
+because it contains opinions and conclusions, not assertions of fact. See also 6/2/2017 Villafaña
+Decl. at 9| 37.
+102. The first sentence in paragraph 102 is admitted. The government further admits
+that the line prosecutor did not inform Mr.
+about the NPA, but the second sentence of
+paragraph 102 is otherwise denied because it is an opinion and conclusion, not an assertion of
+fact. See also id. The third sentence in paragraph 102 also is denied. See id.
+103. The government admits that on June 19, 2008, Mr.
+sent an email to the
+14
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 15 of 22
+line prosecutor requesting to "meet ... and discuss [his] plans." 6/2/2017 Villafaña Decl., Ex.
+11. The government denies the remainder of paragraph 103, including that Mr.
+mentioned more than one client. Id. at 9| 37, Ex. 11.
+104. The first two sentences in paragraph 104 are denied because they are opinions and
+conclusions, not assertions of fact and because on July 3, 2008, Mr. |
+did discuss with the
+line prosecutor his concerns regarding how the Epstein investigation had been resolved. Those
+concerns were shared with managers at the U.S. Attorney's Office. See id. at Il 39. Mr. |
+also did not make it "perfectly clear that his clients wanted to confer with the prosecutor before
+any resolution was reached." Id. at | 37. The last sentence in paragraph 104 is denied. Id.
+105. Admitted.
+106. The first sentence in paragraph 106 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact and because victims, including
+Jane Doe 1, were told about the terms of the NPA, including that the resolution of the federal
+investigation included Epstein's entry of a guilty plea in state court. See 2d Kuyrkendall Decl. at
+91 8; 7/9/2008 Villafaña Decl. (DE14) at I| 12, Exs. 6 &7; 12/22/2008 Villafaña Decl. (DE35) at I
+9,
+107. The first sentence of paragraph 107 is admitted. The second sentence of paragraph
+107 is denied. See 6/2/2017 Villafaña Decl. at 9| 38. The third sentence of paragraph 107 is
+denied because there was no federal plea agreement and the guilty pleas in state court would not
+bring an end to the possibility of federal prosecution under the terms of the NPA. See DE361-
+62.
+108. The Government admits that Jane Doe 1 and Jane Doe 2 did not attend the state
+court plea hearing; paragraph 108 is otherwise denied. See 6/2/2017 Villafaña Decl. at 1 38.
+15
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 16 of 22
+109. Denied. Paragraph 109 is an opinion and conclusion, not an assertion of fact and
+the plea agreement in state court did not make impossible to prosecute Epstein federally for his
+crimes against Jane Doe 1 and Jane Doe 2. See DE361-62.
+110. Admitted.
+111. The government admits the text of the e-mail cited is accurate. It denies the
+assertion that there were continuing efforts to keep the NPA secret since this is an opinion and
+conclusion, not an assertion of fact.
+112. The first sentence in paragraph 112 is admitted. The second sentence is denied
+because it is an opinion and conclusion, not an assertion of fact. See also 2d Kuyrkendall Decl.
+at 99 8-9.
+113. Admitted.
+114. Paragraph 114 is denied because it contains opinions and conclusions, not
+assertions of fact; because Jane Doe 1 had previously been told about the terms of the NPA,
+including that the resolution of the federal investigation included Epstein's entry of a guilty plea
+in state court; and because the state plea did not "block the prosecution of [Jane Doe I's] case."
+See 2d Kuyrkendall Decl. at 9I 8; 6/2/2017 Villafaña Decl. at 99 37-38; DE361-62
+115. Paragraph 115 is denied because it contains opinions and conclusions, not
+assertions of fact and because the state plea did not "block the prosecution of [Jane Doe 2's]
+case." See 6/2/2017 Villafaña Decl. at 99l 37-38; DE361-62.
+116. Denied. 2d Kuyrkendall Decl. at 99l 8-9.
+117. Paragraph 117 is denied because it is an opinion and conclusion, not an assertion of
+fact.
+118. Admitted.
+16
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 17 of 22
+119. Paragraph 119 is denied because it is an opinion and conclusion, not an assertion of
+fact. See also 2d Kuyrkendall Decl. at 99l 8-9.
+120. The Government admits that, on July 7, 2008, the line prosecutor corresponded by
+email with Epstein's counsel seeking his signed agreement concerning a notification letter to the
+victims before beginning the distribution of that letter and acknowledging her previous failure to
+include one victim who was still a minor in 2008; paragraph 120 is otherwise denied.
+121. Paragraph 121 is denied. The cited documents are unsworn and do not support the
+assertion that Mr.
+first saw a reference to the NPA on or after July 9, 2008 or that it was
+the first public mention or first disclosure to Mr.
+. See also 2d Kuyrkendall Decl. at 91 8.
+122. Paragraph 122 is denied because it is an opinion and conclusion, not an assertion of
+fact.
+123. Paragraph 123 is denied because it is an opinion, conclusion, and argument, not an
+assertion of fact, and because it is erroneous. See 6/2/2017 Villafaña Decl. at 99l 27, 30.
+124. Paragraph 124 is denied because it is an opinion and conclusion, not an assertion of
+fact. There is no citation to any material supporting this allegation because there is no
+requirement for a state court judge to review a federal non-prosecution agreement and
+"determine whether it was in the public interest."
+125. Paragraph 125 is denied because it is an opinion and conclusion, not an assertion of
+fact, and because it is erroneous. See 6/2/2017 Villafaña Decl. at T 5, 31, 38; 2d Kuyrkendall
+Decl. at 9 6-9.
+126. The government admits the first sentence of paragraph 126. As to the second
+sentence, the government admits that Jane Doe 1 had not seen the NPA at the time the
+emergency petition was filed, but denies that Jane Doe 1 was unaware of the agreement that had
+17
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 18 of 22
+been reached between Epstein and the U.S. Attorney's Office. See 2d Kuyrkendall Decl. at 1 8.
+The government denies the third sentence of paragraph 126. There is no citation to any material
+supporting this allegation and the government does not know when Epstein first became aware of
+Jane Doe 1's petition.
+127. Admitted.
+128. Admitted.
+129. The government admits that paragraph 129 correctly quotes from DE362-44. The
+government denies that DE362-44 "explain[s] how [the line prosecutor] intended to keep the
+victims from having access to the terms of the NPA." That document actually states that "the
+notification has been slightly modified in order to provide more complete information." DE362-
+44 at p.2.
+130. Admitted to the extent that "Jane Doe 5" refers to an individual with initials S.R.
+131. Admitted.
+132. Admitted.
+133. The government admits that, during the July 11, 2008 hearing, the government
+conceded that all parts of the NPA had been signed by December 2007, but noted that Epstein
+had challenged the NPA and sought further review of the agreement higher up within the
+Department of Justice. See DE361-63 at 14-15. The remainder of paragraph 133 is denied.
+134. Admitted.
+135. The government admits Paragraph 135, with the exception of the term "assured,"
+which reflects an opinion and conclusion not an assertion of fact. DE362-53 informs counsel for
+Epstein of the petitioners' motion and the government's position.
+136. Admitted.
+18
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 19 of 22
+137. Denied. There is no citation to any material supporting this allegation.
+138. Admitted.
+139. Admitted.
+140. Admitted.
+141. Admitted.
+142. Admitted.
+143. Admitted.
+144. Admitted.
+145. Admitted.
+146. Paragraph 146 is denied as to Jane Doe 1, see 2d Kuyrkendall Decl. at 9| 8, and
+admitted as to Jane Doe 2.
+147. Admitted.
+148. Admitted.
+149. Paragraph 149 is denied because it is an opinion and conclusion, not an assertion of
+fact and inaccurately quotes from DE362-66.
+150. Paragraph 150 is denied because there is no citation to any material supporting this
+allegation.
+151. Paragraph 151 is denied because there is no citation to any material supporting this
+allegation. The government admits that DE362-68 is an email from the line prosecutor to the
+State Attorney's Office that references an inquiry from "the Shiny Sheet."
+152. Admitted
+153. Admitted.
+154. Admitted.
+19
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 20 of 22
+155. The first and second sentences in paragraph 155 are admitted. The remaining
+sentences are denied because they are opinions and conclusions, not assertions of fact.
+156. Paragraph 156 is denied because it is an opinion and conclusion, not an assertion of
+fact, and because it is erroneous. See also 6/2/2017 Villafaña Decl. at 99l 6-13, 15, 19-21, 25, 33-
+34, 38; 2d Kuyrkendall Decl. at 1I 8-9; DE361-62. Furthermore, with regard to
+and
+Jane Doe 5, one had informed the FBI that she did not want to be bothered again about the
+Epstein matter and the other had refused to speak to the government. See Villafaña Decl. at 9 19.
+157. The first sentence in paragraph 157 is admitted but the government notes that
+Epstein's guilty plea did not prevent prosecutions of Epstein for crimes against the victims. See
+DE361-62. The remaining sentences are denied. See 6/2/2017 Villafaña Decl. at 99l 5, 7, 10, 12-
+15, 24-27, 30-31, 36; 2d Kuyrkendall Decl. at T 5-8, 12-13.
+111
+111
+11/
+20
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 21 of 22
+Respectfully submitted,
+IG. GREENBERG
+ACTING UNITED STATES ATTORNEY
+By: /s/ Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+Fla Bar No. 0936693
+99 N.E. 4* Street, Suite 300
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+E-mail: dexter.lee@usdoj.gov
+Is/A.
+Villafaña
+A.
+Villafaña
+Assistant United States Attorney
+Fla Bar No. 0018255
+500 S. Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Tel: (561) 820-8711: Fax: (561) 820-8777
+E-mail:
+(s/ Eduardo 1.
+Eduardo I.
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Tel: (305) 961-9057; Fax: (305) 536-4676
+Email:
+Attorneys for the Government
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that on June 6, 2017, the foregoing Response to Petitioners'
+Statement of Undisputed Material Facts was filed with the Clerk of the Court and served on counsel
+on the attached service list using CM/ECF.
+Is/ Dexter A. Lee
+Dexter A. Lee
+Assistant United States Attorney
+21
+
+
+Case 9:08-cv-80736-KAM Document 407 Entered on FLSD Docket 06/06/2017 Page 22 of 22
+JAFFE, WEISSING,
+1. FISTOS & LEHRMAN, P.L.
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Tel: (954) 524-2820; Fax: (954) 524-2822
+E-mail: brad@pathtojustice.com
+Paul G. Cassell
+Pro Hac Vice
+S.J. Quinney College of Law at the
+University of Utah
+332 S. 1400 E.
+Salt Lake City, Utah 84112
+Tel: (801) 585-5202; Fax: (801) 585-6833
+E-mail: casselp.@law.utah.edu
+Attorneys for Jane Doe 1 and Jane Doe 2
+SERVICE LIST
+Dexter A. Lee
+Assistant United States Attorney
+99 N.E. 4" Street, Suite 300
+Miami, Florida 33132
+Tel: (305) 961-9320; Fax: (305) 530-7139
+E-mail: dexter.lee @usdoj.gov
+A.
+Villafaña
+Assistant United States Attorney
+500 S. Australian Avenue, Suite 400
+West Palm Beach, Florida 33401
+Tel: (561) 820-8711: Fax: (561) 820-8777
+E-mail:
+Eduardo I.|
+Assistant United States Attorney
+Florida Bar No. 877875
+99 N.E. 4th Street
+Miami, Florida 33132
+Ema 305) 961-9057: Fax: (305) 536-4676
+Attorneys for the United States
+Jacqueline Perczek
+BLACK SREBNICK KORNSPAN &
+STUMPF
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Tel: (305) 371-6421; Fax: 305-358-2006
+Email: Pleading@royblack.com
+Roy E. Black
+BLACK SREBNICK KORNSPAN &
+STUMPF
+201 S. Biscayne Boulevard, Suite 1300
+Miami, FL 33131
+Tel: (305) 371-6421; Fax: 305-358-2006
+Email: Rblack@royblack.com
+Attorneys for Intervenor Jeffrey Epstein
+22
diff --git a/vision-fixhub/court-02/0a577e374baf485d0cf725a5838afeb580e2a764a3d7982549da04fb386a0250.receipt.json b/vision-fixhub/court-02/0a577e374baf485d0cf725a5838afeb580e2a764a3d7982549da04fb386a0250.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..55ad23ae0c20109d06b486af8fbdf22fcbf301fc
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+++ b/vision-fixhub/court-02/0a577e374baf485d0cf725a5838afeb580e2a764a3d7982549da04fb386a0250.receipt.json
@@ -0,0 +1,14 @@
+{
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+  "engine": "marble-apple-vision",
+  "event_count": 22,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
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+}
diff --git a/vision-fixhub/court-02/0aaf04343818be620ed4e24c2b20e23eb54f8bc6a8d6ade63a11158f5b554ae5.md b/vision-fixhub/court-02/0aaf04343818be620ed4e24c2b20e23eb54f8bc6a8d6ade63a11158f5b554ae5.md
new file mode 100644
index 0000000000000000000000000000000000000000..4dfcda66ee592a1ed6a1da99eae7867cb2dcc470
--- /dev/null
+++ b/vision-fixhub/court-02/0aaf04343818be620ed4e24c2b20e23eb54f8bc6a8d6ade63a11158f5b554ae5.md
@@ -0,0 +1,39 @@
+Case 9:08-cv-80736-KAM Document 361-54 Entered on FLSD Docket 02/10/2016 Page 1 of 2
+
+54
+
+
+Case 9:08-cv-80736-KAM Document 361-54 Entered on FLSD Docket 02/10/2016 Page 2 of 2
+"Ann
+Villafana
+To "Jay Lefkowitz" <JLefkowitz@kirkland.com>
+CC
+boc
+09/16/2007 11:41
+Subject Re: JE negotiations
+AM
+This message has been replied to
+and forwarded t
+Hi Jay -- I looked up some 11th Circuit cases on simple assault and
+found some good language. I also learned that, every moment that
+one is aboard an enclosed civil airplane, they are in the "special
+aircraft jurisdiction of the United States," so the assault charge is
+really a violation of 49 USC 46506, which doesn't change the
+penalties.
+I have drafted up a factual proffer that I would use at the change of
+›lea based upon our brief conversation and the agents' interaction
+with Ms.
+at her home. The agents and I would need to speak
+with Ms. 1
+I briefly to confirm that these
+facts are true. Feel free to make suggestions.
+On an "avoid the press" note, I believe that Mr. Epstein's airplane
+was in Miami on the day of the l
+•telephone call. If he was
+in Miami-Dade County at the time, then I can file the charge in the
+District Court in Miami, which will hopefully cut the press
+coverage significantly. Do you want to check that out?
+I will talk to you later. Thanks.
+< Attachment 'Epstein Plea Proffer.doc' has been archived by user
+CommonStore/IT/Kirkland-Ellis' on "11/26/2007 01:08:17', >>
+US_Atty_Cor_0029
diff --git a/vision-fixhub/court-02/0aaf04343818be620ed4e24c2b20e23eb54f8bc6a8d6ade63a11158f5b554ae5.receipt.json b/vision-fixhub/court-02/0aaf04343818be620ed4e24c2b20e23eb54f8bc6a8d6ade63a11158f5b554ae5.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..6f0f237790df0b586f1dc40396e2b6decfa8269e
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0ae5d45e02c676cf4c19e7643e3969d8a7dc55ebdee8b02e05ae6ad58c67d4f0.md b/vision-fixhub/court-02/0ae5d45e02c676cf4c19e7643e3969d8a7dc55ebdee8b02e05ae6ad58c67d4f0.md
new file mode 100644
index 0000000000000000000000000000000000000000..a4cc91c8d364fc7f75fd7f38b84238bf3495ba12
--- /dev/null
+++ b/vision-fixhub/court-02/0ae5d45e02c676cf4c19e7643e3969d8a7dc55ebdee8b02e05ae6ad58c67d4f0.md
@@ -0,0 +1,86 @@
+Filing # 61593064 E-Filed 09/15/2017 03:26:24 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+L.M., individually,
+individually, and
+Defendants).
+NOTICE OF SERVING EXPERT INTERROGATORIES TO JEFFREY EPSTEIN
+, hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of
+Civil Procedure, Expert Interrogatories numbered 1 through 16 have been directed to JEFFREY
+EPSTEIN, this 15
+_ day of_
+Sept?
+2017.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this
+15
+Sept: 2917.
+NOT
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+IJ.
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/15/2017 03:26:24 PM
+
+
+COUNSEL LIST
+William Chester
+Esquire
+wcblaw@aol.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+Esquire
+staff.efile@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com; Fred@FredHaddadLaw.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+COPY
+2
+
+
+Marc S. Nurik, Esq.
+Law Offices of Marc S. Nurik
+One Broward Boulevard, Suite 700
+Fort Lauderdale, FL 33301
+Phone: 954-745-5849
+Fax: 954-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
+3
diff --git a/vision-fixhub/court-02/0ae5d45e02c676cf4c19e7643e3969d8a7dc55ebdee8b02e05ae6ad58c67d4f0.receipt.json b/vision-fixhub/court-02/0ae5d45e02c676cf4c19e7643e3969d8a7dc55ebdee8b02e05ae6ad58c67d4f0.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..f72826f484245324b4cddd3e6ef642e73da3effd
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b01534fb03cd539dddf7ee98ed8e53e6be4b7925845c906fce5321a21fe4eb2.md b/vision-fixhub/court-02/0b01534fb03cd539dddf7ee98ed8e53e6be4b7925845c906fce5321a21fe4eb2.md
new file mode 100644
index 0000000000000000000000000000000000000000..9c4e5c8130f241ba9550a73fe55586efba100c20
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+++ b/vision-fixhub/court-02/0b01534fb03cd539dddf7ee98ed8e53e6be4b7925845c906fce5321a21fe4eb2.md
@@ -0,0 +1,144 @@
+*** FILED: PALM BEACH COUNTY, FL SHARON R BOCK, CLERK. ***
+Electronically Filed 09/17/2013 10:01:29 AM ET
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+, individually, and
+L.M., individually,
+Defendants).
+COPY
+TO:
+RE-NOTICE OF TAKING DEPOSITION BY VIDEO
+(ONLY CHANGE IS TO REFLECT THAT DEPOSITION IS BY VIDEO)
+All counsel on the attached Counsel List
+PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of:
+NAME AND ADDRESS
+Jeffrey Epstein
+DATE AND TIME
+October 21, 2013
+10:00 a.m.
+LOCATION
+Searcy Denney Scarola
+Barnhart & Shipley, P.A
+upon oral examination before Phipps Reporting, Inc., a Notary Public; or any other officer
+authorized by law to take depositions in the State of Florida. The oral examination is being taken
+for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the
+applicable Statutes or Rules.
+
+
+Case No. 502009CA040800XXXXMBAG
+Notice of Taking Deposition
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 13T
+_ day e
+sept.
+2013.
+Jack Scarola
+Florida Bar No.: 169440
+Primary E-mail:
+jsx@searcylaw.com
+Sceondary E-mail(s): mép@scarcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for Bradley J.
+Cc:
+Phipps Reporting, Inc.
+E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED
+NOT A
+
+
+Case No. 502009CA040800XXXXMBAG
+Notice of Taking Deposition
+Page 3
+"If you are a person with a disability who needs any accommodation in
+order to participate in this proceeding, you are entitled, at no cost to
+you, to the provision of certain assistance. Please contact
+English, Americans with Disabilities Act Coordinator, •
+English,
+at least 7 days before your scheduled court appearance, or immediately
+upon receiving this notification if the time before the scheduled
+appearance is less than 7 days; if you are hearing or voice impaired, call
+711."
+"Si usted
+es una persona minusválida que
+necesita algún
+acomodamiento para poder participar en este procedimiento, usted
+tiene derecho, sin tener gastos propios, a qué se le provea cierta ayuda.
+Tenga la amabilidad de ponerse en contacto con
+English,
+Americans with Disabilities Act Coordinator;
+English, por lo
+menos 7 días antes de la cita fijada para su comparecencia en los
+tribunales, o inmediatamente después de recibir esta notificación si el
+tiempo antes de la comparecencia que se ha programado es menos de 7
+días; si usted tiene discapacitación del oído o de la voz, llame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe
+nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen
+pwovizyon pou jwen kèk èd. Tanpri kontakte
+English,
+Americans with Disabilities Act Coordinator,
+English, nan 7
+jou anvan dat ou gen randevou pou parèt nan tribinal la, oubyen
+imedyatman apre ou fin resevwa konvokasyon an si lè ou gen pou w
+parèt nan tribinal la mwens ke 7 jou; si ou gen pwoblèm pou w tande
+oubyen pale, rele 711."
+
+
+Notice or razing eXAG
+Page 4
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954) 467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+J.
+, Esquire
+staff.efile@pathtojustice.com
+Jaffe, Weissing,
+Fistos &
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+CERTIFI
+Fred Haddad, Esquire
+Dee@FredHaddadL.aw.com;
+haddadfim@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0b01534fb03cd539dddf7ee98ed8e53e6be4b7925845c906fce5321a21fe4eb2.receipt.json b/vision-fixhub/court-02/0b01534fb03cd539dddf7ee98ed8e53e6be4b7925845c906fce5321a21fe4eb2.receipt.json
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@@ -0,0 +1,14 @@
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diff --git a/vision-fixhub/court-02/0b163cf6e7bb69fd8f745421445d2a28d4fc5d47fbe54168734dda0d5662afe3.md b/vision-fixhub/court-02/0b163cf6e7bb69fd8f745421445d2a28d4fc5d47fbe54168734dda0d5662afe3.md
new file mode 100644
index 0000000000000000000000000000000000000000..2b266fd30f73def979ec0251d20e5b4f335ae4b8
--- /dev/null
+++ b/vision-fixhub/court-02/0b163cf6e7bb69fd8f745421445d2a28d4fc5d47fbe54168734dda0d5662afe3.md
@@ -0,0 +1,40 @@
+FILED
+March 04, 2022 25:36 PM
+SI-2021-RV-00005
+TAMARA CHARLES
+CLERK OF THE COURT
+IN THE SUPERIOR COURT OF THE VIRGIN ISLANDS
+DIVISION OF ST.
+AND ST. JOHN
+******************.**..*****..
+IN THE MATTER OF THE ESTATE OF
+JEFFREY E. EPSTEIN,
+Deceased.
+CASE NO: ST-2021-RV-
+00005
+Originating Case No:
+ST-2019-00080
+ORDER
+THIS MATTER is before the Court on the Co-Executors of the Estate of Jeffrey E.
+Epstein, Darren K. Indyke and Richard D. Kahn's Motion for Award of Attorneys' Fees and
+Incorporated Memorandum of Law in Support Thereof. Having considered the Motion, the Court
+will grant the same.
+Accordingly, it is hereby
+ORDERED that the Co-Executors of the Estate of Jeffrey E. Epstein, Darren K. Indyke
+and Richard D. Kahn's Motion for Award of Attorneys' Fees and Incorporated Memorandum of
+Law in Support Thereof is GRANTED; and it is further
+ORDERED that reasonable attorneys' fees in the amount of One Hundred Twelve
+Thousand Two Hundred Sixteen Dollars and Ninety Cents ($112,216.90) is hereby awarded in
+favor of the Co-Executors of the Estate of Jeffrey E. Epstein, Darren K. Indyke and Richard D.
+Kahn and against the Government of the U.S. Virgin Islands; and it is further
+ORDERED that a copy of this Order shall be directed to counsel of record.
+_ 2022
+Dated:
+ATTEST:
+TAMARA CHARLES
+Clerk of the Court
+BY:
+Court Clerk Supervisor
+DEBRA S. WATLINGTON
+Judge of the Superior Court
+of the Virgin Islands
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new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "4fec2646dd5643ef772df49eb0948995c5b16827a8240d31f5c31d9e30d42f34",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b269b0c785e9de4295b00d351b6ef41195e2f77642e56b3c040035c98fd1c32.md b/vision-fixhub/court-02/0b269b0c785e9de4295b00d351b6ef41195e2f77642e56b3c040035c98fd1c32.md
new file mode 100644
index 0000000000000000000000000000000000000000..a91f1808a9d0b578d025e595c2e66490483192ec
--- /dev/null
+++ b/vision-fixhub/court-02/0b269b0c785e9de4295b00d351b6ef41195e2f77642e56b3c040035c98fd1c32.md
@@ -0,0 +1,485 @@
+Filing # 61717726 E-Filed 09/19/2017 03:04:43 PM
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN. individually,
+J.
+, individually, and
+L.M., individually,
+Defendants).
+TO:
+NOTICE OF PRODUCTION FROM NON-PARTY
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+William Chester
+,, Esquire
+wcblaw@aol.com; wcblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+YOU ARE NOTIFIED that after ten (10) days from the date of service of this Notice, if
+service is by delivery, or fifteen (15) days from the date of service, if service is by mail, and if no
+objection is received from any party, the undersigned will issue or apply to the Clerk of this Court
+for issuance of the attached Subpoenas directed to the following individual to produce the items
+listed at the time and place specified in the Subpoena.
+L. Ackerman, Esquire
+Burnett, P.A.
+515 N. Flagler Drive, Suite 2100
+West Palm Beach, FL 33401
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 09/19/2017 03:04:43 PM
+
+
+Notice of Production from Non-Party
+Page 2
+2. Robert D. Critton, Esquire
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+3. Jack A. Goldberger, Esquire
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+4. Roy Black, Esquire
+Black Srebnick Kornspan and Stumpf, P.A.
+201 South Biscayne Boulevard, #1300
+Miami, FL 33131
+COPY
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 19Th
+day of
+Sept.
+NOT A
+Florida Bar No.: 169440
+Attorney E-Mail: isx@searcylaw.com; and
+mmccahn(@searcylaw.com
+Primary E-Mail: _scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: 561-383-9451
+J.
+
+
+Notice of Production from Non-Party
+Page 3
+COUNSEL LIST
+William Chester
+1 Esquire
+wcblaw@aol.com; woblawasst@gmail.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-655-4777
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+Esquire
+staff.efile@pathtojustice.com
+Jatte Weissing
+Lehrman, P.L.
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+Fred@FredHaddadLaw.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+efiling@tonjahaddad.com
+Tonja Haddad, P.A
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+
+
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN. individually,
+i, individually, and
+L.M., individually,
+Defendants).
+COPY
+SUBPOENA DUCES TECUM TO NON-PARTY
+THE STATE OF FLORIDA
+TO:
+L. Ackerman, Esquire
+- Burnett, P.A.
+515 N. Flagler Drive, Suite 2100
+West Palm Beach, FL 33401
+YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A.,
+2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 10, 2017 at 1:00
+p.m. and to have with you at that time and place the following:
+Duces Tecum:
+All documents* regarding your representation of Jeffrey
+Epstein with respeet to any allegation of criminal wrongdoing
+
+
+; adv. Epstein
+Page 2
+*"Documents" shall include, but not be limited to all non-identical copies of writings,
+drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
+compilations from which information can be obtained, translated, if necessary, by the party to
+whom the request is directed through detection devices into reasonably usable form. "Documents"
+also include all electronic data as well as application metadata and system metadata. All
+inventories and rosters of your information technology (IT) systems—e.g., hardware, software and
+data, including but not limited to network drawings, lists of computing devices (servers, PCs,
+laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
+and security tools and protocols.
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney
+whose name appears on this subpoena and thereby eliminate your appearance at the time and place
+specified above. You have the right to object to the production pursuant to this subpoena at any
+time before production by giving written notice to the attorney whose name appears on this
+subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
+1)
+
+
+Case No. 502009CA040800XXXXMBAC
+CERTIFICATION OF RESPONSE TO
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+STATE OF FLORIDA
+COUNTY OF
+The undersigned, as custodian of records for l
+L. Ackerman, Esquire, certifies that
+the attached documents consisting of _
+pages represents a true copy of all items within my
+possession, custody or control which are described in the Subpoena Duces Tecum Without
+Deposition served on me in the above styled action and each page is numbered by me for
+identification. Production is complete and has been numbered by the custodian of records.
+It is further certified that originals of the items produced are maintained under the direction,
+custody and control of the undersigned.
+The foregoing Certification was acknowledged before me, an officer duly authorized in the
+State and County aforesaid to take acknowledgments, this .
+day of_
+→ 2017,
+who:
+is personally known to me; or
+has produced
+as identification; and who:
+did or
+IK
+did not, take an oath,
+and who executed the foregoing certification, and who acknowledged the foregoing certification
+to be freely and voluntarily executed for the purposes therein recited.
+
+
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually, and
+L.M., individually,
+Defendants).
+COPY
+SUBPOENA DUCES TECUM TO NON-PARTY
+THE STATE OF FLORIDA
+TO: Robert D. Critton, Esquire
+303 Banyan Boulevard, Suite 400
+West Palm Beach, FL 33401
+YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A.,
+2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 1:30
+p.m. and to have with you at that time and place the following:
+Duces Tecum:
+*"Documents" shall include, but not be limited to all non-identical copies of writings,
+drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
+
+
+Page 2
+compilations from which information can be obtained, translated, if necessary, by the party to
+whom the request is directed through detection devices into reasonably usable form. "Documents"
+also include all electronic data as well as application metadata and system metadata. All
+inventories and rosters of your information technology (IT) systems—e.g., hardware, software and
+data, including but not limited to network drawings, lists of computing devices (servers, PCs,
+laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
+and security tools and protocols.
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this subpoena on or before the
+scheduled date of production. You may conditión the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney
+whose name appears on this subpoena and thereby eliminate your appearance at the time and place
+specified above. You have the right to object to the production pursuant to this subpoena at any
+time before production by giving written notice to the attorney whose name appears on this
+subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
+1)
+Furnish the records instead of appearing as provided above; or
+Object to this subpoena,
+
+
+You may be in contempt of court. You are subpoenaed to appear by the following attorney, and
+unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena
+as directed.
+DATED this
+Attorney E-Mail(s): jsx@searcylaw.com; and
+mmccann@searcylaw.com
+Primary E-mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+NOT A CER
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+
+
+Ladv. Epstein
+CERTIFICATION OF RESPONSE TO
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+STATE OF FLORIDA
+COUNTY OF
+The undersigned, as custodian of records for Robert D. Critton, Esquire, certifies that the
+attached documents consisting of
+— pages represents a true copy of all items within my
+possession, custody or control which are described in the Subpoena Duces Tecum Without
+Deposition served on me in the above styled action and each page is numbered by me for
+identification. Production is complete and has been numbered by the custodian of records.
+It is further certified that originals of the items produced are maintained under the direction,
+custody and control of the undersigned.
+The foregoing Certification was acknowledged before me, an officer duly authorized in the
+State and County aforesaid to take acknowledgments, this
+_ day of
+_, 2017,
+who:
+[]
+is personally known to me; or
+has produced
+as identification; and who:
+did or
+IK
+did not, take an oath,
+and who executed the foregoing certification, and who acknowledged the foregoing certification
+to be freely and voluntarily executed for the purposes therein recited.
+
+
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+J. m
+, individually, and
+L.M., individually,
+Defendants).
+COPY
+SUBPOENA DUCES TECUM TO NON-PARTY
+THE STATE OF FLORIDA
+TO: Jack A. Goldberger, Esquire
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A.,
+2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 10:30
+a.m. and to have with you at that time and place the following:
+Duces Tecum:
+All documents* regarding your representation of Jeffrey
+Epstein with respect to any allegation of criminal wrongdoing
+against Jeffrey Epstein and any consideration
+involvement in the filing and prosecution of any claim by Jeffrey
+
+
+Page 2
+*'''Documents" shall include, but not be limited to all non-identical copies of writings,
+drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data
+compilations from which information can be obtained, translated, if necessary, by the party to
+whom the request is directed through detection devices into reasonably usable form. "Documents"
+also include all electronic data as well as application metadata and system metadata. All
+inventories and rosters of your information technology (IT) systems- e.g.,hardware, software and
+data, including but not limited to network drawings, lists of computing devices (servers, PCs,
+laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
+and security tools and protocols.
+These items will be inspected and may be copied at that time. You will not be required to
+surender the original items. You may comply with this subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+in advance of the reasonable cost of preparation. You may mail or deliver the copies to the attorney
+whose name appears on this subpoena and thereby eliminate your appearance at the time and place
+time before production by giving written notice to the attorney whose name appears on this
+subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
+
+
+Page 3
+2)
+Furnish the records instead of appearing as provided above; or
+Object to this subpoena,
+You may be in contempt of court. You are subpoenaed to appear by the following attorney, and
+unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena
+as directed.
+DATED
+this
+day of
+_ 2017.
+JACK SCARÓLA
+Florida Bar No.: 169440
+NOT A CER
+Attorney E-Mail(s): jsx@searcylaw.com; and
+ccann@searcylaw.com
+Primary E-mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+
+
+adv. Epstei
+Case No. 502009CA040800XXXXMBA(
+CERTIFICATION OF RESPONSE TO
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+STATE OF FLORIDA
+COUNTY OF
+The undersigned, as custodian of records for Jack A. Goldberger, Esquire, certifies that the
+attached documents consisting of
+— pages represents a true copy of all items within my
+possession, custody or control which are described in the Subpoena Duces Tecum Without
+Deposition served on me in the above styled action and each page is numbered by me for
+identification. Production is complete and has been numbered by the custodian of records.
+It is further certified that originals of the items produced are maintained under the direction,
+custody and control of the undersigned.
+The foregoing Certification was acknowledged before me, an officer duly authorized in the
+State and County aforesaid to take acknowledgments, this
+_ day of
+, 2017,
+who:
+is personally known to me; or
+has produced
+as identification; and who:
+did or
+[K did not, take an oath,
+and who executed the foregoing certification, and who acknowledged the foregoing certification
+to be freely and voluntarily executed for the purposes therein recited.
+
+
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually, and
+L.M., individually,
+Defendants).
+COPY
+SUBPOENA DUCES TECUM TO NON-PARTY
+THE STATE OF FLORIDA
+TO: Roy Black, Esquire
+Black Srebnick Kornspan and Stumpf, P.A.
+201 South Biscayne Boulevard, #1300
+Miami, FL 33131
+YOU ARE COMMANDED to appear at Searcy Denney Scarola Barnhart & Shipley, P.A.,
+2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409 on October 6, 2017 at 3:30
+p.m. and to have with you at that time and place the following:
+Duces Tecum:
+All documents* regarding your representation of Jeffrey
+Epstein with respect to any allegation of criminal wrongdoing
+against Jeffrey Epstein and any consideration of and
+involvement in the filing and prosecution of any claim by Jeffrey
+Epstein against Scott Rothstein and/or
+
+
+Page 2
+*'Documents" shall include, but not be limited to all non-identical copies of writings,
+drawings, graphs,
+charts, photographs, phono-records, recordings, and/or any other data
+compilations from which information can be obtained, translated, if necessary, by the party to
+whom the request is directed through detection devices into reasonably usable form. "Documents"
+also include all electronic data as well as application metadata and system metadata. All
+inventories and rosters of your information technology (IT) systems—e.g., hardware, software and
+data, including but not limited to network drawings, lists of computing devices (servers, PCs,
+laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps
+and security tools and protocols.
+These items will be inspected and may be copied at that time. You will not be required to
+surrender the original items. You may comply with this subpoena by providing legible copies of
+the items to be produced to the attorney whose name appears on this subpoena on or before the
+scheduled date of production. You may condition the preparation of the copies upon the payment
+n advance of the renal cost of repaion. You may mail o dive the cops to the atomey
+whose name appears on this subpoena and thereby eliminate your appearance at the time and place
+specified above. You have the right to object to the production pursuant to this subpoena at any
+time before production by giving written notice to the attorney whose name appears on this
+subpoena. THIS WILL NOT BE A DEPOSITION. NO TESTIMONY WILL BE TAKEN.
+1)
+
+
+5 adv. Epstein
+Page 3
+Furnish the records instead of appearing as provided above; or
+Object to this subpoena,
+You may be in contempt of court. You are subpoenaed to appear by the following attorney, and
+unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena
+as directed.
+DATED
+this
+day of
+_, 2017.
+JACK SCARØLA
+Florida Bar No.: 169440
+NOT A CER
+Attorney E-Mail(s): jsx@searcylaw.com; and
+Iccann
+@searcyla
+w.com
+Primary E-mail: _scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+
+
+s adv. Epstein
+CERTIFICATION OF RESPONSE TO
+SUBPOENA DUCES TECUM WITHOUT DEPOSITION
+STATE OF FLORIDA
+COUNTY OF
+The undersigned, as custodian of records for Roy Black, Esquire, certifies that the attached
+documents consisting of _
+- pages represents a true copy of all items within my possession,
+custody or control which are described in the Subpoena Duces Tecum Without Deposition served
+on me in the above styled action and each page is numbered by me for identification. Production
+is complete and has been numbered by the custodian of records.
+It is further certified that originals of the items produced are maintained under the direction,
+custody and control of the undersigned
+The foregoing Certification was acknowledged before me, an officer duly authorized in the
+State and County aforesaid to take acknowledgments, this
+_day of.
+, 2017,
+who:
+is personally known to me; or
+has produced
+as identification; and who:
+[]
+did or
+IK
+did not, take an oath,
+and who executed the foregoing certification, and who acknowledged the foregoing certification
+to be freely and voluntarily executed for the purposes therein recited.
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0b269b0c785e9de4295b00d351b6ef41195e2f77642e56b3c040035c98fd1c32.receipt.json b/vision-fixhub/court-02/0b269b0c785e9de4295b00d351b6ef41195e2f77642e56b3c040035c98fd1c32.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..06bec23f46ecb28d85dff199a775ce2efed28a8f
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diff --git a/vision-fixhub/court-02/0b2f8519d57e03165d9c73a6fd6e8425de7178c663e29f8ba305be2bd26b76f1.md b/vision-fixhub/court-02/0b2f8519d57e03165d9c73a6fd6e8425de7178c663e29f8ba305be2bd26b76f1.md
new file mode 100644
index 0000000000000000000000000000000000000000..28bbe2cc2360631ccacbb8393999248363b7810d
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@@ -0,0 +1,33 @@
+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA
+IN AND FOR PALM BEACH COUNTY
+CIVIL DIVISION
+CASE NO.: 502009CA040800 AG
+JEFFREY EPSTEIN,
+Plaintiffs),
+VS.
+SCOTT ROTHSTEIN, etc., et al.,
+Defendants).
+SHARON R. BOCK. CLERK
+2011 NOV 21 PM 3:52
+FILED
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S
+MOTION TO DISMISS AMENDED COUNTERCLAIM
+THIS CAUSE having come before the Court upon the Plaintiff/Counter-
+Defendant, JEFFREY EPSTEIN's Motion to Dismiss Amended Counterclaim, and the Court
+having heard argument of counsel, and being otherwise fully advised in the premises, it is
+hereby
+CONSIDERED, ORDERED AND ADJUDGED that the Motion is granted with
+leave to amend within twenty (20) days. The Counter-Plaintiff shall set forth with more
+specificity the alleged improper or perverted use of process and ulterior motive or
+purposes. Count Il fails to allege a specific bona fide termination of prior prosecution and
+also incorporates all previous allegations.
+CIRCUIT COURT JUDGE
+Copy furnished:
+JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409
+L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901
+Point West, West Palm
+Beach, FL 33401
+JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401
+MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301
+GARY M.
+JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301
diff --git a/vision-fixhub/court-02/0b2f8519d57e03165d9c73a6fd6e8425de7178c663e29f8ba305be2bd26b76f1.receipt.json b/vision-fixhub/court-02/0b2f8519d57e03165d9c73a6fd6e8425de7178c663e29f8ba305be2bd26b76f1.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..97efa91ab238ac55fa0da303c05c047a95e31eea
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+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "8f206f7a12956331894f73cf9b24b38c41ec819f6b5ce063f8e476280cca8692",
+  "output_sha256": "a483146c831128562f4c4b2e6196634f08af4f7dc8bc9f29c8b0043229591ba7",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.md b/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.md
new file mode 100644
index 0000000000000000000000000000000000000000..a7084baebbe3e3dc05509fd633a487e9ee0dd2b5
--- /dev/null
+++ b/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.md
@@ -0,0 +1,613 @@
+IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CIVIL DIVISION
+CASE NO. 502009CA040800XXXXMBAG
+Judge David F.
+JEFFREY EPSTEIN,
+Plaintiff,
+v.
+SCOTT ROTHSTEIN, individually,
+J.
+individually,
+Defendants.
+20!1 FEB -8
+PH 1: 28
+MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE
+WAIVED
+Plaintiff/Counter-Defendant, Jeffrey Epstein, (Plaintiff or Epstein") by and through his
+undersigned counsel files this his Motion to Compel; in the alternative, Motion to Determine that
+Privilege Claims of
+J. Edwards, ("Edwards") are waived. The grounds for this Motion
+are as follows:
+On April 12, 2010, the Plaintiff served a Request to Produce to Defendant
+A copy of the Request to Produce i
+"1" to this motion.
+2.
+On May 11, 2010, counsel for
+Produce. A copy of
+filed his Response to Plaintiff's Request to
+Response to the Request to Produce is attached as Exhibit "2".
+3.
+The Plaintiff asks the Court to note that these were requests for documents in
+Defendant
+possession or control as opposed to those documents or records in the
+possession or control of the bankruptcy trustee.
+4.
+Paragraph 4 requests all emails, correspondence, etc. by and between Mr.
+Rothstein and Mr.
+on the one hand and several of their investigators relating to Mr.
+BURNETT P.A. • 90l
+| POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 - (561) 802-9044
+
+
+CASE NO. S02009CA040800XXXXMBAG
+Epstein's case. Objections were filed based on work product and/or attorney-client privilege; and
+to date, no privilege log has been filed.
+Paragraph 6 requested fee sharing agreements between Mr.
+RRA and/or
+Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance
+and other non-privilege grounds. Paragraph 31 of the Complaint demonstrates that these records
+are relevant. Moreover, in addition, the Defendant
+has a counterclaim that seeks
+damages for among other things his reputation, interference in professional relationships, loss of
+value of time required to be diverted from his professional responsibilities. The compensation
+relationship by and between Mr.
+and/or RRA are relevant to that issue and should be
+produced.
+6.
+Mr. Epstein. Defendant
+Paragraph 9 asks for costs or payment, of costs made by the Rothstein firm against
+response is based on relevance and not on any claim of
+privilege. The Requests are relevant based on the allegations in Paragraphs 10, 13, 14 and 31 of
+the Complaint.
+7.
+Paragraph V0 of the Request is similar to Paragraph 9 in that it requests
+documentation pertaining to any liens for any attorney's fees or costs asserted by the trustee for
+RRA. Thé objection is based on relevance. Paragraphs 10, 13, 14 and 31 of the Complaint
+shows that the allegation is relevant.
+8.
+Paragraph 17 seeks documents supporting the contention made by the Plaintiff for
+alleged sexual assaults on airplanes. Defendant
+objects on several non-privilege
+grounds which include relevance, vague, over broad, etc. See Paragraphs 34-36 of the
+Complaint where this is a material part of the Plaintiffs abuse of process claim.
+- 2-
+BURNETT P.A. • 901
+POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 - (561) 802-9044
+
+
+CASE NO. 502009CA040800XXXXMBAG
+Paragraph 18 seeks records similar to those described in Paragraphs 9 and 10.
+Defendant
+has not made a privilege claim. The documents are relevant. See the
+allegations in Paragraphs 10, 13, 14 and 31 of the Complaint.
+10.
+Paragraph 20 seeks the foundation for statements made to the court in one of the
+pending cases. The objection is based on work product for which no privilege log has been
+provided. Objections of vagueness and over broad have also been lodged.
+11. Paragraph 21 seeks documents relating to potential deponents named by
+in each of the three (3) cases against Mr. Epstein. The objections include work product and
+attorney-client privilege for which no privilege log has been prepared. The documents are
+relevant based on the allegations contained in Paragraphs 38-41 of the Complaint and should be
+produced.
+12. Paragraph 22 seeks documents supporting Mr.
+claim for damages with a
+response of not yet determined. Plaintiff Epstein cannot formulate a defense to such a claim in
+absence of those damages and requests an order compelling the production of those records.
+13.
+Paragraph 24 seeks emails exchanged between Mr.
+and a number of
+named individuals relating to Mr. Epstein. The objections are based on attorney-client work
+product privilege and no privilege log has been prepared.
+Under the case of TIG Insurance Corporation of America v.
+799 So. 2d
+339 (Fla. 4" DCA 2001) and its progeny, states that the failure to timely provide a privilege log
+may be grounds to determine that a waiver of privileges have occurred. Given the extraordinary
+passage of time without the preparation of privilege log, the Plaintiff submits those privileges
+have been waived.
+BURNETT P.A. * 901
+- 3-
+POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 - (561) 802-9044
+
+
+CASE NO. 502009CA040800XXXXMBAG
+15. The Plaintiff submits that the discovery request are reasonable, relevant and
+calculated to lead to other discoverable and admissible evidence.
+16.
+The undersigned counsel certifies that this motion is made in good faith and not
+for the purpose of delay.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this
+4 day of February, 2011 to Mare S. Nurik, Esq, One Fast Broward Boule vard, Suite 700,
+Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard
+P.O. Drawer 3626, West Palm Beach, FL 33409.
+Losin to chan .
+Fla. Bar No. 235954
+BURNETT, P.A.
+Point West
+177 South Flagler Drive
+West Palm Beach, Florida 33401
+Telephone: (561) 802-9044
+Facsimile:
+(561) 802-9976
+W:180743IMTNCPL.75-MOTION TO COMPELMOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED-/LA doex
+- 4-
+BURNETT P.A. * 901
+PoINT WEST, 777 SoUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044
+
+
+:
+Divery,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL: CIRCUIT,
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+Complex Litigation, Fla. R. Civ.
+Pro. 1201
+Case No. 50 2009CA040800XXXXMB
+JEFFREY EPSTEIN
+Plaintiff,
+V.
+SCOTT ROTHSTEIN. individually,
+individually, and L.M., individually,
+Defendants.
+EPSTEIN'S REQUEST TO PRODUCE TO
+Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Fla. R. Civ. P. 1.350,
+requests that Defendant,
+J.
+1), produce or make
+available for inspection documents responsive to the requests below within thirty (30)
+days from the date of service:
+DEFINITIONS AND INSTRUCTIONS
+A.
+"Document" means any written or graphic matter or other means of
+preserving thought or expression, and all tangible things from which information can be
+processed or transcribed, including the originals and all non-identical copies, whether
+different from the original by reason of any notation made on such copy or otherwise,
+including, but not limited to, correspondence, memoranda, notes, messages, letters,
+purchase orders, telegrams, teletype, telefax bulletins, e-mails, electronic data,
+meetings, reports, or other communications, interoffice and intra-office telephone calls,
+diaries,
+chronological data, minutes, books, reports, charts, ledgers, invoices,
+worksheets, receipts, returns, trade information regarding fabric, carpets, samples
+
+
+
+etc... computer printouts, prospectuses, financial statements, schedules, affidavits,
+contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper
+articles, releases (and any and all drafts, alterations and modifications, changes and
+amendments of any of the foregoing), graphs or aural records or representations of any
+kind, including, without limitation, photographs, charts, graphs, microfiche, mierofilm,
+video tape, recordings, motion pictures and electronic, mechanical or electric recordings
+or representations of any kind (including, without limitation, tapes, cassettes, discs and
+recordings), and including the file and file cover.
+The term "Document" also means any and all computer records, data, files,
+directories, electronic mail, and information of whatever kind whether printed out or
+stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or
+magnetic-optical disk, computer memory, hard drive, zip drive, jaz drive, orb drive,
+microdisk, external memory stick, software, or any other fixed or removable storage
+media, including without limitation, all back-up copies, dormant or remnant files, and any
+and all miscellaneous files and/or file fragments, regardless of the media on which they
+reside and regardless of whether the data consists in an active file, deleted file, or file
+fragment.
+"Communications" means any oral or written statement, dialogue,
+colloquialism, discussion, conversation or agreement.
+C.
+"Plaintiff" means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County
+Case #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach
+County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein,
+United States District Court Case #08-civ-80893-Marra/.
+D, and any other
+person who is or was represented by Rothstein Rosenfeldt & Adier that has not
+2
+
+
+:
+yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for
+any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her
+authority and control.
+D. "RRA" means Rothstein Rosenfeldt & Adler, P.A.
+E. "Money" means any tangible thing of value.
+F. "Costs" include, but are not limited to, court costs, filing fees, Sheriff's
+service and any other necessary service of legal papers or notices or subpoenas, court
+reporters' charges, long distance telephone charges, postage, courier services or
+Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes,
+Westlaw computerized research, travel expenses, and witness fees and expert witness
+fees and costs.
+G.
+"Trustee" means Herbert Stettin as bankruptcy trustee for RRA.
+REQUEST FOR PRODUCTION
+For the time period from March 1, 2009 to present, any and all documents
+between, or on behalf of RRA, its employees or agents or clients, and any third party
+regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA
+client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA
+client or Plaintiff, (whether existing clients or fabricated clients), including but not limited
+to:
+a.
+b.
+C.
+d.
+e.
+Documents indicating that litigation with Jeffrey Epstein has been
+settled;
+Soliciting or receiving money in return for settlement funds allegedly
+paid or to be paid by Jeffrey Epstein;
+Soliciting money to help finance ongoing litigation against Jeffrey
+Epstein;
+Soliciting money to be given to, or used on behalf of, the Plaintiffs
+in litigation against Jeffrey Epstein;
+Communication between third party investors or potential investors
+and the Plaintiffs or their attorneys involved in litigation against
+• Due to the potential volume of documents Involved, the partles and the Court should consider
+appointment of a special
+and/or an In camera inspection to address any objections, claims of
+privilege and generally manage the production of documents.
+3
+
+
+2.
+following:
+Jeffrey Epstein;
+f.
+Payments made by RRA to or on behalf of any Plaintiff.
+Any and all fee agreements that exist or have existed between the
+a.
+Any Plaintiff and
+J.
+has been associated;
+Any Plaintiff and the law firm RRA.
+or any entity with which he
+b.
+J.
+All emails, data, correspondence, memos, or similar documents betwee
+, Scott W. Rothstein, William Berger and
+attorney or representative of RRA and any investor or third party (pérson or entity)
+regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten,
+Kenneth Jenne,
+or Rick (Rich) Fandrey).
+All emails, data, correspondence, memos, or similar documents between
+J.
+Scott W. Rothstein, and/or any attorney or representative of RRA
+regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten,
+Kenneth Jenne,
+or Rick (Rich) Fandrey).
+All agreements or documents of any nature which were provided to or
+received from an investor or potential investor relating to any case (real or fabricated)
+involving Jeffrey Epstein and any of the following:
+a.
+b.
+C.
+e.
+Scott W. Rothstein
+J
+RRA
+any entity formed by RRA or
+J.
+or Scott W.
+Rothstein to create investment opportunities
+for third party
+investors to invest in any plaintiff's case against Jeffrey Epstein
+6.
+All fee sharing agreements between
+J.
+1, RRA, or Scott
+W. Rothstein and/or any other attorney or investor relating to any aspect of any
+Plaintiff's case.
+Bradley JI
+All documents made available to any investor or potential investor by
+1, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to
+solicit "investors" for any case involving Jeffrey Epstein.
+All document reflecting the names and addresses of all individuals or
+entities who invested or purported to invest in any aspect of any case against Jeffrey
+Epstein.
+All documents evidencing the Costs and payment of any bill or Costs in
+each Plaintiff's case against Jeffrey Epstein, and the source(s) for said payments of any
+Costs.
+4
+
+
+All documents received by you or your current firm wherein the Trustee of
+RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs
+incurred related to the Plaintiffs' cases during the time Plaintiffs' were represented by
+All documents and tangible things retrieved from the trash at 358 El Brillo
+Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein.
+All conversations recorded from any telephones which purported to be that
+of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives,
+hard drives or any other electronic format and any written transcriptions).
+from Jeffrey Epsteins attorneys indeeding Ray telephone bie perior or to be
+Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard
+drives or any other electronic format and any written transcriptions).
+All intercepted phone conversations authorized by RRA including but not
+limited to any one of its attomeys or investigators or anyone retained by or working for
+RRA related to Jeffrey Epstein that are saved or stored in any media (audio tapes, CDs,
+DVDs, zip drives, hard drives or any other electronic format and any written
+transcriptions).
+Epstein authol in by pted on aig ed not nice a anne of or to eter
+investigators or anyone retained by or working for RRA.
+All intercepted or acquired electronic mail (e-mails) to and from the
+attorneys for Jeffrey Epstein Including but not limited to: Roy Black, Alan Dershowitz or
+Jack Goldberger, authorized by RRA including but not limited to any one of its attorneys
+or investigators or anyone retained by or working for RRA.
+All documents related to the amount of all Costs that were incurred by you
+in the representation of you and/or your law firm in representing Jane Doe, L.M. and
+E.W. prior to joining RRA.
+Il documents setting forth to the amount of Costs were incurred by RR
+its representation of Jane Doe, L.M. and E.W. during the time you were employed b
+RRA (or that is being claimed by the Trustee).
+20.
+In the attached transcript dated July 31, 2009, you stated to Judge Hafele
+with regard to the E.W. and L.M. cases the following:
+5
+
+
+"What the evidence is really going to show is that Mr. Epstein - at
+least dating back as far as our investigation resources have permitted,
+back to 1997 or '98 - has every single day of his life, made an attempt to
+sexually abuse children.
+We're not talking about five, we're not talking about 20, we're not
+talking about 100, we're not talking about 400, which I believe, is the
+number known to law enforcement, we are talking about thousands of
+children, and it is through a very intricate and complicated system that he
+devised where he has as many as 20 people working underneath him that
+he is paying well to schedule these appointments, to locate these girls."
+(A) Provide all documents to support this assertion including any
+documents which are the source of the information.
+21:
+All documents related to or mentioning potential deponents in the Jane
+Doe, L.M. or E.W. cases.
+22.
+All documents that support your claim of damages in your counterclaim in
+this case.
+representation of you th this case.
+The written fee agreement with the Searcy Denney fir for their
+All emails exchanged between you (or anyone of your behalf and one or
+more of the olling individuals wherein Epstein, a Palm Beach bilionaire or a similar
+a.
+b.
+Scoft Rothstein
+Adler
+Willam Berger
+d
+e.
+f.
+g.
+h.
+i.
+Michael Fisten
+Kenneth Jenne
+David Boden
+Deborah |
+Andrew Barnett
+Richard (Rick) Fandrey
+Christina Kitterman.
+25.
+A copy of your RRA business card.
+Any employment agreements, letter agreements or memos given to yo
+y RRA or a representative or agent of RRA describing your compensation and benefi
+at RRA.
+6
+
+
+Truete Tor RA, assuming and gamericationes from Herbert Statin, as bankruptcy
+a.
+b.
+c.
+L.M. v. Epstein, Case No. 502008CA028051XXXXMB
+E.W. v. Epstein, Case No. 502008CA028058XXXXMB
+Jane Doe v. Epstein, Case No. 08-CV-80119-MARRA/
+Certificate of Service
+I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S.
+Mail to the following addressees on this 12th day of _ April
+_. 2010:
+Gary M.
+, Jr., Esq.
+Jack Alan Goldberger, Esq
+1, Jaffe, Weissing,
+- Fistos
+Atterbury Goldberger & Weiss, P.A
+& Lehrman, PL
+250 Australian Avenue South
+425 N. Andrews Avenue, Suite 2
+Suite 1400
+Fort Lauderdale, FL 33301
+West Palm Beach, FL 33401-5012
+954-524-2820
+Fax: 561-835-8691
+954-524-2822 - fax
+Co-Counsel for Defendant Jeffrey Epstein
+Attorneys for Defendant, L.M.
+Jack Scarola, Esq.
+MARC S. NURIK, ESQ.
+Searcy
+Denney Scarola Barnhart
+& Law Offices of Marc S. Nurik
+Shipley, P.A
+One East Broward Boulevard
+2139 Palm Beach Lakes Bivd.
+Suite 700
+West Palm Beach, FL 33409/
+Fort Lauderdale, FL 33301
+686-6300
+954-745-5849
+383-9424 F
+954-745-3556 Fax
+Attomeys for Defendant
+Attorneys for Defendant Scott Rothstein
+BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
+303 Banyan Boulevard
+Suite 400
+NOT
+Robert D.'Critton, Jr
+Florida Bar #224162
+Michael J. Pike
+Florida Bar #617296
+(Counsel for Defendant Jeffrey Epstein)
+7
+
+
+01/11/2010 15:50 FAX 5616845816
+2002/003
+JEFFREY EPSTEIN,
+Plaintiff,
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+COPY
+vs.
+SCOTT ROTHSTEIN. individually,
+, Individually,
+and L.M., Individually,
+Defendant.
+DEFENDANT
+RESPONSE TO PLAINTIFF'S REQUEST
+FOR PRODUCTION DATED APRIL 12, 2010
+Defendant,
+J. EDWARDS, hereby files his Response to Request for
+Productlon propounded by Plaintiff on April 12, 2010 as follows:
+None.
+2.
+3.
+14.
+a.
+Objection, relevance, not reasonably calculated to lead to th
+liscovery of admissible evidence
+b.
+None.
+protected by the ok prudid and or to men lint prigators as that ls
+bjection; any such communications are protected by the work-produc
+ind /or altorney-client privileg.
+5.
+None.
+Objection, relevance, not reasonably calculated to lead to the
+objection, there are no lee agreemen is with ny inveeto, without walving
+
+"2"
+
+
+05/11/2010 16:59 FAX 5618845818
+SEARCY DENNEX
+@002/005
+Case No: 502008CA040800XXXXMBAG
+Response to Request for Production dated 4/12/10
+7.
+None.
+8.
+None.
+Objection, relevance, not reasonably calculate
+Noad to
+Iscovery of admissible evidence
+10.
+Objection, relevance,
+not reasonably calculated
+to lead to the
+discovery of admissible evidence.
+11.
+None.
+12.
+None.
+13.
+None.
+14.
+None.
+15.
+None.
+16.
+None.
+17.
+Oblection,
+relevance, not reasonably calculated to lead to the
+ERTIFIED
+discovery of admissible evidence; vague; overbroad, ambiguous.
+18.
+Objection,
+discovery oradmissile event.
+reasonably calculated to lead to the
+19.
+Objection,
+Cheevery or admile evidence and protected dy to work product
+20.
+21.
+22.
+bjection, vague overbroad and any and all such documents ar
+rotected by the work-product privilege
+protected by the work proud and tone steri such documents are
+Not yet determined.
+2
+
+
+05/11/2010 18:00 FAX 6616845616
+SBARCY DENNEY
+@003/005
+Response to Request for Production dated 4/12/10
+23.
+Objection.
+24.
+Objection; attorney-client privilege and/or work-product privllege,
+25.
+None in Defendant's possession.
+26. None.
+27. None in Defendant's possession.
+NOT A CERTIFIED COP
+
+
+05/11/2010 16:00 FAX 8616845816
+@004/005
+Case No.: 502009CA040800XXXXMBAG
+Response to Request for Production dated 4/12/10
+CERTIFICATE OF SERVICE
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been
+fumished via U.S. Mail to all counsel on the attached list on 77. I 2010.
+Searcy Droney Scarola Bahart&s Shipley, P. A
+Attorneys for Defendant,
+2139 Palm Beach Lakes boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9461
+By:
+Jack Scapola
+Falcon
+Florida Bar No: 169440
+NOT A
+NOT A CER
+4
+EFT A02769385
+
+05/11/2010 10:00 FAX 5816845816
+@005/005
+Case No: 502009CA040800XXXXMBAG
+Response to Request for Production dated 4/12/10
+COUNSEL LIST
+Robert D. Critton, Jr., Esquire
+Michael J. Pike, Esquire
+Burman, Critton, Luttier & Coleman LLF
+303 Banyan Boulevard, Sulte 400
+West Palm Beach, FL 33401
+Phone: (561)-842-2820
+Fax: (561)-844-6929
+Attorneys for Jeffrey Epstein
+COPY
+Jack Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue South
+Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+GAL M.
+Fistos & Lehrman, P.L.
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954) 524-2820
+Fax: (954) 524-2822
+CERTIFIED
+Attorneys for L.My
+Marc Nurik
+Law Offices of Maro S. Nurik
+One East Broward Boulevard, Suite 700
+Phone uderdals 545-504
+954-745-5849
+Fax: 954-745-3556
+Counsel for Scott Rothstein
+5
+EFT A02769386
\ No newline at end of file
diff --git a/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.receipt.json b/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..c46e2aeabf07849a8ccbbd3d67857370452089bf
--- /dev/null
+++ b/vision-fixhub/court-02/0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -299,
+  "dataset": "marble-joined",
+  "doc_id": "0b4a11d2f223fdcde54dfc93d53caa175388754c93bf70e2a801aeaf716aae4d",
+  "engine": "marble-apple-vision",
+  "event_count": 17,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\", \"swarm.running-headers\"]",
+  "idempotent": true,
+  "input_sha256": "b4cfcf4bcd02fe48334e4cc37eaf1d2bd41ec237112a8f5f976c18d43275197d",
+  "output_sha256": "49b20c68c1c095d57f89e0d41dc9cc5146bcaf9085ceb0ee7d1cfcb790e6308c",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.md b/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.md
new file mode 100644
index 0000000000000000000000000000000000000000..2867e00494fa97902e702c733dedf84e7bf05960
--- /dev/null
+++ b/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.md
@@ -0,0 +1,83 @@
+Electronically Filed 10/02/2013 11:56:10 AM ET
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually,
+Defendant/Counter-Plaintiff.
+Case No. 50 2009 CA 040800XXXXMBAG
+NOTICE OF FILING EXHIBITS
+Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned
+counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby
+files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for
+Summary Judgment on Defendant/Counter-Plaintiff
+Fourth
+Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously
+filed and accepted by the Palm Beach County, Florida Civil Division Filing # 5846906.
+The files accompanying this Notice of Filing Exhibits were previously filed on September
+26, 2013 at 8:56PM, but moved to Pending Queue, Filing Reference Number: # 584968.
+The attached exhibits follow in order of their attachment to the Motion in compliance with
+Rule 2.516 of the Florida Rules of Judicial Administration as to the size of files served on
+opposing counsel. The start of each new exhibit is marked on the bottom of the first page
+of said exhibit.
+
+
+Epstein v. Rothstein, et al.
+WE HEREBY CERTIFY that a true and correct copy of the foregoing was
+served, via electronic service, to all parties on the attached service list, this October
+2, 2013.
+Is/ Tonja Haddad Coleman
+Tonja Haddad Coleman, Esq.
+Florida Bar No.: 176737
+Tonja Haddad, PA
+5315 SE 7* Street
+Suite 301
+Fort Lauderdale, Florida 33301
+954.337.3716 (facsimile)
+2
+
+
+Epstein v. Rothstein, et al.
+SERVICE LIST
+CASE NO. 502009CA040800XXXXMBAG
+Jack Scarola, Esq.
+ix(@searcylaw.com; mep@searcylaw.co
+earcy Denney Scarola et a
+2139 Palm Beach Lakes Blvd.
+West Palm Beach. FL 33409
+Jack Goldberger, Esq.
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+Suite 1400
+West Palm Beach, FL 33401
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+J.
+Esq.
+brad@pathtojustice.com
+Jaffe Weissing
+425 N Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301
+ERTIFIED
+Fistos Lehrman
+Fred Haddad, Esq.
+Dee@FredHaddadLaw.com
+1 Financial Plaza
+Suite 2612
+Fort Lauderdale, FL 33301
+Tonja Haddad Coleman, Esquire
+Tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Law Offices of Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Attorneys for Jeffrey Epstein
+COPY
+3
diff --git a/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.receipt.json b/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..2a9bc0aafcdf364c85c67620c1b6eff9f6e6de29
--- /dev/null
+++ b/vision-fixhub/court-02/0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -36,
+  "dataset": "marble-joined",
+  "doc_id": "0b5afcf986ed451c5dc732e49c26cd84ef8b6739f67ed667686016c7090f583f",
+  "engine": "marble-apple-vision",
+  "event_count": 3,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "969465fbb218ab6fd8d1576a5e8e68cb81768e7c679fce9d8eb5595a963e2e85",
+  "output_sha256": "ba12b1bbf9fe63c7ac4c62bf656210941f93d848a17a175212f015d937f46e24",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.md b/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.md
new file mode 100644
index 0000000000000000000000000000000000000000..17d5610566664ec2637c3126e7da5974c014d2fa
--- /dev/null
+++ b/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.md
@@ -0,0 +1,148 @@
+Filing # 74525512 E-Filed 07/05/2018 03:54:19 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff/Counter-Defendant,
+v.
+COPY
+SCOTT ROTHSTEIN, individually, and
+, individually,
+Defendants/Counter-Plaintiff.
+RE-NOTICE OF UMC HEARING
+(Cancels July 10, 2018, hearing)
+PLEASE TAKE NOTICE that Plaintiff, Jeffrey Epstein, will call up the following hearing
+at the time stated below, before the Honorable Donald W. Hafele, in Circuit Court at the Palm
+Beach County Courthouse, 205 North Dixie Highway, Courtroom 10D, West Palm Beach, Florida
+33401:
+MOTION: Defendant Scott Rothstein's
+Motion to Dismiss Second Amended
+Complaint
+DATE:
+TIME:
+July 23, 2018
+8:45 a.m. (UMC)
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 07/05/2018 03:54:19 PM
+
+
+LOCAL RULE 4 CERTIFICATION
+Movant's attorney has spoken in person or by telephone with the attorney(s) for
+Il parties who may be affected by the relief sought in the motion in a good-fait
+fort to resolve or narrow the issues raised
+Movant's attorney has attempted to speak in person or by telephone with the
+torney(s) for all parties who may be affected by the relief sought in the motion
+lovant's counsel also communicated by e-mail to attempt to resolve this matter
+One or more of the parties
+who may be affected by the motion are self
+represented.
+CERTIFICATE OF SERVICE
+I certify that the foregoing document has been furnished to the attorneys listed on the
+Service List below on July 5, 2018, through the Court's e-filing portal pursuant to Florida Rule of
+Judicial Administration 2.516(b)(1).
+LINK & ROCKENBACH, PA
+1555 Palm Beach Lakes Boulevard, Suite 930
+West Palm Beach, Florida 33401
+(561) 847-4408; (561) 855-2891 [fax]
+By: /s/ Scott J. Link
+Scott J. Link (FBN 602991)
+Kara Berard Rockenbach (FBN 44903)
+Primary: Scott@linkrocklaw.com
+Primary: Kara@linkrocklaw.com
+Secondary: Tina@linkrocklaw.com
+Secondary: Troy@linkrocklaw.com
+NOT A
+Trial Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+2
+
+
+Jack Scarola
+Karen E. Terry
+David P. Vitale, Jr.
+Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+mep@searcylaw.com
+jsx@searcylaw.com
+dvitale@searcylaw.com
+scarolateam@searcylaw.com
+terryteam@scarcylaw.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+SERVICE LIST
+Philip M. Burlington
+Nichole J. Segal
+Burlington & Rockenbach, P.A.
+Courthouse Commons, Suite 350
+444 West Railroad Avenue
+West Palm Beach, FL 33401
+pmb@FLAppellateLaw.com
+njs@FLAppellateLaw.com
+kbt@FLAppellateLaw.com
+insel for Defendant/Counter-Plaintiff
+J. Edwards
+Pottinger LLC
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301-3268
+brad@epllc.com
+Co-Counsel for Defendant/Counter-Plaintiff
+J.
+Jack A. Goldberger
+Atterbury, Goldberger & Weiss, P.A.
+250 Australian Avenue S., Suite 1400~
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+smahoney@agwpa.com
+Co-Counsel for Plaintiff/Counter-Defendant
+Jeffrey Epstein
+NOT
+Nurik
+fices of Marc S. Nurik
+One E. Broward Boulevard, Suite 700
+Ft. Lauderdale, FL 33301
+marc@nuriklaw.com
+Counsel for Defendant Scott Rothstein
+Paul Cassell
+383 S. University
+Salt Lake City, UT 84112-0730
+cassellp@law.utah.edu
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+Jay Howell
+Jay Howell & Associates
+644 Cesery Blvd., Suite 250
+Jacksonville, FL 32211
+jayhowell.com
+Limited Intervenor Co-Counsel for L.M., E.W.
+and Jane Doe
+3
+
+
+This notice is provided pursuant to Administrative Order No. 2.207-1/15:
+"If you are a person with a disability who needs any accommodation in order to
+participate in this proceeding, you are entitled, at no cost to you, to the
+provision of certain assistance. Please contact Tammy Anton, Americans with
+Disabilities Act Coordinator, Palm Beach County Courthouse, 205 North Dixie
+Highway West Palm Beach, Florida 33401; telephone number (561) 355-4380
+at least 7 days before your scheduled court appearance, or immediately
+upon receiving this notification if the time before the scheduled appearance is less
+than 7 days; if you are hearing or voice impaired, call 711."
+"Si usted es una persona minusválida que necesita algun acomodamiento para
+poder participar en este procedimiento, usted tiene derecho, sin tener gastos
+propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en
+contacto con Tammy Anton, 205 N. Dixie Highway, West Palm Beach, Florida
+33401; telefono numero (561) 355-4380, por lo menos 7 dias antes de la cita
+fijada para su comparecencia en los tribunales, o inmediatamente despues de
+recibir esta notificacion si el tiempo antes de la comparecencia que se ha
+programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la
+voz, lame al 711."
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan
+pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou
+jwen kek ed. Tanpri kontakte Tammy Anton, koodonate pwogram Lwa pou
+ameriken ki Enfim yo nan Tribinal Konte Palm Beach la ki nan 205 North Dixie
+Highway, West Palm Beach, Florida 33401; telefon li se (561) 355-4380 nan 7
+jou anvan dat ou gen randevou pou paret nan tribinal la, oubyen imedyatman
+apre ou fin resevwa konvokasyon an si le ou gen pou w paret nan tribinal la
+mwens ke 7 jou; si ou gen pwoblem pou w tande oubyen pale, rele 711."
+4
diff --git a/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.receipt.json b/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..d708495a51bf8cbd6e439c129b35afce4f289054
--- /dev/null
+++ b/vision-fixhub/court-02/0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -48,
+  "dataset": "marble-joined",
+  "doc_id": "0b7bfcab86c07ce142b427ca6d449278d90cfdb4ce596625f151beaa3d952146",
+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\"]",
+  "idempotent": true,
+  "input_sha256": "f44b6d1366af97b17fcd23929949f85ed7c6d39ecc89ed7ebb3b96ca3daa7c00",
+  "output_sha256": "2c867dec23791d370a8a5dd43e1c21c206661de459e04156a6928da595397bc5",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.md b/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.md
new file mode 100644
index 0000000000000000000000000000000000000000..72c2a59020fd5704a1d2ff36aa757c97355fcccb
--- /dev/null
+++ b/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.md
@@ -0,0 +1,394 @@
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 1 of 7
+P-014924
+P-014925
+thru
+P-014927
+P-014928
+P-014929
+thru
+P-014933
+P-014934
+thru
+P-014935
+P-014936
+thru
+P-014940
+JANE DOE V. UNITED STATES
+COURT FILE NO. 08-80736-CV-MARRA
+THIRD SUPPLEMENTAL PRIVILEGE LOG - BOX #5
+Description
+5/27/2008 emails between A.M. Villafaña and K. Atkinson regarding
+report of new state plea deal for J. Epstein
+› review and revise updated indictment package
+5/23/2008-5/27/2008 emails between A.M. Villafaña, E.N. Kuyrkendall,
+and J. Richards regarding plans to meet to prepare for indictment
+presentation, service of grand jury subpoenas, interviews of additional
+witnesses, and plea negotiation issue
+5/27/2008-5/28/2008 emails between A.M. Villafaña, E. Nesbitt
+Kuyrkendall, and J. Richards regarding request for legal analysis of
+statute of limitations issues under state and federal law
+5/27/2008-5/28/2008 emails between A.M. Villafaña, J. Sloman, R.
+Senior, K. Atkinson, and R.
+regarding report of new state plea
+deal for J. Epstein
+5/29/2008-5/30/2008 emails between A.M. Villafaña, J. Sloman, R.
+Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding
+planned grand jury presentation, status of investigation, possible grant
+of immunity to victim/witness for grand jury testimony
+Privilege(s) Asserted
+6(e)
+Attorney-Client Privilege
+6(e)
+Privacy Act/TVPA/CVRA
+Attorney-Client Privilege
+6(e)
+Privacy Act/TVPA/CVRA
+Attorney-Client Privilege
+6(e)
+Privacy Act/TVPA/CVRA
+
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 2 of 7
+P-014941
+thru
+P-014954
+P-014955
+thru
+P-014971
+P-014972
+thru
+P-014975
+P-014976
+P-014977
+thru
+P-014978
+P-014979
+thru
+P-014980
+P-014981
+Description
+6/2/2008 draft letter to Deputy Attorney General Mark Filip regarding
+reasons to approve continued prosecution of J. Epsteil
+NB: The Court has already determined that final version of this lette
+is protected by Work Product/Deliberative Process/Attorney-Client
+Privileges)
+6/3/2008 draft letter to Deputy Attorney General Mark Filip regarding
+reasons to approve continued prosecution of J. Epstell
+NB: The Court has already determined that final version of this letter
+is protected by Work Product/Deliberative Process/Attorney-Client
+Privileges)
+6/6/2008 emails between A.M. Villafaña and E. Nesbitt Kuyrkendall
+regarding victim/witness subpoenaed to the grand jury and need for
+additional grand jury subpoenas
+6/18/2008 emails between A.M. Villafaña, R. Senior, A. Acosta, J.
+Sloman, R.
+1. and K. Atkinson regarding telephone conference
+with R. Black about allowing J. Epstein to accept state plea to 60 days"
+imprisonment.
+6/19/2008 email forwarding 6/19/2008 email from B.
+to E.
+Nesbitt Kuyrkendall and J. Richards
+(NB: Asserting privilege only for A.M. Villafaña email. Attorney
+presumably has copy of his email to A.M. Villafaña)
+6/23/2008 emails between A.M. Villafaña, A. Fernandez, and S. Ball
+(USAO staff) regarding scheduling of grand jury time for indictment
+presentation and witness testimon
+Information regarding unrelated grand jury case redacted
+5/23/2008 emails between A.M. Villafaña, E. Nesbitt Kuyrkendall,
+Richards, K. Atkinson, and R. Senior regarding grand jury subpoena te
+victim/witness, revisions to indictment, planned grand jury presentation,
+and plans to supersede indictment
+Privilege(s) Asserted
+6(e)
+6(e)
+Attorney-Client Privilege
+6(c)
+Privacy Act/TVPA/CVRA
+Attorney-Client Privilege
+6(e)
+Attorney-Client Privilege
+6(e)
+
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 3 of 7
+P-014982
+thru
+P-014990
+P-014991
+thru
+P-015004
+P-015005
+thru
+P-015006
+P-015007
+P-015008
+thru
+P-015024
+P-015025
+thru
+P-015028
+P-015029
+thru
+P-015034
+Description
+6/25/2008 emails between A.M. Villafaña, J. Sloman, R. Senior, K.
+Atkinson, and A. Acosta regarding draft of notification of victim list for
+J. Epstein counsel with attached drafts
+(NB: Final list, with victim names redacted, has been produced to
+counsel for Petitioners)
+6/23/2008-6/26/2008 emails between A.M. Villafaña and counsel for
+grand jury witness/victim regarding immunity and travel for grand jury
+appearance
+6/28/2008 emails between A.M. Villafaña, J. Sloman, A. Acosta, and R.
+Senior regarding correspondence with J. Goldberger and proposed
+change to state plea agreement
+7/3/2008 emails between A.M. Villafaña, J. Sloman, and A. Acosta
+regarding telephone conf. with B.
+and regarding meeting with
+Sheriff's Office about work release program
+7/8/2008 emails between D. Lee, K. Neal (Attorney Advisory, Victim
+Witness Staff, EOUSA), and A.M. Villafaña regarding filing of
+Petitioners' suit, with attached Draft of Villafaña Declaration and initial
+Petition (DEI)
+(NB: Privilege is not being asserted for second attachment (DEI).
+Attachment was prepared by petitioners and is not being produced
+because it is within their custody and control.)
+7/8/2008 email from A.M. Villafaña to D. Lee, A. Acosta, and J.
+Sloman regarding victim notification letter provided to counsel for J.
+Epstein on 11/28/2007 with attachment
+(NB: The 11/28/2007 email to J. Lefkowitz with attachment will be
+produced to petitioners' counsel contemporaneously with the filing of
+this log)
+717/2008-7/8/2008 emails between A.M. Villafaña and D. Lee regarding
+backgrous, and oracing estigation i goried no Lee questions
+Privilege(s) Asserted
+6(e)
+Investigative privilege
+Privacy Act/TVPA/CVRA
+Attorney-Client Privilege
+Attorney-Client Privilege
+
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 4 of 7
+P-015035
+thru
+P-015062
+P-015063
+thru
+P-015069
+P-015070
+thru
+P-015071
+P-015072
+thru
+P-015074
+P-015075
+thru
+P-015081
+P-015082
+thru
+P-015084
+P-015085
+thru
+P-015090
+Description
+7/8/2008-7/9/2008 emails between A.M. Villafaña, J. Sloman, D. Lee,
+A. Acosta, K. Atkinson, K. Herd, K. Neal, K.
+, and W. Jacobus
+regarding response to Jane Doe suit, procedure for filing, and internal
+office policies
+7/11/2008-7/14/2008 emails between D. Lee, A.M. Villafaña, K. Herd,
+K. Neal, A. Acosta, J. Sloman, and W. Jacobus re outcome of hearing in
+Jane Doe v. U.S. suit and contact from counsel for J. Epstein
+7/14/2008-7/15/2008 emails between A.M. Villafaña, E. Nesbitt
+Kuyrkendall, J. Richards, and T. L
+regarding FBI victim
+notifications and guidance regarding language to use and information to
+provide
+7/17/2008 email from J. Sloman to A. Acosta, A.M. Villafaña, K.
+Atkinson, and Dexter Lee with attached draft of letter to M. Tein
+regarding misrepresentations in filings on behalf of J. Epstein in civil
+suits
+7/18/2008-7/21/2008 emails between A.M. Villafaña, J. Sloman, E.
+Nesbitt Kuyrkendall, J. Richards, D. Lee, and K. Atkinson regarding
+preparation of victim notification letters, victim contact list, filing of
+victim notification letter in a civil proceeding, and contact by B.
+with one victim opining that sentence imposed was insufficient
+7/21/2008 emails between A.M. Villafaña, J. Sloman, R. Senior, D. Lee,
+K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding ongoing
+victim notification process and Epstein filings in state court litigation
+related to federal grand jury investigation
+7/22/2008 emails between A.M. Villafaña, A. Acosta, J. Sloman, R.
+Senior, K. Atkinson, E. Nesbitt Kuyrkendall, and J. Richards regarding
+/21/2008 letter from M. Tein announcing plan to stay the civil suit
+gainst J. Epstein and notification that B. Reinhart is counsel of recor
+for S.
+in civil suits
+(NB: Tein letter is being produced to petitioners' counsel concurrently
+with production of this privilege log)
+Privilege(s) Asserted
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+6(e)
+Attorney-Client Privilege
+
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 5 of 7
+P-015091
+thru
+P-015092
+P-015093
+thru
+P-015097
+P-015098
+P-015099
+P-015100
+thru
+P-015116
+P-015117
+thru
+P-015135
+Description
+7/22/2008 emails between A.M. Villafaña and E. Nesbitt Kuyrkendall
+regarding ongoing victim notification process
+7/22/2008 emails between A.M. Villafaña, R. Senior, E. Nesbitt
+Kuyrkendall, J. Richards, and K. Atkinson regarding correspondence
+from J. Epstein counsel with attached draft response
+(NB: A final version of the letter has been produced.)
+7/23/2008 emails between A.M. Villatana and D. Lee regarding
+correspondence with counsel for J. Epstein and notice of breach
+7/25/2008 emails between A.M. Villafaña and K. Atkinson regarding
+extension of grand jury to allow for continued presentation of J. Epstein
+case
+8/2/2008 email from D. Lee to A. Acosta, J. Sloman, W. Jacobus, and
+A.M. Villafaña summarizing status of Jane Doe v. United States
+litigation and requesting views on making certain disclosures to counsel
+for petitioners with attached pleading filed by petitioners (DE19)
+(NB: Privilege is not being asserted for attachment. Attachment was
+prepared by petitioners and is not being produced because it is within
+their custody and control.)
+8/5/2008 email from A.M. Villafaña to A. Acosta, J. Sloman, R. Senior,
+and K. Atkinson regarding analysis of Jeffrey Epstein agreement, with
+attached 6/24/2008 email from A.M. Villafaña to R. Black and J.
+Goldberger and attached Epstein agreement.
+(NB: Privilege is not being asserted for the two attachments. The
+6/24/2008 email will be produced to petitioners' counsel
+contemporaneously with the filing of this log, and the Agreement has
+previously been produced to petitioners pursuant to an earlier Court
+order.)
+Privilege(s) Asserted
+Attorney-Client Privilege
+6(e)
+Privacy Act/TVPA/CVRA
+Attorney-Client Privilege
+Work Produet
+6(e)
+6(e)
+6(c)
+6(e)
+
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 6 of 7
+P-015136
+thru
+P-015172
+P-015173
+thru
+P-015186
+P-015187
+thru
+P-015194
+P-015195
+thru
+P-015198
+P-015199
+thru
+P-015206
+P-015207
+thru
+P-015213
+P-015214
+thru
+P-015226
+Description
+8/13/2008-8/15/2008 emails between A. Acosta, K. Atkinson, R. Senior,
+J. Sloman, D. Lee, and A.M. Villafaña regarding scope of Epstein
+agreement and correspondence and telephone conference with J.
+Lefkowitz
+(NB: Emails to and from J. Lefkowitz and R. Black have been
+produced to Petitioners' counsel)
+8/25/2008 emails between A.M. Villafaña, A. Acosta, J. Sloman, R.
+Senior, K. Atkinson, and D. Lee regarding letter received from J.
+Lefkowitz
+(NB: Lefkowitz letter has been produced to Petitioners' counsel)
+8/20/2008-8/26/2008 emails between A.M. Villafaña, A. Acosta, J.
+Sloman, R. Senior, and K. Atkinson re draft response to J. Lefkowitz
+and draft amended victim notification letter
+(NB: Final version of letter to Lefkotiz and Black has been produced to
+Petitioners' counsel)
+9/2/2008 emails between A.M. Villafaña, D. Lee, R. Senior, and J.
+Sloman regarding revised victim notification
+9/17/2008 emails between A.M. Villafaña, A. Acosta, J. Sloman, R.
+Senior, D. Lee, K. Atkinson, and R.
+regarding efforts by Palm
+Beach Daily News to unseal NonProsecution Agreement that had been
+filed in state court
+(NB: Emails from Counsel for Daily News and from State Attorney's
+Office have been produced to Petitioners' counsel)
+9/17/2008 email from A.M. Villafaña to A. Acosta, J. Sloman, R.
+Senior, D. Lee, and K. Atkinson regarding attached letters from J.
+Herman alleging that victim notifications violated Bar ethics rules
+(NB: Redacted versions of the letters have been produced to Petitioners'
+counsel)
+9/29/2008 correspondence to Florida Bar Ethics Counsel regarding
+victim notification letters and allegation of ethics violation for
+distribution of letters with attached proposed victim notification letters
+
+Privilege(s) Asserted
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Attorney-Client Privilege
+Privacy Act/TVPA/CVRA
+Relevance
+Florida Bar Privacy Rules
+
+
+Case 9:08-cv-80736-KAM Document 338-1 Entered on FLSD Docket 08/03/2015 Page 7 of 7
+P-015227
+thru
+P-015233
+P-015234
+thru
+P-015238
+P-015239
+thru
+P-015263
+P-015264
+thru
+P-015267
+Description
+10/18/2008-10/20/2008 emails between D. Lee, A. Acosta, J. Sloman,
+and A.M. Villafaña regarding correspondence with B.
+discussing changes to understanding of portions of Non-Prosecution
+agreement and victim notifications
+11/4/2008 correspondence from Florida Bar Ethics Counsel regarding
+Florida Ethics Rules involved in distributing victim notification letters.
+11/26/2008 emails between A.M. Villafaña, J. Sloman, and R. Senior
+regarding email from R. Black about work release
+(NB: Email from R. Black has been produced to Petitioners' counsel)
+12/4/2008 emails between E. Nesbitt Kuyrkendall and A.M. Villafaña
+regarding attempts to send victim notification letters overseas via Legal
+Attaches and unrelated Epstein financial issue
+Privilege(s) Asserted
+Relevance
+Florida Bar Privacy Rules
+Attorney-Client Privilege
+Privacy Act/TVPA/CVRA
diff --git a/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.receipt.json b/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.receipt.json
new file mode 100644
index 0000000000000000000000000000000000000000..646b5b1795a5832d7adc35920815016bf66af2de
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+++ b/vision-fixhub/court-02/0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39.receipt.json
@@ -0,0 +1,14 @@
+{
+  "byte_delta": -1635,
+  "dataset": "marble-joined",
+  "doc_id": "0b8127ab530da64b36057848846cfeee5d7381e57b98cb1a7cdb56941324ca39",
+  "engine": "marble-apple-vision",
+  "event_count": 15,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.page-footer\", \"swarm.running-headers\"]",
+  "idempotent": false,
+  "input_sha256": "8f3650374544baf82460841b5f2dd9e87f6973fcf9b985c5febbd71569faa154",
+  "output_sha256": "f423460abd0ba64b8587dd36c6ca3faa84cd370517c2080ab5d7425f0fa942f2",
+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0ba260474320888d849fe21a00292ec9f77bb9fad1e02b26df3a4f5134bf47a7.md b/vision-fixhub/court-02/0ba260474320888d849fe21a00292ec9f77bb9fad1e02b26df3a4f5134bf47a7.md
new file mode 100644
index 0000000000000000000000000000000000000000..2768fd819a3d7d31c3897de6f89dc13eb3403fc4
--- /dev/null
+++ b/vision-fixhub/court-02/0ba260474320888d849fe21a00292ec9f77bb9fad1e02b26df3a4f5134bf47a7.md
@@ -0,0 +1,122 @@
+Case 9:08-cv-80736-KAM Document 361-40 Entered on FLSD Docket 02/10/2016 Page 1 of 3
+
+40
+
+
+Case 9:08-cv-80736-KAM Document 361-40 Entered on FLSD Docket 02/10/2016 Page 2 of 3
+Villafana, Ann
+From:
+Sent:
+To:
+Cc:
+Subject:
+C. (USAFLS)
+Villalana, Ann
+C. (USAFLS)
+Wednesday. March 19, 2008 6:18 PM
+Kuyrkendall, E N., Twiler
+Representation of Victims in Florida - CONFIDENTIAL
+Hi Jason and Pauline - My info is shown below. The Justice Department Victim Advocate assigned to the case
+is Twiler
+She is located at the FBI office here in West Palm Beach. The number there is
+Nesbitt Kuyrkendall is the case agent assigned to the case. She can answer any questions that you have. Her
+direct dial is
+call.
+I will be out of the office tomorrow, so if you need anything you can give Nesbitt a
+By this e-mail, I will ask Twiler and Nesbitt to put together a letter to the victims informing them of the
+availability of pro bone legal representation with your name and telephone number. I understand that you and
+your colleagues in Maryland are still working out logistics, so we will wait to send out until we know what
+name and contact information should be included.
+The one urgent case is that of victim
+She has been subpoenaed to appear for a deposition on
+Monday in West Palm Beach. I have given
+the contact information for Pauline Mandel, and I know
+that Vanessa was going to call her today. (I just spoke with Pauline and she has everything under control).
+For conflicts purposes, here are the relevant names and firms:
+The targets' names are Jeffrey Epstein,
+The attorneys involved in the case so far are: Guy Fronstin (West Palm Beach), Jack Goldberger of Atterbury
+Goldberger and Weiss (West Palm Beach). Roy Black of Black Srebnick Kornspan & Stumpf (Miami). Guy
+Lewis and Michael Tein of
+& Tein (Miami), Ken Starr and Jay Lefkowitz of Kirkland & Ellis (New York
+and LA. Alan Dershowitz from Harvard, Gerald Lefcourt (New York). Bruce
+Ann
+(Ft Lauderdale), Lilly
+of
+& Burnett (Miami). Jim Eisenberg (West Palm Beach), Michael Dutko of
+Bogenschutz & Dutko (Fort Lauderdale). Robert Targ of
+Reus Rolff & Targ (Miami). Nathan Dershowitz
+of Dershowitz, Eiger & Adelson (New York). Dennis Block of Cadwalader, Wickersham & Taff LLP (New
+York), William Richey (Miami and Palm City, FL), and Stephanie Thacker (West Virginia).
+If a firm name isn't listed, then they are sole practitioners.
+Here is a brief summary of the case:
+The investigation initially was undertaken by the City of Palm Beach Police Department in response to
+a complaint received from the parents of a 14-year-old girl, from
+Palm Beach. When
+and another girl began fighting at school because the other girl accused
+of being a prostitute, one of
+the school principals intervened. The principal scarched :
+I purse and found S300 cash. The
+principal asked
+where the money came from. initially claimed that she earned the money
+vorking at "Chik-Fil-A," which no one believed.
+then claimed that she made the money selling
+drugs; no one believed that either.
+_finally admitted that she had been paid $300 to give a massage
+to a man on Palm Beach island.
+parents approached the Palm Beach Police Department
+(PBPD"*) about pressing charges.
+1300
+08-80736-CV-MARRA
+RFP WPB-001940
+
+
+Case 9:08-cv-80736-KAM Document 361-40 Entered on FLSD Docket 02/10/2016 Page 3 of 3
+PBPD began investigating the recipient of the massage, Jeffrey Epstein, and two of his assistants, I
+_PBPD identified 27 girls who went to Epstein's house to perform
+"massage services" (not including one licensed massage therapist). The girls" ages ranged from 14
+years' old to 23 years" old. Some girls saw Epstein only once and some saw him dozens of times. The
+"massage services" performed also varied. Some girls were fully clothed while they massaged Epstein:
+some wore only their underwear; and some were fully nude. During all of these massages, Epstein
+masturbated himself and he would touch the girl performing the massage, usually fondling their breasts
+and touching their vaginas - either over their clothing or on their bare skin. Epstein often used a
+vibrator to masturbate the girls and digitally penetrated a number of them. For the girls who saw him
+more often, Epstein graduated to oral sex and vaginal sex. Epstein sometimes brought his
+assistant/girifriend,
+into the sexual activity. One of the girls described
+as Epstein's "sex slave".
+On October 18, 2005, PBPD obtained a search warrant with the assistance of the Palm Beach County
+State Attorney's Office ("PBSAO"). By this time, PBSAO had already been contacted by Epstein's
+cadre of lawyers. When PBPD arrived at Epstein's home two days later (10/20/05) to execute the
+search warrant, they found several items conspicuously missing. For example, computer monitors and
+keyboards were found, but the CPUs were gone. Similarly, surveillance cameras were found, but they
+were disconnected and the videotapes were gone. Nonetheless, the search did recover some evidence
+of value, including message pads showing messages from many girls over a two year span. The
+messages show girls returning phone calls to confirm appointments to "work." Messages were taken
+by
+• The search also recovered numerous
+photos of Epstein sitting with naked girls whose ages are undetermined. Two other assistants,
+have also been implicated.
+Photographs taken inside the home show that the girls' descriptions of the layout of the home and
+bedroom/bathroom area are accurate. PBPD also found massage tables and oils, the high school
+transcript of one of the girls, and sex toys.
+The investigation showed that girls from local high schools would be contacted by one of Epstein's
+assistants to make an appointment to "work." Up to three appointments each day would be made. The
+girls would travel to Epstein's home in Palm Beach where they would meet Epstein's chef and
+Epstein's assistant-usually l
+• in the kitchen. The assistant would escort the girls upstairs to the
+bedroom/bathroom area and set up the massage table and massage oils. The girl sometimes was
+instructed to remove her clothing. The assistant would leave and Epstein would enter the room
+wearing a robe. He would remove the robe and lie face down and nude on the massage table. Epstein
+would then instruct the girl on what to do and would ask her to remove her clothing. After some time.
+Epstein would turn over, so that he was lying face up. Epstein would masturbate himself and fondle
+the girl performing the massage. When Epstein climaxed, the massage was over, and the girl was
+instructed to get dressed and to go downstairs to the kitchen while Epstein showered. Epstein's
+assistant would be in the kitchen and the girl would be paid usually $200-and if it was a "new" girl,
+the assistant would ask for the girl's phone number to contact her in the future. Girls were encouraged
+to find other girls to bring with them. If a girl brought another girl to perform a "massage." each girl
+would receive $200.
+More detailed facts appear in the state's probable cause affidavit, which can be found online at
+www.thesmokinggun.com
+1302
+08-80736-CV-MARRA
+RFP WPB-001941
diff --git a/vision-fixhub/court-02/0ba260474320888d849fe21a00292ec9f77bb9fad1e02b26df3a4f5134bf47a7.receipt.json b/vision-fixhub/court-02/0ba260474320888d849fe21a00292ec9f77bb9fad1e02b26df3a4f5134bf47a7.receipt.json
new file mode 100644
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@@ -0,0 +1,14 @@
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+  "engine": "marble-apple-vision",
+  "event_count": 4,
+  "fix_ids": "[\"epstein_legal.bates-stamp.efta-prefixed\", \"epstein_legal.stamp-stripping.exhibit-labels\"]",
+  "idempotent": true,
+  "input_sha256": "990d195b41bf44e9fffed0c4101e878ddcdc44750624490e82c7481202a0970e",
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0bc4cf8ad55c74e628303f6462d0a2070453eda8b04a7f1c5301ee236ae97ac4.md b/vision-fixhub/court-02/0bc4cf8ad55c74e628303f6462d0a2070453eda8b04a7f1c5301ee236ae97ac4.md
new file mode 100644
index 0000000000000000000000000000000000000000..85bbbba72a1b40cfb4295fbbf14758475d1da053
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+++ b/vision-fixhub/court-02/0bc4cf8ad55c74e628303f6462d0a2070453eda8b04a7f1c5301ee236ae97ac4.md
@@ -0,0 +1,98 @@
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individually,
+and L.M., individually,
+Defendants.
+O.
+RACH
+12 SEP 19 PM 4:
+-
+FILED
+Defendant,
+NOTICE OF JURY TRIAL
+, pursuant to Rule 1.440 of the Florida Riles of Civil
+Procedure, to the Court that the action is at issue and ready to be set for trial on the original
+action or a subsequent proceeding. It is expected that this case will take 8 days to try.
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 19th
+_day of September 2012.
+NOT
+ack Scarola
+Florida Bar No.: 169440
+Priyy E-mail: jsx@searcylaw.com
+Secondary E-mail(s): mep@searcylaw.com;
+jxl@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorney for Defendant
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Votice of Jury Trial
+Page 2 of2
+COUNSEL LIST
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com;
+mahoney@agwpa.com
+Atterbury, Goldberger & Weiss, P.A
+250 Australian Avenue South, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jefffrey Epstein
+Esquire
+bje.efile@pathtojustice.com;
+staff.efile@pathtojustice.com
+Jaffe, Weissing,
+Lehrman, FL
+425 North Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Attorneys for Jeffrey Epstein
+Fistos &
+Fred Haddad, Esquire
+Dee@FredHaddadLaw.com;
+haddadfm@aol.com
+Fred Haddad, P.A.
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954) 467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+Law Offices of Marc S. Nurik
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+Lilly Ann
+, Esquire
+Isanchez@thelsfirm.com
+The L-S Law Firm
+1441 Brickell Avenue, 15th Floor
+Miami, FL 33131
+Phone: (305)-503-5503
+Fax: (305)-503-6801
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com;
+Debbie@Tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
diff --git a/vision-fixhub/court-02/0bc4cf8ad55c74e628303f6462d0a2070453eda8b04a7f1c5301ee236ae97ac4.receipt.json b/vision-fixhub/court-02/0bc4cf8ad55c74e628303f6462d0a2070453eda8b04a7f1c5301ee236ae97ac4.receipt.json
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diff --git a/vision-fixhub/court-02/0bf8537c83fa2cba94d4cb74501e485bc3719c303d6e1d870ab77b079b86d16c.md b/vision-fixhub/court-02/0bf8537c83fa2cba94d4cb74501e485bc3719c303d6e1d870ab77b079b86d16c.md
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+- JEFFREY: EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+and
+J.
+individually.
+Defendants.
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN
+AND FOR PALM BEACH COUNTY,
+FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JUDGE:
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN
+OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFE
+RENEWED MOTION FOR LEAVE TO ASSERT CLAIM FOR
+PUNITIVE DAMAGES AND MOTION FOR SANCTIONS AGAINST
+DEFENDANT/COUNTER-PLAINTIFF
+Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned
+counsel and pursuant to Rule 1.190(f) of the Florida Rules of Civil Procedure, §768.72 of
+the Florida Statues, and this Court's prior ruling on July 13, 2011, hereby files this
+Response in Opposition to Defendant/Counter-Plaintiff
+Renewed
+Motion for Leave to Assert Claim for Punitive Damages and Motion for
+- Sanctions
+against
+Defendant/Counter-Plaintiff
+In
+Plaintiff/Counter-Defendant Jeffrey Epstein states:
+CT
+-
+<On October 19, 2010, Defendant/Counter-Plaintiff
+CL
+FILED
+Edwarde therematter
+N.
+"Edwards") filed his first Motion for Leave to Assert Claim for Punitive Damages against
+Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"). This Honorable
+Court denied that motion on July 13, 2011, after an extensive and lengthy hearing, citing
+as grounds therefor the glaring procedural deficiencies contained in
+Motion.
+A true and correct copy of the transcript of the hearing at which the Motion was denied is
+
+
+attached hereto as "Exhibit A." On August 17, 2012,
+filed his Renewed Motion
+for Leave to Assert Claim for Punitive Damages. The renewed motion is identical in all
+material respects to the original Motion that this Court denied, yet
+requests that
+this Court grant this Renewed Motion without having addressed, corrected, or adapted the
+glaring deficiencies therein that were previously explicitly rejected by this Court. This
+Court specifically directed
+1. in meticulous detail, as to how he was required to
+correct the procedural deficiencies endemic to the original Motion.
+however,
+has failed to either heed to this Court's Order or abide by the basic requisites to assert a
+motion to plead punitive damages. For this reason, as explained more fully below,
+Renewed Motion for Leave to Assert Claim for Punitive Damages must be
+denied and Sanctions awarded for
+blatant disregard of this Court's previous
+ruling.
+A. This Motion was Already Denied by this Court as Procedurally Deficient
+Motion' for Leave to Assert Claim for Punitive Damages against
+Plaintiff/Counter-Defendant Jeffrey Epstein was previously denied by this Court, yet he
+re-filed the identical Motion, which must also be denied. First,
+two-page
+Motion is comprised of an introductory paragraph and four short numbered paragraphs. It
+cites neither procedural authority nor any law pursuant to which his request to claim
+punitive damages is permitted. While the glaring absence of rules of civil procedure and
+case law in
+pleadings is routine, this Court has already ruled that it is neither
+tolerated by this Court nor accepted in a Motion for Leave to Assert Claim for Punitive
+Damages.
+As such, the same procedural deficiencies should not be permitted in his
+Because the Motions are identical, with the exception of the Certificate of Service Date and addition of
+new attorneys, Epstein will reference each as the Motion and the Renewed Motion, respectively.
+
+
+Renewed Motion.
+Next,
+Renewed Motion, like his first Motion, endeavors to improperly
+incorporate the record evidence from his previously-filed Motion
+for Summary
+Judgment; the very same act that this Court has already ruled impermissible. As this
+Court is aware,
+Motion for Leave to Assert Claim for Punitive Damages must
+prove to the Court an entitlement to plead a claim for punitive damages. To properly do
+So,
+must demonstrate a reasonable basis upon which to assert this claim. See
+FLA. R.Civ. P 1.190(f). To establish a reasonable basis, both this Court and the Florida
+Rules of Civil Procedure require a "written summary of evidence, complete with
+deposition testimony and affidavits as part of the motion for punitive damages." Fla. R.
+Civ.P 1.190(f). This Court, in denying the Motion, explained to |
+what is
+required under Rule 1.190(f) to pass muster procedurally. This Court declared:
+[Rule] 1.190, which is the rule on amended and supplemental pleadings,
+was amended in two thousand, I believe, 2003 pursuant to Florida Statute
+768.72 to give guidance as to how you go about doing this. And the
+footnotes to the Civil Rules of Procedure... cites it to [sic], it says that
+subsection is amended to comply with the case of Beverly, Beverly Health
+And Rehabilitation Services, Inc. versus Meeks. And I have been applying
+this case before they actually incorporated it into the rules, but that case
+specifically said, it set up a procedure, at least, in the Third District for
+motions for punitive damages. And, I'll quote from paragraph - I don't
+know what page it is here. But, basically, says this - and I've been
+applying this in the past as well. Accordingly, it is and shall be the
+practice of this Court to require a written summary of the evidentiary
+proffer with appropriate page and line citations, deposition testimony,
+affidavits need to be filed and served in advance of the hearing so the
+defendant will have a reasonable opportunity. The motion doesn't do that.
+See Transcript from July 13, 2011 hearing page 36; line 9- page 37; line 4 (emphasis
+added). Because
+Motion failed to provide "a written summary of the
+evidentiary proffer with appropriate page and line citations, deposition testimony,
+
+
+affidavits," the Court determined that the Motion was procedurally deficient and denied
+same.
+repeatedly disagreed with this Court's assessment that his Motion did
+not comply with Rule 1.190(f) of the Florida Rules of Civil Procedure and §768.72 of the
+Florida Statutes, and in support of his assertion recited to the Court the introductory
+paragraph from his Motion, arguing again that by referring to the previously-filed record
+evidence, he incorporated that record evidence into this Motion for Leave to Assert Claim
+for Punitive Damages. This Court flatly rejected
+argument, and cautioned
+that incorporating previously filed "things" into other documents is not
+acceptable procedure for any motion. The Court further commanded
+to present
+each piece of record evidence in support of a particular motion contemporaneously
+therewith; which he has still failed to do. This Court directed
+following straightforward, unadorned instructions:
+to adhere to the
+I want you to make a motion pursuant to what I have just said. I don't
+want any incorporated things, you know ... You know, when you
+incorporate something else that doesn't work for me. I need it in front of
+me.
+I need the page, line so I can read it as a motion ... Again, Mr.
+Scarola, we're going to do it my way.
+Transcript from July 13, 2011 hearing page 38; lines 4-25. The Court continued:
+I want you to file your motion, set it for hearing and I'll look at it. And
+‹then it goes on to say that what happens is the other side, okay, this has to
+be done, at least thirty days, at least, this rule says thirty days before the
+motion, before the motion is set for hearing. To give the opportunity for
+the defendants to file something specifically in opposition, page and line
+and that way I can compare and contrast. That's the way I like to do it
+It's very complex in these cases and, you know, I just do not have the
+ability to go back and do it. So I want you to do that.
+Transcript from July 13, 2011 hearing page 39; lines 2-14. In response to the final
+instruction,
+replied: "I understand the Court's Direction." Transcript from July
+
+
+13, 2011 hearing; page 39; line 15. However, as demonstrated by
+filing of his
+"Renewed Motion," which contains the same glaring deficiencies, the Court's admonition
+was disregarded. Consequently,
+Motion must be again denied by this Court.
+B. The Renewed Motion is Procedurally Deficient and in Direct Contravention with
+this Court's Prior Ruling, Mandating Sanctions
+filed and served his Renewed Motion for Leave to Assert a Claim for
+Punitive Damages on August 17, 2012. This renewed Motion, however, is the original
+Motion with which this Court took serious issue and flatly denied. Word for word, line
+by line, this motion reads exactly as the previous Motion that was denied by this Court;
+with the exception of the certificate of service date and the list of parties upon whom it
+was served.
+with flagrant disregard for this Court's prior ruling irrefutably
+fails, yet again, to meet even the essential pleading requirements; to wit:
+fails to
+cite to proper authority in support of his assertion; fails to prove an entitlement to a claim
+in punitive damages; fails to provide a reasonable basis upon which to base an
+entitlement to a claim in punitive damages; fails.to attach or file any record evidence on
+which this motion is based; fails to provide a written summary of the proffered evidence;
+fails to provide deposition testimony; and fails to provide affidavits. As such, because
+the original Motion was denied for its failure to comply with the procedural requisites as
+delineated not only by the applicable law but also by this Court, so, too, must this
+Motion.
+Finally,
+filing of this identical Motion to Assert a Claim for Punitive
+Damages that was already denied by this Court irrefutably corroborates that he
+completely disregarded this Court's Order, mandating sanctions. At the hearing at which
+was admonished for filing the Motion the first time,
+acknowledged
+
+
+that he understood the court's explicit direction, yet he failed to follow same. See
+Transcript from July 13, 2011 hearing; page 39; line 15. A court has the inherent power
+to implement and enforce effective judicial proceedings pursuant to pretrial rules. As
+such, when a party fails to comply with a pretrial order, a court has broad discretion in
+determining sanctions.. First Republic Corp. of America v. Hayes, 431 So. 2d 624 (Fla.
+3d DCA 1983). Rule 1.380 of the Florida Rules of Civil Procedure likewise governs
+failure to comply with a prior court order and mandates that such failure "may be
+considered a contempt of the court." FLA. R. Civ.P. 1.380(b). Here,
+has not
+only snubbed this Court's order, but also caused Epstein to incur unnécessary expense in
+both responding to his Motion and attending this hearing.
+Accordingly, Defendant
+inapposite and patent disregard for this Court's Order mandates sanctions.
+CONCLUSION
+Accordingly, for all of the reasons delineated above and in reliance upon the
+applicable law cited herein and this Court's prior ruling, Jeffrey Epstein respectfully
+requests that this Court, yet again, deny
+Motion to Assert a Claim for Punitive
+Damages, award attorney's fees in favor of Epstein as sanctions, and such other and
+further relief as this Court deems proper.
+NOT
+del
+Tonja Haddad Coleman, Esc
+Fla. Bar No.: 0176737
+LAW OFFICES OF TONJA HADDAD, PA
+315 SE 7* Street
+Suite 301
+Fort Lauderdale, Florida 33301
+954.467.1223
+954.337.3716 (facsimile)
+Tonja@tonjahaddad.com
+
+
+WE HEREBY CERTIFY that a true and correct copy of the foregoing was
+served upon all parties listed below, via Electronic Service, this October 9, 2012.
+Jack Scarola, Esq.
+Searcy Denney Scarola et al.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+JSX@SearcyLaw.com
+MEP@Searcylaw.com
+Jack Goldberger, Esq.
+Atterbury, Goldberger, & Weiss, PA
+250 Australian Ave. South
+Suite 1400
+West Palm Beach, FL 33401
+jgoldberger@agwpa.com
+Marc Nurik, Esq.
+1 East Broward Blvd.
+Suite 700
+Fort Lauderdale, FL 33301
+marc@nuriklaw.com
+J.
+Esg.
+Jaffe Weissing
+425 N Andrews Avenue
+Suite 2
+Fort Lauderdale, Florida 33301
+bje.efile@pathtojustice.com
+Lilly Ann Sanchez, Esq.
+LS Law Firm
+Four Seasons Tower - 15th Floor
+1441 Brickell Avenue
+Miami, Florida 33131
+Isanchez@thelsfirm.com
+Fred Haddad, Esq.
+1 Financial Plaza
+Suite 2612
+Fort Lauderdale, FL 33301
+Dee@FredHaddadLaw.com
+ERTIFIED COPY
+Fiasychman
+
+
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+IN THE CIRCUIT COURT, 15TH
+JUDICIAL CIRCUIT, IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+CASE NO.: 50 2009 CA 040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually,
+And I.M., individually,
+Defendants.
+*
+*
+COPY
+HEARING BEFORE:
+DATE TAKEN:
+TIME:
+PLACE:
+HONORABLE DAVID F.
+July 13/ 2011
+10:34 a.m. to 4:45 p.m.
+Palm Beach County Courthouse
+205 N. Dixie Highway, Room 9C
+West Palm Beach, Florida 33401
+Kathleen M. Ames, RPR
+REPORTED BY:
+10
+
+
+
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+IN THE CIRCUIT COURT, 15TH
+JUDICIAL CIRCUIT, IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+• CASE NO.: 50 2009 CA 040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+1, individually,
+And I.M., individually,
+Defendants.
+COPY
+*
+*
+HEARING BEFORE:
+DATE TAKEN:
+TIME:
+PLACE:
+July 13, 2011
+10:34 a.m. to 4:45 p.m.
+Palm Beach County Courthouse
+205 N. Dixie Highway, Room 9C
+West Palm Beach; Florida 33401
+Kathléen M. Ames, RPR
+REPORTED BX:
+10
+
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+OF:
+APPEARANCES:
+I. ACKERMAN, JR., ESQUIRE
+I KNIGHT, ESQUIRE
+BURNETT, P.A.
+901
+Point West
+777 S. Flagler Drive
+west Palm Beach, Florida 33401-6170
+WEINBERG, ESQUIRE
+OF:
+WEINBERG, P.C.
+20 Park Plaza, Ste. 1000
+Boston, Massachusetts 02116
+JACK A. GOLDBERGER, ESQUIRE
+OF:
+ATTERBURY, GOLDBERGER & WEISS,
+P.A
+One Clearlake Centre, Ste. 1400
+250 Australian Avenue South
+west Palm Beach, Florida 33401
+APPEARING ON BEHALF OF THE PLAINTIFF
+COPY
+JACK SCAROLA, ESQUIRE
+OF:
+SEARCY, DENNEY, SCAROLA, BARNHART &
+SHIPLEY, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+APPEARING ON BEHALF OF DEFENDANT,
+10
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+MR. SCAROLA: Good morning, Your Honor.
+MR. KNIGHT: Good morning, Your Honor.
+THE COURT: Okay. We're here on Epstein versus
+Rothstein, et al. I want to thank the party that sent me
+the whole list of motions and I appreciate it very much.
+And I did have a chance to go through most of the stuff
+and, quite frankly, it's kind of hard to get my arms around
+this. There is a lot to do. My thoughts is to first kind
+of set-up a schedule to determine where we should go today
+in terms of starting in one place and where we're going to
+go. And seems to me the first place to start is try to get
+the pleadings in order, in terms of the motions that are
+pending that have not been tuled on. Then I would like to
+find out, I mean, I read the, at least, the interim report
+from Judge Carney. Is it Judge Carney? And I want to find
+out what the status of all of that is. And then I guess
+the best way to proceed, unless somebody has a better'
+alternative, is to start with the motions in some type of
+chronological order. But before that, to kind of get an
+opening from both sides as to where they feel or why they
+feel these various issues should be decided in their favor.
+I know they are varied but just to give me some general
+background in terms of the case.
+Having said that then, unless somebody has a better
+alternative, I would like to start with there is a pending
+
+
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+'25
+motion to dismiss on the, I guess, it's the second amended
+complaint.
+MR. ACKERMAN: It's the amended complaint, be the
+second complaint.
+THE COURT: Which I've read in detail the motion.
+Also, I think, pending is still the motion for punitive
+damages in regard to the counterclaim and I don't think
+there is any other motions pending in regard to the
+pleadings, are there?
+MR. SCAROLA: There are not, sir,
+no.
+THE COURT: Okay. I mean, I think I'm here to
+talk about all of those so why don't we start with the
+motion to dismiss because that kind of gets the thing
+rolling so start there!
+It's your motion, MI. Scarola.
+MR. SCAROLA:
+Thank you, Your Honor. With the
+Court's permission, may I address the Court from a seated
+position today?
+THE COURT: Yes, I prefer you do that.
+MR. SCAROLA: Thank you. Your Honor, this case
+started out with a thirty page, seventy-nine paragraph,
+five count complaint that read more like a press release
+than a legal pleading. And was the source of substantial
+procedural difficulty, as a consequence of the imprecision
+with which an effort was made to embroil
+in
+the Rothstein Ponzi scheme: We have moved from that
+
+
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+massive effuse press release to what is now a nine page,
+single count abuse of process case. The state civil remedy
+for criminal practices count gone.
+The state RICCO claim
+gone. The fraud claim gone. The conspiracy claim gone.
+And a whole new abusive process claim has now been asserted
+very different from what we were looking at previously.
+Indeed, the only allegation that attempts to associate
+with anything having to do with Rothstein
+is a claim that appears in Paragraph 20, which says,
+essentially, because so many RRA personnel, Rothstein,
+Rosenfeldt, Adler personnel, were involyed in the
+prosecutions of what were, obviously, very meritorious
+claims on behalf of the child victims of Mr. Epstein's
+criminal molestations, because so many RRA personnel were
+involved in the prosecution Edward, quote, "knew or
+reasonably should have known that his, Epstein's case
+files, were being shown and touted to investors."
+Now, no allegation that he knew or reasonably should
+have known that they were part of a Ponzi scheme but on the
+non sequitur assertion that because there were a lot of
+people involved in these very important, very big cases.
+Mr.
+knew or reasonably should have known that
+someone was trying to attract investors to fund the
+prosecution of these claims.
+The first element of a motion to dismiss relating to that
+
+
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+allegation is so what. A law firm has every right to raise
+funds to prosecute legitimate claims on behalf of its
+clients. And if all
+knew, which he didn't,
+but we must take the allegations of the complaint as true,
+if all he knew was, because there were a lot of people
+involved in the prosecution of these claims, he must have
+known that his files were being shown to and touted to y
+investors, that, certainly, can't form the basis of any
+cause of action.
+Let's take a look at what this complaint says
+did that constituted abuse of process.
+THE COURT: Let me just say off the top here that
+I have one problem with the complaint because it lumps
+defendants together in numerous allegations without
+differentiating as to any of the defendants which one did
+what, if any, or all did.
+MR. SCAROLA: Your Honor has anticipated one of
+the points that I would make and that, clearly, is one.
+But even assuming that all the defendants did all of the
+things that are claimed to have been done by the
+defendants, plural, let's take a look at what they say
+did. In the introductory paragraph they
+say that he is liable for abuse of process because of four
+things. One, he engaged in unreasonable and vexatious
+discovery within the context of claims that are never
+
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+asserted to have been anything other than legitimate
+claims. So one is unreasonable and vexatious discovery in
+the introductory paragraph not specified in any way.
+The second is making unfounded allegations in his
+lawsuits on behalf of his clients who had legitimate
+claims.
+The third is using improper
+investigative tools.
+And the fourth, interfering with a non-prosecution
+agreement.
+Now, of those four generally described elements of
+wrongful conduct, the only category that could possibly
+involve process, which means the filing of a complaint, the
+filing of an answer to a complaint, the filing of some
+pleading or a subpoena.
+The only category that could
+encompass abuse of process arguably could be engaging in
+unreasonable and vexatious discovery. And we're going to
+look at what they claim the unreasonable and vexatious
+discovery was in just a moment.
+We know from Paragraph 17 that the claims were not
+initiated while Mr.
+was an employee of RRA.
+Paragraph 17 tells us that he brought these legitimate
+cases, settled for very large sums of money voluntarily by
+the plaintiff. He brought those claims with him to the law
+firm. So it's not the filing of the claims themselves
+that's anywhere alleged to have been an abuse of process.
+
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+They don't make that claim.
+Paragraph 27 says the defendants embarked a scheme to
+interfere with the non-prosecution agreement, quote, "for
+the purpose of upping the stakes of the litigation." Now,
+the non-prosecution agreement is the agreement that
+Mr. Epstein entered into with the federal government that
+allowed him, what we and our clients, or Mr. Edwards'
+clients contend, was an improper and sweetheart deal.
+But
+attempting to challenge unsucçessfully, at least thus far
+unsuccessfully, a non-prosecution agreement on the basis
+that the victims had a right under federal law to be
+consulted regarding that agreement, which right was never
+afforded to them. Attempting to challenge a
+non-prosecution agreement could not possibly be abuse of
+process.
+And to the extent that there might be some assertion
+that this was tortious interference in an advantageous
+business relationship, the law is very clear, and I'm
+prepared to cite the cases to Your Honor, if it's
+necessary. I don't know that this is going to be
+. challenged. That unsuccessful interference is not
+actionable interference. A case calling Scheller versus
+American Medical International. So the allegations about
+the non-prosecution agreement, I suggest, are an absolute
+nullity. They can't constitute an abuse of process.
+
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+Let's go on to Paragraph 29, because that's where
+presumably an effort is made to set out what the
+unreasonable and vexatious discovery is. Paragraph 29,
+Sub-paragraph One talks about asking three airplane pilots
+inflammatory questions during the course of the depositions
+of those airplane pilots. Asking questions is not an abuse
+of process. Asking airplane pilot questions cannot
+possibly have a causal connection to the damage that is
+alleged by Mr. Epstein in this case.
+Curiously the damages have also changed dramatically.
+We are now told that the damages constitute fees and costs
+incurred in the underlying litigation, any claim for which
+was released in the underlying litigation. We will ask the
+Court to take judicial notice of the orders of dismissal of
+the three underlying claims, which require the parties to
+those cases to bear their own attorney's fees and costs.
+Mr. Epstein, having stipulated as part of the settlement
+that he was going to bear his own fees and costs, cannot
+claim as damages, in this case, fees and costs incurred in
+the underlying litigation, if they could possibly form the
+basis of any claim of liability in light of the broad
+litigation privilege that exists in the state of Florida.
+Let me address that very briefly. If I may approach
+the bench, I want to provide the Court with a copy of the
+Florida Supreme Court decision in Echevarria,
+
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+E-C-H-E-V-A-R-R-I-A, vs. Echevarria. That is the most
+recent Florida Supreme Court decision addressing the
+litigation privilege. It contains an excellent discussion
+of the Court's view of the scope of that privilege. And
+upon review of that case Your Honor will find that the
+Supreme Court has clearly and unequivocally held that/
+conduct that occurs in the course of litigation is covered
+by the absolute litigation privilege. The Court finds, as
+a matter of public policy, that it would be inappropriate
+to allow the assertion of independant claims for conduct
+that occurs within the course and scope of litigation.
+That there are other available remedies, including ethics
+complaints against lawyers involved in such conduct,
+including contempt proceedings and the imposition of
+sanctions, which appropriately can control that conduct.
+And allowing the assertion of claims in independant actions
+for conduct that occurs in the course and scope of
+litigation would have an inappropriate and improper
+chilling effect.
+So in light of that broad privilege, anything and
+everything that is asserted to have occurred in the context
+of the underlying claims, such as asking three airplane
+pilots inflammatory questions, first of all, does not
+involve an abuse of process. And, secondly, is privileged
+conduct.
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+Next paragraph, Sub-paragraph Iwo of Paragraph 29.
+Notifying Epstein of an intent to depose his high-profile
+friends.
+THE COURT: Let me just ask you, I've not read,
+quite frankly, the Echevarria case but does it still stand
+for the proposition that for there to be a litigation
+privilege it must be related to the legal proceeding
+itself?
+MR. SCAROLA: Yes, sir.
+THE COURT: It can't be something like -- okay.
+MR.. SCAROLA: If I were to issue a subpoena to
+Mr.
+for the sole purpose of causing him to miss an
+important business appointment where he was going to make a
+lot of money and I'm requiring him to be in court with no
+legitimate connection whatsoever to the litigation that's
+involved, that could constitute an abuse of process. One
+of the elements clearly is that it must be related to the
+litigation. But any conduct that occurs in relation to the
+litigation is conduct that is protected by an absolute
+privilege.
+There is a discussion of the Levin, Middlebrooks case
+where the Supreme Court makes clear that we're not just
+talking about statements made in the context of litigation
+but all tortious conduct that may be alleged. So it's a.
+very broad privilege. It covers exactly the kind of
+
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+conduct that is alleged to have occurred here in Paragraph
+One, which isn't conduct involving process in any case.
+Paragraph 29, Iwo, notifying Epstein of an intent to
+depose his high-profile friends. Telling somebody I'm
+going to depose your friends isn't process. Issuing a
+subpoena is process. Serving the subpoena is process. .
+Notifying somebody that you're going to depose his friends,
+that's not process.
+Asking Epstein outrageous questions in his deposition,
+Sub-paragraph number Three, that's not process.
+Sub-paragraph Four, requesting records from the federal
+government regarding communications between the government
+and Epstein lawyers. This is where the tortious
+interference with the non-prosecution agreement is alleged
+to have occurred because requests are made to find out
+about communications between Epstein and the federal
+government with regard to the very criminal activity that
+forms the basis of the civil lawsuits that Mr.
+legitimately prosecuting on behalf of the child victims of
+MI. Epstein's criminal activity, clearly, could not
+constitute abuse of process.
+Paragraph Five, quite frankly, I just don't
+understand.
+Paragraph 29, Five, reads the representative of the
+trustee for RRA's bankruptcy stated that there are
+
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+thousands of documents involving RRA's employees and
+government officials, including state and federal law
+enforcement authorities relating to Epstein. What does
+that mean in the context of this abuse of conduct claim
+against
+? It just doesn't make any sense.
+I can't respond to it because I clearly don't understand
+it.
+Six is requesting records from Dr. Bard who it is
+claimed didn't treat MI. Epstein. Well, okay,
+so what.I
+guess one way to find out whether he treated Mr. Epstein is
+to subpoena any records that he has about Mr. Epstein.
+Subpoenaing records from a physician is not an abuse of
+process outside the scope of the litigation privilege.
+Paragraph Seven, filing a second amended complaint
+alleging Epstein forced I.M. to engage in oral sex. Part
+of the litigation privilege clearly.
+Attempting to depose celebrity airplane passengers.
+Clearly, within the course and scope of the litigation
+privilege in the absence of any allegation that this was
+entirely unrelated to the prosecution of the claims against
+Mr. Epstein, which allegation appears nowhere. No such
+allegation appears anywhere.
+Nine, directing third-party subpoenas be used to
+obtain Epstein's prescriptions from pharmacies.
+Now, it doesn't say that the third-party subpoenas are ever
+
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+issued but if we can infer that they were, this is conduct
+that clearly falls within the scope of the litigation
+privilege.
+Paragraph 30 says that the defendants trespassed on
+Epstein's property and conducted surveillance of him. Now,
+without getting into the truthfulness of those allegations
+which must be taken as true, if
+the defendants trespassed
+on MI. Epstein's property, then there may be a cause of
+action for trespass. There is no cause of action for abuse
+of process because somebody trespasses on your property.
+There is no cause of action for abuse of process because
+somebody decides that they are going to surveil you.
+Paragraph 31 says that Mr. Edwards tried to plead a
+RICCO claim. So what.
+And Paragraph 32 says that he tried to freeze
+Mr. Epstein's assets. So what. That does not constitute
+abuse of process and to the extent it might be
+characterized as a use of process in the context of the
+litigation on behalf of his child victims of Mr. Epstein's
+repeated extensive criminal activity, it is covered by the
+litigation privilege.
+There are three elements of damage that are alleged.
+Fees and costs in the underlying litigation, which cannot
+constitute damages in this case. And the installation of
+an enhanced security system, which presumably may have some
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+causal connection to the trespass on Epstein's property and
+the conducted surveillance of him, but, certainly, has
+nothing to do with any abuse of.
+process. And the retention
+of security personnel for Mr. Epstein's personal safety and
+to protect his property. Now, there is no possible causal
+connection between the alleged and privileged litigation
+misconduct and Mr. Epstein's desire for privacy.
+Another significant problem that this complaint, faces
+is that MI. Epstein seeks to assert these claims by way of
+an amended complaint when he has repeatedly and
+persistently refused to provide any relevant or material
+discovery as a consequence of the assertion of his Fifth
+Amendment privilege. We have previously cited to Your
+Honor a number of cases,
+a substantial body of case law
+relating to the sword/shield doctrine. Mr. Epstein is
+seeking affirmative relief. I don't challenge the validity
+of his assertion of Fifth Amendment privilege. There is no
+doubt in my mind that he faces the potential of additional
+criminal prosecution. There are new claims that
+Mr. Edwards himself has placed the defendants on notice
+that he is about to file so there is no doubt about the
+fact that Mr. Epstein faces additional potential criminal
+liability and has a right to assert his Fifth Amendment
+privilege against self-incrimination. But the case law is
+absolutely clear he cannot come to this Court, sue
+-
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+and continue to assert his Fifth Amendment right as
+to matters that are relevant and material to the claims
+that he is attempting to prosecute. For, for all of those
+reasons, and if the applicability of the sword/shield
+doctrine is in any way challenged, I'll address that in my
+response. I don't know how it can be. But for all of
+those reasons this is a complaint, an amended complaint,
+which can, should and finally must be released.
+It must be
+dismissed. Thank you, Your Honor.
+THE COURT: Just one second.
+Let me read
+something here.
+MR. SCAROLA: The motion to dismiss reaches those
+arguments through the incorporation of all of the arguments
+in the summary judgment.
+THE COURT: You must be some kind of psychic.
+MR. SCAROLA: I anticipated that is where the
+court was going,
+The motion to dismiss, Your Honor,
+expressly incorporates the arguments that were made during
+the summary judgment hearing. And, clearly, one of the
+principal arguments that was made in the summary judgment
+hearing was an argument with regard to the sword/shield
+doctrine. I apologize for having intruded upon your
+thoughts.
+THE COURT: Go ahead.
+MR. KNIGHT: Your Honor,
+Knight on
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+behalf of Jeffrey Epstein. And let me back you up as to
+where we are and why we are.
+When we came into this
+lawsuit there was the original complaint, which Mr. Scarola
+talked about and Your Honor was allowing us to move forward
+with discovery before we amended the complaint, which from
+day one we said we will be amending the complaint to plead
+the cause of action that we felt was appropriate.
+we tried
+to go down that angle but plaintiffs -- I mean, excuse me,
+the defendants asserted privilege to pretty much each and
+every document which we will ever be able to get our hands
+on. We did get some limited privilege logs, which will
+come up in part of my argument, which is talks about why
+the frivolity of this motion to dismiss.' If they want to
+move for a motion for summary judgment on down the line if
+they have the facts after we get the document, that's a
+horse of a different color.
+But you asked us to -- first, let's take the
+discovery. Unfortunately between Mr. Rothstein not being
+able to be deposed, which we, of course; need to talk to
+Mr. Rothstein about what Mr.
+' involvement was, and
+their blanket assertion of privilege --
+THE COURT: Let me back up. I don't -- I
+directed you to do discovery. I think I questioned why
+there was never a motion to dismiss to the original
+complaint and I said but this is the complaint we have to
+
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+deal with. And I can't tell from reading this thing what
+in the world the cause of action is and it created a lot of
+problems in terms of what the scope of discovery was.
+Without knowing what you are suing for it's very difficult
+to figure out the scope of discovery and that's why I
+directed Mr. Ackerman to file an amended complaint so we
+would be able to focus in on what is discoverable, what,
+isn't, what the cause of action is and that sort of thing.
+MR. KNIGHT: Correct. And then we went forward
+with what we had to date, which is a reasonable basis for
+abuse of process claim which has been made. The complaint
+on its four corners meets all the standards which are
+required. And these are the cases that are already cited
+in our briefing and the response, is the Donna Della case,
+which is the 4th DCA case out of 1987, and goes through the
+various factors, which leads to what I must give you, which
+is a little bit of background so that you have it.
+Mr. Epstein came over to the Rothstein firm with three
+cases.
+Excuse me. Mr.
+Mr.
+came over to
+the Rothstein firm with three of these files. After he got.
+to the Rothstein firm Mr. Rothstein, Mr.
+and
+others used the cases to pump up the Ponzi scheme. The
+documents that we need and the privilege logs --
+MR. SCAROLA: Excuse me, Your Honor, I'm sorry.
+THE COURT: That's not even alleged.
+
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+MR. SCAROLA: It is not alleged. And I cannot
+allow counsel to make those kinds of statements in open
+court in the presence of the press and leave them
+unchallenged. That's exactly what has repeatedly gone on
+in this case to besmirch Mr.
+' reputation.
+THE COURT: Let me stop you. What I'm concerned
+about with this complaint, okay, and what concerns me is
+that there are allegations that the defendants did this,
+the defendants did this without specifying who did what to
+whom and why. It seems to me if you are going to sue
+Mr.
+or anyone else, for that matter, you need to be
+specific as to what he did or what you accuse him of before
+I -- I dismiss routinely complaints like this, which
+generically say the defendant did something without
+specifying who did what to whom and why. Because it does
+not spell out what your claims are I don't know what
+Mr. Rothstein did. What Mr.
+• did. Or -- and you
+also say and others. Who? I don't know who they are.
+And the other problem I have with it, aside from, I
+think there are some other issues, but your prayer for
+damages is specific as to some things but also has that,
+that, that, phrase that, that we all, you know, perk up our
+ears on, including but not limited to, which leads me to
+believe there is something else there that you're claiming
+in terms of damages, which is not, in fact, spelled out in
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+the complaint. And if there are, in fact, special damages,
+I think they have to be pled, as compared to general
+damages. So I don't know whether you're asking for and it
+makes a big difference, ultimately, what, what -- if we get
+to the point of the discovery issue -- what the defendants
+can get from the plaintiff and vice-versa. I mean, if
+you're claiming damage to reputation, lost profit, I don't
+know what it is you're claiming. I don't know what
+including but not limited to means, quite frankly.
+MR. KNIGHT: Your Honor, let me break these down.
+THE COURT: Okay.
+MR. KNIGHT: You brought up the subject early on
+about lumping the defendants together and there was an
+early paragraph which did so. The Paragraph 29, which MI.
+Scarola went through, is going through allegations relative
+to Mr.
+and if it needs to be divided out relative
+to Rothstein and
+1, we will do so as it relates to
+damages.
+The law under abusive process is even nominal
+damages ate enough to survive for a cause of -
+THE COURT: Don't misunderstand, Counsel, I don't
+disagree with that proposition that you allege damages that
+you claim are a result of this. What I'm concerned about
+is you have thrown in the kitchen sink in that, which is
+included not limited, does that mean you're claiming other
+damages or not claiming other damages? I don't know what
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+that means.
+MR. KNIGHT: At this time we're claiming the
+three areas of specified damages which we went into but the
+reason that catch-all is in there it goes back to this
+whole issue relative to the documents that we have been
+unable to receive. We believe that there will be other
+damages that maybe would be asserted at that time,
+If Your
+Honor is saying what he would rather have us do is once we
+get the documents, amend again, I fully understand. We can
+do so. But at the same time we don't want to be precluded
+from being able to move forward with our cause of action.
+The abuse of process cause of action is spelled out in
+all four corners under the Della, Donna decision and, also,
+the SCI Funeral comments relevant to it, which have been
+provided in the earlier briefings. Here at the motion to
+dismiss stage that is where we, that's what the Court needs
+to look at, as we have discussed. The areas relative to
+litigation privilege, which Mr. Scarola went at length
+into, deals with tortious interference causes of action and
+do not deal with abuse of process. It would be nonsensical
+for abuse of process to have a privilege because,
+therefore, you will never be able to bring a cause of
+action for abuse of process.
+THE COURT: Let me disagree with you. I think
+that the litigation privilege would go to any process
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+served in the litigation that's relevant to the litigation.
+It doesn't give you the right to go out and subpoena the
+president of the United States in a case just to get, for
+some reason, unrelated to the purposes of the litigation.
+So, I mean, there is, I read these cases. Unless this has
+changed the law. At least, it allows abuse of process in
+civil litigation if, in fact, the processes are not for
+legitimate purpose.
+MR. KNIGHT: If the unrelated areas are --
+THE COURT: His point was how can these be
+illegitimate, I think is what his point was.
+MR. KNIGHT: If that's his point but what I was
+taking he was using the cases of tortious interference.
+THE COURT: I don't think it matters what
+tort it is. I think the litigation privilege applies
+whether it's libel, slander, tortious interference, you
+know, abuse of process, malicious prosecution, all of those
+there is a litigation privilege associated with that. And
+it's a natural privilege. That's how I understand the law.
+I may be misquoting it but that's what I understood the law
+is.
+MR. KNIGHT: Understood. And the allegations
+which are in Paragraph 29 go into some of those areas which
+are outside, including Mr.
+' own deposition. I
+mean, in his lawsuit, his clients were never on these.
+
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+airplanes yet they went forward and took the depositions of
+these pilots, et cetera, on the airplane causing excess
+fees. And really what this was being used for is to be
+able to gain information which could be used in the
+underlying promotion in the Rothstein cases. And that's
+why I brought it up earlier when I was interrupted by Mr.
+Scarola. It is relevant to what we're talking about today.
+This is a matter where Mr.
+• deposition said I had
+very little contact with Mr. Rothstein. But at the same
+But ay the same
+time we learn once we get to the privilege log and also the
+only time he dealt with Mr. Jenny was when Mr. Jenny, who
+is the investigator approached him, that they are claiming
+privilege related to, we counted it up, dealing with
+eighteen to twenty attorneys, nine paralegals, plus
+investigators.
+MR. SCAROLA:
+Excuse me, Your Honor, I thought
+we were arguing the motion to dismiss and not the privilege
+issue.
+MR. ACKERMAN: I am. But Your Honor's specific
+question -- I would ask. MI. Scarola to hold his
+arguments -- but Your Honor's specific question dealt with
+what are these areas which are outside of the tort or
+whatever is being sued on. And if those are being done for
+some purpose other than the underlying litigation, which
+were the I.M. and the Jane Doe and E.M. cases here, then
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+that is abuse of process. This is at the point of
+allegations without us being able to get discovery. The
+allegations we have put into Paragraph 29 in specificity,
+especially, when you get into Paragraph Four under, under
+29, which deals with Mr. I
+going to the Court
+relative to what should be something relating to the three
+• Lawsuits that he has, when what it really is undermine the
+non-proseçution agreement. Why is that relevant to abuse
+of process? Well, all that is being used for is to find a
+way to ramp up our client relative to other worries, which
+are unrelated to the prosecution of those individual victim
+cases so that he ends up having to be in a situation where
+he has to pay exorbitant dollars, which otherwise would
+multiply what the amount of the actual value of those
+underlying cases otherwise would be. The complaint itself
+goes through all that is required under Della Donna.
+THE COURT: I presume in those underlying cases
+there were claims of punitive damages; is that correct.
+MR. KNIGHT: There are claims of punitive
+damages, correct.
+THE COURT: Okay.
+MR. KNIGHT: By the same thing, even looking into
+that, the efforts to freeze assets, things like that.
+There was no indication at any point that Mr. Epstein would
+be unable to cover whatever the compensatory damages and,
+
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+if punitive damages were ever to be allowed, any type of
+punitive award. All of this was done to ramp up these
+cases outside of these three, which were the ones that
+MI. Rothstein, and as we get through discovery, we believe
+MI.
+were using to sell to the various investors to
+ramp up the Ponzi scheme. They are tied together. They
+are in the same firm. These are the lawsuits that were,
+used when the various investors came into the office with
+Mr. Rothstein. Mr.
+is claiming, I believe, that I
+had no idea that this was going on with my lawsuits.
+Although, we know in the privilege log they're claiming
+that he's dealing with the eighteen to twenty attorneys,
+the nine paralegals and the investigators. They just don't
+add up both ways.
+But relative to what we're here on today, the motion
+to dismiss, this amended complaint does plead a cause of
+action under Florida law. If Your Honor wants us to go
+back and plead with more specificity relative to where we
+put in defendants, we will do so. I would suggest it would
+be better for us to be able to get the discovery. And the
+reason we have so many people here is we have
+Mr. Weinberg here to represent -- to talk about privilege
+issues. Mr. Ackerman to talk about various issues that may
+come up, including sword and shield. Get to those so that
+we don't constantly have to be coming back to the Court.
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+This complaint does plead a cause of action under Florida
+law and the motion to dismiss should be denied. Thank you.
+THE COURT: Speak to the fact that some of these
+things I, I mean, I understand how, even though they ask
+you, the question in and of itself may not be abuse of
+process. The actual subpoenaing somebody and then asking
+of the questions may be abuse of process, at least, in my
+view. If, in fact, the only purpose of doing that is to,
+'like you have alleged here, to somehow or another for
+illegal purposes or for improper purposes.
+But there are
+some of these things that you've alleged here I don't know
+how ever could be abuse of process. Like notifying
+somebody that they intend to do something, how could that
+possibly be abuse of process? Or saying -- or how can
+investigation be an abuse of process, or surveillance be an
+abuse of process.
+That's not using the process of the
+Court for anything. Maybe I'm missing something.
+Or what, does this mean, the representative of the
+trustee for RRA's bankruptcy stated there are thousands of
+documents involving RRA employees and government officials
+including state and federal law enforcement authorities
+relating to Epstein. What does that have to do with abuse
+of process?
+MR. KNIGHT: That one --
+THE COURT: Let me finish and then you can
+
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+respond.
+MR. KNIGHT: Yes, sir.
+THE COURT: Why is making an allegation in a --
+well, I guess that could -- I can see that. Attempting to
+discover information. You know, it's like —- what I'm
+getting at do you have any case law that says abuse of
+process can be not actually issuing process but thinking
+about it or threatening it or something like that?
+MR: KNIGHT: The Della Donna case doesn't go into
+investigation. The privilege issue really comes up as an
+affirmative defense, Your Honor, and that's what the cases
+say also.
+THE COURT: I'm not tall
+about privilege.
+MR. KNIGHT: As it relates to these allegations,
+though, if some of them can be taken apart to say, well,
+this one could be connected back to the process, i.e. the
+pilots being deposed, et cetera, and the other one is more
+flavor for the complaint. But to be able to spell out this
+complaint so the Court can understand where we're
+eventually going, because we haven't had these documents, I
+think putting that into the pleadings is the correct thing
+to do so that the Court can understand the complexity of
+this and what's involved and why we need to find out more
+so that we can get into the specifics. Clearly, we have
+enough for abuse of process. Whether or not some of these
+
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+individual paragraphs would not survive or individual
+sub-part As or Bs, you may be correct. But I think the
+Court needs that in the amended complaint to get the
+overall flavor of what the abuse of process cause of action
+is.
+THE COURT: That may be. But what you've, you've
+alleged these as specific acts of abuse, though.
+You don't
+allege this as some kind of background or context or
+something like that.
+MR. KNIGHT: And we did -- we allege it but I
+understand Your Honor's point saying how is that connected
+to the process because they did go for
+and actually -
+THE COURT: It says -
+MR. KNIGHT:
+- they didn't serve the celebrities
+they just threatened to serve the celebrities.
+THE COURT: I'm just reading what you said. This
+is not my words.
+It says the defendants made illegal,
+improper and perverted use of the process by utilizing
+unreasonable discoveries, unnecessary discovery, or
+threatening to take discovery and then you list. And some
+of these it seems to me are not actionable as a matter of
+law, the way you've pled it anyway. I mean, maybe --
+MR. KNIGHT: I think Your Honor's point is that
+it should have been more to the general allegations of the
+preamble rather than the specifics.
+
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+THE COURT: I'm also concerned about the fact
+that you've lumped all the defendants together in one --
+two defendants, I guess, together without specifying which
+did which. And I understand it's kind of a chicken before
+the egg, egg before the chicken.
+MR. KNIGHT: Chicken or egg or cart before the
+horse, Your Honor, it's all the same thing. When we look
+at these privilege logs we see the involvement of so many
+people and the Court rightfully said let's try to amend the
+complaint. Now, we did the best we can with the facts we
+have but they are still playing this we're not going to
+give you anything defense, which puts us, you know, in a
+position where certainly they should not be able to take
+that as an advantageous position and now say; • let's go
+ahead and dismiss this complaint and we'll still hide all
+of these documents from you we haven't given. Certainly,
+these documents, many of them are waived. Many of them are
+privileged on their face, et cetera. We want to know the
+who, the how, the when. And then there could be additional
+abuse of process allegations in there with more specificity
+but at it relates to this complaint itself, it has enough
+of the four corners to survive the motion to dismiss.
+THE COURT: Anything further?
+MR. SCAROLA: Yes, sir, Your Honor. What we have
+heard is, indeed, a cart before the horse argument. We
+
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+filed this defective complaint because we haven't gotten
+. the discovery that will enable us to file an appropriate
+complaint. You need to have the basis to sue first. And
+you need to state a viable cause of action first. You
+don't excuse obvious defects in your pleading on the basis
+that you haven't yet gotten the discovery that you hope is
+going to provide a basis for some cause of action and Iy
+don't know what it is. What Echevarria says is, quote, in
+the Levin case the 11th Circuit certified a question to
+this Court asking whether Florida's litigation privilege
+protects the acts of certifying to a trial Court an intent
+to call opposing counsel as a witness at trial in order to
+obtain counsel's disqualification. And later failing to
+subpoena and call that person as a witness from a claim of
+tortious interference with a business relationship.
+Answering in the affirmative we extended the litigation
+privilege to all torts finding that absolute immunity must
+be afforded to any act occurring during the course of the
+judicial proceeding, regardless of whether the act involves
+a defamatory statement or other tortious behavior. And
+here's the qualifications that Your Honor referenced
+earlier. So long as the act has some relation to the
+proceeding.
+There is no allegation anywhere in this amended
+complaint that any of these acts had no relation to the
+
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+pending claims against MI. Epstein, which most clearly
+included claims for punitive damages.
+And the fact that airplane pilots are not asked a
+single question about the particular victim in the cases
+being prosecuted doesn't mean that what was going on on
+those airplanes on a routine basis that formed part of a
+pattern of criminal activity on MI. Epstein's part was not
+relevant and material to the punitive damage claims that
+were being investigated and prosecuted legitimately by
+MI.
+The fact that he took an aggressive, thorough
+approach on behalf of his clients.
+And took discovery
+reasonably calculated to lead to admissible evidence. And
+there is no allegation that any of this discovery was not
+reasonably calculated to lead to admissible evidence, those
+allegations do not appear without specifically alleging the
+exception recognized by the Florida Supreme Court, this
+complaint fails,
+And it is no excuse to say, maybe I'm
+going to find some evidence somewhere that allows me to
+assert some legitimate cause of action, if you allow me to
+proceed with discovery on a case -- on a pleading that does
+not state a legitimate cause of action.
+we start hearing again about the theory of damage that
+no longer appears in this complaint. That is Mr. Epstein
+had to pay more to settle these cases than he otherwise
+would have had to pay to settle these cases if Mr.
+
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+weren't out there putting all of this pressure on him.
+Well, that's, that's Mr.
+job to maximize the value
+of his client's claims by putting as much legitimate
+pressure on the defendant as he possibly could and he,
+obviously, did an extremely effective job.
+So this complaint clearly needs to be dismissed on all
+of those grounds that we have asserted. And one thing that
+is not addressed at all in the argument that we just heard
+is the sword/shield problem that they have.
+Now, this is
+an amended complaint so we know the sword/shield issue
+exists because we've already deposed the defendant. Excuse
+me. We've already deposed the plaintiff.
+THE COURT: Let me tell you, MI. Scarola, I'm not
+going to dismiss the complaint based upon that at this
+stage. The reason, very simply, is that we can't really
+know what the sword/shield doctrine applies to until I know
+what the lawsuit is about. And I don't know what the
+lawsuit is clearly about at this point because there's
+certain things, obviously, that he can object to and I'm
+not making that determination at this point in time.
+I am going to dismiss the complaint with leave to
+amend, however. I find some serious problems with the
+complaint. Specifically, number one, that you have lumped
+together the defendants and it's not, it's not, in my view
+not a, not a basis to make vague allegations that are
+
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+nonspecific to a particular defendant because you haven't
+gotten some privileged documents yet.
+Because you got to come out, if you think this
+gentleman, or anybody, has made, committed a tort, then you
+have to allege it and then you get to the discovery that
+you want. The abuses of process, if they occurred in this
+case, occurred. They're not privilege. They occurred as
+part of the lawsuit.
+NOw, MI.
+involvement or lack of involvement
+in some alleged Ponzi -- not alleged Ponzi scheme, I guess
+it's a fact it's a Ponzi scheme by Mr. Rothstein, that
+may be subject to all of these privilege objections and
+how -- whether he was involved or not involved and what he
+did or didn't know and all of that kind of stuff. But the
+process was in the lawsuits. You have to know at this
+point in time what he did or didn't do that was an abuse of
+process.
+I don't know how you can't know at this point in
+time because, it either, it was either calculated to do
+something with that litigation or it was abuse for that
+litigation.
+MR. KNIGHT: Your Honor, we will re-allege with
+more specificity. Thank you.
+THE COURT: How much time do you need? And it's
+been a problem with this case from day one, okay. And I
+know I've mentioned it several times before without
+
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+getting, knowing what it is that we're litigating, it's
+very difficult to make decisions on all of these other
+issues you guys are talking about, including sword and
+shield, including privilege, including whether or not, you
+know, Mr.
+has to answer questions or Mr. Epstein
+has to answer questions, unless we know exactly what,
+number one, the claims are against - what the abuses are.
+And let me back up. Some of these things the way you've
+alleged them, at least in my view, are not abuse of process
+as a matter of law. The mere threatening of doing
+something without doing it, I don't - unless you get a
+case that says that's abuse of process, I don't see how it
+is.
+The others, I think,
+could be if they're alleged
+properly. If you're taking a deposition and asking
+questions in that deposition for the sole purpose of what
+you have alleged here or for the purpose unrelated to
+actually prosecuting the litigation, then I think that can
+be abuse of process.
+But the mere notifying somebody; I have trouble
+understanding how Paragraph Five is an abuse of process. I
+have trouble understanding attempting to conduct discovery.
+OI, I mean, some of these I just don't see how actionable.
+So I think you need to, to plead it more specifically.
+And, also, I think you need to specify. The included
+
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+but not limited to damages doesn't cut it. If you got
+special damages, I think you have to plead them. Now, you
+can always amend, if you find out there are other damages
+down the line that you have not claimed.
+But see, one of the issues in this case is going to be
+what your damage claims are may have something to do with
+what discovery is or is not calculated to lead to
+admissible evidence in this case.
+So I'm granting the motion with leave to amend. How
+much time do you need?
+MR. KNIGHT: Thirty days, Your Honor.
+MR. SCAROLA: We would object to thirty days,
+Your Honor. This case has been going on for a very long.
+time. This is now a single count complaint. Ten days
+ought to be more than adequate to get this filed.
+THE COURT: Well, I'm going to go ahead and give
+you thirty days to amend. Okay. The next issue, I guess,
+on the -
+MR. ACKERMAN: Your Honor, I've got some blank
+orders on all of the motions. Do you want --
+THE COURT: Well, I'm going to ask you guys to
+fill them out for me. It would make it easier for me.
+okay.
+MR. ACKERMAN: Okay.
+THE COURT: The next one is the motion for
+
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+punitive damages on the counterclaim, is that?
+MR. SCAROLA: Yes, sir.
+THE COURT: Let me, I don't want to take your
+time, Mr. Scarola, and let me tell you what I'm going to do
+on that. I'm going to deny the motion. I already heard an
+argument on it. I already read some of the materials, And
+here's the reason I'm denying the motion at this point, and
+it's without prejudice. The rule, and I think it's
+Rule 1.190. Is that it? Was - yeah. 1.190, which is the
+rule on amended and supplemental pleadings, was amended in
+two thousand, I believe, 2003 pursuant to Florida Statute
+768.72 to give guidance as to how you go about doing this.
+And the footnotes to the Civil Rules of Procedure -- and
+this is a problem we had before this rule came out -- cites
+to, it says that subsection is amended to comply with the
+case of Beverly, Beverly Health And Rehabilitation
+Services, Inc. versus Meeks. And I had been applying this
+case before they actually incorporated it into the rules,
+but that case specifically said, it set up a procedure, at
+least, in the Third District for motions for punitive
+damages. And I'll quote from paragraph -- I don't know
+what page it is here. But, basically, says this -- and
+I've been applying this in the past, as well. Accordingly,
+it is and shall be the practice of this Court to require a
+written sunmary of the evidentiary proffer with appropriate
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+page and line citations, deposition testimony, affidavits
+need to be filed and served in advance of the hearing so
+the defendant will have a reasonable opportunity. The
+motion doesn't do that.
+MR. SCAROLA: It does, sir, respectfully.
+THE COURT: I pulled it. The one sitting here
+doesn't have it.
+MR. SCAROLA: May I call the Court's attention
+to the very first paragraph of the motion that says the
+counter-plaintiff,
+J.
+moves this honorable
+Court for an entry of order granting him leave to assert a
+claim for punitive damages against the counter-defendant,
+Jeffrey Epstein. And in support thereof would show that
+the record evidence presented to the Court in support of
+motion for summary judgment satisfies every
+statutory prerequisite for the assertion of a claim for
+punitive damages.
+That summary judgment motion, if your
+Honor recalls, includes an extremely detailed recitation of
+record evidence and, specifically, cites to page and line
+numbers in supporting depositions, to specific paragraphs
+in supporting affidavits, and, clearly, by virtue of what
+is presented to the Court and incorporated by reference
+every conceivable requisite for a proffer is included in
+that incorporated summary judgment motion:
+Now, if what Your Honor wants us to do is to give you
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+that summary judgment motion back again and change the
+title on the summary judgment motion to say now it's a
+proffer.
+THE COURT: I want you to make a motion pursuant
+to what I have just said. I don't want any incorporated
+things, you know. The same thing with your motion to
+dismiss. You know, when you incorporate something else
+that doesn't work for me. I need it in front of me,
+I
+need the page, line so I can read it as a motion.
+MR. SCAROLA: Do you really want that box of
+material back again?
+THE COURT: I got the box. I saved the box. I
+knew this was coming. I got the box. I need your motion.
+I need it to be specific because your summary judgment
+motion dealt with a lot of other stuff, too, not just with
+the evidence for punitive damages. Okay. And the other
+thing was that on the summary judgment motion, if I recall
+right, one of the reasons I denied the motion was discovery
+not being completed at this point, if I recall.
+MR. SCAROLA: I think that was the only reason
+that Your Honor denied the summary judgment motion, which,
+obviously, would not be any legitimate opposition to a
+motion to assert a claim for punitive damages.
+THE COURT: Again, Mr. Scarola, we're going to do
+it my way.
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+MR. SCAROLA: I understand.
+THE COURT: I want you to file your motion, set
+it for hearing and I'll look at it. And then it goes on to
+say that what happens is the other side, okay, this has to
+be done, at least thirty days, at least, this rule says
+thirty days before the motion, before the motion is set for
+hearing. To give the opportunity for the defendants to,
+file something specifically in opposition, page and line
+and that way I can compare and contrast. That's the way I
+like to do it. And it makes -- it's easy when you have an
+alcohol related case or something like that. It's very
+complex in these cases and, you know, I just do not have
+the ability to go back and do it.
+So I want you to do
+that.
+MR. SCAROLA:
+I understand the Court's direction.
+THE COURT:
+So that's without prejudice and file
+your motion. Okay. Now, having said all of that, where
+are we in terms of the trustee and bankruptcy and Judge
+Carney and where are you at? Because I read his order and
+his order seems to say I agree with Judge
+has to
+control the discovery in this case but it runs the risk of
+having conflicting orders. And I kind of agree with that,
+as well. So where are we at in terms of discovery with the
+trustee?
+MR. ACKERMAN: Well, we need to back up a little
+
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+bit.
+THE COURT: Okay.
+MR. ACKERMAN: Okay. Your Honor, when this
+matter started, and I know you've heard some of it but
+because it's been awhile, I would like a little latitude.
+THE COURT: Sure.
+We got the day so I'm here.
+MR. ACKERMAN: Initially when this case began the
+prior law firm representing Mr. Epstein issued a subpoena
+to the bankruptcy trustee that was in possession of records
+that we believe were related to this lawsuit. Okay. That
+met -- were relevant to the claims that had been pled. At
+that time Mr. Scarola did not object to the issuance of the
+subpoena and I have that here. Okay. When the subpoena
+was served on the bankruptcy trustee we then had four or
+five or six motions filed on the grounds of privilege. And
+since the bankruptcy trustee controlled and was directing
+those matters before Judge Ray a special
+was agreed
+by the party to be appointed.
+Wow, also at that time -- and this is going to come up
+in answer to one of these other motions -- one of the other
+creditors, razorback, had also subpoenaed substantially the
+same amount of documents. Substantially subpoenaed the
+same documents that we had subpoenaed. And it was their
+understanding that they were going to be participating in
+this proceeding with Judge Carney. Now, each time we got
+
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+up to a deadline there was an order, order given to the
+firm and Mr.
+to prepare a privilege log.
+They were given numerous extensions.
+THE COURT: Just so I understand. The
+firm is now where these cases are at of went to after the
+Rothstein --
+MR. ACKERMAN: That's correct. And that's where
+Mr.
+is now. And they had lodged only privilege
+objections as to attorney-client and work-product materials
+as to this subpoena. When the special
+was appointed
+we began a series of meetings and hearings to try and deal
+with these special
+issues. And what that ultimately
+culminated in was an agreement, a confidentiality
+agreement, where MI. Scarola's clients would produce,
+approximately, five boxes of documents that were designated
+work-product, attorney's eyes only, which meant only the
+lawyers for Mr. Epstein could look at them. And what they
+designated to be irrelevant documents, which they believed
+had nothing to do with the case, but felt that it was
+easier to produce them and put them under a confidentiality
+order so, and those were allowed to be shown to our client.
+Now, if any of the parties believed that any of those
+documents were relevant or appropriate to be used in this
+proceeding, they were to take that to the special
+THE COURT: You say this proceeding, you mean my
+
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+proceeding?
+MR. ACKERMAN: This case, your case. Okay. And
+they were to be gone to the special
+Now, about
+that time we were arguing the motion for summary judgment.
+Counsel for
+had argued to Judge Ray that, wait,
+until the summary judgment motion is argued, defer ruling.
+All of those were denied.
+At one point they had asked you to pull back the
+subpoena that had been issued on these matters and you
+denied that. So then they prepared a privilege log that
+was, clearly -- it's in our binder.
+There is two privilege
+logs.
+THE COURT: Fortunately, I looked at it.
+MR. ACKERMAN: The first one, clearly, doesn't
+meet any requirements regarding the privilege log so we
+filed motions directed to that.
+The special
+ruled
+that you have to, at least, identify the people on it. We
+felt that the log was also inadequate, okay, for other
+reasons.
+And so the special
+ordered a
+list
+of the people, a
+list prepared, which is here, that
+identified who the people were. Okay. And in the meantime
+Razorback went ahead and filed a motion before Judge Ray to
+participate in this special
+hearing.
+Then we came in court on a hearing filed by a
+non-party who, Spencer Kuvin, had argued that since he was
+
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+identified on the privilege log as receiving some of these
+documents, he was going to assert a joint prosecution,
+joint defense type of privilege. Now, when we were at that
+hearing, at that point in time the special
+had
+generated his report. The special
+had set up a time
+when we were going to go through, he was going to go
+through the documents with everybody in the room and, at
+least, eliminate the ones that are obviously not privilege,
+which you can do by looking at this log. I mean, one can
+do, okay, by obviously looking at it.,
+And then we were
+going to break them down into what issues related to what
+privileges because there was a different standard of proof
+that related to the different privilege. For example, it's
+the burden of the plaintiff to establish the joint defense
+agreement and
+, we were going to do that.
+Now, as that was occurring, MI. Kuvin came in and
+argued his position and the Court was stating its position
+that you were in charge of the privileges, which we agreed.
+And that you were in charge of discovery, okay. And you
+put a stay on any discovery to the special
+and it
+effectively shut down the special
+I mean, you put
+a stay on any subpoenas to the bankruptcy trustee.
+THE COURT: From this Court?
+MR. ACKERMAN: From this Court.
+THE COURT: I didn't do anything to anybody else.
+
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+MR. ACKERMAN: No. You did from subpoenas issued
+from this Court.
+THE COURT: It could have only been your
+subpoenas or Mr. Scarola's subpoenas.
+MR. ACKERMAN: Correct.
+THE COURT: Somebody read my order otherwise.
+They can continue with any other --
+MR. ACKERMAN: No, no, I'm not saying that.
+THE COURT: Okay. I'm sorry.
+MR. ACKERMAN: If I said that, what I'm trying to
+say your stay applied to subpoenas issued from this Court
+to the bankruptcy trustee.
+THE COURT: Right.
+MR. ACKERMAN:Okay.
+And at that point in time
+we were at the point. in time where you said we were in the
+midst of the hearings that dealt with the amended complaint
+and that you needed to have the complaint done. And we had
+previously told you that we had, we believed we had a good
+faith basis for this complaint. We could demonstrate that
+Rothstein was definitely guilty of a crime. We could
+demonstrate definitely that the Epstein case files were
+shown to investors for the purpose of getting money that
+ultimately came in to the Rothstein firm. We can show that
+Mr. Rothstein, and some of these are in the complaint, I'm
+not re-arguing that, but, we could show at that time that
+
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+Mr. Rothstein made specific representations to these
+investors about what he could do. And then we can show
+that Mr.
+carried those out. And that Mr.
+testified in his deposition that it was a very limited
+number of people involved. And then what, in fact,
+occurred was that Mr. Rothstein was meeting with Mr.
+and the rest of the firm on this and they were
+having meetings about it, thus, providing the link to the
+theory of our cause of action as the abuse of process. And
+the theory of abuse of process related to a misuse of the
+judicial system. The use of these proceedings for some
+other purpose, that purpose to further this Ponzi scheme.
+It meant going after his friends individually. Putting --
+taking steps and taking actions that had nothing to do with
+those, those victim cases.
+Now, at that point in time we had subpoenaed the
+communications between Rothstein and the various investors,
+which is the first subpoena. And the second subpoena
+related to the law enforcement subpoenas. Because at that
+point in time, for one respect, Mr.
+has subpoenaed
+and has requested, we'ie going to get to it later, records
+between Mr. Epstein and the U.S. Attorney's Office. He has
+used those records as part of a summary judgment
+proceeding. We believe in the records that have been
+produced to us that they specifically, particularly when
+
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+you look at some of the items in the privilege 1og, that
+they specifically undertook the course of action to further
+this Ponzi scheme to interfere with a non-prosecution
+agreement that had already been reached with the
+government. Okay.
+It's not a tortious interference claim. It's a claim
+where they were abusing the Court system by using discovery
+mechanisms to bring about a breach or get the government to
+come to regress or retreat from the agreement it had
+entered into it after Mr. Epstein had pled guilty. Had
+served his time. Was on probation and already had
+substantial reliance and change of position on agreement.
+And that was done, we believe, to show investors what they
+were doing to advance this Ponzi scheme. So when we sent a
+letter -- a subpoena, which is why that is in the pleading,
+because it's evidence relating to the interference. This
+was a CVR case.
+And that case was filed by MI.
+in
+2009, okay. At the time his cases were pending with
+Mr. Epstein. There is a long lapse of what occurred, okay,
+until these cases get settled. And then he files a
+pleading in the federal court and he had represented in the
+underlying case that the documents he wanted regarding the
+law enforcement documents were necessary because they might
+lead to other discoverable evidence in that case. And then
+in the CVR case, which is pending before Judge Marra now,
+
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+he said I finally got the documents I wanted for the CVR
+case. So he, in fact, misrepresented to a magistrate why
+he wanted those documents.
+So then there is an order entered by the magistrate
+that says any of the documents that were produced -- and I
+have a copy of it here -- any of the documents that were
+produced pursuant to that order cannot be used in any
+proceeding absent a ruling by the Court on those issues.
+Now, some of those documents have already been filed.
+THE COURT: The Court meaning?
+MR. ACKERMAN: You.
+THE COURT: Okay.
+MR. ACKERMAN: The sitting magistrate or judge
+for which the documents are sought to be used, okay. And
+those are some of the documents that are in the summary
+judgment binders.
+Okay. And those were done for the
+purpose of being able to bring -- to make their summary
+judgment argument.
+Now, when we got to that stage in April, based on the
+Court's ruling we — the special
+proceeding stopped.
+we indicated to the Court at that time that we believed
+that on its face some of these matters in the privilege log
+the Court can look at and rule on and determine that they
+were not privilege and they are not waived and we were
+going to request the Court to do that. As far as Judge Ray
+
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+is concerned, the Court, you, have the ability to determine
+these matters yourself in terms of how it affects your
+case. He is not going to be doing anything, and he stated
+that on the record in one of the proceedings in the
+bankruptcy court, that he's not going to be making an in
+camera review. He's going to allow you to handle that
+process, okay. I mean, you as opposed to him ruling on the
+privilege issue, is what I'm trying to say.
+Now, that's pretty much where we are in terms of --
+THE COURT: Let me ask you a question before you
+proceed. If there are other parties see
+These
+documents for which there was a special
+appointed,
+why did my order, which merely stayed my subpoenas, stop
+production of documents in the trustee if other people are
+seeking these documents for reasons unrelated to this
+lawsuit?
+MR. ACKERMAN: Here's what happened. Your order
+stopped it for us.
+THE COURT: I understand that.
+MR. ACKERMAN: Okay. And I have a copy of the
+pleadings, if you need to see them. But Razorback --
+THE COURT: I read the order. I know what it
+says.
+MR. ACKERMAN: Razorback went in there and said
+we want to do a 2004 exam of Rothstein and we want these
+
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+records. And the records are substantially the same as the
+ones we wanted. They filed a motion to clarify this in
+front of Judge Ray, okay. And this is where one of the
+issues came up that he was not going to be ruling on stuff"
+that related to you. And I have in the binder there the
+transcript of the hearing where Mr. Scarola and his clients
+agreed to produce the documents that they are now claiming
+privilege on and have produced those documents to
+Razorback. So the documents that we're seeking here for
+which they claim privilege, for which we have a
+confidentiality agreement, they have produced voluntarily
+to a third-party.. We believe there's a waiver. We believe
+that invalidates the confidentiality agreement. And
+basically what happens is we're here arguing untold
+privilege issues when the very documents that we're seeking
+they have voluntarily turned over to a third-party without
+any issues of privilege. Without any issues of
+confidentiality. And that's what happened to them. Those
+documents were turned over and that's why that transcript
+of that proceeding is in there because we're prepared to
+argue that many of the documents that we have requested for
+which privilege claims have been brought are now waived.
+And I've also asked to use some of the documents, to use
+confidential documents because I believe it supports our
+cause of action and I believe that the confidentiality
+
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+provisions are now waived.
+So the answer to your --
+THE COURT: That makes it as clear as mud. I
+know -- just understand my frustration. It's very
+complicated when you, you know, you're telling me all of
+this and it's not really clear to me. Let me ask a
+simple
+question. The privilege here, the attorney-client
+privilege belonged to the clients, are they involved in
+this at all? I mean, is anybody protecting the rights of
+these women that were --
+MR. ACKERMAN: Your Honor, Mr, Farmer and
+Mr.
+have asserted attorney-client privilege on
+behalf of those clients but many of these privileges that
+they have asserted are work-product.
+THE COURT: Okay.
+MR. ACKERMAN: Or there is one with confidential
+source so we have no idea.
+THE COURT: Just so I'm understanding, are there
+two separate sets of documents, one is in the hands of the
+new law firm and the ones that are in the hands of the
+trustee and bankruptcy from the old Rothstein firm?
+MR. ACKERMAN: Yes and no.
+THE COURT: Yes and no. Okay. Good.
+MR. ACKERMAN: The first set of documents, okay,
+which were the subject of the first subpoena and our first
+
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+request to produce, the trustee turned over those documents
+responsive to that to the special
+and to the new law
+firm. The new law firm has also turned those documents
+over to Razorback.
+The second set of documents, which we're here on,
+relate to our subpoena to the trustee for law enforcement.
+Basically, communications between law enforcement agencies
+and the RRA law firm. Those documents -- and those were
+the basis of a specific request identifying people -- and
+those documents have been gathered by the trustee on a disc
+ready to be produced. And they have not been turned over
+to anyone because the Court's stay order that said any
+subpoena directed to the trustee is stayed.
+So the trustee has not turned over those documents. Those
+are in the possession of the trustee.
+THE COURT: Okay. So there are -- let me --
+there are two sets of documents then. The law enforcement
+documents, which are in the possession of the special
+master of the trustee proceeding, right?
+MR. ACKERMAN: The law enforcement documents are
+just in the possession of the trustee.
+THE COURT: Trustee.
+MR. ACKERMAN: Not the special
+THE COURT: They're in possession of the trustee.
+The other documents, which were the old Rothstein firm
+
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+files or materials, as well as anything for the new firm
+are all,
+has all of those documents?
+. MR. ACKERMAN: Those were documents that came,
+that the trustee picked up --
+MR. SCAROLA: Yes.
+MR. ACKERMAN: Yes.
+THE COURT: And they are in the hands of, in
+addition, they are in the hands of the special master, he
+has those?
+MR. ACKERMAN: Right.
+THE COURT: Okay.
+MR. ACKERMAN: Now, there Is a third set of
+documents, okay. They are called Qtask and the Fortress
+documents, okay. Those are the softwares that managed the
+cases within the Rothstein firm. The trustee is still
+litigating to get those documents with Qtask. The Court
+has --
+THE COURT: Who is -- help me out here. Who is
+MR. ACKERMAN: Qtask is a company that supplied
+the software system for private communications and, also,
+for case management to the Rothstein firm. We have
+received through exhibits and other depositions in the
+bankruptcy case, that Rothstein used some of this secure
+software communications to communicate with the investors
+
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+and people in his firm about his Ponzi scheme as related to
+the Epstein cases.
+Now, those records were subpoenaed and sought by the
+bankruptcy trustee from a company named Qtask. That
+company is owned and controlled by former Rothstein
+lawyers, Bob Buschel, and others. They have been ordered
+by the bankruptcy court to produce those records and have
+failed to do so and now are subject to -- and have been
+ordered under pain of contempt, including incarceration of
+the individuals, to produce those records.
+They have been
+assessed punitive fines and attorney's fees for not
+producing them as of --
+THE COURT: So we have three sets of documents,
+am I correct now? Okay.
+MR. ACKERMAN: So that's one of the reasons why
+in terms -- I understood your question as to the ones we're
+dealing with now but I need to alert the court there is
+another group of documents that would be responsive to our
+initial subpoena but that the bankruptcy trustee would need
+to produce when task and the Fortress documents become
+available.
+THE COURT: Okay. So we have the Rothstein and
+documents, the file, whatever, may be in existence.
+We have a law enforcement file that dealt with Rothstein.
+And you have the task, I guess, software system.
+
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+MR. ACKERMAN: And Fortress.
+THE COURT: That have not been produced yet but
+will at some point be in possession of the trustee in
+bankruptcy.
+MR. ACKERMAN: Correct.
+THE COURT: What we're dealing with, at least at
+this point in time in terms of your production request,,
+deals with the Rothstein/
+documents and the law
+enforcement documents; is that correct?
+MR. ACKERMAN: Yes.
+THE COURT: Okay.
+So where do we start then?
+That's where I want to -- where do you want to start with
+this? I mean, one of the problems, again, is that -- let
+me stop. Start with this.
+Is it possible that since
+Judge Carney has already spent, I imagine, countless hours
+looking at this, that he could do it for me as well as the
+trustee in bankruptcy?
+MR. ACKERMAN: The problem we've had, Your Honor,
+is that we believe that the more economical method to do
+this would be for you to take a look at the privilege log
+and determine initially whether they have been waived and
+some of the motions here are directed to that. And --
+THE COURT: Maybe I should stop and ask how many
+documents are we talking about? If we're talking fifty
+thousand to a hundred thousand --
+
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+MR. ACKERMAN: No.
+THE COURT: -- there is no way.
+MR. ACKERMAN: If you look at the special
+report -
+THE COURT: I did read. He said like sixteen
+hundred documents, or.
+MR. ACKERMAN: Those are sixteen hundred entries.
+They are not necessarily documents.
+THE COURT: That means it could be thirty
+documents per entry or something like that.
+MR. ACKERMAN: I'm sorry, sixteen hundred
+documents.
+MR. SCAROLA:
+y I address the Court?
+MR. ACKERMAN:
+Iwenty-eight thousand pages.
+THE COURT: What I'm going to do, I'm going to
+let him finish, take a break for lunch. We'll come back
+and you tell me what your position is, okay.
+MR. SCAROLA: I would like to take five minutes
+before lunch because it may keep us from coming after
+lunch.
+MR. ACKERMAN: I don't know if I can finish. But
+the point -- I want to answer your question is that the
+breakdown we're talking about, sixteen hundred documents
+that are identified on the privilege 1og. Now, we believe
+that if you review the privilege log and make rulings
+
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+because of either the inadequacy of the logs, because they
+have failed to comply with the Teague requirements, and we
+believe if you go through and see that some of the matters
+clearly aren't privileged on their face, that number will
+be greatly reduced and then you can do the in camera
+review. It would also give you an opportunity to
+understand what we're trying to accomplish and what we're
+trying to plead in this case because then you could review
+the documents that we have. One of the reasons I want to
+use --
+THE COURT: These documents are in some location?
+MR. ACKERMAN: Yes, they're on discs.
+THE COURT: Okay.
+MR. ACKERMAN: They're on a disc. Okay. You can
+have hard copies, too, if you wish, okay. Either way it
+can be done. But one of the reasons, one of my other
+motions that I wanted to get directed to goes to this
+matter because we had this confidentiality agreement where
+we agreed to keep them secret. I submitted those documents
+to you in camera. Those are documents we wanted to start
+using now in discovery for depositions because part of the
+issue is we can't --
+THE COURT: These?
+MR. ACKERMAN: Those ones.
+THE COURT: Okay.
+
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+MR. ACKERMAN: Okay.
+We can't really effectively
+take discovery --
+• MR. SCAROLA: No objection.
+THE COURT: I'm sorry?
+MR. SCAROLA: No objection.
+THE COURT: Okay.
+MR. SCAROLA:, I don't mean to interrupt but I can
+save some time.
+THE COURT: Okay. Let him have five minutes and
+we'll come back and let you say whatever you want,
+MI. Ackerman, okay. And then come back, okay. Go ahead,
+sir.
+MR. SCAROLA: There are specific documents that
+have been identified by MI. Ackerman from among those
+documents that have been provided to them pursuant to an
+agreement that they would like to use. As long as it is
+expressly understood that by agreeing to the use of those
+specific documents we have not prejudiced any assertion of
+privilege with regard to any other documents, we're
+prepared to allow them to use them. They are worthless. I
+really don't care whether he uses them or not. I just
+don't want to impact upon any other privilege argument that
+we may make by making that concession. I am obliged to
+make sure that we continue to protect all of our other
+privileges because we don't have the right to waive
+
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+attorney-client privilege. Unlike the Fifth Amendment
+privilege, which is controlled by Mr. Epstein, as much as
+we might like to take all of this and put it on the floor
+in this courtroom for Your Honor and everybody else in the
+world to take a look at because we have nothing to hide, we
+can't do that.
+THE COURT: I understand that.
+MR. SCAROLA: Okay. So we're obliged to assert
+our privilege.
+THE COURT: It's not your privilege.
+MR. SCAROLA: We are obliged to assert the
+privilege on behalf of our clients. Not only on behalf of
+the clients who we represented whose claims were settled
+but also because that same information is relevant and
+material to ongoing claims against Mr. Epstein, we must
+protect the work-product privilege, as well, because of the
+obligation that we have to protect the interests of those
+other clients. That's the position that we are in.
+Now,
+before we ever get to questions about privilege and an
+obligation to prepare a privilege 1og, and an in camera
+inspection, the threshold issue is relevance.. And it was
+as a consequence of Your Honor's recognition of the fact
+that there was a threshold relevance issue that Your Honor
+stayed enforcement of any subpoena or production request in
+this Court until such time as the pleadings were clarified
+
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+so that the relevance issues could be determined.
+We are still in that same position today as a consequence
+of the rulings that Your Honor has just made. We can't go
+any further this afternoon. As much as I would like to, to
+help to resolve these issues because the same threshold
+problem exists. We have a relevancy concern that must be
+addressed before any privilege concern can be addressed.
+That's our position, sir. So I would like to get it done
+today. We've got today set aside. I would love to be able
+to resolve all of these issues. It cannot be done and
+that's why I suggested that I needed five minutes before
+lunch, Your Honor. I don't think I took three.
+MR. ACKERMAN: I have a response to that but we
+can do it after lunch.
+It's up to you.
+THE COURT: No, go ahead. Actually, that was my
+concern initially because, I mean, from day one in this
+case, Mr. Ackerman, and I think I articulated this a number
+of times the problem I had initially with the complaint. I
+know you are not the author of the original complaint,
+okay, I know that. Was that I couldn't get a handle on
+what exactly the claims were and what the issues were going
+to be to determine what was relevant or calculated to lead
+to admissible evidence in the case. I think by filing your
+amended complaint, we're getting it down to, I think where
+we're going to ultimately end up at some point but we still
+
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+haven't gotten to that point. One of the things that
+really concerns me is the vagueness of the damage claims
+here because that has to do with some of the discovery, for
+example, that they can get of you. So, I mean, I guess I
+can make decisions on whether or not privileges have been
+waived. If it's been waived, it's been waived.
+MR. SCAROLA: Still doesn't resolve the relevance
+issue, Your Honor.
+MR. ACKERMAN: I need to respond.
+THE COURT: I understand that.
+• But I can make a
+determination -- I'm sorry. Go ahead!
+MR. ACKERMAN: I didn't mean to interrupt. I'll
+let you finish.
+THE COURT: Please, any help I can get.
+MR. ACKERMAN:
+Okay. There is a two part process
+with this relevance test. And the first part, we have
+argued this back and forth several times with you and with
+the special
+, which is why we had some frustration
+with that proceeding, when this subpoena went out with the
+complaint that it was operating under, the first complaint
+that everyone has been referring to, there was absolutely
+no objection on relevance filed at that time. And under
+the rules of procedure that is when it's supposed to be
+done. We argued relevance. They argued, attempted to
+bring up relevance. Really did not bring up relevance in
+
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+front of Judge Ray. The only motions that were filed in
+front of Judge Ray related to privilege. Once we got the
+special
+we started -- they started arguing relevance
+again. And one of the hearings in February the special
+ruled, I'm not going back to relevance. That ship
+has sailed. You could have objected when this subpoena
+went out the special
+ruled. And now we're at the
+point of doing the privilege stuff. That's the first
+aspect of it.
+The second aspect of it is
+that there is enough
+matters here that the Court' should tude on to allow some
+discovery without the need of another complaint. Because
+it allowed the process to proceed in some areas. The
+damages, you know, that's, that's not a significant part of
+this, okay. That's not - the part we're looking for and
+the subpoena we're talking about deals with documents to
+the trustee and the firm related to the Ponzi scheme.
+THE COURT: Let me suggest to you, however, that
+the other concern here has to do with my schedule, my
+ability to devote time to reviewing documents and privilege
+logs for things that may ultimately end up not relevant to
+the lawsuit. Okay. We're talking about thousands and
+thousands and thousands of documents. I'm not a special
+getting paid $300 an hour to look at documents.
+I've got eighteen to two thousand other cases out there.
+
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+You guys want me to sit down and spend two days looking at
+documents, it seems to me that I ought.to make a
+determination as to whether they're relevant before I do
+that but, you know, I understand your position.
+MR. ACKERMAN: The determination of the relevance
+is on the request. That's what they're objecting to and
+they have not -- they've waived the request.
+You can look
+at the subpoena.
+THE COURT: I understand that but then I have to
+look through ten thousand documents to determine whether
+they're privileged or not.
+MR. ACKERMAN: I don't think -- my point earlier
+was is that when you make y
+THE COURT: I don't think you're understanding
+what I'm saying. What I'm saying is it's important to me,
+because I don't want to spend valuable Court time reviewing
+documents to determine whether they are privileged or not
+privileged of whether the privilege has been waived, if
+those documents are not relevant to this lawsuit. That's
+my point. Does that make any sense to you? You know, you
+know, there is a finite amount of time that I have
+available to do this and I'm going to spend as much time as
+necessary to get it done. But I would like to be able to,
+at least, do it in a rational manner rather than just go
+out and 1o0k at documents.. And because I would have to
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+1ook at the documents, it seems to me, unless it's been.
+waived specifically, Mr. Ackerman, or are already, then for
+me to determine whether they are or are not privileged it
+requires me to look at them, does it not?
+MR. ACKERMAN: Yes. But I don't believe that the
+issue of relevance is part of it.
+THE COURT: You are not following me, I guess,
+MR. ACKERMAN: They have claimed. We have sent a
+subpoena. The subpoena has been responded to based on the
+subpoena. Based on specific certain terms relating to the
+subpoena. And the documents you are going to be reviewing
+are work-product relating to the Epstein case.
+THE COURT: Maybe I'm not making sense. and I
+apologize. You don't understand what I'm asking or what
+I'm suggesting. I understand what your position is.
+MR. ACKERMAN: I understand the overall concept.
+THE COURT: I understand your position that these
+have been waived, okay. What I'm concerned about is the
+time necessary to review --
+MR. ACKERMAN: That I understand. I understand
+the time component.
+THE COURT: Okay. Let's take a short break for
+lunch. Be back here by 1:30. We'll talk about -- I'm
+going to go forward this afternoon, do as much as I can on
+this to get as much done as I can. So, at least, on the
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+confidential sealed documents, which is. Tab 4C, the ones
+here in my hand, as I understand Mr. Scarola agreed that
+those documents may be utilized by the plaintiff in this
+lawsuit, as long as it's clear, and I so rule, that by
+doing so is not waiving any privilege associated with any
+documents whatsoever on any basis.
+MR. SCAROLA: Thank you, sir.
+MR. KNIGHT: Thank you, Your Honor.
+Op
+(LUNCH BREAK)
+THE COURT: Anybody want to say anything else
+before we start plowing through some of the motions?
+MR. SCAROLA: Did you have a nice lunch, sir?
+THE COURT: well,no.
+The company was good.
+MR. ACKERMAN: May I take off my coat?
+THE COURT: Excuse me?
+MR. ACKERMAN: Mind if I take off my coat?
+THE COURT: Sure.
+MR, ACKERMAN: It's a little warm.
+THE COURT: My deputy has on a heavy jacket. She
+is saying it's cold.
+MR. WEINBERG: Afternoon, Your Honor. I've been
+nominated by Mr. Knight and MI. Ackerman to try to respond
+to the Court's last set of inquiry, which is how we, as
+counsel, can help facilitate the privilege review and how
+we can narrow down the magnitude of sixteen hundred
+
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+documents, which might, at least, theoretically require
+document by document review down to a more manageable
+perspective. I think there are two ways --
+MR. SCAROLA: Excuse me. Before we proceed could
+I know which motion we're on? I suggest that maybe the
+best thing to do, if we're going to proceed here, is to
+focus on those matters that are currently pending,
+And I
+have no objection to taking then in the order in which they
+appear in the notebook with which the Court has been
+provided. And that would mean the first motion before the
+Court is our motion for reconsideration regarding our
+discovery request.
+. THE COURT: First
+thing, I kind of asked counsel
+to kind of give me some overview of the discovery process
+and what we're dealing with here and I assume this is what
+we're still dealing with.
+MR. KNIGHT: This is in response, Your HonoI.
+THE COURT: That's what I want to do and then
+we'11 deal with the motions in order as we have them.
+Okay.
+MR. WEINBERG: Thank you, Your Honor. I'm not a
+civil lawyer. I've been asked my by colleagues to help,
+particularly, because of some expertise in privileged areas
+and that's the reason they've asked me to address this
+issue. There is two ways.
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+One MI. Ackerman, at an appropriate time, will address
+with the Court and that is whether there is a legally
+enforceable waiver, not of the relevancy issue that was
+previously addressed, but of the privilege issue that would
+make a particularized document by document privilege
+analysis unnecessary.
+The second is more difficult. Privilege logs are
+important. The case law that's been provided to your
+Honor, principally, the Teague case requires more than
+Mr. Scarola has provided in terms of this privilege log.
+It's particularly important in terms of giving us the
+ability to narrow down from the sixteen hundred documents
+to have any potential ability to narrow it down so we're
+asking the Court to review not sixteen hundred, but two
+hundred, three hundred, four hundred. I can't promise you
+in good faith that a better privilege 10g will permit us to
+reduce the number of documents that we believe potentially
+could be related to the issues that ultimately will be
+litigated before Your Honor. But as it stands now there
+are privileged entries, for instance, RRA, meaning
+Rothstein firm lawyers, to Mr.
+• MI.
+to
+Rothstein firm lawyers. We don't even know which Rothstein
+firm lawyers they are. The 1og lacks that degree of
+particularization which the rules and the case law
+requires.
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+• It's particularly important because once Your Honor
+resolves the legal issue of waivers, which I believe can be
+done on a category basis rather than a document by document
+basis, Your Honor will ultimately be looking at whatever
+reduced number of documents there are to put them in to
+three categories.
+Number one, these are documents that, in facto
+demonstrate that Mr.
+gave proper ethical legal
+representation to his three clients.
+These documents are
+related to that representation.
+These documents are
+therefore unwaived and privileged and not subject to an
+exception under client fraud.
+MI.
+The second category would be documents that may have
+he's either the author or the receiver but may
+also involve that subset of lawyers in the Rothstein firm
+who were not engaged in good faith ethical legal
+representation of the three clients that Mr.
+represented., Who he represented before he came to
+Rothstein, who he represented afterward. There are, again,
+twenty lawyers and nine paralegals and many investigators
+and it's hard absent of a more particularized log and
+absent the Court's review of some of the documents. For
+instance, some go to Rothstein. Some go to RRA. May
+involve an investigator named Jenny that Mr.
+said
+he never asked him affirmatively to do anything on behalf
+• ORANGE REPORTING 800.275.7991
+
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+of his clients. So this is that rare firm where there
+can't be a presumption of ethics, a presumption of legality
+and to simply tell us in a log the communications were
+with, quote, "RRA lawyers" or with, quote, "investigators"
+doesn't help resolve whether they're in the category of
+ethical lawyering or criminal fraud, which would be an
+exception to the privilege.
+There is also, as a result of one of the documents
+that Mr. Scarola didn't object to us using,
+an e-mail --
+THE COURT: Let me back up. I thought the crime
+fraud section dealt with fraud of crime being committed by
+the client not the attorney.
+MR. WEINBERG: Not necessarily, Your Honor.
+Crime fraud exception has been used over and over again,
+for instance, by the government when they are investigating
+lawyers. And this really is why I'm here because before
+Judge Hoovler I represented a criminal defense lawyer named
+William Moran. He was one of many lawyers charged in the
+late 1990's. His law firm was searched. Many more
+documents than Mr. Scarola has identified in the log was
+seized. The Court, Judge Hoovler, appointed
+Barcello, who was a former Department of Justice
+prosecutor, because crime fraud was key. And in that case
+what was key is whether it was the crime or fraud of the
+lawyers not of the lawyers' clients.
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+In this case, and, again, I'm not hurling any -- this
+is not the time for me to make allegations.
+THE COURT: We'll deal with that later. I mean,
+I just finished, probably, a three day trial on crime fraud
+exception. I thought I read every case, including some of
+the similar cases dealing with tobacco manufacturers
+dealing with the crime fraid.
+And I'm having a little
+trouble with that but I'll deal with it when we get to that
+point. Because it seems to me --
+MR. WEINBERG: I will, if the Court wants --
+THE COURT: Not now.
+MR. WEINBERG: -- supplement through other cases.
+But clearly the lawyer can't claim work-product when his
+work-product is in furtherance of a crime. Mr. Rothstein
+is a lawyer. He could not protect his documents from
+litigation or from the government by saying you can't see
+my documents, they are work-product. If the lawyer is
+creating the crime, as Mr. Rothstein did, there's no
+privilege to prevent third-parties or Courts from reviewing
+the documents.
+THE COURT: We'll deal with that later. That's
+not my understanding but I didn't think it was quite as
+broad as you just stated but --
+MR. WEINBERG: Let me supplement that piece of
+this argument --
+: 800.275.7991
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+THE COURT: What you're telling me, though, is
+that you feel that the amount of documents that I may be
+able to, or have to review, once I get past the issue of
+whether or not there has been a waiver on the relevance
+issue, is that there may be waivers in regard to the
+attorney-client privilege to begin with.
+And that second, we need a more particularized
+privilege log because from the log itself we can't tell
+whether some of these documents may or may not have other
+exceptions applicable to them.
+MR. WEINBERG: Exactly, Your Honor. And I can't
+say, I cannot make a representation that a better log will
+reduce it to the number that the Court would feel
+comfortable reviewing.
+If the Court is not comfortable
+with what results from a more particularized log and after
+hearing Mr. Ackerman on the waiver issue --
+THE COURT: I'm not sure comfort is the issue.
+MR, WEINBERG: Economy.
+THE COURT: I hate to tell you but in camera
+reviews are probably the least favorite thing I do but you
+have to do them. You have to do them. Okay. Anything
+else you want to tell me?
+MR. WEINBERG: Just lastly, Judge, we now, as one
+of the documents Mr. Ackerman found in attorney's eyes
+only, we have an e-mail from Cara
+--
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+THE COURT: You're talking about these documents?
+MR. WEINBERG: One of the lawyers at the
+Rothstein firm. She was a former FBI agent and she says on
+July 29, I think our best bet is to go after those close to
+Epstein. And those would be the kind of gray documents
+that Your Honor would have to make a document by document
+analysis to determine does this document support good faith
+litigation. Is it in relation to a proper representation
+of Mr.
+client or instead is some investigator
+going off on an intrusive, violative conduct that only is
+to further Mr. Rothstein's ambitions to try to inflate the
+Epstein cases to advance his own investor scheme? I don't
+have an answer because I don't have the documents. I'm not
+making accusations about where any one document will fit.
+I'm hopeful through a log that is more particularized we
+can come back and say, Judge, we would like you to look at
+the following three or four hundred. I can't represent we
+can. If we can't, we would, of course, would then go and
+recommend to the court what Judge Hoovler did in this
+massive law firm search, which is to consider the Court
+looking at some of the documents, either on review or
+de novo, and having a special
+• and, perhaps, a
+special
+with experience in crime fraud such as a
+former U.S. Attorney. I know Mr. Goldberger can identify a
+few from the community who would have ongoing experience
+
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+from their prior jobs as an assistant U.S.
+Attorney, with how documents fit into these three
+categories. Thank you, sir.
+THE COURT: You know, I certainly have no
+objection to appointing a special
+, however, I'm not
+a federal court. I don't have the authority to do that
+absent the consent of the parties, as I understand it. ›
+Although some of my colleagues try to get around that rule
+by appointing a mediator, I think it's still, whatever you
+call it, put a sign on a cow and call it a pig, it's still
+a cow.
+You want to say anything else in response to that
+before we get into the nitty-gritty of the specific motions
+here?
+MR. SCAROLA:
+Very narrowly, your Honor. I
+disagree with the assertion that's been made that an
+attorney's involvement in a crime or fraud in which the
+client is not participating can constitute a waiver of the
+client's privilege. The crime fraud exception is an
+exception that waives the client's privilege when the
+client is using an attorney to advance the client's crime
+or fraud. I think that counsel is incorrect about the
+assertion that he's made regarding the crime fraud
+exception. But talking about these things in the abstract
+is not going to advance this.
+
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+THE COURT: Okay. Let's go forward with so what
+motion would be first up then?
+MR. SCAROLA: It is our motion for
+reconsideration of Your Honor's order sustaining objections
+to requests for admissions and interrogatories propounded
+to Mr. Epstein.
+MR. ACKERMAN: Your Honor, before he proceeds, I
+think that the actual discovery requests were
+• left out of
+the notebook for this.
+THE COURT: Yeah, I've looked at the --
+MR. ACKERMAN: So I have 'the one for the
+request to produce is in there!
+I have the interrogatories
+and --
+THE COURT: I think I've got the request.
+MR. ACKERMAN:
+/ Request to produce is there but I
+don't think request for admissions.
+THE COURT: The response.
+MR. ACKERMAN: The response is there. But the
+actual request and the interrogatories are not.
+THE COURT: Okay.
+MR. ACKERMAN: So you can put these in your book
+at Three a. I apologize for not having it.
+THE COURT: Okay.
+MR. SCAROLA: Your Honor, this motion for
+reconsideration cites to the now less than recent Fourth
+
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+DCA opinion in
+versus
+Tire where the Court
+finds it to have been error for the trial Court to have
+restricted discovery, which I suggest to Your Honor is even
+less clearly related to the allegations that are pending
+then the allegations in this case and their relationship to
+our request for admissions and interrogatories. If wę can
+take a look quickly at --
+THE COURT: Let me ask you a question about that.
+That's Judge Fine's tire case, right?
+MR. SCAROLA: Yes.
+THE COURT: As I understand, is that still on
+rehearing?
+MR. ACKERMAN:
+you to 100k at.
+Yes, and I have a docket sheet for
+THE COURT: I'm concerned that case is gone a
+little too far in the discovery and I, well, I don't know
+what's going to happen.
+MR, SCAROLA: Let me suggest to Your Honor that
+regardless of whether the broader parameters that are
+described in that case are or are not applicable. I think
+that Your Honor simply misapprehended what the appropriate
+scope of discovery in this case is.
+THE COURT: Okay.
+MR. SCAROLA: And I call your attention. We're
+looking at --
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+THE COURT: Let me read the ones again that we're
+talking about because I didn't have them right here in
+front of me, the requests themselves.
+MR. SCAROLA: My suggestion is that you start
+with the counterclaim itself because you'll understand
+their relevance more if you understand the counterclaim.
+first.
+THE COURT: I read that this morning but let me
+go back and read this again.
+MR. SCAROLA: I would just call your attention
+particularly to the allegations in Paragraph Five and Nine.
+If you look at those first and then we go to the discovery,
+I think it's hard to draw the conclusion that this is not
+reasonably calculated to lead to discovery of admissible
+evidence.
+THE COURT: Go ahead. I'm listening.
+MR. SCAROLA: All right, sir. Basically, what
+this complaint says is that Mr. Epstein has engaged in an
+extensive course of conduct that subjected him to civil
+Liability, both with regard to then pending cases and
+potential additional cases, as well. And what he tried to
+do, and continues to try to do in suing MI.
+is not
+to assert a legitimate claim but to make an example of
+Mr.
+to deter Mr.
+and others from suing him
+for the legitimate claims that exist that are out there
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+ready to be filed. So that's the contention in the
+broadest terms.
+So request for admission number one, you have acted on
+sexual preference for minor females on multiple occasions
+over the course of, at least, the last decade. Defining
+the scope of Mr. Epstein's motive to conceal his misconduct
+both in terms of restricting his civil liability and his
+punitive damage exposure, I suggest to Your Honor is, at
+least, reasonably calculated to lead to admissible
+evidence.
+Iwo, you have engaged in sexual activity with more
+than forty minor girls between 2002 and 2006 in your
+residence in West Palm Beach, Florida. Which is where
+Mr.
+clients were assaulted.
+Three, among the minor females with whom you have
+engaged in sexual activity between 2002 and 2006 was a
+person identified in a civil lawsuit filed against you as,
+and those are the identifications of Mr.
+three
+clients.
+›So, clearly, an acknowledgment from Mr. Epstein that
+he, in fact, engaged in sexual activity with these minor
+clients is relevant and material to what we contend is the
+motive.
+Now, if Your Honor may recall, we understand that
+there is very likely to be a Fifth Amendment privilege
+
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+asserted with regard to each of these requests for
+'admissions. But that's not the determination that Your
+Honor is making right now. You're not determining whether
+MI. Epstein can or cannot reasonably assert a Fifth
+Amendment privilege. You're determining whether this
+discovery is reasonably calculated to lead to admissible
+evidence to the claim, the counterclaim that we have
+brought against him. I'm quite frankly very puzzled as to
+how you could arrive at the conclusion that it is not when
+it's these cases we are alleging that he was attempting
+through this spurious lawsuit to avoid liability on.
+All of these cases remained pending at the time that he
+sued Mr.
+The next question, again, relates to these same
+allegations with regard to these three clients of
+MI.
+Number five, talks about his having reason to believe
+that they were minors at the time.
+Number six goes directly to the evidence in the
+underlying claims. And each of these are clearly
+calculated to lead to the discovery of admissible evidence
+regardless of what standard may be applied. What
+reasonable standard may be applied in terms of the scope of
+appropriate discovery.
+Now, if Mr. Epstein asserts a Fifth Amendment
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+privilege with regard to these requests, we're entitled in
+a civil case to draw inferences from that so we're entitled
+to know whether he's going to assert his Fifth Amendment
+privilege or not.
+•And they also continue to have bearing as long as some
+affirmative relief is being asserted against Mr.
+but because that pleading remains undefined I need to focus
+exclusively right now on our pending counterclaim.
+Each of these, and I don't know that I need to go
+through them because the argument is the same with regard
+to each of the request for admissions.
+They are all along
+the same lines. I suggest that Your Honor simply made a
+mistake when you denied that discovery.
+The interrogatories are in some respects even more
+puzzling. The first question is what is the full name and
+Florida address of the person answering these
+interrogatories?'
+THE COURT: Hang on. Let me get to that.
+MR. SCAROLA: I'm sorry.
+THE COURT: Where is my order on that?
+MR. ACKERMAN: Your Honor, just to make things a
+little bit easier. You sustained the objection to
+interrogatory number one, And I don't have an explanation
+but that's not an objection to be raised.
+THE COURT: Which interrogatory are we talking
+
+
+1
+2
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+4
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+19
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+21
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+79
+about because there is an interrogatory at the end of
+these?
+MR. ACKERMAN: The ones that we're talking about
+are two, three, four, five, six, nine, seven.
+THE COURT: Hang on, hang on. Where is the
+order? I'm trying to find the order on that.
+MR. ACKERMAN: It's in there. Three B.
+THE COURT: Okay. I'm sorry.
+Cab Three B.
+MR. SCAROLA: No, it's not, it's not tab Three B.
+It's --
+THE COURT: I've got the order.
+MR. SCAROLA: Okay.
+MR. ACKERMAN: I'm sorry. Three A.
+THE COURT: Yeah. I see where I did one, two,
+three, four, five, six, nine.
+MR. SCAROLA: You deferred as to eight.
+THE COURT: And seven on attorney-client
+privilege.
+MR. SCAROLA: And seven on attorney-client
+privilege. So I'm not sure what Your Honor was looking at
+but I don't see how you can sustain the objection to number
+one under any circumstances.
+THE COURT: Actually, nor do I.
+MR. SCAROLA: And number two, number two is going
+to the same issues as the request for admissions. As is
+
+
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+80
+number three. As is number four. Ghislaine Maxwell is a
+woman who is alleged to have been a procurer for
+Mr. Epstein who engaged in sexual conduct with the same
+minor girls that Mr. Epstein was abusing. She was a
+participant in his illegal conduct.
+Number five had to do with the damages that were being
+claimed. And, again, I can understand how we couldn't
+address that one until we know what the damages are that
+are being claimed now.
+Number six has to do with engaging in sexual
+activities with minors again.
+Number seven, Your Honor has sustained on the basis of
+attorney-client privilege and I think that Your Honor was
+confused. Because William Scherer and the Conrad, Scherer
+Law Firm, were not lawyers who ever represented
+Mr. Epstein. Mr. Scherer and the Conrad, Scherer Law Firm
+are attorneys who represented, and continue to represent,
+Ponzi scheme victims. They have interests adverse to the
+interests of Mr. Epstein. And it is our understanding that
+information was provided by Mr. Epstein to the Conrad,
+Scherer Firm and to William Scherer. We would like to know
+what information they gave them that relates to these cases
+and I don't know how that, that falls within an
+attorney-client privilege.
+You deferred as to number eight and I'm not sure why
+
+
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+81
+that was deferred but I think that, certainly, is
+information to which we're currently entitled. As is
+number nine.
+So I would ask the Court to take a look at these
+again. I think somehow there was some confusion on the
+Court's part. Perhaps Your Honor was focusing on the
+complaint and not discovery relevant and material to the
+counterclaim. If you focus on the allegations in the
+counterclaim I think it's very apparent that this is
+information we're entitled to have. Thank you, sir.
+THE COURT: Thank you.
+Yes, sir.
+MR. ACKERMAN: Okay.
+Your Honor, I would like to
+start off by saying that we had a lengthy argument about
+all of these issues, with the exception of number one,
+which I don't honestly have an explanation for. But we
+went through a lengthy argument about all of these issues
+and one of the concerns that came up at that time was that
+the Court was asking us whether or not, based on the
+complaint, that these matters were going to be at issue.
+We filed an amended pleading where we took these issues, to
+the extent that they were remotely relevant in the first
+complaint, out.
+Even if you look at the amended complaint, there is
+nothing there that puts these matters that he has asked
+with this type of particularity in issue.
+
+
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+18.
+19
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+82
+MR. SCAROLA: Excuse me, Your Honor. I conceded
+that. We're not talking about discovery relating to the
+complaint.
+THE COURT: I'm sure he's going somewhere with
+this, I suspect, so I'm going to let him go.
+MR. SCAROLA: Okay.
+MR. ACKERMAN: All right. Mr. Scarola argued at
+that time his counterclaim issues, okay. And the Court
+entered its ruling and the motion for reconsideration came
+before this Court solely on the basis of Alvarez, okay.
+That's the only reason the Court granted this rehearing.
+And my first argument is is that if the Court is not. going
+to consider
+as the grounds, this is done.
+THE COURT: Well, any ruling, let me just say up
+front, any ruling on the discovery matters, interlocutory
+orders I can reconsider any time for any reason. The issue
+that I want to find the time to go to today is whether or
+not these are; in fact, calculated to lead to admissible
+evidence in this case. So deal with that issue because I,
+quite frankly, it's been awhile since you argued that issue
+and I made my ruling.
+MR. ACKERMAN: We objected, first of all, that
+the scopes are burden -- the scopes are extremely large.
+MI. Scarola's counterclaim, which he's relying on, is an
+abuse of process claim. His abuse of process claim is
+
+
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+83
+directed at Mr. Epstein for this lawsuit. He, therefore,
+has not done so in his counterclaim, needs to particularly
+allege what process, what acts of the judicial system were
+abused in this case as he has argued to this Court. And
+that needs to be done before we undertake this broad,
+extensive discovery.
+Now, we have objected on the grounds of the Fifth
+Amendment. And we have argued before on the sword and
+shield and I need to say something about it at this point.
+The issues that involve -- and the Court overruled them
+when it came to the motion for summary judgment.
+The sword and shield issues come on these lines. When a
+plaintiff makes a claim and then claims privilege on
+matters related to the case, then Mr. Scarola may have
+a point. But nothing in this case, and he has not
+particularly alleged why this case and the actions in this
+case that have been taken by Mr. Epstein's counsel as abuse
+of process raised these issues. Mr. Scarola has -- and,
+therefore, the sword -- and this was briefed in the
+response, our response to the motion for summary judgment.
+It was extensively briefed on the sword and shield doctrine
+and so I'm just going to direct the Court to that.
+But in this case we have, he has asked about sexual
+preferences, sexual activities. The scope of this is
+extremely broad. It's extremely harassing. And given the
+
+
+1
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+84
+limitations of what he has to prove in his counterclaim for
+abuse of process, nothing here remotely leads to any
+discoverable evidence and that's why the Court denied it to
+begin with. Engaged in sexual activity. So we're going to
+have to invade all of these collateral matters. These will
+take the Court, one of the arguments I made last time, on
+a side trip that will take forever. We're not here,
+this
+case is not here to litigate those matters.
+Our case and
+Mr. Scarola's response are related to what the law firm did
+with investors relating to the Epstein cases and how the
+judicial system was perverted for a Ponzi scheme.
+Mr. Scarola's response is, well, we're going to bring
+an abuse of process claim and, frankly, I know we're not
+here necessarily to re-argue it and the Court ruled in a
+prior order that it was an abuse of process claim. But if
+you look at it there is elements of defamation. There is
+other elements of other cases. So I think before you reach
+any issue with regard to whether these matters, he is going
+to have to be required to replead his counterclaim with the
+same particularity that you're requiring us to see how
+sexual activity with all of these minor girls are going to
+relate to an abuse of process claim. Okay.
+Secondly, number three, he wants to know who he had
+specific sexual activity with. That's not going to bear on
+an abuse of process claim. Okay. He can make generally
+
+
+1
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+85
+the allegation that maybe Mr. Epstein filed this lawsuit to
+harass Brad
+but this is not where it's going to go.
+Okay. We don't have to get into the number of minor
+females that he paid for. We don't have to get into all of
+these specific dates. We don't have to get into the names
+of this. And this relates to the motion that we have later
+on relating to pre-trial publicity. Because this stuff,
+gets filed in this Court and the next thing we know it's in
+the newspapers of the Internet. And the Court, If this
+discovery proceeds, is going to be in a position of having
+to deal with those issues that may potentially taint the
+jury pool. So at this point they really have no relevance,
+okay.
+He's asked for socializing minor females in the
+presence of these people. There is no charge, there is no
+allegation that supports this. And an abuse of process
+claim that he has pled, as it presently exists, including
+transporting these and acts of trafficking minors, are
+going to take us on a side trip. Now, with regards to -
+that's pretty much related to the requests for admissions.
+Most of the interrogatories fall under the same
+category. We did raise Fifth Amendment objections there.
+They are not related to pursuing whether his genitals were
+exposed. Whether they were clothed in underwear have
+nothing to do with the claim that we're proceeding with.
+
+
+1
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+86
+They cannot possibly lead to relevant evidence relating to
+this. All it will do is be burdensome,, harassing and
+wasting the Court's time dealing with this.
+The same thing with number three whether your genitals
+were exposed. What was the number of times this lady,
+Maxwell, engaged in activity with minor females? What does
+that have to do with an abuse of process claim? This is
+merely done for the purpose of harassment and has nothing
+to do with the claims that are being brought, which is why,
+I believe, the Court ruled in this matter.
+Here he wants
+to know, number six in the interrogatories, with regard to
+the last time you engaged in sexual activity with a minor
+state the following. We don't need to get into that. This
+Court doesn't need to spend its time on that. There is
+nothing remotely related to this abuse of process claim
+that's going to make that relevant.
+The same thing with I.M. in number eight --
+THE COURT: Let me just ask you, his argument is,
+essentially, that the purpose of the abuse of process here
+is to cover up these alleged conduct. Or to prevent
+exposure of this alleged conduct by Mr.
+and others
+like him. How do you respond to that? If it goes to the
+motive of filing or abusing the process, how is that not --
+if that's true -- how is that not --
+MR. ACKERMAN: Well, first of all, Your Honor,
+
+
+1
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+87
+MI. Epstein pled guilty, okay. There was an overall
+settlement that dealt with a numerous number of victims as
+part of that, okay. He served time.
+He was on probation,
+okay. He entered into a non-prosecution agreement and
+whether they are happy with what the government did or not
+is really irrelevant. So how do you get to the point where
+he wants to cover up all of this when the government has
+concluded the investigation. They've agreed -
+THE COURT: I guess it's the same
+fon your
+client pled the Fifth Amendment. I presume your concern,
+or not maybe concern, that doesn't protect him. I mean, I
+mean, that's a logical answer.
+I don't know what happened
+here. I'm just, I'm asking you to respond to his argument,
+which is, look, if the abuse of process here is misuse of
+the judicial system to silence Mr. |
+and others like
+him from pursuing claims against your client for sexual
+activities with minor females or other sexual misconduct,
+if that's his motive for doing it, how is it not relevant
+that he's engaged in that conduct?
+MR. ACKERMAN: Because the abuse of process claim
+does not require the proof of motive. Okay. The abuse --
+if you file --
+THE COURT: It's not whether it requires proof of
+it. Whether it's relevant to the cause of action.
+MR. ACKERMAN: Well, if one of the elements isn't
+
+
+1
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+88
+one -- if the element of the abuse of process is that they
+took a pending case and abused the system to put some
+extortion on someone else, they got to establish that. To
+extort or put pressure on Mr.
+he has to establish
+that first before we go into all of these other matters.
+Because if the process was legitimately used, it doesn't
+matter what the motive is.
+THE COURT: Well, I thought that abuse of
+process, the whole theory of abuse of process was being
+used for purpose unrelated to the process itself, i.e. to
+cover up misdeeds or whatever the reason may be. At least,
+the allegation. That is the reason or, at least, that's
+their argument.
+MR. ACKERMAN:
+Your Honor --
+THE COURT:
+I'm just asking. I'm not ruling.
+I'm asking questions here. So just, you know, he says the
+reason that it's
+relevant is because the process is being
+abused for the purpose. The reason it's being abused is
+to, the ulterior motive is to cover up and otherwise
+prevent the exposure of your client to these other
+allegations by Mr.
+or others like him that may be
+scared off or afraid to pursue it because of what he's
+doing right now. At least, that's his argument.
+MR. ACKERMAN: Your Honor, based on what he's
+asking -
+
+
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+89
+THE COURT: Uh-huh.
+MR. ACKERMAN: -- you don't need to ask him this
+way.
+THE COURT: Uh-huh.
+MR. ACKERMAN: We don't need to go through and,
+for example, get healthcare provider records for sexual
+disorder. There is no issue there. We don't need to go
+through, in other words, what is the name and last known
+address of every healthcare provider which you have been
+treated or evaluated for sexual disorder.
+We haven't
+placed that in issue. Okay. We don't need, and he doesn't
+need to be able, if the Court is correct, and to follow the
+Court's question, we don't need to know the date of every
+single one of the actions. We don't need to show in detail
+what he's asking about genitals. We don't need to know the
+number of sexual matters that were involved with
+Mr. Epstein to do that. He can introduce that by talking
+about what, you know, what he's pled guilty to. But this
+is such a broad request we have asserted a Fifth Amendment
+privilege on it and he is making this argument in defense.
+I mean, we were making that in defense of a counterclaim.
+THE COURT: I'm sorry. I'm not ruling on the
+Fifth Amendment privilege. I'm ruling on whether or not
+these are relevant to the lawsuit and not whether your
+client has the Fifth Amendment privilege.
+
+
+1
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+90
+MR. ACKERMAN: That's part of our objections
+right now.
+MR. SCAROLA: Which I am not asking be overruled.
+THE COURT: I didn't understand it to be that
+way. I understood it to be the question that was in front
+of me. Your client can always say I object on the basis
+but he has to specifically answer the question that way,
+But the question was, that I thought we were discussing,
+was whether or not he can be required to even give that
+answer because if it's not relevant or calculated to lead
+to admissible evidence, he doesn't have to give any answer
+period.
+MR. ACKERMAN: Your Honor, I just want to put on
+the record that we've raised the Fifth Amendment.
+THE COURT: Okay.
+MR. ACKERMAN: Secondly, this is not calculated
+to lead to any relevant evidence. It is calculated to get
+harassing information that is over broad and has nothing to
+do with, given this type of detail, with what he claims he
+wants to prove, okay. The Court can certainly restrict
+what he's asking. That's one of our objections. It's over
+broad. It's harassing. It's very, very personal in terms
+of doing it, okay. It certainly should be limited in time.
+There is no effort here at all to limit the time. If the
+Court -- he doesn't need to answer questions about his
+
+
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+91
+genitals when they were exposed, okay. If the
+interrogatory is rephrased so that it states that were you
+subject to a number of victims' claims, if so, how many, he
+can establish that, okay. But to go through and ask when
+Maxwell engaged in sexual activity with a minor female,
+what does that have to do with Mr. Epstein? Okay.
+That's someone else. Okay. And whether he did these overt
+sexual acts that are the subject of this request, that's
+really the heart of the objection. I think, I still
+contend it's not relevant based on what is there but,
+certainly, if the Court is going to find that he wants to
+prove motive, this isn't the way to do it. We're going to
+have evidentiary issues with it.) The Court has discretion
+in discovery matters to limit it so as not to waste the
+Court's time with unnecessary litigation. And at a
+minimum, I still believe the Court needs to wait until
+is involved, but at a minimum the Court should
+sustain these objections and make him reask them so that
+they are not, they're limited in time. They're limited in
+not so much detail. And that they are calculated to show
+why it's related to the claims in this lawsuit and these
+don't meet that requirement.
+THE COURT: Okay. Briefly, Mr. Scarola.
+MR. SCAROLA: Your Honor is correct that motive,
+while generally not an element of a tort, is always
+
+
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+92
+relevant and material. And while motive is generally not
+an element of a tort in an abuse of process claim where we
+are obliged to show that the purpose behind the filing of
+the complaint against Mr. |
+. which is the process
+that is clearly addressed in this counterclaim, the purpose
+was unrelated to any legitimate purpose and was intended to
+cover up an extremely broad pattern of conduct that could
+subject Mr. Epstein to both additional criminal liability
+and civil liability.
+It is a very curious argument, indeed,
+that
+Mr. Epstein has engaged in so much of this criminal and
+tortious conduct that it would create an enormous burden
+for him to answer the interrogatories about how many young
+women he has abused. If that's the argument that is being
+made, and it sounds like that's the argument that's being
+made, they have the burden of supporting that
+burdensomeness argument. But there is no way that the
+Court could ever conclude that you have engaged in so much
+misconduct that I'm not going to ask you to tell us how
+much because it would be too much of a burden on you.
+THE COURT: I didn't understand you to say that.
+I thought you were saying it was over broad, not
+burdensome. It's a different standard.
+MR. SCAROLA: Well, the word burdensome was
+spoken many times and it was related to the scope of what
+
+
+1
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+93
+was being requested and how many incidents would need to be
+disclosed. As far as the scope is concerned where this
+conduct took place, when it took place, the extent to which
+it is going to expose Mr. Epstein to potential criminal and
+civil liability is all relevant and material. There's
+nothing overly burdensome about this at all.
+MR. ACKERMAN: The burdensome part of it was the
+detour that this court would go on, if we go down that
+path.
+THE COURT: Okay. I've heard enough argument on
+that. I'm not going to rule right off the top of my head
+here. You'll get an order by the end of the week. I got
+to think about this. Whichever way I go it's kind of like,
+in a sense, a roadmap of where we're going in the future so
+I really have to think about that more. What would be the
+next one here we have to deal with, guys? I mean, I got a
+pretty good idea what I'm going to do but I want to think
+about it overnight before I put it on paper.
+MR. SCAROLA: Your Honor, the next has to do with
+our motion for protective order and objections to a notice
+of taking deposition and appointment of special
+in
+an effort to re-depose Mr.
+MR. ACKERMAN: No, that's not the one.
+THE COURT: I'm sorry.
+MR. ACKERMAN: I don't believe that's the next
+
+
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+94
+one.
+MR. SCAROLA: Three B.
+MR. ACKERMAN: The next one is Three B and Three
+C. Motion for protective order relating to a subpoena that
+we sent to the trustee seeking the law enforcement
+documents.
+MR. SCAROLA:
+. I'm sorry.
+THE COURT: So Three B.
+MR. ACKERMAN: Three B.
+Os
+THE COURT: Let's me pull that.
+Let's take about
+a five minute recess. I've got something I need to take
+care of real quick.
+(BREAK TAKEN)
+MR. SCAROLA:
+Your Honor, an issue has arisen
+during the recess that the court reporter would like some
+guidance on. One of the reporters has requested the
+transcription of this hearing and to receive a copy and the
+court reporter wants the Court's guidance as to whether she
+can accept an order from someone other than a party in the
+case
+MR. ACKERMAN: Your Honor, I would ask that you
+defer that until we get to the motion relating to
+prejudicial statements that we're asking the Court to enter
+some restrictions on because of the use that has been made
+of statements in this case that show up in the press that
+
+
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+95
+relate to the sexual matters, which we believe aren't
+relevant.
+THE COURT: You are asking me to issue a prior
+restraint order, is that what you're asking me to do?.
+MR. ACKERMAN: It's not a prior restraint order.
+THE COURT: Well, what is it you are asking me to
+do?
+MR. ACKERMAN: We're asking you to enter an
+order -- hold on a second.
+MR. KNIGHT: Actually, at this point I think what
+Joe is saying the court reporter issue, if we could take
+that up at the very end because it may relate to some of
+these other issues.
+THE COURT: Let's make sure we get to it. Okay.
+Because -- well, let's deal with it right now. Since it's
+come up let's deal with it and we'll deal with it again, I
+guess, in the order. But this is separate. This is an
+open proceeding. I know of no case law that prevents
+anybody from getting a copy of -- having a court reporter
+type a deposition.
+MR. SCAROLA: That's my understanding, sir.
+THE COURT: I don't know of any. I mean, can't
+somebody come and get a copy of anything that's in open
+court. I don't know, if they're willing to pay for it.
+Do you have any authority for that at all?
+
+
+1
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+MR. ACKERMAN: Well, no, because I wasn't
+prepared to deal with it today. My concern, though, is
+that we have filed -- and this would be, if you want to
+take this up now?
+THE COURT: Well, I guess we better then we can
+go ahead and take it up in order.
+MR. ACKERMAN: Well, this would be sections Three
+E and Three F.
+THE COURT: Okay. This has actually never been
+presented to me for hearing before, right?
+'MR. SCAROLA: This is new.
+MR. ACKERMAN: This is new.
+THE COURT: Okay
+Give me a second, counsel.
+Okay. Mr. Scarola, you filed a response to this?
+MR. SCAROLA:
+Yes, sir, that's the next tab F.
+THE COURT: Okay. I'll hear argument. I have to
+tell you, gentlemen, it's been awhile since I've had this
+issue come up. In fact, I think it's only come up once in
+my judicial career but I will listen to argument. I will
+not rule from the bench today. I have to 1o0k at these
+cases again. It's been a long time since I read that
+Supreme Court decision but go ahead, Mr. Ackerman.
+MR. ACKERMAN: Yes, sir.
+THE COURT: Okay. And did anybody favor me with
+copies of these cases?
+
+
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+MR. SCAROLA: I did not, sir.
+MR. ACKERMAN: I did not, Your Honor. We can
+send them in.
+THE COURT: I can look them up.
+MR. ACKERMAN: One of the things that's been.
+occurring in this case, Your Honor, and a perfect example
+of our position on it is the summary judgment documents,
+Everything that Mr. Scarola and Mr.
+can do to raise
+the issues of these sexual improprieties to insert in this
+case, the Court can see that they are doing. Okay. Once
+they file the stuff in the Court file it is then under the
+law and under the bar rules able to be commented on. So as
+a result, we've attached to the first motion and then the
+amended motion these articles where Mr. Scarola is being
+attributed to saying that he's a convicted pedophile.
+That's not true. Okay. One of the things I want to
+address in this motion is up until today Mr. Scarola has
+constantly referred to Mr. Epstein as a pedophile.
+Okay.
+And there has been no proof of that anywhere. And
+it's inappropriate to do it in a Court proceeding and for
+it to be quoted in this manner because it will taint the
+jury pool. And also has no bearing on what the issues are.
+Mr. Scarola is quoted in other areas about speaking to
+Prince Andrew. There is an address book. All of these
+will become issues in this case if this door gets opened.
+ORANGE REPORTING .800.275.7991
+
+
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+• There is articles where Mr. Scarola says they're
+trying to get a statement from Prince Andrew.. And it's our
+view that these were published comments by Mr. Scarola
+that's clearly trying to generate articles about
+MI. Epstein and that is not the place to try this case.
+The Court does have discretion under the Miami Herald
+Publishing McIntosh case to take control and prohibit
+extraditial commentary in order to ensure the party
+receives a fair trial. And you can take steps to protect
+against pre-trial publicity, as the Shepherd Maxwell case
+discussed. The limitations imposed by the Court on
+communications between the lawyers and/or litigants and the
+media are permissible for good cause in order to assure a
+fair trial. McIntosh case specifically states that
+limitations placed on lawyers, litigants, and officials
+directly affected by Court proceedings may be at the
+Court's discretion. Muzzling lawyers who may wish to make
+public statements has been long recognized it's within the
+Court's inherent power to control professional conduct.
+›There is also a bar canon, 114-3.6 of the rules
+regulating the Florida Bar, called trial publicity. It
+talks about a lawyer shall not make an extraditial
+statement that a reasonable person would expect to be
+disseminated by means of public communication, if the
+lawyer knows or reasonably should know, that it will have a
+
+
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+prejudicial likelihood on material prejudicing an
+adjudicated proceeding due to its creation of an eminent
+and substantial detriment on that proceeding. This rule
+incorporates the substantial likelihood of material
+prejudice standard that the Supreme Court adopted.
+And what's occurred, and the Court can look at the
+docket sheet. I don't think I have it attached here. But
+there was a recent filing that Mr. Scarola made that, he
+used in support of his punitive damages about an interview
+with another alleged victim. He files it in the Court file
+and then there is an article about it.
+That has also been
+the case with some of these other articles. We have in the
+amended motion, the article is Epl
+Claim To Intimidate
+Attorney
+Prosecuting Sex Abuse Cases. He's being
+quoted here. Okay. ^ Then there is another article in the
+Daily News, Jeffrey Epstein Introduced Woman to Prince
+Andrew. That's being quoted. Mr.
+there is a marketing firm that
+is quoted. Then
+firm used where he states Mr.
+1, Mr.
+• law
+has successfully
+represented ten women between twelve and fifteen years old
+by proving that Mr. Epstein and his intentional sex
+trafficking criminal enterprise exploited these girls.
+There is simply no basis in fact for this, at least, based
+on the knowledge we have of the number of cases
+Mr.
+has handled.
+
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+We have a British publication called the Telegraph
+that's published convicted pedophile. Well, he hasn't been
+convicted as a pedophile. Okay. Much of the information
+is from MI. Scarola and he's quoted in the article that
+we've attached and we put forth some of what he said. He
+wants to speak to Prince Andrew. They want to obtain
+additional details. We believe Prince Andrew has been in
+the company of MI. Epstein. And then we talk about The
+Holy Grail that was reprinted.
+Then there is another British publication called the
+observer, which Mr. Scarola is again quoted. We have
+another article published in the Independant discussing the
+same thing.
+And we've got the Farmer Firm on their web site
+issuing press releases and online articles referring to
+MI. Epstein and the lawsuits. And they refer to him on the
+web site as the billionaire pedophile and he helped ten
+women seek justice. Okay.
+We don't believe it's appropriate to wage a media
+campaign, taint the jury pool and pre-try this case in the
+court of world opinion, particularly given the Internet.
+Okay.
+This is one of the reasons why I believe the Court
+should deny the earlier request that we spoke about with
+regard to the discovery on these specific sexual matters
+
+
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+101
+because they will then be in the press. And that will be,
+then we will be faced with real issues about a fair trial.
+The Court can place these limitations --
+THE COURT: Help me out here. The McIntosh case,
+I read this and there has been some Supreme Court cases
+since that decision, as I understand, that tell me what the
+threshold or what the standard is that I have to apply y
+before I do that. I know I have the aúthority to do that.
+I, certainly, have the discretion to do that but there's a
+standard set forth in these cases, as I recall it, that
+tells me what you, you or the person actually seeking this
+restraint, is required to establish before, before I go
+down there. So what is it, what, do the cases tell me on
+that?
+MR. ACKERMAN:
+The Court -- we have proposed what
+the Court can do:
+It says that no person covered by this
+order --
+THE COURT: No, no. You misunderstand me. Let
+me ask the question again. I'm not asking you what you
+want me to do in terms of restraint. What I'm asking you
+is what is the threshold of the bar you have to reach in
+order to get such a restraint? As I understood it, if I
+recall right, the McIntosh case sets forth a standard that
+I have to utilize before I, I use my discretion by entering
+such an order. It's been awhile.
+
+
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+102
+MR. SCAROLA: That standard is described in our
+memo, Your Honor. It's quoted at page three, the top of
+page three in our memo.
+THE COURT: And your memo is at?
+MR. SCAROLA: That's tab F. Comes right after
+their memo.
+MR. ACKERMAN: Hold on. To justify a prior
+restraint the activity must pose a clear and present danger.
+or serious or eminent threat to a protecting competing
+interest and that such a restraint cannot be upheld or --
+cannot be upheld if reasonable alternatives are available
+and that's what McIntosh says.
+MR. SCAROLA: That's a direct quote from
+McIntosh, Your Honor, that's correct.
+MR. ACKERMAN: But the Court also -- and that
+talks about pre-trial proceedings. Okay. This can go on
+between now and the time we go to Court, as long as we are
+discussing these issues. And by the time we get to trial,
+you know, and the issue I think the Court is concerned
+about is eminency. But we have a history right now that's
+been established. If the Court allows this discovery to
+proceed that we've previously argued and does not place --
+and the case law says that a Court -- prohibition on
+comment is an acceptable alternative to prior restraint,
+which is cited in the Florida Freedom Newspapers versus
+
+
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+103
+McCrary case, which is a Florida -- I'm sorry. Yeah,
+Florida Supreme Court case 520 So.2nd 32. And it can
+outline, the Court has also outlined other measures short
+of prior restraint on publication: Okay. And that has
+been held to be an appropriate way of doing it. And what
+the Court can do, and what we're proposing to do, is enter
+some pre-trial order that before any comments are made or
+anything is filed relating of a sexual nature, the court
+review it and impose limitations on counsel before they
+comment to the press. These matters are on the Internet
+and there is really no way to deal with it.
+THE COURT: The order I enter isn't going to
+protect the Internet anyway.
+MR. ACKERMAN: You can't stop the Internet. What
+you can do is stop us, stop the lawyers from talking to
+reporters about stüff before it gets filed in the Court
+file. For example, Mr. Scarola recently filed an interview
+of a woman that was an alleged victim of Mr. Epstein's
+actions. He filed that with a pleading that said this is
+being filed in support of some motion, followed by an
+article in the paper. Okay. That's what we're asking the
+Court to exercise some control over. The case law, as I
+understand it, states that once it's in the public record
+the lawyers are allowed to comment on it. But what we're
+trying to do is prevent that so that we don't have an
+
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+104
+unnecessary amount of pre-trial publicity on issues that
+may not, and the Court may ultimately rule on, have nothing
+to do with this case. Okay. You are not there yet on that
+decision, okay, on what the ultimate issues are. And until
+that occurs, the lawyers shouldn't be making any comments
+to the press about sexual conduct claims involving
+MI. Epstein with the specificity Mr. Scarola has been
+saying.
+What we're proposing is that is contained on page
+eight and nine of the amended motion. That basically
+states that no person covered by this order shall make no
+statement to the media that could interfere with a fair
+trial. Notwithstanding that, the Court --
+THE COURT: What page are you on?
+MR. ACKERMAN:
+I'm on page eight and nine of our
+amended motion.
+THE COURT:
+Does this come out of a case?
+MR. ACKERMAN: Yes.
+THE COURT: What case? Because I wouldn't know
+what in the world that could interfere with a fair trial or
+otherwise prejudice the parties in administration of
+justice means. That's kind of vague. You have a case that
+that came out of?
+MR. ACKERMAN: Yeah, I do, Your Honor. I have to
+locate it. I believe I have it. Your Honor, I don't have
+
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+105
+a copy of it... I'll have to get it to you. I thought I had
+it with me.
+THE COURT: Okay. Go ahead.
+MR. ACKERMAN: But these cases do allow the Court
+to make a balancing test between free expression and a fair
+trial. And in this case, I don't -- we're asking for some
+protection because if we end up, for example, doing a video
+deposition --
+THE COURT: There is a distinction between asking
+for protection against publicity or statements being made
+and asking for protection in regard to the integrity of a
+fair trial. Those are two different things. You
+understand what I'm saying?
+The mere fact that somebody
+says something that your client finds offensive or doesn't
+like or feels that he's been invaded by that comment is not
+the same thing as my concern, which is, which is that there
+is a fair trial in this case and can your client get a fair
+trial with pre-trial publicity. You see what I'm getting
+at? Because you seem to be focusing most on, you know,
+this thing affects your client, are, you know, libel or
+slander.
+MR. ACKERMAN: No, no, that's not the issue, Your
+Honor.
+•THE COURT: Okay.
+MR. ACKERMAN: Here's the thing --
+
+
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+106
+THE COURT: Because I don't have any evidence in
+front me at this point that whatever pre-trial publicity
+has gone on or been said or whatever has been said or done,
+and I don't know what all has been done, has in any way
+affected our ability to sit six jurors in this particular
+case that don't know anything about this case and otherwise
+are able to render a fair verdict.
+MR. ACKERMAN: Here's what I ask the Court to
+consider.
+THE COURT: Okay.
+MR. ACKERMAN: Okay. Let's hypothetically, and
+we don't believe the Court should allow this to occur, but
+hypothetically, let's assume that the Court allows a
+substantial portion of the discovery that Mr. Scarola was
+arguing about before, let's assume that that gets in the
+Court file. Let's assume that Mr. Scarola or Mr.
+is allowed to make continual media releases about it
+between now and the time we have a hearing. Let's assume
+that in response to some of these discovery requests we
+will be filing motions under 90.404(b), which relates to
+other bad acts, to keep that information out because it's
+merely being introduced to prejudice the jury. The Court
+will have to conduct a balancing test in terms of whether
+its proposed relevancy is outweighed by the prejudicial
+impact. Based on the information that they are seeking,
+
+
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+107
+that will be an enormous task. Based on what is likely to
+occur, if this occurs, there will be numerous media
+publications continuously now through the case gets tried.
+Okay. If it's tried. And at that point in time we will
+then be faced with a potential jury pool that will have had
+a steady dose of this and I believe that that is wrong to
+do at this point, particularly, when the Court has not
+solidified the issues about how extensive this will be.
+And at that point I think the Court, it is well within the
+Court's -- the Nebraska Press Association case states that
+while restrictive orders unquestionably are permissible
+within certain limits, the U.S. Supreme Court has not made
+any distinctions between restrictive orders and prior
+restraints. Instead, Nebraska focuses on balancing free
+expression against competing interest in a particular
+context.
+In this case what I'm trying to say is that if my
+hypothetical proves to be true, then we will be faced with
+a jury that will be tainted because of all of the
+publications. And we will -- if this case is limited to
+abuse of process, and Mr. Scarola can inject this into it,
+then the jury, in my opinion, and I will argue to the
+Court, will not be able to set aside any instructions the
+Court makes relating to 404(b) evidence. We have Fifth
+Amendment issues that are coming up. And I submit that
+
+
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+108
+before any further media reports occur that the Court at
+least instruct the lawyers that there be no more media
+discussions about the sexual activities until you've ruled
+on whether they're relevant. And then place some control
+on what the lawyers say so that by the time we do get to
+trial the media -- the jury pool iș not tainted, which
+clearly will occur based on the pattern we've seen right
+now.
+THE COURT: Yes, sir.
+MR. SCAROLA: We have filed an extensive
+memorandum addressing these issues.
+It would be
+unconstitutional for Your Honor to impose any type of gag
+order on us at this point in time.
+Particularly
+considering the fact that this matter has not even yet been
+set for trial.
+THE COURT: Not even at issue.
+MR. SCAROLA: Not even at issue. We don't even
+have a complaint filed yet. So the case law is clear that
+there must be a clear and present danger that a jury pool
+could be tainted by specific --
+THE COURT: Does that standard apply to gag
+orders as to the attorneys, as compared to power of
+restraint of the press or something of that nature?
+MR. SCAROLA: It applies to gag orders with
+regard to attorneys.
+
+
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+109
+THE COURT: Okay.
+MR. SCAROLA: Yes, sir, it does apply to gag
+orders with regard to attorneys. And the standards that
+are applicable, I suggest to Your Honor, clearly cannot be
+met under the present circumstances. And there is a
+complete and total absence of proof before Your Honor that
+we have engaged in any conduct whatsoever that could be
+prohibited under any circumstances.
+We have had the opportunity to appear on national
+television. We have had the opportunity to conduct
+extensive press interviews. We have had the opportunity to
+issue press releases. We have not engaged in any of that
+conduct. The press has taken a keen interest,
+particularly, the foreign press has taken a keen interest
+in this case and there have been a lot of articles that
+have appeared in the British press ever since a victim of
+MI. Epstein's has made public statements that have
+associated British royalty with Mr. Epstein.
+They have been very interested in what is going on in this
+case as a consequence of that. And we have had many
+opportunities to speak to the foreign press about these
+issues. We have scrupulously limited any response that we
+have made to contacts initiated by the press to matters
+that are matters of public record and available to the
+press by going to the courthouse and reading this Court's
+
+
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+110
+file.
+If MI. Epstein is embarrassed by Mr. Epstein's
+conduct, that's Mr. Epstein's problem. And, quite frankly,
+I'm pleased to hear that he's embarrassed by his conduct.
+Maybe it will serve some deterrent effect in the future on
+Mr. Epstein. And if this case and what Mr.
+has
+been through serves the purpose of increasing Mr. Epstein's
+embarrassment over MI. Epstein's misconduct, that's great.
+I will tell you that the focus of public attention on
+this case has served the interests of my client because it
+has produced witnesses that we otherwise might not have
+known about. And I welcome further public scrutiny with
+regard to this case for that reason because it will aid,
+ultimately, in the pursuit of justice.
+We object to any restraints. I will tell you that
+once this case is set for trial we will scrupulously avoid
+participation in any public comments with regard to this
+case that could possibly interfere with our ability to
+select a jury because the last thing we want to do is
+interfere with our ability to get justice in this case.
+Thank you, sir.
+MR. ACKERMAN: Your Honor.
+THE COURT: Yes, sir.
+MR. ACKERMAN: Directing your attention to pages
+five and six here is the bar rule and it specifically is
+
+
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+111
+restricted to a lawyer shall not make extraditial
+statements that a reasonable person would expect to be
+disseminated that will have
+substantial likelihood of
+materially prejudicing an adjudicative proceeding.
+THE COURT: Let me ask you this question.
+MR. ACKERMAN: And that's incorporated into the
+Gentile case, which you asked about earlier.
+THE COURT: Okay.
+MR. ACKERMAN: And --
+Op
+THE COURT: I'm not sure that a Florida bar rule
+provides legal authority for me under the constitution, to
+enter an order. I mean, it l
+y result in sanctions to the
+lawyer.
+MR. ACKERMAN:
+The bar rule, that's exactly what
+Gentile says.
+THE COURT: Tell you what, guys, I understand
+both sides of the argument here. What I need to do is go
+back and look at the cases. Do you all have them here?
+It's been a long time since I read the cases that --
+MR. ACKERMAN: May we submit them to you?
+THE COURT: No. I want to go back and take
+fifteen or twenty minutes and let me read the cases, make a
+decision. This is something you guys need to know right
+now because it's going to affect also what the court
+reporter does.
+
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+112
+MR. ACKERMAN: I don't have the Gentile case.
+THE COURT: You got the cite for me?
+is that
+one 501 US 1030. I got that one. I got the McIntosh case.
+MR. ACKERMAN: I have McIntosh and Florida
+Freedom Newspapers I can give you. I've marked them with
+notes.
+THE COURT: I think I can -- do you have any of
+these cases, Mr. Scarola?
+MR. SCAROLA: I don't have the cases themselves,
+your Honor. They are quoted in relevant part extensively
+in our memorandum.
+THE COURT: Let me take a look at
+these. I'll be
+right back. Okay.
+MR. SCAROLA:
+Thank you, sir.
+BREAK TAKEN) .
+THE COURT: Okay. And I apologize for taking so
+long. It's been awhile since I've read these decisions,
+quite frankly. And I had an opportunity to read the ones
+you've given me, as well as some that were actually cited
+in somé of the decisions cited after the ones you gave me.
+Seems to me in reviewing these cases that Supreme Court of
+Florida, as well as the Supreme Court of the United States,
+made a distinction between the Court's discretion in
+limiting comments by attorneys during or prior to a
+proceeding, as compared to the public's right to knowledge
+
+
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+113
+of trial proceedings, as guaranteed by the freedom of the
+press in provisions in the United States constitution.
+And, specifically, has held that prohibition on comments
+is, in fact, different from prior restraint. And the press
+has a right to print anything and we can't, or should not,
+restrain that except in the most extreme of circumstances.
+But the comments of counsel can be restrained.
+Having said that, it seems the Supreme Court has
+adopted, Supreme Court of the United States has adopted a
+lesser standard when imposing limitations on comments by
+counsel, as compared to any prior restraint of the press.
+And the standard which is set forth seems to be substantial
+likelihood of material prejudice and the Supreme Court of
+the United States said that is a constitutional permissible
+balance between the First Amendment rights of attorneys and
+the guarantee of a fair trial.
+Having said all of that, at this point I will deny the
+motion simply on the basis that I have no evidence in front
+of me that would establish that that standard, that
+comments by counsel or anything that counsel has said, done
+or would do, would have a substantial effect or substantial
+likelihood of material prejudice to this case at this
+point. I think that is an evidentiary thing that requires
+me to make findings of fact and facts on the case before
+you actually say, before you enter such a gag order you
+
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+actually have to make finding of fact that would support it
+before you can prohibit the comments as an acceptable
+alternative to any prior restraint. So I'm denying the
+motion on that basis at this point in time because I just
+have nothing in front of me other than this one motion and
+hearsay documents, which are attached at this point in
+time.
+MR. ACKERMAN: May it be without prejudice, Your
+Honor?
+THE COURT: , any ruling like this is without
+prejudice. Okay. But having said there, I would hope
+counsel, both sides, would understand the necessity for
+having a fair trial in this case.
+And one of the comments
+the Supreme Court made is that one of the reasons that the
+courts do have some restrictions on the attorneys, aside
+from them being officers of the Court, is sometimes their
+statements are taken more authoritatively than others. So,
+anyway, I'm denying the motion at this point and time.
+Let's talk about, I see nothing in the rules that
+would prohibit the press of obtaining a copy of this. They
+can be in here photographing and videoing this entire
+proceeding, as far as I know, without my permission.
+Couldn't they?
+MR. KNIGHT: Your Honor, the comment we made to
+the court reporter before is we haven't ever researched the
+
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+issue. She should check with her office.
+THE COURT: I'm not prohibiting it, is what I'm
+saying.
+MR. KNIGHT: I don't know what their normal
+standards are and we did not want to comment on it.
+THE COURT: Whatever she wants to do is her /
+choice. I'm not prohibiting the press from obtaining it,
+if they want to obtain copies of the proceedings, they can
+obtain it. I'm not entering any such order because it
+seems to me the cases also said the press is entitled to.
+I also point out that most of these cases were
+criminal proceedings. I've never seen a civil case where
+there has been a gag order/and, perhaps, there are. But in
+my twelve years, eleven years on the bench I've never seen
+one in this courthouse or heard of one but that doesn't
+mean it's not proper in the right circumstances..
+Okay.
+Having said that, let's move on. What's next?
+MR, ACKERMAN: Your Honor, that would be Three B
+and a.
+THE COURT: Three B and C. Okay. Go ahead.
+MR. SCAROLA: Your Honor, this is the defendant's
+motion for protective order and objections to a notice of
+deposition duces tecum addressed to the trustee, Herb
+Stettin, seeking a substantial number of e-mail
+communications exchanged between RRA. attorneys and
+
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+government officials and law enforcement officers. The
+objection is to relevancy first.
+There are ten thousand
+two hundred and fourteen pages of e-mails exchanged between
+RRA attorneys and government officials and law enforcement
+officers. And in light of the fact that there is no
+pending claim against Mr. |
+that discovery certainly
+couldn't be relevant or material to any pending claim
+against Mr.
+And in light of the allegations that
+we have made, there is no reasonable argument that could be
+made that that discovery is reasonably calculated to lead
+to admissible evidence with regard to anything having to do
+with the counterclaim.
+So in the present state of the pleadings no relevancy
+can be shown to the counterclaim. No claim is pending.
+The best way for Your Honor to handle this at this point is
+to grant our motion for protective order and if allegations
+are made in the primary complaint which arguably could make
+this discovery relevant, they can re-issue their subpoena
+and we 1l re-address it in the context of whatever
+allegations are then made: I can't imagine that they are
+going to make any allegations that could make this
+information relevant or material.
+The primary concern that we have is that if relevancy
+generally were determined, we need to review ten thousand
+two hundred and fourteen pages of e-mails in order to make
+
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+determinations as to whether there are appropriate
+privilege and work-product objections. We don't want to
+have to do that, so --
+THE COURT: Let the ask you what privilege of
+work-product objections would exist between a communication
+between the law firm and third-parties?
+MR. SCAROLA: The common interest privilege that
+existed between the prosecution of the civil claims and the
+criminal prosecution that was ongoing with regard to
+Mr. Epstein. The common interest, the common interest
+privilege could clearly cover both attorney-client
+communications and work-product.
+So there is potential
+privilege objections that need to be evaluated. There are
+potential privilege objections that need to be evaluated.
+But at this point there could be no possible relevancy as
+to those communications.
+MR. ACKERMAN: Your Honor, I think it's
+important, first of all, if you have --
+THE COURT: Let me stop:
+Somebody prepare an
+order on the, what. I just ruled. You don't have to write
+out all the details but just -
+MR. ACKERMAN: I will. Unless you want to do it?
+MR. SCAROLA: No, that's quite all right.
+THE COURT: All right.
+MR. ACKERMAN: Your Honor, I think it's important
+
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+to address this now even though you've dismissed the
+complaint because for these reasons, and let me show you.
+If you can take that packet that I gave you, I can
+demonstrate why this is relevant.
+THE COURT: What packet?
+MR. ACKERMAN: The packet of the documents that I
+submitted to you --
+THE COURT:
+,, okay.
+MR. ACKERMAN: -- that Mr. Scarola is Iooking at.
+THE COURT: Go ahead. I'm listening.
+MR. ACKERMAN: Okay.
+THE COURT: Aithough, I don't think I can get
+this thing open, it's sealed. Do you have a letter opener
+handy? Go ahead.
+MR. ACKERMAN: Preliminary basis I think it is
+unfair at this point to stop discovery while we amend the
+pleading as it relates to this claim. We will be able to
+prove and allege that Mr. Rothstein ran a Ponzi scheme.
+The e-mails that I'm going to show you here are e-mails
+that Mr. Rothstein sent to the investors using the Epstein
+cases.
+We have proved in deposition that the Epstein case
+files that Mr.
+was prosecuting were shown to these
+investors and their counsel. We can establish that the
+investigators that were working on Mr.
+• case
+
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+against Mr. Epstein were showing the law firm's case files
+to these investors.' We can show, we can make an amendment
+on the damages that will clear up the issues relating to
+damages.
+And I'm going to show the Court now the relevance of
+why on the overall claims, so the Court doesn't delay the
+discovery, but, specifically, the relevance with regard to
+this request and the inability at this point to deal with
+counsel's argument on a privilege.
+If you look at, I think it's the first document,
+01404. Okay. This is an e-mail from
+Adler to Brad
+copying Mr. Nurik and it relates to the
+non-prosecution agreement, which is in our complaint.
+MI. Adler is saying to Mr. Edwards that he had a great
+conversation with Mr. Nurik, who is another lawyer in the
+firm, about the agreement and they wanted me to discuss the
+possibilities. Now, this is an agreement that's already
+been entered into by Mr. Epstein and the government.
+Okay.
+That takes us out of the joint prosecution, joint
+defense argument that Mr. Scarola made. That also refers to
+the assets.
+Okay. We go to the next one, 01661. This is from
+MI.
+Mr.
+to Mr. Adler dated July 18th, 2009, where
+said to Mr. Adler. I want to talk to you about
+a few things. If we make the right moves we may be able to
+
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+force Epstein to settle for a lot of money but we have a
+couple of issues to deal with.
+The next one, 05087, deals with Qtask and that is here
+for two reasons. One, is to demonstrate to you why we
+still need those records down the road. But also to show
+how Mr.
+is using, the media to feature the firm and
+the Epstein case, which we believe was part of the Ponzi
+scheme.
+When you go to the next one, 07304, it's an e-mail
+from Mr.
+to MI. Kassel, who is another lawyer that
+is representing some of the victims in the crime victims
+rights act, where they say we have nothing more on moving
+assets. And that's in the first part. And down below,
+section three, he says I still think collection is going to
+ultimately be the key issue and they have lack of proof of
+transfer of assets. Now, in the federal court proceeding
+they filed a pre-judgment motion to prevent the transfer
+of assets, which was denied. And here they are
+acknowledging potentially their lack of proof of being able
+to do it.
+The next one, 00158, is from Mr.
+to someone in
+his firm directing her to send third-party subpoenas for
+prescription records, which weren't at issue and which we
+had placed in the complaint.
+The next one is, 08412, is where MI.
+is saying
+
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+to one of the secretaries requesting a meeting with Scott
+at some point to discuss Epstein. Now, this is
+particularly important now, and as I go through because
+Mr.
+has testified in his deposition that he only
+had a few, he had almost no conversations with
+MI. Epstein --
+MR. KNIGHT: Mr. Rothstein.
+MR. ACKERMAN: I'm sorry, Mr. Rothstein.
+you. Where an expletive deleted was used and claims
+Thank
+privilege on the other conversation.
+So then we have 01685. I'm sorry, I skipped one. Do
+you have the, -- there is one from Cara
+who is an ex
+FBI agent that is saying to Mr. Edwards, let's go -- I
+don't have it right in front of me because but you have it
+right there.
+THE COURT: I think our best bet is to go after
+the close friends.
+MR. ACKERMAN: Go after his friends. Which we
+contend supports our abuse of process claim.
+Then we go to 01685, which is Mr.
+MI. Fiston, one of the investigators of Mr. Jenny, who he,
+in his deposition, denies having this type of conduct with,
+and talks about audio monitoring and recording in the law
+firm. And that someone talking on the speaker phone can be
+recording that. Now, we've alleged in the complaint that
+
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+MI. Rothstein represented to these investors that he had
+high-tech electronic surveillance equipment in order to
+make this Ponzi scheme go.
+With regard to this motion specifically, 05112,
+Mr.
+is directing an e-mail to two investigators,
+MI. Jenny and Mr. Fiston and Mr.
+, is a third
+investigator, and Cara
+the lawyer we just
+mentioned, speaking to the U.S. Attorney. She said if we
+have proof of him being out of Florida, they will be in
+violation of the agreement and she will prosecute him. Her
+and the state attorney both called on probation. This is
+why we want to get these records because we believe that
+they were purposefully going out of their way in an effort
+to revoke his probation and this was subsequently a portion
+of something that was litigated before the federal court
+and found not to be accurate.
+05113 talks about serving Alan Dershowitz, which we
+discussed earlier.
+01406 is talking about taking Mr. Trump's deposition.
+And we can put those matters into the complaint, as you
+talked about earlier.
+01212 is the proposed subpoena for Dershowitz. And
+Alan Dershowitz was one of Mr. Epstein's criminal lawyers
+in the criminal complaint, criminal cases, and they're
+subpoenaing him for deposition in this case.
+
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+..Now, 26477 is a memo from Ken Jenny to Scott Rothstein
+advising him that the lawyers and investigators working on
+the Epstein matter are meeting on the twelfth floor at two
+p.m. to discuss where we are in the investigation. And
+this is crucial for a number of reasons because it provides
+one of the links, we believe, between Mr. Rothstein and Mr.
+through these investigators where Mr. Scott
+Rothstein is going to these meetings, learning what is
+going on and this is the same time period where he is
+pumping up his cases, these Epstein cases to these
+investors, which we'll show in subsequent e-mails.
+Okay. Now, we begin the e-mails that Rothstein,
+MI. Rothstein is sending to the various investors.
+A. J. Discala is one of the investors. And then if you go
+to 27303, Mr. Rothstein is sending out to |
+Priam who I
+believe is one of the investigators, we have no money in
+for this client,
+She left screaming. This is really bad.
+We can lose the entire plaintiff's group, which we believe
+related to Mr. Epstein's cases.
+If you 100k at 04996, again we have another meeting
+for Mr.
+to the number of people that were involved
+to discuss this matter on October 22nd, 2009.
+Mr. Rothstein in 26817 says I cannot have this blow-up
+in my face. These clients talk to each other. If I burn
+this client, I can end up losing all my clients in the
+
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+Epstein case. And this is occurring within the same day
+that these people are meeting to discuss the case.
+If you flip over to 26335, Mr. Rothstein is sending
+the e-mail to A.J. Discala, Clockwork, an investor,
+Kretschmer, who I mentioned, and
+Priam and at the
+last sentence he states my client clearly feels I have lied
+to her about her funding. She is one step away from going
+to another lawyer and the Florida Bar.
+The next one 02992, we have another meeting going to
+all of these people in the law firm.
+Okay.
+And then 27013 we have the documents of the Epstein
+case that were in Mr. Rothstein's office.
+So we have, contrary to what MI. I
+has testified
+in the deposition, these documents establish that
+Mr. Rothstein conducted the Ponzi scheme with investors for
+the Epstein cases and unlike Mr.
+testimony,
+there's numerous meetings --
+MR, SCAROLA: I'm sorry to interrupt, Your Honor,
+but Mr. Edwards has never ever denied that Mr. Rothstein
+was engaged in a Ponzi scheme. And to tell this Court that
+he has testified in his deposition that that didn't occur,
+that's just false. I don't know what this is all about but
+what we're supposed to be talking about is whether the
+documents that were subpoenaed with regard to the federal
+government have anything to do with the pending
+
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+counterclaim and I haven't heard a word about that.
+MR. ACKERMAN: Your Honor, I have --
+THE COURT: Let's do kind of focus in on the
+issue here.
+MR. ACKERMAN: I will. The point of this was to
+establish the parameter from which we made the request to
+show the relevancy of it. The point I'm trying to make,
+with Mr.
+is that he testified there was a limited
+number of people involved in the prosecution of this case
+against MI. Epstein when these documents clearly show that
+that's not the case. So we have requested, because we
+believe at the time they get the non-prosecution agreement
+that deal is over with, there is no basis at all to assert
+a joint privilege claim.
+Instead what it appears to be is
+that they are looking to try and interfere with the
+non-prosecution agreement. And so, we, because that part
+of our theory of our case, if you go to the subpoena,
+Exhibit 1, we have listed all e-mail communications between
+the attorney and employee of this Rothstein firm, which
+list these people, which we believe were involved with it
+and we specifically list the U.S. Attorney, the State
+Attorney, the Federal Bureau of Investigation, the Palm
+Beach Police Department. and any investigator working foI
+the state of Florida and anyone that represented an
+individual with a claim. Now, if you go to --
+
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+THE COURT: Wait a minute. Where is the --
+MR. ACKERMAN: If you go to my response.
+THE COURT: I'm looking at your response.
+Okay.
+MR. ACKERMAN: Okay. Under the one.
+THE COURT: I got it. One.
+MR. ACKERMAN: Next page Schedule A is the
+MR.. KNIGHT: Let the judge catch up with you.
+MR. ACKERMAN: I'm sorry. Schedule A has the
+documents subpoenaed.
+THE COURT: Okay. Go ahead.
+MR. ACKERMAN: If you go to Exhibit 2 in response
+to an e-mail from Mr. Litman, who is the attorney for the
+bankruptcy trustee, we gave him the specific names for a
+specific search for this subpoena. As you can see, there
+are lawyers in the U.S. Attorney's office. There are
+people in the Palm Beach Police Department. There are
+people in the FBI.
+And there are people in the State
+Attorney's Office. If you go to Exhibit 3, this is
+MI. Ditman's response. He talks about refined e-mail
+search, which sought documents reflecting the
+communications between RRA lawyers and government
+officials, which, if not all, are law enforcement officers.
+He has a disc of those documents that are responsive and
+that are
+stamped.
+THE COURT: Where is that?
+
+
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+MR. ACKERMAN: That's Exhibit 3 to my response.
+THE COURT: Okay. Go ahead. Really, focus in on
+the issue as to relevance, at this point and time.
+MR. ACKERMAN: The relevance is, Your Honor,
+first of all, we believe that part of this Ponzi scheme was
+designed to do things to Mr. Epstein so that Mr. Rothstein
+could tout those things to these investors to increase the
+amount of money that they were investing. In our amended
+complaint we went through the things that he told the
+investors. That they had the eavesdropping equipment --
+THE COURT: This is, this is the government.
+This is the government, not the investors. It's not
+communications with the investors. What are you, you
+looking for any communications between U.S. Attorneys,
+police and these people? How -- I mean.
+MR. ACKERMAN: Because we believe there was an
+effort to torpedo this non-prosecution agreement. We
+believe that they were taking steps to cause a breach or
+get the government to revoke it after Mr. Epstein had
+agreed to it. We believe that that is an abuse of process.
+Subpoenas in those civil cases --
+THE COURT: Let me get this straight. Are you
+saying that an alleged victim of a crime has no right to be
+involved in or to petition the government or even to
+suggest to the state attorney or anybody else that what
+
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+they're doing is contrary to their interest and get it.
+revoked, you think that is an abuse of process?
+MR. ACKERMAN: When the agreement has already
+been made. Okay. Your Honor, and this is, this was an
+agreement that was reached. Okay. And they're attempting
+to undermine the agreement.
+THE COURT: I'm having trouble here. You're
+telling me or you're suggesting that a victim cannot, go to
+the government, even after a reached agreement and say, you
+know, this is bad. I didn't have the input put into it or
+whatever the reason they think it shouldn't be existing, I
+mean, isn't that --
+MR. ACKERMAN: Your Honor, first of all --
+THE COURT: You think that's an abuse of process?
+MR. ACKERMAN: We're not talking the victims.
+We're talking about RRA doing this. And not only that, we
+won't know until we get them to see whether they're related
+to the victim or related to this case. You don't have to
+do an in camera review. We can look at the documents and
+determine whether they relate to a victim. They're still.
+not privileged. They're going to third-parties. We don't
+have a privilege issue here. If he is advocating a case on
+behalf of his victims, there is no privilege. He's
+potentially in an adversary situation and there is a
+present adversary proceeding involving this crime, which I
+
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+have placed in this complaint. But if he is advocating
+that, then there is no privilege and we should be able to
+1o0k at those documents to see if, in fact, that's what
+they were doing or they were using it based on what I've
+given you to show that they were really trying to, to
+effectuate this Ponzi scheme.
+THE COURT: These are relevant to show what
+again? I'm really -- I'm sorry, I'm dense but
+MR. ACKERMAN: Your Honor, we believe that
+Mr. Rothstein, and we believe Mr.
+participated in
+this, undertook a number of things in the Epstein lawsuits
+that would assist them with the marketing of this .
+investment.
+One of the things we believe they did was to proceed
+to interfere -- to proceed to destroy this non-prosecution
+agreement that had already been reached between the
+government and between MI. Epstein. We believe that they
+undertook surveillance, for example, in order to effectuate
+thats
+We believe that had nothing to do with these cases
+that they were prosecuting against Mr. Epstein on these
+three people. We believe it was a concerted effort to
+attempt to have Mr. Epstein's probation violated. And if
+you look at the privilege 10g, there is a designation
+between Paul Kassel and Mr.
+I relating to violating
+his probation.
+
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+THE COURT: Is there already a privilege log
+regarding these? There is not, right.
+MR. ACKERMAN: There is a privilege log that just
+describes the subject matter of that communication. It
+does not relate to this document because the privilege log
+was not prepared with the documents we're talking about.
+THE COURT: Okay.
+So we don't have a privilege
+log?
+MR: ACKERMAN: Not related to these.
+THE COURT: Okay. I understand.
+Yes, sir.
+MR. SCAROLA: It is extremely frustrating to have
+counsel repeatedly talk about what he believes when his
+beliefs are neither relevant, nor, based upon facts and,
+indeed, are directly contrary to the facts.
+The crime victims right act complaint filed by
+Mr.
+was filed by Mr.
+• before Mr.
+ever had any association whatsoever with RRA and before he
+ever filed any civil action on behalf of his clients
+because his client victims were upset about the sweetheart
+deal that Mr. Epstein had gotten, he had every right, he,
+MI.
+I, had every right and, indeed, a responsibility
+to his clients to vigorously petition the government for
+the redress of what they perceived to be a serious
+grievance.
+To compound all of this, there is no complaint that is
+
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+presently pending. And when counsel repeatedly talks about
+interference with the non-prosecution agreement is part of
+the theory of our case, there is no case right now. They
+haven't stated a claim. And the only claim they attempted
+to state was an abuse of process claim, which has got
+nothing to do with tortious interference with a
+non-prosecution agreement.
+They, when repeatedly given an opportunity to relate
+this requested discovery to an effort to obtain evidence
+reasonably calculated to relate to the pending
+counterclaim, are unable to do it because it can't be done.
+Your Honor, respectfully, should grant our motion for
+a protective order. And if after they have decided what it
+is they want to try to sue Mr.
+for, they have
+restated another claim and they believe that evidence in
+the hands of the trustee with regard to communications
+between RRA attorneys and government officials and law
+enforcement officers is relevant and material to whatever
+new fabricated claim they attempt to state, we can come
+back before Your Honor and address it in that context.
+Thank you, sir.
+MR. ACKERMAN: Your Honor, may İ give a brief
+response?
+THE COURT: Briefly, yes, sir.
+MR. ACKERMAN: Again, when I went through these
+
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+documents I'm trying to give the Court where our inferences
+can be that can lead to discoverable information, okay.
+And I think for the Court to postpone this until we have an
+amended complaint when we have this information in front of
+us, which we believe shows a link to a set of patterns
+where they are talking about the non-prosecution agreement,
+where they're going after his friends, where there are
+numerous meetings with the whole firm at the time this
+investment. is being made, that that shows a plan and why
+this is relevant. And if the victims are adverse to the
+government, then they don't have a joint privilege. And I
+submit to you that these are relevant for what our ultimate
+theory of the case is going to be, which you can see, and
+what these documents that we have right here demonstrate.
+THE COURT:
+• Okay. What is the next one? All of
+these orders will be out by Friday, gentlemen, because I'm
+going - actually be out by tomorrow. So go ahead, what is
+the next one?
+MR. ACKERMAN: Okay. Your Honor, I would like,
+this one, Three D involves an amended supplemental motion
+based on, and to be able to compel MI.
+to answer
+questions at a deposition. One of the things, since we
+have a number of issues relating to privilege, that there's
+one thing that I would like to address in this deposition
+because it deals with a request to produce on another
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+motion that relates to damages, okay. If the Court can
+turn to Three C, Three D.' And I'm trying to save
+some time.
+MR. SCAROLA:
+May I make a suggestion to save
+some time? Mr.
+has been deposed extensively
+already. If there is any, any circumstance under which
+he's going to be deposed again, it, certainly, ought to,
+come after he knows what the charges are against him and
+not before.
+MR. ACKERMAN: With one exception, and the reason
+I'm asking now are the damages in their counterclaim. Okay.
+The damages in their counterclaim, he was asked
+extensively
+THE COURT: what are you asking me to do? Are
+you asking me to redepose him on this one question?
+MR. ACKERMAN: I'm willing to defer the
+deposition on this one issue to a time where it makes sense
+to address other issues. But I don't want this objection
+that he's made in the deposition to keep me, keep us from
+getting the information for his damages in the
+counterclaim, which we have not received and is a subject
+for another motion. They raised objections as to how much
+you were making. We asked him -- let me back up. If you
+до -
+THE COURT: If this is a production request, that
+
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+is the request what we're dealing with. I mean, seems
+nonsensical for me to decide questions in the deposition at
+this point until we know exactly who is suing who for what
+and then you can get them altogether at one time.
+MR. ACKERMAN: I can. The only reason I'm
+bringing it up is in the deposition we attempted to make an
+inquiry on financial parts that we believed were relevant
+to defending the counterclaim and he raised an objection of
+economic privacy. That is also raised in our request to
+produce.
+THE COURT: You can still do a request to
+produce, if that's what you want to do. I don't think we
+deal with it at the deposition stage.
+MR. ACKERMAN:
+so just defer this motion?
+THE COURT;
+I'm not going to, seems silly to me
+to order, unless you want him to, just to answer it by, if
+I grant it, answer it by way of interrogatory. I don't
+think you are going to like that.
+MR. ACKERMAN: Well, at some point we need to
+redepose him on the damages.
+THE COURT: My point being is if you're not going
+to accept an answer by way of interrogatories, then you're
+going to have to redepose him anyway. We're not going to
+do this today. Not that. It don't make any sense.
+MR. ACKERMAN: Okay. We'll defer and go to the
+
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+request to produce.
+THE COURT: Which one is that?
+MR. ACKERMAN: Okay. Four A. That also
+involves another issue. To simplify things at this
+point --
+THE COURT: Four.
+MR. ACKERMAN: We sent a request to produce.
+It's attached to the motion Exhibit 1.
+THE COURT: Again, you're dealing with privilege
+issues here, as well as other stuff, right?
+MR. ACKERMAN: Well, there are a number of
+objections here that don't raise privilege. Okay. We
+asked for, I believe, if you go to Paragraph Five of the
+motion refers to Paragraph Six of the request where we
+requested fee sharing agreements relating to the case. He
+has a counterclaim that seeks damages for, among other
+things, his reputation, interference with professional
+relationship, loss of value of time, required to be
+diverted from his professional responsibilities. So we
+believe the compensation relationship between Mr.
+and RRA and anything related to the Epstein cases should
+been produced. His objection to this number six says
+relevance, not reasonably calculated to lead to
+discoverable information, and there are no agreements with
+investors. But we were not asking for investor agreements.
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+we wanted the agreements between Mr.
+Rothstein.
+RRA, and
+THE COURT: It does ask for investor.
+MR. ACKERMAN: Pardon me?
+THE COURT: It says or investor.
+MR. ACKERMAN: Okay.
+THE COURT: And/or any other attorney or investor
+related to any aspect of any plaintiff's case.
+Not just -
+MR. ACKERMAN: Right. So he says that he doesn't
+have the investor ones but he hasn't produced the ones
+between
+RRA and Scott Rothstein.
+THE COURT: Okay.
+MR. ACKERMAN: Number nine, we ask for cost of
+payment that the Rothstein firm had against Mr.
+There's no privilege claim there. Pardon?
+• MR. KNIGHT: Against Mr. Epstein.
+MR. ACKERMAN: Against Mr. Epstein. I'm sorry,
+Your Honor. Okay. We felt that that was related to how
+the cases were being used. We believe that this Ponzi
+scheme was designed to raise money to fund these cases.
+Number ten, we ask for the documents received by you
+relating to the assertion of a lien by the trustee. Okay.
+Because that relates to his compensation on the Epstein
+cases, which is part of the damages of his counterclaim.
+Because in order to find out what he's been damaged, we
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+need to know what he was making at the firm at the time and
+how the compensation formula was set up and what he earned
+on the various cases.
+Number 22 is all documents that support your claim for
+damages. Okay. There is an objection to that that it's
+not determined. They can't formulate. He says they don't
+know what the damages are. Okay. So we need to get that
+information.
+THE COURT: Okay. Yes, sir.
+MR. SCAROLA: Not yet determined is not an
+objection, it is an answer.
+The only argument that was
+made that relates to relevance to the pending counterclaim
+is evidence with regard to damages claimed by MI.
+Mr.
+RRA. RRA has folded.
+is not claiming that he lost any income from
+It went into bankruptcy. It folded
+and went into bankruptcy as a consequence of
+Mr. Rothstein's criminal activity. We do not blame
+Mr. Epstein for the destruction of the law firm and any
+economic loss that resulted as a consequence of the
+destruction of the law firm to Mr.
+Therefore,
+that line of inquiry is irrelevant and immaterial.
+What we have alleged is that Mr.
+has been, and
+continues to be, diverted from other income producing
+activity as a consequence of the prosecution of these
+spurious claims, whatever they may ultimately wind up
+
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+being, but what they have been up until now, as well,
+including the need to defend against Florida RICCO claims
+that no longer exist, and civil remedies for criminal
+activity claims that no longer exist against him, that his
+attention was diverted from other income producing
+activities as a consequence of the need to defend against
+this case. That's
+, got nothing to do with how much money he
+made historically, if anything, from RRA.
+MR. ACKERMAN: Your Honor.
+THE COURT: What about the idea that past
+performance is a predictor of future performance in terms
+of --
+MR. SCAROLA: We're talking about the lost value
+of the time, that's what we're talking about.
+THE COURT: I understand that. But how do we
+measure his time?
+MR. SCAROLA: Because he's got a standard hourly
+rate.
+THE COURT: Okay. But, I mean, it's like
+somebody saying, well, I can no longer detail cars and I
+make X amount of dollars detailing cars but you've been
+doing that work for twenty years, can't you find out what
+you did before.
+MR. SCAROLA: Well, I don't think that's an
+accurate analogy. In the case of an attorney, as I think
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+it was
+Lincoln observed, what we have to sell is
+our time. And there is only a finite amount of that time.
+Regardless of what Brad
+may have made from other
+sources historically or prospectively what he may make in
+the future, he lost time that could have been devoted to
+other income producing activity. What probative value does
+it have to know, for example, that in 2010 Brad Edwards,
+made $5,000 and in 2011 Brad
+made $20,000, if Brad
+could have made $25,000 in 2011, if he wasn't
+obliged in 2011 to be sitting in this courtroom all day
+today as a consequence of having been sued for purposes of
+putting him in this courtroom instead of enabling him to
+make a living.
+So I don't know how you draw any reasonable inference
+. from that other information. Would it be relevant to know
+what his standard hourly rate is, yes. Would it be
+relevant to know how much time he has had to devote to this
+case, those would be relevant and material inquiries. But
+how much he made from other sources is so dependant upon
+factors that are entirely independant of the damages
+claimed in this case, that they have no relevance and
+materiality. And, certainly, in conducting a balancing
+test, when they don't have probative value and we weigh
+against the absence of probative value the invasion into
+his economic privacy, I suggest to Your Honor that the
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+outcome of that balancing test ought to be, I'm sorry, you
+don't get it at this point. There just isn't enough here
+for you to get it on the basis that he has told you that
+what he has lost is his time and the value of his time.
+MR. ACKERMAN: May I respond?
+THE COURT: Yes, sir, just one second.
+But if he
+couldn't sell his time before, I mean, like you say,
+I just
+keep getting back to the fact that if his time was not
+productive or he couldn't sell his time before, I don't
+know what he made with this law firm.
+It may have been a
+lot of money, it may have been nothing., I don't know. How
+could we say that's not, at least, calculated to lead to
+admissible evidence in this case as compared to what the
+potential value may be.
+MR. SCAROLA:
+relevant question.
+That, Your Honor, would be a
+His ability to productively use his
+time in the past would be relevant. But Brad is primarily
+a plaintiffys lawyer. That's principally the work that he
+does and has been doing. Your Honor knows that this year's
+productivity is a consequence, or potentially a
+consequence, of effort that was made and begun five years
+earlier.
+THE COURT: Let me suggest to you, I've had cases
+where the plaintiff in a personal injury case was a
+practicing attorney. And they claim as a result of the
+
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+injuries sustained in the accident they're unable to work
+like they were and, therefore, have lost earnings or
+ability to earn money in the future as a result of the
+physical limitations, injury or whatever it is. I can't
+imagine in that kind of case the attorney could come and
+say, well, you can't find out what I made before this,
+injury because that's not relevant to what my time is worth
+today.
+MR. SCAROLA: I absolutely agree with you. In
+that kind of case, I think that, I think it is a relevant
+and material inquiry. But let's assume those same set of
+circumstances and the attorney says I was, as a consequence
+of my injury -- I'm a lawyer who works on an hourly basis
+and as a consequence of my injury I missed two weeks of
+work. Or I work on a salary and I missed two weeks of work
+and this is how much I get paid and I didn't get paid for
+that two week period of time. All you get --
+MR, ACKERMAN: Your Honor.
+THE COURT: Wait a minute.
+MR. SCAROLA: All you get in terms of discovery
+is what you need to know for what the value of that time
+was. That's all you get. And you don't get to know what
+he was making five years earlier at a different law firm or
+what he may be making today because that's not relevant to
+the loss that he had during that limited period of time.
+
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+And that's what we're saying, what Brad
+has lost is
+the value of that time that has to have been devoted to
+this case as a consequence of his having been the victim of
+an abusive process.
+MR. ACKERMAN: Your Honor, I've attached the
+interrogatory answers. We've asked him what the amount of
+the damages alleged to be, it's in excess of one million.
+They have said emotional distress, mental anguish, which
+I'm not sure is a claim that can be brought.
+But he's
+asked for loss of reputation
+and standing in the community.
+Loss of value of time spent in defense and in responding to
+this process. In the counterclaim he talks about damages
+to his reputation, interference with professional
+• relationships, loss of a value of time. We can't begin to
+make that evaluation for the amount of money that's claimed
+without being able to look into what relationships he had,
+what fee agreements he had, what money he made so that we
+can determine whether, in fact, he has been damaged by this
+or by something else that's happened in his life. And one
+of the ways we can do it is by looking at what his
+compensation plan was. What agreements he had with the
+firm. What he had with referral lawyers so we can
+establish whether there has been, in fact, an interference
+with these professional relationships and find some way to
+get to this million dollars which they are claiming and
+
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+that we now have to defend. So it is relevant and likely
+to lead to relevant information.
+THE COURT: Okay. What about the -- I don't know
+if you mentioned this, Mr. Scarola, the documents
+evidencing cost and payments of bills and the trustee lien
+for attorney's fees and costs?
+MR. SCAROLA: Couldn't have any relevancy at all
+to the pending counterclaim and there is no pending claim.
+THE COURT: Okay.
+MR. ACKERMAN: Your Honor, that goes to, what,
+ultimately, there is going to be a number of factors that
+make up what
+salary was and what he made and where
+it came from. Okay. And if he didn't actually net money
+from the cases but it had to go to the trustee, that may
+affect the calculation and the number. And what we're
+trying to do is make a determination as to the overall
+impact on his ability to earn money and anything that
+relates to what the fee is, what the costs were, or
+affected his income and his relationships is relevant.
+THE COURT: Okay. What is next? I'll tell you
+what, I'm going to have to take a short break. You can
+stretch your legs, as well. Tell me which one is the next
+one.
+MR. ACKERMAN: Hold on a second, Your Honor. I
+guess the next one would be the protective order relating
+
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+to the deposition of the plaintiff and a motion to compel
+relating to the plaintiff. And then we have some
+objections to request to produce that each has lodged
+against the others.
+MR. SCAROLA: We don't want to redepose
+MI. Epstein until after the new complaint is filed.
+can be deferred.
+That
+THE COURT: Okay. So which motion you want to
+hear next?
+MR. ACKERMAN: Hold on a second.
+THE COURT: You all figure it out and I'll be
+back in a few minutes.
+MR. SCAROLA: Thank you, sir.
+(BREAK TAKEN)
+THE COURT:
+Thank you. I wasn't back there
+twiddling my thumbs. Unfortunately -- not unfortunately.
+Fortunately, I'm going on vacation Friday to see my
+grandchildren. And needless to say it always happens,
+there is all of these emergency motions that are filed that
+have to be ruled on by Friday so I was dealing with one of
+our laws clerks on issues I've never heard before in my
+thirty-five years practicing law.
+MR. SCAROLA: Law clerk?
+THE COURT: We have law clerks. We have to share
+the law clerks but we have law clerks. Okay. Which one we
+
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+doing now?
+MR. SCAROLA: Three G.
+THE COURT: Three G. Okay.
+MR. ACKERMAN: It's really in relation to Three G
+and H.
+THE COURT: Okay.
+MR. ACKERMAN: Okay. If I could also ask the,
+Court to flip over to J. Just keep your finger there.
+We
+filed -- basically, what had occurred, is that Mr. Scarola
+re-noticed MI. Epstein for deposition, for video deposition
+on April 13 of this past year. Now, I communicated with
+Mr. Scarola to find out what the nature of the deposition
+was going to be about since he had testified extensively
+already in deposition.
+Mr. Scarola's response was that he
+was going to go into inquiry relating to public statements
+made by the plaintiff regarding his criminal activity, any
+documents supporting - he was going to take the position
+that the plaintiff had waived his Fifth Amendment right.
+He had taken the position that he had lost his Fifth
+Amendment rights by operation of law and that was the basis
+of the deposition. So I sent a request to produce out,
+which is in J, based on that and received objections to all
+of those matters. So we filed a motion for protective
+order based on the grounds that he had already been
+deposed. That no meaningful grounds had been alleged to
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+justify taking another deposition. Particularly, on the
+grounds that he had waived his Fifth Amendment and we had
+sought the discovery to find, understand the basis of that
+so we could understand why we were being, my client was
+being deposed again. And we had also requested in this
+motion that it not be a video deposition. And the reason
+why we were requesting that it not be a video deposition is
+particularly meaningful in light of the discovery request
+that this Court is about to rule on where he may be asked
+several questions of a specific sexual nature that then are
+placed on videotape on and then goes into the public domain
+and the prejudice to that is incredible and should not be
+allowed. So we filed this motion. We advised counsel that
+unless, we had to have a hearing on this, and that before
+he could be redeposed on this new information we needed a
+hearing. So we advised him in advance. Mr. Epstein, we
+also, I think, had a problem with a date but he did not
+appear for the deposition so Mr. Scarola has filed a motion
+to compel and for sanctions not to appear.
+›And so our position, basically, is that the grounds
+that he sought to depose him on that we were advised was
+not appropriate. And that we did not, particularly, we had
+a good faith concern, in light of the discovery that he was
+attempting to take, of the vast information into prior
+sexual issues, that those become, be placed on a video
+
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+deposition and then become something in the public domain.
+THE COURT: Are you asking me to prohibit the
+deposition, prohibit the video deposition or prohibit or
+require him to produce the documents? I'm not sure. Or
+all of the above?
+MR. ACKERMAN: If he's going to depose him on the
+Fifth Amendment, I want the documents that allege that that
+was, that that was done. I think that's a reasonable
+request. It's a subject that he's claimed numerous times
+that that has occurred. And before any deposition occurs
+on that we want the documents that establish that.
+Secondly, we felt that he should not be deposed on
+that, on that issue because all it would do -- I mean, he
+had already been extensively deposed. And he, Mr. Scarola,
+needs to come in and establish why he wanted to
+take his
+deposition again and that's not in his motion to compel for
+sanctions.
+forth.
+And that needs to be presented to the Court and
+approved before any sanctions of order compelling is set
+And third, I can't, the rules allow a video deposition
+but the Court can make restrictions on how it's used.
+And our concern in this case, as I articulated before, that
+if we end up going down this rabbit trail of this, the type
+of discovery that they have asked for, the sexual nature,
+and then that is on a video deposition and it can then be
+
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+placed on the Internet, we need to have a hearing on that
+so that the Court can place some restriction on the use of
+that so there is no unfair prejudice and we can't do that
+at this point in time. So that was the basis of the
+motion.
+THE COURT: Yes, sir.
+MR. SCAROLA: This was a dually noticed video
+deposition. Counsel has acknowledged the fact that there
+were communications about the scheduling of this deposition
+and what we intended to do. While a motion for protective
+order was filed on April 8 of 2011, no effort was ever made
+by the plaintiff to set the motion for protective order for
+hearing. They just unilaterally chose not to show up.
+There's a certificate of non-appearance. We had a court
+reporter present we were there. We were ready to proceed
+and they simply did not appear.
+Mr. Epstein has made numerous public statements to
+reporters. And his denials about having engaged in
+misconduct with minors have been reported. I want to ask
+him about those public statements that he has made.
+I want to know whether the reports of those public
+statements are accurate or not accurate. I want to know
+what the denials are based upon. I want to know whether he
+admits having spoken to these reporters or denies having
+spoken to them at all. All for purposes of determining
+
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+whether there, in fact, has been a waiver of his Fifth
+Amendment right to remain silent. Because he cannot choose
+to remain silent when he is deposed but speak to every
+court reporter who he can get in front of to tell them this
+is all silly because I really didn't do anything wrong.
+THE COURT: You said court reporter, I don't
+think you meant.
+MR. SCAROLA: I meant reporter, not court
+reporter, you are correct, Your Honor. There is,
+obviously, significant evidentiary value to having these
+depositions recorded on video for purposes of later
+presentation before a jury. The Florida Rules of Civil
+Procedure recognize that value.
+And the concerns that
+MI. Ackerman has, if they need to be addressed at all,
+certainly, don't need to be addressed by a prohibition of
+the videotaping of the deposition, which while he
+appears to be backing off from that now, is what his motion
+asked for.
+We are entitled to take a video deposition. As I've
+told Your Honor, I don't want to do it until after I know
+what the new allegations are in the new complaint. We
+didn't have a new complaint as of the time of this request
+for deposition but I do now want to delay it until such
+time as the video deposition can be taken to cover all of
+the issues that are raised in the new complaint.
+
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+But I do want to be able to video it when we take the
+deposition.
+THE COURT: Well, I'm not going to rule on when
+you have to take the deposition. If I allow it, I'm just
+going to rule as to whether or not you're allowed to take
+the deposition --
+MR. ACKERMAN: Your Honor, may I respond?
+THE COURT: -- in the areas we're talking about.
+Second, whether or not you have to produce the documents
+you have requested.
+MR. SCAROLA: Let me address that, Your Honor.
+THE COURT: And third, whether or not it can be
+by video and, if so, what restrictions I put on any video
+that's done.
+MR. SCAROLA:
+Had this deposition gone forward,
+as it should have gone forward on April 13, I obviously
+would not have been obliged to respond to a request to
+produce in advance of that deposition. And the selection
+of particular documents for use during the course of the
+deposition is attorney work-product. I ought not to have
+to give this party a script of what he is going to be asked
+about in advance. I don't think I'm obliged to do that.
+Obviously, I'm not obliged to absent an order of the court,
+and if the court did order me to do it, I would do it. But
+İ don't think that I should have to give them a script of
+
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+what I'm going to be asking about in advance and that's,
+basically, what they're asking for.
+MR. ACKERMAN: Couple of things, Your Honor.
+This motion was filed at the time you were basically saying
+I need to have an all day hearing and we're going to defer
+any ruling on discovery and stuff until you get your hands
+around this case. And so based on the statements the Court
+made it was set for today and it would have been set in
+May, if we had reached it in May, but that's why it wasn't
+noticed because it was my understanding that you were going
+to, you needed to understand what the issues were before
+you could --
+THE COURT: Let's just deal with the subject of
+aspect not the procedural.
+MR. ACKERMAN:
+Okay. Secondly, MI. Scarola
+hasn't shown why he needs to be deposed again. He hasn't
+shown why these matters weren't addressed in the previous
+deposition.
+Okay. He has already been extensively deposed
+already and he hasn't met his burden to show that he's
+entitled to be deposed again on these issues, at least
+until -
+THE COURT: I understand the rule to be the
+opposite of what you just said. I understand the rule to
+not limit the type, scope of discovery unless it's shown
+that it's oppressive, burdensome. And that becomes your
+
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+burden, as I understand it, the way the rule reads.
+MR. ACKERMAN: I don't believe that's the case,
+Your Honor.
+THE COURT: I thought it states it doesn't limit
+it unless
+MR. ACKERMAN: But the case law does allow
+protection --
+THE COURT: True.
+MR. ACKERMAN: -- to a party that's already been
+deposed.
+THE COURT: I agree.
+MR. ACKERMAN: And that's my point. He's already
+been extensively deposed.
+THE COURT: But, I guess what I'm saying, maybe
+I'm saying the same thing by different, different wording.
+MR. SCAROLA: What has repeatedly been referred
+to as an extensive deposition is a series of MI. Epstein
+reciting a script provided to him by counsel about how he
+is asserting his Fifth Amendment privilege even though he
+would like to be able to answer my questions, but his
+lawyer has instructed him not to answer my questions and so
+I'm not going to answer your questions and it goes on for
+about three paragraphs.
+MR. ACKERMAN: Your Honor.
+MR. SCAROLA: And it's the same response we got
+
+
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+over and over and over again.
+MR. ACKERMAN: Your Honor.
+MR. SCAROLA: It was not an extensive deposition
+as to the merits of this case.
+And I have clearly stated
+why I need to redepose him because I believe he has now
+waived his right to Fifth Amendment privilege and I want to
+explore the basis for making that claim. And in addition
+to which he will have made new assertions for new
+affirmative relief at some point between now and thirty
+days from now and I want to ask him a lot of questions
+about every claim for affirmative relief he's making.
+MR. ACKERMAN: Your Honor, we keep going back to
+this. If you 100k at MI. Epstein's deposition, when he's
+asked questions about the abuse, what I'm going to call the
+abuse of process case, he answers those. What he has taken
+the Fifth Amendment on are all of these sexual matters,
+which we have contended have no bearing on this case.
+THE COURT: We're not dealing with that right
+now.
+we're dealing with the questions that he wants to ask
+him with regard to the fact that he may or may not have
+waived his Fifth Amendment privilege just by making public
+statements or discussing it with third-parties. That's --
+MR. ACKERMAN: Then I think, then I think he
+needs to come to this court and produce the documents to
+show that that has been waived before we have to undergo a
+
+
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+deposition about it. He had the opportunity to do it. He
+hasn't shown that he could have or would have been able to
+do it before. And at this point in time we've made a
+request for it. And the Court, I believe, in order to
+properly protect the parties from someone that's already
+been deposed is to determine whether, in fact, there is a
+prima facie basis for a waiver, otherwise, we're going to
+be arguing about it in the deposition.
+THE COURT: See, here's part of the rule I'm
+talking about. It says unless the Court orders otherwise
+and under subdivision C, which is protecting you against
+oppressive, et cetera, et cetera.) The frequency and use of
+these is not limited. I always understood you could take
+deposition as long as you are not abusing the system or
+otherwise subject to protective order because you're
+harassing, whatever the rules says here: I can get you the
+exact words:
+MR, ACKERMAN: But there is the case law that the
+court is aware of where if the party has already been
+deposed they have to come -- a party seeking to redepose
+• him has to show the basis. Now, he's --
+THE COURT: You got a case that says that?
+MR. ACKERMAN: I don't have it with me, Your
+Honor. I'm relying on my memory.
+THE COURT: I think that's an overstatement of
+
+
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+what these cases say. I think they say you can protect
+somebody against burdensome, harassment, oppressive,
+repetitive discovery. I don't see it says that you can't
+take more than one deposition.
+You can take five
+depositions if you're not going over the line. But, you
+know, certainly, if you want to give me a case that says
+that. Okay. Guys, that's going to have to be it because
+I, unfortunately, have to do a couple of orders back there
+that I got that man working on. I'll get these orders out
+by tomorrow for you. And then what I want you to do is
+contact my JA and I would hope, what I would like to do,
+and I know you all don't want to do it this way
+necessarily. I want to get a complaint out there that
+withstands the motion to dismiss before we go into all
+these privilege things.
+I just want to be able to know
+what the heck we're talking about and what the lawsuit is
+about. Because some of the things you've alleged in my
+view in the complaint at present may not fall within the
+area of abuse of process unless can you show me otherwise.
+MR. ACKERMAN: What I would like to do, your
+Honor, because I know the time is late, I would like before
+our complaint is due, to have a fifteen minute hearing, I
+don't think it will take longer that than, where I can put
+to the Court one area where I believe the privilege issue
+has been waived, and, that is, those documents that we are
+
+
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+arguing about here have been produced to a third-party.
+And I believe that that would then allow us to get the
+documents that are subject to the privilege and we can use
+that to prepare our complaint. The Court denies it, we
+still are on track. But it's very important because they
+have maintained. We have had six or seven months of
+litigation over these issues over privilege. You issue a
+stay to us that we can't go subpoena the trustee and then
+when they are faced with the choice of having to deal with
+it in the bankruptcy court they turn over the records that
+we are under confidentiality agreement with to a
+third-party without that confidentiality.
+THE COURT: Set your fifteen minute motion and
+I'll listen to that. But, otherwise, I want the other
+thing set, as well. Get/some time so we can go through
+this stuff, okay.
+MR. SCAROLA: And that is not, that is not
+delaying the thirty day period that they have to file their
+new complaint; is that correct, Your Honor?
+THE COURT: No.
+MR. ACKERMAN: I'm just asking it be done before
+the thirty days so I have an opportunity to, if you agree
+with me, to get those documents.
+THE COURT: You will prepare the orders on the
+motion to dismiss, on the motion for punitive damages, and
+ORANGE REPORTING 800.215.7991
+
+
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+on the issue about the pre-trial gag order.
+MR. ACKERMAN: Yes.
+THE COURT: I'll do the rest of these.
+MR. KNIGHT: Enjoy your vacation.
+Sounds like
+you need it.
+THE COURT: Well, yeah. Thank you.
+(Court adjourned 4:45 p.m.)
+A CERTIFIED COP'
+COPY
+NOT
+
+
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+158
+CERTIFICATE
+I, Kathleen M. Ames, RPR, Notary Public, State of
+Florida, was authorized to and did stenographically report
+the foregoing proceedings; and that the transcript, pages 3
+through 157, is a true and accurate record of my
+stenographic notes.
+I further certify that I am not a relative, ory
+employee, or attorney, or counsel of any of the parties'
+attorney or counsel connected with the action, nor am I
+financially interested in this action.
+Dated this 15th day of July,
+2011.
+NOT A
+KATHLEEN M. AMES, RPR
\ No newline at end of file
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@@ -0,0 +1,241 @@
+Filing # 66595023 E-Filed 01/16/2018 03:39:48 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+, individually, and
+L.M., individually,
+Defendant,
+COPY
+RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR PROTECTIVE ORDER
+AND IN LIMINE OF UNRELATED SETTLEMENT AGREEMENTS
+Counter-Plaintiff,
+J. L
+by and through undersigned counsel, hereby files
+this Response in Opposition to Jeffrey Epstein's Motion for Protective Order and in Limine of
+Unrelated Settlement Agreements, and as grounds therefor states as follows:
+Introduction
+One of the underpinnings of Epstein's malicious prosecution against
+was that
+had "fabricated," "manufactured" and "ginned up" his clients' claims against Epstein for
+the express purpose of supporting a massive Ponzi scheme. In furtherance of this patently false
+charge, Epstein alleged that the claims being pursued by L.M., E. W. and Jane Dow "were weak
+and had minimal value." Complaint at 9 42(h).' In fact, Epstein even sued one of his victims, L.M.,
+and charged that she was knowingly furthering Scott Rothstein's Ponzi scheme by seeking a
+'Allegations that the victims' claims were ginned up are replete throughout Epstein's maliciously-filed complaint.
+1
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 01/16/2018 03:39:48 PM
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+"multi-million dollar recovery ... which was completely out of proportion to her alleged
+damages." Id. at 9| 7. Thus, there can be no credible argument that Epstein has not put at issue the
+amounts voluntarily paid by Epstein to settle these purported "weak" claims.?
+suit against
+Argument
+Epstein's motion once again ignores a critical fact: this is his lawsuit. Ep
+chose to file
+and built the playing ground on which the parties must litigate. The only
+remaining claim is
+malicious prosecution counterelaim, which is premised on the
+assertion that Epstein lacked probable cause to file the underlying complaint. Thus, when Epstein
+argues that evidence of settlement amounts related to L.M, E. W. and Jane Doe's cases are not
+relevant, he defeats his own argument by haying put the value of their cases at issue. And, while
+evidence regarding settlement amounts is admittedly highly prejudicial to Epstein's ability to
+support his fabricated claims against Edwards, that prejudice is neither unfair nor unjust.
+A. The Timing and Settlements Paid to L.M., E.W., and Jane Doe are Relevant under a
+401 Analysis?
+2 The Court has previously ruled that the number of claims that Epstein was facing at the time he initiated, and during
+his continuance of, this proceeding against
+, and the significant financial exposure related to those claims, is
+admissible (although the details and merits of the claims may not be disclosed without further Court order).
+3 While
+asks the Court to permit him to introduce evidence of the settlement amounts and date of each
+settlement, at this time
+does not intend to introduce the settlement agreements between Epstein and L.M.,
+E.W., and Jane Doe. Epstein's trial strategy or subsequent rulings by the Court, however, could impact
+decision in that regard. For example, L.M.'s settlement agreement includes reference to the underlying claims brought
+against her by Epstein. Thus, it is possible that |
+may seek to introduce L.M.'s settlement agreement into
+evidence to rebut assertions made by Epstein at trial.
+2
+
+
+I adv. Epstein
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+As a result of the false charges that L.M., E. W. and Jane Doe's cases were "fabricated" and
+"had minimal value,"
+intends to introduce to the jury the individual settlement amounts
+received by L.M. ($1,000,000), E. W. ($2,000,000) and Jane Doe ($2,500,000), and well as the
+dates that the cases were settled (2010). The relevance and probative value of these facts is
+straightforward: they will help assist the jury in determining whether Epstein was motivated to sue
+as a means of attempting to evade liability to his victims, whether Epstein had probable
+cause to believe that the cases were "fabricated" and "weak" at the time he filed the lawsuit, and
+whether Epstein had probable cause to continue his
+licious prosecution for another two years
+after the settlements were reached. See § 90.401, Fla. Stat.
+The settlement amounts paid to Edwards' clients are particularly relevant and material to
+Epstein's motive to file this baseless lawsuit.* Epstein knew at the time he filed suit that
+clients' claims were exceedingly strong and represented a great risk of significant financial
+exposure, whether via settlement or through a compensatory and punitive damage verdict. Epstein
+therefore filed this lawsuit in order to intimidate
+and his clients, L.M., E.W. and Jane
+Doe, into cheaply compromising their valuable claims. Moreover, by suing the attorney
+representing the victims who had suffered the most, Epstein was sending a message to every other
+victim. If Epstein was willing to use his billions to sue children that he had molested 20, 30, or
+' Page 1 of Epstein's Motion for Protective Order details the contested factual issue regarding Epstein's motive:
+has argued that Epstein's filing of the original civil proceeding against
+was
+motivated by a desire to silence [L.M., E. W. and Jane Doe] and possibly others. Epstein denies
+this motivation[.]."
+3
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+150+ times and their counsel, what else might he be willing to do to avoid an extended prison term
+and tens or even many hundreds of millions of dollars in damages?
+B. The Timing and Settlements Paid to L.M., E.W., and Jane Doe Are Not Subject to
+Exclusion Under a 403 Analysis.
+Epstein's claim that evidence related to the settlements of L.M., E. W., and Jane Doe is
+unduly prejudicial under a 403 analysis is baseless. "In order for relevant, probative evidence to
+be deemed unfairly prejudicial, it must go beyond the inherent prejudice associated with any
+relevant evidence. Relevant evidence is inherently prejudicial; however, it is only unfair prejudice,
+substantially outweighing probative value, which permits exclusion of relevant matters." State v.
+Gad, 27 So. 3d 768, 770 (Fla. 2d DCA 2010) (internal quotations omitted). Relevant evidence of
+Epstein's having settled claims brought by L.M., E.W., and Jane Doe is of course inherently
+prejudicial because it is at least Circumstantial if not direct evidence that Epstein lacked probable
+cause to claim that the cases were "fabricated" or "weak". There is however no unfair prejudice
+from this evidence, which is only relevant due to Epstein's false allegations that the three victims'
+claims were "fabricated," "ginned up," and "had minimal value." While the Court has
+understandably made efforts to sanitize the trial as much as possible, the values of the claims being
+pursued by L.M., E. W., and Jane Doe are at the very heart of this case and there is no unfair
+prejudice to admitting this relevant evidence.
+4
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+C. Evidence of Settlements Paid in Prior Cases is Admissible Under Florida Law.
+Finally, Section 90.408, Fla. Stat. does not bar introduction of the amount of settlement
+payments made to L.M., E.W, and Jane Doe because the settlements are relevant to an element of
+claim (in case two, lack of probable cause, and are not being used to prove Epstein's
+liability in the civil cases brought by those three victims (case one). As stated by the Fourth District
+Court of Appeal in Levin v. Ethan
+. Inc.:
+Although settlement offers are generally not admissible as evidence in the lawsuit
+in which the offers are made, an offer of settlement in one case can be relevant
+in another case.
+825 So. 2d 132, 139 (Fla. 4th DCA 2002) (emphasis added) (holding that the trial court erred in
+excluding settlement offers from case one under Section 90.408, because the settlement offers
+were relevant to contested factual issues in case two).
+For example, in Ritter v. Rifter, the husband to a divorce proceeding sought to include the
+value of his wife's pending personal injury claim as an asset in the parties' equitable distribution.
+690 So. 2d 1372, 1376 (Fla, 2d DCA 1997). In order to place a value on that asset, the husband
+sought to introduce evidence of the wife's offer to settle the claim with the at-fault party's
+insurance company. Id. The Second DCA reversed the trial court's ruling excluding that evidence
+under Section 90.408, because the settlement offer in the personal injury case (case one) was
+relevant to a contested factual issue in the divorce proceeding (case two and did not propose to
+settle any issue in that proceeding. See id. Thus, Section 90.408 did not bar introduction of the
+settlement amount offer in the divorce proceeding. Id.
+5
+
+
+s adv. Epstein
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+The value of the independent claims has been expressly placed in issue by Epstein's
+allegations in his maliciously filed Complaint. There is no better evidence of that value than the
+price he chose to pay to resolve those independent claims. These were not merely offers or
+demands, they are the final contracted prices for the settlements. Here we are speaking merely of
+"Offers" to settle.
+Similarly, the settlement amounts paid by Epstein are relevant both as to whether Epstein
+aro whether Epstein
+had an economic motive to extort
+;, to the extent of that motive, and as to whether Epstein
+had probable cause to file this malicious proceeding alleging. that the claims against Epstein by
+L.M., E. W., and Jane Doe were "fabricated," "ginned up" and "had minimal value." Moreover,
+the settlements paid by Epstein in the victim cases did not propose to settle any claim related to
+in this proceeding. Based on Levin and Ritter, the settlement amounts are therefore
+admissible.
+Conclusion
+For the foregoing reasons, the Court should deny Jeffrey Epstein's Motion for Protective
+Order and In Limine of Unrelated Settlements and permit
+to introduce the timing and
+settlement amounts paid to L.M., E.W., and Jane Doe.
+6
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve
+to all Counsel on the attached list, this 1e day of January 2018.
+DAVID P. VITALE JR.
+Florida Bar No.: 115179
+Attorney E-Mails): jsx@searcylaw.com and
+mmccann@searcylaw.com
+Primary E-Mail: ScarolaTeam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+(561) 383-9451
+Attorneys for
+J.
+NOT A CE
+NOT A
+7
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+COUNSEL LIST
+J.
+, Esquire
+staff.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+TIFIED COPY
+Nichole J. Segal, Esquire
+njs@FLAppellateLaw.com; kbt@FLAppellateLaw.
+.com
+Burlington & Rockenbach, P.A.
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+J.
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard
+Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Mare S. Nurik, Esquire
+marc@nuriklaw.com
+8
+
+
+Response in Opposition to Epstein's Motion for Protective Order and In Limine of Unrelated Settlements
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL
+, 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
+9
\ No newline at end of file
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@@ -0,0 +1,1986 @@
+•
+IN THE CIRCUIT COURT OF THE 15™H JUDICIAL CIRCUIT
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+CASE NO. 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+J.
+, individually and
+L.M., individually,
+Defendant(s).
+CIRCUIT CIVIL 6
+PALM BEACH COUNTY.
+SHAMUR BOCK. CL
+12 NOV - 8 AMI0: 54
+FILED:
+NOTICE OF FILING
+COMES NOW Jeffrey Epstein, through counsel undersigned, hereby notifies the Court that
+the attached is being placed in the Court File for review:
+Excerpt transcript of proceedings from October 25, 2012, copy attached hereto.
+I HEREBY CERTIFY that a copy of the foregoing was furnished via Email to all counsel
+listed below, this 2id day of November, 2012.
+NOT A
+FRED HADDAD, P.A.
+One Financial Plaza, Suite 2612
+'ort Laudergale, Florida B339
+Tel:
+Fax:
+By:
+Photo
+Florida Bar No. 180891
+Dee@FredHaddadLaw.com
+
+CLERKS OFFICE
+
+
+COUNSEL LIST
+Jack Scarola, Esq.
+E-mail: jsx@searcylaw.com & mep@searcylaw.com
+2139 Palm Beach Lakes Blvd
+West Palm Beach, Florida 33409
+Jack Goldberger, Esq.
+E-mail: igoldberger@agwpa.com & smahoney@agwpa.com
+250 Australian Avenue, South, Suite 1400
+West Palm Beach, Florida 33401
+Marc Nurik, Esq.
+E-mail: marc@nuriklaw.com
+One East Broward Blvd., Suite 700
+Fort Lauderdale, Florida 33301
+Bradley J.
+Esq.
+E-mail: bje.efile@pathtojustice.com & staff.efile
+staff.efile@pathtojustice.com
+D COPY
+425 N. Andrews Avenue, Suite 2
+Fort Lauderdale, Florida 33301
+Tonja Haddad Coleman, Esq.
+Lity
+E-mail: tonja@tonjahaddad.com & debbie@tonjahaddad.com
+315 S.E. 7* Street, Suite 301
+Fort Lauderdale, Florida 33301
+Lilly Ann
+Esq.
+E-mail: Isanchez@thelsfirm.com
+1441 Brickell Avenue, 15" Floor
+Miami, Florida 33131
+NOT
+
+
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+IN THE CIRCUIT COURT OF THE FIFTEENTH
+JUDICIAL CIRCUIT, IN AND FOR
+PALM BEACH COUNTY, FLORIDA
+JEFFREY EPSTEIN,
+Plaintiff,
+VS.
+SCOTT ROTHSTEIN, individually,
+individuaily, and i.m.,
+individually,
+Defendants.
+Case No. 502009CA040800XXXXMBAG
+ORIGINAL
+EXCERPT TRANSCRIPT OF PROCEEDINGS
+DATE TAKEN:
+TIME:
+PLACE
+BEFORE:
+Thursday, October 25th, 2012
+1:30 p.m. - 2:23 p.m.
+205 N. Dixie Highway, Room 9C
+West Palm Beach, Florida
+David
+1, Presiding Judge
+This cause came on to be heard at the time and place
+aforesaid, when and where the following proceedings were
+reported by:
+Florida Professional Reporter
+Palm Beach Reporting Service, Inc.
+1665 Palm Beach Lakes Boulevard, Suite 1001
+West Palm Beach, FL 33401
+
+
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+APPEARANCES:
+For I
+SEARCY, DENNEY, SCAROLA, BARNHART &
+SHIPLEY, P.A.
+2139 Palm Beach Lakes Blvd.
+West Palm Beach, FL 33409
+By DARRYL I. L
+ESQUIRE
+Pro Se:
+LEHRMAN, P.L.
+JAPEE, WEISSING,
+425 North Andrews Avenue #2
+Fort Lauderdale,
+FL 33301
+By
+J.
+For Jeffrey Epstein:
+FRED HADDAD, P.A.
+One Financial Plazá,
+Suite 2612
+Fort Lauderdale,
+FL 33394
+By FRED HADDAD, ESQUIRE
+For Jeffrey Epstein:
+TONJA HADDAD COLEMAN, P.A.
+524 S Andrews Avenue
+Fort Lauderdale, FL 33301
+By TONJA HADDAD COLEMAN, ESQUIRE
+For Jeffrey Epstein:
+ATTERBURY, GOLDBERGER & WEISS, P.A.
+250 Australian Ave. South, Suite 1400
+West Palm Beach, FL 33401
+By JACK A. GOLDBERGER, ESQUIRE
+FISTOS &
+
+
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+DIRECT EXAMINATION
+BY MR.
+What is your profession?
+A
+Attorney.
+• At some point in time were you employed by
+the law firm of RRA, the way it's been called in this
+case?
+Yes, from approximately April of 2009 until
+what Mr. Haddad described as implosion around, I
+believe, November Ist, 2009, but possibly the day
+before.
+& And in what capacity were you employed by
+that firm?
+A
+I was an attorney. I was an employee there.
+And when you came to the firm, did you
+bring some cases with you where you were prosecuting
+some cases on behalf of some minor children against
+Mr. Epstein for him molesting them?
+A
+Yes. There were two different
+classifications of cases all revolving around the same
+issue. I filed them all around the same time in 2008.
+One, I represented -- ultimately I represented, I
+believe, 10 to 12 victims of Jeffrey Epstein. But
+while I was at RRA, I represented at least three files
+that were being litigated. I had filed those in 2008.
+
+
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+In addition to those files, I was
+litigating, and still currently litigating, another
+case on behalf of all of Jeffrey Epstein's minor
+victims against the United States Attorney's Office
+wherein the allegations are that the U.S. Attorney's
+Office improperly gave Jeffrey Epstein immunity from
+prosecution of the crimes against these victims in
+violation of the Crime Victims Rights Act.
+That
+case is currently pending in front of Judge Marra.
+Jeffrey Epstein has intervened in that
+case and
+certainly is interested in knowing the information
+that we have regarding those allegations.
+And if -- one of the things that we are
+asking for in that case is to overturn the immunity
+agreement which would open him back up to
+prosecution. Those causes were all being litigated
+while I was) at RRA, and the Crime Victims Rights Act
+case is still active today.
+Now, who was your supervisor at RRA, your
+direct supervisor?
+A
+Adler was the head of the personal
+injury tort division. He was in charge of the
+division, and that's the division that I was in.
+And did you have communications from time
+to time with Mr. Adler regarding these cases against
+
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+Mr. Epstein?
+A
+It was more than just from time to time.
+Adler knew what was going on with the cases, we
+had Epstein meetings where myself, former Judge Bill
+Berger, Russ Adler, other members of the firm would
+talk about Epstein, talk strategy about Epstein.
+mental impressions were out on the table, so to speak;
+discovery, strategy was discussed. Not only that, the
+intimate details of our clients was discussed. Things
+that all fall into the parameter of work product
+privilege and attorney-client privilege, and that's
+just in-person communication.
+l In addition to in-person communications
+with Mr. Adler on a regular basis regarding these
+cases, was there also a computer program at the firm
+called & Task?
+NO.
+e
+A
+• Yes.
+Can you explain to Judge I
+what & Task
+Yes.
+THE COURT: Say that again.
+MR.
+: l Task, I-A-S-K, Judge.
+Can you explain what that is, please?
+A
+Adler describes that program much
+better than I do. He was one of the creators of the
+
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+program, and it was a very good program. I only used
+it during the time at RRA. I think Russ Adler has
+described himself as an evangelist for the program.
+But it is basically a virtual boardroom for attorneys
+to communicate specifically back and forth, have
+meetings in a virtual manner so that you can discuss
+cases, details of cases, strategy on cases.
+And one of
+the projects -- actually, every case, I think, had a
+project within l Task. Certain people who would give
+impact or input on cases were invited to the project.
+Both myself and Russ Adler were on those projects,
+which means everything that I posted or Bill Berger,
+for instance, posted, or Russ Adler posted -- I believe
+those were the main participants in that project --
+would have access to literally everything that was in
+that communication device.
+Q
+Let's be very specific for Judge
+- Did
+the Epstein project have a l Task project associated
+with that case?
+A
+There was an Epstein project.
+• Was Mr. Adler also on the l Task list for
+that project?
+Yes. Meaning he had access to literally all
+of the privileged communications and privileged
+information, work product, attorney-client and
+--.
+- -
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+otherwise, all of it that I had access to, MI. Adler
+also had access to.
+• And can you explain to the Judge what it
+was for?
+A It was so that we could brainstorm, share
+ideas, discuss strategy, discuss discovery, discuss
+what was going on in the case, and we would not have to
+call formal meetings. We would communicate in a
+private manner about details involving any case going
+to that project.
+l Let's be specific about the Epstein case,
+which is why we are here to show that they have an
+unfair advantage by Mr. Haddad representing both
+Mr. Epstein and - go ahead. Just keep it to the
+Epstein --
+The Epstein case was one project that I
+communicated ideas in, Russ Adler communicated ideas
+in. I was handling the case; I was the primary
+A
+attorney. Any idea that I had to bounce off of any
+other attorney that was in this project, the other
+attorneys invited to that private project also had
+access to.
+So Russ Adler had access to literally all
+of my mental impressions going on that were in this
+private site. It is designed -- basically designed
+
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+and utilized solely for the purpose of sharing
+privileged information amongst lawyers in the law
+firm.
+Can you please share with the court whether
+or not you considered all of those communications
+with Mr. Adler and the other lawyers who were on that
+e Task project privileged?
+A
+Of course, so did Russ Adler,
+and, I believe,
+Mr. Haddad definitely won't dispute that.
+Now, from your perspective,
+are you
+concerned with respect to all of the communications,
+personal communications that you had with Mr. Adler
+in person where you were talking about the Epstein
+case, all the communications that you had on l Task
+that you considered privileged, that with Mr. Haddad
+representing Mr. Adler how that can give him a
+tactical adyantage in his representation now of
+MI. Epstein? Can you explain that to Judge
+please?
+A I am concerned because Russ Adler had access
+to all of the information I knew. Mr. Haddad
+representing Jeffrey Epstein would be no different at
+this point than Russ Adler representing Jeffrey
+Epstein.
+Jeffrey Epstein's lawsuit against me was
+
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+based exclusively on things that I did while at RRA.
+The allegations against Russ Adler had been made --
+similar allegations, but made by Scott Rothstein
+against Russ Adler.
+Mr. Haddad has the task of defending Russ
+Adler in those allegations. I am assuming any
+information that would help to acquit or defend Russ
+Adler, that Mr. Haddad could ask his clients about
+those things. And if it would assist in that
+defense then he certainly would. And certainly, all
+of this information that is privileged that Russ
+Adler has, he would have the ability to share with
+his attorney -- probably should share with his
+attorney so that his attorney can effectively
+represent him.
+And I have a problem understanding how
+Mr. Haddad could represent Russ Adler in the exact
+accusations related to his actions at the time that
+he was at RRA when Scott Rothstein is alleging that
+he was, in Scott Rothstein's words, deeply involved
+in the Ponzi scheme and a co-conspirator, that Russ
+Adler is saying are false; and how Mr. Haddad can
+represent Russ Adler against those accusations and
+divorce himself from the knowledge that he learned
+from Russ Adler so that he can represent Jeffrey
+
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+Epstein in this action without utilizing information
+he learned or could learn from his client.
+THE COURT: Let me -- I want to -- I'm
+confused. What lawsuit or claim is
+Mr. Haddad representing Mr. Adler in regards
+to allegations that he is involved in the
+Ponzi scheme?
+THE WITNESS: I believe that from the
+very -- Mr. Adler has not been charged.
+THE COURT: I am asking is there any
+pending either criminal or civil matter
+against Mr. Adler based upon allegations
+that he was involved in some way in this --
+you keep saying that he is defending him
+against these allegations. I want to know
+what case -
+THE WITNESS: I am sure that Mr. Haddad
+would be better able to explain this. But
+Mr. Adler was from the very beginning a
+target of a criminal investigation. He has
+not been cleared as of yet to the extent
+that I know.
+THE COURT: I understand that, sir.
+What I am asking you is -- I may have
+misunderstood. But I got the impression
+
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+here there is an active, pending litigation
+or criminal proceeding. And maybe there
+isn't. What you're talking about is the
+potential for some claim down the road or
+some possible criminal action or some sort
+of possible civil action, but anything
+pending right now, to your knowledge?
+THE WITNESS: I don't know.
+There was
+also an adversary proceeding, which I
+believe also settled where
+THE COURT: The clawback--
+THE WIINESS: Right, But other than
+that, I don't
+lly know.
+MR. LEWIS:
+Thank you very much, Your
+Honor. Just a few more questions.
+BY MR.
+Io put everything in context, you heard
+Mr. Haddad in his opening statement in response to a
+statement I made to the court in our opening
+statement how is he going to cross-examine Mr. Adler
+about information that may be adverse to Mr. Epstein
+and Adler in this case. And jou heard him say that,
+well, I probably wouldn't cross-examine Mr. Adler,
+MI. Goldberger would do that. You heard him say
+that, right?
+
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+A
+Yes.
+• Now, practically, if he's a co-counsel, I
+guess he's also representing Mr. Epstein, too?
+Yes.
+And Mr. Haddad is representing Mr. Epstein,
+too?
+A
+Right.
+Do you have a concern at all that all
+Mr. Haddad has got to do is say Mr. Goldberger, why
+don't you ask him this, don't ask this, that they can
+communicate things that you have asserted as
+privileged in our case that he knows from --
+MR. GOLDBERGER:
+Judge --
+THE COURT: This is not closing
+argument, counsel. Just ask the question.
+MR.
+: I apologize, Judge. I want
+to get|to the issue.
+THE COURT: Ask your question.
+BY MR.
+Are you concerned about that? And can you
+please explain to the court what your concern is?
+A My concern is that any privileged information
+that Mr. Haddad wants, if we invoke a privilege all he
+has to do is ask Russ Adler. That's my concern.
+That's it.
+
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+MR.
+Thank you, Judge. I don't
+have any other questions for Mr.
+right now.
+THE COURT: Cross-examination, sir?
+MR. HADDAD: Yes, sir.
+CROSS-EXAMINATION
+BY MR. HADDAD:
+correct?
+A
+• Mr. Adler is a very close friend of yours,
+That's true.
+& And Mr. Adler is the one who brought you
+into RRA, correct?
+That's true.
+And as a matter of fact, if Mr. Adler were
+to testify for you, he would be a character witness,
+would he not?
+I would think so.
+He considers you one of the finest lawyers
+around, does he not?
+A
+I believe so.
+He's expressed that to a number of people?
+A I believe so.
+• Do you think that Mr. Adler is going to be
+a witness adverse to you?
+A I think that --
+
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+Answer the question please, sir.
+THE COURT: Excuse me, sir.
+If you can answer the question, answer,
+but you can explain your answer if you can.
+A I don't know what that question means.
+e MI.
+1, you will concede that
+Mr. Epstein dropped his lawsuit against you,
+correct?
+A
+Yes.
+& And the only thing pending now is your
+lawsuit against Mr. Epstein, correct?
+A
+Right.
+& Would you concede that Mr. -- that RRA fell
+apart and the Feds came in from October to November
+of 2009?
+A
+I believe so.
+Would you agree that the files that were
+RRA files regarding Epstein were taken at that time?
+A
+Right, Russ Adler no longer had access.
+He had no access to l Task or anything,
+Q
+correct?
+A I don't know that.
+& Now, that was before I began to represent
+him, correct?
+A I guess so.
+Well, you would agree November 2nd was when
+
+
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+you guys were told this is it?
+A That's right. I just don't know when you
+started representing him.
+• On November 2nd you sent an email, as a
+matter of fact, to Mr.
+-- I can't say his name.
+Epstein's lawyer at that time, Cuman (phonetic) or
+something like that?
+A
+Okay.
+• And you asked him in an email if he would
+agree to reset the deposition because you had no
+access to files, your office or anything else,
+correct?
+A
+That's true.
+And you sent an email saying you were very
+surprised that he said no, correct?
+A
+I don't remember which' lawyer this is because
+it is a whole team of them. I don't doubt that this
+happened.
+Q
+Well, I think you filed a joint motion to
+continue on the 14th of November, 2009 setting forth
+that you had no office, no files, no ability to do
+anything, and therefore you would request that it be
+continued?
+A
+I don't remember doing that, but I don't
+quarrel with any of that because it is all true.
+
+
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+MR. HADDAD: May I show him a certified
+copy of the motion?
+A I am not disputing it. I haven't seen a copy
+in years.
+That looks like it?
+A Filed by Bob Crichton as a joint motion, yep.
+& Now, did you today get to review a copy of
+an affidavit by |
+Adler that I filed this
+morning by email?
+A I saw it.
+• And, of course, you are aware of your
+answer to Interrogatory 32 of the second set of
+interrogatories -- the third set of interrogatories
+to you, correct?
+A
+Am I aware of my answer to question
+Number 32?
+Yeah, where I put out there that you said
+in your answer to interrogatory that -- let me read
+It:
+Identify all attorneys who worked on the client
+cases against plaintiff-counter defendant Jeffrey
+Epstein, including, but not limited to the attorneys
+formerly at RRA, abbreviated, the attorneys of the
+former Jaffe -- that's your firm, correct?
+A Correct.
+- and outside attorneys and referring
+
+
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+, Paul
+attorneys. And your answer was: Brad
+Cassel (phonetic) -- that's the lawyer in --
+A Correct..
+• Matt Weissing, Steve Jaffe and Bill Berger
+rendered substantive services in the prosecution of
+the plaintiff Jeffrey Epstein.
+Adler was in
+attendance, you said, at multiple depositions, but
+was not an active participant, correct?
+A. All true.
+Adler did not actively participate
+in your case at all, correct?
+A
+Other than what you just described.
+• Now, is it not correct that none of the
+Epstein cases settled during the period of time that
+you were at RRA?
+A
+That is true.
+And you are aware, of course, that
+Mr. Rothstein said in his deposition that you
+attended with Mr. Scarola, that in fact you settled
+one of them that was part of the Ponzi scheme,
+correct?
+A
+I don't remember that at all.
+There's no question one of the cases
+settled?
+A
+No question about it.
+
+
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+And you were there for a grand total of six
+months?
+A
+At the most.
+• Six months at the most. You brought your
+files with you, you left with your files?
+A
+True.
+And you settled them later, correct?
+A
+Over a year later.
+Now, whatever work product
+-- and I don't
+know what work product you have or what you are
+talking about, you did have interviews with the Daily
+News, correct; for the reporter for the Daily News,
+regarding Jeffrey Epstein?
+A
+Over the last few years.
+A
+Even at that time, yeah?
+I believe so.
+You had an interview with a gentleman named
+Rush, George Rush?
+A
+I think Epstein had an interview with
+Rush.
+Yeah, and then you called the guy back
+after that and you had a conversation with him, which
+you filed an affidavit on, right?
+• A Right.
+And you used that affidavit and other
+
+
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+affidavits to make a determination of why you found
+it necessary to depose Bill Clinton, Donald Trump,
+Prince Albert -- was it Prince Albert? One of those
+guys, and all of those individuals, correct?
+A
+I didn't --
+THE COURT: Where are you going with
+this?
+MR. HADDAD: To show that every single
+thing that he claimed would have been
+privileged, he put out in affidavits and
+interviews that he gave to the press.
+THE COURT: That's going to be a neat
+trick if you don't know what he spoke to the
+press about.
+MR. HADDAD: I'm sorry?
+THE COURT: Go ahead.
+MR. HADDAD: Well, Russ Adler is going
+to testify and I think that will clear that
+up.
+THE COURT: Mr. Adler is not going to
+talk about attorney-client privilege
+communication he had with him, is he?
+MR. HADDAD: He's got an affidavit I
+can show the court.
+THE COURT: I have seen the affidavit.
+
+
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+I didn't see the emails. I'm not on your
+email list.
+MR. I
+: We did object --
+THE COURT: Just ask the question,
+okay. I was wondering where you were
+headed.
+MR. HADDAD: I'm sorry, yes, sir.
+BY MR. HADDAD:
+Op
+• You never had a conversation with Mr. Adler
+regarding Epstein until you got to RRA, correct?
+Correct.
+& And then when you were at RRA you advised
+him of these cases that you had, correct?
+What I advised him of, I believe, would be
+product privilege, which is the problem here.
+I am talking about the existence of the
+case which is public record, not any inner workings,
+all right?
+Okay.
+Did you not make the statement that Russ
+Adler learned about the case from the newspapers in
+your deposition?
+I might have.
+l You won't dispute that, correct?
+A No.
+
+
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+& Sir?
+I wouldn't dispute it.
+• Now, you have read Mr. Adler's deposition,
+correct, in this matter?
+A
+At some point in time I did.
+• You have read my response in opposition to
+the motion to disqualify me, correct?
+Yes.
+And do you disagree with Mr. Adler's
+assertions that he had nothing to do with the file
+and has no privileged information?
+A
+Which question are you asking, that he had
+nothing to do with the file?
+Do you agree with his assertions in his
+deposition that he had no privileged information or
+anything that was privileged regarding that case?
+I don't think he said that, so that's the
+problem. He invoked the privilege at the deposition
+where you represented him.
+& I understand that. He invoked every
+privilege he could in that deposition?
+A Right, implying that --
+My question to you is -- sir?
+A
+-- implying that he had privileged
+information, and that's all I'm --
+
+
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+I will let it go at that point.
+Do you have any -- you wouldn't, but okay.
+The claim that now exists is your claim
+for damages against Mr. Epstein, correct?
+A Yes.
+• And that claim for damages is for abuse of
+process, correct?
+That's one of the counts, correct.
+And the other is what, defamation?
+A
+Malicious prosecution.
+Malicious prosecution.
+Those are separate and apart from the
+claims that you have with the United States of
+America, correct?/
+A
+Separate claims from that claim?
+Yes.
+A
+Yes, they are separate claims.
+Y And you filed -- excuse me, Mr. Epstein's
+attorneys filed a lawsuit against you while you were
+actively prosecuting claims for the victims that you
+cited were of what occurred, correct?
+A That's true.
+• And that is where your inner workings were,
+involving the plaintiffs who have already settled,
+correct? They have all settled?
+
+
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+A. They have settled. The case against Epstein
+has settled.
+• That's what I'm saying. The case against
+Epstein has settled, the case against you by Epstein
+has settled?
+The case against you by Epstein has
+settled by his dismissal of the claims against you?
+A He dismissed the claim, right
+So the only thing remaining is the claim
+that you have against him?
+A
+That's correct.
+For malicious prosecution and for abuse of
+process?
+A
+As well/as the Crime Victims Rights Act.
+That's still ongoing.
+now, you made mention to the Judge of
+Mr. Adler's defense. Are you aware of anything that
+Mr. Adler has outstanding where I represent him?
+By outstanding --
+Well, other than -- let me put the caveat.
+I am sure you've read -- he may have an appeal of a
+30-day suspension by Judge |
+for a failure to
+sign an affidavit and a fraudulent mortgage
+application. But other than that, are you aware of
+anything against Mr. Adler with whom you are very
+
+
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+friendly?
+A I talk to Russ. Adler frequently. I know
+generally what he believes is going on with respect to
+Scott Rothstein's accusations. And I don't know
+exactly formally where that prosecution or potential
+prosecution is or if it will ever be. But that is the
+only thing that I know is ongoing that you have any
+role in representing him in.
+• Let me ask you this. Based upon your
+long-term knowledge and friendship with Mr. Adler, is
+there any doubt in your mind he would never breach a
+confidence and share anything with me?
+If he's --
+MR. LEWIS:
+Your Honor, how --
+THE COURT Excuse me. Please stop. I
+think you are asking for credibility. This
+is character reference. I don't think
+that's --
+BY MR. HADDAD:
+Okay, I will rephrase it. Do you have any
+information to remotely suggest that
+Adler
+has passed one bit of information to me?
+I would believe that Russ Adler will tell you
+all of the information that would assist you in
+representing him. And if the allegations against him
+
+
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+are that he was involved in a Ponzi scheme and emails
+would help to refute that, then I would hope that he
+would pass that on to you. But I don't know what he's
+given you, because I'm not involved in your
+attorney-client relationship.
+& Do you have any information that Russell
+Adler would in any way share any information with
+me -- share any information that's privileged with
+me, if there is any, regarding Jeffrey Epstein and
+this case?
+A
+He shares a privilege with you. So if it
+helped in his defense, he would and he could and he
+should.
+I am talking about the instant case.
+It's all related to the same subject matter.
+Do you have any information, even remotely,
+that Mr. Adler was involved in a Ponzi scheme?
+No.
+Did you ever hear any -- Mr. Adler has
+dénied from the first day that he had any knowledge
+of the Ponzi scheme, correct?
+A
+He has.
+& And he said the only way he found out about
+the Ponzi scheme was the same way you did, in the
+newspaper?
+
+
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+A
+26
+Correct. I have read that. I believe that.
+MR. HADDAD: I don't have anything
+else.
+THE COURT: Any redirect?
+MR. : Just real brief, Judge.
+REDIRECT EXAMINATION
+BY MR.
+Were you deposed in the case that's pending
+before Judge
+A For hours. Eight hours,
+sure.
+& And during the time that, you were deposed,
+did you have occasion to assert work product
+privilege to questions that Mr. Epstein's lawyers
+were asking you?
+A
+Yes
+And those questions that you were asserting
+privilege to, would Mr. Adler have access to that
+information that you were asserting privilege to?
+A
+I don't remember the specific questions, but
+he had access to all information that I had access to
+at RRA. He had access to the information.
+He wasn't the active attorney prosecuting
+the file, but through & Task he had access to all
+privileged information, yes.
+MR.
+: May I approach, Your Honor,
+
+
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+and show the witness one document?
+BY MR.
+• Mr.
+1. I am going to hand you a
+document, it's two pages. And first of all, can you
+tell the court what it is?
+A A string of emails that -- four emails that
+began October 13th, 2010 from one of
+Adler's
+other attorneys. By other, I mean other than Fred
+Haddad, and it is initially directed to Russ Adler and
+Fred Haddad. And it is asking:
+Russell, any idea what
+this is all about? It was in response to pleadings
+filed by Jeffrey Epstein's attorneys at the time in the
+bankruptcy case wherein they were attempting to gain
+access to privileged information, including emails at
+RRA, & Task information. It was a list. The court is
+familiar with that subpoena.
+My. Haddad apparently responds: Russ, I
+thought Sheer (sic), referring to Bill Sheerer, I
+presume --
+Explain to the court who Mr. Sheerer was.
+A
+Mr. Sheerer was representing some creditors
+in the bankruptcy proceeding, who were apparently a
+part of the purchase of fraudulent settlements that
+Scott Rothstein had made up out of thin air related to
+Jeffrey Epstein.
+
+
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+• And so Mr. Haddad is cc'd or whatever on
+this string. And what does Mr. Haddad do with
+respect to Mr. Adler after receiving this?
+A He forwards to Russ Adler an email that says:
+Russ, I thought Sheer filed for that discovery of
+Stettins stuff from RRA. You better reread in case you
+have to assert privilege. Your name was mentioned.
+This says to me Mr. Haddad is telling
+to protect the privilege of the victims of
+the Epstein girls if need be, discussing privilege.
+Adler responds back to Mr. Haddad
+with the message: Pedophile Jeffrey Epstein is
+trying to capitalize on the Rothstein situation by
+filing lawsuits and making baseless claims in the
+bankruptcy case that the lawsuits filed against him
+by Brad Edwards on behalf of the young girls Epstein
+molested were cooked up and fabricated as part of
+Rothstein's Ponzi scheme. This claim is ridiculous
+and Epstein has settled most of the molestation
+• cases with Brad
+Most of what Epstein and others are asking
+for is privileged, and Brad and Seth Lehrman, my
+current partner, are already fighting the disclosure
+of the materials sought in the notice.
+The only reason that I have this
+
+
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+information is because Russ forwarded it to me
+saying do I need to assert a privilege since my name
+was mentioned? And we told him back, no, we are
+protecting the same information. You are protecting
+privileged information relating to the girls, we are
+already protecting privileged information related to
+our communications and the girls, you don't have to
+additionally protect that same privileged
+information. So we took care of it, so that's the
+only reason I even have this email.
+I don't know
+what other emails exist.
+Exactly. And the import of that is that
+privilege that he's asserting and Mr. Haddad asked
+him to assert, are these consistent with the
+privileges you have asserted in this case with
+respect to specific questions that Mr. Epstein's
+lawyer has asked you?
+A
+Y Like I said, if my privilege is asserted
+here, the only thing that Mr. Haddad would have to do
+is ask his client,
+Adler, who would be able to
+tell him all of the privileged communications, so long
+as
+remembers those things.
+Q
+Would that give Mr. Epstein a tactical
+advantage in his defense of the case that you have
+brought against him for abuse of process and
+
+
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+malicious prosecution?
+MR. GOLDBERGER: Argumentative, Your
+Honor.
+THE COURT: It is argumentative,
+Counselor.
+MR.
+|: Your Honor, may I go ahead
+and mark this, please?
+THE COURT: Exhibit Number 1.
+Any objection, Counsel?
+MR. HADDAD: If I can cross-examine on
+it.
+THE COURT: I will allow that.
+(Plaintiff's Exhibit Number 1 was marked
+for identifícation.)
+THE COURT. Are you finished, Counsel?
+BY MR.
+Sir, Mr. Adler was also deposed in this
+case pending before the court, correct?
+A
+That's correct.
+Did Mr. Adler on many occasions in that
+deposition invoke a work product privilege?
+A His deposition has been filed. And
+basically, at the beginning of the deposition he said I
+am going to invoke privilege on all communications and
+everything else. So it was basically a standing
+
+
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+objection, and additionally, throughout the deposition
+he invoked privilege.
+MR. I
+: Thank you very much, Judge.
+THE COURT: Mr. Haddad, limited to the
+document.
+MR. HADDAD: Yes, sir, limited to the
+document.
+May I approach the witness?
+RE-CROSS EXAMINATION
+BY MR. HADDAD:
+• This email has a string of emails that
+begins with from Russell Adler to Katie Adler;
+Slatkin, who is the bankruptcy lawyer, Fred Haddad?
+A
+Okay.
+"What is this?"
+Dated October 13th,
+2010 --
+A
+correct.
+-- at 10:46, correct?
+Yeah.
+And that's the whole pedophile stuff,
+Epstein?
+A Right.
+& Most of what Epstein is asking for is
+privileged. Brad and Seth Lehrman -- Brad, that's
+you -- are fighting the disclosures of the materials
+
+
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+sought, right?
+A Right.
+• The sentence you left off is Russ Adler
+saying I am not involved in that battle?
+A
+He wasn't.
+& Okay, you didn't tell that to the Judge.
+A I think there's even a back page,
+if you
+wanted to read the last one.
+• There is a response, as opposed to being in
+that, is from me on October 14th, the next day.
+So
+the sequence you have is in error, correct?
+A
+okay.
+Correct?
+A
+Yes.
+And my response was: Russ, I thought Sheer
+filed for the discovery of Stettins stuff from RRA.
+You better receive (sic) that in case you have to
+assert a privilege, correct?
+That appears to be correct.
+You don't know whether I was discussing
+with him the Fifth Amendment privilege or
+attorney-client privilege?
+A I have no idea what your discussions would
+be.
+What kind of law do I practice?
+
+
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+A
+What kind of law are we practicing in this
+case?
+It's pretty close to criminal.
+You know that. --
+THE COURT: We are in civil court,
+right?
+MR. HADDAD: I am trying to be, Judge.
+THE WIINESS: He forgot for a second.
+BY MR. HADDAD:
+You don't know what privilege I was talking
+about, correct, Mr.
+No, I have no idea.
+• And there was another response to that
+later that day. Brad said do I need to assert
+privilege since my name was mentioned? His response
+was: I don't think so, since my only communications
+were within the firm. He puts work product, and all
+of that was already being asserted by you guys?
+Correct.
+I have never had any communication with any
+Epstein clients?
+A That's true.
+• Now --
+MR. HADDAD: Okay, I will let it go,
+Judge. I said I would only go that far,
+
+
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+sorry.
+THE COURT: You can step down, sir.
+•Thank you for your time.
+-
+(The requested portion of proceedings were
+concluded at 2:23 p.m.)
+TOT A CERTIFIED COP
+
+
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+COURT CERTIFICATE
+STATE OF FLORIDA
+COUNTY OF PAIN BEACH; 8S
+I, SONJA D. I
+certify that I was
+authorized to and did stenographically report the
+foregoing proceedings and that the transcript is a
+true record of my stenographic notes.
+Dated this 29th day of October, 2012.
+NOT A
+Listall
+SONJA D.
\ No newline at end of file
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new file mode 100644
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diff --git a/vision-fixhub/court-02/0c7b74313f5c48442fb5fb59fcf6efb3d8368475dc1e1414388c3467e0301b1c.md b/vision-fixhub/court-02/0c7b74313f5c48442fb5fb59fcf6efb3d8368475dc1e1414388c3467e0301b1c.md
new file mode 100644
index 0000000000000000000000000000000000000000..872bc392b8f00595ef59542ca4b0aeee570e5adc
--- /dev/null
+++ b/vision-fixhub/court-02/0c7b74313f5c48442fb5fb59fcf6efb3d8368475dc1e1414388c3467e0301b1c.md
@@ -0,0 +1,266 @@
+Filing # 69276098 E-Filed 03/14/2018 04:11:32 PM
+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+Case No. 50-2009CA040800XXXXMBAG
+Plaintiff,
+v.
+JEFFREY EPSTEIN
+Defendant,
+L.M., E. W., and JANE DOE,
+Intervenors.
+COPY
+COUNTER DESIGNATIONS AND OBJECTIONS TO
+EPSTEIN'S DEPOSITION DESIGNATIONS FOR WILLIAM BERGER'S
+FEBRUARY 23, 2018, DEPOSITION TRANSCRIPT
+Plaintiff/Counter-Defendant Jeffrey Epstein ("Plaintiff") hereby designates the following
+testimony from William Berger's February 23, 2018, deposition transcript for use in the instant
+case and/or as rebuttal:
+Designation
+5:9-6:1
+9:8-17
+10:17-22
+15:2-16:9
+16:25
+17:2-12
+18:8-11
+18:16-20
+55:10-13
+55:17-56:1
+56:7-58:12
+58:14-59:16
+Completeness/Counter /
+Cross Designation
+Objections
+Response to
+Objections
+56:7-25 Compound
+58:6-59:25 Hearsay/
+2nd hand knowledge/
+Relevancy
+59:19-60:13
+FILED: PALM BEACH COUNTY, FL, SHARON R. BOCK, CLERK, 03/14/2018 04:11:32 PM
+
+
+60:16
+60:18-61:19
+62:12-13
+Designation
+62:15
+62:17-63:18
+63:25-64:5
+65:4-6
+65:13-20
+66:13-19
+66:24-25
+67:23-24
+68:9-11
+69:23-25
+70:3-25
+71:13-72:13
+72:21-75:3
+75:8-16
+75:19-76:1
+76:11-15
+77:11-14
+77:17
+77:21-78:5
+78:10-79:6
+79:22-80:7
+80:16-20
+81:3-20
+81:25-82:13
+82:16-84:2
+84:5
+84:19-87:11
+87:14-88:4
+88:7-89:5
+89:17-91:3
+91:13-92:6
+92:14-97:10
+60:14-15
+60:17
+Completeness/Counter /
+Cross Designation
+65:7-12 if overruled
+71:1-12 if overruled
+72:14-20 if overruled
+78:6-9 if overruled
+60:23-61:7; 61:17-
+19
+Rel./Repetitious
+Objections
+Rel./Repetitious
+Rel.
+Rel.
+Rel.
+Rel.
+Rel.
+Rel.
+Rel.
+Rel.
+Rel. /SHK
+Rel./SHK
+Rel.
+Rel.
+Rel.
+Rel.
+Rel.
+Rel./No predicate
+Rel.
+Rel.
+Rel.
+Rel./Derived from
+Priv. Docs.
+Response to
+Objections
+82:11-17 Rel./Hearsay
+SHK/Speculation
+82:20-84:22 Legal
+Concl./Rel.
+Rel.
+Rel.
+Rel.
+Rel. up to 90:20
+
+
+97:16-100:2
+100:5
+100:18-104:13
+107:9-24
+108:2-14
+108:16-23
+110:14-111:2
+111:4-9
+111:11-112:9
+112:12-19
+112:24-114:13
+114:17-117:7
+117:12-120:17
+120:21-122:4
+122:16-21
+Designation
+123:10-124:1
+125:1-4
+125:7-12
+125:15-126:18
+126:21-127:1
+127:5-9
+127:14-129:22
+130:6-23
+138:11-139:9
+139:17-140:7
+141:06-24
+144:5-8
+144:18-145:2
+146:15-147:5
+148:24-149:5
+150:17-24
+151:4-13
+152:1-153:25
+154:2-11
+154:23-156:2
+104:14-105:18
+Completeness/Counter /
+Cross Designation
+124:10-25
+147:9-148:23
+150:5-15
+|151:1-3
+156:9-14
+99:25-100:5 Rel.
+Rel.
+Rel.
+112:6-9 Rel./Opinion/
+Compound
+112:17-113:13 Rel./
+Opinion/Speculation
+113:18-116:1 Hearsay
+SHK/Predicate
+116:7-23 Rel.
+Objections
+1117:4-7 Rel./Assumes
+Facts not in evid.
+117:12-118:2 Rel
+118:18-119:24 Rel.
+120:15-122:4 Rel.
+Response to
+Objections
+No predicate
+Hearsay/SHK
+155:4-17 Privileged
+
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all
+Counsel on the attached list, this
+day of
+Manch 2018.
+Dul Clank
+JACK SCAROLA
+Florida Bár No.: 169440
+Attórney E-Mail(s): jsx(@searcylaw.com; and
+minecann@searcylaw.com
+Primary E-Mail:_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley, P.A.
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, Florida 33409
+Phone: (561) 686-6300
+Fax:
+561-383-9451
+Attorneys for Bradley J. Edwards
+CERTIFIED
+NOT A CERTIFIED
+
+
+COUNSEL LIST
+Esquire
+statf.efile@pathtojustice.com
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.com
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+Nichole J. Segal, Esquire
+ys(@FLAppellateLaw.com; kbt(@)FLAppellateLav
+Burlington & Rockenbach, P.A
+444 W Railroad Avenue, Suite 350
+West Palm Beach, FL 33401
+Phone: (561)-721-0400
+Attorneys for
+RTIFIED COPY
+Berard Rockenbach, Esquire
+kara@linkrocklaw.com; tbermudez@flacivillaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Blvd., Suite 301
+West Palm Beach, FL 33409
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+Scott J. Link, Esquire
+Scott@linkrocklaw.com; Tina@linkrocklaw.com
+Scott J. Link, Esquire
+Eservice@linkrocklaw.com; Scott@linkrocklaw.com; Kara@linkrocklaw.com;
+Angela@linkrocklaw.com; Tanya@linkrocklaw.com; tina@linkrocklaw.com
+Link & Rockenbach, P.A.
+1555 Palm Beach Lakes Boulevard, Suite 301
+West Palm Beach, FL 33401
+Phone: (561)-727-3600
+Fax: (561)-727-3601
+Attorneys for Jeffrey Epstein
+
+
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+NOT A CERTIFIED COPY
diff --git a/vision-fixhub/court-02/0c7b74313f5c48442fb5fb59fcf6efb3d8368475dc1e1414388c3467e0301b1c.receipt.json b/vision-fixhub/court-02/0c7b74313f5c48442fb5fb59fcf6efb3d8368475dc1e1414388c3467e0301b1c.receipt.json
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@@ -0,0 +1,14 @@
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+  "page_markers": false,
+  "source_id": "epstein-external",
+  "text_format": "markdown"
+}
diff --git a/vision-fixhub/court-02/0cc17d7bdbb195db5258dbb416b7e30453777d647e07a1553e49fb217594aa5a.md b/vision-fixhub/court-02/0cc17d7bdbb195db5258dbb416b7e30453777d647e07a1553e49fb217594aa5a.md
new file mode 100644
index 0000000000000000000000000000000000000000..56dd698cc7d709ac00ecf10e257bbb65d13e3a27
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@@ -0,0 +1,805 @@
+Case 9:08-Cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 1 of
+
+36
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 2 of
+SUPREME COURT
+NEW YORK COUNTY
+TRIAL TERM
+PART 66
+THE PEOPLE OF THE STATE OF NEW YORK #097XT*
+AGAINST
+JEFFREY EPSTEIN
+page 1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+Defendant.
+-x SORA HEARING
+111 Centre Street
+New York, New York 10013
+January 18, 2011
+BEFORE:
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24|
+25
+HONORABLE RUTH PICKHOLZ
+Justice of the Supreme Court
+APPEARANCES:
+For the People:
+For the Defense:
+CYRUS R. VANCE, JR., ESQ.
+New York County District Attorney
+Atlant District Attorney
+KIRKLAND & ELLI, LLP
+153 East 53rd Street
+SANDRA MUSUMECI, ESQ.
+Senior Courl Reporter
+
+
+- -
+Entered on FLSD Docket 02/10/2016 Page 3 of
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 2
+COURT CLERK: This is number two on the calendar,
+matter of Jeffrey Epstein.
+Your appearances please.
+MS. GAFFNEY: Jennifer Gaffney for the People.
+Good afternoon, Your Honor.
+MR. LEFKOWITZ: Jay Lefkowitz and Sandra Musumeci
+for Mr. Epstein.
+THE COURT: Mr. Epstein is not here.
+MR. LEFKOWITZ: That's correct.
+THE COURT: Are you waiving his appearance?
+MR. LEKWOWITZ: Yes.
+MS. GAFFNEY: Your Honor, this case is on for a
+SORA hearing this afternoon.
+The People did receive the board's recommendation
+of a Level Three. However, we received the underlying
+information from them and also had some contact with
+Florida, and we don't believe that we can rely on the entire
+probable cause affidavit.
+I don't know if the board sent that to you as
+well.
+THE COURT: I don't know why you cannot rely on
+it.
+MS. GAFFNEY: Because in Florida of all of the
+victims in that probable cause affidavit, they actually only
+went forward on one case. There was only an indictment for
+
+
+Entered on FLSD Docket 02/10/2016 Page 4 of
+page 3
+one victim and that is what the defendant plead to.
+So it is unlike a situation where everything was
+indicted and then we get to sort of assess points for all of
+the victims, if it was part of a plea bargain. They did not
+actually choose to go forward on any except for the one
+victim.
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+!
+22
+23
+24
+25
+So under the board guidelines, the risk assessment
+interim guidelines, it actually says, you know, by way of
+contrast if an offender is not indicted for an offense, it
+is strong evidence that the offense did not occur and I
+don't think-.
+THE COURT: Do you find that if somebody is not
+indicted it is strong evidence that it did not occur?
+MS. GAFFNEY: I don't know that we can rely on it
+as clear and convincing evidence if the prosecutor's office
+never went forward on it. The prosecution said that the
+victims, although they spoke to the police early on, did not
+cooperate with them. So we don't have any follow up
+information.
+THE COURT: But the board found a Level Three.
+I have to tell you, I am a little overwhelmed
+because I have never seen the prosecutor's office do
+anything like this. I have never seen it. I had a case
+with one instance it was a marine who went to a bar, and I
+wish I had the case before me, but he went to a bar and a 17
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 5 of
+16
+2
+3
+4
+5
+6
+7
+8
+9
+10
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 4
+year old, he was an adult obviously, he was a Marine, a 17
+year old came up to him and one thing lead to another and he
+had sex with her and the People would not agree to a
+downward modification on that.
+So I am a little overwhelmed here because I see --
+I mean I read everything here, I am just a little
+overwhelmed that the People are making this application.
+I could cite many many, I have done many SORAs
+much less troubling than this one where the People would
+never make a downward argument like this.
+MS. GAFFNEY: I agree with Your Honor, it is
+incredibly unusual for us to make a downward argument. But
+the problem is the one thing that we have from the board is
+it seems to be in contradiction to their own guidelines
+which if something was not indicted, you are not supposed to
+rely on it.
+THE COURT: They obviously took that into
+consideration.
+MS. GAFFNEY: And I tried to reach -- I reached
+the authorities in Florida to try to see if they had all the
+interview notes or other things that we can then
+subsequently rely on that might be considered clear and
+convincing evidence, if they had interviewed these women on
+their own, and they never did. No one was cooperative and
+they did not go forward on any of the cases and none of them
+
+
+Entered on FLSD Docket 02/10/2016 Page 6 of
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+16
+page 5
+were indicted. So I don't know.
+THE COURT: And you spoke to the prosecutor?
+MS. GAFFNEY: The actual prosecutor left the
+office. I spoke to the prosecutor that took over the case.
+THE COURT: Maybe you can find the prosecutor that
+left the office.
+You have done more in other cases looking into it.
+I have never seen the prosecutor's office do this. I have
+to tell you, I am shocked.
+MS. GAFFNEY: Right, but I spoke to the prosecutor
+that took over the case and they don't have anything, any
+affidavits, any statements, any notes.
+THE COURT: Why don't you speak to the prosecutor
+that did do the case, I am sure you could find that
+prosecutor.
+MS. GAFFNEY: I can find her, but based upon what
+the other prosecutor said, they did not speak to that
+prosecutor either.
+THE COURT: You did not speak to the prosecutor
+yourself, you did not speak to them, that is hearsay. You
+did not speak to the prosecutor that handled the case.
+MS. GAFFNEY: That's right.
+THE COURT: I don't think you did much of an
+investigation here.
+MS. GAFFNEY: I mean I called the prosecutor.
+Senior Cour Reporter
+
+
+.....
+Entered on FLSD Docket 02/10/2016 Page 7 of
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 6
+Even though the first prosecutor left, presumably the
+prosecutor's office has the file.
+THE COURT: I would still call the prosecutor.
+MS. GAFFNEY: Anything from these women they would
+have forwarded it to us.
+THE COURT: I don't know that, I think you have to
+speak to the prosecutor.
+But be that as it may, I hear your argument.
+Anything else?
+MS. GAFFNEY: I mean that is why I don't think we
+can, I don't think we are entitled to rely on this because
+they did not go forward.
+THE COURT: The board made a recommendation.
+MS. GAFNEY: Correct.
+I speak, Your Honor?
+THE COURT: Yes.
+MS. MUSUMECI: Good afternoon.
+I would like to bring a few additional points to
+Your Honor's attention that don't come across in the board
+recommendation.
+The first is that Mr. Epstein is not a resident of
+New York, unlike most of these out of state, he has not
+changed his address and moved to New York, he maintains a
+vacation home in New York. His primary residence is the
+U.S. Virgin Islands.
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 8 of
+16
+page 7
+2
+3
+4
+5
+6
+7
+8
+9
+10
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+He is registered in the U.S. Virgin Islands, he
+has been since his release from jail. He notifies the
+Virgin Island authorities every time he leaves that
+jurisdiction. Virgin Island authorities rated him at the
+lowest level of registration.
+He also registered in Florida, which is the state
+of this particular offense, and the only reason that this
+conviction is even before Your Honor.
+The offense for which he was convicted is not a
+registrable offense in New York. He is only registrable
+here arguably because based on the provision of SORA that
+says if a crime is registrable in the state of conviction,
+then it is registrable here in New York. And the Florida
+authorities that considered that rated him at the lowest
+level of their SORA statute.
+He additionally has a vacation home in New Mexico
+and is registered in New Mexico. The New Mexican
+authorities when they considered his offenses, determined he
+need not register at all. Nevertheless, he has voluntarily
+registered with New Mexico and maintains that registration.
+Additionally, because of his possession of a
+vacation home in New York, he has been voluntarily
+registered with New York SOMU, the Sex Offender Monitoring
+Unit since May of this year. He notifies them whenever he
+comes to travel to New York. He never comes to New York for
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 9 of
+16
+2
+3
+4
+5
+6
+7
+8
+9
+10
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 8
+more than seven days or at least he has not since he has
+been registered. He has no intention to ever be here for
+Tonger than a period of ten days.
+Like I said, he does notify the authorities when
+he is here. He fully understands the reason for voluntary
+registration, he wants to be compliant with the Federal SORA
+law which requires wherever you own a property to register.
+To require Mr. Epstein to register as a Level
+Three offender in New York would actually require him to
+come to New York more than he does normally, it would
+require him to come every 90 days and renew his
+registration.
+He is very diligent in registering with New York
+authorities.
+All of the other jurisdictions that have
+considered his case have determined that he either not
+register at all or register at the Towest level, and he has
+been more than compliant with all of those requirements.
+Your Honor, we would join in the prosecutor's
+application.
+THE COURT: I am sure you would.
+MS. MUSUMECI: By way of background, we have been
+in contact with the prosecutor's office on this matter since
+I believe certainly since Mr. Epstein got his notification,
+which I believe was in August. We have met with the
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 10 of
+16
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 9
+prosecutor and provided numerous materials for the
+prosecutor to consider. We have included in that a
+deposition from the detective who headed this investigation
+who acknowledged in a sworn deposition that the lead
+prosecutor who originally had the case, whose name I cannot
+pronounce, Lanna Belohlavek, I apologize for the
+mispronunciation, said to the detective after her
+investigation, there are no real victims here.
+All of the alleged conduct that is cited in the
+board's write up was commercial conduct. All of the alleged
+conduct the women went voluntarily, there are no allegations
+of force certainly none.
+THE COURT: There was no allegation of force in
+the marine either, who met a girl in a bar, a young girl 17,
+there was no force there.
+MS. MUSUMECI: It is our understanding that the
+prosecutor in Florida conducted a full investigation, as
+full as she was able with the cooperation afforded by these
+complainants, and determined that the only case that she
+could present to the grand jury was this indictment for a
+non registrable offense then --
+THE COURT: But it is registrable here.
+I don't know what you mean non registrable
+offense.
+MS. MUSUMECI: Let me explain, Your Honor.
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 11 of
+page 10
+Mr. Epstein plead to two charges, one was an
+indictment which is an offense that is not registrable, it
+is a Florida indictment for -.
+THE COURT: Then why does he have to register
+here?
+MS. MUSUMECI: It was a second offense that he
+!
+1
+2
+3
+4
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+8
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+11
+12
+13
+14
+15
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+18
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+22
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+plead to --
+THE COURT: That is registrable.
+MS. MUSUMECI: That is registrable.
+That offense was by information and that is the
+only registrable offense, that is what the DA's office is
+considering in doing their scoring.
+The indictment which was the only case that the
+prosecutor even prosecuted through grand jury is not even a
+registrable offense.
+THE COURT: He plead guilty to a registrable
+offense.
+MS. MUSUMECI: Yes.
+THE COURT: What did he plead guilty to?
+MS. GAFFNEY: He plead guilty to the procuring a
+person under 18 for prostitution.
+THE COURT: Procuring a person under 18 for
+prostitution.
+MS. GAFFNEY: Right.
+THE COURT: How old was she?
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 12 of
+16
+1
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 11
+MS. GAFFNEY: It appears the first time they met
+she was either 16 or 17, then for the remainder of their
+relationship she was probably 17.
+THE COURT: How long was their relationship?
+MS. GAFFNEY: She met, she gave him approximately
+15 massages, including with sexual contact, and ultimately
+when she is 17 had intercourse with him.
+THE COURT: She is a child.
+MS. MUSUMECI: Your Honor, I would note that under
+SORA it is clear that prostitution offenses are only
+registrable when in fact by clear and convincing evidence
+the women or victim is 17, is under 17.
+THE COURT: Well, she met him at 16, he procured
+her at 16 from what I read.
+MS. MUSUMECI: There is evidence we challenged.
+THE COURT: He plead guilty to that, didn't he?
+MS. MUSUMECI: He plead guilty to under 18, which
+is the law in Florida, which is a different standard than
+what the law is in New York. And there is no evidence,
+there is no clear and convincing evidence as to her specific
+age at the time of the specific conduct.
+THE COURT: Well, the DA just told me she was most
+Tikely 17, she just said it on the record.
+MS. MUSUMECI: Your Honor, we agree that the
+evidence is that she was 17 on the one occasion she had
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 13 of
+16
+2
+3
+4
+5
+6
+7
+8
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+page 12
+consensual intercourse with him and 17 is not registrable or
+criminal under New York law.
+And the prostitution aspect of having intercourse
+with a 17 year old is not registrable conduct.
+THE COURT: Why does he have to register here?
+MS. GAFFNEY: Because it is a register able
+offense in Florida, New York State board of examiners --
+THE COURT: Recognizes it.
+MS. GAFFNEY: Recognizes it, yes.
+THE COURT: I have had many cases like that where
+it was not registrable here but it was in the state where
+the person came from and New York recognized that.
+MS. MUSUMECI: Your Honor, we are not saying that
+he should not register. Mr. Epstein has already registered
+and recognizes his duty to register.
+THE COURT: I am glad of that, very glad of that.
+I am sorry he may have to come here every 90 days.
+He can give up his New York home if he does not
+want to come every 90 days.
+Anything else?
+I rely on the board.
+MS. MUSUMECI: Your Honor, we would reserve our
+right to appeal Your Honor's ruling.
+THE COURT: Of course, do so.
+MS. GAFFNEY: For the record, Your Honor, he is
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 14 of
+2
+3
+4
+5
+6
+7
+8
+9
+10
+page 13
+going to be deemed a Level Three sex offender with no
+designation, correct?
+THE COURT: Correct.
+MS. MUSUMECI: For purposes of the appeal I
+believe that Your Honor --
+THE COURT: Give me the board's scoring.
+The board has scored use of violence the least,
+10.
+!
+Sexual contact with victim, 25. I agree.
+Number of victims, three or more. He only plead
+guilty to one, but apparently there were more than one and I
+think the People concede that although they say it was not
+reliable.
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+Duration of offense, conduct with victim,
+continuing course of sexual misconduct, the People have told
+me it was continuing for 20 points.
+Age of victim 11 through 16, he got 20 points for
+that, and she was 16 at the time.
+Other victim characteristics, there was no mental
+disable or helplessness. I agree.
+Relationship with victim stranger, 20 points.
+Age at first act of sexual misconduct, 20 or less.
+They scored him zero on that.
+Number and nature of prior crimes, no history,
+they scored him five on that.
+
+
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 15 of
+16
+2
+3
+4
+5
+6
+page 14
+Recency of prior offense less than three years,
+they gave him zero.
+Drug or alcohol abuse history, they gave him zero.
+Acceptance of responsibility, they gave him zero.
+Conduct while confined, they gave him zero.
+And supervision, they gave him zero.
+Living employment situation, zero.
+They gave him 130 points, which is the highest
+level, and I agree with that.
+MR. LEFKOWITZ: If I could be heard for one
+moment.
+(
+:
+8
+9
+10
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+It appears that the state board made its
+determination based on access to a police report in Florida.
+The prosecutor, the lead prosecutor, the lead sex
+crimes prosecutor in Palm Beach made a determination that
+the complainants and the police report itself was not
+credible and decided not to prosecute on the basis of all of
+that.
+In addition, there has been through the course of
+the last few years some civil litigation, as you might
+imagine, involving these matters and we now have sworn
+testimony in evidence from the complainants themselves
+disclaiming much of what appears in the police report.
+So, Your Honor, we would submit and this is not to
+make light in any way of the conduct what Mr. Epstein did or
+
+
+il
+•
+Case 9:08-cv-80736-KAM Document 361-36 Entered on FLSD Docket 02/10/2016 Page 16 of
+16
+page 15
+2
+3
+4
+5
+6
+7
+8
+9
+10
+11
+12
+13
+14
+15
+16
+17
+18
+19
+20
+21
+22
+23
+24
+25
+what Mr. Epstein plead guilty to, but with respect to
+everything and that is why Mr. Epstein voluntarily
+registered in New York even though there is a question about
+whether he has any obligation just as a jurisdictional
+matter, but Your Honor, with respect to the appropriate
+level for him to register, we would submit Your Honor that
+the evidence simply does not support the foundation of the
+state's determination.
+THE COURT: You have made a very clear record and
+you have your right to appeal.
+I feel the board looked into all of this, made
+their recommendation, found him to have 130 points and I see
+no reason to disturb that.
+Thank you.
+I, Vikki J. Benkel, a Senior Court Reporter in and for
+the State of New York, do hereby certify that the foregoing
+transcript is true and accurate to the best of my knowledge,
+skill and ability.
\ No newline at end of file
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diff --git a/vision-fixhub/court-02/0d1ac97ada2377e4971b6143dd69690e64153e81b06984beb748e550c9c6eb74.md b/vision-fixhub/court-02/0d1ac97ada2377e4971b6143dd69690e64153e81b06984beb748e550c9c6eb74.md
new file mode 100644
index 0000000000000000000000000000000000000000..00e672f36d0bf45050773ea4e6008ec006be7120
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+IN THE CIRCUIT COURT OF THE
+FIFTEENTH JUDICIAL CIRCUIT, IN AND
+FOR PALM BEACH COUNTY, FLORIDA
+CASE NO.: 502009CA040800XXXXMBAG
+JEFFREY EPSTEIN,
+Plaintiff(s),
+VS.
+SCOTT ROTHSTEIN, individually,
+individually, and
+L.M., individually,
+Defendants).
+ORDER ON MOTION TO COMPEL ATTENDANCE IAT MEDIATIONI
+THIS CAUSE having come to be considered upon the MOTION TO COMPEL
+ATTENDANCE [at mediation], and the Court having reviewed the file and being fully advised
+in the premises, it is hereby,
+ORDERED and ADJUDED: Than the mediation ockeduled
+dayor fely 2015.
+ARON
+DONALD
+HATELE
+CIRCUIT JUDGE
+Copies have been furnished to all counsel on the attached counsel list.
+CLERK
+2015 JUL 2I
+AMII: 30
+ILE
+L..
+
+
+adv. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Order on Motion to Compel Attendance [at mediation]
+COUNSEL LIST
+Jack Scarola, Esquire
+_scarolateam@searcylaw.com
+Searcy Denney Scarola Barnhart & Shipley PA
+2139 Palm Beach Lakes Boulevard
+West Palm Beach, FL 33409
+Phone: (561) 686-6300
+Fax: (561) 383-9451
+Attorneys for
+J.
+William Chester
+, Esquire
+wcblaw@aol.com; wcblawasst@aol.com
+250 S Australian Avenue, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561) 655-4777
+Fax: (561) 835-8691
+Attorneys for Jeffrey Epstein
+IRTIFIED COPY
+Jack A. Goldberger, Esquire
+jgoldberger@agwpa.com; smahoney@agwpa.
+Atterbury Goldberger & Weiss, P.A.
+250 Australian Avenue S, Suite 1400
+West Palm Beach, FL 33401
+Phone: (561)-659-8300
+Fax: (561)-835-8691
+Attorneys for Jeffrey Epstein
+J.
+, Esquire
+staff.efile@pathtojustice.com
+Jaffe Weissing L
+425 N Andrews Avenue, Suite 2
+Fort Lauderdale, FL 33301
+Phone: (954)-524-2820
+Fax: (954)-524-2822
+Fistos & Lehrman, P.L.
+Fred Haddad, Esquire
+)ee@FredHaddadLaw.com; Fred@FredHaddadLaw.con
+red Haddad, P.A
+2
+
+
+Lady. Epstein
+Case No.: 502009CA040800XXXXMBAG
+Order on Motion to Compel Attendance [at mediation]
+One Financial Plaza, Suite 2612
+Fort Lauderdale, FL 33394
+Phone: (954)-467-6767
+Fax: (954)-467-3599
+Attorneys for Jeffrey Epstein
+Tonja Haddad Coleman, Esquire
+tonja@tonjahaddad.com; efiling@tonjahaddad.com
+Tonja Haddad, P.A.
+315 SE 7th Street, Suite 301
+Fort Lauderdale, FL 33301
+Phone: (954)-467-1223
+Fax: (954)-337-3716
+Attorneys for Jeffrey Epstein
+Marc S. Nurik, Esquire
+marc@nuriklaw.com
+One E Broward Blvd., Suite 700
+Fort Lauderdale, FL 33301
+Phone: (954)-745-5849
+Fax: (954)-745-3556
+Attorneys for Scott Rothstein
+CERTIFIED COPY
+NOT
+3
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